ML20203F851

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Insp Rept 70-1151/98-02 on 980126-30.Violations Noted. Major Areas Inspected:Licensee Programs for Operational Safety & Maint of Safety Contols
ML20203F851
Person / Time
Site: Westinghouse
Issue date: 02/20/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203F837 List:
References
70-1151-98-02, 70-1151-98-2, NUDOCS 9803020067
Download: ML20203F851 (16)


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U. S. NUCLEAR REGULATORY COMMISSION j REGION !! i l

Docket No.: 70 1151 l License No.: SNH 1107 l I

Report No.: 70 1151/98 02 l Licensee: Westinghouse Electric Corporation Facility: Comercial Nuclear Fuel Division i Columbia. SC 29250 -l Inspection Conducted: January 26 30, 1998 j Inspectors: D. Ayres, Senior fuel Facility Inspector I D. Seymour Senior Fuel Facility inspector Approved by: E. McAlpine, Chief Fuel Facilities Branch .

Division of Nuclear Materials Safety l

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EXECUTIVE

SUMMARY

Commercial Nuclear fuel Division NRC Inspection Report 70 1151/98 02 The primary focus of this inspection was the observa. ion and evaluation of the licensee's programs for operational safety and maintenance of safety controls.

The report includes ins)ection efforts of two regional inspectors. The inspection identified tie following aspects of the licensee programs as outlined below:

Safety Doerations e Operations in Uranium Recycling and Recovery Services Area were performed within the safety margiis identified in operating procedures (Section 2.a),

e Process controls identified in the Criticality Safety Evaluation (CSE) were in place and implemented. However, many of the controls listed in the CSE were not identified as " safety significant" in the procedure for safety significant interlocks. Inconsistencies between the controls mentioned in the CSE and licensee procedures will be addressed by the licensee upon the completion of the ISA (Section 2.b).

Facility Suocort e The designation of safety significant programmed / preventive maintenance (PM)in the licensee's Maintenance Planning and Control System (MAPCON) was inconsistently a) plied to items that have been identified as safety significant through icensee Procedure RA 108. " Safety Significant Interlocks and Passive Controls." Other safety-related items required by the License Application to have PMs did not have a unique identifier in MAPCON 'o prevent unauthorized or inadvertent removal from the PM system. An inspector follow up item was opened to track the licensee's implementation of a consistent system to identify and control PMs on items important to safety, e The review of the maintenance work control system revealed several instances of failure to follow work control requirements. Collectively, these non compliances are cited as Violation 70 1151/98 02-02.

Mlachment:

Persons Contacted and Exit Interview List of Items Opened, Closed, and Discussed List of Acronyms

REPORT DETAILS

1. Summary of Plant Status This report covered a one week period. Special activities during the week included the replacement of the powder production line #3 off-gas
filter and scrubbing system. There were no unusual plant operational occurrences during the onsite inspection. Two NMSS license reviewers were on site during the week to perform reviews of Integrated Safety Analysis (ISA) documentation.
2. Plant Doerations (88020) (03)
a. Conduct of Ooerations (03.01)

(1) Inspection Scope The operation of the Safe Geometry Dissolver (SGD) and Solvent Extraction (Sx) systems were reviewed for verification of adherence to safety requirements.

4 (2) Observations and Findings The inspectors toured the Uranium Recycling and Decovery Services (URRS) Area with the Process Engineer to obtain a thorough understanding of its operation and safety systems.

The Inspectors observed various safety significant engineered controls in the safe geometry dissolver area and found them to be functional. The inspectors also observed various safety significant operating parameters through process instrumentation and operator logs. The inspectors found that operations in URRS were being performed within the margins identified in operating procedures and safety analyses.

(3) Conclusions Operations in the URRS were being performed within the safety margins identified in operating procedures,

b. Imolementation of Process Safety Controls (03.03)

(1) Inspection Scope The implementation of process controls in the URRS Area was reviewed to verify that administrative and engineered controls identified in area safety analyses were properly utilized.

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(2) Observations and Findings ,

The inspectors reviewed the Criticality Safety Evaluation I (CSE) of the SGD system. The inspectors observed that the  !

i CSE described forty three (43) potential initiating events that could challenge system safety. The inspectors also  ;

found that defense elements (controls) to prevent the 1 occurrence of or protect the system from the initiating

! events were discussed in the CSE. The inspectors found that i the defense elements discussed in the CSE were in place in the SGD system. However, the inspectors found that although  ;

these defense elements were in place, most of them were not

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i listed in the licensee's procedure RA 108, " Safety '

Significant Interlocks and Passive Controls. The inspectors found that the controls listed in RA 108 were considered

" safety significant" and had established preventive maintenance (PM) and testing requirements placed on them (See Section 3). The inspectors were informed by the licensee that the controls mentioned in the CSE but not listed in RA 108 were not considered " safety significant."

, and were not required to be routinely functionally tested, t

The inspectors noted that the License Application defined safety related as " Relevant to systems crucial or important to safety; and, those systems that improve the margin of safety (e.g., in the context of maintenance):" and safety significant as " Relevant to systems crucial or important to safety (e.g. in the context of quality assurance)."

Licensee Proc ^ dure RA-108. " Safety Significant Interlocks  ;

and Passive Controls." defined safety significant as

" essential to plant safety." The licensee also indicated, during discussions with the inspectors, that safety significant meant necessary to maintain double contingency.

The inspectors noted, during their inspection that safety significant and safety related were used interchangeably by the licensee.

e The inspectors determined that the CSE had not been updated

  • since its original issuance and that the controls on initiating events identified therein were not all presently considered safety significant by the licensee. The inspectors also found inconsistencies cnd typographical errors in the SGD system CSE. This was similar to deficiencies found in previous inspections for the powder production areas. The inspectors discussed this situation with the-licensee and found that the licensee planned to begin updating its CSEs in April 1998 upon completion of the  ;

plant ISA.

The inspectors reviewed the Criticality Safety Analysis (CSA) for the Sx system since a CSE had not been completed for this system. The inspectors found that, unlike the ,

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The Inspectors reviewed the engineered safety controls with the process engineer and found the controls adequately implemented the safety philosophy for the Sx system.

(3) Conclusions Process controls identified in the CSE were in lace and [

implemented. Many of these controls were not identified as  :

safety significant in the procedure for safety significant i interlocks. However, sufficient controls were identified, l maintained, and periodically functionally tested to assure protection against an inadvertent-criticality accident.

Inconsistencies between the controls mentioned in the CSE and licensee procedures will be addressed upon the completion of the ISA. .

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c. Follow uo on Previous 1v Identified issues (03.08)

I (1) Inspection Scope Progress was reviewed on updating the CSEs for the ADU process (IFl 97 03 01 and 97 03 03) and on preventing the inadvertent use of contaminated shoe covers (IFl 97 206 03).

(2) Observations and findings -

The insnector reviewed the status of the two items involving updatins ^f the CSEs for the ADV process. IFl 97 03 01 involved controls listed in the CSE for the dewatering centrifuge that were no longer used due to their inability ,

to perform their intended function. IFI 97 03 03 involved -

the more generic problem of outdated 3rocedural references and typographical errors found througiout the CSE for the ADV process. The inspector found that neither of these items had yet been adoressed. The inspector also found that  :

the licensee had planned to address these inconsistencies (and those in other CSEs) in April 1998 upon completion of the development of the ISA for the facility. Both of these items remained open. ,

The inspector reviewed the licensee's actions taken in response to IFI 97-206 03 concerning a situation where NRC inspectors had been sup) lied with contaminated shoe covers for a facility tour. T1e contamination occurred when black.

rubber shoe covers that had been used to cover contaminated shoes, were left at the entrance to the IFBA and were thought to have been clean shoe covers. The inspector found that the licensee had posted a new sign at the entrance to

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I the IFBA area prohibiting the storage of the black shoe  :

covers at the entrance to t.1e !FBA area. The inspector found that the licensee also planned to modify the plant procedure for shoe cover usage and train the staff on the procedural changes. The inspector will review the adequacy i

and effectiveness of these corrective actions during a l future inspection. This item remained open.

(3) Conclusions I The follow up on the items associated with updating the CSEt for the ADU process (IFIs 97 03 01 and 97 03 03) showed that the issues had not yet been fully addressed but were planned for April 1998 upon completion of the ISA effort.

2 The follow up on the issuance of contaminated shoe covers to NRC inspectors (IFI 97 206 03) showed that changes had been made to the system used for controlling shoe covers, but j that further evaluation of the adequacy of these changes was needed. All items discussed above remained open.

3. Maintenance / Surveillance (88025) (F1)
a. Conduct of Maintenance (F1,01) dort Contro' Procedures (F1.0Ti Wor t Contro' Authorizations (

.03)

(1) Inspection Scope 4 The conduct of maintenance was reviewed to verify that 4 safety related systems and components received the required programmed maintenance. The procedurer. and software for controlling the authorization and performance of maintenance work on systems and components im)ortant to safety were reviewed for effectiveness and adlerence to license requirements.

(2) Observations and findings (a) Proarammed Maintenance Control and Authorizations The inspectors reviewed the use of the licensee's computerized Maintenance Planning and Control (MAPCON) system. This system is used to track programmed maintenance (PM) and initiate work orders (W0s) for PMs. -Section 3.2.1 of the License Application (LA) lists several safety related systems and components that are required to receive programmed maintenance.

The inspector reviewed an index of the PMs included in MAPCON to verify that the syste..s and components -

listed in the LA had PMs included on the index. The inspectors found that all the systems and components -

listed in the LA had PMs in MAPCON except for " pellet

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carts." The inspectors found that the. pellet cart PM had been deleted from MAPCON on January 5. 1998. The  !

inspectors also found that although the licensee's Regulatory Affairs organization was apprised of this i deletion, the licensee had not recognized that the deletion was contrary to regulatory requiremerts.

The inspectors reviewed Maintenance and Calibration .

Procedure-10800. Preventive Maintenance. Revision 4. <

dated August 14., 1997, to determine how a PM could be  !

revised or deleted from MAPCON. The inspectors i determined that PMs could be revised or deleted by the ,

person res of the PM.ponsible for the equipment or by the " owner"Th ,

for any regulatory interfaces or in any way identify that some PMs should not be deleted from MAPCON because they were required by the LA. The ins >ectors also found aa apparent discrepancy involving t u indexing of MAPCON PMs. The inspectors noted that ,

some PMs were coded as "SS." which indicated a safety significant PM: while the rest were coded "PM."

However, the inspectors noted that not all safety significant PMs were coded as "SS." Also, the inspectors found that many of the safety related systems and components listed in the LA as requiring

.PMs were not coded "SS" or with any other special designator. The inspectors pointed this out to the licensee who indicated this would be changed as of the Safety Margin Improvement Program (SMIP).part The inspectors will review the licensee's actions to prevent deletion of required PMs from MAPCON during subsequent inspections. This item will be tracked as Inspector Follow up Item (IFI) 70-1151/98 02-01.

-(b) Pellet Cart Insoection Process The inspectors reviewed the process the licensee used to perform the pellet cart PMs at the time of this inspection, and determined that a pellet operator (the tool crib attendant) was assigned to maintain a computerized spread sheet to track which pellet carts needed to be inspected. Although this program was not a part of MAPCON, the inspectors found that it was an effective method to track the PMs. However, unlike MAPCON, this spread sheet did not generate a work order (W0) to trigger the performance of the PMs'on a set frequency. License Section 3.2.1. Programmed i Maintenance of Safety Related Systems and Components.  ;

requires in part, that maintenanct planning and-control computer programs will be used to initiate work orders for programmed maintenance. The failure to provide a computerized maintenance program that .

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6 l initiated work orders is a violation of work controls (Violation 70 1151/98 02 02).

l The ins)ectors found that with the deletion of the MAPCON >M for pellet carts, the pellet operator was  !

responsible for checking the spread sheet on a regular i basis to determine which pellet carts were to be 1 inspected for damage requiring PM repairs. If a pellet cart did not need repairs, the spread sheet was annotated with the next PM due date, and a sticker was ,

placed on the pellet cart with the date the PM l inspection was performed. If a pellet cart needed repairs, a work order (WO) was prepared by the i operator for maintenance to repair the cart.

(c) MAPCON Instructions ,

The inspectors reviewed the procedures used to perform i the 3ellet cart PMs prior to the PM deletion from '

MAPCON. The inspectors determined that MAPCON had originally been programmed to generate a weekly WO to trigger maintenance to perform the pellet cart PMs.

Maintenance would interface with the pellet operator.  ;

who would reference the spread sheet to determine ,

which specific pellet carts were due for PM. The pellet operator would follow portions of COP 825204. .

" Pellet Tray Carts " to prepare the selected carts for '

the PM (this included locating the carts and cleaning them out, etc.), and would then send the carts to maintenance for the PM. After the PH was completed.

  • maintenance would return the pellet carts to the pellet operator.

(d) Procedural Discrecancies The inspectors observed two discrepancies between the original MAPCON PM instructions for 3ellet carts and the PM instructions in COP 825204 ")ellet Tray Carts." The first discrepancy was that the MAPCON instructions specified that each cart should receive a  :

PM annually. The C0P used by the >ellet operator specified a biennial frequency. T1e inspectors determined that the carts were being inspected or a biennial basis. The inspectors discussed this with i the licensee and who stated that the pellet carts i started out on an annual PM frequency. This was '

extended to a biennial frequency after the licensee determined, based on the PM results, and because of _l the installation of erhanced engineered controls, that '

the biennial PH was sufficient to maintain the pellet cart integrity. However, the MAPCON PM was not I

7 updated to reflect the new PM frequency. .The inspectors noted that the two procedures (the PM and the COP) used by two different organizations (pellet operator and maintenance) to perform the PMs. did not refercace each other. This complicated any offorts to maintain procedure consistency.

The second procedural discrepancy was a note on the C0P which stated that PMs were valid for only the calendar year in which the PM was performed and the following calendar year. The note iand. "A cart PM'ed in 1994 is acceptable for use in 1994 and 1995 but cannot be ured in 1996." The inspectors determined, through a a view of the spread sheet, and through observations of pellet carts in use, that this note was not being followed. Although the pellet carts were being PHed every two years, pellet carts PMed in October 1996 were still available for use, and were being used, in January 1998. Section 3.4.1 of the License requires, in part, that activities be conducted in accordance with approved procedures.

This failure to follow COP-825204 is another example of Violation 70 1151/98 02-02 for failure to follow required work controls.

Prior to the end of this inspection, the licensee revised the MAPCON pellet cart PM to eliminate the discrepancies, and reinstated the PM in MAPCON on January 30, 1998. The licensee also indicated that COP 825204 would be revised to be consistent with actual practices. The revised PM now generates an operator maintenance (OH) PM on a monthiy basis to trigger the pellet operator to check the spread sheet and perform the inspections of the pellet carts as needed.

(e) Licensee-Identified Non Comoliances During the inspection. the licensee identified instances where maintenance inspections and tests that were not performed with the frequency required by internal procedures. The inspectors reviewed two Licensee Identified Non Compliance (LINC) Reports dated January 26, 1998, and January 28, 199e.

associated with the deficiencies.

(f) Insoection of Ventilation Ducts The LINC Report dated January 26, 1998, involved the failure to conduct monthly inspections of ventilation ducts for accumulations of uranium bearing materials as required by COP-814321. " Inspection of Ventilation

8 Oucts." The LINC P.eport explained that the MAPCON system was programmed to control the issuance of work ,

order to perform these monthly inspections. The  ;

LINC Report also explained how work orders were automatically is. cued 30 days after the closure of the i previous work order. However, due to delays in i closure of work orders, new work orders were not 1 issued by MAPCON during seven of the twelve months  ;

within CY 1997. Thus, only five of the twelve required monthly inspections were performed during -

1997.

The inspector reviewed the corrective actions taken by the licensee and the results of the ventilation duct inspections that had been performed. The inspector found that the results of the five inspections that were performed yielded a total of approximately 3 kg of uranium. Immediate corrective actions included the  !

development of a tracking system for use by shift team managers to more easily determine the status of OM/PM activities, and revising MAPCON to automatically issue work orders for ventilation duct inspection on the 20th of each nionth regardless of the status of the previous inspection. Proposed longer term corrective actions included a thorough review of the MAPCON system for other similar situations, and a re-ovaluation of the ventilation duct inspection procedures for consistency with process needs and regulatory requirements.

Notwithstanding the fact that this non compliance was identified by the licensee, a previous Notice of Violation (NOV 96 05) identified a similar situation in that a boiler inspection was not performed within

the required frequency. The corrective action to NOV 96 05 was to assign a specific individual to track and report on scheduled PM activities that threaten to exceed procedure frequency requirements, and to assign a specific individual with the responsibility for closure of PH work orders to assure accuracy and timeliness. Thus, the failure to conduct monthly ventilation inspections could reasonably be expected to have been prevented by the licensee's corrective actions for NOV 96 05. Section 3.4.1 of the License requires, in part, requires that activities be conducted in accordance with approved procedures.

This failure to conduct required ventilation inspections in accordance with C0P 814321. " Inspection of Ventilation Ducts" is anotner example of Violation 70 1151/98 0?-02 for failure to follow required work controls.

9 (g) Ammonia Scrubber System Interlocks The LINC Report dated January 28. 1998, involved the failure to conduct annual testing of safety significant interlocks for three process syr.tems as required by Licensee Procedure RA-108 " Safety

$lgnificant Interlocks and Passive Controls." The inspector observed that this LINC Report described two separate incidents that resulted in deficiencies associated with process interlocks. The inspector observed that the first incident occurred on interlocks associated with an ammonia scrubber during an approved configuration control change. The approved change involved modification of process control software for the ammonia scrubber in June 1997. When the annual testing of the ammonia scrubber safety interlocks was performed in January 1998. It was discovered that the interlock for a high high level alarm had been removed from the system. Thus a safety significant alarm was not functional for approximately seven months. The ammonia scrubber system was shut down so that the process control software could be revised to reinstate the removed interlock and the annual functional tests could be performed.

The inspector observed that the corrective actions for this incident included establishing an investigation team to evaluate had interlocks are determined to be safety significant; how these interlocks are maintained, tested, and verified functional: how it is ensured that such interlocks are not altered during routine maintenance and configuration control modifications: and determine if other required maintenance activities could be subject to similar failures.

Although this discrepancy was identified by the licensee as a failure to properly conduct functional testing of safety significant interlocks, the inspector found that the licensee's Configuration Control and Quality Assurance systems should have been able to prevent this occurrence. Specifically.

adherence to procedures 0A-007 " Programmable Logic Controller Software Quality Assurance" and TA-500.

" Columbia Manufacturing Plant Configuration Control" should have been able to prevent, or immediately detect through post-maintenance testing, the inadvertent removal of a safety significant interlock.

10 Section 3.3 of the LA. " Quality As;urance." requires, in part, that safety significant processing equipment be designed installed, operated, and maintained so that it will perform its desired function when called upon to do so. Licensee Procedure TA-500 defined the review and approval process necessary to assure that systems continued to meet the specification requirements in a manner that was safe and complied with all applicable regulations. The removal of a safety significant interlock from the ammonia scrubber was not subjected to this defined review and approval process and is another example of Violation 70-1151/98 02-02 for failure to follow required work controls. Additior. ally, the licensee's efforts to assess the adequacy of post-maintenance functional testing of process equipment and control software will be tracked as an inspector Followup Item (IFI 98-02-03).

(h) URRS Safety Sionificant Interlocks The second incident oe.,cribed in the LINC Report datej January 28, 1998, involved the failure to perform annual functional tests for the URRS Safe Geometry Dissolver and Incinerator systems in the required time frame. During a triennial internal audit of the program for functionally testing safety significant interlocks, it was discovered that the interlock testing associated with these two process systems had not been conducted. Further investigation by the internal auditor found that when a global change occurred in the systen for tracking the functional testing of interlocks, the status of certain interlocks was changed from ")rocess" to " safety signi ficant. " Those interlocts identifled as safety significant were set up to have instructions for functional tests automatically initiated by the MAPCON system. However, the safety significant interlocks in the URRS area were never changed from its " process" designation. Thus, functional tests of these interlocks were not automatically initiated by MAPCON.

and subsequently these tests were not performed within the fifteen month time frame as required in Licensee Procedure RA-108. Once discovered, the interlocks were immediately functionally tested and development of procedures to provide instructions for the annual functional testing of these interlocks were initiated.

The corrective actions taken to prevent recurrence are the same as those for the ammonia scrubber discussed above. Section 3.4.1 of the LA. " Procedures."

requires, in part, that activities be conducted in accordance with approved procedures. The failure to

11 conduct anr.ual testing of_ safety significant interlocks as required by RA-108 is another example of Violation 70 1151/98 02-02 for failure to follow required work controls.

(3) Conclusions The designation of safety significant PMs in MAPCON is inconsistently applied to items that have been identified as safety significant through procedure RA 108. Other safety-related items that are required by the LA to have PMs do not have a unique identifier in MAPCON to prevent unauthorized or inadvertent removal from the PM system. The implementation of a consistent system to identify and control PMs on items important to safety will be tracked as IFI 98 02-01.

The review of maintenance work control system also revealed several instances of non compliance with procedures or inadequate controls in procedures. Collectively, these non-compliances are being cited as VIO 70-1151/98-02-02.

An assessment of the adequacy of post-maintenance functional testing of process equipment and control software will be tracked as an Inspector Followup Item (IFi 96-02-03),

b. Manaaement Audit of Maintenance (F1.05)

Follow-uo on Previously Ldentified issues (F1.08)

(1) Inspection Scope The conduct of the initial independent audit of the maintenance program that was previously identified for inspector follow-up (IFI 97-02 03) was reviewed.

(2) Observations and Findings The ins)ectors reviewed audit ESBU-97-08. conducted by the Westinglouse ESBU from December 8 through 12. 1997. The audit was performed to confirm that activities at the plant were conducted in accordance with the ESBU Quality Management Systems. and covered many different types of activities and programs. including the Maintenance Program.

The audit identified six findings and eleven recommendations. Only two findings were in the maintenance area. One finding was product-quality related, and was not reviewed by the ins)ectors. The second finding concerned non-safety-related )Ms exceeding the PM grace period and written notifications not being issued as required by a Procedure MPC-108000. Preventive Maintenance Revision 4.

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This concern is similar to concerns addressed by the

, inspectors in this report (see Section 3.a.(2)) and-in previous reports.

l Three of the recommendations dealt with the maintenance program, and included: the lack of a document to describe '

the hierarchy of documents / procedures for the Maintenance Ouality Program
grece periods not being provided for all PH frequencies: and a reduction in training for maintenance >

personnel in 1997, Westinghouse had until February 2. 1998, to respond to the findings of the audit. These res the time of this inspection, and,ponses thus, werewere not complete at not available for review by the inspectors.

(3) Conclusions

, Although the inspectors determined that the audit was performed, this IFI will remain open until a review of the audit responses and corrective actions for the findings and recanmendations is conducted.

. 4. Exit Interview On January 30, 1998, the inspection scope and results were summarized

with licensee representatives. The inspectors discussed in detail the routine program areas inspected, and the findings, including the

, potential violation for failure to follow required work controls. The a licensee was informed via telephone on February 19, 1998, of the final NRC decisions regarding the cited violation. No dissenting comments

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were expressed by the licensee, J

The licensee did not identify any of the materials provided during the inspection as proprietary.

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ATTACHMEliI _

PARTIAL LIST OF PERSONS CONTACTED Licensgg

  • J. Allen, Plant Manager
  • R. Ervin.-Technical Su ort Chemical Process Engineering
  • W. Goodwin. Manager. R ulatory Af fairs
  • S. Mcdonald. Manager, T hnical Services
  • A. Parker. MAPCON Administrator
  • N. Parr Manager. Chemical Process Engineering
  • C. Perkins, Manager, Maintenance
  • T..Shannon. Regulatory Affairs Tecir .n
  • R. Williams. Regulatory Affairs Ad<isory Engineer Other Licensee employees contacted included engineers, technicians, security and office personnel.
  • Attended exit meeting INSPECTION PROCEDURES USED IP 88020 Region Nuclear Criticality Safety Inspection Program IP 88025 Maintenance and Surveillance Testing LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 70-1151/98-02-01 IFI Review Licensee's Actions to Prevent Deletion of Required PMs (Section 3.a.(2)(d))

70-1151/98 02-02 VIO Several Examples of Failure to Follow Required Work Controls (Section 3.a.(2))

70-1151/98-02 IFI Assess Adequacy of Post-Maintenance Functional Testing

-of-Process Equipment and Control Software

..- (Section 3.a.(2)(g))

Closed None

2 Discussed  ;

70 1151/97-02-03 IFI OPEN Completion of Maintenance Audit.(Section 3 b) 70-1151/97-03-01 IFI OPEN Follow-up on Testing of the Centrifuge Instrumentation (Section 2.c) 70 1151/97-03 03 IFI OPEN Follow-up on Actions to Supplement CSE Documents ji (Section 2.c) 1 70-1151/97 206 03 IFI OPEN 'Inadvertant use of Contaminated Shoe Covers (Section 2.c) i LIST OF ACRONYMS USED l

ADU Ammonium Diuranate C0P Chemical Operating Procedure CSA Critical Safety Analysis

CSE Critical Safety Evaluation

! CY Calendar Year IFBA Integrated Fuel Burnable Assembly IFI- Inspector Follow-up Item i ISA Integrated Safety Analysis kg Kilogram LA License Application LINC Licensee Identified Non Compliances MAPCON Maintenance Planning and Control OM Operator Maint' nance

PM Pragrammed Maintenance
6 SGD Safe Geometry Dissolver L SMIP Safety Margin Ir.iprovement Program 4 Sx Solvent Extraction
URRS Uranium Recycle and Recovery Services VIO. Violation W0 Work Order i

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