ML20211B926

Insp Rept 70-1257/99-202 on 990802-05.No Violations Noted. Major Areas Inspected:Plant Operations,Criticality Safety Training,Administrative Controls,Internal Audits & Internal Reporting of Nuclear Criticality Safety Infractions

ML20211B926
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/19/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20211B918	List: ML20211B910 ML20211B926
References
70-1257-99-202, NUDOCS 9908250124
Download: ML20211B926 (14)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/99-202 Licensee: Siemens Power Corporation Location: Richland, Washington 99352 Inspection Dates: August 2 - 5,1999 Inspectors: Dennis Morey, Criticality Safety Inspector, NRC llQ Sheryl Burrows, Criticality Safety inspector, NRC llQ Jeremy Smith, Criticality Safety Specialist, NRC IIQ Douglas Outlaw. Contractor, S AIC Approved By: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety And Safeguards Enclosure 9908250124 990819 PDR ADOCK 07001257 C PDR

2 SIEMENS POWER CORPORATION NRC INSPECTION REPORT 70-1257/99-202 EXECUTIVE SUMM ARY Introduction The Nuclear Regulatory Commission (NRC) perfonned a routine, announced criticality safety inspection at Siemens Power Corporation (SPC) located in Richland, Washington, from August 2 - 5,1999. The inspection focused on plant operations, criticality safety training, administrative controls, internal audits, internal reporting of nuclear criticality safety (NCS) .

infractions, and the criticality safety function. The inspectors reviewed documents, interviewed plant staff, and conducted walkdowns of affected plant areas.

During the inspection, the inspectors opened one IFI, closed three open items from previous inspections, and identified a weakness in the location of computerized training for operation employees.

Results The inspectors observed that the licensee used a high percentage of temporary employees in fissile material but no safety concerns attributable to the practice were identified.

Two minor process area infractions identified by the inspectors were immediately and effectively corrected by the iicensee.

The training program at SPC is adequate to provide new and existing employees a firm grasp of criticality safety concerns, limits, and responsibilities.

The location for the personal computer (PC) based training is inadequate. SPC has a new training classroom in a different location slated for construction later this year.

The inspectors determined that administrative controls for criticality safety and the overall scheme ofimplementation at the Siemens plant meets license requirements.

The inspectors determined that the internal audit program at SPC is adequate to assure compliance with NCS controls and limits.

The inspectors found that the SPC system for reporting, reviewing, and resolving internal criticality safety discrepancies met license and NRC Bulletin 91-01 requirements.

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3 The inspectors determined that licensee assumptions and controls for fire fighting in the Dry Conversion Area moderator exclusion area were adequate.

The inspectors determined that licensee cross-indexing of controls was a good management practice.

The inspectors noted that SPC had developed an excellent system for documenting physical dimensions important to criticality safety.

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4 REPORT DETAILS 1.0 Plant Operations

a. Scope ofInspection The inspectors reviewed ongoing fissile material operations throughout the licensee facility and conducted informal interviews with operators and engineers regarding equipment, processes, and safety requirements.

b. Observations and Findings The inspectors performed extensive walkdowns at the UO 2 facility including the uranium recovery area, dry conversion area, powder blending area, pellet forming area, rod loading area, and fuel bundle assembly area. The inspectors also performed walkdowns at the Engineering Laboratory and Office Facility, Warehouse #7, Modular Extraction Facility, and Lagoon Uranium Recovery / Solids Processing Facility.

The inspectors noted that the licensee is in the midst of a very heavy work cycle due to multiple contracts requiring simultaneous efTorts and that extensive activity was taking place in all production areas. The inspectors noted that the quantities of ma:erial in process appeared to be well within the capability of the facility. The inspectors were infonned that the licensee has made extensive use of temporary employees in production areas in order to support the increased workload. Very high percentages of temporary employees were being used in some production areas; for example,43% of the employees in the ceramics area during the day shift were temporary. The inspectors did not identify any safety concerns regarding the high reliance on temporary employees.

During a walkdown in the uranium recovery area, the inspectors observed a vinyl posting on overflow lines for fissile material systems. Tne posting stated that the line was to be kept clear at all times. The inspectors noticed that the overflow line for the Room 240 pellet dissolver lag tank (a safe geometry slab tank) did not have a posting. The licensee stated that this was a fissile system, and a sign was required. The licensee installed the required posting prior to completion of the inspection. The inspectors noted that this appeared to F>e an isolated incident.

The inspectors noted that used vacuum filter canisters are stored in positions designated by a metal frame on the floor at various locations in the facility. These locations are marked with a one-foot spacing line painted on the floor around the storage location.

Analytically, the filter canisters are treated as a fully moderated sub-critical unit which must be spaced at least one foot from other similar units. The inspectors observed a combustible trash container with fissile material bearing trash place inside the one-foot line. These trash containers are also considered fissile units under the license analysis.

5 The licensee immediately moved the can and contacted operators. The licensee determined that the canister did not contain any fissile material so no safety limit had been exceeded. Operators were subsequently briefed on all shifts that the combustible material containers were fissile units and should not be placed within one foot of other fissile units. The licensee acknowledged that if the canister had cc.ntained fissile material, the inspectors would have considered this a potential violation.

c. Conclusions The inspectors observed that the licensee used a high percentage of temporary employees in fissile material but no safety concerns attributable to the practice were identified. Two minor process area infractions identified by the inspectors were immediately and effectively corrected by the licensee.

2.0 Criticality Safety Training

a. Scope ofInspection f

The inspectors reviewed the criticality employee training program for content and applicability. The inspectors reviewed employee training records and observed in-process training.

b. Obsenations and Findings The inspectors interviewed SPC training staff and determined that the staff had a good understanding of criticality safety and its importance in the workplace. The inspectors determined that the licensee lesson plans for training classes were comprehensive and adequate to give a new employee a good understanding of what criticality safety is, the associated dangers, limits and controls, and the necessary actions to take in an abnormal situation.

The inspectors noted that a large portion of the required entry and annual criticality safety training is performed on one of several personal coreputers dedicated to employee training. The inspectors determined that the layout of the PC based training and its '

coverage ofcriticality safety was good. Employees must score 80% or better on the general criticality safety examination, and 100% on the site-specific criticality safety examination before they are allowed to work at SPC. Additional work station specific criticality safety training is required for certain tasks. PC based training results are saved and maintained by the licensee training department along with adequate backups of all training records.

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6 Although training was determined to be adequate, the inspectors observed that the computer based training was located in an open operations area with a high activity level such as loudspeaker announcements, personnel walking by, talking, and so on. The inspectors determined and the licensee acknowledged that the area was not ideal for training. The licensee stated that a new and more suitable area had been identified for the training and was pending construction.

c. Conclusions The training program at SPC is adequate to provide new and existing employees an adequate understanding of criticality safety concems, limits, and responsibilities. The inspectors detemiined that the location of the PC based training is inadequate. SPC has a new training classroom slated for construction later this year in a different location.

3.0 Administrative Controls

a. Scope ofInspection The inspectors conducted a review of the implementation scheme fbr criticality safety administrative controls. The objective was to characterize the flow-down from the higher level Nuclear Criticality Safety Analysis (CSAs) to the applicable training, procedures and postings used at the facility for nuclear criticality safety controls.

b. Observations and Findings The inspectors reviewed selected CSAs and observed that in each case there was a clear and documented link to a Criticality Safety Specification (CSS). The inspectors observed plant wide and system specific CSSs which implement CSA required controls. All CSAs are available on-line and are cross-indexed by specific controls to plant procedures for operations, preventative maintenance (such as cheel;ing interlocks), and repetitive maintenance (such as instrument calibrations). The inspectors also noted that time licensee cross-references NCS controls to operation and preventive maintenance using a common number so that controls may be quickly traced to their analytical basis. The inspectors determined that licensee cross-indexing of controls was a good management practice. <

Licensee postings include Criticality Safety Limit Cards and Criticality Safety Instruction Cards. Intemal audits and walkdowns are conducted to determine where postings should be placed. Licensee staffindicated that postings are not relied upon as a criticality safety control on their own. The licensee considers operating procedures and training as the primary administrative controls. Posted limits simply summarize key requirements for the benefit of operators.

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CSS P67-001," General Criticality Safety Guide Rules, Workstation Specific Training, and Recovery Actions" was reviewed. This specification requires workstation specific criticality safety refresher training at least quarterly which includes all applicable CSSs and postings. For less complicated processes, all CSSs and postings are covered quarterly. For more complex operations, topics are staggered so that different subject matter is reviewed quarterly, but all applicable material is covered each year. The inspectors examined training records for this training, and the facility was detennined to be in compliance with license requirements.

c. Conclusions The inspectors determined that administrative controls for criticality safety and the overall scheme ofimplementation the Siemens plant meets license requirements. The

, reference to all procedures contained in the Criticality Safety Specifications was noted as a good practice.

4.0 Internal Audits a Scope ofInspection Inspectors reviewed the internal audits of plant operations by licensee criticality safety staff to determine compliance with license requirements.

b. Observations and Findings The licensee performs internal audits in accordance with written procedures. The frequency ofinternal audits for various systems are spelled out on specification sheets, and each frequency is based on the safety significance of each system, not to exceed two years. This frequency is dynamic such that a low frequency area that has shown to be of concern will have its audit frequency increased. Internal audits include a review of previous audits to identify probable reas of ec,ncern, a review of the specification sheets, a posting check, and a preventative maintenance check. In addition, personnel re::ponsih!e far internal audits are rotated for each specific area audit to allow a different perspective as well as to ensure that every member of the criticality staffis cross trained i

in all areas.

The inspectors observed that the licensee identified substantive issues, reported as j required, and took timely, effective corrective actions. The inspectors detennined that for all new prouisses undertaken at SPC, a "Startup Council" is formed consisting of the subject experts to review every aspect of the system before startup, and always includes at least one representative from the criticality safety section.

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c. Conclusions The inspectors determined that the internal audit program at SPC is adequate to assure compliance with NCS controls and limits.

5.0 Internal NCS Infraction Reporting

a. Scope ofInspection The inspectors reviewed the system for reporting, reviewing, and resolving internal criticality safety discrepancies to confirm that the sv ; tem met license requirements and that incider.ts meeting the requirements of NRC Bul etin 91-01 were reported. The inspectors also reviewed the documentation of 41 incidents that had occurred to date in 1999 to verify that requirements were being followed and to determine whether adverse trends could be noted. I

b. Observations and Findings l The inspectors determined that the licensee kept notebooks of criticality safety l occurrences. The licensee notebooks had the complete documentation files for each event. The inspectors reviewed both the 1998 and 1999 notebooks and determined that they adequately documented events in accordance with requirements of the I fcense and I the SPC Nuclear Criticality Safety Standards (EMF-30, Ch. 3, Section 11). For each event, the licensee had completed a Criticality Safety Corrective Action Report documenting the event and corrective actions needed. If an event was determined by the SPC criteria to be potentially reportable to the NRC, a separate evaluation was included that documented the basis for the decision on whether to report the incident. The inspectors determined that this system was adequate and met the requirements of the  ;

license, as implemented by the SPC safety standards.

The inspectors reviewed the 4) incidents identified from January through July 1999 in more detail. The evaluations of reportability under NRC Bulletin 91-01 were reviewed, and in each case, were determined to no: be reportable. At least two unlikely additional failures were identified as necessary for a potential criticality.

The inspectors also reviewed the 1999 incidents and correctis e action reports to determine if corrective actions were adequate and were being implemented. The inspectors determined that corrective actions identified by the licensee appeared adequate to correct the immediate situation and generally attempted to prevent recurrence elsewhere. The files in the notebooks were sufficient to indicate progress in completing corrective actions.

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9 Corrective actions are also tracked in the licensee Manufacturing Regulatory Commitment Tracking System. The inspectors reviewed current list ofcriticality safety related open items to confirm progress in completing 1998 and 1999 corrective actions.

Progress indicated by the licensee was determined to be adequate by the inspectors.

The inspectors reviewed the 1999 incidents and corrective action reports to determine if the types of events occurring indicated adverse safety trends or could be precursors of future problems. The inspectors determined that the events were principally self reported by operations staff. The inspectors determined that the reports indicated that the incidents being reported were generally minor and random. The inspectors did not l

identify any systematic trends. In all cases reviewed by the ir.spectors, multiple unlikely '

controls remained in place to prevent a criticality.

The inspectors determined that the licensee criticality safety staff maintained a database of criticality safety inciden!s and used that database to track and trend incidents for review by licensee criticality safety staff and management. The trending data for 1993-1999 indicated a general correlation on numbec ofincidents with production rates with no other adverse trends.

c. Conclusions The inspectors found that SPC system for reporting, reviewing, and resolving internal criticality safety discrepancies met license and NRC Bulletin 91-01 requirements. The inspectors did not find any adverse safety trends from reviewing the documentation on the 1999 criticality safety-related incidents.

6.0 Criticality Safety Function

a. Scope ofInspection  ;

The inspectors reviewed criticality safety assumptions and controls related to emergency

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operations in the dry conversion facility,

b. Observations and Findings The inspectors noted that the pre-fire plan for the dry conversion facility restricts j firefighting methods in the powder preparation area to high expansion foam, CO2 , and dry chemicals. The Richland Fire Department maintains a copy of the pre fire plan at the -

. Central Fire Station but does not possess high-expansion foam or application equipment.

l The licensee stated that the pre-fire plans firefighting methods are not requirements but l are limitations on methods. After interviewing fire department and SPC safety staff, the inspectors determined that this was a common understanding of the pre-fire plan. i

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10 The inspectors reviewed assumptions in the Dry Conversion Area (DCA) CSA D830 to ensure that the assumptions corresponded to field conditions. The inspectors noted that the licensee had claimed that a fire occurring in the DCF was unlikely, The inspectors then observed that the goveming CSA did not call out a control restricting the introduction of combustibles iinto the facility. Combustibles were controlled in the Criticality Safety Specifications (CSS) for the facility due to the requirement being called l out in other related CSAs. The licensee stated that failure to list the control was an l oversight in the process of upgrading the affected CSA, and the requirement would be

( incorporated into a pending revision of the CSA. Incorporation of CSA controls on the l

introduction of combustibles into the DCF will be tracked as Inspector Followup Item (IFI) 70-1257/99-202-01. Prior to the completion of the inspection, the licensee demonstrated that the control had been inserted into a pending revision of the affected CSA.

l The inspectors noted that SPC had developed an excellent system for documenting  !

physical dimensions important to criticality safety. This system allows both engineering i and criticality safety staff to quickly and simply determine whether a physical dimension l of an item or spacing is important to criticality safety. This safety system is significantly more efficient than typical industry practice.

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The !nspectors determined that licensee assumptions and controls for fire fighting in the Dry Conversion Area moderator exclusion area were adequate. The inspectors identified a CSA that failed to call out a control which would be expected in order to justify an assumption.

7.0 Open Items 70-1257/98-201-02 This item tracks licensee actions to upgrade CSAs to a new format. The inspectors reviewed licensee actions and determined that the licensee has not completed all scheduled CSA upgrades. This item remains open.

70-1257/98-204-01 This item track.s the uniform implementation of facility-wide criticality safety limits.

There is an administrative control required by Criticality Safety Specification (CSS) P67, 253 that requires a 12-inch edge-to-edge spacing between carts to transport finished pellets and other fissile materials. This 12-inch spacing is defined by red tape or painted red lines. The inspector observed an empty (therefore no fissile material) cart inside the red line. The original concern was that the carts should never cross the line unless

I1 material was being added to that station / array and an administrative control was being violated. Since the cart was empty, i.e. no fissile material, the fact that a cart was across a red line was not in violation of any limit or control. However, this is not a good practice.

In a follow-up during this inspection, the inspector did not notice any empty carts inside of the red lines. Additionally, when ceramic operations workers were asked about the red lines, they indicated that they would never cross a red line tvith a cart unless it was empty and in transport and would never leave an empty cart inside of a red line. The inspector questioned the shift supervisor, an operator who works for Siemens, and a manpower worker (non-Siemens employee) who was relatively new to the operation. The contract operator indicated that there was no circumstance where he would cross a red line with a cart. The other operators, including the shift supervisor, indicated that if a cart was empty and in transit it could cross the line, but in no other case. The facility has 64 facility-wide CSSs that can be traced backward to the Criticality Safety Analysis (CSAs) and forward to administrative contmis. The plant wide criticality safety controls appear to be implemented uniformly iesed on a document review, a plant walkdown, and interviews with plant personnel. While this item will be closed, the inspectors agree that leaving an empty cart inside the red line is a poor practice. This does not to appear to be a common practice and was not observed during the current inspection. This item is closed.

70-1257/98-204-02 VIO 70-1257/98-204-02 concerned the failure of an operator to visually verify that any equipment disassembled was free from visible uranium before staging it with other disassembled equipment. The inspectors reviewed the immediate and long-term actions taken by the licensee to correct this problem. The actions taken included a formal SPC incident Investigation Board that identified the root causes of the incident as " Procedures Not Followed,"" Communications / Tumover Less Than Adequate," and '

" Training / Understanding Less Than Adequate." Review of the report from this board indicated that the root cause analysis was adequate. Each of the corrective actions identified by the SPC Incident Investigation Board and reported to the NRC in the January 12,1999, reply to the NOV was reviewed and verified to be adequate.

Corrective actions included rework of the ductwork to facilitate visual inspections, review of other portions of the plant for similar situations, and institution of pre-job briefings on ,

all non-routine maintenance activities that require a Maintenance Work Permit. All corrective actions are now complete, and no safety issues remain. This item is closed.

70-1257/98-204-03 This item tracks the licensee commitment to upgrade the validation report. The licensee has not initiated SCALE 4.4 implementation. Licensee has further committed to prepare tables for the heterogeneous cases in the SCALE 4.4 validation report. This item remains open.

12 70-1257/98-204-04 This item tracks the licensee commitment to revise internal 91-01 reporting requirements.

Review of the modified procedure EMF-30, " Reporting Criticality Safety Violations, Incidents, and Emergencies," Appendix 11, " Conditions that require reporting to the NRC," showed that adequate modifications to the procedure have been implemented.

Upon review of the subsequent NRC reportability determination reports, one report

(#99-036) was found to contain an error in implementing this methodology of reportability determination. The error did not effect the original determination and is not cited as a violation. The inspectors reviewed the modified reportability procedure and found it to be adequate to close out the open item. The nuclear criticality staffis reviewing the error found above and will take corrective actions. This item is closed.

8.0 Management Meetings The inspectors met with SPC management periodically during the inspection. The inspectors presented the inspection scope and findings to members oflicensee staiTat the conclusion of the inspection on August 5,1999. The licensee acknowledged the findings presented.

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ITEMS OPENED. CLOSED. AND DISCUSSED )

Opened i

l IFI 70-1257/99-202-01 Tracks licensee actions to incorporate required controls into a I CSA.

l l Closed IFI 70-1257/98-204-01 Tracked licensee actions to achieve uniform implementation of j facility-wide criticality safety limits.

l VIO 70-1257/98-204-02 Concerned the licensee failure to adequately control decommissioning operations.

IFl 70-1257/98-204-04 Tracked licensee correction of NRC Bulletin 91-01 reporting requirements.

Discussed IFI 70-1257/98-201-02 Tracks licensee action to upgrade older CSAs to the more rigorous standards of recent CSAs. I IFI 70-1257/98-204-03 Tracks licensee development of a new validation report.

l PARTIAL, LIST OF PERSONS CONTACTED Bernard Femreite Vice President, Manufacturing Bernie Bently Manager, Operations Loren Maas Manager, Regulatory Compliance JeffDiest Criticality Safety Cal Manning Criticality Safety Andy McGehee Criticality Safety Tom Probasco Manager, Safety Marilyn Law Manager, Analytical Services Ray Vaughan Manager, Safety and Licensing

A 14 ACRONYMS USED CO 2 Carbon dioxide CSA Criticality safety analysis CSS. Criticality safety specification DCF Dry Conversion Facility IFI Inspector Followup Item NCS nuclear criticality safety NOV Notice of Violation PC personal computer SCALE computer' code package SPC. Siemens Power Corporation UO 2 Uranium dioxide

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