ML20207B378

Insp Rept 70-1257/99-01 on 990322-26,0514 & 21.Violations Noted.Major Areas Inspected;Licensee Programs for Radiation Protection,Emergency Preparedness,Operator Training, Transportation & Followup of Open Items from Previous Insps

ML20207B378
Person / Time
Site:	Framatome ANP Richland
Issue date:	05/21/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207B371	List: ML20207B368 ML20207B373 ML20207B378
References
70-1257-99-01, 70-1257-99-1, EA-99-085, EA-99-85, NUDOCS 9905280225
Download: ML20207B378 (14)

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ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket Nos.: 70 1257 i License No.: SNM-1227 1

Certificate of Compliance Nos.: 6581,9248 EA No.: 99-085 Report No.: 70-1257/99-01 Licensee: Siemens Power Corporation (SPC)

Facility: Siemens Power Corporation Location: Richland, Washington Dates: March 22-26,1999, and May 14,1999, and May 21,1999 Inspector: Wayne L. Britz, Fuel Facility inspector Fuel Cycle Decommissioning Branch Division of Nuclear Materials Safety (DNMS)

Accompanied By: Linda L. Howell, Technical Assistant, DNMS Approved By: D. Blair Spitzberg, Ph.D., Chief Fuel Cycle / Decommissioning Branch, DNMS ATTACHMENT: Supplemental inspection information

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EXECUTIVE

SUMMARY

Siemens Power Corporation NRC Inspection Report 70-1257/99-01 This routine, announced inspection included a review of selected aspects of the licensee's programs for radiation protection, emergency preparedness, operator training, transportation, and followup of open items from previous inspections.

I Radiation Protection

. The inspector concluded through procedure review, record review and interviews with facility staff that the external dosimetry program was effectively implemented onsite consistent with 10 CFR 20.1502,20.2102, and 20.2106 (Section 1.1).

Emeraency Preparedness

. The licensee maintained a good inventory of emergency response equipment and supplies that were in a state of operational readiness. The Emergency Plan is being enhanced based on experiences following an event which tested the notification process (Section 2.1). )

Operator Trainina

. The licensee was adequately providing training to employees and tracking the training needs of the employees (Section 3.1).

Transoortation

. The loading, packaging, preparation for shipment and shipment of transportation containers observed during the March 22-26,1999, inspection was performed and l documented according to procedures (Section 4.1). l

. Required audits of the transportation program were performed. The Quality i Assurance (OA) Program is still undergoing a program upgrade in response to a prior NRC inspection. The OA Program has been submitted to NRC for review and approval.

The results of the program upgrade will be reviewed during future inspections (Section 4.2).

. . The licensee had assigned a new full-time person and two temporary assignees to work on transportation program enhancements (Section 4.2).

. A violation of 10 CFR 71.12 was identified involving the licensee's use of several Model 51032-1 shipping containers which did not conform with Certificate of Compliance No. 6581 (Section 4.3). Another example of a 10 CFR 71.12 violation was identified involving the licensee's use of several Model SP-1 shipping containers which did not conform with Certificate of Compliance No. 9248 (Section 6.2).

. A violation involving 10 CFR 71.85 was identified involving the licensee's use of several Model SP-1 shipping containers to which model numbers were applied without determining that the packaging has been fabricated in accordance with Certificate of Compliance No. 9248 (Section 6.2).

1. . A violation of 10 CFR 71.133 was identified with two examples. One example involved the licensee's established measures not having assured that conditions adverse to quality were promptly identified during inspections of the Model 51032-1 shipping containers between March and June 1998 (Section 4.3). Another example of a 10 CFR 71.133 violation was identified involving the licensee's continued use of Model SP-1 inner shipping containers with identified nonconformances which were not promptly corrected (Section 6.2).

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4 Report Detalls Summary of Plant Status The plant was operating Lines 1 and 2 of the dry conversion facility (DCF). Uranium recovery I activities were also in operation. Fuel pellet production, fuel rod loading and downloading, and fuel bundle assembly operations were also in progress.

1 Radiation Protection (83822) 1.1 Insoection Scope The inspector reviewed selected portions of the external dosimetry program io determine compliance with 10 CFR 20.1502,20.2102, and 20.2106 requirements for monitoring occupational workers for external radiation exposure and maintaining records I of occupational exposures, and interviewed licensee health physics staff.

1.2. Observations and Findinas The inspector discussed procedures for administering external dosimetry to personnel based on work location and potential to receive dose. Procedures specify certain groups of workers who require dosimetry based on their work location, if they work in

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posted radiation areas 8 or more hours per week on the average or who would be expected to receive an annual deep dose in excess of 250 mrem. Exposure records for the period 1996 through 1998 were reviewed. Quarterly exposure records for various work groups were reviewed as well as the dosimetry files for selected personnel. The storage and retention process for exposure records were reviewed. Radiological exposures recorded were within the regulations for occupational workers. No concerns were identified with the procedures or records reviewed.

1.3. Conclusion The inspector concluded through procedure review, record review and interviews with facility staff that the external dosimetry program was effectively implemented consistent with 10 CFR 20.1502,20.2102, and 20.2106.

2 Emergency Preparedness (88050) 2.1 Inspection Scope The inspector toured the licensee's facilities to examine selected emergency response equipment maintained in emergency repositories, and the changes being made to stream! iris emergency notification info mation to county and state officials.

5-2.2. Observations and Findinas The inspector noted that the emergency equipment repositories contained equiprnent identified in the licensee's Emergency Plan. The cabinets containing emergency equipment were clearly identifiable, contents were orderly, and they appeared to be well maintained. The inspector noted that the placement of certain types of equipment was near the areas most likely to be needed.

The inspector noted changes were being made to the Emergency Plan as a result of experiences following the April 15,1998, fire which resulted in emergency notifications to state and county personnel. Revisions are being made to Part 1, " Emergency Plan,"

and Part 3," Implementing Procedures." A description of the Modular Extraction / Recovery Facility (MERF) being placed into service is being added to the Emergency Plan and the prioritization of the call list to the state and county is being revised. Part 2, the Quick Reference Section, and Part 4, " Memorandums of Understanding," are up to dcte.

The inspector noted that the emergency equipment repositories were consistent with tha Emergency Plan. The inspectors noted that enhancements were being made to improve the emergency notification process. No concerns were identified. {

2.3. Conclusions The licensee maintained a good inventory of well maintained emergency response 1

j equipment and supplies that were in a state of operational readiness. The Emergency j Plan is being enhanced based on experiences following an event which tested the l notification process.

3 Operator Training / Retraining (88010) 3.1 inspection Scope The inspector reviewed the licensee's general employee training (GET), radiological worker training (RWT), the training program for various plant workers, the records i system documenting training, toured the various training locations and observed  !

equipment used in training.

3.2. Observations and Findinas The inspector observed the training provided to new employees, the new employee required reading list, the materials and equipment used to train new employees for their various positions, and the testing and records of the completed training.

Personnel working in designated radiological areas and in special skills positions receive more comprehensive radiological and technical training. The training includes work station training on procedures and on-the-job training with written tests and skill demonstrations. Control room operators receive extensive training on the computer controlled DCF. The inspector reviewed the depth of training, written tests administered

6-to new personnel, and skills testing provided for DCF control room operators, UO2 shop operations

• personnel, and DCF powder preparation personnel. The inspector found the training and testing adequate and had no concerns. ]

Employee refresher training is provided by completion of interactive video for several topics such as hazard communications, hearing conservation, heat / cold stress, criticality safety, annual radiological worker training, annual safety training and respiratory protection. Other refresher training is provided by classroom instruction and testing.

The inspector found the refresher training adequate and had no concerns.  !

The training data base was examined for several employees. The data base contains records of all training provided to the employees over the years with the employee data, 1

the course subject / description, revision number, instructor, and the date of the course. 1 A commitment tracking system sends training due notifications to personnel. The inspector found the training data base adequate and had no concerns.

3.3 Conclusions i I

The licensee was adequately providing training to employees and tracking the training I needs of the employees.

4 Transportation of Radioactive Materials (86740) 4.1 Radioactive Materials Packaaina. Labelina. Storaae and Maintenance i 1

a. Insoect;on Scoce  !

The inspector reviewed packaging, labeling and storage of shipping containers prior to shipment, and the maintenance and rework of containers. The inspection consisted of procedural reviews, interviews and observation of work being performed to implement the requirements of 10 CFR Part 71, the license, and Certificates of Compliance,

b. Observations and Findinas The inspector observed preparation and shipment of four fuel assemblies in SP-1 containers, including shipping paper preparation, the safety check of the truck and trailer, the radiation protection check and the overall procedural requirements.

The inspector observed the loading of powder into containers, the health and safety {

conditions, and the criticality safety controls applicable to this evolution.

l The above observations also included safety discussions and interviews with personnel.

The inspector found the loading and shipment evolutions observed to be adequate and had no concerns.

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c. Conclusions The loading, packaging, preparation for shipment and shipment of transportation I containers were performed and documented according to procedures. l 4.2 OA Proaram for Transportation of Shiocina Packaaes

a. Insoection Scoce On March 17,1998, the NRC issued Confirmatory Action Letter (CAL)

No. NMSS 98-8-002 describing the licensees commitments to implement certain corrective actions related to SPC's transportation OA program. The licensee documented the status of these actions in several responses to the CAL, and the CAL was closed on December 7,1998. The inspector reviewed QA procedures and QA audit ,

reports executed after the OA program was revised in response to the NRC CAL.

b. Observations and Findings J The inspector reviewed documents related to the QA program for transportation. The licensee's document EMF-1, Revision 30, Part II," Quality Assurance Program for Nuclear Fuels, Services, and Packaging and Transportation of Radioactive Materials,"

was submitted to the NRC for review and approval on December 23,1998. The OA program revision incorporates the existing EMF-439, " Quality Assurance Program for Nuclear Fuel Shipping Containers," Revision 11, into EMF-1 to provide a single OA program to comply with both 10 CFR Part 50, Appendix B, and 10 CFR Part 71, Subpart H. The revised QA program corrects the previous program which provided for minor changes to shipping containers, an issue which is discussed in Inspection Report 71-0003/98-203.

Work practice guides a ; heing written to provide additional guidance to the SPC staff.

Work Practice Manual EMF-2084, Revision 0," Licensing of Shipping Containers," was reviewed. The manual describes the responsibilities of various departments involved in the certification of shipping containers, determining the need for an application, the i' application process, and the container certificate review and maintenance.

The inspector reviewed SPC Internal Audit Summary Report (Audit 98:45), " Shipping  !

Containers (EMF-439)," dated March 1,1999. The audit was performed to evaluate the effectiveness of licensee actions taken in response to issues raised during a February 1998 inspection (NRC Inspection Report 71-0003/98-203). The inspector reviewed two audits performed by Regulatory Compliance as required by Chapter 5 of EMF-30, Safety Manual," Radioactive Material Shipment Audit," dated November 16,1998; and

" EMF-30 Chapter 5 Radioactive Materials Shipping Audit," dated January 14,1999.

Two self-assessments performed by OA personnel for compliance with 10 CFR Part 71 were also reviewed.

The inspector reviewed audits performed by the licensee's consultant who has performed prior assessments at SPC and a root cause analysis in response to the CAL.

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8-l The auditor conducted an exit briefing the week prior to the current NRC inspection. l The inspector found the audits adequate and had no concerns. j The inspector reviewed organizational changes made to support the licensee's i trancportation program. A new position in Regulatory Compliance was established and 1 a person was hired to devote full time to shipping containers. Two other staff mernbers were temporarily assigned to work on transportation program improvements.

The inspector found the personnel provided to support the transportation program were adequate. No concerns were identified.

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c. Conclusions Required audits of the transportation program had been performed. The OA program is  !

still undergoing a program upgrade in response to a prior NRC inspection. The QA i program has been submitted for review and approval to the NRC. The results of the l program upgrade will be reviewed during future inspections.

The licensee had assigned a new full time person and two temporary assignees to work on transportation program enhancements.

4.3 Review of Shiocina Container Condition Reco_r1

a. Insoection Scoce The inspector reviewed Condition Report No. 7477, "51032 Shipping Containers - Weld inspection," dated March 18,1999, and subsequent 30-day report submitted to the NRC on April 16,1999.

b. Observations and Findinas The inspector reviewed the licensee identified nonconformance documented in Condition Report No. 7477 dated March 18,1999, concerning five Model 51032-1 shipping containers that were determined to have multiple welds located on the strongback and outer container shellihat did not conform to drawings referenced in the applicable Certificate of Compliance. The licensee's immediate remedial action was to reinspect the same welds on all 71 previously inspected and released 51032-1 shipping containers to determine if they conformed to the drawings referenced in the Certificate of Compliance. The licensee determined that most of the remaining containers were in nonconformance, and the containers were removed from service until they could be brought into compliance with the license drawings. The licensee submitted a " Report of Non-Compliance with Conditions of Fissile Material Shipping Container Certificate of Compliance, Siemens Power Corporation; Docket No. 71-6581," on April 16,1999,as required by 10 CFR 71.95.

All of the 51032-1 containers had been previously inspected between March and June 1998 (except the five described above) as part of the compensatory actions taken in response to the NRC's February 1998 inspection of the transportation program. The licensee is evaluating the reasons that its inspection program did not identify these

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nonconformances on the containers when they were previously inspected for nonconformances during the March to June 1998 time period.

10 CFR 71.12 conditionally grants a general license to any licensee of the Commission l to transport, or to deliver to a carrier for transport, licensed material in a package for which a Certificate of Compliance was issued, and requires that the licensee comply with the terms and conditions of the certificate. Certificate of Compliance No. 6581 has l been issued for the Model 51032-1 shipping container and describes conditions for its '

use. The licensee's use of the Model 51032-1 containers which did not conform to drawings referenced in Certificate of Compliance No. 6581 was identified as the second example of a violation of 10 CFR 71.12 (71-9248/9901-01). In addition,10 CFR 71.133 states, in part, that the licensee shall establish measures to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected. The l failure to promptly identify multiple weld nonconformances on Model 51032-1 shipping containers when they were inspected by the licensee between March and June 1998 was identified as the second example of a violation of 10 CFR 71.133 (71-9248/9901-03).

c. Conclusions l

The licensee's use of shipping container Model 51032-1 in nonconformance with its Certificate of Compliance No. 6581 was identified as a violation of 10 CFR 71.12 and 10 CFR 71.133.

5 Year 2000 Readiness Status SPC does have a program in place to evaluate Year 2000 (Y2K) readiness. The company has adopted a procedure similar to one developed for use by nuclear power l pants to evaluate Y2K readiness. The procedure, EMF-2097, SPC Year 2000 l Readiness, was reviewed and was determined to be comprehensive. The procedure provides for assessment of information technology readiness as well as potential hardware issues, and requires that risk assessments be used as part of the readiness review process in order to prioritize system testing and projected replacement of systems or components which are not either Y2K compliant or compatible. The procedure calls for date testing for potentially significant dates such as 9/9/99,01/01/00, and the next leap year. SPC has assigned a Y2K project team to review assessments ,

completed by various departments, and the project team consists of representatives I from all business units. Two project team representatives were interviewed during the inspection regarding SPC's findings and progress in assessing Y2K readiness.

SPC has identified several information management systems and process controls which are not Y2K compliant. The issues involving these systems are described below.

Information Technoloav (IT):

Siemens has an extensive database for maintaining training records for personnel. This system has recently been identified as Y2K non-compliant. The central file server must

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1 be replaced because it is date sensitive. The system will be upgraded in the June 1999 time frame.

I The SPC laboratory (onsite lab) analysis systems are known to be date sensitive and cannot be relied upon to generate automated reports after December 31,1999. SPC is evaluating use of another software program to assign dates rather than relying only l l upon the current software. l l l l

The nuclear materials accountability system is being replaced. The system relies upon l l a mainframe which may be 9/9/99 sensitive (based on reports which have appeared in l IT trade journals). SPC is trying to replace this mainframe prior to September 1999, and will definitely replace the system before the year 2000.

I Hardware and Process Control:

The distributed control systems (DCS) for both the ammonium diuranate (ADU) process line and the new DCF are not Y2K compliant. The ADU line in the uranium 1

dioxide (UO2) area is an older system which runs controllers for the process. Although the DCS is not Y2K compliant, the controllers are not equipped with clocks, thus they are not date sensitive. Replacement of the DCS for the ADU line is planned for later this calendar year. The DCS for the DCF facility is also not Y2K compliant. SPC is evaluating changes for this control system.

There are a number of process monitors and various types of recorders which are stand alone systems. These systems are being tested for Y2K compliance; results of the  ;

licensee's evaluation are not yet available.

SPC plans to complete the high priority initial date sensitive testing by the end of June  !

so that they can include the results of the evaluation in SPC's response to NRC Generic Letter 98-03.

SPC does plan to be in production on December 31,1999, due to a heavy production and shipping schedule. IT personnel will be on site on December 31 to provide support should any problems be identified. SPC managers believe that they have "no system l that couldn't be manually shut down or safely controlled." With regard to potential disruption of power, critical process control systems and ventilation systems are '

equipped with a backup emergency power supply (diesel generator).

6 Followup (92701 and 92702) 6.1 (Closed) Unresolved item (URI) 70-1257/9805-01: Failure to remove uranium during dismantlement of ductwork as required by criticality safety requirements. Inspection '

l Report 98-204 dated December 14,1998, documented NRC's review of URI 70-1257/9805-01 and was issued in conjunction with a Notice of Violation. The violation involved disassembling ductwork without verifying that the ductwork was free from visible uranium as required by the criticality safety specification. The licensee

! responded to the Notice of Violation by letter dated January 12,1999, and provided

! descriptions of corrective actions taken and additional corrective actions to be taken.

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T The inspectors reviewed the corrective actions completed and those in progress. The inspector reviewed the changes made to the ADU Line 2 ductwork to improve the geometry and ductwork inspection capability and reviewed the revision in progress to EMF-858," Maintenance Work Permit," to address the pre-job briefings. This URI is closed, but followup inspections will be performed to verify completion of the corrective actions for the identified violation.

6.2 (Closed) URI 71-0003/98-203 01: SPC's use of an SP-1 package that did not conform with the applicable Certificate of Compliance. Inspection Report No. 71-0003/98-203 dated June 2,1998, described circumstances associated with URI 71-0003/98203-01.

The resolution of these items is complete and three v.olations of NRC requirements were identified. The portions of the URI details support;ng the three violations issued in this inspection report are summarized below.

The inspection team found that SPC shipped a fresh fuel shipment using a nonconforming SP-1 package on February 25,1998. Condition 5(a)(3) " Drawings" of COC No. 9248, requires that the packaging be fabricated in accordance with SPC Drawing No. EMF-304,416, Revision 5. However, the inspectors found that an SP-1 inner container purchased from Lanzen was not fabricated in accordance with the drawing. The drawing specifies weld configurations for lugs used to close the SP-1 inner container. The inspectors found that the required weld configurations did not exist on an SP-1 inner container fabricated by Lanzen and accepted by SPC. In addition, on February 26,1998, SPC Traffic and Warehousing informed the inspection team that they made a quick check of the packages and found that all SP-1 inner containers built by Lanzen appeared to be in the nonconforming condition.10 CFR 71.12 states, in part, that a general license to transport licensed material, or to deliver licensed material to a carrier for transport. applies only to a licensee who complies with the terms and conditions of the certificate. The shipment of a package not in accordance with its j Certificate of Compliance was identified as the first example of a violation of j 10 CFR 71.12 (71-9248/9901-01).

The inspection team found that SPC allowed identification information for Model SP-1 packagings to be applied by the fabricator, Lanzen, even though the packagings were not in compliance with the design approved by NRC in Certificate of Compliance No. 9248. The application of the model number before the first use of any packaging for the shipment of licensed material without determining that the packaging has been fabricated in accordance with the design approved by the Commission is a violation of 10 CFR 71.85 (71-9248/9901-02).

The inspection team found that SPC Variance Report No. 5540, dated November 7, 1994, identified corrective actions for nonconformances identified with SP 1 inner containers purchased from .Lanzen. SPC issued General Nonconformance Report No. 6077, dated April 7,1997, to address the failure to complete the proposed corrective l actions not completed since issuance of Variance Report No. 5540. The corrective actions were not made by the time of the NRC inspection in February 1998. The continued use of the containers with identified nonconformances which are not promptly corrected was identified as the first example of a violation of 10 CFR 71.133 (71-9248/9901-03).

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7 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at ,

l the conclusion of the inspection on March 26,1999. The facility staff acknowledged the '

findings presented. The licensee did not identify any of the information discussed at the meeting as proprietary. Telephone re-exits were held on May 14,1999, and May 21, 1999, to present the violations developed as a result the investigation of an unresolved item and the licensee identified violation concerning continuing problems with shipping container nonconformances.

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ATTACHMENT l l

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee B. F. Bentley, Manager, Plant Operations D. L. Beit, Radiological Safety Training J. K. Davis, Supervisor, Receiving & Component inspection J. B. Edgar, Regulatory Compliance B. N. Femreite, Vice President, Manufacturing  ;

E. L. Foster, Supervisor, Radiological Safety l S. F. Gaines, Manager, Materials & Scheduling R. L. Gentz, Traffic & Logistics L. E. Hansen, Manager, Manufacturing Engineering J. L. Holm, Senior Quality Engineer  ;

E. J. Hough, Technical Training Specialist l B. E. Lewis, Project Engineer, Plant Engineering L. J. Maas, Manager, Regulatory Compliance C. D. Manning, Criticality Safety M. R. O'Neill, Manager, Maintenance Engineering L. C. Phillips, Traffic & Logistics T. C. Probasco, Manager, Safety W. E. Tadlock, Chemical Operations Training A. L. Trost, Quality Engineering R. S. Utter, Manager, Corporate Information Services l

INSPECTION PROCEDURES USED j i

83822 Radiation Protection 88050 Emergency Preparedness 88010 Operator Training / Retraining 86740 Transportation 92701 Followup IFis 92702 Followup Violations ITEMS OPENED, CLOSED, AND DISCUSSED Opened 71-9248/9901-01 VIO Failure to comply with 10 CFR 71.12 requirements for the terms and conditions of the certificate of compliance (Example 1 is closed; Example 2 remains open) 71-9248/9901-02 VIO Failure to comply with 10 CFR 71.85 requirements that packaging has been fabricated in accordance with the design approved before the model number is applied to the package

e 3 71-9248/9901-03 VIO Failure to comply with 10 CFR 71.133 requirements to assure nonconformances are promptly identified and corrected (Example 1 is closed; Example 2 remains open)

Closed 71-0003/98203-01 URI SPC's use of an SP-1 package that did not conform with its COC 70-1257/9805-01 URI Review failure to remove uranium during dismantlement of ductwolk as required by criticality safety requirements 71-9248/9901-02 VIO Failure to comply with 10 CFR 71.85 requirements that packaging has been fabricated in accordance with the design approved before the model number is applied to the package LIST OF ACRONYMS USED ADU ammonium diuranate CAL confirmatory action letter DCF dry conversion facility DCS distributed control system GET general employee training IT information technology MERF modular extraction / recovery facility NRC Nuclear Regulatory Commission i

PDR public document room OA quality assurance RWT radiological worker training SPC Siemens Power Corporation UO, uranium dioxide URI unresolved item VIO violation Y2K year 2000 i

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