ML22012A238
| ML22012A238 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 01/14/2022 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Annacone M Westinghouse |
| References | |
| IR 2021004 | |
| Download: ML22012A238 (14) | |
Text
January 14, 2022 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 07001151/2021004
Dear Mr. Annacone:
This letter refers to the Nuclear Regulatory Commission (NRC) inspection oversight activities conducted from October 1 to December 31, 2021 for the Columbia Fuel Fabrication Facility. On October 8 and November 19, 2021, the NRC inspectors discussed the results of two inspections during this period with you and other members of your staff. The results of these inspections are documented in the enclosed report.
No violations of more than minor significance were identified during this period.
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, 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 Signed by Michel, Eric on 01/14/22
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 NAME N. Peterka E. Michel T. Vukovinsky DATE 1/12/2022 1/14/2022 1/12/2022
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001151 License Number:
SNM-1107 Report Number:
07001151/2021004 Enterprise Identifier:
I-2021-004-0129 Licensee:
Westinghouse Electric Company Facility:
Columbia Fuel Fabrication Facility Location:
Hopkins, SC Inspection Dates:
October 04, 2021 to November 19, 2021 Inspectors:
B. Adkins, Sr. Fuel Facility Projects Inspector N. Pitoniak, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector T. Vukovinsky, Sr. Fuel Facility Project Inspector R. Womack, Fuel Facility Inspector Approved By:
Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection
2
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 Type Issue Number Title Report Section Status WER 07001151/2021-001-00 24 Hour Report - Unplanned Medical Treatment (EN 55412) 88072 Closed
3 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 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 CFR 70, including 70.24, 70.61, 70.62, and Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.
Identification of Safety Controls and Related Programs (IP Section 02.01)
The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety, fire safety, and chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
accident sequence 4.1.1.3, lines 1-4 ADU conversion area cylinder loss of containment, initiating event 1, high vaporizer steam
accident sequence 4.1.1.3, lines 1-4 ADU conversion area cylinder loss of containment, initiating event 3, defect in cylinder valve
accident sequence 4.1.1.3, lines 1-4 ADU conversion area cylinder loss of containment, initiating event 5, overfilled (overweight) cylinder received
accident sequence 4.1.1.3, lines 1-4 ADU conversion area cylinder loss of containment, initiating event 6, overweight cylinder produced
accident sequence 4.1.1.7, ADU conversion area loss of containment of hot oil leading to potential fire in the hot oil room
4 Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
ADUHOS-907, hot oil system 3 and 4 structural integrity, chemical/fire safety, passive engineered control
ADUFIRE-901, fire protection program combustible control, criticality/fire safety, administrative control
ADUVAP-111, UF6 delivery line block valve (outside vaporizer, but beyond PIT-S-x01-A/B/C-2) shall be closed and the cylinder valve opened prior to cylinder heating, chemical safety, administrative control, criticality/chemical/fire safety
ADUVAP-902, vaporizer pressure relief valve, criticality/chemical/fire safety, active engineered control
ADUVAP-903, vaporizer high pressure steam interlock, criticality/chemical/fire safety, active engineered control
ADUVAP-906, vaporizer high interlock, criticality/radiation safety, active engineered control
ADUVAP-907, vaporizer high-high Interlock, criticality/radiation safety, active engineered control
ADUVAP-909, UF6 cylinder high pressure interlock, criticality/chemical/fire safety, active engineered control
ADUVAP-911, failure of 1st weight verification, criticality/chemical/fire safety, administrative control with computer/alarm assist
ADUVAP-912, failure of 2nd weight verification, criticality/chemical/fire safety, administrative control with computer/alarm assist
ADUVAP-920, visually inspect cylinder valve, criticality/chemical/fire safety, administrative control
ADUVAP-921, visually inspect external parts of cylinder, criticality/chemical/fire safety, administrative control
ADUVAP-933, valve isolation between hot and cold cylinders, criticality/chemical/fire safety, passive engineered control
ADUVAP-934, vaporizer block valve and UF6 block valve, criticality/chemical/fire safety, administrative control Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The
5 inspectors conducted the following activities to verify the implementation of selected safety controls:
observed the annual surveillance test of the Line 2 vaporizer hi and hi-hi level interlocks associated with IROFS ADUVAP-906 and ADUVAP-907 (COP-815417)
reviewed mechanical integrity inspection records and conducted a system walkdown of IROFS ADUHOS-907, hot oil system 3 & 4 structural integrity
reviewed inspection records and observed nameplate pressure rating/lock wire installation for line 2 vaporizer pressure relief valve (ADUVAP-902)
reviewed procedures COP-810094, COP-810096 through COP-810099, COP-814604, and COP-816020 associated with IROFS ADUVAP-906, ADUVAP-907, ADUVAP-920, and ADUVAP-921
observed operations perform heel cylinder and pigtail removal, new cylinder weighing, and new cylinder installation in the line 3 vaporizer. The following IROFS were observed: ADUVAP-912, ADUVAP-914, ADUVAP-918, ADUVAP-919, ADUVAP-920, and ADUVAP-922 Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors conducted the following:
reviewed the following CAP entries associated with failed/degraded IROFS:
2021-4738, 2021-4739, 2021-6912, 2021-7140, 2021-8809, and 2021-6144
reviewed the last four quarterly Nuclear Criticality Safety Facility Walkthrough Assessments for the Conversion area
reviewed the most recent use of SYP-300-2, "Housekeeping Inspection," in the Hot Oil Room
reviewed operator training/qualification for two conversion area operators
reviewed the conversion area organizational chart FACILITY SUPPORT 88072 - Plant Modifications (Triennial)
The inspectors conducted an extensive review into the licensees configuration management system for plant modifications to ensure that safety-related systems and components (i.e.,
IROFS or credited safety controls) could adequately perform their intended safety function and that system changes had not adversely impacted plant safety and operability. The inspectors review focused on verifying compliance with the applicable requirements in 10 Code of Federal Regulations (CFR 70), License Application, Chapter 3, "Conduct of Operations," and Integrated Safety Analysis (ISA) Chapter 13, "Low Level Radioactive Waste System."
Selection of Modifications (IP Section 02.01)
6 The inspection team leader reviewed licensing documents and coordinated with the licensee to discuss plant modifications in risk-significant areas/processes with the licensee. The inspectors selected the following process for an in-depth review of historical modifications identified as Configuration Control Forms (CCF).
Incinerator System (ISA-13, Low Level Radioactive Waste System)
CCF 06392, Scrubber Liquid Recirculation Loop
CCF 06488, FN-949 Drain Hole
CCF 06542, Incinerator Sump Emergency Drain Size Increase
CCF 12155, Tie-in for Incinerator BFP and Area Contaminated Drain Inputs
CCF 16159, Modifications to Incinerator Ram Controls and Safety System Upgrades
CCF 05120, Incinerator Safety PLC
CCF 09339, Incinerator/ABF Torit Level Probe
CCF 06610, PLC Level Probe Input
CCF 06605, Incinerator PLC Fault
CCF 05361, Incinerator Mass Control
CCF 16178, Install drain line in incinerator duct just prior to "C" demister
CCF 17494, Demolition of Incinerator System 6A Ventilation
CCF 17495, 6A Incinerator Ventilation System Design Process Review (IP Section 02.02)
For the selected modifications listed above, the inspectors reviewed the design process to verify the licensee followed the applicable configuration management requirements in the license application and 10 CFR 70. Specifically, the inspectors conducted the inspection activities listed below:
Interviewed licensee staff, performed walk-downs, and reviewed configuration management packages and supporting documentation to verify that plant modifications were developed, reviewed, classified, approved, and implemented in accordance with 10 CFR 70.72, Facility Changes and Change Process, and 70.62(d), Management Measures.
Interviewed licensee staff, performed walk-downs, and reviewed the ISA, ISA Summary, and safety program information impacted by the modifications to verify compliance with 10 CFR 70.62, 10 CFR 70.72, and the baseline design criteria of 10 CFR 70.64, as applicable.
Interviewed licensee staff, performed walk-downs, and reviewed configuration management packages and supporting documentation to verify that safety systems and components impacted by the modification, including interactions with other systems, would perform their intended safety function as described in the ISA and safety program documentation.
Interviewed licensee staff, performed walk-downs, and reviewed design information for the selected modifications to verify that design assumptions, including Natural Phenomena Hazards (NPH) analysis and set points for instrumentation and control equipment, were supported by adequate technical basis consistent with the design bases and licensing bases of the facility.
Interviewed licensee staff, performed walk-downs, and reviewed documentation to verify the licensee applied management measures to the
7 IROFS affected by the modifications in accordance with 10 CFR 70.62
Interviewed licensee staff, performed walk-downs, and reviewed corrective action documents for plant modification issues, including configuration management audits, to verify compliance with the corrective action program activities described in Chapter 3 of the License Application. The scope of the corrective action review included outstanding design and operational issues for the processes selected for in-depth review.
Interviewed licensee staff to verify that system/responsible engineers had an adequate understanding of their assigned systems and the impact of selected modifications on the systems function.
System Condition and Capability Review (IP Section 02.03)
For the selected modifications, the inspectors reviewed the system condition and tested capability to verify they were consistent with the applicable design requirements and licensing basis. Specifically, the inspectors conducted the inspection activities listed below:
Interviews, records reviews, and plant walk-downs were conducted to verify whether the selected modifications to the Incinerator were adequately implemented consistent with the configuration management package.
Interviews, record reviews, and plant walk-downs were conducted to verify assumptions in the ISA or safety basis applicable to the modification were valid based on the actual configuration and operation of the modified processes.
Interviews, record reviews, and plant walk-downs were conducted to verify whether management measures were properly implemented to ensure that IROFS or other safety controls were available, capable, and reliable to perform their function when needed.
Interviews, record reviews, and plant walk-downs were conducted to verify that administrative controls that involve operator action could be accomplished as assumed in the licensees ISA.
Post-Modification Testing (IP Section 02.04)
For the selected modifications, the inspectors interviewed licensee staff and reviewed post-modification testing records to determine whether the plant was in a safe configuration during post-modification testing. The inspectors reviewed the following post-modification tests to determine whether post-modification testing ensured adequate implementation of the design and safety system functionality.
Integrated Safety Analysis (ISA) Chapter 13, "Low Level Radioactive Waste System, Incinerator System."
Work Order (WO) 813557, 8/15/2018
WO 813558, 8/15/2018
WO 854156, 8/7/2019
WO 854337, 8/7/2019
WO 859681, 9/25/2019
Dispatch 10387, 10/22/2020
Dispatch 10388, 10/22/2020
8
Dispatch 10389, 11/9/2020 Documentation Review (IP Section 02.05)
The inspectors reviewed a sample of plant documents impacted by the modifications selected for review to verify the licensee had either updated or was in the process of updating such documents to reflect the modifications in accordance with the license application requirements and 10 CFR 70.72. The inspection sample included:
COP-830210, Incinerator Operation, Rev. 55
TA-500, Configuration Control Program, Rev. 39
training records for Incinerator operators and area/system engineers associated with the incinerator system
ISA Chapter 13, Low Level Radioactive Waste System
Criticality Safety Evaluations (CSE) o CSE-1-A, Incinerator Filter Housings, Rev. 0, 5, 12 o
CSE-13-1, Incinerator System, Rev. 3 through 16 INSPECTION RESULTS WER (Closed) 24 Hour Report - Unplanned Medical Treatment (EN 55412)
WER 07001151/2021-001-00 88072
==
Description:==
On August 17, 2021, a Westinghouse employee was washing piping over a container of nitric acid in the Conversion Decontamination Area. The piping fell into the container of nitric acid and employee reached into the container to retrieve the piping and received nitric acid burns to hands and left wrist. Appropriate treatment for exposure to nitric acid was provided by on-site medical response staff. As a precautionary measure, the employee was transported to an off-site medical facility. Per procedure, the employees hands and arm were wrapped in plastic, and the employee was transported to an off-site medical facility accompanied by plant health physics personnel for evaluation. The licensee reported this event to the NRC as EN55412 on August 17, 2021; and submitted their 30-day follow-up report dated September 15, 2021 (ADAMS Accession Number: ML21258A403), in accordance with 10 CFR 70.50. This event was also entered into the licensee's corrective action program.
The inspectors reviewed licensee records to verify that the potential spread of contamination was minimized by wrapping contaminated areas in plastic prior to transport by ambulance and that a licensee HP technician accompanied the worker in the ambulance in accordance with licensee procedures. Smear samples taken at the site, ambulance, and hospital confirmed that smearable contamination was below the licensee's free release limits and there was no spread of contamination.
The Written Event Report was reviewed. No violations of NRC requirements were identified.
This item is considered closed.
9 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On October 8 and November 19, 2021, the inspectors presented the integrated inspection results to Mike Annacone and other members of the licensee staff.
10 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date Drawings 347F04PI02 HOT OIL ROOM / FACILITIES Rev. 28 Miscellaneous ECL-80004 UF6 Installation and Removal Employee Checklist 11/18/21 CF-81-002 UF6 Cylinder Record Rev. 60 CM-81026 39501: 52 Weeks OM81026 SI-SAFETY, XOMOX3-WAY VALVE VERIFICATION 04/29/2021 COP-810094 REPLACEMENT OF PLUGGED PIGTAIL PROCEDURE ON UF6 CYLINDER 09/03/2020 COP-810096 COLD PRESSURE CHECKING OF UF6 CYLINDER 09/06/2018 COP-810097 UF6 BAY HANDLING OF UF6 CYLINDERS 02/13/2020 COP-810098 UF6 CYLINDER INSTALLATION PROCEDURE AND REMOVAL 04/29/2021 COP-810099 UF6 VAPORIZER 12/05/2018 COP-814604 UF6 CYLINDER VACUUM PRESSURE PROCEDURE MEASUREMENT 06/11/2021 COP-816020 UF6 Cylinder Installation and Removal for Line 5 10/13/2016 OM81025 36664: 52 Weeks OM81205 SI-SAFETY ITEMS,ADU LINE 5 SYF-220-1 PIPELINE INSPECTION SHEET 05/27/2021 Procedures W2-5.1-101.W03 Issue Review Committee Work Instruction 10/27/2021 Radiation Surveys ROF-07-001-7 Health Physics Response to a UF6 Release 08/12/2021 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Conversion - Conversion Operations and Various Containers, 4Q20 12/18/2020 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Conversion - Conversion Operations and Various Containers, 1Q21 03/31/2021 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Conversion - Conversion Operations and Various Containers, 2Q21 06/29/2021 RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Conversion - Conversion Operations and Various Containers, 3Q21 09/29/2021 88020 Self-Assessments SYF-300-2 HOUSEKEEPING INSPECTION, CHEM-05 HOT OIL ROOM 02/18/2021
11 Inspection Procedure Type Designation Description or Title Revision or Date CFFF Dispatch 27829 26 Weeks PM20206 SI-SAFETY - PRESSURE RELIEF VALVES - 26 WEEK PM 02/15/2021 CFFF Dispatch 27830 26 Weeks PM20206 SI-SAFETY - PRESSURE RELIEF VALVES - 26 WEEK PM 02/15/2021 CFFF Dispatch 39442 52 Weeks SI-SAFETY EXTERNAL MECHANICAL INTEGRITY INSPECTION - 52 WEEK PM 05/07/2021 Checklist OM81201 SI-SAFETY ITEMS, ADU LINE 1 - 52 WEEK OM 03/14/2021 Checklist OM81203 SI-SAFETY ITEMS, ADU LINE 3 - 52 WEEK OM 08/09/2021 Work Orders Checklist OM81204 SI-SAFETY ITEMS, ADU LINE 4 - 52 WEEK OM 07/26/2021 Corrective Action Documents IR-2017-736 IR-2020-8885 IR-2020-9268 IR-2020-13960 IR-2020-14085 IR-2021-7742 IR-2020-13168 Incident Reports various Drawings 304F07PI02 Scrubber System Modifications Rev. 12, 13, 21 CCF 05210 Incinerator Safety PLC 04/07/2005 CCF 05361 Incinerator Mass Control 08/11/2005 CCF 06488 FN-949 Drain Hole 10/6/2006 CCF 06605 Incinerator PLC Fault 01/11/2007 CCF 06610 PLC Level Probe Input 1/31/2007 Engineering Changes CCF 09339 Incinerator/ABF Torit Level Probe 05/31/2009 CAF-203-5 Readiness Review Plan Rev. 1 CSE-13-A Criticality Safety Evaluation for the Incinerator System Rev. 3-16 PSEDoc-0001912 Independent Technical Review for CCF12155 Incinerator Backflow Preventer Installation Rev. 1 Engineering Evaluations PSEoc-0003557 Qualification Plan for Incinerator PLC Modifications to Remove Ram Controls Rev. 0 88072 Miscellaneous 06542 Incinerator Sump Emergency Drain Size Increase 01/08/2008
12 Inspection Procedure Type Designation Description or Title Revision or Date 16178 Install drain line in incinerator duct just prior to "C" demister 03/15/2016 17494 Demolition of Incinerator System 6A Ventilation 11/03/2017 17495 6A Incinerator Ventilation System 04/15/2018 CCF 06392 Scrubber Liquid Recirc Loop 05/21/2007 CCF 12155 Tie in for Incinerator BFPs and Area Contaminated Drain Inputs 08/24/2014 CCF 16159 Modifications to Incinerator RAM Controls and Safety System Upgrades 12/27/2017 Operability Evaluations CF-20-010 Incinerator Safety Significant Interlocks Functionality Verification Form Rev. 4 COP-830210 Incinerator Operation Rev. 55 CSE-1-AP Incinerator 6A Ventilation System Rev. 0 ISA-13 Low Level Radioactive Waste System Various Revisions Procedures TA-500 Columbia Manufacturing Plant Configuration Control Rev. 39