ML20211L300

Insp Rept 70-1113/99-04 on 990726-0805.No Violations Noted. Major Areas Inspected:Plant Operations,Mgt Organization & Controls,Maint/Surveillance & Emergency Preparedness

ML20211L300
Person / Time
Site:	07001113
Issue date:	08/31/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211L285	List: ML20211L282 ML20211L300
References
70-1113-99-04, NUDOCS 9909080204
Download: ML20211L300 (15)

Text

'

. U.S. NUCLEAR REGULATORY COMMISSION REGtONll Docket No.: 70-1113 License No.: SNM-1097 Report No.: 70-1113/99-04 Licensee: General Electric Company

-Wilmington, NC 28402 Facility Name: Nuclear Energy Production Dates: July 26 through August 5,1999 Inspectors: D. Ayres, Senior Fuel Facility inspector D. Seymour, Senior Fuel Facility inspector.

Approved by: E. J. McAlpine, Chief Fuel Facilities Branch 4 Division of Nuclear Materials Safety i

Enclosure 9909000204 990031 PDR C ADOCK 07001113 PDR p

1

.~ .

1

)

EXECUTIVE

SUMMARY

General Electric Nuclear Energy NRC Inspection Report 70-1113/99-04 The primary focus of this routine unannounced inspection was the evaluation of the licensee's conduct of plant operations, management organization and controls, and maintenance. The report covered a two-week period and included the results of the inspection efforts of two regional fuel facility inspectors.

Plant Operations l

• The facility was operated safely and in accordance with regulatory and license requirements. Housekeeping was adequate to ensure routes of egress were clear in case of an emergency. (Section 2.a)

• Facility modifications associated with the installation of the new gadolinia scrap recycle I system and associated with the shutdown of obsoleted systems were being adequately l controlled. (Section 2.b)

• Engineered and administrative (procedural) controls were used in the fuel pellet production area as identified in the Integrated Safety Analysis (ISA). (Section 2.c)

• Nuclear criticality safety control devices and measures were properly implemented.

(Section 2.d) l

• The licensee's evaluation of and corrective actions for two criticality safety events were adequate to prevent recurrence. The failure to properly implement the configuration management program for the nitrogen distribution system was identified as a non-cited violation. (Section 2.e)

Manaaement Oraanization and Controls

• The licensee's organization met the structure and qualification requirements specified in the License Appliation (LA). (Section 3.a)

• The Wilmington Safety Review Committee (WSRC) meetings and internal safety audits were conducted in a timely manner, and covered a wide range of safety concerns. The reviews and audits were detailed and adequate for detecting potential safety concerns.

(Section 3.b)

Maintenance / Surveillance

• The licensee's lockout /tagout procedure adequately instructed workers on isolating energy sources during maintenance activities. (Section 5.a)

• Appropriate approvals were obtained on safety-related maintenance work control procedures and instructions prior to their use. (Section S.b) l I

l

2 )

)

Trainina l

• . The general safety training of contractor employees adequately covered the required topics. Test results for employees adequately indicated their understanding of safety- I related issues.' Work assignments to employees were properly made based on worker )

comprehension and abilities. (Section 6.a) {

1

(

Emeroency Preparedness i

• The licensee's Emergency Response Team (ERT) performed effectively in response to a potential chemical safety concern. (Section 7.a) i r

i

i. I l \

l 1

l l

l 6

1 I i l b l REPORT DETAILS l

1. Summary of Plant Status This report covered the efforts of two regionalinspectors, each performing one-week inspections, but in separate and consecutive weeks. An NRC Headquarters inspection of Fire Safety was also conducted during the second week of this inspection. The public i Licensee Performance Review meeting was conducted with NRC and licensee l management on August 6,1999. I The CaF2stored in outdoor lagoons was in the process of being relocated to storage warehouses. Portions of the new integrated gadolinium shop dry recycle system were being installed. Pellet production, rod loading, bundle assembly, and uranium recovery l continued operations at normallevels. There were no unusual plant operational i occurrences reported during the onsite inspection.

2. Plant Operations (03)(IP 88020)

a. Conduct of Operations (03.01) and Housekeeoina (O3.06)

(1) Inspection Scope l The inspectors made routine tours of the licensee's facilities to observe vanous 1 operational and work activities to verify the facility was operated safely and in  !

accordance with license and regulatory requirements. I Housekeeping associated with the storage of equipment and materials throughout the facility was also reviewed to assure significant potential hazards did not exist.

The inspectors a!so reviewed various operational procedures and records, and nuclear criticality safety postings, to verify operations were performed safely and in accordance with approved plant procedures and postings.

(2) Observations and Findinos The inspectors observed that specific operations were performed safely and in accordance with approved plant procedures and postings. Routine discussions with operations personnel revealed an understanding of the procedural and posting requirements.

Outside areas were toured and inspected. No conditions that could create an l undesirable situation or hazard in the event of adverse weather conditions such as high winds or flooding or blocked evacuation pathways were observed.

During tours of the facility, the inspectors noted radiological signs, postings, and procedures were properly posted or readily available. The inspector observed conditions and determined that equipment and devices used to confine and contain radioactive contamination and airborne radioactivity in fuel processing and other areas were in l

l

I 3 ,

p 2 i

proper working condition, and that proper personal protective clothing and dosimetry were issued and properly worn.  ;

- During process area tours, the inspector noted that emergency egress routes were adequately clear of debris.

l (3)- Conclusions

)

l The facility was operated safely and in accordance with regulatory and license requirements. No conditions that could create an undesirable situation or hazard in the event of adverse weather conditions were observed. Personnel complied with nuclear criticality safety and radiological safety requirements.

l l

Housekeeping was adequate to ensure routes of egress were clear in case of an emergency,

b. E_acility Modifications and confiauration controis (o3.02) l (1) Insoection Scope i

Facility modifications associated with the installation of new processes and shutdown of obsoleted processes were reviewed to determine that adequate safety controls were being implemented. I (2) Observations and Findings The inspector observed the installation of processing equipment to be used in the new gadolinia scrap recycle system. The inspector observed safety controls to be used to prevent nuclear criticality. Lessons learned from a recent event (see Section 2.e) involving buildup of uranium in a ventilation system filter housing were being

) implemented throughout the new process. Redundant moderation controls were also being designed into the system to ensure the moisture level of product being forwarded to the Moderation Restricted Area was acceptable for criticality safety.

The inspector observed the equipment in the obsoleted wet production process and the equipment associated with the fluoride waste system that had recently been placed in a g

" safe store" configuration. The inspector noted an improvement over a previous observation (see Ins,nection Report 70-1113/98-01) in the durability and legibility of the

! tags that were being used to identify out-of-service equipment. The inspector also l observed that the tags were being properly filled out and applied per licensee procedure.

l .

(3) Conclusions t

l' Facility modifications associated with the installation of the new gadolinia scrap recycle system and associated with the shutdown of obsoleted powder production and fluoride waste systems were being adequately controlled.

O e 3

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

(1) Insoection Scoce The inspectors reviewed the Integrated Safety Analysis (ISA) process at GE and reviewed the ISA for fuel pellet production to verify that the process was performed in accordance with their procedures and that there was adequate implementation of process safety controls.

(2) Observations and Findings The inspectors reviewed the ISA for the fuel pellet production process and verified that the iSA identified process controls relied upon for safety. The inspectors toured the fuel pellet production area and verified that selected administrative and active engineered controls were in place. The inspectors also discussed these controls with different operators and verified they were knowledgeable about them.

The inspectors randomly chose two active engineered controls listed in the ISA for the pellet production process. Both controls were considered high importance controls according to the ISA, and as a result, required numerous assurances according to the ISA procedure. The inspector determined that the licensee was still in the process of implementing some of the assurances for this area. For example, wiring drawings depicting the controls were not available, or were in the process of being generated.

The licensee indicated that the completion of these assurances was an ongoing process and would be coupled with their deadline for the ISA. The inspectors also reviewed the last functional tests performed for these two controls and verified they were completed as required.

(3) Conclusions Engineered and administrative (procedural) controls were used in the fuel pellet production area as identified in the ISA. Some required assurances for these controls ,

were not implemented at the time of the inspection. The licensee indicated that these )'

assurances would be implemented by the time the ISA is completed.

d. Imolementation of Storaae Safety Controls (O3.04) l (1) Insoection Scope l

The inspectors reviewed nuclear criticality control devices and measures to assure that  ;

the licensee's program provided a high degree of reliability for the prevention of an j inadvertent criticality.  !

l (2) Observations and Findinas The inspectors routinely toured fuel processing and storage areas and observed that personnel were complying with approved, written nuclear criticality safety limits and

.~ .

4 controls. The inspectors verified that nuclear criticality safety limits were posted and available to the operators. Proper spacing practices and controls, use of storage locations, and identification of special nuclear material were also observed during routine tours of both encapsulated and unencapsulated areas of the facility.

(3) Conclusions Nuclear enticality safety control devices and measures were properly implemented.

e. Review of Previous Events (O3.07)

(1) Insoection Scooe The internalinvestigation results for two previous events were reviewed to determine the adequacy of the licensee's actions.

(2) Observations and Findinas Event Notice No. 35788: Mass Limit Exceeded for a Hiah Efficiency Particulate Air (HEPA) Filter The inspectors reviewed the root cause evaluation surrounding Event Notice No. 35788, that concerned exceeding the mass controllimit within a HEPA filter. Moderation control remained intact, so no unsafe condition existed and the licensee concluded that the ,

event was of low safety significance.

On June 2,1999, maintenance personnel performing a routine inspection determined that a HEPA filter in the Dry Scrap Recycle (DSR) facility contained a mass equivalent to approximately 45 kilograms (kgs) uranium dioxide (UO2 ). This exceeded the mass controllimit of 25 kgs UO 2established for this type of filter housing throughout most of the facility.

The HEPA filter involved in this event was installed in the ventilation system that served both the DSR oxidation furnace and a seldom-used utility hood. The established method of determining material hold-up in HEPA filters at GE is based on the pressure drop across the HEPA filter. Typically, a pressure drop of 4.0 inches of water was determined by GE to be roughly equivalent to a hold up of 25 kgs UO2 on the HEPA filter. However, this equivalency was based on a hold-up of triuranium octoxide (U3 0 ) powder produced by the ammonium diuranate (ADU) process. Powder produced with the dry conversion process (DCP) has different bulk density characteristics that affected the pressure drop across a layer of this powder deposited on a filter. The licensee's initiated an investigation to address these issues.

The licensee's immediate corrective actions included: shutdown of the DSR oxidation furnace and utility hood operations and nondestructive assay gamma monitoring of the DSR ventilation system, removal of the prefilter and HEPA filter cartridge and removal of the materialinto safe geometry three gallon containers, and performance of a root cause

.~ .

5 investigation. Other corrective actions included: replacement of the HEPA filter housings in that area and in the gadolinium area with favorable geometry HEPA filter I housings designed by GE; changing the criticality safety controls to geometry and moderation; identification of other areas where U3 0,is processed and reviewing the criticality safety controls used to demonstrate safety; weighing and replacing as necessary the HEPA filters in areas of highest U3 0, input;'and establishing increased monitoring of HEPA filter housings in U3 0, processes.

Long term corrective actions included studying the history of the differential pressure readings across the HEPAs versus net weight and material type, and develop a reporting l

capability. The licensee noted that this filter housing had not been included in their routine gamma scan monitoring program because the housing was after a long vertical run which would normally prevent an accumulation of material. The licensee concluded that their lack of understanding of the characteristics of the materialin the ventilation system prevented recognition of this problem until the unexpected accumulation occurred.

The inspectors reviewed the licensee's root cause investigation and their corrective actions for this event, and determined they were thorough and complete.

Event Notice No. 35110: Improper Confiauration of Nitroaen Pioina System The inspector reviewed the licensee's actions in response to a criticality safety event (see NRC Event No. 35110) reported on December 3,1999, involving the improper installation of a nitrogen piping system. The original run of nitrogen piping served the old ADU process, most of which was in a " safe store" condition. In 1996, the nitrogen piping was redesigned to supply nitrogen to the DCP in addition to the ADU process. Since the DCP was designated as a Moderation Restricted Area (MRA), extra precautions were taken to ensure that the amount of water allowed in the DCP was extremely limited and tightly controlled. One concern identified by the licensee was the potential siphoning of water from the wet areas of the ADU process to the DCP upon loss of nitrogen system pressure, in order to prevent such a siphoning effect, the licensee installed an automatic isolation valve that closed upon low nitrogen system pressure. However, on December 2,1999, the licensee discovered that the nitrogen supply point for the DCP was installed on the wrong side of the isolation valve. This configuration could theoretically allow passage of water (or other materials) from the wet ADU process into DCP.

The inspector reviewed the licensee's root cause analysis of the event. The inspector found that the area engineer did not review and approve the drawings provided for the

, installation of the DCP nitrogen tie-in as required by the licensee's configuration l

management program. The pipe fitter installed the system per the drawings provided to him. After installation, an installation verification inspection was performed by the licensee, but since the drawings were in error, no problems were found during the verification. Prior to start-up of the system, a pre-operational safety audit was performed on the system. The inspector found that since the audit was on a utility system, there was less than adequate attention given to it to detect the improper configuration.

6 The licensee's evaluation of the event stated that the root cause was the inaosquate installation verification. However, since erroneous drawings were used during construction, the installation verification was not likely to discover the improper configuration. The inspector found that the lack of engineering review and approval of the construction drawings was the most fundamental error that caused the improper configuration, and the inadequate pre-operational audit was a major contributor.

Although the inspector disagreed with the main root cause identified by the licentae, the inspector found that the corrective actions implemented by the licensee adequately addressed the problems associated with implementing the configuration management system. The corrective actions included a thorough review of all other safety controls associated with utility systems, the evaluation of a generic checklist for the installation verification process, and intensive retraining of safety engineers and managers on nuclear safety design criteria and the configuration management program.

The inspector observed the nitrogen piping system in the old ADU process areas and found that all nitrogen use points were at the top of powder milling gloveboxes and other dry process steps. Thus, the siphoning of water from the wet process area to the DCP, even upon loss of nitrogen system pressure, was considered highly unlikely. Even though the likelihood of a criticality accident resulting from this event was low, the failure to properly implement the configuration management program could have more serious consequences if the same failure was to recur in another area of the facility. Therefore, this non-repetitive, licensee-identified and corrected violation is being treated as Non-Cited Violation (NCV) 99-04-01, consistent with Section Vll.B.1 of the NRC Enforcement Policy.

(3) Conclusions The licensee's evaluation of and corrective actions for two criticality safety events were adequate to prevent recurrence. The failure to properly implement the configuration management program for the nitrogen distribution system was identified as a NCV.

3. Management Organization and Controls (IP 88005) (05) i

a. Oraanizational Structure (O5.01)

(1) Insoection Scope The inspectors reviewed the licensee's organizational structure to determine whether it met the requirements in the License Application (LA) for structure and personnel qualifications, and to determine if key individuals were aware of their responsibilities with respect to nuclear criticality and radiological safety.

I (2) Observations and Findinas The inspectors reviewed the licensee's organizational structure and the resumes of l severalindividuals in the area manager position and determined that the licensee's  !

p l

! 7 organization met the requirements specified in the LA. Discussions with selected individuals indicated that the personnel were aware of their responsibilities with respect to nuclear criticality and radiological safety.

(3) Conclusions No problems were noted with the licensee's organization. Individuals were aware of their

, responsibilities with respect to nuclear criticality and radiological safety. The l organization met the structure and qualification requirements specified in the LA.

l

b. Internal Reviews and Audits (O5.03) and Safety Committees (05.04) l (1) Insoection Scope The licensee's system for performing their internal reviews and audits, and for holding safety review committees was examined to determine its adequacy for detecting potential safety concerns.

(2) Observations and Findinas l

l The inspectors reviewed the Wilmington Safety Review Committee (WSRC) meeting l notes for 1999 and determined that the WSRC meeting met the LA requirements for frequency and subject matter. The inspectors also reviewed the weekly audit findings (the weekly audits are performed in support of the quarterly audits) for criticality and

radiological safety for 1999 to date. The inspectors noted that the audits were conducted as required, covered a wide range of concerns, and were detailed and thorough.

Potential non-compliances, findings, and observations identified by the licensee during these audits were communicated to the appropriate personnel, tracked, and corrected as required by the LA.

l One inspector accompanied the licensee on the weekly criticality and radiological safety audit. The inspector noted that the audit team contained the appropriate members (area manager, criticality safety representative, and a radiological safety representative), and that the audit was detailed.

(3) Conclusions The WSRC meetings and internal safety audits were conducted in a timely manner, and covered a wide range of safety concerns. The inspector concluded that the reviews and audits were detailed and adequate for detecting potential safety concerns, i

l i

.~ .

8 1

4. Security (IP 92701)(S2) 1

- a. Follow-up on Previousiv identified Issues (S2.10)

_ (1) Inspection Scope The inspectors reviewed the licensee's response to inspector Followup Item (IFI) 70-1113/98-05-01, A Few Employees Were Not Wearing Their Badges During Lunch and Breaks.

(2) Observations and Findinas The inspector reviewed the licensee's response to the IFI, which included a letter in the Eleven Minute Meeting for Fiscal Week 39 (September 1998). This letter stressed the  ;

importance of wearing your badge, how to wear your badge properly, and to stop anyone  ;

seen without a badge. The inspector verified that the licensee posted a sign on the turnstiles at the Emergency Control Center (the entrance to the controlled area) stating that your identification badge must be visible at all times. The inspector also made random checks of the lunch rooms and break areas and verified that GENE employees i were correctly wearing their badges. The inspector determined that the corrective actions were acceptable '

(3) Conclusion  !

This item is closed.

5. ' Maintenance / Surveillance (88025) (F1)

a. Work Control Procedures (F1.02)

(1) Inspection Scope Safety related procedures used to supplement maintenance activities were reviewed to verify t iat they contained adequate safety precautions for isolation of energy sources.

(2) Observations and Findinas The inspector reviewed the licensee's procedure C-1, " Lockout /Tagout," for isolation of energy sources. The inspector found that the procedure contained adequate generalized instructions for isolating energy sources and applying tags and locking devices. The procedure also referenced other Equipment Specific Procedures (ESPs) that identified particular hazards to be isolated during work on specific equipment. The inspector reviewed a selection of these ESPs and found them to provide adequate instruction for identifying and isolating hazards during maintenance.

1

I j

i l

l 1

9

)

.(3) Conclusions The licensee's lockout /tagout procedure adequately instructed workers on isolating energy sources during maintenance activities.

b. Work Control Authorizations (F1.03) l l ,

(1) Inspection Scope l Selected maintenance instructions and procedures were reviewed to verify that they had received proper administrative approvals.

1 (2) Observations and Findinos The inspector reviewed the licensee's procedures C-1, " Lockout /Tagout"; C-22, " Safety Barriers, Signs, and Tags"; and numerous functional test instructions for the Uranium Recovery area. The inspector found that these procedures and instructions had been approved by the appropriate safety and management personnel prior to being used for performing maintenance activities.

(3) Conclusions Appropriate approvals were obtained on safety-related maintenance work control procedures and instructions prior to their use.

6. Training (88010)(F2)

(1) Inspection Scoce Safety training for newly-hired contractor employees was reviewed to verify adequacy of topics covered and trainee comprehension.

(2) Observations and Findinos  !

The inspector reviewed the training records of selected contractor employees. The inspector observed that all of the selected employees passed a comprehensive test covering aspects of 10 CFR 19.12 requirements, general nuclear criticality safety, general radiological safety, and general emergency procedures. The inspector noted that a passing grade of 70 percent was required. It was also noted that one employee had not passed the written test due to a lack of reading skills. A passing grade was achieved when the test was re-administered orally to that individual, whose work assignments were limited to custodial duties away from potentially contaminated areas.

The inspector reviewed the training provided on operating procedures and or,-the-job training records for specific tasks. The inspector found that documentation was lacking on precisely which procedures certain operators had been trained. No documentation existed that showed an employee's signature as a record of training on specific l

.~ .

10 i 1

procedures. However, comprehensive testing records were maintained that covered all pertinent aspects of the job being performed. The inspector found that this was adequate as long as the operators were limited to the procedures on which they were .

formally trained and tested. l (3) Conclusions The general safety training of contractor employees adequately covered the required topics. Test results for employees adequately indicated their understanding of safety-related issues. Work assignments to employees were properly made based on worker comprehension and abilities.

7. Emergency Preparedness (88050)(F3) l

a. Drills and Exercises (F3.05)

(1) Insoection Scoce The activation of the Emergency Response Team (ERT) in response to a potential safety concern was observed to determine its effectiveness. i (2) Observations and Findinas The inspector observed the activation of the ERT upon receipt of an area alarm at a drum storage building. A potential safety concern existed due to the bulging of drums containing industrial cutting fluids that were known to potentially evolve hazardous vapors. The ERT arrived on scene within two to three minutes of the alarm activation and effectively placed barriers at the entrance to the drum storage area. The ERT effectively rotated two-man crews into the drum storage area in order to assess the situation, relieve pressure from the drums, and sample the gases evolved for flammability and toxicity. The crew rotations occurred at specified time intervals to ensure that bottled forced-air supplies were not depleted, and that heat stress to the responders was minimized. The inspector found that the team was well-coordinated, well-equipped and safely addressed the situation.

(3) Conclusions The licensee's ERT performed effectively in response to a potential chemical safety concern.

8. Exit Meetings On July 30 and August 5,1999, the inspection scope and results were summarized with licensee representatives. The inspectors discussed,in detail, the routine program areas inspected, and the findings. No dissenting comments were expressed by the licensee.

The licensee identified materials provided during the inspection as proprietary, although proprietary information is not contained in this report.

r

..~ ,

i f

ATTACHMENT l

PARTlAL LIST OF PERSONS CONTACTED Licensee Personnel

' #D. Brown, Team Leader, Environmental Programs l

1. R. Crate, Manager, Industrial Hygiene and Safety

• D. Dowker, Leader, Chemical Product Line

• 1. R. Keenan, Manager, Site Security and Emergency Preparedness

• 1. J. Kline, Manager, GENE Production

• 1. C. Monetta, Manager, GENE, EHS

1. S. Murray, Manager, Regulatory Compliance l . *#L. Paulson, Manager, Nuclear Safety

'#R. Reda, Manager, Fuel Fabrication

1. C. Vaughan, Manager, Facility Licensing Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.

• Denotes those present at the exit meeting on July 30,1999.

1. Denotes those present at the exit meeting on August 5,1999 INSPECTION PROCEDURES USED IP 88005 Management Organization and Controls -

! IP 88010 Operator Training / Retraining IP 88020 Regional Nuclear Criticality Safety inspection Program IP 88025 Maintenance and Surveillance IP 92701 Followup Tl 2600/003 Plant Operations >

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened 70-1113/99-04-01 NCV Failure to Properly implement Configuration Management Program for Nitrogen System Installation.

Closed 70-1113/98-05-01 IFl A Few Employees Were Not Wearing Their Badges During Lunch l

and Breaks.

1 I

r1 '

, 1

.~ . .

I I

!- 2 l l

I 70-1113/99-04-01 NCV . Failure to Properly implement Configuration Management I Program for Nitrogen System Installation

. ACRONYMS ADU Ammonium Diuranate CFR Code of Federal Regulations DCP Dry Conversion Process- i DSR Dry Scrap Recovery ERT' Emergency Response Team

. ESPs Equipment Specific Procedures .

GE ' General Electric

' GENE General Electric Nuclear Energy HEPA High Efficiency Particulate Air IF! Inspector Follow-up Item I IP inspection Procedure ISA Integrated Safety Analysis 4 kgs Kilograms LA License Application MRA Moderation Restricted Area.

NCV Non-Cited Violation NRC _ Nuclear Regulatory Commission SNM Special Nuclear Material U03 Triuranium Octoxide UO 2 Uranium Dioxide WSRC Wilmington Safety Review Committee i

e 4