ML20217J867

Insp Rept 70-1257/98-201 on 980313-19.Violations Noted.Major Areas Inspected:Open Item Resolution,Configuration Mgt & Flowdown of Analytical Limits & Controls

ML20217J867
Person / Time
Site:	Framatome ANP Richland
Issue date:	04/01/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20217J859	List: ML20217J854 ML20217J867
References
70-1257-98-201, NUDOCS 9804070041
Download: ML20217J867 (14)

Text

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e U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS CRITICALITY SAFETY INSPECTION REPORT Docket No. 70-1257 License No. SNM-1227 Report No. 70-1257/98-201 Licensee: Siemens Power Corporation.

' Location: Richland, Washington 99352 Inspection Dates: March 13 - 19,1998 Inspectors: Dennis Morey Criticality Safety Inspector Approved By: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards 2 Enclosure 1 9804070041 900401 PDR ADOCK 07001257 C PDR

SIEMENS POWER CORPORATION NRC INSPECTION REPORT 70-1257/98-201 EXECUTIVE

SUMMARY

latroduction )

The NRC performed a routine unannounced criticality safety inspection at the Siemens Power j Corporation (SPC) located in Richland, Washington, from March 13 - 19, 1998. The inspection focused on NRC inspection open item resolution, configuration management, and flowdown of analytical limits and controls. The inspector reviewed older criticality analyses with broad application and followed controls from these analyses through covered operations to determine how effectively controls were implemented. The inspector reviewed plant changes for the past two years to determine how well the licensee configuration management program is followed.

During this inspection, the inspector identified a Non-cited Violation concerning an unapproved work procedure and an unapproved parameter sheet in a work area, opened two Inspector Followup items, and closed six open items from three previous criticality safety inspections.

RAults

• A Non-Cited Violation was identified concerning an unapproved work procedure and an unapproved parameter sheet posted in work areas.

• Six open items from three previous inspections were closed.

• The licensee has nearly completed an upgrade of criticality safety analyses. Where the safety basis rests on the remaining older Criticality Safety Analyses (CS As) there is not always a clear correlation between the controls mandated by the CSA and the controls that exist in the field. All required controls were in place.

• The licensee configuration management program allows a lower level of review for criticality safety related changes that are part of an ongoing, larger change. No inadequately reviewed change was identified.

• An incident report was identified that did not adequately characterize root causes or corrective actions. Although the report had weaknesses, the actions taken were adequate to resolve the incident. ,

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• Independent verification and documentation of the adequacy of Criticality Accident Alarm j System (CAAS) detector coverage for the Dry Conversion Facility (DCF) is complete and {

has been reviewed by a qualified criticality safety engmeer.  !

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• 1.icensee testing has established that CAAS audibility in the DCF is adequate.

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4 REPORT DETAILS 1.0 n 2 crations

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a. Lnnsstion Scosc License Section 2.5 requires that activities involving special nuclear material (SNM) be conducted in accordance with approved written procedures, standards and guides. During the course of the inspection, the inspector conducted walkdowns of several plant operating areas and observed procedural and criticality safety limit compliance. Areas reviewed included cylinder wash operations, Engineering Laboratory Operations (ELO),

the Dry Conversion Process, powder handling operations, and rod loading operations. ,

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b. Observations and Findings  !

l During the walkdown of the ELO building, the inspector observed what appeared to be an j unauthorized procedure taped to a utility hood in room 58. The handwritten, one-page {

procedure had 16 steps for the UO2ceramograph dissolution process, a process that was j last performed in December 1997. This process involves the dissolution of plastic encased J pellet samples from the laboratory. Operations statTindicated that the unauthorized procedure was written by a particular operator and attached to the hood about 18 months previously and was not used by the current operators. The licensee investigated the hood in question and also removed two interim procedures which were posted on the hood.

The interim procedures contained the work sequences for dissolution of UO2 ceramograph samples and boron pellets in the pencil dissolver. Both interim procedures were properly approved but had expired and been replaced with permanent procedures. Because the )

interim procedures were out of date and had been superseded, they were not being properly used in accordance with license requirements. No conflict with the approved work procedures was noted, and the safety significance is low.

The dissolution of UO 2ceramograph samples is an intermittent operation that is performed occasionally and was last performed in December 1997, but it is not clear that the dissolution had been performed in accordance with the interim procedure after it had expired. It was also not clear that any boron pellets had been dissolved after the interim procedure for that process had expired. The inspector noted that both the pencil dissolvers and the utility hood in question are planned to be removed under a pending ECN. The handwritten procedure and the two interim procedures were removed from the 1 hood, and the facility was inspected by the licensee for any additional unapproved  !

procedures. Licensee management plans an additional operator briefing on this issue j following the inspection. The presence of the handwritten ceramograph dissolution procedure and interim procedure violates NRC requirements. The inspector concluded that the safety significance was low because the presence of the unapproved procedures was confined to one hood which is used intermittently, and the informal procedures were in accordance with the approved work procedure. Licensee management stated that they l l

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l were attempting to eliminate the use of unapproved operator aids in the plant.

During a walkdown of the DCF, the inspector observed a Field Parameter Sheet taped to a filter housing near the line one reactor. The sheet contained operating parameters for the operation of the production line, specifically, settings for purge gases. The licensee indicated that equipment damage might result if the parameters were incorrectly set. The sheet was not signed by the originator, reviewed, approved, or dated. The sheet contained handwritten changes with a single set ofinitials. Licensee procedure EMF-858,

" Preparation of Parameter Sheets," requires that parameter sheets be reviewed and approved by a designated individual. The licensee procedure also requires that changes to an issued parameter sheet be initialed by the Process Engineer, his manager, and the affected area / process supervision. Licensee management indicated that the parameter sheet should have been signed and took immediate corrective action to replace all field parameter sheets in the DCF with properly issued documents. No incorrect parameters were apparent on the posted sheet, and the process engineer and criticality analyst both indicated that none of the parameters directly afTected the safety of the operation, so the inspector concluded that the safety significance of the unapproved parameter sheet was j low.

l These failures, in aggregate, constitute a violation of minor significance and are being l treated as a Non-Cited Violation, consistent with Section IV of the NRC Enforcement Policy. The presence of unapproved procedures and operator aids in work areas and the failure to document the review and approval of a field parameter sheet in use on DCF line one is NCY 70-1257/98-201-01.

c. Cnnclusions j Examples of expired or informal procedures in work areas were observed and are a l

concern because they are not reviewed and may not be changed as required. An ex imple of an improperly documented parameter sheet was observed in the DCF and is a co icern because parameter sheets are the means by which operators receive their instruction s for operation of the plant. No violations of criticality safety requirements or controls w :re I observed.

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2.0 r C_nili.cality Analysis

a. Insp_qction Scops License Section 4.1.2 requires that before any operation with SNM is begun or changed, it shall be determined that the entire operation or process will be suberitical under both normal and credible abnormal conditions. Safety Demonstration Section 14.1.3 contains a list of 11 requirements for the Second Party Review of CSAs. The inspector reviewed )

selected older CSAs for compliance with the above commitments.

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b. _ Observations and Findings The licensee currently uses 28 older criticality analyses which cover either specific operations or serve as the controlling safety analysis for plant-wide operations such as the use of safe batch containers or vacuum cleaners. The inspector reviewed two of these older general CSAs to determine if controls identified in them were actually in place in the .

plant. The specific CSAs reviewed were: ,

e. CSA GEN-1.0, Safe Batch Containers and Work Stations.

• CSA GEN-4.0,45 Gallon Drums- Loading, Transport, Storage, Lube Addition,  !

Tumbling.

These older analyses are not of the same quality as recently developed analyses such as those that cover the DCF. The inspector noted that no discussion of how double contingency requirements are met is included in these CS As. Also, the specific accident conditions of concern are not discussed. The technical analysis in the CSAs is clear and the limits and controls are developed and listed. How double contingency is met was apparent in the operations inspected.

Where the safety basis rests on older CSAs, there is not always a clear correlation between the controls mandated by the CSA and the controls that exist in the plant. The inspector walked through the complete dmm handling process to determine whether all the CSA limits and controls were fully implemented. The inspector determined that there are no specific controls to prevent the placing of a non-cenified drum into a multi-tiered array, rather, the accountability system prevents this from occurring by prohibiting admission of non-certified drums into the storage area where multi-tier stacking is done. Also, there is no specific control to implement the requirement that drum cones not be placed on non-certified drums. Improper installation of the drum cones is prevented primarily by locking non-certified drums into specific positions until the certification process is complete. The purpose of the cone is to funnel powder from inverted drums into the process line.

According to CSA GEN-0.4, if a powder filled drum was invened with a slight amount of moderator present in the drum, a criticality would occur in the cone. The inspector noted that controls in place have the collateral effect of preventing the installation of the cone, thus eliminating immediate safety concerns. The inspector noted that no specific 1 prohibition against installing a cone on a non-certified drum was apparent in procedures or postings. A single employee was responsible for installation of the cones, and the - )

employee was aware that the cones were not geometrically safe. There appeared to be  !

sufficient defense in depth to prevent placing moderated powder into the cones.

The licensee is expected to complete an upgrade of CSAs in June 1998 which is expected to eliminate this issue; This issue has been tracked by Region IV as an open item. Region IV staff have agreed to close their open item so that the issue can be tracked by Headquarters criticality safety staff. Upgrading of CSAs will be tracked as Inspector 4

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i Follow-up Item (IFI) 70-1257/98-201-02.

c. ' Conclusions Newer CSAs prepared by the licensee are of very high quality. There remain examples of older analyses for which limits and controls do not correspond directly with limits and controls in plant postings and work procedures. All of the older analyses are scheduled to be upgraded or replaced by operation specific analyses. No additional compensatory measures are expected to be required.

3.0 incident Investigation

a. Insprc.jion Scops License Section 4.1.5 requires that all reported criticality safety violations, incidents, or

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abnormal conditions shall be reviewed and appropriate corrective actions taken. The inspector reviewed the licensee process for conducting and documenting incident '

investigations to determine whether adequate investigations are conducted and corrective actions identified and completed. The inspector reviewed representative incident

. investigations from the past year to determine licensee compliance with the approved ,

process.

b. Observations and Findings l

The licensee conducts incident investigations in accordance with internal procedure EMF-p P81,002, " Incident Review and Investigation Boards." This procedure contains guidelines for Incident Investigation Board Teams including the composition of teams and the l conduct of the investigation including identification of the method of analysis. The inspector reviewed documentation of three Incident Investigation Boards:  ;

q e Overflow of hydrofluoric acid on December 10,1997. l e Loss of moisture control in the Dry Conversion Pilot Plant Screw Conveyor, Rotary Airlock Assembly and Reactor on September 16,1997. l

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e Incorrect spacing between stored fissile material arrays on June 10,1997.

The report of the investigation of the acid overflow demonstrated a thorough investigation with root causes credibly identified and adequate corrective actions listed. The report did not identify the method of analysis. . Licensee management noted that there are two methods of analysis in general use by facility staff, Taproot

• and Apollo *.

The report of the loss of moisture control in the Dry Conversion Pilot Plant also

' demonstrated a' thorough investigation with root causes credibly identified and adequate 5

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l corrective actions listed. This report identified the method ofinvestigation as Taproot

• Corrective actions for this incident include installation of additional engineered safety features in the Dry Conversion Pilot Plant prior to restart (complete status of the Dry Conversion Pilot Plant is discussed in Section 6.0). The inspector concluded that the licensee investigation of this loss of moisture control incident was adequate therefore VIO 70-1257/97-202-03 is considered closed.

The report of the spacing violation demonstrated a thorough investigation but did not identify the method of analysis, and several of the identified root causes did not appear appropriate. Essentially, the incident involved storing powder buckets within the three foot limit of stored filters. Only one of the six identified root causes referred to what was probably the real root cause, which was the creation of an error likely situation which occurred when two storage and handling areas were placed so close that their simultaneous use violated spacing requirements. The first two corrective actions, evaluate changing the location of one of the subject areas and conduct training on criticality safety limits, appear adequate to eliminate the problem. The third corrective action, complete corrective actions for another report and evaluate reportability under NRC Bulletin 91-01, does not appear to be a corrective action. An additional corrective action, a plant-wide review of storage locations, was undertaken and reported but was not listed as a l corrective action. The investigation and corrective actions resolved the incident

! adequately even though the fmal report was weak in the areas of root cause and corrective action identification.

c. Conclusip_ns The inspector observed a weakly documented incident investigation but noted no safety concerns. Overall, conduct and documentation ofincident investigations is adequate.

4.0 Configuration Managemen_t l

a. Insps_clipn Sc_ gps License Section 2.6.1 requires that complete and proper reviews are undertaken prior to and afler changes to facilities or equipment. The inspector reviewed the licensee configuration management program including a review of ECNs from the past two years to determine whether changes affecting criticality safety at the plant are adequately reviewed and approved by the criticality safety staff.

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l b Obseryttjanund_Eindi.ngs The licensee configuration management program is implemented through procedure EMF-858," Engineering Change Notice." Section 3.4 of this procedure requires that for projects involving fissile material, the Criticality Analyst will determine ifinspection by the Criticality Safety Review Team is required. If a Safety Review Team is required, the ECN is given a suflix of"C." In practice the procedural requirement requires a criticality analyst to determine whether the ECN is "C" and will, therefore, receive close scrutiny by the criticality safety staff The inspector reviewed ECNs for the past two years and identified six ECNs for modifications in fissile material areas that had not been reviewed by a criticality safety analyst. Inspection of these six ECNs revealed that two of them involved fissile material as follows:

• ECN 6233L dated 7/3/97 concerned a modification to the incinerator assay box.

• ECN 6252L dated I/7/98 concerned a modification to the pellet press.

The inspector observed that the decision not to classify these two ECNs as "C" was not l made by a criticality analyst but was instead made by the Safety Manager. The Safety Manager stated that he had once been a criticality analyst and was therefore qualified but agreed that this action did not conform to the procedural requirements. All"C" ECNs that were reviewed were found to contain appropriate review by the criticality safety engineer. The safety significance of the failure to have these two ECNs reviewed by a criticality analyst is low because the modifications do not affect the criticality safety basis l of the operation. The licensee committed to ensure that all ECNs would be reviewed by a criticality analyst, efTective immediately.

l The inspector noted a weakness in the licensee configuration management program in that modifications that would clearly require criticality safety analyst review if performed under a unique ECN do not require and do not always receive such review if performed as a field I

change under an open ECN. The inspector reviewed the following two field changes performed under ECN 6170C for the DCF line one:

• Installation of an on/ofTswitch to calciner and blender moisture analyzers.

• Installation of a cone to the powder preparation area lid seal device.

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The on/off switch allows the power to the calciner and blender moisture analyzers to be turned offin order to perform a weekly check of the interlock preventing operation of the equipment if the moisture analyzer is inoperable. The cone in the powder preparation area helps mix powder as it flows into 45 gallon drums so that smaller particles do not lump together in the center of the drum. The licensee indicated that both of these items would have required criticality safety review if they had been performed under a separate ECN.

The criticality safety specialist indicated that neither item would have been classified as a "C" ECN so the safety significance is low. The inspector did not observe a direct conflict '

with the ECN procedure. Licensee management indicated that they would immediately investigate and correct this weakness in the configuration management program.

Upgrading the requirements for field changes in the configuration management program  ;

I will be tracked as IFl 70-1257/98-201-03.

c. Conclusions The license configuration management program is adequate to prevent undetected changes to safety systems and, with the exception of the NCV above, is followed by licensee employees. The inspector did not identify any safety significant item that had not received adequate review. A weakness was identified in the way the configuration management program deals with changes to an ECN that is in process.

5.0 CAAS Configuration

a. Lnsp_estion Scope  ;

The inspector reviewed the Criticality Accident Alarm System (CAAS) and supporting documentation to determine whether calculations supporting the placement of a new alarm detector in the DCF had been reviewed by a qualified criticality specialist. The inspector also reviewed licensee actions to establish CAAS annunciator audibility under all plant conditions

b. Observations and Findings The licensee uses BF3 neutron detectors in clusters of three with one or two clusters connected to a two-out-of-n logic system. The inspector determined that the licensee had performed extensive computer aided analysis of the estimated neutron field throughout the facility including the new detector cluster in the DCF. Redundant coverage by criticality j alarm detectors was in place. The analysis of CAAS detector placement and coverage was J reviewed by the licensee senior criticality safety engineer. The inspector determined that all significant structures and equipment appear to have been incorporated into the analysis.

Because shielding is extremely important when neutron detectors are used, the inspector looked for unanalyzed shielding that might affect the neutron flux near the detector. No unanalyzed shielding was identified.

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The inspector reviewed additional licensee actions taken to assure CAA S audibility in all areas of the DCF. The inspector observed that ambient noise conditions in the DCF under normal steady state conditions were roughly equivalent to a standard office environment.

The DCF was relatively quiet and hearing protection was not normally required. The licensee identified the noisiest operation as the hammermill in the powder blending area.

When the hammermill is operating, the noise level is approximately 85 dB. The licensee performed a measurement of the CAAS horn audibility in the powder blending area with the hammermill operating and determined that the alarm noise level was approximately 95 dB or approximately 10 dB above the ambient noise. Based on this information, the inspector determined that CAAS detector coverage and audibility is adequate and IFl 70-1257/97-202-02 is considered closed.

c. Conclusions Independent verification and documentation of the adequacy of CAAS detector coverage for the DCF is complete and has been reviewed by a qualified criticality safety engineer.

CAAS audibility in the DCF is adequate.

Sound pressure measurements have been conducted in the DCF and CAAS annunciators have been found to produce noise at least 10 dB above ambien' as required by ANSI /ANS 8.3.

6.0 Dry Conversion Pilot Plant

a. Ln_spection Scope The inspector reviewed corrective actions associated with the loss of moisture control in the Dry Cor. version Pilot Plant to determine that adequate controls are in place to prevent a repeat occurrence in this facility.

b. Observations and Findings The Dry Conversion Pilot Plant has been shut down pending completion ofcorrective actions and remains shut down as of the time of this inspection because all corrective actions have not been completed. Corrective actions following the September 1997 loss of moisture control event were:

• Shutdown of the facility

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• Evaluation of additional engineered moisture barriers  !

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• Installation of additional engineered barriers

• Revision of atTected Dry Conversion Pilot Plant SOPS There are currently no plans to restart or otherwise use the Dry Conversion Pilot Plant.

The licensee has not yet made a decision regarding reusing or abandoning the facility and is aware of the requirement to decommission if the facility is shutdown for two years. The plant has been partially disassembled but has not been completely disassembled because there remains a slight possibility that it may be needed. The pilot plant Criticality Safety Standard (CSS) has been revised to prohibit use of the plant and this and other plant controls appear adequate to insure that the plant will be upgraded as needed before it is restarted. Therefore, IFI 70-1257/97-202-01 is considered closed.

c. CAnglusions Corrective actions in the Dry Conversion Pilot Plant are not complete and the plant will remain shutdown until their completion.

7.0 Open item Review

a. Inspection Scops The inspector conducted walkdowns of plant operating areas and interviews of plant staff to confirm completion of corrective actions for six open items. Areas reviewed included  ;

cylinder wash operations, ELO operations, and the Dry Conversion Process. All six open items are discussed below, and three are also discussed elsewhere in this report.

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b. Observations and. finding: i I

(Closed) VIO 70-1257/96-201-01 concerned the failure to confirm that evaluated geometry spacing controls were in place and functional for the mop water dissolution tank i and dolly system. The inspector conducted a walkdown of the operations in the ELO {

Building. The walkdown covered the pellet dissolution, solvent extraction and mop water l recovery facilities. Various laboratory operations are also conducted in the building. The j inspector observed that six inch bumpers have been installed on the " pencil" dissolver )

tanks which were formerly used for the recovery of powder from mop water. The pencil 1 dissolvers are no longer in use for mop water recovery and are pending removal under an ECN. Powder recovery from mop water is now performed in a permanently installed system in the ELO building. One of the pencil dissolvers is occasionally used to support laboratory operations and is expected to be replaced. All corrective actions are complete and with the removal of the dissolvers from the facility, no safety issues remain, therefore, VIO 70-1257/96-201-01 is considered closed.

(Closed) VIO 70-1257/96-206-01 concerned the failure to update a posted criticality 10

safety limit card for the cylinder wash operation to reflect a change in a CSS limit. The inspector reviewed postings in the cylinder wash area to confirm that the correct limit card was posted. The criticality limit card P90,034 was identified on the licensee Criticality Safety Limit Card Index and the licensee on-line document control system. The inspector determined that the correct version of the card, revision 3, is now posted, therefore, IFI 70-1257/96-206-01 is considered closed.

(Closed) IFl 70-1257/96-206-02 concerned speakers associated with safety systems having material packed inside. The inspector observed emergency and communication speakers during walkdowns in various parts of the plant and noted that no speakers had material packed insik The licensee provided copies of plant operation communications sheets and attendance rosters which indicated that plant employees had been briefed on the problem of muffling speakers in the plant. In addition, licensee management provided

- documentation including plant drawings and checklists which demonstrated that all speakers in the plant had been physically checked, therefore, IFI 70-1257/96-206-02 is considered closed.

(Closed) IFI 70-1257/97-202-01 concerned the failure to install all of the mitigative  ;

features identified in the Dry Conversion Process Hazards Evaluation. The inspector

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determined that the plant Criticality Safety Standard (CSS) for the Dry Conversion Pilot Plant has been revised to prohibit use of the plant. This and other plant controls appear adequate to insure that the plant will be upgraded as needed before it is restarted.

Therefore, IFI 70-1257/97-202-01 is considered closed.

(Closed) IFl 70-1257/97-202-02 concerned the lack ofindependent technical review and approval of CAAS coverage determinations. The analysis of CAAS detector placement and coverage was reviewed by the licensee senior criticality safety engineer. The inspector determined that all significant structures and equipment appear to have been incorporated into the analysis. The licensee performed a measurement of the CAAS horn audibility in the noisiest area of the plant and determined that the alarm noise level was approximately 10 dB above the ambient noise. The inspector determined that CAAS detector coverage and audibility is adequate and IFI 70-1257/97-202-02 is considered closed.

(Closed) VIO 70-1257/97-202-03 concerned the failure to conduct an adequate and  ;

complete incident investigation following the April 1997 loss of moderation control event  !

at the Dry Conversion Pilot Plant. Corrective actions for the second occurrence of this incident in September of 1997, include installation of additional engineered safety features l in the Dry Conversion Pilot Plant prior to restait. The inspector concluded that the  !

second licensee investigation of the loss of moisture control was adequate. Therefore, VIO 70-1257/97-202-03 is considered closed.

c. Conclusions Corrective actions are completed and adequate for the open items reviewed.

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ITEMS OPENED, Cl,OSED, AND DISCUSSED Opened NCV 70-1257/98-201-01 Concerns the presence of unapproved procedures, operator aids and an improperly documented parameter sheet in work areas.

IFI 70-1257/98-201-02 Concerns licensee action to upgrade older CSAs to the more rigorous standards of recent CSAs.

IFl 70-1257/98-201-03 Concerns a weakness in the requirements for criticality safety l review of field changes to ECNs.

l Closed _

VIO 70-1257/96-201-01 Concerned the failure to confirm that evaluated geometry spacing controls were in place and functional for the mop water dissolution tank and dolly system.

i VIO 70-1257/96-206-01 Concerned the failure to update a posted criticality safety limit card for the cylinder wash operation to reflect a change in a CSS limit.

IFl 70-1257/96-206-02 Concerned speakers associated with safety systems having material packed inside.

IFl 70-1257/97-202-01 Concerned the failure to install all of the mitigative features identified in the Dry Conversion Process Hazards Evaluation.

IFI 70-1257/97-202-02 Concerned the lack ofindependent technical review and approval of CAAS coverage determinations.

VIO 70-1257/97-202-03 Concerned the failure to conduct an adequate and complete incident investigation following the April 1997 loss of moderation control event at the Dry Conversion Pilot Plant.

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o MANAGEMENT MEETINGS l The inspector met with SPC management periodically during the inspection. The inspector presented the inspection scope and findings to members oflicensee stalTat the conclusion of the inspection on March 19,1998. The licensee acknowledged the findings presented.

PARTIAL LIST OF PERSONS CONTACTED Sigmg_ns Power Cnrporating Bernard Femreite Vice President of Manufacturing Bernie Bently Manager, Operations Loren Maas Manag;r, Regulatory Compliance JefT Diest Criticality Safety Nak Urza Manager, Manufacturing Technology Cal Manning Criticality Safety Andy McGehee Criticality Safety Doug Kilian Manager, Manufacturing Engineering Hugle_ar Regulatpry Commission Dennis Morey, Criticality Safety inspector, NRC Headquarters ACRONYMS USED CAAS Criticality Accident Alarm System CSA Criticality Safety Analysis CSS Criticality Safety Specification DCF Dry Conversion Facility ECN Engineering Change Notice ELO Engineering Laboratory Operations SNM Special Nuclear Material  !

SOP Standard Operating Procedure SPC Siemens Power Corporation 13