ML21298A181

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Fuel Fabrication Facility Integrated Inspection Report 07001151/2021003
ML21298A181
Person / Time
Site: Westinghouse
Issue date: 10/25/2021
From: Eric Michel
Division of Nuclear Materials Safety II
To: Annacone M
Westinghouse
References
IR 2021003
Download: ML21298A181 (14)
v • d • e


Text

October 25, 2021 Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061

SUBJECT:

COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2021003

Dear Mr. Annacone:

On July 29, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Fuel Fabrication Facility. On July 29, 2021, the NRC inspectors discussed the results of this inspection with you and other members of your staff. The results of this inspection are documented in the enclosed report.

No violations of more than minor significance were identified during this inspection.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Docket No. 07001151 License No. SNM-1107

Enclosure:

As stated cc w/ encl: Distribution via LISTSERV

ML21298A181 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME P. Startz T. Sippel E. Michel DATE 10/15/21 10/15/21 10/25/2021 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2021003 Enterprise Identifier: I-2021-003-0117 Licensee: Westinghouse Electric Company Facility: Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: July 26, 2021 to July 29, 2021 Inspectors: T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.

List of Violations No violations of more than minor significance were identified.

Additional Tracking Items None.

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PLANT STATUS The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricated fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing.

INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

SAFETY OPERATIONS 88015 - Nuclear Criticality Safety The inspectors evaluated selected aspects of the licensees Nuclear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, including 70.61, and 70.62, Chapter 6.0, Nuclear Criticality Safety (NCS) Program, of the facilitys license application, and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3, 6.1.4, 6.1.5.2, and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed CSEs for scrubbers as described below:

  • CSE-1-G, "Criticality Safety Evaluation (CSE) for Acid Scrubber S-2A/2B,"

Rev. 13, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences. The inspectors walked down the S2A2B scrubber and other scrubbers that may be exposed to enriched uranium with licensee NCS engineers. The requirements and technical basis for IROFS that were established to prevent criticality accidents.

  • CN-CRI-09-11, "S-2A/2B System (With Concrete Walls Near Sump Tanks),"

Rev. 2, which was reviewed because it contained a variety of calculations and information supporting the licensee's evaluation of criticality accident sequences and IROFS in CSE-1-G.

  • The inspectors interviewed licensee NCS engineers and the NCS manager about the review, approval, and implementation of CSEs and other NCS documentation. The inspectors interviewed licensee NCS staff about validation and the use of computer codes in the licensee's criticality safety program.

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Criticality Implementation (IP Section 02.02)

The inspectors selected engineered and administrative controls from the licensees integrated safety analysis (ISA) summary to verify proper implementation through a review of process and system descriptions, drawings, plant walkdowns, and operator interviews to verify compliance with 10 CFR 70 and applicable sections of the license application, including, 6.1.2, 6.1.3. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the CSE listed above:

  • IROFS VENT-S2A2B-103, -106, and -122 which are passive IROFS preventing solutions from overflowing/backflowing into unfavorable geometries. The inspectors walked down these controls in the field to verify their presence and condition, and reviewed drawings and maintenance records.
  • IROFS VENT-S2A2B-116, -117, and -118 which are passive IROFS controlling the credited geometry, absorption, and reflection properties of the scrubber sump. The inspectors walked down these control in the field to verify their presence and condition and reviewed maintenance records.
  • IROFS ADUSCRA-147 and VENT-S2A2B-131 which are credited as active and passive IROFS to prevent backflow. The inspectors walked down these controls in the field, reviewed drawings and maintenance records.
  • IROFS VENT-S2A2B-107 and -108 which are administrative IROFS to prevent foreign objects from causing blockages in the scrubber. The inspectors walked down portions of these controls and reviewed procedures and maintenance records.
  • IROFS VENT-S2A2B-109 which is an administrative IROFS to perform a routine inspection and cleanout. The inspectors reviewed maintenance records and condition reports.
  • IROFS VENT-S2A2B-110 and -124 which are administrative IROFS controlling concentration in the scrubber sump through routine sampling, the inspectors walked down the lab that processes the samples, interviewed lab personnel, and reviewed procedures and sample results.
  • IROFS VENT-901 which is an administrative IROFS that limits mass accumulations through routine gamma surveys of selected ductwork; the inspectors also interviewed licensee staff and reviewed applicable procedures, survey records, and related drawings.

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant operators, procedures, and operations of systems involving special nuclear material to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors performed the following activities:

  • Reviewed TRN-001-2, "Rad Protection Criticality Safety SSCs Safeguards,"

which is NCS training that covers types of controls, IROFS, postings, the double contingency principle, the consequences of a criticality and other NCS topics.

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  • Reviewed Criticality & Radiation Safety NSQT, dated September 30, 2020, which is NCS training that covers criticality control parameters, past accidents and other NCS topics.
  • Observed a licensee NCS engineer conduct a weekly Facility Walkthrough Assessment (FWA) in the Scrap Cage area and reviewed the FWA schedule and FWA records for 2021.

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and NCS staff qualification records to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.3.3, and 6.1.10. Specifically, the inspectors interviewed licensee NCS staff, reviewed the following documents, and conducted a walkdown as described below:

  • COP-815023, "S-2A and S-2B Inspection and Clean Out," Rev. 4, which provides instructions for the periodic inspection and cleanout of the inside of scrubber system components and includes the implementation of IROFS VENT-S2A2B-108, -109, -111.
  • Various WOs related to the surveying, inspecting, and cleaning ductwork and scrubber systems (e.g., WO 874993).
  • COP-814325, "Scrubbers 2A & 2B," Rev. 31, which includes instructions for taking the IROFS VENT-S2A2B-110 and -124 concentration samples of the scrubber sump water.
  • RAF-125-5, "Nuclear Criticality Safety Engineer Training Checklist," dated March 30, 2021, which documented the training and qualification of a recently qualified licensee NCS engineer.
  • The inspectors also walked down the laboratory where the scrubber sump samples are analyzed for uranium concentration and interviewed lab personnel.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident alarm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.8. Specifically, the inspectors reviewed documents, and/or interviewed licensee staff concerning the following:

  • NCS-related corrective action records, including IR-2021-2474, IR-2021-3870, IR-2021-4738, IR-2021-4957, and IR-2021-5048
  • the evaluation and use of portable criticality detection devices RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities program to determine whether the licensee has established and is maintaining an effective, management-5

controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable Nuclear Regulatory Commission 10 CFR Parts 20 and 71 regulations and Department of Transportation (DOT) (49 CFR Parts 171-178) transport regulations.

The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with the regulations above. Specifically, the inspectors reviewed or observed the following:

  • receipt contamination surveys, physical inspections, and off-loading of full 30B cylinders from their UX-30s (overpacks) and placement into a UF6 storage yard
  • inspection/removal of tamper indicating devices (seals) from UX-30 overpacks
  • removal of the UX-30 overpack lids
  • receipt, inspections, and off-loading of incoming LR-230 uranyl nitrate hexahydrate (UNH) contents
  • shipment of three truckloads of fuel assembly traveller shipping packages Preparation of Packages for Shipment (IP Section 02.01)

The inspectors examined the licensees procedures and package preparations to verify compliance with the Chapter 3 of the License Application. Specifically, the inspectors reviewed, verified, and observed the following:

  • traveller package refurbishment bay including spare parts, procedures, and calibrated tooling
  • ongoing preparations of a traveller package
  • Nuclear Material Transaction form 741 for Manifest 52-2140933
  • Nuclear Material Transaction form 741 for Manifest WS-53455-0-149
  • TR-501 Shipment of Liquid Low Enriched Uranium, Rev. 7 Delivery of Completed Packages to Carriers (IP Section 02.02)

The inspectors examined the licensees procedures and shipment records and observed actual transport activities to determine that the licensee met package delivery regulations and Chapter 3 of the License Application. Specifically, the inspectors reviewed or observed the following:

  • Shipping Manifest WS-53457-0-001, shipment of LSA-1 waste materials
  • Shipping Manifest ISEU (000001-219 through 000023-221), shipment of LSA-1 waste materials
  • Shipping Manifest ISEU (000012-229 through 000039-232), shipment of LSA-1 waste materials 6

Receipt of Packages (IP Section 02.03)

The inspectors examined the licensees procedures to verify compliance with 10 CFR 20.1906 and Chapter 3 of the License Application. Specifically, the inspectors reviewed the following:

  • COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers"
  • CF-83-239, "LR-230 Offload Checklist"
  • TR-300, "Unload UF6 Cylinders" Records and Reports (IP Section 02.04)

The inspectors examined the licensees recordkeeping and reports to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:

  • Certificate of Disposal, Receipt LSA-1 waste for disposal, dated March 3, 2021
  • Certificate of Disposal, Receipt LSA-1 waste for disposal, dated March 14, 2021 General License Requirements (IP Section 02.05)

The inspectors reviewed licensee package certifications utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C, and Chapter 3 of the License Application. Specifically, the inspectors reviewed:

  • Certificate of Compliance No. 9291 for the LR-230 container
  • Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34
  • Model 30B Certification Type AF Fissile Package Design Certificate USA/0411/AF-96, Rev. 12 Management Controls (IP Section 02.06)

The inspectors reviewed management controls for transportation activities to verify compliance with Chapter 3 of the License Application. Specifically, the inspectors reviewed:

  • COLUMN MC&A Software Guide, Form 741, Domestic UF6 Gas Receipts
  • LCTP-20-06, "Management Assessment of the LR-230 Packaging," Rev. 0, dated December 21, 2020
  • LCPT-21-02, "Management Assessment of the Traveller Packaging," Rev. 0, dated March 30, 21
  • LCTP-21-04,"Management assessment of UF6 incident during transport,"

Rev. 0, dated June 2, 2021 Indoctrination and Training Program (IP Section 02.07)

The inspectors conducted interviews, reviewed training, and indoctrination documentation, and observed activities for shipping container engineering staff involved in transport 7

activities to verify compliance with Chapter 3 of the License Application. Specifically, the inspectors:

  • reviewed ESH-015 DOT Radioactive Materials training records, classroom training required every three years, for employees 4889 and 30696 Quality Assurance Program (IP Section 02.08)

The inspectors reviewed the quality assurance documents to verify compliance with 10 CFR 71.137 and Chapter 3 of the License Application. Specifically, the inspectors reviewed:

  • COP-831010, "Shipping Low Level Radioactive Waste," Rev. 33, dated May 14, 2020
  • LCPT-21-02, "Nuclear Fuel Transport assessment"
  • LCPT-20-06, "Management assessment of the LR-230 packaging" Audit Program (IP Section 02.09)

The inspectors reviewed the assessment reports to verify compliance with 10 CFR 71.137 and Chapter 11 of the license. Specifically, the inspectors reviewed:

  • LCPT- 21-04, Management assessment of UF6 incident during transport
  • Incident Report 2020-4142
  • Incident Report 2020-11489 Procurement and Selection of Packagings (IP Section 02.10)

The inspectors examined the licensees recent purchase of new Traveller packages to verify compliance with the federal regulations above. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors reviewed the following:

  • Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Assembly,"

Rev. 8, dated November 5, 2019

  • Sketch 938603-22, "Traveller Shipping Container," Rev. 11, issued August 10, 2017 Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings and documentation to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed:

  • MOP-500153, "Pack and Unpack Fuel Assembly - traveler package," Rev. 3, dated July 30, 2020
  • MOP-730753, "Pack Fuel Assembly - traveler package," Rev. 54, dated May 13, 2021 8

Periodic Maintenance of Packagings (IP Section 02.12)

The inspectors examined the licensees procedures and ongoing refurbishment activities to verify compliance with applicable parts of the federal regulations above. Specifically, the inspectors reviewed the following:

  • Drawing 10043E83, sheet 1, "Traveller STD Upgrade General Assembly,"

Rev. 8, dated November 5, 2019

  • Traveller Refurbishment Verification Checklist, Package Serial Number TX-200, completed June 12, 2021
  • TR-229, "Traveller Recertification," Rev. 2, dated June 21, 2021 Records, Reports, and Notifications (IP Section 02.13)

The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the federal regulations above. Specifically, the inspectors reviewed the following:

  • 938603-22, "Traveller Shipping Container Checklist"
  • Licensee Investigation Report 2020-13034, "LR-230 discovered package defect," dated November 12, 2020
  • Licensee Investigation Report 2020-4142, "LR-230 tamper seal discovered to be improperly applied," dated March 26, 2020
  • Licensee Investigation Report 2021-1944, "MCC container discovered cracked during preparation for loading," dated February 16, 2021 INSPECTION RESULTS No issues were identified.

EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.

  • On July 29, 2021, the inspectors presented the integrated inspection results to Mike Annacone and other members of the licensee staff.

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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 86740 Drawings Drawing Traveller STD Upgrade General Assembly Rev. 8 10043E83, sheet 1 of 3 Miscellaneous ESH-015 DOT Radioactive Materials (classroom training), three years, 11/9/2020 completions for #30696 and 4889 on 11/9/2020 Procedures Form 741 COLUMN MC&A Software Guide for Form 741, Domestic UF6 Gas Receipts CF-83-239 Offload Checklist Rev. 5 COP-831010 Shipping Low Level Radioactive Waste Rev. 33 COP-836047 Uranyl Nitrate Offloading from LR-230 Containers Rev. 22 MOP-730753 Pack Fuel Assembly - traveler package Rev. 54 NOP-500153 Pack and Unpack Fuel Assembly - traveler package Rev. 3 Sketch 938603- Traveller Shipping Container Inspection Checklist Rev. 11 22 Assessment, Management assessment of the LR-230 packaging, performed 12/21/2020 TR-224 Refurbish Traveller Shipping Package Rev. 23 TR-229 Traveller Recertification Rev. 2 Traveller Package Serial Number TX-200, completed 6/12/2021 6/12/2021 Refurbishment Verification Checklist 88015 Corrective Action IR-2021-2474, IR- A sample of various NCS related corrective action records.

Documents 2021-3870, IR-2021-4738, IR-2021-4739, IR-2021-4957, IR-2021-5048, IR-2021-5141, IR-2021-5481, IR-2021-7327 Drawings 313F01HV07 Process Ventilation System Scrubbers S-2A/2B Isometric Rev. 9 Sheet 01 10

Inspection Type Designation Description or Title Revision or Procedure Date 313F01PI01 Piping Flow Diagram - Scrubbers S-2A & S-2B Rev. 18 Sheet 01 313F01PI02 Process Ventilation Flow Diagram Scrubbers S-2A & S-2B Rev. 25 Sheet 03 313F01PI02 Process Ventilation Filters 1A and 1B P&ID Rev. 18 Sheet 04 Engineering NSA-TR-08-27 Using Electronic Dosimeters as Alarming Personal Criticality 12/2/08 Evaluations Detectors at Westinghouse Facilities Miscellaneous 2021 FWA Schedule Criticality & Radiation Safety NSQT 9/30/20 PSEDoc-0004972 Results from startup testing for FN-962 for CCF 17-493 Rev. 0 PSEDoc-0005351 Results from startup testing of FN-961 for CCF 17-531 Rev. 0 TRN-001-2 Rad Protection Criticality Safety SSCs Safeguards Procedures CA-220 Safety Basis Qualification Training Rev. 12 CAP-815023 S-2A and S-2B Inspection and Clean Out Rev. 4 CN-CRI-003 NCS Manual Rev. 3 COCL-M14 Use of Agilent 7800 for TMI and PPM U Analysis Rev. 4 COP-814325 Scrubbers 2A & 2B Rev. 31 RA-303 Controls of Moderating Materials for Nuclear Criticality Safety Rev. 19 RA-305 Nuclear Criticality Safety Computer Code Validation Rev. 11 RA-313 Criticality Safety Evaluations (CSEs) Rev. 16 RA-314 Implementation of Criticality Safety Evaluations Rev. 20 Radiation ROF-05-062-7, Ventilations Systems Equipment Radiation Survey Monthly - 6/21/21, Surveys ROF-05-062-7, S-1030 Survey, 7/23/21, ROF-05-062-8, Ventilations Systems Equipment Radiation Survey Monthly - 6/21/21, ROF-05-062-8, S-1030 Survey, 7/23/21, ROF-05-062-11 Ventilations Systems Equipment Radiation Survey Monthly - 6/6/21 S-2A/2B Survey, Ventilations Systems Equipment Radiation Survey Monthly -

S-2A/2B Survey, Ventilations Systems Equipment Radiation Survey Quarterly

- S-958 Survey Self-Assessments RAF-316-1 Various Nuclear Criticality Safety Checklist for NCS Facility Various Walkthrough Assessments for various areas in the first and Dates 11

Inspection Type Designation Description or Title Revision or Procedure Date second quarter of 2021 Work Orders 38975 52 Week OM81233 SI-Safety, S2A/2B Vacuum Breaks and Completed Overflow Piping 4/30/21 38976 52 Weeks OM818809 SI-Safety, S2A and S2B Scrubbers Completed Cleaning and Inspection 4/20/21 39160 52 Weeks PM81151 SI-Safety, Spring to Close Air Blowdown Completed Valve Replacement on S2A2B Bag Filters 4/19/21 4507 52 Weeks PM81155 SI-Safety, S2A2B Bag Filter Blowdown Completed Back Flow Preventer Ball Valve Leak Check 9/25/20 47230 13 Weeks OM91115 SI-Safety - Gamma Surveys of Completed Ventilation Systems 6//9/21 47341 13 Weeks OM81262 SI-Safety, S2A/2B Filter Instrument Air Completed Spring Return Valves 6/23/21 49609 4 Weeks (Monthly) OM81806 SI-Safety, S2A and S2B Completed Uranium Concentration Samples 7/2/21 54052 4 Weeks (Monthly) OM91009 SI-Safety, HP Ventilation Completed Survey 7/23/21 WO 874988 OM81233 SI-Safety, S2A/2B Vacuum Breaks and Overflow Completed Piping - 52 Weeks OM 4/27/20 WO 874992 OM 818809 SI-Safety, S2A and S2B Scrubbers Cleaning Completed and Inspection - 52 Week OM 4/27/20 WO 891490 SI-Safety, Instrument Air Shut-Off Valve for Air to S2A2B Bag Filter Blowdowns - 52 Week OM 12

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