ML20207D373

Insp Rept 70-1151/99-01 on 990201-05.No Violations Noted. Major Areas Inspected:Licensee Programs for Operational Safety,Mgt Controls,Environ Protection,Waste Mgt & Facility Support

ML20207D373
Person / Time
Site:	Westinghouse
Issue date:	02/26/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207D363	List: ML20207D360 ML20207D373
References
70-1151-99-01, 70-1151-99-1, NUDOCS 9903090315
Download: ML20207D373 (20)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION ll Docket No.: 70-1151 License No.: SNM-1107 Report No.: 70-1151/99-01 Licensee: Westinghouse Electric Corporation Facility: Commercial Fuel Fabrication Facility Columbia, SC 29250 Inspection Conducted: February 1-5,1998 Inspectors: D. Ayres, Senior Fuel Facility inspector D. Seymour, Senior Fuel Facility inspector R. Swatzell, Fuel Facility inspector Approved by: E. McAlpine, Chief, Fuel Facilities Branch Division of Nuclear Materials Safety a

Enclosure 9903090315 990226 PDR ADOCK 07001151 C PDR

1 EXECUTIVE

SUMMARY

Commercial Nuclear Fuel Division NRC inspection Report 70-1151/99-01 i

The focus of this routine, unannounced inspection was the observation and evaluation of the licensee's programs for operational safety, management controls, environmental protection, - '

waste management, and facility support. The inspection also included evaluations of the licensee's responses to several previously identified issues. The report includes inspection efforts of three regional inspectors accompanied by NRC Region ll management. The inspection identified the following aspects of the licensee programs as outlined below:

Plant Operations

• The engineered process safety controls identified in the pellet area Criticality Safety Evaluation (CSE) were being adequately implemented (Section 2.a).

• The common failure mechanism of one passive engineered moderation control with the failure of mass controls on the bulk powder feed system was not documented in the CSE (Section 2.a).

• Administrative controls identified in the CSE were not always implemented through the use of operating procedures (Section 2.a).

• Assumptions made and conclusions reached for the sintering furnace portion of the CSE would not be valid during certain maintenance activities (Section 2.a).

Manaaement Oraanization and Controls

• The licensee's Quality Assurance program for safety-significant processing equipment was adequate to ensure that such equipment would perform its desired safety function (Section 4.a).

Environmental Protection

• The licensee's environmental monitoring program was effectively implemented to monitor radioactivity released to the environment (Section 6.a).

Waste Manaaement ,

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• The licensee had implemented an effective liquid and airborne effluents monitoring program (Section 7.a).

• Discrepancies between licensee administrative procedures and license SNM-1107 concerning liquid effluent criteria were identified (Section 7.a).

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• The safety-related interlocks associated with the pellet area process active engineered controls received functional testing as specified by the CSE and license requirements

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Attachment:

Persons Contacted i Lists of items Opened, Closed, and Discussed List of Acronyms j i

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REPORT DETAILS  ;

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1. Summary of Plant Status l

I This report covered a one week period. Powder, pellet, and fuel assembly production proceeded at normal rates. There were no unusual plant operational occurrences  ;

during the onsite inspection. ,

2. Plant Operations (03) .

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a. Implementation of Process Safety Controls (O3.03)

(1) Inspection Scope Safety controls identified in the Criticality Safety Evaluation (CSE) for the f ADU Pellet Area process were reviewed to verify that they were being )

implemented in a manner to assure continuing operability and .

maintenance of safety margin. l (2) Observations and Findings t t

The inspectors observed that the safety controls identified in the Pellet I Area CSE were divided into three major categories for discussion:

Passive Engineered Controls (PEC), Active Engineered Controls (AEC),

and Administrative Controls. The inspectors reviewed each of these categories separately and then reviewed the overall assumptions used in developing the control system described in the CSE. The inspectors noted that the CSE included fault trees that showed the analyzed safety controls that were in placc to prevent a criticality accident. The ,

inspectors also noted that the CSE identified potential causes for the failure of each control, the consequences of a control failure, and the defenses in place to prevent the controls from failing.

Passive Enaineered Controls t

The inspectors reviewed the PECs identified in the CSE. PECs were

defined in the license application as controls which require no action or

other response to be effective when called upon to ensure safety. PECs .

are preferred over all other types of system controls. The inspectors observed that all of the PECs identified in the fault trees of the pelleting area CSE were in place. However, the inspectors questioned the ability  ;

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of me of the PECs to perform its intended function. The PEC in question was a slot cut into the containment system for collection of spilled uranium powder from the pelleting feed system. The slot was one of six  ;

controls identified in the CSE for protecting aga.nst the accumulation of water (for assuring moderation control) in the powder collection system.

!. The observed slot was only about 1/16 inch wide and partially plugged ,

viith powder. The inspectors observed that the slot's ability to drain water  ;

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from the system would be negated by the presence of an accumulation of powder, in effect, the failure of any mass control that limited the accumulation of powder in the collection system also caused the failure of the moisture drainage slots. Thus, the inspectors found that a common cause failure mode existed between the moisture drainage slots and each of the mass controls on the system. The inspectors observed that this common failure mode was not discussed in the CSE as were other common failure scenarios. The inspectors discussed the potential ineffectiveness of the slots with the licensee. The licensee's criticality safety staff indicated that the situation would be reviewed for potential ,

modification. The inspectors concluded that other sufficient controls were i in place to assure double contingency protection. Since this issue potentially deals with the adequacy of the CSE, it has been referred to l the NRC Fuel Cycle Operations Branch and tracked as Inspector l Follow-up Item (IFI) 99-01-01.

Active Enaineered Controls The inspectors reviewed the active engineering controls referenced in the  :

pelleting area CSE. The License Application (LA) defines active engineering controls (AEC) as controls which raquire an external signal and/or an electronic / mechanical action / operation to occur when called upon to ensure nuclear criticality safety. The inspectors noted that the CSE identified several active engineered controls (safety interlocks) for the pelleting area. The inspectors noted that the AECs were the main defense for several initiating events. The inspectors observed, during process tours, that the AECs identified in the pelleting area CSE were implemented as described. The inspectors also reviewed the maintenance of these controls which is further discussed in Section 9.a.

Administrative Controls The inspectors reviewed the administrative controls referenced in the pelleting area CSE. The inspectors noted that the administrative controls  !

referenced in the fault trees were part of the primary defense against a  !

criticality accident. The inspectors also noted that most passive engineered and active engineered controls were linked to other l administrative contrcls. These " secondary" administrative controls were l discussed in the CSE summary of initiating events, but not shown in the l fault trees. They were normally actions performed by maintenance or operations personnel to ensure that the PECs and AECs remained functional. The inspectors observed that the primary administrative controls were not always found in the operating procedures referenced on the fault trees. The most notable example of this was the administrative control for operators detecting accumulations of water in i powder processing equipment. Although the inspectors found that )

operators were trained to recognize hazardous accumulations of water in powder processing areas, there were no instructions in the operating procedurcs to implomont this administrative control. Also, the inspector i I

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i found that the licensee's administrative procedure CA-200, " Management i Control of Safety Significant Structures, Systems and Components," I stated that all safety related controls were listed in appropriate area  ;

operating procedures. The licensee agreed that all safety related  !

controls should be included in procedures and would ensure that such controls were identified in future procedure revisions.

Controls Durina Off-Normal Conditions Some processes covered by the pelleting area CSE did not include fault trees and identification of nuclear criticality safety controls. The assumptions made for these areas were that the accumulation of mass and moderator in quantities to make a criticality possible was incredible.

In one such area, the inspectors observed that the evaluation of the sintering furnaces stated that criticality was not credible, and thus double contingency was not required. This conclusion was reached although the internal furnace chamber was of non-favorable dimensions, pellets were known to spill into the furnace during normal operations, and many areas of the furnace were water-cooled. The CSE also states that there is no credible source of moderator available to the furnace chamber when pellets are in the chamber in the assumption that the furnace is at production temperatures. Furnace temperatures during normal operations would keep any moderator in the vapor phase. This assumption would not be valid when the furnace was cooled and disassembled due to a major pellet spillinside the furnace. Water was being used to cool various parts of the furnace including the exit chamber, heating element electrical connections, and optical pyrometer mounting hardware. Water was also used to humidify the fumace atmosphere. In some cases, water lines must be disassembled and/or moved in order to access the interior furnace chamber. Since controls did not exist for assuring all pellets from a spill were removed prior to cooling the furnace, the possibility existed for water to enter the furnace while pellets were in the chamber. The adequacy of the assumptions made and conclusions reached in the sintering furnace portion of the CSE will be referred to the Fuel Cycle Operations Branch for further review and tracked as IF! 99-01-02.

(3) Conclusions The engineered process safety controls identified in the pellet area CSE were being implemented. The common failure mechanism of one passive engineered moderation control with the failure of mass controls on the bulk powder feed system was not documented in the CSE. The adequacy of the discussion of common cause failures in the CSE will be reviewed by the NRC Fuel Cycle Operations Branch and tracked as IFl 99-01-01. Administrative controls identified in the CSE were not always implemented through the use of operating procedures. The licensee agreed to ensure that such controls were identified in future procedure revisions. Assumptions made and conclusions reached for the

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sintering furnace portion of the CSE would not be valid during certain maintenance activities. The adequacy of the licensee's criticality safety l reviews during such maintenance activities will be reviewed by the NRC i Fuel Cycle Operations Branch and tracked as IFl 99-01-02.

b. Housekeepina (O3.06)

(1) Inspection Scope Housekeeping associated with the storage of equipment and materials throughout the facility was reviewed to assure that significant potential hazards did not exist.

(2) Observations and Findings During process area tours, the inspectors noted that routes of egress to be used in emergencies were adequately clear of debris. The inspectors observed two isolated instances of improperly stored equipment that had contamination control implications. First, the inspectors found a used respirator being stored behind a process glove box. Although the respirator was stored in a cloth bag, the bag was not closed, thus allowing for the potential contamination of the respirator. The respirator was immediately removed and placed in an approved storage container.

The inspectors also ob%rved a plastic container used for mixing uranium powder and lubricant that had been discarded due to loss of integrity.

Although the container was obviously contaminated, it was being stored on a ventilation platform with no protection against the spread of contamination. The container was quickly removed from the area and sent to an area for disposing contaminated parts. The licensee verbally reinstructed the area workers in each of the two instances.

(3) Conclusions Housekeeping was adequate to ensure routes of egress were clear in case of emergency. Two isolated instances of poor housekeeping that had potential contamination control concerns were immediately addressed by the licensee,

c. Review of Previous Events (O3.07)

(1) Inspection Scope The licensee's evaluation and corrective actions for two previously reported events were reviewed for adequacy to prevent recurrence.

(2) Observations and Findings The inspector reviewed the licensee's evaluation of an event involving a polypack fire in a ventilated hood in the uranium recovery (UR) area on

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January 12,1999, as reported in NRC Event Notice No. 35249. The j licensee identified the cause of the fire as inadequate cooling of a press i cake residue prior to transferring it to a polypack. The residue had hot l

spots which caused the polypack to catch on fire. The fire was quickly extinguished. The fire was not considered safety significant by the ,

j licensee because there were no injuries or personnel contaminations, and

, the probability of the fire spreading outside the hood was negligible. The

, event was reportable because the fire damaged (melted) the container i which contained licensed material.

i The inspectors toured the UR area, and reviewed the licensee's corrective actions for this event, which included operator training and a procedure revision which amplified the directions for placing residue

, material in the polypack by including directions for breaking up solids and i

observing the material for hot spots. The inspectors agreed with the t i licensee's conclusions regarding the event and concluded that the

licensee's corrective actions would prevent recurrence of this event.  ;

e l The inspectors also reviewed the licensee's actions in response to a fire l '

! discovered in a Uranium Recovery and Recycle System (URRS) l decentamination cutting room on January 12,1999. Plasma and

! acetylene torches are used in this room to cut up large metal compwnts l to facilitate their handling and decontamination. The fire occurred after  ;

cutting work was completed. The licensee determined that the sparks from the cutting room work ignited some combustible liquid in a small ,

1 (approximately one gallon) open container left in the cutting room. The j fire was quickly discovered and extinguished. There were no injuries or

equipment damages.

l l The licensee performed an investigation of this event and determined it  ;

j was safety significant and could have become larger. The burning open

container of combustible liquid was next to other closed containers of l combustible liquids, including one five-gallon container. The licensee l determined that the combustibles were left in the cutting room without 1

authorization (i.e., they were " dumped"), and that combustible materials ,

were supposed to be moved out of the cutting room prior to starting hot .

I work. The licensee also determined that the hot work procedure, which  !

J. required an operator to remain in the area for 30 minutes after hot work j

was completed, was not followed.

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The licensee's corrective actions included chemical area operator training on labeling, storage, and disposal of flammable materials, and on I j acquiring proper authorization prior to leaving materialin the URRS area;  !

and cutting room operator training on hot work permits and hot work procedure requirements (checking the room for combustibles, maintaining a fire watch during hot work and for 30 minutes following hot j work). The inspectors reviewed and verified the licensee's corrective actions and concluded that they were thorough and complete, and would j preclude recurrence of this event. The inspectors observed cutting room I'

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6 hot work in progress and noted a fire watch was implemented as required by procedure.

The failure to follow procedure requirements for storage and labeling of combustible materials, for checking the cutting room for combustibles, and for maintaining a fire watch for 30 minutes following the completion of hot work is identified as a violation. Because of the prompt corrective actions implemented and pursued, this non-repetitive, licensee-identified and corrected violation is being treated as a non-cited violation (NCV 70-1151/99-01-03) consistent with Section Vll.B.1 of the NRC Enforcement Policy.

(3) Conclusions The licensee's response to Event No. 35249 was adequate to prevent future UR ventilation hood fires due to hot residues. The licensee's corrective actions for the cutting room fire were thorough and complete and should preclude recurrence of this event. A non-cited violation was identified for failure to follow procedures.

3. Fire Safety (O4)

a. Follow-up on Previousiv identified issues (O4.11)

(1) Inspection Scope A previously identified issue was reviewed to determine whether sufficient licensee review and/or action had been completed to permit closure.

(2) Observations and Findings The inspectors reviewed the licensee's actions taken in response to IFl 97-05-01, which dealt with revision of the Pre-Fire Plan (PFP) due to reorganizations and retirements. The licensee also provided details of

, fire detection and suppression equipment, the location of vents, doors and dampers, as well as electrical control boxes. The inspectors reviewed selected portions of the planned revision to the PFP. The licensee indicated that the revisions would be implemented by February 28,1999. Based on this review, IFl 97-05-01 is closed.

(3) Conclusions Licensee actions for IFl 97-05-01 were scheduled for completion by February 28,1999. Although not fully implemented at the issuance of this report, the actions already taken by the licensee were adequate to

, close this item.

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4. Manaaement Oraanization and Controls (O5)

a. Quality Assurance Proarams (OS.05)

(1) Inspection Scope The licensee's Quality Assurance program was reviewed to verify that it adequately addressed methods for controlling the functionality of safety-significant processing equipment.

(2) Observations and Findings The inspectors reviewed the implementing procedures associated with '

the Quality Assurance program. The inspectors observed that the program was largely a subset of the facility's Process Safety Management program, and was implemented by a series of procedures for the various aspects of controlling the functionality of safety equipment.

The inspectors observed that procedures for configuration management and process hazard analysis helped control the quality of the design and installation of safety-significant process systems. The inspectors

- observed that these procedures utilized a " graded approach" system of hazard rankings so that potential process hazards with the greatest risks received the greatest attention. The inspectors also noted that the Quality Assurance program included procedures that assigned responsibilities to each of the various management functions involved in ensuring the availability and reliability of safety controls.

(3) Conclusions Based on a limited review, the licensee's Quality Assurance program for safety-significant processing equipment appeared to adequately ensure that such equipment was designed, installed, operated and maintained to perform its desired safety function. The adequacy of the implementation of the program will be assessed at a future inspection.

5. Physical Protection (S2)

a. Follow-up on Previousiv identified Issues (S2.17)

(1) Inspection Scope Three previously identified issues were reviewed to determine whether sufficient licensee review and/or action had been completed to permit closure.

(2) Observations and Findings The inspectors reviewed the licensee's actions taken in response to IFl 98-04-01, identified as a result of an inaccuracy in the Physical n

8 Security Plan (PSP) dealing with access authorization. The inspectors reviewed Section 4.1.3.2, Identification, of the PSP and determined that the plan had been revised and clarified. Based on this review, IFl 98-04-01 is closed.

The inspectors reviewed the licensee's actions taken in response to Violation (VIO) 98-04-02, identified because of inaccuracies in the PSP with respect to fences, gates, access portals, security equipment, drawings in the PSP, and fence line signs. The inspectors reviewed the licensee's corrective actions as delineated in the licensee's response (dated July 20,1998) to the violation, and verified the site changes, including the new signs, changes to the fence, and the revisions to the PSP. The inspectors noted that a formal quarterly audit program was initiated to preclude recurrence of the violation. The inspectors reviewed quarterly audit checklists for September and December 1998, and noted that only minor deficiencies were identified. Based on this review, VIO 98-04-02 is closed.

The inspectors reviewed the licensee's actions taken in response to VIO 98-04-03, identified because of a failure by the licensee to properly escort a commercial vehicle and its driver. The inspectors reviewed the licensee's corrective actions to the violation, which included providing escorts to commercial vehicles (the escort drives a small cart alongside of the commercial vehicle). The inspectors also observed the escorting process to verify it was as stated. Based on this review, VIO 98-04-03 is closed.

(3) Conclusions Licensee corrective actions were adequate for three previously identified issues; IFl 98-04-01, VIO 98-04-02, and VIO 98-04-03 are closed.

6. Environmental Protection (R2)

a. Monitorina Proaram implementation and Results (R2.01 and R2.02)

(1) Inspection Scope The licensee's monitoring results for groundwater, soil, vegetation, and surface water samples were reviewed to ensure that radionuclides were not being released to the environment in significant quantities. The licensee's response to sample results that exceeded action levels were reviewed to ensure adequate steps were taken to prevent releases above regulatory limits.

(2) Observations and Findings The inspector reviewed the gross alpha results for the annual vegetati-on samples (four locations) and observed that the sample from one location

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had exceeded the 15 picocuries per gram (pCi/g) limit (19.1 pCi/g). The -

licensee obtained and analyzed an additional sample with results significantly lower than the 15 pCi/g limit (0.69 pCi/g). The initial vegetation sample's elevated alpha activity was attributed to sampling and analytical error. Soil samples from the site showed that the uranium activity levels were consistently lower than the licensee's action level of 10 pCl/g for all four sampling locations. The inspector also noted that monthly 1998 surface water samples from the site's three sampling locations showed that the gross alpha (range of 0.5 to 51 pCi/l) and gross beta (0.4 to 20 pCi/l) activities were consistently below the licensee's action levels of 300 pCl/l (gross alpha) and 600 pCi/l (gross beta). The inspector also reviewed results from sampling of environmental air stations at the licensee's facility and observed that the reported weekly activity concentrations were consistently less than the licensee's action level of 5.00E-15 microcurie per milliliter (pCl/ml).

The inspector reviewed the licensee's quarterly (first three quarters of 1998) groundwater sampling results and observed that the gross beta activity levels were significantly greater than the licensee's action level of 50 picocuries per liiter (pCl/l). Wells 7 (average of 627 pCi/l),15 (average of 237 pCi/l),30 (157 pCi/l average), and 32 (1633 pCl/l) exhibited the greatest beta activity levels. The elevated gross beta activity levels had been identified in a previous inspection and the inspector's follow-up on the licensee's actions is discussed in Section 6.b of this report.

(3) Conclusions The licensee's environmental monitoring program was effectively implemented to monitor radioactivity released to the environment. The licensee implemented timely investigations and corrective actions in response to results which exceeded action levels. The environmental data indicated that airborne radioactivity was not at significant concentrations at the various onsite air monitoring stations. The soil and vegetation sample data indicated that radioactivity was not significantly accumulating in the environment.

b. Follow-up on Previousiv Identified issues (R2.08)

(1) Inspection Scope The licensee's progress on four IFis associated with the Environmental Protection Program were reviewed to determine whether sufficient licensee review and/or action had been completed to permit closure.

(2) Observations and Findings IFl 98-01-02 involved a routine soil sample taken at environmental air sampling station number 4 for split analyses between the licensee and

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l l 10 the NRC for confirmatory measurement purposes. The inspector reviewed the gross alpha and isotopic uranium results for the licensee l (3.48 pCi/g) and NRC analyses (2.86 pCi/g) and found that the I difference between the two measurements was not statistically l significant. This item is closed.

IFl 98-01-03 involved an observation that the gross alpha results for the  ;

licensee's surface water samples were elevated and had exhibited wide variability. The inspector reviewed the licensee's most recent results for l surface water samples and observed that the licensee's most recent gross alpha results for surface water samples (range of 0.50 to 51.0 l pCi/l) were consistently below the licensee action level criteria (i.e. gross l alpha of 300 pCi/l). This item is closed. j l

IFl 98-01-04 concerned the gross beta activity levels in the licensee's l groundwater being elevated above the action levels specified in license l SNM-1107. The inspector observed that the licensee had initiated an I investigation into the elevated gross beta activity levels in groundwater samples. The licensee determined that the increase in activity was most probably due to a leak from a concrete trench in the cylinder j recertification building which had contained contaminated liquid spillage l

from the hydrostatic test process. This building was observed to be hydraulically upgradient from wells 7 and 32 which exhibited the highest beta concentrations. In addition, technetium (Tc-99) was confirmed by l the licensee as a significant contributor to the beta activity levels in these I wells. The trench was subsequently grouted and the cylinder recertification operation was changed to prevent liquid spillage to I eliminate this site as a primary source for contamination of groundwater. i These modifications were completed in October 1998 and the licensee l was continuing to monitor the affected wells in order to determine the effectiveness of the recently implemented corrective actions. Current beta levels in groundwater monitoring wells 7 and 32 remain at consistent levels (approximately 600 and 1700 pCi/l). Technetium-09 levels in these l wells are currently at levels below environmental safety significance. This l item is closed. l l

IFl 98-01-05 referenced a line break in the Congaree river discharge line near the diffuser observed on January 14,1998. The inspector observed that the licensee had acquired soil samples in the vicinity of the leak and that no substantial contamination (<10 pCi/g) was observed. In addition, responsive repairs to the discharge line were made on January 15,1998, and appropriate investigations were being conducted in order to ensure the long term integrity of the discharge line piping. This item is closed. l (3) Conclusions The licensee's responses to four previously identified issues in the j environmental program were adequate. The licensee continues to monitor groundwater sample locations where elevated beta radioactivity 1

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7. Waste Manaaement (R3)

a. Liauid and Airborne Effluent Monitorina Results (R3.02 and R3.04)

(1) Inspection Scope The licensee's program for the monitoring of liquid and airbome effluents was reviewed to verify releases were within established safety limits. The review consisted of an examination of the licensee's liquid and airborne sampling locations, the administrative procedures for implementing the liquid and airborne effluents program, the semi-annual effluent monitoring report for the first half of 1998, and the available third and fourth quarter 1998 liquid and airborne discharge summaries.

(2) Observations and Findings The inspector reviewed the semi-annual report for airborne effluents and noted that the total quantity of radioactivity released due to uranium isotopes (gross alpha determination) was approximately 0.19 millicurie (mci) during the first half of 1998. This appeared to be a consistent level in relation to the total airborne effluent of approximately 0.43 mci of uranium released in all of 1997. A subsequent review of available second half 1998 data for weekly airborne effluents indicated that the weekly gross uranium activities were generally consistent with that experienced during the first half of 1998. It was observed that one weekly period in July 1998 exhibited an elevated uranium activity concentration (approximately 0.03 mci), primarily due to a defective High Efficiency Pa ticulate Air (HEPA) filter in the ADU Scrubber 3A exhaust line. The licensee reacted to this situation according to internal procedures and promptly initiated an investigation and implemented appropriate corrective actions (i.e. replaced HEPA filter). This effectively reduced the effluent radioactivity concentration to an acceptable level. The inspector also toured several of the plant's stack sampling stations and observed that modifications to several of the airborne effluent sampling locations had been completed per previous NRC observations in order to enhance the representativeness of the samples.

The inspector reviewed the licensee's procedures for implementation of the liquid effluents monitoring program. The inspector noted that several discrepancies existed between the procedures and the license requirements as to effluent limit concentrations. Procedure COP-811601, "On-Line Gamma Activity Monitors and Quarantine Tanks System Operation," stated that a limit of 24 parts per million (ppm) uranium (U) was used as guidance for suspension of discharges to the water treatment facility (WTF) from the main chemical processing areas. The limit of 24 ppm U (5.5E-5 uCi/mi based on four percent U-235 content)

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12 exceeded the criteria of 3.0E-5 uCi/ml as stated in license SNM-1107. In addition, procedure RA-401, " Environmental Control Requirements Mandated By 10 CFR20 and NRC License SNM-1107," stated that a setpoint of 3.6E-5 uCi/ml for the online gamma spectroscopy system was used to automatically divert flow from the WTF to diversion tanks. In discussions with personnel, the inspector determined that these procedural discrepancies were not significant issues due the resulting ..

Iow offsite dose levels (i.e <0.002 millirem / year) associated with the '

procedural limits. The inspector also noted that procedure COP-830509,

" Release of F-1165 Effluent for Processing," specified that discharges from the WTF should be less than 0.2 ppm U which exceeds the license criteria of 0.05 ppm U. The inspector discussed this with the licensee who indicated that the license requirement of 0.05 ppm U was a typographical error, and should have been 0.5 ppm U. Again, this discrepancy was not viewed as being safety significant due to the low offsite public exposures as a result of the licensee's radiological liquid effluents. However, the inconsistencies between the limits in the operating procedures and license requirements will be resolved by the licensee through modification of procedures and/or license amendment.

The correction of these items will be tracked as an IFl (IFl 99-01-04).

The inspector reviewed the semi-annual report for liquid effluents for the first half of 1998. The inspector observed that approximately 21 mci due to uranium isotopes were released in comparison to the total 1997 quantity of 53 mCl. Data reviewed for the liquid effluent uranium concentrations for the remainder of 1998 (approximately 20 mci released through October 1998) indicated that uranium activity totals in liquid effluents should remain consistent with 1997 data.

(3) Conclusions The licensee had implemented an effective liquid and airborne effluents monitoring program and had met the radioactivity release and as low as reasonably achievable (ALARA) constraint criteria in 10 CFR Part 20.

The total radiological emissions due to uranium constituents in liquid and airborne effluents were consistent with the 1997 reported quantities based upon the preliminary results obtained for the first three quarters of 1998. Discrepancies between licensee administrative procedures and i license SNM-1107 concerning liquid effluent criteria were identified, but I were determined to be of low safety significance due to calculated offsite l dose projections. These license and procedural discrepancies will be l corrected by the licensee, and will be tracked by NRC as an IFl. l

b. Waste Shiocina (R3.08)

(1) Inspection Scope The inspector reviewed the licensee's waste shipping records to verify that proper information was documented to ensure safety in conjunction  :

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13 with 10 CFR Part 20, Appendix G, and 10 CFR Part 61. The inspector also reviewed calibration records for the gamma spectroscopy drum counter system which is used to determine the U-235 content in radwaste shipment containers.

(2) Observations and Findings The inspector reviewed three waste manifest shipping documents for November and December of 1998. The inspector observed that the licensee was using the appropriate NRC forms as required by Appendix G of 10 CFR Part 20 and that the required information (uranium content, activity levels, waste type, etc.) was being provided. The inspector observed that the licensee had made significant improvements in the information provided on the waste manifests in response to previous NRC observations. In addition, the licensee had performed and received the appropriate notifications and documentation for the tracking of Low Level Waste (LLW) shipments. The inspector also reviewed the calibration, quality control, and background check records of the licensee's drum counter system, and found that the licensee was performing the required system analyses at the prescribed frequencies.

(3) Conclusions The licensee was adequately ensuring safety in accordance with the requirements of 10 CFR Part 20, Appendix G, and 10 CFR Part 61 for the documentation and characterization of low level radioactive waste (LLRW) shipments.

8. Transoortation (R41

a. Follow-up on Previously identified issues (R4.07)

(1) Inspection Scope The items associated with the licensee's response to VIO 97-01-04 were reviewed to determine whether sufficient licensee review and/or action 1 had been completed to permit closure.

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(2) Observations and Findings Violation 97-01-04 involved the failure to inspect neutron absorber plates on certain fuel assembly shipping containers within the required five-year i time frame, and subsequently using those containers to transport fuel I assemblies. The corrective actions included removing the affected I containers from service until inspsetions could be performed and modifying the Certificate of Compliance to enable the inspection of the neutron absorber plates without disassembly of the shipping containers.

The inspector found that these items had been completed in March 1997.

This issue is closed. i l

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(3) Conclusions

[ The licensee's actions in response to VIO 97-01-04 were adequately  ;

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9. Maintenance / Surveillance (F1) l l a. Conduct of Maintenance and Surveillance Testina (F1.01 and F1.06)

(1) Inspection Scope

.The conduct of maintenance was reviewed for the safety-related '

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interlocks associated with the pellet area AECs to verify that the interlocks received functional testing at specified by the CSE and the l LA. The functional tests verify that the interlocks will perform as intended to ensure criticality safety during a process upset.

(2) Observations and Findings  :

i l The inspectors reviewed the procedures used for the functional testing 8

of the safety-related interlocks. The inspectors also reviewed j documentation for the performance of these functional tests for 1997 and I 4 1998, and discussed the test results with cognizant licensee personnel.

No test deficiencies were noted. The inspectors noted that two of the safety interlocks were only recently identified as safety significant, and had not yet been placed into the functional testing program. The licensee indicated that these interlocks would be functionally tested by April 30, 1999. The inspectors concluded that the functional tests of the pellet area safety interlocks were performed as specified by the CSE and the

. LA.

!< The inspectors noted that the information flow (component identifications, 4

nomenclature, etc.) from the CSE to the associated procedures was not

always smooth, and required an in-depth knowledge of the system and procedures. The licensee acknowledged the inspector's comments, and j indicated that they weta in the process (as part of their overall Safety i- Management improvement Process initiative) of evaluating and reviewing j procedure format and nomenclature associated with safety controls. J (3) Conclusions 1

.l The safety-related interlocks associated with the pellet area process active engineered controls received functional testing as specified by the ,

CSE and the LA.

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b. Follow-uo on Previousiv Identified Issues (F1.08)

-(1) lospection Scope  :

The status of the licensee's corrective actions in response to VIO 98-02-02 (failure to adequately utilize computer programs to .

Initiate work orders for programmed maintenance) was reviewed for possible closure. The licensee's self-evaluation of the adequacy of their post-maintenance functional testing of procecs equipment and control  ;

software in response to IFl 98-02-03 was also reviewed for possible closure.

(2) Observations and Findings l The inspector reviewed the status of the licensee's corrective actions in  !

response to VIO 98-02-02. This violation involved five examples where '

the licensee failed to conduct maintenance activities in accordance with the license requirements for using computer programs and/or approved  :

procedures. The corrective actions for three of the five examples were l deemed adequate during a previous inspection report (70-1151/98-09). l The long-term corrective actions for the remaining two examples involved  :

implementing the 14 recommendations made by a licensee investigation l team. The inspector observed that some of these recommendations included improving the system for identifying, documenting, and  ;

communicating the presence of safety significant controls. These ,

recommendations were implemented by developing a regulatory policy _

for defining safety-related controls, and developing an administrative  ;

procedure defining areas of management responsibility for the availability  :

and reliability of safety controls. The inspector observed that the other recommendations primarily involved improving the system for designing, i documenting, and performing maintenance and functional tests on safety i controls. These recommendations were implemented by revising various '

applicable maintenance procedures and developing logic flow charts for  ;

determining the appropriate step to be taken during repairs involving i

safety controls. The implementation of these corrective actions are  ;

adequate. The two issues (VIO 98-02-02 and IFl 98-02-03) are closed.  :

(3) Conclusions The licensee's actions in response to VIO 98-02-02 and IFl 98-02-03 I were adequate to consider both of these items closed. l 1 l J

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10. Emeroency Preoaredness (F3)

a. Follow uo on Previousiv identified issues (F3.07)

(1) Inspection Scope The licensee's response to IFl 97-05-03 for developing an emergency preparedness audit checklist / plan was reviewed to determine whether sufficient licensee review and/or action had been completed to permit closure.

(2) Observations and Findings The inspector reviewed the emergency preparedness audit plan developed by the licensee dated November 30,1998. The inspector observed that the plan included specific audit objectives; requirements for inspecting program changes, procedures, training and staffing; reviewing the coordination with off site agencies; and evaluating drills, exercises, equipment, and supplies. The inspector found the plan to be a good effort toward identifying the necessary focus for an independent audit.

This issue is closed.

(3) Conclusions The licensee's emergency preparedness independent audit ,9lan was adequate.

11. Exit interview The inspection scope and results were summarized on Februery 5,1999, with those persons indicated in the Attachment. The inspectors described the areas inspected and discussed in detail the inspection results. Although proprietary documents and processes were reviewed during this inspection, the proprietary nature of these

documents or processes has been deleted from this report.

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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED ,

Licensee Personnel

• D. Precht, Acting Plant Manager

• R. Ervin, Senior Engineer, Chemical Process Engineering

• W. Goodwin, Manager, Regulatory Affairs

• N. Parr, Manager, Chemical Process Engineering

• C. Perkins, Manager, Maintenance

• D. Williams, Senior Engineer, Regulatory Affairs '

• J. Hooper, Senior Engineer, Regulatory Engineering and Operations

• S. Gant, Senior Engineer, Regulatory Engineering and Operations

• R. Fischer, Senior Engineer, Regulatory Engineering and Operations

• E. Reitler, Fellow Engineer, Regulatory Engineering and Operations Other Licensee employees contacted included engineers, technicians, security and office personnel.

NRC Personnel

• D. Collins, Director, Division of Nuc! car Material Safety, Region 11

• Attended exit meeting on February 5,1999. l l

i INSPECTION PROCEDI RES USED 4

IP 84850 Radioactive Waste Management-inspection of Waste Generator Requirements IP 88005 Management Organization and Controls IP 88020 Regional Nuclear Criticality Safety inspection Program IP 88025 Maintenance and Surveillance Testing IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Follow-up on inspector Problems j IP 92702 Follow-up on Corrective Actions For Violations / Deviations LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Ooened -

IFl 99-01-01 Common failure mode between the moisture drainage slots and the mass controls in powder collection system (Section 2.a.(2))

! IFl 99-01-02 Adequacy of the assumptions and conclusions in the sintering furnace portion of the pelleting area CSE (Section 2.a.(2))

1

2 NCV 99-01-03 Failure to follow procedures while performing hot work in the URRS Cutting Room (Section 2.c.(2))

IFl 99-01-04 Review and track the progress of the licensee's recommended corrective action of submission of license amendments to modify license liquid effluent release criteria (Section 7.a.(2))

l Closed i NCV 99-01-03 Failure to follow procedures while performing hot work in the URRS Cutting Room (Section 2.c.(2))

IFl 97-05-01 Revision of the Pre-Fire Plan (Section 3) I IFl 98-04-01 Revision of the Security Plan (Section 5)

VIO 98-04-02 Revision of the Physical Security Plan (Section 5) i VIO 98-04-03 Failure of licensee to properly escort a commercial vehicle and driver  !

(Section 5)  !

l IFl 98-01-02 Compare analytical results of a split soil sample from environmental )

stationary air sample station (Section 6.b.)

IFl 98-01-03 Review licensee's determination for the wide variability and slightly elevated surface water sample gross alpha results (Section 6.b.)

IFl 98-01-04 Review the licensee's investigation into the observed elevated gross beta ground water sample results (Section 6.b.) I IFl 98-01-05 Review the licensee's completion of the action plan items for the i river discharge line break at the Congaree River near the diffuser (Section 6.b.) ,

VIO 97-01-04 Failure to re-inspect the two model MCC new fuel shipping containers I (M140 and M230) within the five year frequency in accordance with I the Maintenance Prograrn specified in the supplement to the Certificate of Compliance (Section 8)

VIO 98-02-02 Failure to adequately use computer programs to initiate work orders for i programmed maintenance (Section 9.b.)

IFl 98-02-03 Review the licensee's self-evaluation of the adequacy of their post-maintenance functional testing of process equipment and control software (Section 9.b.)

IFl 97-05-03 Develop an audit checklist and audit plan detailing the areas of the audit and the acceptance criteria (Section 10)

3 LIST OF ACRONYMS USED ADU Ammonium Diuranate AEC Active Engineered Controls ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations CM. Criticality Management CSE Critical Safety Evaluation HEPA High Efficiency Particulate Air ,

IFl inspector Follow-up item IP Inspection Procedure LA License Application LLRW Low Level Radioactive Waste LLW Low Level Waste pCi/ml microcurie per milliliter mci millicurie NCV Non-cited Violation .

NRC Nuclear Regulatory Commission PEC Passive Engineered Controls ,

pCi/g picocuries per gram pCi/l picocuries per liter PFP Pre-Fire Plan PM Preventative Maintenance ppm parts per million PSP Physical Security Plan l SNM Special Nuclear Material Tc-99 Technetium-99 U Uranium UR Uranium Recovery i URRS Uranium Recycle and Recovery System 3

VIO Violation WTF Water Treatment Facility 1

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