ML20210G014

Insp Rept 70-1201/99-202 on 990716.No Violations Noted. Major Areas Inspected:Plant Activities,Administrative & Engineered Controls,Ncs Function & Chemical Safety

ML20210G014
Person / Time
Site:	07001201
Issue date:	07/28/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20210G004	List: ML20210F999 ML20210G014
References
70-1201-99-202, NUDOCS 9908020262
Download: ML20210G014 (8)

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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS l

l Docket No: 70-1201 License No: SNM-1168 Report No: 70-1201/99-202 l

License Holder: Framatome Cogema Fuels l Location: Lynchburg Manufacturing Facility Lynchburg, VA Date: July 16,1999 l

Inspectors: Dennis Morey, Senior Criticality Safety inspector Sheryl Burrows, Criticality Safety Inspector William Troskoski, Senior Chemical Safety inspector Garrett Smith, Chemical Safety inspector Approved by: Philip Ting, Chief Operations Branch, Division of Fuel Cycle Safety and Safeguards, NMSS Enclosure 9900020262 990728 PDR ADOCK 07001201 C PDR-

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2 FRAMATOME COGEMA FUELS l LYNCHBURG MANUFACTURING FACILITY NRC INSPECTION REPORT 70-1201/99 202 EXECUTIVE

SUMMARY

I l Introduction 1

NRC conducted a routine announced nuclear criticality safety (NCS) and chemical safety inspection of the Framatome Cogema Fuels' Lynchburg Manufacturing Facility (LMF)in Lynchburg, Virginia, on July 16,1999. The inspection was conducted by NRC Headquarters staff to ensure that the facility is being operated in a safe manner and in compliance with NRC regulations. The inspection focused on the following areas:

Plant activities.

Administrative and engineered controls. I NCS Function.

Chemical Safety.

Followup on open items from NRC Inspection Report 70-1201/97-202.

Results I

No safety issues were identified during the inspection.

i The inspectors determined that the licensee has improved the quality of criticality safety postings and has posted fire fighting instructions in appropriate locations.

l One weakness was identified regarding accurate representation of material compositions in calculations supporting safety limits.

Three open items from inspection Report 70-1201/97-202 were closed.

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. , j REPORT DETAILS CRITICALITY SAFETY (88015) 1.0 PLANT ACTIVITIES I

a. Scope The inspectors conducted a walkdown of the LMF facility to determine whether ongoing activities were being conducted safely, applicable procedures were in use, and administrative i controls were being complied with.

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b. Observations and Findinas

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The inspectors walked down all plant areas involving the handling of fuel including:

l Pellet Receiving / Shipping Areas l

Fuel Rod Downloading Area )

Pellet Storage Vault I Pellet Loading Area Fuel Rod Handling Area (outside the pellet loading area up to the He leak tester)

Mezzanine Pellet Storage Fuel Ascembly Room Fuel Assembly inspection Pit Area Fuel Assembly inspection (two stations)

Fuel Assembly Storage Fuel Assembly Shipping / Receiving Area l l

The inspectors walked through the plant following the entire fuel bundle assembly process from

! the pellet receiving area, through the manufacturing process, and to the fuel assembly shipping area, and conducted discussions with licensee management and safety staff in order to determine whether there had been any significant changes to special nuclear material (SNM) processing operations affecting criticality safety since the last inspection. None were identified.

The inspectors observed that licensee operators were performing work in accordance with approved work procedures. When questioned by the inspectors, operators were able to immediately identify and locate the work procedure in use. Licensee staff was in compliance l with applicable limits and controls in all activities observed by the inspectors. Plant personnel indicated that posted signs were the primary guidance for criticality safety; however, when l asked, an operator was able to quickly locate the applicable criticality safety rules and limits in the governing work procedure.

c. Conclusions Facility activities observed by the inspectors were conductad safely and in compliance with posted criticality safety rules and license commitments r

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4 2.0 ADMINISTRATIVE AND ENGINEERED CONTROLS

a. Scope l

The inspectors observed engineered and administrative criticality safety untrols at the LMF facility to determine whether they were adequate to assure criticality safety of plant operations under normal and upset conditions.

b. Observations and Findinas During recent inspections, the inspectors questioned the connection between license commitments and controls in the plant. The inspectors determined that the specific criticality safety controls are clearly identified in the license as slab thickness and moderator control in part of the plant and spacing and moderator controlin the remainder of the plant. The inspectors observed improvement in the implementation of controls in the facility.

The inspectors determined that licensee administrative criticality safety controls are mainly communicated to plant personnel through the use of posted " Criticality Safety Rules." The posted rules were clear, up-to-date, and posted in appropriate locations. Rules that do not relate to criticality safety which were found on the postings during a previous inspection had been removed from the postings. The inspectors also observed that posted licensee administrative criticality safety requirements were now signed. The main administrative controls in use at the facility were height limits on stacking materials, limits on the use of moderators, and requirements to store fuel above the floor. The inspectors determined that license requirements had been adequately flowed down into posted administrative criticality safety controls.

The inspectors noted that the licensee has, since the last inspection, posted four moderator controlled areas with a new type of sign which limits the diameter of hose acceptable for fire fighting purposes. These new moderator controlled area postings will improve the licensee's ability to comply with criticality safety requirements during a fire.

The inspectors determined that engineered controls for criticality safety consisted of barriers to limit stacks of pellets to 4", racks to control the spacing of fuel pellets and assemblies, and boral or borated stainless steel (BSS) plates to act as neutron poison in higher risk locations. Fuel assembly racks were engineered to maintain a 21" center-to-center spacing. In these racks, there is a limit of 21" center-to center spacing for fuel assemblies with enrichments less that 4.1 wt%, and a limit of 42" center-to center spacing for assemblies with greater than 4.1 wt%.

Since physical controls only limit the spacing to 21", there is a combination of administrative and an engineered controls for fuel assemblies with enrichments greater than 4.1 wt%. The inspectors observed that fuel assemblies in the assembly storage area were labeled with tags indicating the enrichment of the fuel assembly.

Conclusions The inspectors determined that administrative and engineered controls were in place in the facility and were adequate to assure critied 7 safety of plant operatione under normal and upset l

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5 conditions. The inspectors determined that the licensee has improved the quality of criticality safety postings and has posted fire fighting instructions in appropriate locations. The inspectors also determined that engineered controls remain adequate.

i 3.0 NUCLEAR CRITICALITY SAFETY (NCS) FUNCTION j a.ScoDO l

The inspectors examined selected areas of the nuclear criticality safety program to determine whether the licensee had an independent criticality safety function in accordance with license 3 commitments. '

l b. Observations and Findinas The facility retains a Nuclear Criticality Safety Specialist (NCSS) who is organizationally independent of the LMF, with no interest in plant operations, other than the nuclear critically safety aspects. The NCSS is responsible for evaluating licensee fissse material operations, determining safety limits and controls, and conducting semi-annual criticality safety audits to assure compliance and identify potentialimprovements. The inspectors reviewed the most recent semi-annual criticality safety audit which was conducted on July 9,1999, as well as the procedure for Criticality Safety Evaluations. The inspectors determined that the audit was thorough and in accordance with license commitments.

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The inspectors determined that the implementing procedure for performing criticality safety l evaluations was in compliance with license conditions. The NCS analysis for the fuel assembly inspection pit used a nominal value of 1.5 wt% boron content for thts BSS plates. Subsequently, the licensee determined that the correct value for the boron content was 1.47 wt%. The licensee argues that this minor difference in the value will not result in a change in system reactivity that will be detectable with a computer calculation, which the inspectors agree is true.

Regardless, when the correct value for the material content has been determined, the licensee  !

should update analysis for future reference. Although the minor deficiency did not challenge a j safety limit, the inspectors determined that failure to update analytical assumptions was a  !

program weakness.

c. Conclusions The inspectors determinea that the licensee NCS program was in compliance with license commitments. A weakness was identified regarding accurate representation of material compositions in calculations supporting safety limits.

6 4.0 CHEMICAL SAFETY

a. Scope The inspectors reviewed facility operations to verify that there were no unacceptable risks from hazardous chemicals to worker safety or to the safe handling, processing and storage of SNM.

b. Observations and Findinas The inspectors conducted a walk through of facility operations on July 16,1999, and conducted {

discussions with licensee management and industrial health and safety personnel in order to determine whether there had been any signiiicant changes to SNM procesc;cg operations since the last inspection. None were identified.

The inspectors determined that current operations involved mostly mechanical processes and only minimal chemical usage in areas with SNM. Those areas appeared to be well maintained, and no uncontrolled hazards were observed. The inspectors determined through interviews that licensee operators were appropriately trained and knowledgeable of the safe operatirig practices for the chemicals used on site.

l During a tour of the chemical storage building, the inspectors observed acid and base chemicals I stored next to each other and within the same berm. This was brought to the licensee's attention and immediate corrective action was taken. The inspectors also noted that the expiration date had just passed for certain chemica!a used as first aide treatment for HF acid.

The licensee stated that they were aware of the expiration date and that a fresh supply had already been ordered. The inspectors had no further concerns. .

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c. Conclusions  !

l The inspectors determined that the facility was being operated in a safe manner with no l unacceptable chemical hazard risks.  ;

5.0 OPEN ITEMS IFl 70-1201/97-202-01 This item tracked licensee efforts to obtain a certificate of compliance for the BSS plates in the fuel assembly inspection pit. The licensee was unsble to obtain written certification from the manufacturer regarding the weight percent of boron in the plates. The licensee elected to perform analysis of the boron content in the plates. The analysis was completed by an i independent research chemistry laboratory, Ledoux and Company and found to range from 1.47 wt% to 1.49 wt%, with an average value of 1.48 wt%. The plates were originally modeled i

by the licensee with 1.5 wt% boron, and the licensee argues that the small difference in the content will not result in a detectable increase in system reactivity. This item was closed by the inspectors based on the independent analysis and documentation by the licensee criticality safety staff indicating that this small difference in the boron content of the plates does not compromise any cnticality safety control. This item is closed.

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7 IFl 70-1201/97-202-02 Thi+ % :. tracked the development of a procedure for performing, reviewing, and approving criticality safety evaluations. Procedure SL-1510 " Criticality Safety Evaluations" issued February 27,1998, meets this requirement and implements the license conditions. This item is i closed.

IFl 70-1201/97-202-06 This item tracked the interface between emergency response functions during firefighting.

Written guidance, management controls, lines of communication and organizational interfaces were not clearly established in emergency procedures for fire fighting activities in fissile material processing and storage areas.

The inspectors determined that the licensee hac corrected this deficiency with the issuance of SL-1308 and Addendums. SL-1308 added to the Emergency Response Team the NCSS or an alternate representative cognizant of criticality safety issues which might be encountered during fire fighting activities. The procedure documents the organizationalinterfaces and the addendums detail the procedures for response to local fires (Addendum 3), major fires (Addendum 9), and response to a LMF fire or criticality alarm (Addendum 15). The issue dates on these documents range from December 2,1998, through June 17,1999. This item is closed.

5.0 Exit Meeting <

l An exit meeting was held between NRC Headquarters staff and plant management on July 16, l

1999. No classified or propriety information was discussed. LMF management acknowledged l l

the closure of the three open items and made a commitment to correct the one identified  ;

weakness.

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PARTIAL LIST OF PERSONS CONTACTED l

• Timothy Allser Manager, Radiation Protection l

• Charles Armontrout Manager, Licensing and Quality Systems

• David Driscoll Regulatory Compliance

• Gerald Lindsey Health Physicist Brian Palmer NCS Specialist

• T. Scott Wilkerson Manager, Licensing and Quality Systems

• Attended exit meeting.

ITEMS OPENED. CLOSED. OR DISCUSSED Closed 70-1201/97-202-01 IFl Certificate of compliance for BSS plates in inspection pit.

70-1201/97-202-02 IFl Procedure for performing criticality safety evaluations.

70-1201/97-202-06 IFl Emergency procedures for response interfaces.

ACRONYMS USED BSS Borated Stainless Steel LMF Lynchburg Manufacturing Facility NCS Nuclear Criticality Safety NCSS Nuclear Criticality Safety Specialist SNM Special Nuclear Material

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