ML20236V589
| ML20236V589 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 07/30/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236V578 | List: |
| References | |
| 70-0036-98-03, 70-36-98-3, NUDOCS 9808040065 | |
| Download: ML20236V589 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION lll I
1 I l Docket No: 070-00036 l l License No: SNM-33 i j
j Report No: 070-00036/98003(DNMS)
Licensee: ABB Combustion Engineering, Inc.
l Facility: ' Hematite Nuclear Fuel Manufacturing Facility I
Location: Hematite, MO 63047 Dates: July 13 - 17,1998 Inspector: Robert G. Krsek, Fuel Cycle Safety inspector Approved by: Patrick L. Hiland, Chief Fuel Cycle Branch l Division of Nuclear Materials Safety i
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9800040065 980730 '
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l EXECUTIVE
SUMMARY
ABB Combustion Engineering, m.
Nuclear Fuel Manufacturing Facility NRC Inspection Report 070-00036/98003(DNMS)
This routine unannounced inspection included aspects of licensee operation, radiation protection, emergency preparedness, radioactive waste management, and management organization and control.
Operations e The inspector concluded that operations observed and reviewed were conducted safely and in accordance with the applicable procedures and nuclear criticality safety requirements. Significant improvements were noted in the housekeeping of the maintenance shop; however, housekeeping on the mezzanine of the item Plant remained poor. (Section 01.1) e Alarm calibrations and testing of equipment relied upon for the safe operation of the Oxide Building and vaporizers were performed at the required frequencies in accordance with the applicable procedure. However, the inspector identified that since February 1998 several routine weekly and monthly surveillance relied upon for safety and operability of the Oxide Building and required by operating procedures, were not performed. One example of a procedural violation was identified. (Section 01.2)
Radiation Protection e The licensee continued to effectively implement the radiation protection program in accordance with the license and facility procedures. The inspector randomly observed i
and reviewed selected aspects of the licensee's radiation protection program in the areas of contamination surveys, respiratory protection requirement postings, and periodic surveillance of fume hoods and noted no concems. (Section R1.1)
Emeroency Preparedness e The inspector observed the licensee's onsite emergency response team respond to an !
unusual event which occurred at the hydrofluoric acid absorber system. The inspector {
concluded that communications during the event were excellent and that the overall i response was effective. As a result of the incident, several corrective actions were ;
proposed to prevent recurrence of a similar incident in the future. (Section P1.1) i e The inspector concluded that the licensee's emergency equipment and supplies were maintained in an excellent state of operational readiness. The inspector noted that the Emergency Plan, Part ll of the License Conditions, and Emergency Plan implementing )
Procedures were either undergoing or scheduled to undergo enhancements and revisions j to better assist key licensee staff durir.g emergencies. (Section P2.1) ,
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Radioactive Waste Manaaement i
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l e The inspector determined that licensee staff continued to address an increase of onsite l radioactive waste. Increased inventories of radioactive waste onsite had occurred mainly due to upgrades of the onsite incineration system, recycle and recovery process changes, and initiation of the South Yard pond decommissioning project. (Section W1.1)
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Self-Assessment Activities
- The inspector identified that a significant Nuclear Regulatory Affairs fourth quarter 1997 safety inspection finding had not been corrected. Although the risk of actual fire for this situation was low due to the minimal amount of oil and combustible materialin the immediate area, the nitric acid was not stored in accordance with the hazardous materials procedure, and licensee staff had not initiated the correction of this significant safety inspection finding in a timely manner. One example of a procedural violation was identified. (Section C1.1) e The inspector concluded an annual plant stand down, initiated by Uranium Operations management, to review and enhance current safety and operations in the plant was successful. The inspector also identified a violation of minor significance, in that, health physics and nuclear industrial safety procedures were not appropriately updated and reviews were not adequately documented in accordance with plant policies and license conditions. (Section C1.2)
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! Report Details
- 1. Operations 01 Conduct of Operations
! 01.1 Facility Tours and General Operations
- a. Inspection Scom (88020's The inspector toured the plant areas with cognizant licensee personnel and observed the general status of facility operations, implementation of nuclear criticality safety requirements, and site housekeeping.
- b. Observation and Findinas The inspector toured and reviewed the operations of the vaporizer room, Oxide Building, l and new hydrofluoric acid (HF) absorber system. The inspector noted that housekeeping l in these areas was good and that day-to-day operations observed were conducted in accordance with approved procedures. One operational safety issue was noted in the Oxide Building and is discussed in Section 01.2 of this report. The inspector also l observed operations and reviewed procedures for the new HF absorber system. The
' inspector noted that the procedures thoroughly addressed the operations and chemical hazards associated with the HF absorber system. In addition, oxide operations staff were i
knowledgeable of the hazards and new safety systems associated with the HF absorber.
The Erbia, Item, Rod-Loading and Pelletizing Plants, recycle-recovery and incineration areas, and maintenance shop were also toured and reviewed. No concems were identified with day-to-day operations in these areas, and the inspector noted a significant improvement in the housekeeping of the maintenance shop. However, the inspector noted that housekeeping on the mezzanine of the item Plant had declined and was generally poor. The mezzanine contained previously used plant equipment which was stored until reuse. Similar observations were also made by the Health Physics organization during the June audit of the item Plant. Plant management acknowledged that housekeeping in this area needed to be addressed. During facility inspections and tours of the Hematite facility, the inspector noted no contems with the implementation of nuclear criticality safety requirements.
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- c. Conclusions Excepi as notei in Section 01.2, the inspector concluded that operations observed and l reviewed were Londucted safely and in accordance with the applicable procedures and i
nuclear criticality safety requirements. Significant improvements were noted in the
! housekeeping of the maintenance shop; however, housekeeping on the mezzanine of the item Plant remained poor.
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j 01.2 Oxide Buildina Routine Surveillance and Semiannual Alarm Testina and Calibrati.gn
- a. InspecQon Scope (88020) i J
! The inspector reviewed the routine surveillance performed by operations sisff in the Oxide Building. In addition, the alarm testing and calibration of equipment relied upon for I the safe operation of the Oxide Building and vaporizers was also reviewed. The j inspection consisted of interviews with various operations and engineering staff, a review l of the applicable approved procedures, and reviews of appropriate documentation.
l l b. Observation and Findinas L
The calibration and testing of equipment was addressed in Procedure O.SA101.00,
- " Oxide inspection and Alarm Calibration / Testing." The annual and semiannual calibrations and tests were performed by the oxide manufacturing engineer, with assistance from various plant staff. The equipment tested and calibrated included the l~
following: pressure and temperature alarms for the Oxide Building reactors; vaporizer temperature alarms; vaporizer uranium hexafluoride (UF.) and conductivity detectors; j oxide cooler moisture monitors; UF, emergency shutoff and carbon dioxide emergency i l cooling buttons; and, UF. and steam interlock verifications. Although no activities regarding the calibration and testing were conducted during the inspection, the inspector reviewed the procedure with the oxide manufacturing engineer. The inspector noted no concems with the procedure and subsequently reviewed the calibration and testing sheets for the past two annual and semiannual alarm calibrations and tests. No concems in the review of calibration and testing data were identified, and test values were within '
the tolerance ranges of Procedure O.SA101.00.
l The inspector also interviewed operators on shift at the Oxide Building and reviewed
! periodic survei; lances required to be performed by operations staff in the Oxide Building.
Procedure O.S.604.12, " Operational Inspection and Checklists," listed equipment which was required to be checked periodically to maintain safety and/or operability of the Oxide
! Building. The surveillance were divided into three frequencies, which included shiftly checks, weekly checks, and monthly checks. A review of the shiftly checks revealed that these surveillance were performed over the past two months, as required, once per shift. However, in a review of the weekly and monthly checks, the inspector identified that several weekly checks were not completed since February 1998, and at least two monthly checks since February 1998 were not performed. The weekly and monthly surveillance included checks on the following items: reactor bicwback valve operation; emergency carbon dioxide cylinder pressure checks; visual inspections of air filter banks; j sampling of the UF, scrubber; cleaning strainers for the UF, scrubber and cooling water; I
cleaning cooler vent piping; and, inspection of oxide and micronizer transfer hoses. The j inspector interviewed the manufacturing engineer and operators on two shifts, and confirmed that the items on the weekly and monthly surveillance were not performed as a part of other routine surveillance or operational duties, in addition, the inspector noted that operations staff and management were not aware that the weekly and monthly surveillance had not been performed. Overall, since February 1998,12 out of 23 required weekly surveillance and two of the five monthly surveillance were not i performed. At the end of the inspection, operaticas management had discussed several l proposed recommendations to prevent the recurrence of this issue. 4 i
Safety Condition S-1, of Special Nuclear Materials License SNM-33 authorizes the use of licensed materials in accordance with the statements, representations, and conditions in Chapters 1 through 8 of the application dated October 29,1993, and supplements and 5
4 revisions thereto. Chapter 2 Section 2.6, " Operating Procedures," of the supplement dated August 8,1997, requires, in part, that all operations which affect licensed material l shall be conducted in accordance with approved procedures. From February 1998 to July 17, plant staff failed to check certain equipment at weekly and monthly frequencies, as required by Procedure O.S.604.12, to maintain safety and/or operability of the Oxide l Building. Specifically,12 weekly and two monthly checks were not performed from l February 1998 to July 17. The failure to perform the weekly and monthly checks is an example of a Violation of Safety Condition S-1 of the License Conditions. (VIO 070-00036/98003-01a)
- c. Conclusions The inspector concluded that alarm calibrations and testing of equipment relied upon for the safe operation of the Oxide Building and vaporizers was performed at the required frequencies in accordance with the applicable procedure. However, the inspector identified that since February 1998 several routine weekly and monthly surveillance relied upon for safety and operability of Oxide Building equipment and required by operating procedures, were not performed. One example of a procedural violation was identified.
Ill. Plant Support R1 Conduct of Radiation Protection Activities R1.1 Observation of Routine Radiation Protection Activities
- a. Inspection Scope (83822)
The inspector reviewed random records and ir some cases observed Health Physics Technicians (HPT) routine activities related to contamination surveys, posting of airbome radioactivity areas, and weekly hood face velocity checks.
- b. Observations and Findinas The inspector observed various routine contamination smear surveys in the plant during the course of the inspection and noted the surveys were conducted in accordance with the Health Physics Implementing Procedures (HPIP). Shift tumovers among the HPTs were noted to adequately communicate any outstanding issues which could have affected the oncoming HPT shift. During facility tours and accompaniments with HPTs during the inspection, the inspector noted that areas requiring postings for airbome radioactivity were property posted prior to the start of work which required the use of respiratory protection. The inspector also reviewed HPIP 336, " Weekly Hood Face Velocity Checks,"
which required the weekly performance of face velocity checks for fume hoods. A random review of records and walkdowns of fume hoods revealed that fume hoods which failed the weekly check were appropriately posted with quarantine tags, and properly tracked in a health physics log book. The inspector also noted that radiation protection equipment used throughout the site was operable and within the required calibration period. The inspector noted no concems with the conduct of radiation protection activities observed.
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- c. Conclusions I
The licensee continued to effectively implement the radiation protection program in l accordance with the license and facility procedures. The inspector randomly observed )
and reviewed selected aspects of the licensee's radiation protection program in the areas of contamination surveys, respiratory protection requirement postings, and periodic surveillance of fume hoods.
P1 Conduct of Emergency Preparedness Activities P1.1 Unusual Event at the Hydrofluoric Acid Absorber System on July 13
- a. Inspection Scope (88050)
On July 13 an operator activated a site emergency alarm when a minimal quantity of HF was spilled during the transfer of HF from an onsite storage tank to a vendor's HF trailer.
The inspector observed the onsite emergency responders and emergency director address the incident, remediate the situation, clean-up the affected outside area, and critique the incident which addressed corrective actions to prevent recurrence.
- b. Observations and Findinas l
Hydrofluoric acid onsite was recovered from various Oxide Building processes, processed through a wet-scrubber system to remove any residual uranium contamination, sampled to ensure uranium contamination was below license-required limits, and then transferred from a 8,500-gallon onsite storage tank to a vendor owned and operated HF trailer for offsite shipment. This new process for handling onsite HF began operation in March 1998, and the maximum concentration of HF in the process was approximately 35 porcent HF by weight.
On July 13, at approximately 3:40 p.m., an operator activated the Oxide Building site emergency alarm for a spill of HF which had occurred while attempting to uncouple the transfer line from the onsite HF storage tank to the vendor's HF trailer At the time of the alarm, the inspector was on a facility tour with an onsite emergency response team (ERT) member, and upon notification that the emergency did not involve a facility evacuation, both the inspector and onsite ERT member reported to the Building 253 alarm panel area.
The Building 253 alarm panel area was the designated assembly point for ERT members, when an emergency does not involve a facility evacuation. Upon arrival, the inspector observed the onsite ERT member's activities throughout the entire event. The inspector noted that all the required personnel had reported to the assembly point, and that the Emergency Director had classified this response as an unusual event, due to a spill of HF in an outside area, as required by Emergency Plan Implementing Procedure (EPIP) l No. 2.00, Attachment A. (No notification to the NRC Operations Center was required for this event, as fuel cycle licensees were only required to report emergencies classified as an Alert or Site Area Emergency to the NRC.)
At the time of the incident the following facts were conveyed to the Emergency Director:
I while attempting to disconnect the transfer line from the onsite HF storage tank to the vendor trailer, approximately 2 quarts of HF spilled to the ground; none of the licensee's HF absorber safety systems actuated and HF absorber system pressures were noted to be normal (no pressure relief systems for the licensee's process had actuated); and, the tanker was noted to be at a pressure which was higher than normal. The Emergency Director directed the onsite emergency responders and vendor truck d6ver, who were in 7
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The inspector noted excellent communications among ERT members and staff during the response, in addition, the Emergency Director remained focused on employee safety, objectively assessed the information provided to him throughout the event, and kept the number of emergency responders near the incident at a minimum. Upon review of the applicable EPIP procedures, the inspector noted no concems and & termined the emergency response to this incident was effective.
Two days after the event, an Accident Investigation Board was held, as was required by Nuclear Industrial Safety (NIS) Procedure 212.00. The inspector attended this meeting and noted that cognizant licensee staff were present. An open discussion and critique of the response and event was conducted, and staff members discussed root causes and proposed several recommendations to prevent recurrence. As was noted previously, the vendor HF trailer driver was not aware that the HF trailer had a second safety vent valve which was required to be opened during filling operations. Licensee staff had contacted the vendor following the incident, and noted that the driver had not received specialized training, as was agreed upon by the vendor and licensee staff. One of the root causes of the incident was accurately noted to be that the vendor representative was not knowledgeable of the proper operation of the vendor's equipment, and that the vendor representative had not received vendor training for this evolution. Some potential corrective actions proposed by licensee staff were the following: require licensee staff to walkdown all the valves on the HF trailer with the vendor representatives to ensure the proper safety vent valves were fully opened prior to transferring operations; and, develop a list of vendor representatives who were properly trained and verify the representatives' training prior to being allovfed onsite.
- c. Conclusions The inspector observed the licensee's onsite emergency response team respond to an unusual event which occurred at the HF absorber system. The inspector concluded that communications during the event were excellent and that the overall response was good.
As a result of the incident, several corrective actions were proposed to prevent recurrence of a similar incident in the future.
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P2 Status of Emergency Preparedness Facilities and Equipment P2.1 Status of Emeroency Preparedness Facilities and Eauipment
- a. Inspection Scope (88050) )
The inspector toured areas of the plant with the Emergency Director and evaluated the status and material condition of emergency preparedness facilities and equipment, j Licenroe staff explained the purpose of various pieces of equipment and demonstrated ,
the operability of certain emergency equipment.
- b. Observations and Findinas j The inspector determined that emergency equipment maintained in the tile bam !
(Emergency Operations Center), the Building 253 pump room, and various locations l throughout the plant was consistent with the Emergency Plan. The emergency i equipment and supplies stored in the various plant areas onsite were consistent with the minimum equipment lists of Tables 5.03-1 through 5.03-3, as required by Section 3.7 of EPIP No. 5.03, " Emergency Equipment." The contents and operability of randomly !
selected equipment were determined to be in an excellent state of readiness. The i inspec or also noted that additions were made to the emergency equipment onsite to accommodate the new HF absorber system, and the associated chemical hazards of i handling liquid HF onsite. On various tours throughout the course of the inspection, fire extinguishers were noted to be periodically checked and serviced, as required.
Inoperable fire extinguishers were properly taken out of service and caution tagged. j The Emergency Director highlighted several enhancements which were made to the Emergency Operations Center, and the inspector acknowledged these enhancements l would assist key emergency responders and licensee staff during an emergency. The i inspector also noted that revisions to the Emergency Plan and Part 11 of the License ,
Conditions were being made to reflect the addition of the HF absorber system to the .
plant. In addition, future enhancements and revisions to the EPIPs were planned for the I near future, to enable the procedures to better assist key licensee staff during an emergency.
- c. Conclusions !
The inspector concluded that the licensee's emergency equipment and supplies were maintained in an excellent state of operational readiness. The inspector noted that the Emergency Plan, Pari ll of the License Conditions, and the EPlPs were either undergoing l or scheduled to undergo enhancements and revisions to better assist key licensee staff during emergencies.
W1 Conduct of Radioactive Waste Management Activities W1.1 Onsite Storace of Radioactive Waste
- a. Inspection Scope (88035)
The inspector reviewed the current storage of radioactive waste onsite with cognizant licensee staff, and discussed the licensee's current actions and future plans for addressing radioactive waste stored onsite.
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- b. Observation and Findinas The inspector toured the plant with cognizant operations, health physics and regulatory affairs staff to assess the licensee's radioactive waste management activities. The inspector noted that the licensee continued to focus on the storage of contaminated metal with removable contamination, and the inspector noted that contaminated metal with removable contamination was not stored outside in the South Yard.
Decommissioning of the ponds in the South Yard continued to be actively addressed by licensee management, and significant progress was noted. In addition, issues associated with the inoperability of the onsite incinerator continued to be actively addressed, with the addition of a new blower system and programmable logic controller to the incinerator. At the end of the inspection, the manufacturing engineer had started initial functional tests of the upgraded incinerator. Enhancements were also made to the recycle and recoury process, with the previous filtrate evaporation equipment no longer used, and a solidification process put in place for filtrate sludges. The solidified filtrate sludges were then scheduled for offsite shipment to a commercial disposal facility.
During tours and interviews with plant staff, the inspector made several observations regarding the current onsite storage of radioactive waste. A notable increase in the onsite storage of incinerable wastes was observed due to operational problems associated with the onsite incinerator. A backlog of incinerable wastes stored in several sea land containers and trailers onsite was noted in addition to a backlog of incinerable filtered oil. As was noted previously, however, licensee staff were addressing the issues associated with the onsite incinerator, to reduce the incinerable waste backlog. An increase of onsite waste from the decommissioning of the ponds was noted concurrent with the progression of clean-up activities associated with the pond decommissioning.
However, the inspector observed that there had been minimal shipments of wastes generated, since the start of the project, to an offsite commercial disposal facility.
Concurrent with the operational changes described previously for the recycle and recovery process, there had been an increase of solidified contaminated filtrate waste onsite. The backlog of solidified contaminated filtrates onsite continued to increase, with minimal shipments of material to an offsite commercial disposal facility since the recycle and recovery process change occurred. Finally, the inspector observed that the backlog of contaminated silica based filters (utilized in the plant's ventilation system) continued to increase, with no formal plan in place to address either onsite processing and decontamination or offsite disposal of the contaminated silica based filters. The inspector j noted that regulatory affairs staff were addressing remediation of the contaminated silica filter issue. The inspector noted an overall increase in the storage of radioactive waste I onsite, and that licensee staff were addressing the increased inventories. No regulatory concems were identified.
- c. Conclusions The inspector determined that licensee staff continued to address an increase of onsite radioactive waste. Increased inventories of radioactive waste onsite had occurred mainly .
due to upgrades of the onsite incineration system, recycle and recovery process changes, !
and initiation of the South Yard pond decommissioning project.
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C1 Conduct of Self-Assessment Activities C1.1 Nuclear Reaulatory Affairs Quarterly inspections
- a. Inspection Scope (88005)
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i The inspector reviewed selected Nuclear Regulatory Affairs (NRA) quarterly safety inspections and interviewed various plant staff regarding the inspections. The inspector focused on NRA inspection findings related to outside waste and storage areas.
- b. Observations and Findinas The NRA quarteriy safety inspections were required by Chapter 2.8 of Part I of the License Application. The inspector reviewed safety significant inspection findings related i to the outside waste and storage areas, and while on tours and walkdowns of outside {
storage areas (See Section W1.1) verified that safety significant NRA inspection findings I were addressed and corrected. A fourth quarter 1997 NRA safety inspection finding, Section 15.7, dated February 10,1998, stated the following: " Filters on pallets in the South Vault were stored in the west aisle, touching a nitric acid container in the northwest comer. This is a fire hazard from incompatible items. Also, due to the quantity of filters and lack of spacing, it is difficult to audit the pallet inventory totals for compliance with the criticality limits."
While inspecting the South Yard and South Vault, the inspector noted that in the nodhwest comer of the South Vault, a damaged metal carboy (approximately 30-gallon metal container) with no clear labeling was stored in the west aisle next to uranium contaminated filters on metal pallets. The inspector also noted a sign above the carboy which stated " nitric acid," with an arrow pointing down to the container. In addition, the inspector observed that the South Vault west aisle floor where the carboy was stored had minor oil contamination. (Nitric acid mixed with oil, a combustible organic material, has the potential to cause violent exothermic chemical reactions, fires, or explosions.) The inspector notified the site safety engineer of the apparent container of nitric acid stored in the South Vault.
The site safety engineer immediately reported to the South Vault with an operator, and the carboy was moved out of the South Vault into a proper storage area. The carboy was labeled as nitric acid, and analyses determined that the contents of the carboy was nitric acid. The site safety engineer confirmed that the west aisle floor where the nitric acid was stored had minor oil contamination and that the South Vault was no longer the designated storage area for this material. Nitric acid was currently stored in a designated hazardous materials storage area onsite. The site safety engineer determined and the inspector concurred that risk of fire associated with this paiticular instance was low due to the fact there was minimal oil contamination on the floor, and that combustible materials were not readily available in the area to sustain a fire. (The filters stored nearby were made of metal and fiberglass and were not a combustible material.) Overall, the time to correct this situation took approximately 20 minutes. i Upon further review of the NRA quarterly inspections, the inspector noted that the finding in Section 1.5.7 was documented as an open item in the first quarter 1998 safety .
inspection, dated April 28,1998. In addition., a review of the June monthly audit for the South Vault, conducted by the Health Physics organization, documented that the chemicals in the South Vault were properly labeled and stored. Although subsequent interviews with licensee staff in the South Yard, and Recycle and Recovery Area revealed l l 11 l 1
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that staff were aware that nitric acid was only stored in the Hazardous Materials storage area, the Hazardous Materials Data Table in NIS Procedure 213, " Hazardous Material Management," dated April 4,1996, had not been updated, and listed the waste storage l area for nitric acid as the South Vault (See Section C1.2). l l
l Safety Condition S-1, of Special Nuclear Materials License, SNM-33, authorizes the use of licensed matenals in accordance with the statements, representations, and conditions in Chapters 1 through 8 of the application dated October 29,1993, and supplements and revisions thereto. Chapter 2, Section 2.6, " Operating Procedures," of the supp;.sment, dated August 8,1997, requires, in part, that all operations which affect licensed material l shall be conducted in accordance with approved written procedures. Section 6.6, of l l Nuclear Industrial Safety Procedure 213, " Hazardous Materials Management," required, in part, that chemicals shall be compatible with their containers, lockers, containment, and l the other materials with which they were stored. A guideline was provided in the ;
Hazardous Material Data Table. Prior to July 16,1998, a carboy of nitric acid was i stored on the floor in the South Vault, where the floor was contaminated with oil, an organic combustible chemical incompatible with nitric acid, as defined in the Hazardous l Material Table in NIS Procedure 213. The failure to properly stom hazardous l materials in accordance with written procedures is an example of a Violation of Safety l I
Condition S-1 of the License Conditions. (VIO 070-00036/980G3-01b)
- c. Conclusions The inspector identified that a NRA fourth quarter safety inspection finding had not been corrected. Although the risk of actual fire for this situation was low due to the minimal amount of oil and combustible materialin the immediate area, the nitric acid was not stored in accordance with the hazardous materials procedure, and licensee staff had not initiated the correction of this significant safety inspection finding in a timely manner.
However, once notified by the inspector, the licensee took timely corrective actions.
One example of a procedural violation was identified.
C1.2 Annual Operations and Maintenance Stand-Down and Biennial Procedure Review
- a. Inspection Scope (88005)
The inspector reviewed the results of a new process, initiated by licensee management, to conduct an annual stand down of all manufacturing activities in order to self-assess onsite activities and review existing proceduras. In ac 'ition, the inspector reviewed plant l records conceming procedures which were past the licinse required biannual review frequency.
- b. Observations and Findinas l
This past spring Uranium Operations management initiated a stand down of all plant operations to provide for a review of current operations and maintenance activities including safety related activities. During the stand down each plant area (i.e., pellet operations, oxide operations, etc.) ceased manufacturing and conducted a review of current activities and processes, as well as plant operating procedures. Plant staff, including operations staff, received training on how to conduct the stand down and address any issues or problems identified. Teams were then formed for each area to review the applicable processes and procedures. The teams were empowered to take whatever actions determined necessary to improve safety and operations in an area, including making a process more robust, or simpler and less complex. Finally, 12 L__________________. _ _ _ _
I compliance with applicable procedures was reviewed to determine if current procedures could be followed, and if enhancements or changes were warranted, the procedure was revised. In interviews with plant management and operations staff the inspectof determined that the stand down was successful and corrective actions as a result of the stand down were completed. In addition, the inspector noted that several procedures had undergone revisions as a result of the stand down.
The inspector also reviewed various procedures during the course of the inspection and requested a listing of all procedures which were past the periodic review frequency of two years. The inspector noted that the licensee's process for tracking procedure reviews highlighted to the appropriate manager when a procedure was due for a review approximately 30 days prior to the date. Once a procedure was overdue, a listing of overdue procedures was sent to the cognizant manager every week. The inspector noted that as of July 15, 32 procedures were past the blannual review frequency required by Part I, Section 2.6 of the license application. Of these 32 procedures,20 procedures were overdue for a period of time greater than or equal to three months, and four procedures were overdue for a period of time greater than or equal to six months. In addition, the majority of procedures overdue for review were the responsibility of the Regulatory Affairs organization (Health Physics and NIS procedures).
The inspector interviewed various regulatory affairs staff, including the Director, and supervisor of Health Physics. The Director of Regulatory Affairs and Health Physics Supervisor highlighted that although the administrative issue of updating the overdue list of procedures was not performed, during the annual radiation protection program review, documented in July of 1997, all the procedures used by the Regulatory Affairs organization had been reviewed for accuracy and consistency with day-to-day operations.
The managers also noted however, that procedural enhancements could be made and were planned for completion in the upcoming weeks. During the course of the inspection, !
the inspector reviewed various activities associated with the procedures (See Sections j R1.1 and C1.1) and noted that health physics activities observed were performed in j accordance with approved procedures. (One issue was noted with the Hazardous l Materials Management Procedure as discussed in Section C1.1.) Part I, Chapter 2.6 of the license application, states, in part, that the minimum frequency for review, for the purpose of updating operating procedures affecting Special Nuclear Materials and health physics procedures, shall be every two years. The failure to appropriately update and i
adequately document reviews of Regulatory Affairs procedures every two years, in l ' accordance with plant policies and license conditions is a Violation of Minor !
Significance not subject to formal enforcement action, consistent with Section IV of 1 L the NRC Enforcement Policy (NUREG-1600, Revision 1). (NCV 070-00036/98003-02) j
- c. Conclusions l The inspector concluded an annual plant stand do.m initiated by Uranium Operations management, to review and enhance current safety and operations in the plant was l successful. The inspector also identified a violation of minor significance, in that, regulatory affairs procedures affecting nuclear industrial safety and health physics were I
not appropriately updated and adequately documented in accordance with plant policies and license conditions.
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V. Manaaement Meetinas X1 Exit Meeting Summary .
The inspector met with plant management and other staff throughout the inspection and on July 17,1998, for the exit meeting. The inspector summarized the observations and findings of the inspection. ;
The licensee did not identify any of the information discussed at the meetings as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED License _t l
l M. Eastbum, Nuclear Criticality Specialist i H. Eskndge, Senior Consultant Regulatory Affairs R. Freeman, Nuclear Criticality Specialist K. Funke, Supervisor Health Physics K. Hayes, Safety Engineer J. Long, Oxide Manufacturing Engineer E. Saito, Health Physicist l B. Sharkey, Director of Regulatory Affairs
- P. Weaver, Production Manager INSPECTION PROCEDURES USED
, IP 83822: Radiation Protection IP 88005: Management Organization and Controls IP 88020: Operations Review / Regional Criticality Safety IP 88035:' Radioactive Waste Management IP 88050:' Emergency Preparedness ITEMS OPENED, CLOSED, AND DISCUSSED
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070-00036/g8003-01a,b VIO Two examples of procedural violations related to oxide Building surveillance and hazardous chemical storage Closed 070-00036/38003-02 NCV Minor violation involving failure to appropriately update and l adequately document procedure reviews Discussed None f
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LIST OF ACRONYMS IJSED CFR Code of Federal Regulations DNMS Division of Nuclear Materials Safety EPIP Emergency Plan implementing Procedure ERT Emergency Response Team HF Hydrofluoric Acid HPIP Health Physics implementing Procedure HPT Health Physics Technician Nis Nuclear Industrial Safety NRA Nuclear Regulatory Affairs NRC Nuclear Regulatory Commission OS Operations Sheet PDR Public Document Room UF. uranium hexafluoride VIO Violation l
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