ML20236K768

Insp Rept 70-1151/98-203 on 980622-26.Violation Noted. Major Areas Inspected:Criticality Safety Program

ML20236K768
Person / Time
Site:	Westinghouse
Issue date:	07/07/1998
From:	Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
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ML20236K763	List: ML20236K759 ML20236K765 ML20236K768
References
70-1151-98-203, NUDOCS 9807100075
Download: ML20236K768 (18)

Text

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U.S. NUCLEAR REGULATORY COMMISSION DFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS CRITICALITY SAFETY INSPECTION REPORT Docket No: 70-1151 License No: SNM-1107 Report No: 70-1151/98-203 l Licensee: Westinghouse Electric Corpo.ation

. Commercial Nuclear Fuel Division Location: BlufrRoad Columbia, SC l Dates: June 22 - 26,1998 l

i Inspectors: Dennis Morey, inspector NRC Headquarters i Albert Wong, Inspector NRC Headquarters l Doug Outlaw, Consultant SAIC Approved by: P. Ting, Chief Operations Branch Division of Fuel Cycle Safety  !

and Safeguards, NMSS l l

Enclosure 2 9807100075 980707 PDR ADOCK 07001151 C pg

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• WESTINGIIOUSE ELECTRIC CORPORATION NRC INSPECTION REPORT 70-1151/98-203 EXECUTIVE SUMM ARY Introduction I The NRC performed a routine, announced criticality safety inspection at the Westinghouse l .

Columbia Fuel Manufacturing Facility in Columbia, South Carolina, from June 22 - 26,1998.

The objective of the inspection was to review the adequacy of the licensee's criticality safety program and assess corrective actions for open items. The inspector reviewed plant operations, configuration management, criticality analysis, reliability of controls, internal audits and inspections, and the status of 18 open items.

During this inspection, the inspector identified one violation (VIO) concerning the failure to verify calculations that support criticality safety limits, two inspector follow-up items (IFI) concerning reliability of controls and verification of analytical assumptions, and two unresolved items (URIs) concerning licensee criticality calculations and computer code verification.

I Results l

e The licensee has reduced reliance on administrative controls (Section 1.0).

e The licensee has committed to upgrade HF procedures to prevent recurrence ofIIF exposure (Section 1.0).

I e A weakness was identified in the licensee configuration management program in that review by safety staff of a configuration change installation is not required (Section 2.0).

• A URI was identified regarding licensee calculational results in the Criticality Safety Evaluation (CSE) for the granulator hopper showing k,y greater than 0.95 (Section 4.0).

e A violation was identified because the licensee was using unverified criticality calculations to support the interaction analysis of the solvent extraction process (Section 4.0).

e A URI was opened pending review oflicensee computer code validation (Section 4.0).

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i e One URI, four IFIs, and eight Violations were closed (Section 7.0).

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i e The inspectors determined that the licensee had not provided an adequate response to Inspection Report 96-204. The licensee was given 30 days to respond to the violations cited in the report (Section 6.0).

l REPORT DETAILS i l

1.0 Plant Onerations 1 1

a. Insnection Scone  !

During the course of the inspection, the inspectors conducted walkdowns of plant oper,ating areas and observed compliance with criticality safety limits and controls. Areas reviewed included ammonium di-urinate (ADU) processing, solvent extraction, powder preparation, and fuel mechanical assembly.

The inspectors reviewed a hydrofluoric acid (HF) incident that had occurred in March of 1998. The inspectors toured the HF bulk storage tank area where the accident had ,

occurred, interviewed affected personnel, and reviewed applicable documents.

b. Obsenations and Findings 1 The inspectors completed a general plant tour of the fissile material areas. The general plant walkdown did not raise any safety significant issues. Criticality safety-related housekeeping was observed to be generally good. The inspectors noted that licensee criticality safety controls in the plant are based primarily on operator training, postings specific to the operation or equipment, and moderator exclusion zones.

The inspectors observed that criticality safety postings were used sparingly and contained only those instructions required for the specific application. Instructions contained in the criticality safety postings were clear and concise. The inspectors noted that the licensee has reduced reliance on administrative controls throughout the plant and planned corrective actions will further reduce this reliance.

The inspectors also completed detailed walkdowns of several selected systems, including the Pellet Line Granulator Hopper, the Pellet Ventilation System Moisture Drop-Out Tank, and the Solvent Extraction System. Each of these specific systems was discussed with the criticality safety engineer and the cognizant process engineer. No safety significant issues were identified.

I On March 10,1998, three licensee employees were exposed to what is believed to have l

been hydrofluoric acid when they were working near the HF transfer pump in the outside 3

liF bulk storage area. Two employees were treated by onsite medical personnel and released. The other employee suffered a second degree chemical burn and was transferred to a local hospital for further treatment. All three employees recovered from the injuries.

The inspectors determined that the first employee went into the diked area near the HF transfer pump with only cotton work coveralls, inadvertently brushed up against a wet hose and came into contact with acid solution. Later, a second employee was assigned to work near the liF transfer pump. The second employee was wearing an acid suit, acid resistant gloves, face shield and safety glasses. The third employee, wearing no personal protective equipment (PPE), was standing outside the diked area. A technician wearing a fully enclosed suit with supplied breathing air from a nearby air bottle drained a portion of the pipe into a plastic bucket and handed the bucket to the second employee. The bucket had been sitting in the diked area for some time and had become brittle due to exposure to ultraviolet light. As the second employee was leaving the diked area, the i

bucket broke apart and fell to the ground, acid splashed out and hit the employee on the neck, cheek and face, and the employee immediately went to the nearest safety shower to wash himself. The third employee, who was not wearing PPE, was exposed to acid I when he rushed to provide assistance to the second operator. The first and the third l employees were treated at the licensee's on-site dispensary and the second employee was sent to the hospital for further medical attention. The technician was uninjured.

The licensee subsequently identified that inattention to surrounding equipment was the l root cause of why the first operator was hurt. The second operator's injury was attributed to the fact that proper PPE was not specified for the type of work he was tasked to perform. Absence of PPE was the reason why the third operator was injured.

To prevent recurrence of this event, the licensee has completed the following corrective actions:

• Placed warning signs specifying the minimum level of PPE at the HF storage area entrance gates.

• Conducted additional IIF safety training for employees handling liF including a review ofIIF material safety data sheet (MSDS), PPE requirement, and first aid treatment.

• Revised the IIF Handling Procedure (COP-836003) to specify the level of PPE needed for the type of work to be performed in or near the HF area.

Implementation of the HF safety procedure will be tracked as Inspector Followup Item (IFI) 70-1151/98-203-01.

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c. Conclusions No safety significant issues or violations were observed during plant walkdowns. The inspectors observed that the licensee has reduced reliance on administrative controls. The licensee safety margin improvement program and corrective actions to recent events are expected to further reduce the reliance on administrative controls. Licensee corrective actions to prevent ilF exposure events appeared to be adequate to prevent the recurrence of accidents involving spilled HF.

2.0- Configuration Management

a. Inspection Scops The inspectors reviewed the licensee configuration management program to determine whether it was adequate to insure appropriate review by the criticality safety function of changes to equipment or processes affecting criticality safety.

b. Observations and Findings The licensee has developed a configuration management program over the past eight years which is controlled by licensee procedure TA-500. This procedure requires the use oflicensee form TAF-500-1 which describes the reviews required for implementation of a change. The inspectors observed that changes are required to be reviewed by responsible safety staffincluding criticality safety staff and the requirements appear to be well established in plant operations and procedures. The inspectors noted that the entire plant is not under full configuration control. About half of the licensee operations are under full configuration control and the remainder are under limited configuration control. Limited configuration control means that only those elements of fully controlled areas passing through the limited area are controlled. The licensee plans to bring the entire plant under configuration control in the next year.

License Section 6.2.l(a) states, in part, that "All equipment will be examined in the 'as-built' condition to validate the design and to verify the quality of the installation."

Normal industry practice is to have the criticality safety staff review the final installation when a configuration change involves criticality safety. The licensee criticality safety  ;

engineers rely on operations and engineering staff for field verification of designs and verification that criticality safety controls are adequately implemented. Neither the criticality safety engineers preparing a CSE or the criticality safety engineer performing the independent review function for Regulatory Affairs is required to field verify that the as built conditions conform with the conditions assumed in the CSE and that the installed criticality safety controls meet the intentions of the criticality safety engineer. This weakness contributed to the root causes of violations cited in Insp ction Report 70-1151/97-205. The licensee agreed that requirements need to be established for safety 5

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staff to review safety significant changes after final installation as part of closing out a change. Improvements to the configuration control program will be tracked as IFI 70-1151/98-203-02.

The inspectors also noted that controls on in-process changes are limited. Once a change has been approved there are no controls or threshold requiring the project engineer to seek additional review or approval of modifications. The licensee stated that recent corrective actions and training of engineers, had strengthened requirements in this area and that further changes to the program were not required. Licensee staffinvolved with implementing changes in the plant appeared to be well aware of the requirements. The inspectors did not have safety concerns in this area.

c. Conclusions A weakness was identified in the licensee configuration management program because in-process changes are not controlled and final installation is not reviewed by responsible safety staff. No uncontrolled changes were observed by the inspectors.

3.0 Open items Involving Configuration Management

a. Insnection Scone The inspectors reviewed the status of several open items involving configuration management.

b. Observations and Findmgs Violation (VIO) 70-1151/96-202-01 concerned licensee failure to obtain authorization prior to removing criticality safety controls from UN storage tanks. The violatice resulted when the licensee removed pH monitors from discharges to UN tanks and substituted a sampling process without performing required analysis. Although crit 3cality safety staff had reviewed the change, the analysis was not updated as required by l

procedure prior to making the change. Licensee corrective actions included revising their l configuration management procedure and the form used to control proposed changes to l strengthen criticality safety review. The inspectors reviewed the licensee corrective actions and determined that they had been completed along with other upgrades to configuration management in response to more recent events. The licensee corrective actions to upgrade the configuration management program appear adequate to prevent recurrence of the event. The inspectors determined that this item is closed.

VIO 70-1151/97-205-02 concemed the failure to perform adequate criticality safety evaluations and establish appropriate controls. The licensee has performed a comprehensive, facility-wide field-verification of plant equipment to demonstrate that the 6

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geometry and volumes important to criticality safety matched the assumptions used by the' criticality safety engineers. The results of that effort were reviewed by the inspectors and found to be adequate. The inspectors determined that this item is closed.

The licensee has identified longer-term actions to prevent recurrence of the problems identified in two 1997 incidents. These actions included improved configuration control of criticality safety documentation, continued completion of system integrated safety assessments (ISAs) in accordance with a multi-year schedule through December 2002, and restructuring of the configuration management (CM) system. These long term actions were reviewed and discussed in during inspection 98-202 .

c. Conclusions Licessee corrective actions are adequate to prevent removal of approved criticality safety controls without review and revision of the affected CSA/CSE.

4.0 Criticality Analysis

a. Insnection Scope The inspectors reviewed analyses for the granulator hopper, moisture drop-out tanks, and j solvent extraction system concentrator to determine the adequacy of criticality safety controls and verify that controls specified in the analyses were implemented in the plant.

b. Observations and Findings The inspectors reviewed the granulator hopper CSE in conjunction with the review of corrective actions for issues raised in Inspection Report 97-205. The inspectors determined that the new CSE for the hopper accurately reflected as-built conditions and was based on an accurate model of the hopper and volume reducer. The inspectors transferred an example licensee KENO input file into CSAS format and performed a confirmatory calculation which produced a k,y = 0.96 which was the same as the licensee result. The calculational result greater than 0.95 appears to conflict with License Section 6.4.2(a) which requires that computed ke y for normal operating conditions and expected process upsets be less than or equal to 0.95. The licensee stated that unexpected accident conditions are required to be less than 1.00. License Section 6.4.2(a) also requires, in part, that "The sensitivity of key parameters with respect to the effect on k,ywill be evaluated for each system such that adequate system controls are defined for the analyzed system." The inspectors determined that although the license requirement for determining k,y is unclear, the requirement to establish and document the safety margin is clear. The licensee has submitted a license amendment to clarify the requirement. The adequacy of 7

the safety margin when the calculated multiplication factor is greater than 0.95 is Unresolved Item (URI) 70-1151/98-203-03. The inspectors determined that the margin of safety for the granulator hopper was adequate.

The inspectors reviewed the moisture drop-out tank CSE and determined that the CSE accurately reflected as-built conditions and was based on an accurate model of the tank.

The inspectors performed confirmatory calculations using SCALE KENO and verified the licensee results. The inspectors noted that controls were not easily identified from licensee CSEs or CSAs. The licensee showed how controls are listed in one section of the ISA which inspectors noted was an improvement over current documentation.

The inspectors reviewed the solvent extraction concentrator CSE which was a portion of the interaction analysis for the solvent extraction system. The concentrator was conservatively modeled as an infinite cylinder along with other components of the solvent extraction system. The inspectors noted that the concentrator calculations (a CALCNOTE) had not been independently verified. License Section 6.4.2.c.1 states, in part, that " Independent technical reviews of criticality safety assessments, criticality safety evaluations, or calculations in support oflimits specified in CSA's or CSE's will be performed." The licensee recognizes that this is a compliance problem and stated that all interaction analyses are planned to be upgraded from the solid angle method to keno within six months. The inspectors noted that the k,y results determined by the unverified calculation were within the expected range for the geometry and material involved by comparison with accepted data in TID-7016 so that this issue has minor safety significance.

The inspectors asked how many CALCNOTEs were not verified and were informed by the licensee that 86 out of 205 were not verified. Of the unverified CALCNOTEs,13 are q referenced in CSEs or CSAs. Of the 13 referenced and unverified CALCNOTEs,10 j were done to confirm previous analyses, two were done to analyze sensitivity, and one {

was done to validate handbook data. The licensee acknowledged that sensitivity studies and confirmatory type calculations of handbook values often did not get independent review, even when documented in CALCNOTEs and referenced in CSEs and CSAs. The failure to perform an independent review of criticality safety calculations that support the solvent extraction CSE is Violation (VIO) 70-1151/98-203-04.

While reviewing the unverified CALCNOTE packages, the inspectors noted that CALCNOTE CRI-95-001-0 used XSDRN, a one-dimensional deterministic code, to calculate k,g. When the inspectors requested the validation report, the licensee provided CALCNOTE CRI-94-038-0, another unverified CALCNOTE package, which compared XSDRN bias to KENO bias. The licensee stated that one-dimensional benchmarks were not available for validation and the comparison to KENO met the license requirements.

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The inspectors requested additional information regarding the KENO validation report.

The adequacy of the KENO and XSDRN validation is URI 70-1151/98-203-05.

c. Conclusions Licensee criticality safety analysis is generally thorough. Weaknesses were noted in the licensee identiGeation of required controls in the CSE and a past practice of not consistently demanding that criticality safety calculation documented in CALCNOTEs be independently verined 5.0 Reliability of Controls

a. Insnection Scone The inspectors reviewed controls described in selected CSEs against their associated plant operation or equipment to insure that the controls were reliable, available, and would function as required or assumed in the analysis.

b. Observations and Findings Corrective actions for open items and recent events at the licensee facility include efforts ;

to verify the adequacy, availability and reliability of criticality safety controls. The l inspectors performed a walkdown of the solvent extraction concentrator to determine the l reliability and availability ofinstruments IR-1084 and RI-1087 which are listed as primary criticality controls in the interaction analysis CSE for the solvent extraction system.

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U-235 concentration at the discharge of the concentrator is required to be less than 5 gms U-235/Itr or 140 gms U/ltr to prevent criticality in large tanks downstream. IR-1084 is an

! in-line opacity monitor which alarms if concentration exceeds 140 gms U/ltr and RI-1087 is an in-line gamma monitor that will stop flow if concentration exceed 5 gms U-235/ltr.

The inspectors determined that these instrunwnts are suitable to provide the double contingency protection noted in the system analysis. The instruments are included in the licensee automated system that tracks maintenance and calibration. This system appears adequate to assure the availability and reliability of these controls.

c. Conclusions Generally, required maintenance, calibration, and surveillance requirements insure the reliability and availability of engineered safety features in the licensee facility. The inspectors did not identify any instances ofinadequate or unavailable controls.

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6.0 InternalInspections and Audits

a. Insnection Scope The inspectors reviewed corrective actions for an IFI and three violations identified in Inspection Report 96-204 involving the licensee internal audit program.

b. Observations and Findings Inspector examined licensee corrective actions for open items from Inspection Report 96-204, specifically VIO 70-1151/96-204-02, VIO 70-1151/96-204-03, and VIO 70-1151/96-204-05 which concerned the failure to implement license required internal inspection and audit activities. The inspectors determined that the licensee had denied the viol;ttions in the report. In response to the denial, VIO 70-1151/96-204-04 was rescinded and the remaining three violations were aflirmed. Neither the cover letter to the NRC denial response or the amended Inspection Report required a licensee response and the licensee had not provided additional response or developed appropriate corrective actions.

The licensee was given 30 days to respond to amended Inspection Report 70-1151/96-204,

c. Conclusions The licensee was given 30 days from June 24,1998, to provide an adequate response to amended Inspection Report 96-204.

7.0 Open item Review

a. Inspection Scors 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 configuration management, criticality safety analysis, internal inspections and audits, and reliability of controls.

b. Observations and Findings.

IFI 70-1151/96-204-01 The inspectors reviewed licensee actions to establish independent analysis of dual samples in the licensee analytical laboratory. The licensee has established two separate rooms for the processing of samples. Samples are processed by separate technicians and posted to separate computer systems. The inspectors determined that current procedures were adequate and the item is closed.

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URI 70-1151/96-204-06 The inspectors reviewed licensee documentation of the 1996 program review of criticality safety. The inspectors determined that the program review had been completed after the L inspection and included all aspects of the criticality safety program. This item was

! closed.

l VIO 70-1151/97-202-01 1

The inspectors reviewed licensee corrective actions to change the emergency procedures approval process. The inspectors reviewed all emergency procedures issued since February 27,1997 and confirmed that all emergency procedures were reviewed and approved by the cognizant Regulatory Component Manager. This item was closed.

I IFI'70-1151/97-202-01 L The inspectors determined that the licensee has modified two of the five vaporization lines to comply with OSHA /NEC regulations requiring 42 inches of space in front of the electrical panels. The licensee is scheduled to modify the remaining three lines at a rate of one line per year. This item was closed.

IFI 70-1151/97-202-02 The inspectors determined that the licensee has revised the9 Site Emergency Plan (SEP) approval process. The inspectors determined that the SEP now requires the Regulatory :

Component Manager's approval prior to issuance. This item was closed.

IFI 70-1151/97-202-03 The inspectors determined that the licensee has revised procedures to include the 10 CFR 20.2202 (b) 24-hour reporting requirement. The inspectors reviewed the procedures and confirmed that the 24-hour reporting criteria was included. This item was closed. j l

VIO 70-1151/97-205-01 l

l The inspectors reviewed the status and adequacy of corrective actions identified by the 1 licensee in the February 5,1998, response to VIO 97-205-01. The inspectors determined that the licensee had revised procedure RA-111 and trained ~ staff on those revisions. The L revised procedures were expected to provide a proceduralized structure that would improve incident investigations. The licensee also committed to develop a structured post-incident recovery process that would be used after an incident to restore or confirm

'the design safety basis and verify closure. These actions may be expected to significantly improve future incident investigations. This item was closed.

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l VIO 70-1151/97-205-02 Inspectors reviewed the status and adequacy of the actions identified by the licensee in the Feb. 5,1998, response to VIO 97-205-02. The inspectors determined that corrective actions had been completed in response to the concern that the licensee had failed to conduct an adequate criticality safety evaluation and technical review for each significant portion of a process to identify the specific controls necessary to assure safe operation, and to incorporate those controls into process design criteria. The Licensee updated the Pellet Line Granulator llopper CSE and Pellet Ventilation System Moisture Drop-Out Tank CSE to meet license commitments. The inspectors determined that the updated CSEs were adequate. This item was closed.

VIO 70-1151/97-205-03 Insp'ectors reviewed the status and adequacy of the actions identified by the licensee in the February 5,1998, response to VIO 97-205-03. The licensee was found to have completed several actions in response to the failure to functionally verify that the controls necessary to assure safe operation of a process were installed to match the requirements identified in the design criteria. The licensee identified near and long-term actions for this violation that were essentially the same as for VIO 70-1151/97-205-02. This included field verification of the volumes for the Pellet Line Granulator Hopper and Pellet Ventilation System Moisture Drop-Out Tank, revision of procedure RA-104, additional training of the CS engineers, and a facility-wide field verification of plant equipment to demonstrate that the geometry and volumes important to criticality safety matched the j assumptions used by the criticality safety engineers. With the exception of the concerns 1 identified with VIO 70-1151/97-205-02, the results of the near-term actions and plans for longer-term actions were found to be adequate. This item was closed.

VIO 70-1151/97-205-04 Inspectors reviewed the status and adequacy of the actions identified by the licensee in the February 5,1998, response to violation 97-205-04. The licensee was found to have completed several actions in response to the concern that the licensee had failed to assure that all assumptions relating to process / equipment / material theory, function, and operation, including credible upset conditions, are justified, documented, and i independently reviewed. The licensee identified near and long-term actions for this  !

violation that were essentially the same as for VIO 70-1151/97-205-02. This included revision of procedure RA-104, additional training of the CS engineers, and a facility-wide field verification of plant equipment to demonstrate that the geometry and volumes important to criticality safety matched the assumptions used by the criticality safety engineers. With the exception of the concerns identified with VIO 70-1151/97-205-02, the results of the near-term actions and plans for longer-term actions were found to be adequate. This item was closed.

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VIO 70-1151/97-205-05 c

Inspectors reviewed the status and adequacy of the actions identified by the licensee in the Feb. 5,1998 response to violation 97-205-05. The licensee was found to have modified procedure CA-004, " Columbia Plant Records Quality Management Policy" to address the concerns raised in the violation. The procedure was revised to enhance guidance and requirements for the maintenance, control, and storage of criticality safety documents. The revised procedure was approved, implemented, and appropriate personnel trained. The inspectors reviewed efforts to implement these new controls for

- criticality safety records and determined that the efforts were adequate. This item was closed.

VIO 70-1151/97-205-06

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Inspectors reviewed the status and adequacy of the actions identified by the licensee in l the February 5,1998, response to violation 97-205-06. The short-term actions by the licensee to ensure that criticality safety procedures and policies identify the requirements for implementation of the license requirements were reviewed during NRC Inspection 98-202. Substantial progress was noted in implementation oflicense chapter 6 requirements in administrative procedures. During this inspection, progress was noted in the development of the criticality safety manual. This item remains open.

c. Conclusions The licensee has made substantial progress in improving the criticality safety program and has developed a " Safety Margin Improvement Program" that, over the long term, will significantly improve the program.

ITEMS OPENED. CLOSED. AND DISCUSSED Opened IFI-70-1151/98-203-01 Concerns implementation of the HF safety procedure specify the level of PPE needed for the type of work to be performed in or near the HF area.

IF1-70-1151/98-203-02 Concerns improvements to the configuration control program to require safety staff to review safety significant changes after final installation as part of closing out a change.

URI-70-1151/98-203-03 Concerns the failure to adequately demonstrate the safety margin for the granulator hopper.

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VIO-70-1151/98-203-04 Concerns the failure to perform an independent review of criticality safety calculations that support the solvent extraction CSE.

URI-70-1151/98-203-05 Concerns the adequacy of the KENO and XSDRN validation.

Closed VIO 70-1151/96-202-01 Concerns the failure to obtain prior review and approval before altering criticality safety controls on pH monitoring of favorable geometry UNH tanks. The licensee has completed corrective actions in response to this and more recent events as noted in the report. This Item is considered closed.

IFI 70-1151/96-204-01 Concerned evaluating laboratory practices to ensure compliance with the intent of the independent measurement criteria. The licensee has constructed separate rooms for processing samples and samples are processed by separate technicians. This item is considered closed.

VIO 70-1151/96-204-04 Concerned the failure of the Regulatory Component to adequately summarize and trend items documented in the performance based reporting process and adequately review the summaries and trends. 1 This violation was rescinded by the NRC by letter dated June 9, i 1997, and is considered closed. I URI 70-1151/96-204-06 Concerned a planned review of the NCS program for 1996 to verify that it included the administrative NCS program aspects.

The licensee review has been completed and includes all aspects of the criticality safety program. This item is considered closed.

VIO 70-1151/97-202-01 Concerned the failure of the Regulatory Component Manager to approve emergency procedures until after the procedures had been issued and implemented. The inspectors determined that licensee program changes will prevent recurrence of the violation. This item is considered closed.

IFI 70-1151/97-202-01 Concerned the licensee commitment to maintain the required 42 inch clearance in front of electrical panels in the vaporization bay area. The inspectors determined that completed and scheduled modifications will assure compliance with requirements. This item is considered closed.

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IFI 70-1151/97-202-02 Concerned the licensee commitment to raise the approval authority for the Site Emergency Plan (SEP). The inspectors determined that the licensee revision of their SEP approval process has placed the approval authority at the required level. This item is considered closed.

IFl 70-1151/97-202-03 Concerned the licensee commitment to include the 10 CFR 20.2202 (b) 24-hour reporting requirement in the licensee procedure NRC notiGcation procedure. The inspectors determined that the licensee has revised procedures to include the reporting requirement. This item may be closed.

VIO 70-1151/97-205-01 Concerned the failure to implement corrective measures to prevent reoccurrence of a criticality incident prior to restart of the affected operation. The licensee was found to have made substantial progress in improving the weaknesses in the safety systems that led to Violation 97-205-01. Near-term actions were considered adequate. This item is considered closed.

VIO 70-1151/97-205-02 Concerned the failure to perform an adequate evaluation of the granulator hopper and establish appropriate controls. The licensee was found to have made substantial progress in improving the weaknesses in the safety systems that led to Violation 97-205-02.

Near-term actions are considered adequate, although certain aspects of the safety system, including independent veriGcation by the criticality safety function, should be improved (IFI 98-202-01).

Longer-term actio:ts will continue to be tracked under IFI 98-202-02 and IFI 98-202-03. This item is considered closed.

VIO 70-1151/97-205-03 Concerned the failure to assure that the hopper volume control identiGed in the CSE matched the as-built configuration. The licensee actions to correct this concern were found to be the same as for VIO 70-1151/97-205-02. These actions were expected to result in substantial progress in improving the weaknesses in the safety systems that led to VIO 70-1151/97-205-03. Near-term actione are considered adequate, although certain aspects of the safety system, including independent veriGcation by the criticality safety function, should be improved (IFl 98-202-01). Longer-term actions will continue to be tracked under IFI 98-202-02 and IFI 98-202-03. This item is considered closed.

VIO 70-1151/97-205-04 Concemed the failure to assure that the assumptions relating to the granulator hopper were justined. documented and reviewed prior 15 i

to restart. The licensee actions to correct this concern were found to be the same as for VIO 70-1151/97-205-02. These actions were expected to result in substantial progress in improving the weaknesses in the safety systems that led to Violation 97-205-04.

Near-term actions are considered adequate, although certain aspects of the safety system, including independent verification by the criticality safety function, should be improved (IFI 98-202-01).

Longer-term actions will continue to be tracked under IFl 98-202-02 and IFI 98-202-03. This item is considered closed.

VIO 70-1151/97-205-05 Concerned the failure to develop an adequate written procedure to specify the management program for CSEs/CSAs and their retention. The licensee actions to correct this concern were found to be adequate. This item is considered closed.

Discussed VIO 70-1151/96-204-02 Concerned the failure of formal audits to look for process upsets and procedural inadequacies beyond simple paper reviews.

VIO 70-1151/96-204-03 Concerned the failure to have a documented policy outlining the purpose and objectives of the facility management self-assessment program.

VIO 70-1151/96-204-05 Concemed the failure to conduct and document process review inspections and audits in accordance with written procedures.

IFI 70-1151/96-204-07 Concerned licensee evaluation and development of guidance for the reporting of criticality safety violations internally. The inspectors reviewed that the licensee has upgraded procedures appropriately so that criticality safety violations will be reported.

VIO 70-1151/97-205-06 Concerned the failure to notify the NRC within four hours of discovering that the moisture drop-out tank was unanalyzed.

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MANAGEMENT MEETINGS I .

The inspector met with licensee management periodically during the inspection. The inspector presented the inspection scope and findings to members of the licensee's staff at the conclusion of the inspection on June 26,1998. A re-exit was held by telephone conference on July 6.1998 to discus findings which were identified afier the June 26 meeting. The licensee acknowledged the findings presented at both meetings.

PARTIAL LIST OF PERSONS CONTACTED Westinghouse Columbia Plant Jack Allen , Manager, Columbia Plant Edward Reitler Regulatory Engineer Sam Mcdonald Technical Services Manager Michael Corum Criticality Safety Engineer Bill Newmyer Criticality Safety Engineer Bob Ervin Chemical Process Engineer Nancy Parr Chemical Process Engineering Manager JeffHooper Regulatory Engineer David Williams Criticality Safety Engineer Tommy Shannon Regulatory Technician Wilbur Goodwin Regulatory Affilirs Manager Nonnan Kent Criticality Safety Engineer Bob Williams Regulatory Engineer Nuclear Regulatory Commission Dennis Morey, Criticality Safety inspector, NRC Headquaners Albert Wong, Chemical Safety Inspector, NRC Headquarters Doug Outlaw, Consultant, SAIC l

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ACRONYSIS USED ADU ammonium di-urinate CM configuration management CSA criticality safety analysis j CSAS SCALE control module CSE criticality safety evaluation IIF hydroflouric acid JFI inspector followup item ISA integrated safety analysis KENO a criticality analysis computer code MSDS material safety data sheet PPE personal protective equipment

) SCALE , computer code package for nuclear calculations UNil uranyi nitrate hexahydrate UN uranyl nitrate URI unresolved item VIO violation

} XSDRN one-dimensional deterministic SCALE module 18 mmmmm