ML20237D798

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Insp Rept 70-1151/98-204 on 980810-13.No Violations Noted. Major Areas Inspected:Plant Operations,Criticality Analysis, Internal Audits & Insps,Recently Issued Procedures & Status of Fourteen Open Items
ML20237D798
Person / Time
Site: Westinghouse
Issue date: 08/21/1998
From: Ting P
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20237D796 List:
References
70-1151-98-204, NUDOCS 9808270235
Download: ML20237D798 (17)


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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

, CRITICALITY SAFETY INSPECTION REPORT Docket No: 70-1151 License No: SNM-1107 Report No: 70-1151/98-204 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Location: BluffRoad Columbia, SC Dates: August 10 - 13,1998 Inspectors: Dennis Morey, Inspector, NRC Headquarters Harry Felsher, License Reviewer, NRC Headquarters Doug Outlaw, Consultant, SAIC Approved by: P. Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS l

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Enclosure I 9808270235 980821

, PDR ADOCK 07001151 l C PM l

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WESTINGIIOUSE ELECTRIC CORPORATION NRC INSPECTION REPORT

, 70-1151/98-204 EXECUTIVE

SUMMARY

k Introduction )

The Nuclear Regulatory Commission (NRC) performed a routine, announced criticality safety inspection at the Westinghouse Columbia Fuel Manufacturing Facility in Columbia, South Carolina, from August 10 - 13,1998. The purpose of the inspection was to close out unresolved items (URIs) from the previous inspection, review the progress of criticality safety program l upgrades and review the recent loss of water level control event. The inspectors reviewed plant operations, criticality analysis, internal audits and inspections, recently issued procedures, and the status of 14 open items.

During this inspection, the inspectors identified three inspector followup items (IFIs) concerning procedural compliance, criticality calculation result limits, and computer code verification.

Results e The inspectors determined that 1icensee investigation and root cause determination for the ;

loss of water level control event was adequate. (Section 1.0). I e The inspectors determined that licensee independent verification of criticality safety analysis (CSAs)/ criticality safety evaluations (CSEs), and associated documents describing criticality calculations (CALCNOTEs), along with scheduled verification i l

act'ivities are adequate to complete the corrective actions by the end of the year.

(Section 2.0). ]

e The inspectors determined that the licensee had provided adequate criticality safety surveillance, support, and response to six recent plant upset conditions. (Section 3.0).

e The inspectors determined that licensee computer code validation was adequate. The required elements of a site-specific validation report exist but are not in one location or document. (Section 4.0).

e The licensee continues to make progress in upgrading the criticality safety program.

(Section 5.0).

e The licensee committed to clarification of ambiguous language in Chapter 6 of the license application regarding kalimits by proposing a specific limiting value. (Section 6.0).

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e Two unresolved items and five violations were closed (Section 7.0).

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9 REPORT DETAILS l.0 Loss of Vaporizor Water Level Control Event

a. Insnection Scone The inspectors reviewed the licensee investigation and corrective actions related to an event involving loss of water level control in the ammonium di-urinate (ADU) vaporizers. The inspectors reviewed the investigation report and root cause analysis, interviewed licensee management and operations staff, and conducted a walkdown of the vaporizor system.
b. Observations and Findings On July 17,1998, the licensee reported an event involving the loss of water level control in the ADU vaporizors to the NRC under Bulletin 91-01. The event occurred on July 16, 1998, while licensee operators were performing a 30-day Operator Maintenance check on the Line #3 vaporizer. The maintenance check consisted of filling the vaporizer with water from a hose and observing the closure of the steam valve. Operators performing the test observed improper drainage of the water being added to the vaporizer and took actions to clear obstructions to the drain opening. After clearing obstructions to the drain opening, operators successfully performed the test and reported the problem in the internal reporting system. Operators did not recognize the safety significance of the item and failed to report the event immediately to licensee criticality safety engineers for review. The problem was subsequ'ntly determined to be reportable under NRC Bulletin 91.01. The inspectors determined that reporting requirements were met.

Subsequent investigation of the event revealed that the water level control system was degraded in all eight operational vaporizors. It was also determined that operators had not been routinely performing shift operability tests for water accumulation in the vaporizors. The shift test consisted of opening the blowdown valve to see if water was ejected by the steam pressure. Some operators had been opening the riser valve instead.

The riser valve is connected to the level probe pot and opening this valve would not reveal whether the vaporizer drain line was plugged. In addition, it was detennined that at least one operator was using the riser valve to remove accumulated water from the vaporizer during operations to clear the vaporizer high level alarm, instead cf reporting the problem so that the reason for the accumulation could be determined.

l l The licensee has completed root cause analysis and determined that the first root cause of l the event was that paint was peeling ofTof certain UF 6cylinders and was being deposited on the screen over the one and two inch vaporizer drains blocking flow through the drains. The second root cause of the event was that requirements for operation and 3

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, maintenance of the system were not being consistently complied with. The inspectors J discussed the vaporizer tests with operators and determined that operators did not have a r

l universal understanding of how the vaporizer equipment operated, even though they 1

( clearly understood their required actions. The inspectors determined that this was l because the subject equipment was partially under the Soor and was not completely i visible. No additional safety issues were identi6ed and, although the licensee root cause

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evaluation was reasonable, the inspectors determined that operator training may have also i been a root cause.

1 Immediate corrective actions included painting the blowdown valves white, performing maintenance on and verifying proper functioning of all eight operating vaporizers, and )

conducting training of all operators to insure compliance with operating and maintenance  !

requirements. The inspectors intervewed a plant operator assigned to the vaporizer i system and observed a blowdown check for water in the vaporizer. The check was performed by opening the blowdown valve and observing how much water is ejected

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from the vaporizer. Although the operator understood that he was required to perform the J

I test each shift, he did not understand that he was checking for water accumulation in the )

vaporizer. The inspectors interviewed another operator on a different shift and determined

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that the operator understood the required actions, understood that he was checking to see I that the vaporizer drained, but did not completely understand the vaporizer equipn ent f con 6guration. Based on the operator responses, the inspectors had a concern with the overall quality of training. Because both operators clearly understood that a check was required and which valve was involved, the inspectors determined that immediate '

corrective actions were adequate.

I After demonstrating the shift test of the blowdown valve, the first shift operator showed 1 the inspectors a worksheet that is Hlled out when the test is done at the appropriate time.

The operator explained that an unsuccessful test (i.e., no trickle of water followed by steam) means an accumulation of water in the vaporizer or a nonfunctioning drain and the operator would notify their team manager.

Licensee determination of corrective actions are in progress. The inspectors determined l

that the most safety significant aspect of the event was the failure of operators to follow l procedures when working with the vaporizer system and the discovery that an operator was bypassing a safety significant control. The licensee indicated that a management team is investigating procedural non-compliances related to this and other events and I expects to develop formal corrective actions as a result. The licensee indicated that the quality of training was recognized as a possible factor in the procedural non-compliances.

Corrective actions associated with procedure non-compliances will be tracked along with other long term corrective actions as IFI 70-1151/98-204-01. l l

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d The inspectors determined that the licensee investigation was detailed and documented.

. ' The root cause evaluation used a version of the Taproot

  • method. The resulting root

. causes were reasonable and justified.

c. Conclusions The inspectors determined that licensee investigation and root cause determination for the loss of water level control event was adequate.

2.0 Criticality Analysis

a. Inspection Scop _g The inspectors reviewed the licensee response and corrective actions for Vi ?3 tion I (VIO) 70-1151/98-203-04 which involved the failure to perform indeperaient verification of CALCNOTEs. The inspectors interviewed criticality safety staff, reviewed the new j CALCNOTE index, and reviewed procedure RA-310, Regulatory Affairs Technical Reviews, to assure effectiveness of corrective actions. ,
b. Observations and Findmgs 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." During inspection 98-203, inspectors I identified 11 CALCNOTE packages that were referenced in CSEs/CSAs. Further licensee review determined that a total of 34 CALCNOTEs needed to be independently reviewed because they were either directly or indirectly referenced by a CSE/CSA. The independent reviews are scheduled to be completed by December 31,1998. To date, the reviews have identified no safety issues with the CALCNOTEs.

The licensee has developed a safety margin improvement program (SMIP) item requiring that CSEs/CSAs be collected into an indexed, controlled file with all documents in the field upgraded and verified. The inspectors determined that the index has been developed ,

and is a useful, comprehensive tool. The inspectors reviewed procedure RA-310 and l determined that it will adequately control independent verification of CSAs/CSEs and j supporting calculations.

l The inspectors determined that licensee corrective actions are adequate and l VIO 70-1151/98-203-04 is considered closed.

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c. Conclusions
The inspectors determined that licensee independent verification of CSAs/CSEs and associated CALCNOTEs, along with scheduled verification activities, are adequate to bring the licensee into compliance by the end of the year and prevent recurrence of the violation.

3.0 Review of Recent Unusual Occurrences

a. Inspection Scope The inspectors reviewed the recent occurrences ("Redbook" items) to verify that the criticality safety program was providing adequate criticality safety surveillance, support, and response to upset conditions in plant operations as required by Section 3.7 of SNM-1107.
b. Observations and Findings The inspectors identified five unusual occurrence reports since the last criticality safety inspection for more detailed review to verify that the criticality program was continuing

, to function in accordance with SNM-1107 requirements. These reports were:

ADU-0863, 8/6/98 Conductivity probes for the ADU steam cher's not failsafe.

ADU-0860,7/23/98 Identification of significant erosion of wall thickness of slab tanks.

I ADU-0855,7/16/9o Loss of water level control for ADU steam chests.

URRS-211,7/31/98 Failure oflevel indicators to prevent spill.

l URRS-210,7/31/98 Loss of circulation for bulk uranyl nitrate (UN) storage

' tanks.

URRS-209,7/27/98 Transfer to bulk UN storage tanks without required sample results.

L l The inspectors discussed each of these incidents with criticality safety and engineering l staff and walked down the specific process. In each case, the criticality safety function had been promptly notified of the occurrence and had taken action to safely resolve the situation with operations. Discussions with the criticality safety staffindicated that they were well aware of each of these occurrences and had concluded that only one of the occurrences, the loss of water level control for the ADU steam chests (ADU-0855), was reportable under NRC Bulletin 91-01. That incident was reported to the NRC in accordance with procedure RA-107.

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D The inspectors observed that both of the incidents involving the uranium recycle recovery

. ' services (URRS) bulk, unfavorable geometry UN storage tanks resulted in loss of some of the criticality safety controls assumed in the fault trees in the Integrated Safety Analyses.

In both cases, the criticality safety staff had concluded that multiple controls remained that would prevent a criticality and that NRC notification was not required. In the loss of circulation incident (URRS-210), operators had failed to properly line up valves when a tank was placed in the recirculation mode to help prevent precipitation of uranium in the unfavorable geometry tank. A recirculation pump was functioning but a valve on the discharge side was closed, which prevented circulation. The overheating pump was discovered about 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> later. Staffindicated that a root-cause investigation had not been performed but it was clear that operations had failed to ensure that the valve lineup was correct prior to energizing the recirculation pumps. Failure to ensure that the valves were correctly aligned was a violation of Chemical Operating Procedures. This item was still being addressed by plant staff and had not been closed.

In the unusual occurrence URRS-209, a batch of UN was transferred from safe geometry tanks to the unfavorable geometry bulk storage tanks without first receiving sample results that ensured that the uranium concentrations were below prescribed limits. This )

was in violation of Chemical Operating Procedure 836025, Rev. 4, Section 6.1. {

Preliminary investigations indicated that the transfer was caused by an operator error.

Under the procedure, completion of a log with sample results from the laboratory and supervisor sign off was required prior to the transfer. The criticality safety evaluation

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indicated that multiple transfers would be required to create a potential criticality. This incident was still being investigated. I Since two of the URRS incidents had resulted from the failure of operators to follow operating procedures, the staff was questioned on whether additional follow up had .]

occurred to stress the importance of following procedures. The inspectors confirmed that l the plant manager had stressed safety and the importance of following operating procedures during the quarterly all-hands meeting that occurred during the week that followed the incidents.

c. Conclusions The inspectors found that the criticality safety program had provided adequate criticality
safety surveillance, support, and response to the six recent plant upset conditions

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'4h Validation of Criticality Analysis Software

a. Inspection Scone 4

In order to resolve URI 70-1151/98-203-05 and determine the adequacy oflicensee validation efforts, the inspectors interviewed the licensee about the validation of one-dimensional deterministic SCALE module (XSDRN) and a criticality analysis computer code (KENO), and reviewed documentation for the validation of KENO.

b. Observations and Findings i The inspectors interviewed the licensee about the validation of XSDRN and KENO and reviewed the CALCNOTEs, which the licensee believes shows the validation of KENO.

The licensee validates the one-dimensional XSDRN code by comparing results and bias q to the three-dimensional KENO code. The licensee stated that the XSDRN results and j bias are conservative as compared to KENO. Therefore, the validation of XSDRN requires validation of KENO. The inspectors determined that this approach to validate XSDRN, as compared to KENO, is within industry standards and is appropriate. The .

inspectors determined that the licensee does not have a site-specine validation report for j KENO; however, the elements of a site-specine validation report appear to exist in other documents located both off-site and at the Columbia plant. The original cover pages of the CALCNOTEs signed by the author and verifier (independent reviewer) are located off-site. The licensee provided faxed copies of those pages to the inspectors. The licensee agreed with the inspectors that the information in a site-specific validation report needs to be independently reviewed and approved by management before being used. j

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The licensee provided faxed copies of memorandums containing management approval to use cross section processing code (NITAWL), XSDRN, and KENO-Va at the site. The I inspector reviewed procedure EP-307, " Computer Software Installation and Checkout,"

which described the necessary steps to verify the installation of computer codes at the site (veri 6 cation). The procedure appears to be adequate and follows standard industry practice.

l A site-speciSc validation report requires a theoretical methodology report, a generic validation report, and site-specine processes and conditions. Use of the standard validation methodology in ANSI /ANS 8.1 is appropriate if representative critical experiments, appropriate data, and a validated computer code system with appropriate boundary conditions are used. Part of a site-speciDe validation report should describe

' why it is appropriate to use the 227-group library for the licensee's code system of NITAWL, XSDRN, and KENO-Va to perform criticality safety analyses.

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Using the 227-group cross section library and the NITAWL, XSDRN, KENO-Va code

'. ' system, the CALCNOTEs provide the bias for the 95% certainty of the 95% confidence j level for homogenous systems to be 0.00285 (CALCNOTE # CRT-94-012-0,

" Benchmark runs for the [ Columbia] criticality criticals with NITAWL, XSDRN, and

. KENO-Va on an HP-735 Workstation") and for heterogeneous systems to be 0.0077 4 (CALCNOTE # CRT-94-010-0," Calculation of KENO-Va Method Benchmarks & Bias Comparison with 32 Critical Experiments Development of Bias and Uncertainty").

l The licensee is in the process of updating its criticality safety program through the SMIP initiative. One part of SMIP is the development of a site-specific criticality safety handbook. The licensee has volunteered to include the site-specific validation report as a

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chapter in the handbook. The criticality safety handbook would be inspectable. The licensee has volunteered to create a subtask under SMIP to create the Table of Contents (toc) for the handbook. The toc will be ready to be reviewed by NRC inspectors by October 1,1998. Inclusion of the validation report in the criticality safety manual will be tracked as IFI 70-1151/98-204-02. This closes URI 70-1151/98-203-05.

c. Conclusions The inspectors determined that validation was adequate with the exception of documentation. The required elements of a site-specific validation report exist but are not in one location or document. The licensee has committed to include a validation report in a single document.

5.0 Criticality Safety Program Ungrades

a. Inspection Scope The inspectors reviewed licensee actions taken in response to open items concerning criticality safety program improvements. The inspectors met with licensee management and discussed progress with implementation of program improvements.
b. Observations and Findings IFI 70-1151/98-202-01 The inspectors discussed with criticality safety staff the concern that the criticality safety program procedures and practices might not always ensure that all criticality safety determinations had adequate' independent review prior to operation. The specific concern was that the criticality safety approval process had not always ensured that there was independent verification that 1) calculational models reflected as-built and operated 9

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conditions, and 2) the as-built passive controls matched the design criteria. The licensee

  • criticality safety staffindicate that they now have a clearer understanding of the concern 1 and will modify their procedures to address the issue. IFI 70-1151/98-202-01 remains open.

IFI 70-1151/98-202-02 1

The status and adequacy ofimplementation of the SMIP was discussed with criticality safety and management staff. One concern raised in the 98-202 report was that management had not ensured that adequate and appropriate staffing and resources would be available to accomplish the SMIP corrective actions commitments by the scheduled dates. The licensee stated in the July 24,1998, response to VIO 98-202-04 and the concerns identified in the inspection report 98-202 that the licensee had " reviewed and evaluated the effectiveness of the current organization structure and stafTmg relative to ongoing regulatory compliance initiatives. This review and evaluation are complete, and any subsequent modifications should be in place by July 31,1998." Discussions with j senior staff on August 12,1998, indicated that the plant manager was auiting external approvals prior to implementing changes to the organizational structure.

IFI 70-1151/98-202-02 remains open.

I IFI 70-1151/98-202-03 The inspectors discussed with criticality safety staff the status of the improvements to the configuration management program for nuclear criticality safety controls, specifically the clear identification of criticality controls and integration of safety functions. It is still pre-mature to make a final determination on the effectiveness of the improvements.

-IFI 70-1151/98-202-03 remains open.

c. Conclusions The licensee continues to make progress in improving the criticality safety program and has added additional comniitments to the Safety Margin Improvement Program in order to focus criticality safety program improvements on specific areas such as validation.

6.0 License Limit on Calculated i@ltinlication Factor  !

a. Insnection Scope I The inspectors met with licensee management and criticality safety staff concerning l- licensee calculations resulting in a km greater than 0.95 under credible upset conditions. l

{ This issue was initially reviewed and reported as URI 98-203-03 and focused on the 10 l

l adequacy of the granulator hopper evaluation. Because the licensee indicated that other

. ' cases exist where k,y is greater than 0.95, the inspectors reviewed the broader issue of safety margin adequacy.

, b. Observations and Findings License Section 6.4.2(a) requires that computed k,y for normal operating conditions and expected process upsets be less than or equal to 0.95. The licensee stated that unexpected

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j accident conditions are different from expected procese upsets and are required to be less j than 1.0. The inspectors determined that what the license considered as " normal operating conditions and expected process upsets" are nomial operating and process conditions and that " unexpected accident conditions" are the equivalent of credible j process upsets. The inspectors determined that although the license requirement for l determining k,yis ambiguous due to the above unique terminology, the requirement to j establish and document the safety margin is clear.

The licensee has applied for a license amendment (Revision 10.0) for Chapter 6,  !

" Criticality Safety," which includes an explicit request for an upper k,y limit of 1.0. Th'.s I amendment request is currently under review. During discussion with the inspectors, the licensee agreed to change the suggested k,y limit to 0.98 in response to a pending request for additional information (RAI). Clarification of ambiguous license language will be tracked as IFI 70-1151/98-204-03. This closes URI 70-1151/98-203-03.

c. Conclusions The inspectors determined that safety limits currently evaluated by the licensee are (

adequate. The licensee committed to clarification of ambiguous language ia Chapter 6 of j the license application regarding k,ylimits by proposing a specific limiting value to be j submitted in response to a proposed RAl. l 7.0 Ogn Item Review l

VIO 70-1151/96-204-01  !

This violation concemed inadequate guidance in procedure RA-102 which did not require intemal auditors to look for process upsets and procedural inadequacies as required in Section 3.6.1 (b) of the license. To determine the status of corrective actions, the inspectors reviewed a memorandum from Regulatory Affairs, dated January 24,1997, and Procedure RA-102, Rev. 8. '

The January 24,1997, memorandum stated that "AS YOU ARE ALREADY DOING, your formal monthly Regulatory Compliance Inspections for criticality .... safety WILL 11 i

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CONSIST OF ON-THE-FLOOR TOURS." The inspectors observed that Section 2.0,

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. ' Policy and Scope"in RA-102, Revision 8, dated April 17,1997, states that " Inspections j shall include looking on the floor for process upsets and procedural inadequacies well beyond those that would be surfaced by simple paperwork reviews."

The inspectors determined that the January 24,1997, memorandum is consistent with l RA-102, Revision 8 which contained the appropriate language regarding process upsets q and procedural inadequacies to comply with license requirements. This item is closed.

VIO-70-1151/96-204-02 i This violation concerned the failure to implement the facility self-assessment program as t required by License Section 3.6.2. To determine the status of corrective actions, the inspectors reviewed memorandums dated January 17 and 29,1997, concerning licensee communications on Audits and Self-Assessments.

The inspectors observed that the January 17,1997, memorandum stated that "[All employees shall] PROMPTLY REPORT ANY UNSAFE ACT OR CONDITION TO LINE MANAGEMENT AND REGULATORY AFFAIRS." This memorandum confirms that all employees are aware of the need to perform self-assessments and report results to both their management as well as Regulatory Affairs. The inspectors observed that the January 29,1997, memorandum provided clarification in the meanings of the requirements in License Section 3.6," Audits and Self-Assessments." The clarifications described the requirements in Section 3.6, as well as who is responsible for performing

- the audit or self-assessment.

The inspectors determined that the January 17 and 29,1997, memorandums, are adequate to clarify the purpose and objectives of the facility management audit and self-assessment program. This item is closed.

VIO-70-1151/96-204-04 This violation concerned the failure to conduct process review inspections and audits in accordance with a written procedure as required by License section 6.1.2. The inspectors reviewed the licensee reply to the Notice of Violation, the Guidelines for Preparing an  ;

htegrated Safety Analysis, and licensee procedure RA-111 to close out the violation.

The inspectors determined that process review inspections and audits are now conducted in accordance with licensee procedure RA-111. This item is closed.

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. . VIO 70-1151/97-205-06 The inspectors reviewed the corrective actions identified by the licensee in the February 5,1998, response to violation 70-1151/97-205-06. 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. As discussed above, the licensee has now committed to include their validation report in the criticality safety handbook. Although corrective actions have been established and the schedule is being followed, the inspectors determined that due to the long term safety significance of this item it should continue to be tracked. This item remains open.

VIO 70-1151/98-202-04 The inspectors reviewed the status and adequacy of corrective actions identified by the licensee in the July 24,1998, response to VIO 98-202-04. The inspectors determined that the immediate actions taken by the licensee were adequate. The licensee has several initiatives in the Safety Margin Improvement Program that are expected to significantly strengthen the overall criticality safety controls and reduce the likelihood of problems such as identified by this violation. Specific changes include revision to Procedure RA-108 to clearly document all safety controls associated with each plant system or component. The revision is scheduled for completion by September 30,1998. Progress in implementing the Safety Margin Improvement Program initiatives will continue to be

tracked under IFI 70-1151/98-202-02. Sufficient progress has been made to reduce the likelihood of recurrence of similar problems. This item is closed.

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, , ITEMS OPENED. CLOSED. AND DISCUSSED Opened

. IFI-70-1151/98-204-01 ibcks the investigation of procedure noncompliance related to several recent events including the loss of water level control event. ,

IFI-70-1151/98-204-02 Tracks the inclusion of the validation report in the proposed criticality safety handbook.

IFI-70-1151/98-204-03 Tracks the licensee commitment to clarify ambiguous license language concerning kg limits.

C!xed I URI 70-1151/98-203-03 Concerned the failure to demonstrate the safety margin for the granulator hopper. This item is now covered by IFI 98-204-03.

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

This item is now covered by IFI 98-204-02.

VIO 70-1151/96-204-01 Concerned inadequate guidance in procedure RA-102 which did I not require internal auditors to look for process upsets and procedural inadequacies.

VIO 70-1151/96-204-02 Concerned the failure to implement the facility self-assessment program.

VIO 70-1151/96-204-04 Concerned the failure to conduct process review inspections and audits in accordance with a written procedure.

VIO 70-1151/98-202-01 Concerned licensee operation of equipment with an inoperable

! criticality safety control.

I VIO 70-1151/98-203-04 Concerned the failure to perform independent review of calculations supporting :alvent.

Discussed VIO 701151/97-205-06 Concerned the failure to notify the NRC within four hours of discovering that the moisture drop-out tank was unanalyzed.

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IFI 70-1151/98-202-01 Concerns the revision of procedure RA-310 to ensure calculational models match accurately reflect existing conditions and licensee development of adequate independent review requirements.

IFI 70-1151/98-202 Concerns the availability of adequate and appropriate staffing and resources to accomplish the SMIP corrective actions commitments by the scheduled dates.

IFI 70-1151/98-202-03 Concerns the effectiveness of the configuration management program to support the NCS function.

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, , MANAGEMENT MEETINCS

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Thie inspector met with licensee management periodically during the inspection. The presented the inspection scope and findings to members of the licensee's staff at the conclusion of the inspection on August 13,1998. The licensee acknowledged the fmdings presented at the meeting.

PARTIAI. LIST OF PERSONS CONTACTED Westinghouse Columbia Plant Edwin Keelen Manager, Product Assurance Edward Reitler Regulatory Engineer Sam Mcdonald Technical Services Manager l

Nancy Parr Chemical Process Engineering Manager j David Williams Criticality Safety Engineer j Tommy Shannon Regulatory Technician j Wilbur Goodwin Regulatory Affairs Manager l Norman Kent Criticality Safety Engineer I Bob Williams Regulatory Engineer l

Don Goldbach Manager, Chemical Operations )

Jim Bush Manager, Manufacturing I Jim lleath Manager, Regulatory Engineering and Operations Spencer Gantt Senior Regulatory Engineer Harold Docton Manager, Maintenance Keith Fowler Information Systems Lucian Weatherford 1 raining Nuclear Regulatory Commission Dennis Morey, Criticality Safety inspector, NRC Headquarters Harry Felsher, License Reviewer, NRC Headquarters Doug Outlaw, Consultant, SAIC l l

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' ACRONYMS USE]l

.. IDU- ammonium di-urinate CALCNOTE. document describing criticality calculations

.CSA criticality safety analysis CSE. criticality safety evaluation IFI inspector followu,n item KENO a criticality analysis computer code NITAWL cross section processing code RAI- . request for additional information SMIP safety margin improvement program 4 toc table ofcontents UN uranyl nitrate

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URI unresolved item URRS uranium recycle and recovery services VIO '- violation XSDRN one-dimensional deterministic SCALE module 17 l i

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