ML20249C808

Insp Rept 70-1151/98-202 on 980427-0501.Violation Noted. Major Areas Inspected:Progress Made Involving Near & Long Term Improvements in Nuclear Criticality Safety Program

ML20249C808
Person / Time
Site:	Westinghouse
Issue date:	06/26/1998
From:	Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20249C805	List: ML20249C804 ML20249C807 ML20249C808
References
70-1151-98-202, NUDOCS 9807010223
Download: ML20249C808 (15)

Text

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• • • • • 4 OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS NUCLEAR CRITICALITY SAFETY INSPECTION REPORT REPORT NO: 70-1151/98-202 I

DOCKET NO: 70-115i LICENSE NO: SNM-1107 LICENSEE: Westinghouse Electric Corporation Commercial Nuclear Fuel Division P.O. Drawer P.

Columbia, S.C. 29250 FACILITY NAME: Commercial Nuclear Fuel Division INSPECTION DATES: April 27 - May 1,1998 INSPECTORS: J. R. Davis, Team Leader ,

NCS Engineer, Fuel Cycle Operations Branch D. A. Outlaw, Contractor Science Applications International Corporation APPROVED BY: Philip Ting, Chief Fuel Cycle Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS I

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,SNM.1107 i 70 1151/93 202 TABLE OF CONTENTS B AC K G RO UN D . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 EXECUTIVE SUM. MARY . . . . . . . . . . . . . . . ........................... ........ 1 Introduction . . . . . . . . . . . . . . . . . ............... ........................ 1 M aj or Resul ts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 REPO RT D ETAI LS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1. NCS CORRECTIVE ACTION PLAN REVIEW ......... ............. 2 A. Immediate Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 B. Long-Term Corrective Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Enhance Interim Design Safety Basis . . . . . . . ... .................. 5 Establish QA & Maintenance of Safety-Related Controls . . . . . . . . . . . . . . . 6 Management Oversight & Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

11. PLANT ACTI VITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 A. UN B ulk S torage Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 9 B. UF6 Vaporization Chests . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 C. ADU Processing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 D. 1008 Ammonia Scrubber . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 MANAG EM ENT MEETING S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 ACRON YM S U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 l suss reis l

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])ACKGROUND

' The Nuclear Regulatory Commission (NRC) conducted a previous nuclear criticality safety inspection at the Westinghouse Commercial Nucleai Fuel Division (CNFD) on August 25 -29, 1997. As a result of this inspection, the NRC initiated enforcement action against the Licensee for several apparent violations in the administration and implementation of safety significant issues in the CNFD Nuc! car Criticality Safety (NCS) Program. As part of the NRC's '

consideration for severity level, the Licensee presented a plan and schedule for implementing lasting corrective actions. The purpose of the present inspection was to follow-up on the progress ,

that the plant had made in implementing their comprehensive NCS corrective action plan. 1 EXECUTIVE

SUMMARY

Introduction l The NRC performed an announced nuclear criticality safety inspection of the Westinghouse CNFD in Columbia, SC, from April 27 - May 1,1998. The purpose of the inspection was to review the progress made involving near- and long-term improvements in the NCS program. As a result of the inspection, one violation of NRC requirements was identified and several weaknesses were noted with the NCS corrective action plan implementation. These specific findings and areas of review are fully developed in the Report Details; the major conclusions are summarized below.

Maior Results i

1) A weakness was identified in the implementation ofimmediate NCS corrective actions. i (Section I.A]

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2) An inspector followup item was identified concerning the development of adequate arid effective independent NCS review methodology. [Section I.A]

3) An inspector followup item was identified conceming the adequacy of Safety Margin Improvement Program (SMIP) item implementation related to NCS. [Section I.B]

4) A weakness was identified concerning the interim identification and management of NCS controls and safety-related devices. [Section I.B]

5) Weaknesses were identified in the management oversight and control to ensure full ]

l integration of the SMIP initiatives, completion of SMIP items, and resource allocation management to ensure successful completion of committed tasks at an acceptable quality level. [Section I.B]

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6) An inspector followup item was identified concerning the effectiveness of the

. . Configuration Management Program to adequately support and implement the NCS function. [Section ll.b]

7) A violation was identified involving the operation of process equipment with an inoperable criticality safety control. [Section ll.b]

REPORT DETAILS

1. COMPREllENSIVE NCS CORRECTIVE ACTION PLAN REVIEW A. Immediate Corrective Actions

a. Scope As a result of the findings identified in NRC Inspection Repon 70-1151/97-205, the licensee evaluated and prioritized the deficiencies into immediate and long-term corrective actions. The licensee committed to completing the near-term actions no 1 later than December 15,1997. The inspectors reviewed the available evidence to determine if the licensee appropriately completed the committed actions.

b. Observations and Findings The licensee determined that many of the near-temi corrective actions involved revisions to administrative procedures detailing necessary NCS practices. The licensee also indicated that an extensive review of Section 6.0 of SNM-1107, to identify applicable program elements which were to be captured in new or revised procedures, was necessary to meet the immediate corrective action commitments. The inspectors reviewed the revised documents and Cound that the licensee had made a number of substantive changes to 12 administrative procedures in response to the issues raised in NRC Inspection Report 70-1151/97-205 and also issued " Guidelines for Preparing a Baseline Integrated Safety Analysis," Revision 0, November 10,1997. Ilowever, the inspectors found that several important revisions were not completed or did not fully address the issues as committed.

For instance, the licensee indicated that applicable program elements of Section 6.0 of the license were incorporated into new or revised draft procedures and provided the inspectors a copy of Section 6.0 of the license that was marked in the margins indicating the administrative procedures that implemented each of the specific license requirements. Upon review, the inspectors determined that the majority of margin notes indicated that most of the technical aspects of the criticality safety requirements of Sectica 6.0 were implemented in the new l Nuss reis

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%NM I t'07 4 70-I l 31M-202 Integrated Safety Analysis (ISA) guidelines. Ilowever, a comparison of the specific Section 6.0 license requirements with the information in the ISA guidelines indicated that not all of the specific license requirements were incorporated. Examplesinclude:

1. Section 6.2.1 contained a 12-line paragraph on the Double Contingency Principle and its specific implementation requirements; however, the ISA guidelines simply referred the reader to ANSI /ANS 8.1 which has much less specific guidance and requirements than that of the license;

2. Section 6.2.2 contained a half-page write-up on the use and implementation of passive, active, and administrative NCS controls; however, the ISA guidelines did not explicitly identify these requirements; and

3. Section 6.2.4 contained six pages of definitions and requirements for criticality safety controlled parameters, but the ISA guidelines did not incorporate the specific requirements of this section.

Discussions with the nuclear criticality safety staff concerning these discrepancies indicated that they intended to incorporate license requirements related to criticality safety analyses / evaluations and calculations in a planned criticahty safety manual.11owever, the inspectors note that development of this manual is identified as a long-term corrective action that exceeds the commitment date for the near-term items.

As further evidence ofincomplete flowdown oflicense requirements into procedures, RA-302, " Criticality Signs," was revised to incorporate a license condition from Section 6.1.l(c) which states that," Posting will occur at the entrance to work or storage areas . . " Ilowever, the RA-302 revision read,

" Consideration shall be given to posting of entrances to work or storage areas . . "

which changed the specific meaning of Section 6.1 l(c). As well, RA-311,

" Nuclear Criticality Safety Programs and Annual Process Reviews," was revised to add requirements for annual process reviews as required by License Section 6.1.2.

Ilowever, the revised procedure refers to the ISA guidelines document which does not provide specific requirements for the annual process reviews. The RA-311 revision also did not address the specific deficiencies in the NCS program elements as identified in inspection report 97-205. Specifically, the procedure lists the elements of a program review, but does not include the Verification Program, the Maintenance Program, methods of criticality safety control, use and implementation of all the controlled parameters defined in the license, and control of criticality safety documentation among the NCS program elements.

Finally, RA-310," Regulatory Affairs Independent Technical Reviews," was revised, but did not incorporate a requirement for the technical reviewer to verify

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. . $NM 1107 4 70-l M INK-202 that the proposed calculational model adequately represented the system being analyzed or to verify that the as-built passive controls matched the design criteria.

Discussions with the nuclear criticality safety staffindicated that independent technical reviews were performed on the criticality safety analyses, but that independent verification to ensure that the calculational model reflected as-built and operated conditions and that the as-built passive controls matched the design criteria had not necessarily been performed. Revision of RA-310 or other procedures to correct all these deficiencies and the development of adequate and effective independent review will be tracked as Inspector Followup Item (IFI) 70-1151/98-202-01.

c. Conclusions Although the inspectors found that progress had been made in ensuring that all significant license requirements were incorporated into administrative procedures, the limited review by the inspectors identified several deficiencies in accomplishing this goal. Specifically, several of the items identified by NRC inspectors in the violations from the 97-205 inspection had not been incorporated into procedures as committed, and the incorporation of Section 6.0 requirements into procedures was flawed and incomplete. Licensee technical staff apparently did not fully understand the commitments made at the pre-enforcement conference and planned to include the technical requirements for criticality safety in the planned long-term corrective actions.

l The inspectors believe that these findings are the lingering results of the management deficiencies identified by inspection Report 97-205 and acknowledged by the licensee at the enforcement conference, in that, management systems to ensure that corrective actions were adequately implemented were still immature. However, since the long-term corrective actions will address these issues more fully, such deficiencies are identified here as weaknesses.

B. Long-Term Corrective Actions

a. Sgspe Westinghouse has in.arporated the development oflasting corrective actions into their SMIP either as new initiatives or enhancements to existing initiatives. The inspectors reviewed this plan to determine the progress made by the licensee and to ensure that all commitments were appropriately addressed by this program.

i l b. Observations and Findings j The licensee committed to lasting corrective actions in their Nuclear Criticality Safety Program by establishing new initiatives or by making enhancements to l NMSS l cIS l

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I existing initiatives under the SMIP. The inspectors reviewed the SMIP and j

. , determined that it consists of eight key initiatives: 1) Enhance Interim Design Safety Basis; 2) Establish Final Design Safety Basis; 3) Enhance Management of Change; 4) Enhance Compliance Quality Assurance; 5) Enhance Recordkeeping and Document Control; 6) Enhance Reflection of License Requirements in Administrative and Operating Procedures; 7) Enhance Incident Management and Notification; and 8) Management Oversight and Control. The inspectors sampled several of these areas to determine progress made since the October 28,1997, enforcement conference.

SMIP Item 2-SS0100. Enhance Interim Design Safety Basis - The inspectors reviewed the SMIP Status report for this item ano determined that a subtask was identified to identify all geometry and volume centrolled components and field-verify that the as-built equipment matched the design basis. In addition, a subtask was initiated to verify all passive and active engineered controls matched the as-built condition and were functionally reliable and available.

The inspectors reviewed the evidence file for the field-verification of geometry and volume controlled components and completed a sarnple field-review to ensure that this action was adequately completed. Although the inspectors did not find any deficiencies with the equipment reviewed, they did determine that the team completed the field-verification on an individual or two-member basis and did not complete independent cross-checks of each others' work. Such method of review does not receive the benefit of the synergy and available diversity of the group l

effort. The inspectors also noted that several action items were identified by the review team and listed within the evidence file. However, such action items lacked ownership and subsequently were not tracked to completion. When this item was raised to the licensee, the action items were added to the plant's Commitment Tracking System (CTS) and assigned a responsible person.

Other subtasks under this initiative include collecting all Nuclear Criticality Safety Evaluations (NCSEs), Criticality Safety Analyses (CSAs), and Criticality Safety Evaluations (CSEs) into an indexed controlled file, conducting independent peer reviews of all completed CSAs/CSEs in accordance with SNM license requirements and related procedures, developing a documented and approved ,

j process for transition from CSAs/CSEs to ISAs as the facility design safety basis, l and developing a criticality safety manual. Although the inspectors did not l specifically review these subtask areas, all tasks were on schedule for completion by the committed dates. However, the inspectors noted that the last subtask will require revision to include the items missed under the immediate corrective actions discussed above. The licensee's progress on completing the corrective actions will  ;

I couinue to be monitored.

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SMIP Item 5-GN1100. Establish Ouality Assurance and Maintenance of Safetv-

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Related Controls - The inspectors reviewed the SMIP Status Report for this item and discussed the progress to date with responsible personnel. This initiative is a l follow on to the Design Safety Bases initiative and is intended to identify

preventive and mitigative controls relied upon for nuclear criticality safety and l appropriately classify each control as to its importance and assigned rigor related i to the required component reliability and availability. The licensee indicated that l following identification and categorization, the controls will be listed in  !

Regulatory Affairs Procedure RA-108 such that there is a one-to-one correspondence between the controls identined in CSAs/CSEs/ISAs and the associated procedures. The licensee indicated that they have identified eight tasks under this item and plan to complete the initiative by the fourth quarter of 1998 l using a technical team consisting of fourteen members. The inspectors pointed out that this item is also closely linked to the Management of Change process under j SMIP Initiative 5-GNO300 for identifying system, structures, and components (SSCs) important to safety and questioned the staff as to whether they considered l the interface of these two initiatives. Plant stalTindicated that the overall l integration of the SMIP initiatives was being reviewed and coordinated under  !

SMIP Initiative 5-GN0200, Management Oversight and Control. This item is 4 discussed later.

In further discussions, the inspectors questioned plant staff as to interim compensatory measures and/or progress in this area concerning appropriate measures to return plant process equipment to operable status following a process l upset and how the interaction of competing safety disciplines was handled. Plant staffindicated that, although the subtasks had not all been completed, the plant was ensuring that all safety-related incidents and plant changes were reviewed by the '

appropriate safety disciplines as they occurred. The inspectors reviewed the l internally-reported, problem tracking system (Red Book) to determine if an appropriate safety review was applied to the correction of recently reported plant deficiencies. The inspectors found that many of the items did not receive an appropriate, integrated review as indicated by plant staff and that NLS controls l were still not consistently recognized by operations and management personnel.

I For instance, l

l 1. ADU-0843,4/28/98, detailed a criticality safety control on the line 4 bucket l elevator that was apparently by-passed for health protection reasons without understanding its NCS importance and without the benefit of the change review process (discussed more fully in Section II);

2. ADU-0838,3/4/98, detailed a stop work order issued for health protection l reasons involving ammonium diuranate (ADU) that was being blown out from l

a boot on the line 2 elevator bucket during shift turnover, but did not receive l appropriate NCS notification and review; l

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3. ADU-0832,1/21/98, detailed discontinuation of the nitric acid source to the S-1008 Ammonia Scrubber resulting in loss of pH control (having NCS importance), but the system was allowed to continue operation without NCS notification and review; and

4. Just prior to the NRC on-site visit, two redundant N 2blowdown check valves on the Uranium Hexafluoride (UF.) vaporization chests for line 4 failed causing UF6gas to enter the N2 system, but NCS was not notified of this J condition.

Although Westinghouse has not completed all of the subtasks for identification and control of SSCs and NCS controls, it was not clear how effective this process will be once completed and it also was not clear that management oversight and control had been effectively applied to fully integrate the SMIP initiatives. Further,it did not appear that the plant has an effective interim program for clearly identifying 1 and managing NCS controls including the necessary level of rigor that must be  !

applied to ensure safety. The inspectors believe that the weaknesses identified m '

this area require close attention to ensure that all necessary aspects of this process j are considered and appropriately revised to ensure the desired effect. ,

l SMIP Item 5-GN0200. Management Oversight & Control - The inspectors reviewed the SMIP Status Report for this item and determined that three subtasks were identified for this item involving: 1) a determination that adequate mechanisms exist to provide oversight and control, and monitoring of progress toward completion of the prescribed initiatives, as well as other ongoing initiatives and regulatory commitments: 2) a review and evaluation of the effectiveness of the current organization structure and staffing relative to ongoing regulatory compliance initiatives, current workload, and assigned functional responsibilities; and 3) confirm the need, charter, and responsibilities for standing " process review teams," as appropriate.

For item one, the inspectors reviewed the Commitment Tracking System (CTS),

which is a fundamental tool relied upon by management to ensure committed actions are completed, and discussed the management of the system with the responsible plant staff. Such discussions indicated that the CTS did not appear to be prioritized as to safety and risk significant implications. Plant staff were unable to identify which tasks were the highest priority or whether tasks were divided appropriately among responsible personnel. In addition, it did not appear to have consistent post-closure effectiveness determinations and did not appear to have a reliable mechanism of notification for currently due items. Further discussions with the licensee indicated that consideration had been given to updating the system to provide management with a more effective tooi for eversight and control, but that no decision had been finalized.

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,%NM-I l 07 8 70-1151 % 202 In review ofitem 2 progress and adequacy, the inspectors reviewed documentation

, . which indicated that a total of 69 tasks were described under the various SMIP initiatives related to the NCS problems identified in NRC Inspection Report 97-205. Each of the SMIP initiatives had team members assigned ranging from five team members for the Design Safety Basis Initiative to nineteen team members assigned for the Compliance Quality Assurance SMIP initiative. However, the inspectors determined that many of the team members are the same for the majority of tasks and some team members are responsible for as many as  ;

20 concurrent tasks. The inspectors also noticed that the subtask number 2 identified above listed team members as "Ad lloc."

Although the plant has limited resources to accomplish the improvement in safety margin, it did not appear to the inspectors that adequate emphasis was placed on this subtask to ensure appropriate staffing and resource allocation to accomplish the corrective action commitments by the scheduled dates. The inspectors also raised concem that the large involvement of the NCS staffin completing these initiatives has resulted in much less floor time for these engineers which could impact the safety of plant operations.

Since weaknesses were identified in several of the SMIP items which are intended to address the long-term corrective actions for nuclear criticality safety at CNFD, the adequacy of SMIP item implementation related to NCS will be tracked as IFI 70-1151/98-202-02.

c. Conclusions The inspectors identified weaknesses in the implementation of SMIP initiatives 2-SS0100,5-GN1100, and 5-GN0200. Specifically, these included:

1) self-identification of additional weaknesses, but lack of ownership for review and closure of such items; 2) weak interim measures for identification and control of NCS controls and safety-related devices; and 3) weak management oversight and control measures to ensure full integration of SMIP initiatives, completion of SMIP items, and resource allocation management to ensure successful completion of committed tasks at an acceptable quality level.

The weaknesses involving safety margin improvements (i.e., items one and three above) should be viewed as areas requiring additional emphasis prior to the scheduled completion dates. The issue involving interim compensatory measures to ensure continued availability and reliability of NCS controls (i.e., item two above) must be addressed immediately. As such, the licensee committed to ensure NCS personnel review the process equipment upsets for criticality safety concems until such time as a permanent method of effective review and control can be accomplished.

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11. PLANT ACTIVITIES

a. Scope A general plant tour and fissile material area walkdown was completed to evaluate the objectives and characteristics of NCS field-verification reviews consistent with the established license conditions and commitments in the comprehensive NCS corrective actions plan. ,

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b. Observations and Findings The inspectors reviewed the Uranyl Nitrate (UN) bulk storage tanks, vaporization chests, and the ADU processing equipment. While reviewing the UN bulk storage l tanks, the licensee indicated that the tanks and storage area had been fully walked down and field verified per the expectations of the corrective action plan. However, when the NRC inspectors questioned the discharge location of a favorable geometry sump pump located within the dyked area, plant personnel were not immediately able )

to respond. The inspectors questioned how processing equipment could be thoroughly field-verified without knowing the discharge location of the equipment. The licensee indicated that they had not considered the sump from that aspect since i: was of favorable geometry and had a manually-operated valve which, in their opinion, would stop the operator from transferring the material until the appropriate safety personnel were notified. The licensee later determined the location of the discharge point and notified the inspectors that the exit iocation was adequately analyzed for fissile streams from an unexpected process upset.

It is interesting to note that a problem report was issued on April 4,1998 (WR&D-200) involving a situation where the UN Tanks did not have recirculadon for several hours. As a result, there was no gamma monitoring of the tank contents during this period.- The absence of the pump recirculation was discovered by. operators and the pumps were restarted. The fault tree showed two redundant on-line gamma monitors supporting the system, but both were rendered inoperative by one action. In addition, it was unanticipated that following a planned power shutdown, that the pumps would not automatically restart, but would require a manual reset. Field-verification reviews of controls and barriers to prevent criticality safety should be thoroughly reviewed to ensure that they remain reliable and available as necessary during all plant operability modes. These two issues bring into question the effectiveness and thoroughness of the licensee's field-verification reviews. Ilowever, rather than being cited separately, this issue is identified as another example ofIFI 70-1151/9F "?-01 While field reviewing the vaporization chests, ths av .,, - .. ed that one of the l vaporization chests was roped off and questionc ..e .w - r this action. It was learned that UF,, had backflowed into the nitrogr Hov.wn system for this line. The inspectors questioned why two block valv-+ w ~, ,ed for redundancy on such NMSS iCis

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a system and learned that two block valves were indeed installed on the system, but that the UF6bypassed both valves. The inspectors questioned the generic implications of defective parts since it is unlikely that both valves would fail at the same time from corrosion-induced fatigue. The inspectors also questioned whether there were any l NCS concems with such a failure. The licensee NCS staffindicated that he was not aware of the problem until now and that he only sees problems that are identified as NCS significant in the plant's Red Book tracking system. Further discussions indicated that the NCS department previously resiewed all Red Book items for NCS applicability, but management discontinued this practice to ensure that the NCS staff could meet the commitment dates of the corrective action plan and ISA development schedule. The inspectors were concerned that such actions may degrade the NCS safety of plant operations, because the staff personnel charged with determining applicability may not have the necessary NCS skills to make such a detennination.

The licensee staff took this issue under consideration and also committed to inspect the other UF6 lines to ensure that similar defects in the nitrogen blowdown check valves were not evident.

During the review and discussion of the ADU processing equipment, it was noted that 1 a non-favorable geometry (NFG) enclosure was in place around the bottom of the elevator feed to the calciner. The NRC inspectors questioned whether backflow of moderator or material to the enclosure was possible. Westinghouse staffindicated that i a passive overflow was installed on the front of the enclosure to prevent excessive solution accumulation. Ilowever, it was discovered that this passive overflow had been duct-taped shut by o, rations personnel. Upon discovery, plant staff immediately removed the tape and questioned the operators concerning this issue. l Operators indicated that the tape was placed on the enclosure for health protection (IIP) reasons and that they didn't think this was a concern since the enclosure was not  ;

air tight anyway. The inspectors questioned how an operator would know that 'he opening was a criticality control since no sign was located there to indicate its '

function. Westinghouse staffindicated that such guidance is provided as part of the ,

NCS training received by all plant personnel, and therefore, a sign was unnecessary.

The licensee also stated that modifications to line four were made to remove the NFG enclosure and that modifications to the remaining lines were scheduled to occur over '

the next two years.

Upon fm'her plant review to ensure the remaining lines had operable overflow lines installed, the inspectors noticed numerous pieces of equipment that had been taped due to airborne contamination concerns. Although the inspectors did not identify any other equipment taped shut that had NCS significance, the excessive use of tape within the facility and the apparent lack of communication between the IIP organization and the NCS staff was of concern. Westinghouse staffindicated that they were committed to majorly revising the configuration management control program to clearly identify NCS controls and to more appropriately integrate the various safety functions reducing the hazard of competing safety disciplines. Since this upgrade was initiated in suss icis A

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, SNM 1107 11 70 1151 % -202 January 1998, it is pre-mature to make a final determination on its effectiveness.

, Therefore, the effectiveness of the CM program to adequately support the NCS function is identified as IFl 70-1151/98-202-03. Also, although the inspectors believed the inoperable status of the passive overflow was reportable under license requirements as a loss of NCS control, plant personnel indicated that this control was a defense-in-depth control and not of a primary nature. The inspectors reviewed the supporting evidence and concurred that under the current documentation, this item was not a primary control.

Finally, the inspectors field reviewed the 1008 Ammonia Scrubber and questioned how plant personnel verified the differential pressure (DP) gauges used for NCS control were operable since both gauge readings were below the zero mark. Licensee staffindicated that they believed the signal was transmitted to the local area control room which is continuously manned. The inspectors and licensee staff discussed this assumption with the local area control room supervisor and discovered that the signal does not transmit to this station. Licensee staff then indicated that they needed to 4 review the situation before discussing it further with the inspectors. It was later determined that the gauges had been removed from service some time in the past following modifications to the equipment, but that the NCS evaluation was not revised and approved for this change. However, the licensee indicated that the equipment does not process production quantities of SNM, but is designed as an air scrubber to meet environmental release standards. Although the equipment does contain some amount of SNM, it typically only contains 20 ppm. In addition, a revised evaluation had been prepared under the ISA upgrade and was recently approved such that the equipment no longer relied upon the DP gauges for criticality control. Nevertheless, the inspectors pointed out that the equipment operated from May 8,1997 to March 31,1998 with an inoperable NCS control and plant personnel were unaware of this condition until it was brought to their attention by the NRC inspectors. Further, it raises concern over the assumptions expressed to the NRC during the pre-decisional enforcement conference concerning the interim safety of plant operations during the time that NCS corrective actions are being implemented.

Condition S-1 of Special Nuclear Materials License No. SNM-1107, Authorized Use, requires use oflicensed materials in accordance with statements, representations, and conditions in the License Application dated April 30,1995, and supplements dated May 11,18; August 4,25; and September 25,1995; and July 25 and August 11, 1997. Section 6.2.1, General Control Program Practices, states, in part, that "for each significant portion of the process, a defense of one or more system parameters will be employed and documented within the Nuclear Criticality Safety Evaluation . . Prior to use in any process, nuclear criticality safety controls will be verified against design criteria, A program for routine maintenance and testing will assure continued compliance."

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+ . sNM-Il07 12 70-I l51N8-202 Contrary to the above, as of April 30.1998, continued compliance was not assured for

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. a nuclear criticality safety control as employed and documented within a nuclear l criticality safety evaluation, in that, the 1008 Ammonia Scrubber was operated since May 1997 with an inoperable nuclear criticality safety control. This is identified as Violation (VIO) 70-1151/98-202-04.

j c. Conclusions The inspectors detennined that management and stafThave been weak in measures needed to improve control over safety-significant items in the area of nuclear criticality safety. The corrective action plan has been taking resources away from NCS floor support such that improvements in controlling safety will be more difficult to attain until the corrective action plan is completed.

ITEMS OPENED. CLOSED. AND DISCUSSFR Opened IFl 70-1151/98-202-01 Development of adequate and effective independent NCS review methodology.

IFl 70-1151/98-202-02 Adequacy of SMIP item implementation related to NCS.

IFI 70-1151/98-202-03 Effectiveness of the CM Program to adequately support and implement the NCS function.

VIO 70-1151/98-202-04 Operation of the 1008 Ammonia Scrubber with an inoperable nuclear criticality safety control.

Closed No NRC-identified issues were closed during this inspection.

MANAGEMENT MEETINGS Exit Meeting Summary The NRC Inspection Team met with Westinghouse CNFD management throughout the inspection. An exit meeting was held on May 1,1998. The violation involving the 1008 Ammonia Scrubber was discussed with management. Westinghouse management acknowledged l the violation as stated, but had trouble understanding the significance since this equipment normally does not process production quantities of fissile material. Westinghouse management NMSS ICIS

+ -

,sNM 107 O To.u n w.202 l

l also agreed with the weaknesses identified by the inspectors in the NCS corrective action plan

. , and indicated that management would continue to strive in improving the safety margin at the CNFD. No classified or proprietary information was identified. The following is a partial list of exit meeting attendees:

Westinghouse CNFD '

1 Jack Allen, Plant Manager Jim liesth, Regulatory Engineering & Operations Manager ,

Wilbur Goodwin, Regulatory Affairs Manager Robert Williams, Regulatory Affairs Advisory Engineer l Norman Kent, Senior NCS Engineer Tommy Shannon, Regulatory Affairs Technician Jim Bush, Manufacturing Manager Nuclear Regulatory Commission Jack Davis, Nuclear Criticality Safety, NRC IIcadquarters Doug Outlaw, Consultant, SAIC ACRONYMS USED ADU.. . .. .... ........ . .... .. .. ...... .. Ammonium Diuranate ANSI /ANS . . . . . . . . . . . . . . American National Standards Institute /American Nuclear Society CNFD....................... .. .. . .. . . Commercial Nuclear Fuel Division CSA .. ..... ...... ........ .. . ... . ... . .. . Criticality Safety Approval CSE.. . .. ...... ..................... . .. . .. . Criticality Safety Evaluation CTS ..... ...... .............. ...... .. ..... . Commitment Tracking System DP.......................... .. ...... ... . . ... Differential Pressure IIP . ................ .. .. . . . .. .. ... ..... .. IIealth Protection IFI.. . .. ......... ... ..... . . ..... ......... . . Inspector Followup item ISA . . . . ................ . .... ........... . . . . . . . . Integrated Safety Analysis N 2 ...................... ... .... ... .. .... .. . ....... ... Nitrogen NCS.................................. .. . . Nuclear Criticality Safety NCSE ,. .. .... ....... ..... ...... . . . . . . . Nuclear Criticality Safety Evaluation NFG ..... ....... ..... ........ .. . .. ... .. . . Non-Favorable Geometry NRC............................ . .... . . . . . . Nuclear Regulatory Commission PPM....................... ... ... .. .... .. . . . . . . . . . . Parts Per Million SMIP ....... ... ... . ........ . . . . . . . . . Safety Margin Improvement Program l SNM . .... . . .. ... . . ...... ... . . . Special Nuclear Materials l SSC . ... . ................ ......... System, Structures, and Components UF6 . . . . .. .. . ... ... .. ... . .. .. . . . Uranium Ilexafluoride UN........................... .... . ....... . . . Uranyl Nitrate VIO . ... .................. . .. . . . . ......... . . . Violation suss icis

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