ML22104A135

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Fuel Fabrication Facility - Integrated Inspection Report 07001151/2022001
ML22104A135
Person / Time
Site: Westinghouse
Issue date: 04/18/2022
From: Eric Michel
NRC/RGN-II/DFFI/FFB2
To: Annacone M
Westinghouse
Peterka N
References
IR 2022001
Download: ML22104A135 (13)


Text

April 18, 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 07001151/2022001

Dear Mr. Annacone:

On March 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Columbia Fuel Fabrication Facility. On March 3, 2022, 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, Signed by Michel, Eric on 04/18/22 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

ML22104A135 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI/PB2 RII/DFFI/PB2 RII/DFFI/PB2 NAME N. Peterka T. Vukovinsky E. Michel DATE 4/15/2022 4/15/2022 4/18/2022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2022001 Enterprise Identifier: I-2022-001-0079 Licensee: Westinghouse Electric Company Facility: Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: February 28, 2022 to March 04, 2022 Inspectors: L. Pitts, Sr. Fuel Facility Projects Inspector T. Sippel, Fuel Facility Inspector Approved By: Eric C. 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 70.24, 70.61, 70.62, Chapter 6, Nuclear Criticality Safety (NSC) 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 assumptions and calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following CSEs:

CSE-17-B, "Criticality Safety Evaluation for Final Assembly Wash Pit," Rev. 8, including the review of what-if analysis sequences 1 through 6 which cover various credible and incredible sequences involving equipment failures and human errors such as assembly drops and flooding. Which including reviewing the basis for why the licensee screened certain accident sequences as incredible.

CSE-1-H, "Criticality Safety Evaluation (CSE) for the S-958 Solvent Extraction Scrubber," Rev. 10, including the review selected accident sequences involving backflow into the ducts and accumulations in the ducts. The inspectors conducted walkdowns and reviewed Drawing 301F07HV06 to verify that the inputs to the scrubber, and selected controls on those inputs, where consistent with the CSE.

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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, plant walkdowns, and staff interviews to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee staff and reviewed the following controls, and their management measures, associated with the CSEs listed above and other selected areas:

FA-901, an administrative control to prevent dropped fuel assemblies, and associated procedures VENT-901, an administrative control using gamma surveys to prevent accumulations in ductwork, associated procedures and recent completed surveys records VENT-S1190-121, an administrative control preventing accumulations in ductwork, and associated inspection, cleanout and sampling records associated with this control, as well as implementing procedures VENT-SOLX-101, a passive engineered control preventing backflow into ductwork, and walked down the implementation of this control VENT-SOLX-108, a passive engineered control preventing overflow into ductwork, and walked down the implementation of this control VENT-SOLX-109, an administrative preventing accumulation in ductwork, and recent associated inspection records and implementing procedures VENT-SOLX-112, a passive engineered control preventing overflow into ductwork, and walked down the implementation of this control 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:

interviewed NCS staff concerning criticality hazards and control methods, including monitoring for and cleaning out long-term accumulations in ducts; reviewed NCS oversight of accumulation cleanouts reviewed the documentation of selected NCS weekly facility walkthrough assessments (FWAs) performed by the licensee over the last year, the FWA scheduled for 2022, and selected items identified by the licensee during the FWAs Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed revisions to NCS program procedures to verify compliance with 10 CFR 70 and applicable sections of the license application. Specifically, the inspectors interviewed licensee NCS staff and reviewed the following:

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procedures, work orders and records relating to the licensee's use of nondestructive assay controls (e.g., VENT-SOLX-901) the most recent revision to licensee procedure RA-304, Criticality Accident Alarm System 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 section 6.1.8. Specifically, the inspectors observed activities, reviewed documents, and interviewed licensee staff concerning the following:

selected NCS-related CAP entries over the last year the annual NCS evacuation drill records for 2021 the licensee's project to upgrade the CAAS, CAAS component design and CAAS performance; including review of SEP-012 and SYP-306 FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the Emergency Plan, the license and license application, and NRC requirements in 10 CFR Part 70.

Emergency Preparedness Program Review and Implementation (IP Section 02.01)

The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10CFR70(i)(3),

Chapter 9 of the license application, and the Emergency Plan. Specifically, the inspectors conducted the following inspection activities:

reviewed the plant process for evaluating plant changes and modifications that could potentially impact the emergency preparedness program reviewed the revisions to site emergency procedures that had been revised since the last inspection to verify that the overall effectiveness of emergency procedures had not decreased due to those changes; the following procedures were reviewed:

o SEP-001 o SEP-003 o SEP-005 o SEP-007 o SEP-009 o SEP-012 o SEP-018 reviewed the training records for ten members of the emergency response organization and interviewed four emergency response staff regarding emergency response organization training, tracking of training, the required 5

number of hours for specific training topics, and the process for notifying emergency response organization staff of expiring training reviewed the pre-fire plans to verify they reflected special considerations such as chemical hazards and those current revisions were available in the designated locations observed a tabletop training exercise that required activation of the emergency operations center, verification of communication capabilities, emergency declarations and accountability of staff reviewed drill and exercise records to verify that the licensee was performing the required drills and that items identified during drill critiques were being captured and addressed reviewed the letters of agreement for emergency response services, between Westinghouse Electric Company and Richland County Sheriffs Department, Columbia-Richland Fire Department, Richland County Government Emergency Services Department, Prisma Health-Midlands, and South Carolina Department of Health and Environmental Control reviewed the licensee's process for providing site familiarization tours and training for offsite response organizations reviewed communications between the licensee and offsite response organizations inviting the offsite response organizations for onsite walk throughs for emergency protocols performed system walk-downs, observed inventory checks and reviewed inventory, maintenance and testing records to verify emergency equipment was being maintained in the required state of readiness Identification and Resolution of Problems (IP Section 02.02)

The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors reviewed the following corrective action program entries, audits, and self-assessments:

reviewed EHS-Audit-22-2 which was the external audit of the emergency preparedness program, which included the site emergency plan and emergency procedures, training activities, emergency facilities, equipment, supplies, records, and elements that have had weaknesses identified in Issue Reports from previous audits, drills, exercises, and events reviewed corrective action program entries generated to address the issues identified in the external EHS audit, EHS-Audit-22-2, specifically the inspectors reviewed IR-2022-1549 dated 2/25/22 and IR-2022-1826 dated 2/17/22 6

Event Review (IP Section 02.03)

The inspectors reviewed the licensees safety-significant and internal events related to emergency preparedness to verify compliance with 10 CFR 70.22(i)(3), Chapter 9 of the license application, and the Emergency Plan.

reviewed records of site events that required a response by the emergency response organization to determine:

o if those events had been properly assessed o if corrective actions had been developed to address any identified issues o if any problems or deficiencies associated with the emergency plan had been identified INSPECTION RESULTS No issues were identified.

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

On March 3, 2022, 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 88015 Corrective Action IR-2021-8257, IR- Various NCS-Related CAP Entries Various Documents 2021-8349, IR- dates 2021-10152, IR-2021-10527, IR-2021-10689, IR-2021-10833, IR-2021-12208, IR-2021-12762, IR-2021-13749 Drawings 301F07HV06 Process Ventilation System Scrubber S-958 Isometric Rev. 3 Engineering CSE-1-H Criticality Safety Evaluation (CSE) for the S-958 Solvent Rev. 10 Evaluations Extraction Scrubber CSE-17-B Criticality Safety Evaluation for Final Assembly Wash Pit Rev. 8 CSE-3-I Criticality Safety Evaluation (CSE) for the Columbia Fuel Rev. 9 Fabrication Facility ADU Conversion Calciner Miscellaneous Annual Criticality Evacuation Drill Records for 2021 Criticality Accident Alarm System Replacements Project 03/01/2022 Overview and History Analytical Chemistry Work Request - Miscellaneous Samples 12/22/2021 Form CF-83-152 Scrubber S-958 Ventilation Duct Inspection Documentation 10/08/2020, 04/08/2021 RAF-316-1 Various completed Nuclear Criticality Safety Checklists for Various NCS Facility Walkthrough Assessments dates within the last year Procedures Operation/Maintenance Manual for Criticality Accident Alarm System (CAAS)

COP-801018 Inspection and Cleanout of Area Ventilation Ducts Rev. 10 Form CF-83-152 Inspection Form for Ventilation Duct Inspection URRS S-958 Rev. 8 Scrubber Form CF-84-021 URRS ROOF VENTILATION DUCT INSPECTION Rev. 0 QUARTERLY (13 WEEK)

Form ROF Ventilation Systems Equipment Radiation Survey Quarterly - Rev. 1 8

Inspection Type Designation Description or Title Revision or Procedure Date 062-11 S-958 Survey MCP-108218 Inspection of Roof Ventilation Ducts with Boroscope Rev. 11 MOP-730502 FUEL ASSEMBLY CLEANING - GENERAL Rev. 58 RA-304 Criticality Accident Alarm System Rev. 17 ROP-05-062 Radiation Survey of Ventilation Equipment Rev. 23 SEP-012 Operation Guidelines During Loss of Criticality Accident Rev. 1 Alarm System Coverage SYP-306 CFFF Fire/Criticality System Impairment Rev. 23 Radiation Form ROF Various Quarterly Ventilation Systems Equipment Radiation Completed Surveys 062-11 Surveys for the S-958 Scrubber various dates Work Orders Dispatch #69100 W/O#: 6345 - Planned Work -S-1190 Duct Inspections Dispatch #85344 Clean solids from ventilation ducts WO 7403 Add Cleanout Port to Support SSC VENT-S1190-121 WO: 855686, SI-Safety, S-958 Scrubber Ventilation Inspection - 26 Week 10/09/2019, 575020 OM 04/08/2020 88050 Corrective Action IR-2022-1549 Corrective Actions from Comprehensive Independent Audit 02/25/2022 Documents of CFFF's Emergency Preparedness Program IR-2022-1826 Additional Items from Comprehensive Independent Audit of 02/17/2022 CFFF's Emergency Preparedness Program Corrective Action CFFF Dispatch Inspect and repair corroded and leaking piping in Fire Pump 03/02/2022 Documents #99181 House #1 Resulting from CFFF Dispatch Inspect and repair corroded and leaking piping in Fire Pump 03/02/2022 Inspection #99183 House #2 Miscellaneous Post Incident Analysis dated March 17,2021 03/17/2021 Columbia- Emergency Response Services Agreement 01/18/2022 Richland Fire Department Memorandum of Emergency Services Agreement 05/16/2019 Understanding Between Westinghouse Electric Company and South 9

Inspection Type Designation Description or Title Revision or Procedure Date Carolina Department of Health and Environmental Control Richland County Emergency Response Services Agreement 01/31/2022 Government Emergency Services Department Letter Site Security Plan Emergency Response Services Agreement 03/18/2021 Letter of Agreement from the Richland County Sheriffs Department Procedures Agreement Emergency Response Services Agreement 05/15/2019 between Prisma Health-Midlands and Westinghouse Electric Company SEP-001 Emergency Response Organization Rev. 9 SEP-003 Emergency Response Team Rev. 7 SEP-005 Evacuation, Accountability and General Response Rev. 14 SEP-007 Notification Guidelines Rev. 54 SEP-009 Emergency Response Organization Check Sheets Rev. 18 SEP-012 Operation Guidelines During Loss of Criticality Accident Rev. 1 Alarm System Coverage SEP-018 Emergency Operations Center Operations Rev. 5 SEPF-004-1 Haz Mat / Special Operations Truck Inventory Sheet Rev. 29 SEPF-004-10 Monthly Inspection of Emergency Radios and Telephones Rev. 22 SEPF-004-16 Hose House Equipment Rev. 19 SEPF-004-17 First Responder/Brush Truck Inventory Sheet Rev. 20 10

Inspection Type Designation Description or Title Revision or Procedure Date SEPF-004-19 Fire Engine Inventory Sheet Compartment Layout Rev. 3 SEPF-004-2 Emergency Response Van Inventory Sheet Rev. 31 SEPF-004-3 Fire Engine Inventory Sheet Compartment Layout Rev. 25 SEPF-004-6 Emergency SCBA Monthly Over Check Sheet Rev. 19 SEPF-004-7 Rescue Jump Bag Checklist Rev. 6 Self-Assessments EHS-22-2 Comprehensive Independent Audit of the Emergency 02/07/2022 Preparedness Program including the Site Emergency Plan and Emergency Procedures, training activities, emergency facilities, equipment, supplies, records, and elements that have had weaknesses identified in Issue Reports from previous audits, drills, exercises, and events.

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