ML20217G108
| ML20217G108 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20217G091 | List: |
| References | |
| 70-1113-98-01, 70-1113-98-1, NUDOCS 9804020201 | |
| Download: ML20217G108 (13) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:
70-1113 License No.:
SNM-1097 Report ~No.:
70-1113/98-01
' Licensee:
General Electric Company Wilmington, NC 28402 Facility Name:
Nuclear Energy Production Dates:
February 23-27.-1998 Inspectors:
D. Ayres Senior Fuel Facility Inspector D. Seymour Senior Fuel Facility Inspector Approved by:
E. J. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Safety 9004020201'980326 PDR ADOCK 07001113 C
pon
Executive Summary General Electric Nuclear Energy NRC Inspection Report 70-1113/98-01 The primary focus of this routine unannounced inspection was the evaluation of.
the licensee's conduct of plant operations and training. The report covered a one week period and included the results of inspection efforts of two regional fuel facility inspectors.
Plant Ooerations Operations in the Dry Conversion Process (DCP) and gadolinia shop areas were in accordance with safety requirements (98-01. Section 2.a.3).
Storage.of wooden boxes and metal cans containing radioactive waste was in accordance with posted safety requirements. A violation was identified for storage of three waste drums within 12 feet of other storage arrays. The drums contained used solvent and the uranium content had not been measured (98-01. Section 2.a.3).
Changes to Ammonium Diuranate (ADU) lines 2 and 4 were made in accordance with the licensee's configuration management procedure (98-01. Section 2.b.3).
The licensee's safety controls identified in the Integrated Safety Analysis (ISA) for the new gadolinia shop integration equipment were adequately implemented (98-01. Section 2.c.3).
e' The licensee's identification and correction of previous incidents that violated license requirements was adequate and timely (98-01.
Section 2.d.3).
The licensee was reviewing ways to improve implementation of its lockout /tagout procedure in the OCP areas (98-01. Section 2.d.3).
Trainina General employee training included the required topics and was provided e
to personnel with potential safety significant positions (98-01.
Section 3.a.3).
The licensee met the requirements for retraining frequency and the retention of training records (98-01. Section 3.a.3).
Training for the DCP was detailed and extensive (98-01. Section 3.a.3).
. Attachments:
Persons Contacted and Exit Meeting
. Inspection Procedures Used
. List of Items Opened. Closed and Discussed List of Acronyms
1 Reoort Details 1.
Summary of Plant Status I
This report covered the efforts of two regional inspectors for a one week period.
Lines #1 and #2 of the Dry Conversion Process (DCP) were operational with line #3 undergoing qualification testing.
I Qualification testing of the DCP/gadolinia shop integration equipment was also underway.
Lines #2 and #4 of the wet ammonium diuranate (ADU)
.]
process had been placed into long-term safe storage. There were no 4
unusual plant operational occurrences during the onsite inspection.
2.
Plant Ooerations (03) (IP 88020) a.
Conduct of Ooerations (03.01)
(1)
Insoection Scoce The operations in the DCP, gadolinia sho), and outdoor storage areas were reviewed to verify adlerence to safety requirements in postings and operating procedures.
(2)
Observations and Findinas The inspectors toured the DCP facility and observed operation of the sowder production equipment.
The inspectors also o) served the storage of bulk powder containers and the control of moderating materials throughout the facility. The inspectors found that bulk powder containers were bc;ng properly stored and that the
)resence of moderating materials in the Moderation Restricted Area was in accordance with license requirements.
The inspectors reviewed the operation of the new gadolinia shy equipment installed to be used with DCP-produced powder anu compared it with the requirements in the area Nuclear Safety Release / Requirements (NSR/R). The inspectors observed that this new equipment was operated with enriched powder so that qualification for long-term usage could be obtained. The inspectors observed the storage of bulk powder containers and product cans in the area and found all such container being properly stored. The inspectors also observed the operation of the milling, slugging and granulating (HSG) equipment. The inspectors noted the lack
- of a fire extinguisher at the top of the 3-tiered MSG system and observed that it would be difficult to get to the nearest extinguisher quickly. The inspectors discussed this with the licensee who decided a small fire extinguisher was needed and would be provided. The inspectors also noted that a sign prohibiting uranium in a glovebox for weighing gadolinia was worded differently than instructed in the NSR/R. The licensee decided to change the sign to match the
2 NSR/R verbatim. The inspectors found that all other.
observed engineered and administrative safety features were being adequately implemented.
The inspectors observed an outdoor storage area for wooden boxes, metal cans. and metal and plastic drums, all containing various forms of radioactive waste materials.
The inspectors observed that the wooden boxes and metal cans of waste material were stored as required by posted nuclear safety requirements. The inspectors observed three arrays of 32 drums each in the drum storage area.
Each of these drums had been scanned (measured using non-destructive assay) to verify their low uranium content. The inspectors observed that the sides of some of the plastic drums in the arrays were becoming concave, possibly due to prolonged exposure to the weather.
In addition to the drums in the arrays, the inspectors observed eight metal drums in the drum storage area. each spaced at least twelve feet apart from each other.
These drums contained solvent from the Urariium Recovery system that had not yet been scanned to verify their uranium content. The inspectors found that although these unscanned drums were properly spaced' apart from each other, three of them were im)roperly spaced with respect to the scanned orum arrays. T1e posted NSR/R number 04.06.06 dated September 16, 1996, required that unscanned drums be limited to one drum per array, scanned drums be limited to 32 drums per array (with a concentration limit of 25 parts per million U-235). and that these arrays (scanned and unscanned) each be stored 12 feet from each other and 30 feet from other container arrays. However, the inspectors observed three of the unscanned drums being stored at distances of 4 to 10 feet from the arrays of scanned drums. This failure to properly store unscanned drums containing radioactive materials is a violation of posted safety instructions (VIO 98-01-01).
(3)
Conclusions Operations in the DCP and gadolinia shop areas were in accordance with safety requirements.
Storage of wooden boxes and metal cans containing radioactive waste was in accordance with posted safety requirements. A violation was identified for improper storage of three unscanned solvent waste drums.
b.
Facility Modifications and Confiouration Controls (03.02)
(1)
Insoection Scoce The licensee's procedure for configuration management, and the changes made to ADU lines 2 and 4 to place these lines into " safe storage." were reviewed to determine if these changes were made in accordance with the procedure.
3 (2) ' Observations and Findinos The inspectors discussed the shut down of ADU lines 2 and 4 with cognizant licensee personnel. These lines were being phased out as the new DCP process was implemented. The shut down of these lines was performed in phases:
hot standby, cold standby, and safe storage.
In hot standby, operational readiness was maintained, although the lines were not running.
In cold standby, ecuipment was valved out and maintained, although it woulc take one to three weeks to restore the ADU lines to operability.
In safe storage, vessels were emptied, uranium was removed, backflow prevention was implemented, equipment was isolated.
utilities were removed, and supporting administrative and operational requirements were deactivated (e.g..
calibrations were allowed to lapse etc.). The licensee indicated it would take a major effort to restart the ADU lines once they were in safe storage.
ADU Line 4 was' in safe storage. ADU Line 2 was in cold standby and was being prepared to be placed in safe storage.
The licensee had scheduled Lines 1 and 3 to be ) laced in safe storage in the near future.
Line 5 was scleduled to remain operational.
The inspectors reviewed Procedure Number 10-10.
Configuration Management Program - Fuel Manufacturing.
Revision 2. to determine if the changes to the ADU lines were in accordance with the procedure. The inspectors also reviewed the Change Initiation Request and Change Request Report for ADV Line 4.
A Safe Storage Sign Off List was required by the Change Request Report. This list detailed the actions necessary to place Line 4 in safe storage.
The inspectors reviewed the list, and field verified numerous items on the list as complete. The inspectors noted. and pointed out to the licensee, that some tags on the ADU line were already becoming illegible. The licensee indicated they would pursue improving the_ longevity and legibility of the tags.
The ins)ectors also noted that there were traces of ADV powder on t1e underside of the dewatering centrifuge (the sign off list had a step verifying the dewatering centrifuge and hopper had been cleaned). The licensee immediately removed the traces of ADU powder and made the observation a " lessons learned" for the other ADU lines.
(3)
Conclusions Based on this review, the inspectors determined that the changes made to place ADU lines 2 and 4 in safe storage were in accordance with the licensee *s configuration management procedure.
4 c.
Imolementation of Process Safety Controls (03.03)
(1)
Insoection Scooe Process controls identified in the Integrated Safety Analysis (ISA) for the new DCP/gadolinia shop integration equipment were reviewed for implementation in accordance with license requirements.
(2)
Observations and Findinas The inspectors reviewed the licensee's procedure for conducting an IEA. The inspectors also reviewed a summary of the controls identified through the ISA process for the gadolinia shop integration with DCP. The inspectors observed that the ISA identified more than 100 controls (both administrative and engineered). The inspectors chose to verify the implementation of twenty of these controls that dealt mainly with criticality and radiological safety issues. The engineered controls were reviewed by the
-inspectors were passive in nature. The inspectors verified the presence of the passive engineered controls by observation and discussed them with the cognizant individual. For the administrative controls, the inspectors verified that the controls were specified in either procedures or NSR/Rs.
In addition, the inspectors questioned one operator concerning controls in his area and received. satisfactory responses indicating an adequate level of operator knowledge relative to the controls.
(3)
Conclusions The licensee's safety controls identified in the ISA for the new gadolinia shop integration equipment were adequately implemented, d.
Review of Previous Lvents (03.07)
(1)
Insoection Scooe The internal investigation results for selected incidents occurring since the last operations inspection were reviewed for adequacy and timeliness of responses.
(2)
Observations and Findinas The inspectors reviewad the licensee's investigation report of the incident involving degraded moderation control in the DCP when the wrong additive was used during a uranium powder blend. This event was reported to the NRC Operations Center as Event Notice #33624. The inspectors observed that the licensee assembled a six-person investigation team to determine root causes and corrective actions. The
5 investigation team found the root ct"ses to include inadequate equipment identification oad inadequate training of operators on procedure changes. The corrective actions addressed these root causes by improving the system for identifying the different additives used: validating all existing procedures, including checklists: improving the j
method by which procedure changes are reviewed: and retraining the operators on current procedural requirements.
The Standard Operating Instruction (S0I) required the operator to confirm the proper labeling of the additive containers. The inspectors determined that since the containers were not labeled a violation of the procedural requirements occurred.
However, the inspectors determined that adequate safety margin existed to preclude a criticality accident due to using the wrong additive.
Specifically, the computer controls would have limited the total additive to less than the 3rescribed safety limit and the material conditions were suc1 that the likelihood of a criticality accident was low.
Thus, this failure to follow procedure is considered a violation of minor safety significance and is identified as a non-cited violation (NCV 98-01-02) consistent with Section IV of the NRC Enforcement Policy (NUREG-1600).
The inspectors reviewed the licensee's Unusual Incident Report (UIR) on the rupture of a DCP powder hopper feed line boot.
The DCP Jowder cooling hoppers became pressurized when repair worc on a system vent valve was aerformed. The vent valve was shut during the re) air work. Jut inlet gas flow to the hoppers continued. T1e hoppers subsequently pressurized and a flexible boot in the system developed a tear that caused airborne radioactivity in the hopper room.
No worker overexposures occurred.
The inspectors observed that the UIR was accurate in its assessment of the incident, except that the ins)ectors determined that a better implementation of tie licensee's lockout /tagout procedure should have been able to prevent this incident. This was not mentioned in the licensee's evaluation of the incident.
The inspectors discussed this with the licensee and found that ways to better implement the lockout /tagout procedure in DCP were being reviewed by the licensee.
The inspectors reviewed the licensee *s investigation of an incident in which a contaminpted component (600-2300 verses the limit of 1000 dpm/100 cm') was taken from the controlled area to an off-site machine shop without being properly surveyed and released.
The part was recovered and subsequent surveys of the machine shop showed no contamination. The release of contaminated equipment violated the requirements in paragraph 1.3.2 of the GE License Application (LA). This incident was documented as a Licensee-Identified Violation (LIV) by the licensee, was not expected to have been prevented by corrective actions for a
6 previous violation in the )ast two years, and corrective actions were committed to Jefore the end of this inspection.
The inspectors determined that the conditions in NUREG-1600 for NRC acceptance cf a LIV had been met.
Thus, this incident is identified as a NCV (NCV 98-01-03) consistent with Section IV of the NRC Enforcement Policy (NUREG-1600).
A higher level critique was also to be conducted by the licensee on this issue to determine if any further actions were needed. The results of this critique will be tracked as an Inspector Followup Item (IFI 98-01-04).
(3)
Conclusions The licensee's identification and correction of incidents that violated license requirements was adequate and timely.
The licensee was reviewing ways to improve implementation of its lockout /tagout procedure in the DCP areas.
e.
Follow-uo on Previous 1v Identified Issues (03.08)
(1)
Insoection Scooe A review of the licensee *s corrective actions for past open items was conducted for potential closure.
(2)
Observations and Findinas The inspectors reviewed the higher level criticue conducted by the licensee in response to the unauthorizec change to the pellet boat design tracked as IFI 97-08-02. The inspectors observed that the higher level critique recommended further corrective actions to be implemented that affected other types of portable containers (in addition to pellet boats) used for uranium processing. The target completion of these actions was documented as May 30.
1998. This IFI will remain open to follow the completion of these actions.
The inspectors reviewed the NRC approval of a change in the GE LA tlat addressed permitting personnel movement between controlled areas and non-controlled areas through access points other than change rooms. The inspectors determined that the approval of this license change completed the actions for closure of IFI 97-07-03.
(3)
Conclusions Actions followed in reference to IFI 97-07-03 have been completed and this item is considered closed.
Further actions were identified in reference to the incident being tracked by IFI 97-08-02 and this item will remain open.
l L
7 3.
Trainina (88010) F2.01. F2.02. F2.03. F2.04 (1)
Insoection Scoce The licensee *s general employee training was reviewed to verify it included the topics required by 10 CFR 19.12 and the LA.
(2)
Findinas and Observations The inspectors attended portions of the licensee's employee training (radiation worker training) course; discussed course content with licensee trainers: reviewed the course overview, course objectives, and course material: and reviewed the exam given to the workers after they attended the course.
This training called " Red-Bar" training by the license 9. is required prior to an employee being allowed access to airborne radioactivity controlled areas. The inspectors noted that the general employee training included general nuclear criticality safety training, general radiological safety training, and general emergency training.
The inspectors verified that the training included the topics required by 10 CFR 19.12 and by the LA. These topics included:
the storage. transfer. or use of radiation and/or radioactive material at the site:
the health risks associated with exposure to radiation e
and/or radioactive material:
precautions and procedures to minimize exposure:
e the purposes and functions of protective devices:
NRC regulations regarding the protection of personnel from exposure to radiation and/or radioactive material:
the responsibilities of site workers to immediately report to the licensee any condition which may lead to or cause a violation of NRC regulations:
the appropriate responses to warnings and alarms made in the event of an unusual occurrence that may involve exposure to radiation and/or radioactive material: and illustrations of evacuation routes through or around site buildings:
NRC Forms 3. 4 and 5. and general nuclear criticality safety principles.
~
The inspectors noted that the trainers made good use of past situations at the site to emphasize key points in the class.
For example, the students were given a detailed explanation of why
8 chewing gum and chewing tobacco should not be brought into the airborne controlled areas. The inspectors noted that the test required the students to sign a statement that they understood the licensee s )olicy about not carrying or consuming food or drink.
includin clewing gum and chewing tobacco. into airborne
'controll d areas. The inspectors concluded that the licensee's general employee training met tne requirements of 10 CFR 19.12 and Sections 3.4 and 3.4.1 of the LA.
Section 3.4.1 of the LA also requires that previously trained employees who are allowed unescorted access to the airborne radioactivity controlled areas be retrained at least every two years. The inspectors determined that training at GE was tracked electronically using the Radiological Data Management System (RDMS). GE's internal procedures require general radiological refresher training once 3er year. The refresher training is an abbreviated version of t1e training given to new employees (the aforementioned red bar training). The inspectors reviewed computer records for selected site individuals and confirmed that tney were retrained every year. The inspectors also determined, through discussions with training personnel, that the RDMS interfaced with the electronic system that controlled personnel access into the airborne controlled areas of the facility.
If an individual allowed their employee training to la)se, this electronic system would not allow access into t1e airborne controlled areas. The employee would also be required to retake the original red-bar training course.
Section 3.8 of the LA requires that personnel training and retraining records be maintained for at least three years.
The inspectors determined, through a review of RDMS records, that training and retraining records were maintained for greater than three years.
The inspectors also attended a monthly safety meeting.
Tnrough discussions with the licensee. the inspectors determined that one topic per month is discussed at these safety meetings.
A series of meetings are held each month on the selected topic so that all workers can attend. The safety meeting the inspectors attended focused on the different types of signs and postings in the facility. This included criticality. chemical, industrial.
radiological and fire safety signs and postings.
The format of the safety meeting attended by the inspectors was a contest with prizes given to the team of site personnel who could correctly answer questions about the signs and postings. The inspectors noted that answering the questions required very detailed knowledge and understanding of the signs in the facility.
The inspectors also reviewed the training provided for the DCP.
The. inspectors determined through discussions with cognizant licensee personnel, that DCP training was conducted for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for approximately three months.
The inspectors noted there were approximately 40 separate courses, of which 30 were
r l
9 tested. The inspectors reviewed the tests for several of these 4
courses. The inspectors also reviewed the training outline.
selected portions of the course material, and selected training records. The inspectors noted that the training was detailed and extensive.
(3)
Conclusions Based on this review, the inspectors concluded that general employee training included the to)1cs required by 10 CFR 19.12 and Section 3.4 of the LA: and that t11s training was provided to personnel with potential safety significant positions. The inspectors verified that retraining was provided more frequently than the once per two years required by Section 3.4.1 of the LA.
The licensee met the requirements for retention of training records as specified in Section 3.8 of the LA.
The inspectors also determined that the training for the DCP was detailed and extensive.
4.
Exit Interview On February 27, 1998, the inspection scope and results were summarized with licensee representatives. The inspectors discussed in detail the routine program areas inspected, and the findings, including the potential violation for criticality safety spacing controls.
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.
ATTACHMENT Licensee
- D. Brown.. Team Leader. Environmental Programs
- D. Dowker. Team Leader. Fuel Sup) ort
~*N. Dunne. Manager. Training and )evelopment Programs
- T. Flaherty.' Manager. Dry Conversion Project
- R. Foleck. Senior Licensing Specialist
- T. Henshaw. Acting Chemical Production Line Manager
- R. Keenan. Manager. Site Security and Emergency Preparedness
- G. Luciano. Area Engineer
- A. Mabry. Program Manager. Radiation Safety Engineering
- C Monetta. Manager. Environment. Health & Safety
- S. Murray. Team Leader. Chemical Conversion
- L. Paulson Manager. Nuclear Safety
- L. Quintana, Manager. Fabrication Product Line
- H. Strickler. Manager. Site Environmental. Health & Safety
- C. Tarrer. Leader. Configuration Management
- C. Vaughan. Acting Manager. Facility Licensing Other licensee employees contacted included engineers, technicians. production staff security and office personnel.
- Denotes those present at the exit meeting on February 27. 1998.
INSPECTION PROCEDURES USED IP 88020 Plant Operations IP 88010 Training LIST OF ITEMS OPENED. CLOSED, AND DISCUSSED Ooened 70-1113/98-01-01 VIO Failure to properly store unscanned drums containing radioactive materials per posted safety instructions.
70-1113/98-01-04 IFI Review results of higher level critique for release of contaminated equipment.
Closed i
70-1113/98-01-02 NCV.
Failure to follow procedure.
~70-1113/98-01-03 NCV-Release of contaminated equipment.
170-1113/97-07-03 IFI Personnel movement between controlled and uncontrolled areas.
g l
2 Discussed 70-1113/97-08-02 IFI Review of higher level critique for unauthorized change to pellet boat design.
ACRONYMS ADU Ammonium Diuranate DCP Dry Conversion Process GE General Electric IFI Inspector Follow up Item
'ISA Integrated Safety Analysis IP Inspection Procedure LA License Application LIV Licensee-Identified Violation MSG Milling, Slugging and Granulating NCV Non-Cited Violation NSR/R Nuclear Safety Release / Requirement RDMS Radiological Data Management System 50I Standard Operating Instruction VIR Unusual Incident Report