ML20217R056

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Trip Rept of 980330-0403 Visit to W Columbia Fuel Fabrication Facility Re Operations at Facility,Licensing Issues & Documentation on Submittals of Criticality Safety Analyses/Criticality Safety Evaluations
ML20217R056
Person / Time
Site: Westinghouse
Issue date: 04/21/1998
From: Harry Felsher
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Weber M
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9805130160
Download: ML20217R056 (8)


Text

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, I 8 E NUCLEAR REGULATORY COMMISSION l WASHINGTON, D.C. 20665-4001

[ April 21, 1998 )

MEMORANDUM TO: Michael F. Weber, Chief Licensing Branch Division of Fuel Cycle Safety i and Safeguards, NMSS THRU: Mary Adams, Section Chief Licensing Section 1 /

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Licensing Branch 4 Division of Fuel Cycle Safety and Safeguards, NMSS THRU: Joe Giitter, Section Chief Licensing Section 2 dlM IU Licensing Branch  !

Division of Fuel Cycle Safety and Safeguards, NMSS l FROM: Harry Felsher Licensing Section 2 h M y/d4/ %

Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS

SUBJECT:

TRIP REPORT FOR WESTINGHOUSE COLUMBIA VISIT MARCH 30, TO APRIL 3,1998 The purpose of the trip was to familiarize Nuclear Regulatory Commission (NRC) sta'; with the operations at the Westinghouse Electric Corporation (WEC) Columbia Fuel Fabrication Facility, to participate in an open meeting with the licensee on licensing issues, and review documentation on the submittals of Criticality Safety Analyses (CSAs)/ Criticality Safety Evaluations (CSEs) as requireo oy License Condition S-2.

In the aftemoon of March 30,1998, NRC staff (Chuck Gaskin, Harry Felsher, and Pam Shea)  !/

7 met with WEC staff to discuss site orientation and was provided a tour of the chemical side of '/

the fuel fabrication process by WEC staff (Tommy Shannon). In preparation for the inventory to be started the following week, most of the chemical side was being taken apart for cleanup. _j-l However, the mechanical side was stillin operation. in the moming of March 31,1998, the tour ///gG continued with the same WEC and NRC personnel visiting the mechanical side of the fuel /

fabrication process. On both days, Mr. Shannon answered NRC staff's questions concerning the manufacturing process, equipment used, and safety issues at WEC.

In the afternoon of March 31,1998, and morning and aftemoon of April 1,1998, NRC staff met with WEC staff to discuss licensing issues. A summary of the items discussed and a list of participants are provided in the attachment.

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In the moming of April 1,1998, WEC staff (Shannon and Dan Colwell) met with NRC staff (Shea) to discuss and review the Records Management Program at WEC. How WEC tracks and utilizes the computer systems and where and how hard copy documents are stored were discussed. The program was reviewed relative to how well it compared with the draft NRC Standard Review Plan.

Later in the moming cf A pril 1,1998, WEC staff (Shannca and others) met with NRC staff (Gaskin, Felsher, and S'ua) about WEC's MAPCON cystem (computerized maintenance control program) and the Year 2000 (Y2k) problem at WEC. The MAPCON system ulas

- discussed and "vious scenarios were described wherein MAPCON would alert WEC staff ,

when operationW o. preventative maintenance was required. NRC staff raised a concem about l manual input of dates into MAPCON which could affect maintenance at the site. WEC i committed to investigate this concem. WEC recognized the Y2k problem and has a team i working on addressing this issue. j From March 31 through April 2,1998, NRC staff (Craig Hrabal) reviewed the CSEs for the ADU Process, Powder Blending, and UN Bulk Storage Tanks. NRC staff conclusions will be made in the forthcoming Safety Evaluation Report (SER). On April 2,1998, NRC staff (Felsher)  ;

reviewed the CSE for the UN Bulk Storage Tank as well as a programmatic review of the l Ventilation System ISA.

On April 2,1998, NRC staff members (Hrabal and Felsher) met with WEC staff (Norm Kent) to i discuss the changes to Chapter 6, " Nuclear Criticality Safety" of WEC's license. WEC understood that the NRC may request additional information from WEC when the revised Chapter 6 (Revision 10)is reviewed.

On April 2,1998, NRC staff members (Hrabal and Felsher) met with WEC staff members (Bob Williams and Kent) to discuss how WEC intends to inform NRC of changes in the License Annex. Currently, WEC's License Annex consists of summaries of CSEs/CSAs. License Condition S-2, which requires summaries of CSEs/CSAs for the License Annex, may be deleted in the near future based on either (1) NRC staff review of the CSEs onsite or (2) summaries of the CSEs/CSAs submitted to NRC. Modifications to the License Annex will be made when an ISA summary is complete for a particular system (which would replace the CSE/CSA summary fer the system) or when the safety basis in the CSE/CSA changes. After all systems have ISAs, the License Annex will consist of ISA summaries of the individual systems.

After the License Annex is in the form of ISA summaries, there needs to be a mechanism to update NRC's copy of the License Annex. WEC proposed the following method:

. WEC determines that a change in the ISA summam does not decrease the effectiveness of the license commitments

. WEC modifies the License Annex

. WEC informs the NRC Project Manager of the modification (via facsimile or e-mail)

. within 30 days after WEC modifies the License Annex, WEC submits updated License Annex pages to the NRC for review

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3 The actual method of updating the License Annex will be mutually agreed upon by WEC and NRC.

On April 2,1998, WEC informed NRC staff onsite that a high-high level monitor in a moisture tank had failed. This failure was discovered when WEC tested the monitor when the moisture tank was being cleaned out for inventory. Before the tank is put into operation again, the .

monitor will have to pass a functional test. Even though this was not a reportable event, WEC I wanted to facilitate good communication with the NRC.

Attachment:

As stated Docket 70-1151 License SNM-1107 l

cc: Mr. Robert A. Williams  !

Safeguards Coordinator i Westinghouse Electric Corporation Commercial Nuclear Fuel Division Drawer R Columbia, South Carolina 29250 l

l Distribution

' Docket 70-1151 P~I NRC File Center ;lPUBLiCy3 ,

FCSS r/f NMSS r/f FCLB r/f Region ll DCollins, Ril

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  • See Previous Concurrence OFC FCLB FCLB FCLB FCLB FCLB NAME HFelsher
  • CGaskin
  • PShea
  • JGiitter
  • Madams
  • DATE 04/ /98 04/ /98 04/ /98 04/ /98 04/ /98 l

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. 3 The actual method of updating the License Annex will be mutually agreed upon by WEC and NRC.

On April 2,1998, WEC informed NRC staff onsite that a high-high level monitor in a moisture tank had failed. This failure was discovered when WEC tested the monitor when the moisture

.tr k was being cleaned out for inventory. Before the tank is put into operation again, the  !

monitor will have to pass a functional test. Even though this was not a reportable event, WEC I wanted to facilitate good communication with the NRC.

Attachment:

As stated Docket 70-1151 License SNM-1107 cc: Mr. Robert A. Williams Safeguards Coordinator Westinghouse Electric Corporation Commercial Nuclear Fuel Division Drawer R Columbia, South Carolina 29250 I

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Westinghouse Electric Company Meeting Meeting Summary March 31 - April 1,1998 Tha following items were discussed at the open meeting and are listed along with discussion summaries for each item:

o WEC's proposed revised license notification criteria (Section 3.7.3 of license) j Discussion summary - At tha NRC/WEC management meeting January 9,1998, WEC  !

committed to reconsider its communication procedures to ensure their clarity and effectives3s.

WEC believed that the proposed license amendment for notification criteria (TAC NO. to be determined) adds additional clarification and criteria for notifying both the NRC Operations j Center as well as the NRC Region II Office. WEC explained that there was a flowchart of responsibilities that defined the duties of personnelinvolved in a notification event. WEC staff, l management, and members of the incident Review Committee all have duties assigned to them in the course of an event and the investigation of the event. WEC explained their views on the start of the clock (recognizent engineer onsite), what constitutes an analyzed system (CSA/CSE), and the purpose of adding notification to Region ll (to facilitate communications with the NRC).

As a result of the discussion, WEC intended to submit a license amendment concerning changes to the notification criteria (Revision 11) to the NRC on April 3,1998.

o WEC's proposed consolidation of License Chapter 6, " Nuclear Criticality Safety" Discussion summary - Prior to the plant visit and after talks between WEC and NRC, it was agreed that WEC would withdraw the four smendment requests regarding Chapter 6 (Revisions 2,4,6, and 9) and submit one license amendment which would include not only the changes from the previous revisions but others as well. WEC informed NRC that the withdraw letter had been sent (dated March 3,1998,) but it had not been received before the trip. WEC l explained that Revision 10 would also include changes to Chapter 3 as well as changes to Chapter 6 due to editorial content. Discussions centered on the use of geometry, definitions in reflection, the sensitivity of k-effective, conduct of operations review, and changes to the Control Parameter Table. WEC understood that NRC may send a Request for Additional Information (RAl) when Revision 10 is reviewed.

As a result of the discussion, WEC intended to submit Revision 10 to the NRC on March 31, 1998. Afterwards, WEC intends to respond quickly to a forthcoming NRC RAl.

ATTACHMENT

2 {

o WEC's methodology on CSAs, CSEs, and Integrated Safety Analyses (ISAs) l j

l Discussion summary - Each system at WEC will have at least a CSA. For higher-ris,:, t r more complicated systems, a CSE will be performed instead. In either case, an ISA will be performed on the system. If the safety basis changes, the CSA or CSE as well as the ISA and j

. License Annex will be changed via WEC's configuration management program. Since WEC's methodology on the relationship between CSAs, CSEs, ISAs, and the License Annex are {

unique, WEC presented a summary (see below) of where the parts of the ISA which deal with criticality safety are from as well as what information will be in the License Annex after the ISA 3 is complete. Thus, once all the ISAs are complete, the License Annex would consist of approximately 35 binders, each containing the safety basis for a system at WEC. Until the ISA for the system is complete, the License Annex for the system will be a summary of either the CSA or CSE for that system.

Pcrts of the ISA and whether they are from a CSE or a CSA CHAPTER SECTION CSE CSA 1.0 Process Description XXX 2 0 Process Theory XXX l 3.0 Design of Equipment XXX 4.0 Drawings and Procedures XXX l

l 5.0 Safety Analysis 5.1 Radiation / Environment 5.2 Criticality / Safeguards XXX XXX 5.3 Fire / Chemical 6.0 Process Hazards Analysis 6.1 HAZOP/Wl/CL XXX 6.2 Fault Trees XXX XXX 6.3 Event Trees 7.0 License Conditions XXX 8.0 Appendices 8.1 Consequence Analysis 8.2 NCS Sensitivity Analysis XXX XXX 9.0 Photographs XXX 10.0 Integrated Safety Analysis

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Items that will be in the License Annex after the ISA is complete Summary of 1.0 Process Description 4.0 Drawings and Procedures Controls from 5.1 Radiation / Environment Controls from 5.2 Criticality Safety / Safeguards Controls from 5.3 Fire / Chemical 6.2 Fault Trees (for both CSE and CSA systems)

As a result of the discussion, NRC has a better understanding of the relationship between WEC's ISA and CSEs/CSAs and of what WEC intends to submit in an ISA summary License Annex. WEC informed NRC that the Ventilation / Scrubber system ISA summary License Annex l had been submitted to NRC on March 27,1998.

o WEC's schedule of submittal of CSAs/CSEs Discussion summary - In a December 12,1997, letter to Division of Fuel Cycle Safety and Safeguards (FCSS) Director, Elizabeth Ten Eyck, WEC committed to enhance the interim design basis of the plant in part by upgrading the CSAs/CSEs and summaries (in the form of the License Annex) which would be submitted to NRC on a mutually agreed upon schedule.

WEC wanted to review the revised schedule which would be submitted to NRC. NRC informed WEC that it would be best to develop a reasonable schedule that includes commitments that could be met.

As a result of discussion, WEC intends to review the revised CSE/CSA schedule and submit it as part of WEC's addition to the December 12,1997, letter.

o WEC's uncoming projects Discussion summary - WEC wanted to inform NRC of the possibility of an upcoming project concerning the use of downblended High Enriched Uranium (HEU) and plutonium (Pu) to make fuel for its customers. Several issues are still undecided, including whether the enrichment would be greater than 5 wt.% U-235 and what the health physics effects would be in dealing with plutonium dioxide in addition to uranium dioxide. NRC replied that current license conditions do not allow greater than 5 wt.% U-235 material and it would be WEC's responsibility ,

to provide the safety basis in order to receive a license amendment to use t5e proposed material.

As a result of the discussion, WEC intends to investigate the downblending project further before submitting a license amendment application.

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4 o Submittal of information to the NRC l

Discussion summary - NRC reminded WEC to include its docket number in all licensing

submittals to the NRC and to send the licensing submittals directly to the docket room. NRC informed WEC that it would be a reasonable idea to call the project manager to advise that a licensing submittal was being made and/or send a facsimile or direct copy. WEC and NRC reviewed the list of submittals made since January 1,1998, and no discrepancies were found.

WEC intends to submit a complete copy of its license (with a new revision number and date) after Revisions 10 and 11 have been approved as amendments.

As a result of the discussion, WEC intends to submit license amendments for changes to  ;

Chapter 6 and 3 (Revision 10) and the notification criteria in Chapter 3 (Revision 11). In '

addition, WEC will submit a complete license application (Revision 12).

Westinghouse Electric Company Meeting ATTENDANCE LIST l

March 31,1998 NAME TITLE Robert A. Williams WEC Advisory Engineer, Regulatory Affairs Norman A. Kent WEC Senior Engineer, Regulatory Affairs Jim Bush WEC Manager, Manufacturing Spencer Gantt WEC Senior Regulatory Engineer Pam Shea NRC Licensing Branch Hrrry Felsher NRC Licensing Branch Charles E. Gaskin NRC Licensing Branch Project Manager Craig Hrabal NRC Licensing Branch Jack Allen WEC Fuel Fabrication Facility Plant Manager l

l Wilbur L. Goodwin WEC Manager, Regulatory Affairs Din Colwell WEC Measurement Control Coordinator, Principal Engineer, Regulatory Affairs Bill Newmyer WEC Engineer, Regulatory Affairs

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