ML24023A695
| ML24023A695 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 01/26/2024 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Pope A Westinghouse |
| References | |
| EN56199 IR 2023004 | |
| Download: ML24023A695 (20) | |
Text
EN56199 Annette Pope Plant Manager Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061
SUBJECT:
WESTINGHOUSE COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2023004
Dear Annette Pope:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from October 1 to December 31, 2023, for the Westinghouse Columbia Fuel Fabrication Facility. On November 16 and November 30, 2023, 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, 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 January 25, 2024 Signed by Michel, Eric on 01/25/24
SUNSI Review x
Non-Sensitive
Sensitive x
Publicly Available
Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME J. Raudabaugh T. Vukovinsky E. Michel DATE 1/24/2024 1/24/2024 1/25/2024
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07001151 License Number:
SNM-1107 Report Number:
07001151/2023004 Enterprise Identifier:
I-2023-004-0069 Licensee:
Westinghouse Electric Company Facility:
Westinghouse Columbia Fuel Fabrication Facility Location:
Hopkins, SC Inspection Dates:
November 13 to 16, 2023 November 27 to 30, 2023 Inspectors:
L. Cooke, Fuel Facility Inspector N. Peterka, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector C. Taylor, Sr. Fuel Facility Project 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 Westinghouse 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 07001151/2022-003-00 Hematite Ash (EN56199) 88015 Closed URI 07001151/2023-004-01 Structural Support and Weld Modifications for the Hot Oil Expansion Tanks 88020 Open
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 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 (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 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-5-A, "Criticality Safety Evaluation for Ammonium Diuranate (ADU) Bulk Blending System," Rev. 2, including review of what-if analysis, normal, credible abnormal, and non-credible accident sequences.
CSE-9-B, "Criticality Safety Evaluation for Cylinder Wash," Rev. 8, including the review of selected accident sequences involving cylinders containing greater than a heel quantity of Uranium Hexafluoride (UF6) and backflow from the cylinder wash to other process systems. The inspectors conducted walkdowns to verify that the inputs/outputs to and from the cylinder wash, and selected controls on those inputs/outputs, were consistent with the CSE.
CSE-19-A, Criticality Safety Evaluation for Oxidation Ovens and Hoods," Rev.
5, including the review of what-if analysis, normal, credible abnormal, and non-credible accident sequences and the IROFS that were established to prevent criticality for accident scenarios 4.1.1 and 4.1.2.
4 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:
ADUBB-14, an administrative control to inspect for moderator in powder in polypaks prior to use, and associated procedure ADUBB-119, a passive engineered control to prevent moderator intrusion in a moderator restricted area via an outer roof, and associated inspection records ADUBB-120, a passive engineered control to prevent moderator intrusion in a moderator restricted area via an inner roof, and associated inspection records OVEN-9, a passive engineered control to ensure favorable geometry via drains in the oxidation hoods, and observation in the field WASH-102, a passive engineered control overflow to prevent backflow, and observation in the field 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 engineering staff concerning criticality hazards and control methods, including monitoring and control of moderators within the ADU Bulk Blending System moderated controlled area reviewed the documentation of selected NCS weekly facility walkthrough assessments (FWAs) performed by the licensee over the last six months interviewed cylinder wash operators on implementation of administrative controls through the applicable operating procedures Criticality Programmatic Oversight (IP Section 02.04)
The inspectors reviewed NCS program procedures, audits, and NCS staff qualifications 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 documents:
discussed qualification and training status of the NCS staff with NCS management interviewed NCS staff concerning the NCS review of changes, including changes to operating procedures that may affect NCS, and changes to the facility the most recent revision to licensee procedure RA-301, Floor Storage of Special Nuclear Material
5 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:
reviewed selected issues entered in the CAP pertaining to IROFS and audit findings reviewed final sample analysis results of suspect Hematite ash showing uranium enrichment was less than the allowed license limit of 5 percent (EN56199) reviewed engineering evaluation for CAAS detector placement based on the facility's minimum accident of concern 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 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, radiation safety, fire safety, and/or chemical safety based on the information provided in the integrated safety analysis (ISA) summary, safety basis documentation. 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 03, ADU Conversion System o
4.1.1.2 UF6 Pad Storage Area Fire Leading to Loss of Containment o
4.1.1.3, ADU Conversion Area Lines 1-4 Cylinder Loss of Containment o
4.1.1.5, ADU Conversion Area Lines 1-5 Cylinder Loss of Containment due to Fire o
4.1.1.7, Loss of Containment of Hot Oil in Hot Oil Room ISA 17, Final Assembly Area o
CSE-17-B, Final Assembly Wash Pit
6 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:
ISA-03 UF6CYL-905, UF6 Pad Annex and Expansion Area Bollards, passive engineered control (PEC)
SBG-401, SBG3 and 4 Concrete Barrier, PEC SBG-901, SBG3 and 4 Double Walled Fuel Tank, PEC ADUVAP-902, Vaporizer Pressure Relief Valves, active engineered control (AEC)
ADUVAP-903, Vaporizer High Steam Pressure Interlocks, AEC ADUVAP-904, Conversion Line Conductivity Interlock, AEC ADUHOS-405, Fire Doors to Hot Oil Room Closed, administrative control (AC)
ADUVAP-917, Anti rotation device used for inspection of valve stem and coupler assembly (admin)
ADUHOS-901, Oil System Temperature Shutoff (AEC)
ADUHOS-906, Hot Oil Room Fire Wall, PEC ADUHOS-907, Hot Oil System Structural Integrity, PEC ADUHOS-908, Backup Oil System Temperature Shutoff, AEC ADUHOS-910, Hot Oil Room Dike, PEC ADUHOS-912, Hot Oil Backflow Prevention Interlock, AEC ISA-17 FA-101, Overhead Trolley Crane Spacing, PEC FA-103, Rinse Tank Inserts, PEC FA-137, Rinse Tank Insert Verification, AC FA-138, Empty Rinse Tank Verification, AC FA-146, Pit Cover and Inspection Stand Confines, PEC FA-901, Crane Operator Training, AC FA-902, Inspection and Load Testing of Lift Equipment, AC 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 inspectors conducted the following activities to verify the implementation of selected safety controls:
7 performed walkdowns of ADU conversion lines 1 - 5, the UF6 storage pad, control room, final assembly, and observed general housekeeping in the focus areas observed maintenance staff performing inspections associated with IROFS ADUHOS-906 and ADUHOS-910 interviewed operations and maintenance staff assigned to perform inspections to verify their knowledge of the requirements associated with their assigned inspections and duties interviewed and accompanied maintenance technicians who performed calibrations of PH probes 220116, 202117 and 202123 located in ADU conversion performed walkdown and observed condition of primary barriers for IROFS SBG-401 (Generators) & SBG-901 (fuel tanks) reviewed CALC-194-8169-01, Fire Hazards Analysis Combustible Loading Calculations reviewed FHA-13-001, Fire Hazards Analysis reviewed Revalidation of the PHA of the ADU Conversion Process reviewed CSE-17-B, Criticality Safety Evaluation for the Final Assembly Wash Pit reviewed NSA-TR-COL-13-53, Seismic Evaluation of Equipment and Tanks reviewed PSEDoc-0003335, Hot Oil Systems Preliminary PHA Report 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:
observed plan of the day, production chemical operations and corrective action meetings reviewed sample of technician training and qualifications related to the operation of the monorail and bridge cranes reviewed samples of IROFS-related Correction Action Program (CAP) entries for the previous six months reviewed samples of compensatory measures established for the following:
o Conversion ICM Verification Log, CF-81-101, Rev 8 dated November 11/20/2023 o
Bulk Room Daily Checks, CF-81-115, Rev 0, dated 11/21/2023 reviewed the licensee's following audits:
o Regulatory Component Audit for the Integrated Safety Analyses Program (EHS-Audit-23-7) o Formal Compliance Audit Report of Areas of ISAs (EHS-Audit-23-10) o Regulatory Component Audit for Procedures, Training and Qualifications, Human Performance, QA Elements (EHS-Audit-23-2) reviewed procedure, CA-044, Interim Compensatory Measure (ICM), Rev.0 reviewed work order OM85019, 52 Week SI-Safety, UF6 Pad Annex and Expansion completed on May 5, 2023, to verify inspection of bollards surrounding the UF6 pad for IROFS UF6CYL-905
8 reviewed work order OM81213, 52 Week Interlocks Test completed on October 23, 2023, to verify functionality of high temperature limit trip for IROFS ADUHOS 908 & 909.
reviewed the following procedures for verification testing of IROFS ADUHOS 908 and 909 o
MCP-203390, Verification of Interlocks ADUHOS-908, System 3, Rev 2
o MCP-203391, Verification of Interlocks ADUHOS-908, System 4, Rev 2
reviewed work order OM73950, 52 Week, Rinse Tank Inserts, completed April 28, 2023, to verify functionality of rinse tanks and measurements for IROFS FA-103 reviewed PM 2026, Pressure Relief Valve 26 Week PM for IROFS ADUVAP 902 reviewed OM 81204, ADU Line 4 Verification of Safety Significant Interlocks for IROFS ADUVAP-903 and 904 reviewed PM 21018, Concrete Barrier for SBG Fuel Tanks for IROFS SBG-401 reviewed OM 81086, Hot Oil Room Dike Inspection for IROFS ADUHON-910 reviewed sample of procedural revisions in ADU Conversion FACILITY SUPPORT 88070 - Permanent Plant Modifications The inspectors conducted a review to verify the licensee had established and implemented a configuration management system to evaluate, implement, and track changes to the facility in accordance with the applicable requirements in 10 CFR 70.72 and the License Application, Management Measures/Configuration Management. The inspectors verified that the licensee had established management measures for changes to the facility in accordance with 10 CFR 70, Subpart H and the License Application, and that the following modifications involving new processes met the requirements in 10 CFR 70.64.
Sample Selection (IP Section 02.01)
The inspectors reviewed samples of licensing documents, changes the licensee determined did not require NRC pre-approval under 10 CFR 70.72, and changes that effected the ISA Summary to select changes/modifications to review. The inspectors selected the following plant modifications, identified as electronic Change Requests (CCFs), to assess whether the licensee conducted evaluations according to their established configuration management system:
CCF 19261 spiking station #1 CCF 21057 uranyl nitrate storage tank reinforcement project CCF 21217 process off-gas ventilation system modification CCF 21103 criticality accident alarm system replacement, phase 14 CCF 21293 replacement of a component with an equivalent
9 Facility Change/Modification Process (IP Section 02.02)
The inspectors reviewed the selected modifications listed in Section 02.02 above to verify the licensee established a configuration management system in accordance with 10 CFR 70.72 and the conditions of the license. Specifically, the inspectors conducted the inspections activities listed below:
Management Measures (IP Section 02.03)
For the selected modifications, the inspectors reviewed the management measures established for affected IROFS (or credited safety controls) to verify the management measures ensured the IROFS (or credited safety controls) were available and reliable to perform their intended function as required by 10 CFR 70.61 and the license. Specifically, the inspectors conducted the inspection activities listed below:
interviewed licensee staff and reviewed a sample of change management procedures to verify the licensee implemented the aspects described in configuration management system procedures and the license application interviewed licensee staff and reviewed samples of affected procedures to verify the licensee followed the procedure control process in accordance with the license application reviewed the following procedures to verify the configuration management system was documented in written procedures and the procedures addressed the aspects in 10 CFR 70.72(a) o TA-500, Columbia Manufacturing Plant Configuration Control, Rev.
42 o
RA-104, Regulatory Review of Configuration Change Authorization, Rev. 35 o
QA-007, Programmable Logic Controller Software Quality Assurance, Rev. 24 o
QA-004, Equipment and Process Qualifications o
FSS-018, Seismic Design Specifications, Revision 1 interviewed licensee staff; reviewed technical and regulatory evaluations, and performed walk-downs of the modifications selected in Section 02.01 above to verify the licensee provided technical bases to support the determination of whether an amendment to the license was required based on the criteria in 10 CFR 70.72 reviewed samples of facility documentation associated with the selected changes to verify the affected documents were updated promptly in accordance with 10 CFR 70.72(e) reviewed samples of configuration management system records, including multi-year projects, for 2021, 2022 and 2023, to verify the licensee submitted a summary with facility changes and applicable revised ISA Summary pages to the NRC in accordance with 10 CFR 70.72(d)
10 reviewed samples of post-modification testing procedures and post-modification tests to verify they ensured adequate implementation of the design and functionality of the following safety systems o
CCF 21103, New Criticality Accident Alarm System
PSEDoc-0001718, Revision 0, Criticality Monitoring System Test Plant for the 4-20mA Installation o
CCF 19261, Spiking Station #1
MCP 202149, Revision 7, HF spiking 31 & #2 Gamma Monitor Calibration
MCP-203388, Revision 3, Verification of Interlocks IROFS ADUHFS-114A
MCP-203447, Revision 2, Verification of HF Spiking Station #2 BPCS High Level Interlock reviewed samples of maintenance and surveillance records of selected modifications to verify the licensee established periodic maintenance and surveillance testing in accordance with the license application o
MCP-202002, process inline pH probe assessment and 3-point calibration for probe numbers 220116, 220117, and 2220123 o
OM81209, #SS4024-5-398538 52-week verification of safety significant interlocks - HF Spiking, completed 7/3/23 o
PSEDoc-0001718, Revision 0, Criticality Monitoring System Test Plant for the 4-20mA installation reviewed licensee training records to verify the staff involved in facility changes were qualified in accordance with license conditions interviewed licensee staff to verify the licensee conducted training on plant modifications in accordance with the license application reviewed samples of condition reports to verify that the licensee identified configuration management, post modification testing, and/or plant modification issues and corrected the condition in accordance with approved corrective action program procedures and the license application reviewed EHS-AUDIT-21-14, Regulatory Component Audit for Configuration Management, Audits and Assessments; Record Keeping and Reporting, completed 11/16/2021.
reviewed three samples of condition reports originating from the above audit findings to confirm completion of corrective actions: IR 2021-12495, 2021-12497, 2021-12498 License Application Changes (IP Section 02.04)
For the selected modifications, the inspectors interviewed licensee staff and reviewed applicable sections of the license application to verify the licensee evaluated license application changes and conducted NRC pre-approval screenings in accordance with the license requirements.
Specifically, the inspectors conducted the inspection activities listed below:
reviewed the licensee application changes submitted to the NRC, titled Westinghouse 10CFR70.72 Facility Change Report, on January 30, 2023, accession # ML23030B855, to verify the licensee complied with their approved change management process reviewed applicable revisions to the license application resulting from facility modifications listed in Section 02.01 of this inspection report
11 reviewed the licensees procedure used to determine whether NRC pre-approval of license application changes is required to verify the that the licensee correctly evaluated license application changes listed in Section 02.01 New Processes at Existing Facilities (IP Section 02.05)
The licensee had not implemented any new facility processes during the previous one-year period, which was the primary focus of the 2023 inspection. Therefore, the inspectors review did not include evaluations of whether the licensee addressed the baseline design criteria and defense-in-depth as stipulated in 10 CFR 70.64.
Records Retention (IP Section 02.06)
The inspectors reviewed a sample of facility documents impacted by the selected modifications to verify the licensee-maintained records of facility changes in accordance with the license requirements and 10 CFR 70.72. The sample of documents included:
process operating procedures training records for process operators, technicians, and engineers process and instrumentation drawings, electrical schematic/wiring/
connection drawings ISA Summary license application
12 INSPECTION RESULTS WER Closed Hematite Ash (EN56199)
WER 2022-003-00 88015
==
Description:==
Uranium Recovery and Recycle Services (URRS) personnel were offloading ash received in 2003 from the decommissioned Hematite site at Dock 3, which is where material enters the manufacturing building for processing. The operators opened the Type A drum and the inner canister, pulled out the bag of ash, and noted the tag on the bag stated that the contents were 5.010% U235. The operators stopped and contacted criticality safety engineering and the safeguards coordinator. The operators were instructed to replace the bag in the canister, place the canister in the drum, segregate the drums that contained material potentially >5%
U235 and space the containers at least 24 inches apart in accordance with generally accepted guidance for criticality safety. An extent of condition was performed using MC&A records of the received material. It was discovered that 7 drums potentially contain a bag of material between 5% and 5.17% U235, with a total of 9 drums with contents potentially at or above 4.96% U235. Total U235 material potentially at or exceeding 5% was 540 grams, which is above the material possession limits of SNM-1107.
NRC inspectors noted that the drum unloading activity was stopped and management and nuclear criticality safety personnel were notified. The unopened bag was placed back in the drum and the drum was segregated from other material. Only seven drums remained to be opened when that bag and discrepancy was discovered. The remaining seven drums that had not been processed were opened and the contents of each drum were checked against the information in their inventory system and the original Hematite paperwork. No discrepancies were identified on the remaining seven drums. Based on inventory records, the item should contain 2,779 grams of uranium at 4.190% U-235 or 116 grams U-235. However, the item tag inside the shipping drum labeled one bag containing 6.526% U-235, and if correct, may contain up to 181 grams of U-235. No other instances of discrepancies between inventory records and actual labels were identified by the licensee during their inspection of the remaining unprocessed drums.
On September 13, 2023, Westinghouse was conducting operations to process the ash contained in the approximately 100 drums that were segregated from the 9 drums that potentially contained ash with greater than 5% enriched U-235 (% U). After processing 95 of these drums, they discovered one drum (H118) that contained one bag of material that was labeled at 6.526% U-235. An enrichment of 4.190% was recorded in their inventory records as well as the original Hematite paperwork.
Drum H118 was segregated along with the original 9 drums from the previous EN awaiting decision on the LAR submitted to process these drums with ash indicated greater than 5%
enrichment. These 10 drums are spaced at least 24 inches apart from all other fissile material as a conservative criticality safety measure based on generally accepted spacing for criticality safety. The licensee made an update to EN 56199 to document this discovery and contacted NRC staff to discuss the issue. This issue has been entered into the licensees corrective action program as IR-2023-8953.
After the initial EN 56199 report and summary included below, a temporary license amendment request (LAR) was approved to allow Westinghouse to continue to store these known containers of legacy Hematite ash greater than 5% enriched U-235 (% U) in the array, location, and reported quantities. Subsequently, the NRC approved LAR that was submitted
13 to allow processing the material in the identified 9 drums of ash with greater than 5%
enrichment.
After receiving a LAR to allow processing the material, the drums were sampled and it was determined that all material was <5.00% U-235, and as such, the licensee was not in violation of their possession limits as detailed in their license. No violations of NRC requirements were identified, and WER 2022-003-00 (EN 56199) is closed.
Unresolved Item (Open)
URI 07001151/2023-04-01 Structural Support and Weld Modifications for the Hot Oil Expansion Tanks 88020
==
Description:==
During the inspection, inspectors observed C-clamps (total eight) between the support beam for the roof and I-beam support that hold up two hot oil expansion tanks. The support I-beam and support I-beam for the roof appeared to provide structural support for the two hot oil expansion tanks located directly above the ceiling of the Hot Oil room in ADU conversion. Inspectors questioned the purpose of the clamps, and the licensee later identified the Hot Oil Expansion tank I-beams and roof support I-beams were not welded together. In addition, the licensee could not provide an engineering evaluation that showed the current configuration was acceptable nor could they provide a bounded accident sequence that analyzed the potential consequences of the beams (4) and/or tanks (2) falling on the Hot Oil room ceiling. The inspectors identified two IROFS that could be impacted by this scenario.
IROFS (ADUHOS-906) is a 1.5-hour fire rated barrier for the walls, floors, doors, and ceiling of the Hot Oil room and IROFS (ADUHOS-907) piping integrity of the Hot Oil System. Either IROFS could be impacted by a fall of the support beams and/or tanks on the ceiling of the Hot Oil room potentially causing a fire or structural breach of the Hot Oil system contents in the Hot Oil room or the Conversion Area. The licensee subsequently performed an engineering evaluation, calculation number GES-2500-CN-SSQ-000001_Revision_0.
Planned Closure Actions: Inspectors plan to evaluate the licensee configuration management process that includes design and engineering evaluations for the initial installation of the hot oil expansion tanks and any additional corrective actions as a result of this inspection during the second quarter of 2024. Therefore, URI 07001151/2023-04-01, "Structural Support and Weld Modifications for the Hot Oil Expansion Tanks," will remain open.
Licensee Actions: The licensee provided a design calculation and additional supplemental information regarding the initial installation of the hot oil expansion tanks at the end of the inspection. The calculation number is GES-2500-CN-SSQ-000001_Revision_0. On 12/26/2023, the licensee completed the welding of the Hot Oil Expansion tanks support I-beams to building roof I-beams. The licensee created issue report 2023-11929 to capture the issue in their corrective action program.
Corrective Action
References:
The licensee documented the issue in their corrective action program as IR 2023-11929.
14 EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On November 16 and 30, 2023, the inspectors presented the integrated inspection results to Annette Pope and other members of the licensee staff.
15 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date 88015 Corrective Action Documents IR 2022-9728 Hematite Ash investigation with analysis results 88015 Corrective Action Documents IR-2023-7862, 2023-7881 Nuclear Criticality Safety Corrective Action Entries Various 88015 Engineering Evaluations CSE-19-A Criticality Safety Evaluation for Oxidation Ovens and Hoods Rev. 5 88015 Engineering Evaluations CSE-5-A Criticality Safety Evaluation for Ammonium Diuranate Bulk Blending System Rev. 2 88015 Engineering Evaluations CSE-9-A Criticality Safety Evaluation for UF6 Cylinder Cleaning and Surveying Facilities Rev. 2 88015 Engineering Evaluations CSE-9-B Criticality Safety Evaluation for Cylinder Wash Rev. 8 88015 Engineering Evaluations NFP 31036 Uranium Oxide Powder 05/13/1998 88015 Engineering Evaluations NSA-TR-05-15 Radiation Source Terms for use in CAAS Detector Placement Analyses at Westinghouse Columbia Rev. 0 88015 Engineering Evaluations NSA-TR-06-02 Westinghouse Criticality Detector Coverage Report, Part 1 Rev. 0 88015 Engineering Evaluations NSA-TR-06-06 Westinghouse Criticality Detector Coverage Report, Part 2 Rev. 1 88015 Miscellaneous 2023 TRN-001-2 Radiation Protection, Criticality Safety, Safety Significant Controls (SSCs) and Safeguards 88015 Miscellaneous 2023 TRN-001-6 Alarms, Emergency Response, Fitness for Duty, Site Security and Threats 88015 Procedures COP-810097 UF6 Bay Handling of UF6 Cylinders Rev. 30 88015 Procedures COP-814700 Bulk Handling / Moderation Control Rev. 32 88015 Procedures COP-814747 Transferring Material from Bulk Containers to Polypaks Rev. 34 88015 Procedures COP-814749 Cleaning Bulk Containers Rev. 23 88015 Procedures COP-833010 Cylinder Cleaning System Rev. 70 88015 Self-Assessments RA-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Outside URRS 06/19/2023 88015 Self-Assessments RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility 06/30/2023
16 Inspection Procedure Type Designation Description or Title Revision or Date Walkthrough Assessments, Pelleting - Pellet Grinding /
D&V Operator 88015 Self-Assessments RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, URRS Bay Operator 06/14/2023 88015 Self-Assessments RAF-316-1 Nuclear Criticality Safety Checklist for NCS Facility Walkthrough Assessments, Bulk Blending Operations 06/16/2023 88015 Work Orders Dispatch #174361 52 Weeks PM20320, SI-Safety, Inspection of Moderation Controlled Barriers 10/03/2023 88015 Work Orders Dispatch #191463 26 Weeks OM85150 SI-Safety, V-09 Column Overflow Verification 07/03/2023 88020 Calculations CALC-194-8169-01 Fire Hazards Analysis Combustible Loading Calculation Rev. 0 88020 Corrective Action Documents IR-2023-10484 UF6 release at Conversion Line 3 Tretter Valves 10/23/2023 88020 Corrective Action Documents IR-2023-10910 Vaporizer Steam Valve 11/01/2023 88020 Corrective Action Documents IR-2023-1844 Individual Observed Moving an Assembly with Monorail Host Qualification ECL-005 Expired 02/21/2023 88020 Corrective Action Documents IR-2023-2945 Audit # EHS-AUDIT-23-7, Regulatory Component Audit for the Integrated Safety Analyses (ISA) Program-CAP Type Regulatory Identified IROFS Issues 03/22/2023 88020 Corrective Action Documents IR-2023-3589 Vendor Fabrication does not meet SSC Requirements 04/06/2023 88020 Corrective Action Documents IR-2023-4695 Deficiencies Observed Outside URRS Secondary Containment Dikes 05/11/2023 88020 Corrective Action Documents IR-2023-4720 Fuel Rack Inspection Issues 05/12/2023 88020 Corrective Action Documents IR-2023-6402 Line 1 Xomox Three-Way Valves Pressure Loss Greater than 3 Psig During Leak Test (OM81026) on 4/29/2023 4/29/2023 88020 Corrective Action Documents IR-2023-7357 UF6 Release Bay Operations 07/27/2023 88020 Drawings 347F04PI02 Sheet 3 Hot Oil Systems 3 and 4 Expansion Tanks T-1375 and T-1383 Rev. 12 88020 Drawings 347F04PI02 Sheet 6 Hot Oil Systems 3 and 4 Rev. 7 88020 Drawings 448F13P102 Final Assembly/Washing & Vacuuming Wash Tanks Rev. 9
17 Inspection Procedure Type Designation Description or Title Revision or Date 88020 Drawings 612F01AR03 UF6 Cylinder Flat Storage Pad Expansion Storage Pad Expansion Arrangement 88020 Drawings 612F01AR04 UF6 Cylinder Flat Storage Pad Expansion Arrangement Rev. 2 88020 Engineering Evaluations CSE-17-B Criticality Safety Evaluation for the Final Assembly Wash Pit Rev. 8 88020 Engineering Evaluations ISA 03 ADU Conversion System Rev. 18 88020 Engineering Evaluations NSA-TR-COL-53 Seismic Evaluation of Equipment and Tanks 10/28/2013 88020 Engineering Evaluations PSEDoc-0003335 Hot Oil System Preliminary PHA Report 06/11/2010 88020 Engineering Evaluations PSEDoc-0003368 Revalidation of the PHA of the ADU Conversion Process at the Westinghouse Nuclear Fuel Facility Rev. 0 88020 Fire Plans FHA-13-001 Fire Hazard Analysis for Columbia Fuel Fabrication Facility Rev. 3 88020 Fire Plans Pre Fire Plan 70 UF6 Bay (CHEM 04) and Hot Oil Room (CHEM 05)
Rev. 1 88020 Miscellaneous Current User Training Status for Control Room Operators 11/29/2023 88020 Miscellaneous Baseline Integrated Safety Analysis and ISA Summary Handbook Rev. 5 88020 Miscellaneous 150000093438 Therminol 66 Heat Transfer Fluid Safety Data Sheet Rev. 2.6 88020 Miscellaneous ECL 2013-005 Monorail Crane Training 11/28/2023 88020 Miscellaneous ECL-2023-005 Monorail Crane Checklist Requirements 11/19/2023 88020 Miscellaneous ECL-213-001 Bridge Crane Training 11/28/2023 88020 Miscellaneous ECL-213-001 Bridge Crane Checklist 11/19/2023 88020 Miscellaneous PM73061, SS4722-5 Safety Inspection Stand and Wash Pit Seismic Restraint -
104 PM-Template 88020 Operability Evaluations OM81086 Hot Oil Room Dike Inspection 05/02/2023 88020 Operability Evaluations OM81204 ADU Line 4 Verification of Safety Significant Interlocks, Alarms, and Passive Engineered Controls 07/21/2023 88020 Operability Evaluations OM85019 UF6 Pad Annex Bollard Inspection 05/04/2023 88020 Operability Evaluations PM 2026 Pressurizer Relief Valves Conversion Lines 1 - 4 07 and 08 2023 88020 Operability PM20189 13 Week PM, Fire Alarm System, Damper 10/02/2023
18 Inspection Procedure Type Designation Description or Title Revision or Date Evaluations 88020 Operability Evaluations PM21018 Concrete Barriers for SBG Fuel Tanks 08/30/2023 88020 Procedures CA-006 Columbia Plant Training Delivery System Rev. 36 88020 Procedures CA-044 Interim Compensatory Measures (ICM) 0 88020 Procedures COP-810094 Replacement of Plugged Pigtail on UF6 Cylinder Rev. 9 88020 Procedures COP-810099 UF6 Vaporizer Rev. 39 88020 Procedures COP-814001 Hot Oil Systems Rev. 31 88020 Procedures COP-816031 Cleaning of Polypak Carriers for Weld Repair Rev. 1 88020 Procedures COP-816037 Scrap Uranium Recovery Equipment Wash Process Rev. 2 88020 Procedures COP-816037 Scrap Uranium Recovery Equipment (SURE) Wash Process Rev. 2 88020 Procedures MOP-730502 Fuel Assembly Cleaning - General Rev. 59 88020 Procedures MOP-730700 General Operating Procedure - Packing Area Rev. 25 88020 Procedures MOP-730753 Pack Fuel Assembly - Traveler Package Rev. 61 88020 Procedures MOP-735303 General Operating Procedure-Fuel Assembly Area Rev. 74 88020 Self-Assessments EHS-AUDIT-23-2 Regulatory Component Audit for Procedures, Training and Qualification; Human Performance; QA Elements 06/22/2023 88020 Self-Assessments EHS-AUDIT-23-10 Formal Compliance Audit Report of Areas of ISAs 09/08/2023 88020 Self-Assessments EHS-AUDIT-23-7 Regulatory Component Audit for the Integrated Safety Analyses Program 03/24/2023 88020 Self-Assessments LTR-EHS-23-23 2022 Redbook Failure Evaluation Report 05/24/2023 88020 Work Orders 177634 Pipeline Inspection Sheet, SYF-220, Conversion, All Hot Oil Piping on DWG 04/21/23 88020 Work Orders OM73050-SS4402-1-366839 OM Safety Rinse Tanks Inserts -52 Week OM 04/28/2023 88020 Work Orders OM81086, SS3983-1-374781 SI-Safety, Hot Oil Room Dike Inspection - 52 Week 05/02/2023 88020 Work Orders PM81018-SS4210-371042 Safety, Hot Oil System External Mechanical Integrity Inspection - 52 Weeks 04/21/2023