ML20204J320

Insp Rept 70-0036/99-01 on 990301-05.No Violations Noted. Major Areas Inspected:Aspects of Licensed Operations,Maint & Surveillance,Ep,Training & Transportation Safety

ML20204J320
Person / Time
Site:	07000036
Issue date:	03/23/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
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Shared Package
ML20204J301	List: ML20204J298 ML20204J307 ML20204J320
References
70-0036-99-01, 70-36-99-1, NUDOCS 9903300059
Download: ML20204J320 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli Docket No:

070-00036 License No:

SNM-33 Report No:

070-00036/99001(DNMS)

Licensee:

ABB Combustion Engineering, Inc.

Facility:

Hematite Nuclear Fuel Manufacturing Facility Location:

Hematite, MO 63047 Dates:

March 1 - 5,1999 Inspector Courtney A. Blanchard, Resident inspector Portsmouth Gaseous Diffusion Plant Approved By:

Patrick L. Hiland, Chiaf Fuel Cycle Branch Division of Nuclear Materials Safety

-I 9903300059 990323 PDR ADOCK 07000036 C

PDR L:--

i EXECUTIVE

SUMMARY

ABB Combustion Engineering, Inc.

Nuclear Fuel Manufacturing Faciilty NRC Inspection Report 070-00036/99001(DNMS)

This routine, announced inspection included a review of aspects of licensed operations, maintenance and surveillance, emergency preparedness, training, and transportation safety.

Plant Ooarations The inspector concluded that the operations observed and reviewed were generally conducted in accordance with the applicable procedures and nuclear criticality safety requirements. Plant housekeeping had improved and was noted as good, except for the decontamination area. The inspector identified and the licensee revised a posting that j

did not clearly identify the nuclear criticality safety requirements for the pallet receipt i

area next to Build 5ng 230. (Section 01.1)

The inspector concluded that a cold trap safety system was not tested or calibrated to s

ensure that the safety system functioned as required by the Integrated Safety Assessment / Hazard Analysis for the Oxide Conversion Facility. The as-found condition of the safety system indicated that the primary system shutdown mechanism may not have functioned as designed, to prevent overfilling an 8A cylinder with uranium hexafluoride. The inspector conclw J Sat the licensee's immediate compensatory actions were adequate. (Section O2.1)

Maintenance and Surveillance Activities 4

e The inspector concluded that the licensee adequately controlled the calibration program for the oxide plant instruments in addition, the inspector concluded that the catioration of instruments controlled under Procedure No. 1500.00 was rigorous. (Section M2.1)

Plan + Sucoort The inspector found that the licensee's emergency operations center and emergency j

response equipment were adequately maintained. (Section P.1) 1 The inspector concluded that the required biennial radiation safety and nuclear criticality safety refresher training was comprehensive and included both theoretical and practical aspects of the programs. The proficiency examinations were challenging for the refresher training and conducted as required. (Section 11.1)

Activities for loading truck trailers and preparing shipping papers, for fuel rod assembly e

transport to a reactor, were conducted in accordance with applicable NRC and Department of Transportation requirements. (Section T1.1) 2

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Report Details

1. Operations 01 Conduct of Operations 01.1 Facility Tours and G6neral Operations a.

Insoection Scooe (88020)

The inspector toured various plant areas with cognizant licensee personnel and observed the status of facility operations, implementation of nuclear criticality safety (NCS) and radiation protection safety requirements, and site housekeeping. The areas included the uranium hexafluoride (UF.) cylinder loading dock area, oxide conversion facility, fuel pellet manufacturing facility, uranium recycle and recovery area, fuel rod loading, and fuel bundle assembly facility, and other selected plant areas.

b.

. Observations and Findinas Operations observed were conducted safely and in accordance with the goveming procedures. Current procedure manuals were observed at numerous locations throughout the plant and minor updates (Temporary Shop Instructions) were posted near the applicable work locations. Material inventory logs and operator check sheets were completed and available in the immediate area of the operation. Operators were knowledgeable of criticality controls, radiation safety controls, and system operating parameter limits associated with the operators' respective work assignments.

Specifically, the conversion plant control room operators demonstrated sufficient knowledge of the purpose and the intended safety function of alarms and safety interlocks associated with the process.

The inspector observed the location and accuracy of postings, emergency egress routes, pressure differentials across the high efficiency particulate air (HEPA) filters, and the lighting intensity throughout the plant. Posting of criticality limits and controls were consistent with Section 4.1.5, " Posting of Limits and Control," and Section 2.4,

" Criticality Safety Limits and Signs," of the license application and with Nuclear Industrial Safety (NIS) Procedure No. 201, " Nuclear Safety Manual." However, the inspector noted that a posting for the staging area for pallet receipt, next to Building 230, did not clearly specify the quantity of pallet containers allowed per array. The following day the licensee took corrective action to enhance the posting for the pallet receipt area next to Building 230.

The inspector observed that the current NRC Form 3 was posted at all portals and on a

bulletin boards throughout the producti a plants, and that hallways, stairways, and paths were clear of obstacles for egress out of the production plants. Lighting also appeared to be adequate for operators and maintenance personnel. Additionally, the inspector observed that the differential pressure was below 6 inches of water across the HEPA filters, as required.

The inspector noted improvement in housekeeping. In particular, inspection Report 070-00036/98004(DNMS), identified that housekeeping in the Oxide Building was poor and had generally deteriorated from previous inspections. In discussion with 3

the inspector, the Director of Uranium Operation explained that stored equipment, tools, and maintenance supplies were removed from the oxide plant and discarded from the site. The inspector observed that the licensee had removed tops to receiver hoppers, HEPA filters, used process equipment, and spare insulation from the second and third levels of the Oxide Building noted during past inspections. In addition, the inspector noted housekeeping initiatives which included the removal of unused piping and equipment from the red room. However, the inspector found a significant amount of used plant contaminated equipment staged in the decontamination area. The Director of Uranium Operation explained that the equipment observed was staged for site removal. The following day, the inspector observed that the licensee had begun packaging for shipment the debris in the decontamination area.

I c.

Conclusions Except as noted in Section O2.1, the inspector concluded that the operations observed and reviewed were conducted in accordance with the applicable procedures and NCS requirements. The plant housekeeping had improved and was noted as good except for the decontamination area. The inspector identified and the licensee corrected a posting that did not clearly identify the NCS requirements for pallet receipt area next to Building 230.

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02 Operation Status of Facilities and Equipment O2.1 Uranium Hexafluoride Cold Traooina System j

a.

- Inspection Scope (88020)

On March 3, during a tour of the oxide plant, the inspector observed that the cold trap weight scale and other associated instruments did not appear calibrated. The inspector reviewed the UF, cold trap system and discussed noted concerns with the appropriate

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engineering, operation, and management personnel.

b.

Observations and Findinas The inspector noted that the licensee used the cold trap system to remove the remaining UF (heel) from the 30B cylinders after the production run from the cyhnder was complete. The cold trap system included an 8A cylinder encased in a container of propylene glycol solution. During cold trapping operations the solution was chilled to below 45 degrees Farenheit (*F). The system operates by transferring heated UF, vapor from the 30B cylinder to the 8A cylinder which was under vacuum. The inspector noted the vacuum in the 8A cylinder, during cold trapping, was caused by the vapor pressure difference between the hot vapors in the 30B cylinder and the UF solidification in the cold trap. To remove the UF from the 8A cylinder, the licensee valved the cold trap into the oxide plant process and heated the propylene solution above 200*F (heating / vaporization operation) with plant steam. The UF. vapor then flows from the 8A cylinder to the oxide plant process. The inspector noted the licensee's method to remove the heel material from 30B cylinders was consistent with industrial practice.

The inspector observed, during a walk down of the cold trap system with Operation Sheet Procedure No. 604.13. "UF Cold Trap System," Revision 7, dated March 30, 1998, that the licensee did not appear to calibrate the instrumentation used to monitor 4

the cold trap system. The inspector noted that a load cell under the cold trap system was used to measure the weight of the 0% product in the 8A cylinder. The local digital scale and oxide plant control room displayed the UF product in the 8A cylinder, in discussion with the inspector, the Oxide Plant System Engineer explained that the 8A cylinder fill limit alarm (set at 70 kilograms (kgs)) and isolation system (set at 100 kgs) used the same scale / load cell, but that tne licensee did not calibrate the

- scale / load cell.

The inspector discussed the weight scale calibration and functional verification issue with the Director of Uranium Operations. The Director of Uranium Operations directed the Oxide System Engineer to complete the cold trap process and then perform a system functional test and weight scale calibration. The inspector noted that oxide plant operators completed the heating / vaporization operation (removal of the UF, from the cold trap) as directed by the Director of Uranium Operations, but the scale displayed approximately 16 kgs without a load. -The Oxide Plant System Engineer explained that the weight scale was not zeroed because there was no assurance that the displayed 16 kgs was not in the 8A cylinder in the form of a UF, deposit or build-up of material on the inner surface.

On the evening of March 3, the inspector observed the Oxide Plant System Engineer and Industrial Safety Engineer perfum several weight scale calibration and safety system functional tests for the cold trap system. The Oxide Plant System Engineer and Industrial Safety Engineer performed several tests with certified weights to test the accuracy of the weight scale and alarm / system isolation set points. During the tests, the inspector observed that the scale displayed between 38 to 54 kgs when loaded with 45 kgs and approximately 93 kgs when loaded with 93 kgs. In addition, the cold trap system alarm sounded when the scale displayed 70 kgs and the cold trap system isolated at 100 kgs as designed. Throughout the tests, the scale read between 11 to 19 kgs when not loaded, and the licensee conservatively assumed this mass was UF.

deposit or build-up in the 8A cylinder. This error was noted in the following test runs as examples:

e During the third test the weight scale displayed 11 kgs (which the licensee assumed was UF, product in the 8A cylinder) with no load and 56 kgs after 70 kgs were loaded on the cold trap system. The scale should have displayed 81 kgs, with the 11 kgs assumed in the cylinder (from the reading with no load) plus the loaded weight of 70 kgs.

During the fifth test the weight scale displayed 19 kgs with no load and 93 kgs after 93 kgs were loaded on the cold trap system. The scale should have displayed 102 kgs with the 19 kgs assumed in the cylinder plus the loaded weight of 93 kgs.

Therefore, the licensee calculated that the cold weight scale a.d alarm / system isolation set points were in error by as much as 25 kgs in the rnn-conservative direction due to the reading on the scale with no load.

During the interim cold trap system calibration and functional verification, the inspector identified a design concern. As described previously, the licensee designed the 8A cylinder and cooling / heating jacket to be vertically supported solely by the load cell.

The accuracy of the scale / load cell required that the cold trap system move freely when UF, was added to the system. However, the inspector observed a rigid steam and UF.

5 N

r pipe between the 8A cylinder and 4-way. The 4-way valve was bolted to a plate which was welded to the steel cold trap tubular framework. This configuration restricted the vertical movement of the 8A cylinder. In response to this finding, the licensee developed a work instruction to rep'.ce the rigid pipe with flexible tubing, calibrate the scale / load cell, adjust the alarm set-point from 70 to 60 kgs, and adjust the system shutdown set-point from 100 to 70 kgs with the zero point error of 16 kgs. In addition, the Director of Uranium Operations stated that the licensee would clean the 8A cylinder and cooling / heating jacket by April 1999.

The inspector reviewed the safety impact of over filling the 8A cylinder with UF.. The UF volume increased by approximately 33 percent during the solid to liquid phase change. The inspector noted that the fundamental phase change issue was addressed in the licencee's Integrated Safety Assessment / Hazard Analysis (ISA) for the oxide conversion facility. Specifically, the ISA identified an overfilled 8A cylinder may rupture if heated and release UF.. The catastrophic rupture of an 8A cylinder in the vaporization area would create an environment which was immediately dangerous to life and health i

I for workers in the general area. The licensee's safeguards to mitigate overfilling an 8A cylinder included the 70 kgs fill limit alarm, limiting the number of cold trapping cycles to seven 30B cylinders, and a cold trap system shutdown at 100 kgs. The cold trap 70 kgs alarm and 100 kgs system shutdown function relied on the accuracy of the scale / load cell. The inspector noted that the importance of the scale / load cell accuracy was addressed in the ISA which required the licensee to calibrate the scale / load cell.

The as-found condition of the scale / load cell represented an increased risk for a failure of the 8A cylinder.

During a followup conversation with the licensee, the inspector leamed that Revision 6 to Procedure No. 604.13 required a test to verify scale / load cell accuracy, but the licensee had removed this requirement during the development of Revision 8. Licinsee management stated that an investigation as to why the scaie/ load cell verification test was removed from Procedure No. 604.13 was ongoing. However, the licensee explained that the new procedure would require a more rigorous calibration than originally identified in Procedure No. 604.13 and would include a functional test of the alarm and safety system shutdown function. In addition, the inspector noted that inspection Report 070-00036/98-203 contained a Non-Cited Violation regarding an unexpected accumulation of material in the incinerator heat exchanger. The licensee had identified that one of the root causes for the unexpected accumulation of material was that a required heat exchanger inspection was incorrectly deleted from the applicable procedure.

License No. SNM-33, Safety Condition S-1 states, in part, that the license is authorized for use in accordance with the statements and representations in Chapters 1 through 8 of the application. Chapter 1.6(e), " Exemptions and Special Authorizations," requires, in part, that ABB Combustion Engineering, Inc., shall perform ISA for plant processes. For equipment important to safety, programs for testing, calibration, and inspection of all instrumentation and control systems (important to safety) were required to be included in the hazard analyses to assure equipment reliability. Chapter 2.6 " Operating Procedures,"

states, in part, that operations which affect licensed material shall be conducted in accordance with approved written procedures. Suitable control measures were prescribed, and pertinent control proceduras relative to NCO and radiological safety were followed. Integrated Safety Assessment / Hazard Analysis for the oxide conversion facility, dated March 27,1996, defined the scale / load cell for the uranium hexafluoride 6

cold trap system in the vaporization room as equipment important to radiological safety and required that the scale / load cell be calibrated. Operation Sheet Procedure No. 4101.00, " Oxide inspection and Alarm Calibration / Testing," prescribed the implementation of the program for testing, calibration, and inspection of all instrumentation and control systems important to safety, relative to the uranium hexafluoride cold trap system, to assure the equipment reliability. Prior to March 3,1999, the licensee's operating procedures failed to prescribe control measures for the programs to test, calibrate, and inspect instrumentation and control systems important to safety for the uranium hexafluoride cold trap system, as identified in the ISA.

Specifically, Procedure No. 4101.00, " Oxide inspection and Alarm Calibration / Testing,"

failed to prescribe a program for the testing, calibration, and inspection for the scale / load cell of the uranium hexafluoride cold trap system, equipment defined as important to radiological safety in the Oxide Conversion Facility ISA. Testing performed by plant personnel also demonstrated that the scale was significantly out-of-tolerance. The failure to perform the calibrations as required by the ISA resulted in an increased risk of having the safety interlock system fail for the cold trap system, which may have resulted in a failure of the 8A cylinder cold trap during normal cold trap operations. The failure to prescribe a program for the testing, calibration, and inspection of the scale / load cell of the uranium hexafluoride cold trap system is a Violation of Safety Condition S-1 of the License Conditions. (VIO 070-00036/99001-01) c.

- Conclusions The inspector concluded that a cold trap safety system was not tested or calibrated to ensure that the safety systems functioned as required by the ISA for the Oxide Conversion Facility. The as-found condition of the safety system indicated that the primary system shutdown mechanism may not have functioned as designed, to prevent overfilling an 8A cylinder with UF.. The inspector concluded that the licensee's immediate compensatory actions were adequate.

11. Maintenance l

M2 Maintenance and Material Condition of Facilities and Equipment i

M2.1 Instrumentation Calibration Review a.

Insoection Scope (88025) i The inspector reviewed' selected elements of the licensee's calibration program for process instruments. The review included an evaluation of the licensee's consistency and effectiveness in assuring calibrated instruments were used to control process operating parameters by operators. Specific documents reviewed were:

j Procedure No. 4101.00, " Oxide Inspection and Alarm Calibration / Testing," dated e

February 7,1998; and Procedure No. 1500.00, " Control of Measuring and Test Equipment," dated December 4,1998.

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b.

Observations and Findinas j

Procedure No. 4101.00 specified the inspection, calibration, and testing methods for maintaining controls that monitor the oxide process. The process instruments monitored

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the oxide process to ensure that the system operated within design parameters to prevent an industrial or NCS event. The inspector noted that Procedure No. 4101.00 j

addressed in detail the frequency, process, and acceptance criteria to accurately calibrate the alarm set points for the oxide plant pressure alarms, reactor temperature darms, vaporizer temperature alarms, UF, detectors, air supply hygrometers, moisture monitor, and vaporizer conductivity sensors. In addition, required surveillance activities were also addressed in Procedure No. 4101.00 for the oxide plant. The inspector noted that instruments and sunteillances ensured that NCS required operating parameters were maintained. However, the inspector noted some instruments used to ensure industrial operating parameters were not calibrated. Specifically, the alarms and weight scale addressed in Section O 1.1 ware not calibrated or functionally tested.

The inspector reviewed the process to ensure that process control and monitoring instruments were calibrated at specified intervals and within prescribed limits. Procedure No.1500.00 addressed the required process controls for quality and accountability measurement instruments. The licensee used an industrial calibration program for instruments identified in Procedure No. 1500.00. The calibration program was controlled and updated by the Calibration Manager who ensured on a daily basis that instruments which required calibration were either calibrated within the prescribed frequency o-taken out of service. However, the inspector noted that the oxide plant instruments identified in Procedure No. 4101.00 were not controlled under the rigor required by Procedure No.1500.00. A manual method was used to track required calibration frequencies for instruments in the oxide plant. In addition, the inspector noted that the oxide plant instruments were not labeled with calibration stickers as were all instruments controlled by Procedure No. 1500.00.

Licensee management recognized that the calibration program used for oxide plant instrumentation was not controlled to the level of rigor as instruments controlled by Procedure No.1500.00. The Director of Uranium Operations explained that the oxide plant instruments would be controlled by Procedure No. 1500.00.

c.

Conclusions The inspector concluded that the licensee's control of the calibration program for oxide plant instruments was generally adequate. The inspector further concluded instrument control identified by Procedure No. 1500.00 was adequate.

IV. Plant Support I

P2 Status of Emergency Preparedness Facilities, Equipment, and Resources l

P2.1 Facilities and Eauioment a.

Inspection Scooe (IP 88050)

The inspector toured the Emergency Operations Center (EOC) (tile barn) and the Pump House to evaluate the material condition, operability, and equipment readiness.

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b.

Observations and Findinas The inspector determined that emergency equipment maintained in the EOC, and at required locations in the plant facilities was consistent with the current Emergency Plan

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(EP). Storage areas for the emergency equipment and supplies were stocked in accordance with the EP Implementing Procedure No. 5.03, " Emergency Equipment."

Emergency equipment was inspected and the inspector determined the licensee maintained the equipment in an excellent state of readiness. Specifically, the self contained breathing apparatus and fire extinguishers required surveillances were current.

i The inc,pector verified through record reviews that equipment in the EOC and fire water pumps in the Pump House were operational, properly maintained, and tested at the frequencies required by the EP. The Emergency Manager explained that the licensee q

retained current documentation with the local hospital on health concerns from industrial l

chemical and radiation exposures. The licensee issued the current EP to the local fire department.

c.

Conclusions The inspector found that the licensee's EOC and emergency response equipment were adequately maintained.

11 Conduct of Training 11.1 Biennial Refresher Trainina a.

Inspection Scope (88010)

The inspector reviewed the recent biennial refresher training provided to plant staff through a review of exams and exam results, and discussions with plant personnel.

b.

Observations and Findinas The biennial refresher training, required by Section 2.5 of Chapter 2 of the license included classroom training sessions for both radiation safety and NCS training. Each employee allowed unescorted access to the restricted area was required to pass a written examination. The inspector found the examinations were challenging and j

focused on requirements pertinent to routine plant operations. The Nuclear Criticality i

Manager explained that approximately 90 percent of the workers passed the criticality refresher training the first time the examination was administered. Remedial training was provided for those workers who did not pass the examination. A review of the objectives and examinations indicated that the training covered both theoretical and practical j

aspects of radiation safety and NCS. Selected training records reviewed indicated the licensee was tracking the status of training for each worker in the plant and meeting refresher training frequency requirements of the license.

c.

Conclusions The inspector concluded that the required biennial radiation safety and NCS refresher training was comprehensive and included both theoretical and practical aspects of the 9

4 programs. The proficiency examinations were challenging and were conducted as required.

- T1_

Transportation Safety T1.1 Preparation of Fuel Assemblies for Shioment a.

Insoection Scope (86740)

The inspector observed the preparation and movement of a truck trailer loaded with fuel assemblies.

b.

Observations and Findinas The inspector observed a trailer that had been loaded with approved 327C1 shipping containers in preparation for transport. The containers were used for fuel assemblies and were appropriately labeled and braced as required by 10 CFR 71 and the Department of Transoortation (DOT) regulations. Shipping papers prepared for the shipments contained the bill of lading with correct identification of container contents, shipper's certification, exclusive use requirements, and emergency response information, as required by DOT regulations. In addition, the inspector noted that the trailers were appropriately placarded.

The inspector observed the tractor trailer driver perform the required tractor and trailer checks. In addition, the inspector reviewed the drivers training records, and the maintenance records for the tractor trailer. The driver performed the following verifications:

e The 927C1 shipping containers were adequately blocked and secured to the

trailer, e

Trailer and tractor lights functioned as required.

e All appropriate documentation was completed.

The driver was current in required training and knowledgeable in DOT and NRC requirements for shipping radiological materials.

c.

Qonclusions Activities for loading truck trailers and preparing shipping papers for fuel assembly transport to a reactor were conducted in accordance with applicable NRC and DOT requirements.

V. Manaaement Meetinas X1 Exit Meeting Summary

- The inspector met with plant management and other staff throughout the inspection and on March 5,1999, for the exit meeting. The inspector summarized the observations and findings of the inspection. The licensee management acknowledged the findings. The licensee did not

- identify any of the information discussed at the meetings as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Eastbum, Nuclear Criticality Specialist K. Funke, Supervisor Health Physics l

K. Hayes, Industrial Safety Engineer G. Page, Director of Operations D. Rohde, Technical Trainer E. Saito, Health Physicist B. Sharkey, Director of Regulatory Affairs P. Weaver, Production Manager INSPECTION PROCEDURES USED IP 86740:

Inspection of Transportation Activities IP 88010:

Operator Training / Retraining IP 88020:

Operations Review / Regional Criticality Safety IP 88025:

Maintenance and Surveillance IP 88050:

Emergency Preparedness.

ITEMS OPENED, CLOSED AND DISCUSSED Opened 070-00036/99001-01 VIO Failure to establish a program for the testing, calibration, and inspection of the cold trap system.

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LIST OF ACRONYMS USED

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CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety DOT Department of Transportation EOC Emergency Operation Center EP Emergency Plan HEPA High Efficiency Particulate Air ISA Integrated Safety Assessment / Hazard Analysis kgs kilograms NCS Nuclear Criticality Safety NRC Nuclear Regulatory Commission PDR Public Document Room SNM Special Nuclear Material UF, uranium hexafluoride VIO Violation 12