ML20210E224

Forwards Feeder Rept Re Assessment at Ge,Wilmington,Nc on 861006-10.W/exception of Solid Waste Collection Program in FMO & 60-day Storage W/O Inventory Measurement,Licensee Has Integrated,Technically Sound Nuclear Criticality Program

ML20210E224
Person / Time
Site:	07001113
Issue date:	11/19/1986
From:	Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Kahl J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8702100252
Download: ML20210E224 (8)

Text

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MEMORANDUM FOR: John B. Kahle, Project Engineer Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards, RII THRU: W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS FROM: George Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

SUBJECT:

FEEDER REPORT, ASSESSMENT AT GENERAL ELECTRIC COMPANY, WILMINGTON, NC, OCTOBER 6-10, 1986, DOCKET NO. 70-1113 Enclosed is the subject Feeder report, bith the exception of the solid waste collection program in FM0 and sixty day storage without inventory measurement, GE has an integrated, technically sound nuclear criticality safety program. Recommendations for resolving the solid waste problem are given in the report. The rest of the program appears to go well beyond license requirements and should be considered a safety program strength, per the discussion in your Assessment Plan.

' Original Signed By:

George H. Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

Enclosure:

As stated DISTRIBUTION w/ encl .

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SUBJECT:

FEEDER REPORT - ASSESSMENT AT GENERAL ELECTRIC CO.,

WILMINGTON, NC, OCTOBER 6-10, 1986, DOCKET NO. 70-1113

References:

1. TI 2600/1, Inspection of Plant Operations at Uranium Fuel Fabrication and Conversion Facilities

2. Region II Operational Safety Assessment Plan INTRODUCTION This report has been submitted by the Nuclear Criticality Safety Member of the team assembled by Region II to satisfy the requirements of T12600/1 (Ref.1).

The report follows the format prescribed in Ref. 2.

I. CONVERSION AREA A. Nuclear Criticality Accident Potential There is a nuclear criticality accident potential in this area because enriched uranium solutions and wet and " dry" enriched uraniun compounds are processed in this area. If the uranium solution is not maintained in well-spaced favorable geometry equipment or if the " dry" uranium is allowed to be moc'erated, nuclear criticality could occur.

B. Licensee's Nuclear Criticality Safety Controls In the ADV conversion area, GE relies primarily on favorable geometry control to assure nuclear criticality safety. In the vaporization area, the GECO con-version area, and the powder storage areas, the primary nuclear safety control is moderation control. Liquid wastes are subject to concentration control and solid wastes are subject to mass control. Mass control is also imposed on many of the units which are subject to favorable geometry control.

C. Adequacy of Nuclear Criticality Safety Controls The basis for safety starts with a corporate policy (NEDE 24697) which establishes the number of criticality controls which must be provided and the margins of safety for normal and potential upset conditions. Some of the policy requirements have been incorporated into the SNM license for the Wilmington facility.

NEDE 24697 establishes a hierarchy of controls. The preferred control is a passive one such as favorable geometry design. The next type of control is an automatic engineering control (AEC). The third and least preferred type of control is administrative in nature, e.g., mass control.

2 The specific nuclear criticality safety controls for a process station are identified by a documented safety analysis and an independent technical review.

Both the analysis and review are performed by personnel who possess, as a minimum, the qualifications specified in the license. For changes to existing facilities, area management initiated a Facility Change Request (FCR) form.

Nuclear Safety Engineering (NSE) personnel review the FCR to determine whether a criticality control evaluation is needed. Area management or proiect management may have to supply additional information which is also documented.

When the nuclear criticality evaluation is completed, NSE management and area management approve the criticality controls for the proposed activity.

Approval of the nuclear criticality controls is recorded on the FCR.

Operators are trained to follow written, approved procedures which are avail-able in each area. NSE and area management conduct quarterly audits of each operating area to ensure that procedures are followed and that procedures are adequate to ensure safety.

D. Maintenance and Surveillance No report has been prepared by the Nuclear Criticality Safety Team Member.

Instruments and controls important to nuclear criticality safety were identified to the Operations Engineer Team Member during the assessment.

E. Adequacy of Licensee's Programs to Mitigate (the Effects of)

Postulated Potential Nuclear Criticality Accidents The licensee has an evacuation plan and re-entry plan which was not reviewed during this assessment.

II. SCRAP REC 0VERY AREA A. Nuclear Criticality Accident Potential Scrap recovery areas include the solid waste collection and sorting areas (Decon Room) in FP0, the outdoor storage pads and counting facility, and the incinerator. In UPMP, areas include the oxidation area, liquid rad waste, liquid fluoride waste, liquid nitrate waste, dissolution, and solvent i

extraction.

There is a nuclear criticality accident potential in this area because enriched uranium is accumulated in arrays of boxes where the contents of each box is an estimated safe mass of uranium. The incinerator is operated on a continuous safe batch operation where the inventory is based on uranium mass input minus the mass output difference. The UPMP is based on combinations of favorable geometry - limited mass operations except that some of the FM0 feed surge tanks and waste collection tanks are large nonfaverable geometry. Also, the UPMP equipment uses favorable geometry control for a specified maximum enrichment or i

en-ichments. Also, GE is authorized to possess uranium which is enriched to a higher level than the enrichment authorized in UPMP.

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3 B.- - Licensee's Nuclear Criticality Safety Controls Combustibles contaminated with enriched uranium are collected in 4-foot cubic

' boxes and are controlled to an estimated safe mass by operating procedures.

The loaded boxes are moved to the New Decon Room for final sorting and packaging for long-term outdoor storage. The inventory of a box is not

-measured for 60 days.

Noncombustibles are processed in the same way as combustibles until the inventory is determined. Then the boxes are scheduled for disposal.

The incinerator is operated on a safe batch basis. Uranium with an assumed U-235 enrichment is measured into the system. As ash is removed, the uranium and U-235 content is measured ai.d the system inventory is adjusted accordingly.

.The incinerator feed conveyor is operated by an AEC which prevents charging the incinerator if the inventory exceeds the batch limit.

.The non-favorable geometry tanks for collecting FM0 waste streams for feed into UPMP are controlled by concentration control and AECs. The same situation is true for non-favorable geometry tanks between UPMP and liquid waste treatment.

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The oxidation area is' subject to safe mass and volume controls which are assured by AECs.

The dissolution and solvent extraction areas are based on favorable geometry and limited mass controls which are ensured by AECs.

C. Adequacy of Nuclear Criticality Safety Controls The mass control on solid waste boxes during the FMD solid waste collection, sorting, and storage during the 60 day isotope grow-in period is based on procedural control. There are no positive controls on batch control during this tine; the nuclear safety control program is not adequate. The soild waste collection boxes in UPMP do have monitors which are indicative of uranium content.

The AECs in UPMP are monitored in the UPMP control room. The process lab near the control room provides frequent information to the control room operator.

The control room operator is promptly aware of the process lab information and/or conditions where AECs require an operator to take action. In other situations, the operator is aware that AECs have shut down the process. The close interaction between the control room operator monitoring the AECs, the frequent input of information from the process lab, and the automatic response of the AECs provide adequate nuclear safety control.

GE has a procedure whereby AECs in UPMP cannot be changed without NSE review and approval. Each change of an AEC is made using the FCR process. Following review and approval by NSE, a preoperational audit is performed to assure that indicated AEC response in the control room actually takes place in the UPMP process area.

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4 The writer was shown an extensive preoperational audit plan which was to be performed following upgrade.of the incinerator controls, including AECs. The NSE-individual who had been involved in the incinerator modifications was scheduled to participate in the audit. The writer also saw evidence of other preoperational audits in UPMP following minor FCR approvals.

D. Maintenance and Surveillance ,

Within UPMP, an annual surveillance program is conducted to verify the AECs-are performing as-designed and controlled. The program is new because UPMP has just recently become operational. This program is over and above the routine i maintenance program discussed by other team members.

E . .. Adequacy of Licensee's Programs to (the Effects of) Mitigate Postulated Accidents

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See I. E. above III. FASTE TREATMENT AREA A. Nuclear Criticality Accident Potential There is a nuclear criticality accident potential in the liquid waste treatment l area because some of the low-concentration enriched uranium solutions are l collected in large tanks for final treatment and release.

The accident potential for solid waste was discussed in Section II. This subject will not be treated further.

8. Licensee's Nuclear Criticality Controls Liquid is collected in nonfavorable oeometry tanks and then, based on the uranium concentration, processed through final treatment in safe batch

, quantities. Uranium solids from liquid waste treatment are collected in 5-gallon containers and treated as scrap or waste, depending on the uranium '

content. .

C. Adequacy of Nuclear Criticality Safety Controls

' NSE has done some dynamic analyses for UPMP to determine the time that some of the UPMP process could be out of control before a minimum critical mass could be accumulated. While this dynamic analysis is subject to a variety of basic assumptions, it does show that considerable time is available for the process lab in UPMP to detect a significant process upset.

j The collection of uranium solids in 5-gallon containers is based on a combina-tion of favorable geometry containers and safe wet masses of uranium. Concen-tration controls, which are supported by safety controls in FM0 and UPMP are adequate. ,

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D. Maintenance and Surveillance Program ,

See I.D. above. .

Adequacy of Licensee's Program to Mitigate (the Effects of) Postulated E.

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See I.E. above-IV. HYDR 0 GEN SINTERING FURNACE AREA No review of this area was performed. All low-enriched uranium is in ceramic s form and processed in a favorable geometry (slab) configuration. Process equip-ment is designed to keep the ceramic material in this geometry. The process is normally dry. The criticality accident potential, composed to the other areas described above, is quite low. Explosions and fires can be postulated.

Explosions could possibly cause the slab geometry to be lost but this accident; situation would tend to disperse uranium in the area. Moderation was assumed I to be present in establishing the slab geometry so that fire-suppression water should not affect nuclear safety.

V. ' STRENGTHS AND WEAKNESSES OF NUCLEAR CRITICALITY SAFETY PROGRAM A ~. Strengths of Nuclear Criticality Safety Program The NSE group is essentially independent of all production operations. The size of NSE' staff allows qualified individuals to specialize in different areas of the facility.

The FCR process requires process engineering or production engineering to provide the information that is needed for NSE to perform the nuclear criticality safety analyses. When the nuclear safety controls have been identified by NSE, the Area Manager signs the FCR to show that he approves of '

the controls for his area of responsibility. These nuclear safety controls are then provided to the operating staff in the form of written procedures which are also approved by the area snanager and NSE. '

The nuclear criticality safety evaluations are very detailed and well documented. Another individual can review the document for auditing or as the basis for a future FCR. The independent review process was evident because a change in the evaluation or conclusion was noted occasionally on the FCR.

The quarterly audit program involves.an NSE representative and an area manage-ment representative. This dual audit demonstrates plant management concern.

The detailed audits following an FCR approval or prior to new plant startup are very extensive. The detailed audit plan is approved by process engineering and NSE and is conducted by both groups. This is particularly effective where AECs are involved.

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Area management can make changes without the FCR process if the change does not t impact on nuclear criticality safety. As a backup,-however, the changed written procedure must be approved by NSE. With a good nuclear safety training program, this program can eliminate unnecessary records generation.

B. Weaknesses of Nuclear Criticality Safety Program Significant'Wehkness: Combustible and noncombustible wastes, contaminated with enriched uranium, are collected in 4-foot cubic boxes, processed in the New Decon Room, and stored for 60 days before the uranium content is measured.

During this period of time, safe mass control is based on operator judgment.

No positive control exists on this material.

Recommendation: GE should establish positive nuclear criticality controls for the collection and processing of solid wastes. If the controls are not precise, consideration should be given to immediate incineration to eliminate the 60 day accumulation of such boxes of combustible material.

Minor Weakness: One recently transferred individual was not familiar with the PRUDs for his new area. Since this individual is a backup supervisor, the

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personnel transfer program should ensure training.

Mir.or Weakness: The UPMP area should have the maximum enrichment allowed in UPRF'~ established as an AEC.

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