ML22200A247
| ML22200A247 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/20/2022 |
| From: | Eric Michel NRC/RGN-II/DFFI/FFB2 |
| To: | Annacone M Westinghouse |
| References | |
| IR 2022002 | |
| Download: ML22200A247 (11) | |
Text
July 20, 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 07001151/2022002
Dear Mr. Annacone:
This letter refers to the Nuclear Regulatory Commission inspection activities conducted from March 1 to June 30, 2022 for the Westinghouse Columbia Fuel Fabrication Facility. On May 20 and June 1, 2022 the NRC inspectors discussed the results of these inspections with you. The results of these inspections 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 07/20/22 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
ML22200A247 x Non-Sensitive x Publicly Available x SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI/PB2 RII/DRP/RPB5 RII/DFFI/PB2 NAME T. Vukovinsky N. Peterka E. Michel DATE 7/20/2022 7/20/2022 7/20/2022 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2022002 Enterprise Identifier: I-2022-002-0057 Licensee: Westinghouse Electric Company Facility: Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: May 16, 2022; June 02, 2022 Inspectors: M. Greenleaf, Technical Assistant N. Peterka, Senior Project Engineer T. Vukovinsky, Senior Fuel Facility Project 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 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 70.61, 70.62, and Chapter 3, Conduct of Operations, 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, radiation 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:
- ISA-3, ADU Conversion System Summary - Vaporization Section 4.1.1.7, Loss of Containment of Hot Oil Accident Sequence: Initiating Event 1, Mechanical Integrity Failure Accident Sequence: Initiating Event 2, Over-pressurization Discussion of Therminol-66
- ISA-03, ADU Conversion System Summary Section 4.1.1.14, Seismic Induced Release from Vaporizer System Accident Sequence Accident Sequence: Initiating Event 1, Seismic Induced Release from Vaporization System 3
- ISA-02, Uranyl Nitrate (UN) Bulk Storage System Section 4.1.1, Accident Sequence for Fire Safety, Chemical Safety, Radiological Safety and Environmental Protection Accident Sequence: UN Accident Sequence Due to Failure of UN Bulk Storage Tank Earthquake Initiated Failure of UN Bulk Storage System Discussion of seismic upgrades to the bulk storage tanks (70.72 changes)
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 ADUFIRE-901/902 ADUHOS-407, 901, 902, 908, 909 ADUVAP-945, 946, 949, 950, 948, 947 PLANT-SEP-901, 903, 905 Boiler-905, 906 UN-901, 912, 915 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 Section 3.0, "Conduct of Operations," 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 inspectors conducted the following activities to verify the implementation of selected safety controls:
walk-downs performed to verity implementation of safety controls or IROFS listed above walk-down of the 'C' Isolation Valve and discussion with conversion control room operators on closure of the valve following a seismic event walk-down of the S-2A/2B sump maintenance activities reviewed change to procedure COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers" reviewed postings and operator aids for IROFS listed above 4
reviewed seismic qualification data for the UN Bulk Storage Tanks and seismic IROFS observed safety significant testing conducted by operations and maintenance personnel observed morning turnover and shift briefings for Conversion and Uranium Recycling and Recovery Services operators.
observed pre-job briefings for S-1030 Scrubber duct work inspections and S-2A/2B Scrubber sump inspection and cleanout.
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 Section 3.0 of the license application. Specifically, the inspectors conducted the following:
reviewed operator training/qualification for multiple conversion and URRS area operators reviewed annual compliance and program audits for the operations organization reviewed the following CAP entries associated with failed/degraded IROFS:
2021-12133, 2021-13082, 2021-13508, 2021-13868, 2021-4738, 2021-4739, 2022-2000, 2022-209, 2022-4352, and 2022-4576 OTHER AREAS 88075 - Event Follow-up An event follow-up inspection was conducted for Event Notice (EN) 55911, "Procedural Noncompliance with Administrative Items Relied on for Safety (IROFS)."
Event Follow-up Administrative IROFS WT-165 and WT-166 require independent operators to sample and verify the V-1170 tanks' uranium concentration is below an administrative limit prior to discharge to the V-1160 tank. These IROFS were correctly performed on May 18, 2022, for both the V-1170A and V-1170B tanks. In between May 18th and the 23rd, the warm caustic filter was water washed with the process solution sent to the V-1170 tanks. On May 23, 2022, the contents of V-1170A and V-1170B tanks were then pumped to the T-1160B tank without the tank uranium concentration being updated following the warm caustic filter wash. On May 23, 2022, an evaluation into the reportability of the event was initiated when a Uranium Recovery and Recycling Services (URRS) team manager contacted Criticality Safety Engineering to report the transfer without the test results required by procedure. After reviewing updated tank test results, performing calculations to determine risk, and discussing actions taken by the operators, IROFS WT-165 and WT-166 were considered failed.
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Per CSE-15C-S1-G3, the remaining safety margin was 1.000E-2, which was below the required 1.000E-4. The result is reportable per 10 CFR Part 70 Appendix A (b)(2), "Loss or degradation of items relied on for safety that results in failure to meet the performance requirements of 10 CFR 70.61." Following the event, the contents of V-1170A and T-1160B were tested and historical tank level indication data was reviewed with results well within the IROFS limits.
An on-site inspection of this event was conducted using Inspection Procedure (IP) 88075, "Event Follow-up." The inspectors walked down the system and reviewed the sample data associated with the tanks involved. Operators, area engineers, criticality safety engineers, and plant management were interviewed. The inspectors reviewed CAP IR 2022-4718, "White Paper to NRC justifying event performance requirements." In conclusion, the incident resulted in failed IROFS as depicted on the fault tree which resulted in a scenario that required a report to the NRC. The licensee's evaluation demonstrated that controls were in place to assure performance requirements required by 10 CFR 70.61 were met and the plant was not in an unsafe condition. The licensee conducted an extent of condition, and corrective actions were put in place to improve both procedures and forms for administrative controls as well as reviewing fault trees to determine if proper credit is being applied to available IROFS. There was no safety impact as a result of the failed IROFS.
EN 55911 will remain open pending review of the 60-day letter submittal by the licensee and a final review of the extent of condition and corrective actions. This EN will be closed in the third quarter report 2022-003 which will be issued by October 31, 2022.
INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On May 20 and June 1, 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 88020 Corrective Action Inspection Corrective Action Reports Various Documents Reports: 2021-4739, 2021-12133, 2021-13082, 2021-13508, 2021-4738, 2022-2000, 2022-4352 Drawings 333F08PI03 UN Valve Station Rev. C2 334F01P101 Vaporizer V-101B Rev. 29 334F04PI02 Hot Oil Dryer System - Sheet 1 Rev. 27 335F11EL01 ADU Line #2/Control Systems Rev. 5 347F04PI01 Hot Oil Pump Seal Cooling System - Sheet 1 Rev. 7 347F04PI02 Hot Oil Systems 3 & 4 Catch Tank T-1399 - Sheet 06 Rev. 7 347F04PI02 Hot Oil System 4 - Sheet 02 Rev. 13 347F04PI02 Hot Oil Systems 3 & 4 Supply and Return - Sheet 05 Rev. 9 347F04PI02 Hot Oil Systems 3 & 4 Distribution Manifold - Sheet 04 Rev. 3 347F04PI02 Hot Oil System 3- Sheet 1 Rev. 28 347F04PI04 Hot Oil, FL-1389 and FN-1389 P&ID - Sheet 1 Rev. 4 600F07EL01 Storm Drainage Control Structure "C" Electrical Schematic - Rev. 2 Sheet 01 622F01PI01 Uranyl Nitrate Storage Tanks Rev. C2 Engineering CCF 21058 Tank 1040 Seismic Modifications 02/09/2021 Changes Engineering 'C' Valve Information Evaluations CSE-2-A Criticality Safety Evaluation for Uranyl Nitrate Bulk Storage Rev. 12 CSE-3-H Criticality Safety Evaluation for Conversion Lines Oil Dryers Rev. 11 and Bucket Elevators CSE-99-M Criticality Safety Evaluation for the CFFF Design Basis Rev. 4 Seismic Event Miscellaneous Work Week 2220 Cycle Schedule Procedures CF-83-239 LR-230 OFFLOAD CHECKLIST Rev. 5 7
Inspection Type Designation Description or Title Revision or Procedure Date COP-810099 UF6 Vaporizer Rev. 38 COP-814532 General Safety Requirements - Conversion Rev. 27 COP-815417 Functional Verification of Safety Significant Controls Rev. 24 Conversion Area COP-836047 Uranyl Nitrate Offloading from LR-230 Containers Rev. 23 CSE-99-M CFFF Design Basis Seismic Event Rev. 4 MCP-108246 Operating the Cleaver Brooks Boilers Rev. 2 PM81109 Seismic SSC Verification - 52 week PM SEP-002 Classification Rev. 6 SEP-009 Emergency Response Organization Check Sheets Rev. 19 SS4210 PM81018 05/06/2021 104528 Self-Assessments EHS-AUDIT-21-3 Formal Compliance Audit Report 04/16/2021 EHS-AUDIT-22-1 Regulatory Component Audit for Maintenance, Incident 02/09/2022 Investigations, and Corrective Action EHS-AUDIT-22-5 Audit Report for the SNM-1107 Chemical Safety Program 03/31/2022 Work Orders WO 62948 SSC Testing T-1042 Valve 05/17/2022 WO 78991 52 Weeks OM81213 SI - Safety Interlocks, Hot Oil Systems 11/24/2021 WO 80478 SI-SAFETY, SLUICE GATE VALVES - 13 WEEKPM 12/15/2021 WO 874434 Seismic SSC Verification - 52 week PM 04/21/2020 WO 97805 SI-SAFETY, SLUICE GATE VALVES - 13 WEEKPM 03/15/2022 88075 Corrective Action IR 2022-4718 Warm Caustic Failure to Meet Performance Requirements Various Documents Procedures CF-83-213 Warm Caustic Filtrate SSC Verifications Rev. 3 COP-830524 Operation of F-1168 - Warm Caustic Water-Glass Cake Rev. 10 Dissolution and Filtration CSE-15-C Criticality Safety Evaluation (CSE) for Waterglass Liquid Rev. 10 Waste Effluent Treatment System CSE-15-D Criticality Safety Evaluation for Warm Caustic Waterglass Rev. 7 Cake Dissolution System Work Orders Dispatch 106881, Various gamma monitor and pH probe calibration records Various 109441, 109442, 109443, 96195, 8
Inspection Type Designation Description or Title Revision or Procedure Date 96217 9