ML20247F016

Insp Rept 70-1113/89-02 on 890123-27.No Violations or Deviations Noted.Major Areas Inspected:Mgt Organization Controls,Training & Retraining,Nuclear Criticality Safety, Operations Review,Maint & Surveillance Testing

ML20247F016
Person / Time
Site:	07001113
Issue date:	03/10/1989
From:	Kasnicki D, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247F004	List: ML20247F001 ML20247F016
References
70-1113-89-02, 70-1113-89-2, NUDOCS 8904030292
Download: ML20247F016 (8)

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Report No.: .70-1113/89-02

!' Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conducted: January 23-27, 1989 Inspector: V d esi 3 d D. A. Kasnick u D ate (Signdd Approved by: DD E. J. McAlpins, Section Chiel 3 bo b 9 Oate Signed.

Material Control and Accountability Section Nuclear Materials. Safety and Safeguards Branch Division of Radiation Safety and Safeguards

SUMMARY

-Scope:

This routine unannounced inspection was conducted in the areas of Management

. Organization ~and Controls, Training and Retraining, Nuclear Criticality Safety, Operations Review, Maintenance and. Surveillance Testing. The inspection addressed certain Inspector Follow-up Items (IFI) from the Operational Safety Assess-ment, other IFIs, gathered information on upcoming activity at General Electric (GE),- and followed up on a non-reportable event which recently occurred at GE.

Results:

In the areas inspected, violations or deviations were not identified.

Thirteen IFI's were addressed, eleven were closed, and two remain open. The two IFis which remain open deal with work that is still on going and progress toward their closing is being made. 'One item investigated regarding upcoming activity is within the scope of GE's existing license and there 13 licensing activity on going with the other item. Their corrective action regarding thre nc11-reportable event appears more thant adequate. GE's response to questions and concerns raised by NRC Region II,in the form of IFIs has been noteworthy.

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2 REPORT DETAILS

1. Persons Contacted Licensee Employees

• G. Bowman, Senior' Program Manager, Nuclear Safety Engineering

• A. Dada, Manager, Chemical Programs

• R. Foleck, Senior Specialist, Licensing Engineering

• R.-Keenan, Senior Nuclear Safety Engineer G. Mobley, Maintenance Planner

• S. Murray, Senior Nuclear Safety Engineer W. Peters, Manager, FM0 Maintenance

• J. Taylor, Senior Nuclear Safety Engineer

• C, Vaughan, Manager, Regulatory Compliance L. Ward, Site Instrumentation and Electronics (formerly)

• T. Winslow, Manager, Licensing and Nuclear Materials Management

• Attended exit interview

2. Wilmington Safety Review Committee Reviews of Major Site Operations (88005, 88020)

The inspector reviewed the functions and responsibilities of the Wilmington Saf9ty Review Committee (WSRC) with GE representatives and reviewed GE documentation associated with WSRC meetings. GE procedure P/P40-1 "Wilmington Safety Review Committee," Revision 8, dated October 23, IM7, establishes the WSRC and designates more than five senior members of the GE technical staff as committee members. The in-spector reviewd WSRC meeting minutes and attachments dated January 9, 1986, February 4,1986, February 20, 1986, and April 12, 1988, which are minutes of spe:ial meetings of the WSRC which were held in acdition to routine meetirqs which are held at a frequency of four meetings each calendar year with no more than 180 days between consecutive meetings as required by Paragraph 2.3.1 of the license application. The reviewed meeting minutes and attachments addressed major operations. These WSRC reviews appeared to be indicative of a comprehensive management review of major operations. IFI 86-22-44 is closed.

No vialations or deviations were identified.

3. Trainir,3 (88010)

Paragraph 2.6 of the license application requires that employees complete formal nuclear safety training prior to being allowed une morted access to controlled areas. Additionally, the license application requires

3 retraining every two years. The inspector discussed the nuclear safety training program with a GE representative and inspected employee training records.

l No violations or deviations were identified.

4. Waste Box Monitors (88015, 88020)

The inspector reviewed the nuclear criticality safety analysis dated October 26, 1988, for waste accumulation monitoring systems which measure the dranium accumulation in four foot cubic waste boxes used as collection and disposal containers for uranium contaminated waste. The analysis was discussed in detail with a GE nuclear safety engineer. The analysis had received an independent review as required by Paragraph 2.5.2.1 of the license application and was performed so as to determine fuel processing limits and any further nuclear safety requirements for fuel processing and handling operations so as to conply with the Double Contingency Principle as is required by Paragraph 4.1.1 of the license application. The corresponding Nuclear Safety Requirements (NSRs) and operating procedure had been issued and the monitors were in use. The inspector observed one location where the system was in use. The accumulation of a mass of uranium in excess of the mass limit would trip a local alarm and a control room alarm. The above reviews and discussions indicated that these monitors appear to be a well designed and implemented systems. IFI 86-22-05 is closed.

No violations or deviations were identified.

5. Nuclear Safety Engineering (NSE) Audits of Non-routine Maintenance (88005, 88015, 88025)

Previously, if an Area Manager decided that an NSE review of requested non-routine maintenance work was not required, he documented that decision on a Configuration Change Request (CCR) form and this constituted approval for performing the work. The inspector had previously determined that these decisions by the Area Manager were not audited as part of the routine nuclear safety audit program. GE representatives questioned the necessity of including this item in their audit program by citing the level of experience and competence of their Area Managers, however, they had agreed to evaluate this issue. GE's review of this issue resulted in their concurring that a potential weakness existed here and their corrective action consisted of eliminating the CCR form, and revising the Facility Change Request (FCR) form (P/P40-5(1), Rev. 5, dated December 16, 1988) such that the Area Manager still makes the decision as to whether or not an NSE review per se is required but he now documents that decision on the FCR form. NSE receives, reviews and files a copy of all FCR forms whether or not the FCR form precipitates a formal NSE evaluation and this essentially constitutes a 100 percent NSE audit of these Area Manager decisions. These changes satisfy the question of concern and streamline this part of GE's programmatic control system and they should be commended for their initial cpenness and subsequent response to this item. IFI

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. 4 88-07-01 is closed.

No violations or deviations were identified.

6. Engineering Changes (88005, 88015, 88025)

The inspector had previously determined that related procedures (Plant Engineering Work Request, No. 20-12, Revision 5, dated February 19, 1987, and Design Services work Request, No. 20-13, Revision 3, dated September 12, 1985) and forms require that the Area Manager review the engineering work package and initiate an NSE review via an FCR form if he decides that an NSE review is required. The inspector had also determined that the Area Manager's "no FCR required" decisions were not audited as part of the routine nuclear safety audit program. GE representatives had agreed to evaluate this potential weakness in their programmatic control system. During this inspection the inspector determined that GE's evalu-ation resulted in their decision to include this item in their audit program. Further, the " Request for Assistance" form established by P/P 20-12, on which the Area Manager documents his decision as to whether or not an FCR is required, and P/P 20-12 itself, was revised (P/P 20-12, Plant Engineering Work Request, Revision 6, September 28, 1988), to better ensure the Area Manager's early involvement in engineering work within the Controlled Access Area (CAA). These changes meet and exceed the corrective action implied by the potential weakness originally identified and GE should be commended for their initial openness and subsequent response to this item. IFI 88-07-02 is closed.

No violations or deviations were identified.

7. Criticality Alarm Calibration (88015, 88025)

A GE procedure, " Nuclear Safety Instrumentation," NSI No. 0-4.0, Revision 25, September 2,1988; Appendix C, " Instructions for Inspection of the Criticality Warning System," establishes daily panel indicator lights and detector current status checks, weekly internal source response and horn sounding checks, and yearly calibrations with an external gamma source. The inspector reviewed records for the weekly internal source checks from January 1988 to January 1989 and for the most recent annual external source calibration on November 12, 1988, and everything appeared to be in order.

No violations or deviations were identified.

8. New Fuel Assembly (88015, 88020)

NRC Region II was notified of a new fuel assembly design which GE will be manufacturing in the near future and the inspector pursued this further from the standpoint of any new but related health and safety activity.

The inspector learned that higher enrichment than previously

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5 processed will be used but still within the current limit of the ~

licensee's license.

No violations or deviations were identified.

9. Uranium Recovery from Contaminated Sludge (88005, 88015, 88020)

NRC Region II was informed of a project being designed at GE to recover uranium from contaminated sludge and the inspector pursued this further from the standpoint of any new but related health and safety activity.

The inspector learned that the project is to decontaminate sludge and recover uranium from waste lagoons on site and, while the project had been dormant, licensing communication with NMSS on this project began in 1983 and GE plans to have a modified draft license amendment application prepared during January 1989. GE plans that the project will operate on a safe batch basis.

No violations or deviations were identified.

10. Liquid Waste Holding Tank Leak (88020)

The licensee had notified the NRC that at 8:10 p.m. on December 21, 1988, a thumb-size hole developed in a liquid waste holding tank. This notification was made under the provisions or 10 CFR 70.52 and was later determined by the licensee to be unnecessary. The tank which is located outside holds nitrate waste from the licensee's scrap recovery system.

The licensee initiated pumping of liquid from the leaking tank at 8:45 p.m. and the leak was stopped by 10:00 p.m. The liquid which leaked from the tank overflowed a curb around the tank and drained into a parking lot and into a service drain. The service drain carried the liquid to the process lagoon. The licensee estimates that a maximum of 1,500 gallons of liquid leaked from the tank. The concentration was approximately 3 ppm uranium (5 pCi/ml) which is below unrestricted area MPC. The pH of the liquid was about 2. The liquid was scheduled for release to the nitrate lagoon after being treated with lime to adjust the ph and centrifuged.

Liquid from the nitrate lagoon flows to the process lagoon before being discharged to the Cape Fear River. There were no injuries and no one was contaminated by the event. Through discussion with GE representatives, the inspector learned that following this incident GE performed an evaluation of the tank and the decision was made to take this tank out of service immediately and ultimately replace it with a new tank. This tank was a surge tank in a continuous process line in that solution could be accumulated in it if necessary because of problems and/or maintenance downstream.

No violations or deviations were identified.

11. Correction of Previously Identified Errors in Calibration Records (88025)

The Operational Safety Assessment, Inspection Report No. 70-1113/86-22, discussed some errors which were obseived in calibration records.

Specifically, the inspection report stated, "The I&C group maintains a computer scheduling system for the process instruments and controls

. 6 assigned to it. The group has primary responsibility for implementation of P/P 70-23. The team was informed that there have been three different computer systems (t ograms) for scheduling calibration within the last five years. In fac;, it appears that some data has been incorrectly entered into the current program database. For example, the due date for instrumentation calibration in 1985 was recorded as 1986 instead of 1985.

The cognizant supervisor indicated that the data was available to correct the database and that action would be taken on this matter." GE's subsequent written response to the Operational Safety Assessment stated,

" Errors identified in calibration due date records have been corrected."

Cognizant GE representatives during a subsequent inspection (87-15) verbally confirmed GE's written response and the issue remained open pending the NRC's review of the corrected data. During this inspection, since the Operational Safety Anessment inspection report had not explicitly identified exactly which calibration data were in question and l now a cognizant GE representative could not recall exactly which calibration data were in question, these data could not be specifically retrieved for inspection. However, during the course of this inspection the inspector, in reviewing various characteristics of GE's latest site-wide maintenance and calibration database (MPAC), did not note any errors of the type described by the Operational Safety Assessment inspection report. IFI 86-22-34 is closed.

No violations or deviations were identified.

12. Nuclear Safety Engineering (NSE) Audits of Maintenance and Calibration Histories on Active Engineering Controls (AEC) (88005, 88015, 88025)

During a previous inspection the inspector had questioned whether NSE should audit calibration histories on AECs related to nuclear safety and GE representatives had agreed to evaluate this issue since it is a potential weakness in their programmatic control system. Discussions with GE representatives during this inspection indicated that their evaluation of this issue resulted in the decision to include calibration histories on AECs in their audit program. GE should be commended for their initial openness and subsequent response to this item. IFI 88-07-03 is closed.

No violations or deviations were identified.

13. Maintenance Planning and Control (MPAC) System (88005, 88015, 88025)

The inspector reviewed with GE representatives various capabilities of the MPAC system software which has now been fully implemented as the sole system for tracking and planning calibration and maintenance activity. l The system can produce various data sorts such as retrieval of the calibration history for specific types of instruments and controls such as solution density AECs. Multiple calibration frequencies can be handled by the system and in most cases the next "due date" is generated automatically when the " job completed" date is entered. Essential equipment is identified on the system as are the audits of chemical bulk storage tanks and diesel generator maintenance. The tracking of active and passive interlocks has not yet been implemented on the system and is still in development. MPAC appears to be developing into a fine system, i

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7 however, in reviewing the system's displays with GE representatives, the inspector noted and GE representatives concurred that there are some awkward peculiarities associated with using the system and with understanding some of the displayed data that are related to the inflexibility of the purchased software. While MPAC has been fully implemented, it is still in development and GE representatives indicated that such issues are being addressed. Closed are IFIs 87-15-01, 87-15-02, 87-15-03, 87-15-05, 88-07-04. Remaining open are IFIs 87-15-04 and 87-15-06.

No violations or deviations were identified.

14. Exit Interview The inspection scope and results were summarized on January 27, 1989, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results described below. Although reviewed during this inspection, proprietary information is not contained in this report. Dissenting comments were not received from the licensee.

Item Description and Reference IFI 87-22-05 Positive nuclear criticality safety controls for four foot cubic waste boxes (paragraph 4).

IFI 86-22-34 Correct calibration "due date" records (paragraph 11)

IFI 86-22-44 Accident scenarios and controls (paragraph 2).

IFI 87-15-01 Chem safety audits implementation on MPAC computer tracking system (paragraph 13).

IFI 87-15-02 Identification of essential safety equipment on MPAC computer tracking system (paragraph 13)

IFI 87-15-03 Tracking of multiple calibration frequencies on MPAC computer system (paragraph 13).

IFI 87-15-04 Improved calibration records (paragraph 13).

IFI 87-15-05 Tracking of diesel generator maintenance on MPAC computer system (paragraph 13).

IFI 87-15-06 Tracking of testing of active / passive interlocks on MPAC computer system (paragraph 13).

IFI 88-07-01 Random sample of CCRS which did not precipitate FCRS (paragraph 5).

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IFI 88-07-02 Procedures and forms related to FM0 engineering work I packages (paragraph 6).

IFI 88-07-03 Maintenance and/or calibration histories (paragraph 12).

IFI 88-07-04 MPAC System's capability of providing various data sorts of calibration . and maintenance histories (paragraph 13).

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