ML21298A181

Fuel Fabrication Facility Integrated Inspection Report 07001151/2021003

ML21298A181
Person / Time
Site:	Westinghouse
Issue date:	10/25/2021
From:	Eric Michel Division of Nuclear Materials Safety II
To:	Annacone M Westinghouse
References
IR 2021003
Download: ML21298A181 (14)

Text

October 25, 2021

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

SUBJECT:

COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2021003

Dear Mr. Annacone:

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

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

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

Sincerely,

/RA/

Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

Docket No. 07001151 License No. SNM-1107

Enclosure:

As stated

cc w/ encl: Distribution via LISTSERV

ML21298A181 X SUNSI Review X Non-Sensitive X Publicly Available Sensitive Non-Publicly Available

OFFICE RII/DFFI RII/DFFI RII/DFFI NAME P. Startz T. Sippel E. Michel DATE 10/15/21 10/15/21 10/25/2021

U.S. NUCLEAR REGULATORY COMMISSION Inspection Report

Docket Number: 07001151

License Number: SNM-1107

Report Number: 07001151/2021003

Licensee: Westinghouse Electric Company

Facility: Columbia Fuel Fabrication Facility

Location: Hopkins, SC

Inspection Dates: July 26, 2021 to July 29, 2021

Inspectors: T. Sippel, Fuel Facility Inspector P. Startz, Fuel Facilities Inspector

Approved By: Eric C. Michel, Chief Projects Branch 2 Division of Fuel Facility Inspection

Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitori ng the licensees performance by conducting an integrated inspection at Columbia Fuel Fabrication Facility, in accordance with the fuel cycle facility inspection program. Thi s 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 info rmation.

List of Violations

No violations of more than minor significance were identified.

Additional Tracking Items

None.

2 PLANT STATUS

The Westinghouse Facility converts uranium hexafluoride (UF6) i nto uranium dioxide using a wet conversion process and fabricated fuel assemblies for use i n commercial nuclear power reactors. During the inspection period, normal production activ ities were ongoing.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of th e inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise note d. Currently approved IPs with their attached revision histories are located on the public web site 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 inspe ction activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cyc le Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed sel ected procedures and records, observed activities, and interviewed personnel to asse ss licensee performance and compliance with Commission rules and regulations, license condi tions, site procedures, and standards.

SAFETY OPERATIONS

88015 - Nuclear Criticality Safety

The inspectors evaluated selected aspects of the licensees Nuc lear Criticality Safety program to verify compliance with selected portions of 10 CFR 70, inclu ding 70.61, and 70.62, Chapter 6.0, Nuclear Criticality Safety (NCS) Program, of the facilit ys license application, and applicable licensee procedures.

Criticality Analysis (IP Section 02.01)

The inspectors interviewed licensee staff and reviewed nuclear criticality safety evaluations (CSEs), and associated calculations, to verify compliance with 10 CFR 70 and applicable sections of the license application, including 6.1.1, 6.1.3, 6. 1.4, 6.1.5.2, and 6.1.6. Specifically, the inspectors interviewed licensee staff and reviewed CSEs for scrubbers as described below:

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

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

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

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

• The inspectors interviewed licensee NCS engineers and the NCS manager about the review, approval, and implementation of CSEs and othe r NCS documentation. The inspectors interviewed licensee NCS staff ab out validation and the use of computer codes in the licensee's crit icality safety program.

3 Criticality Implementation (IP Section 02.02)

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

• IROFS VENT-S2A2B-103, -106, and -122 which are passive IROFS preventing solutions from overflowing/backflowing into unfavora ble geometries. The inspectors walked down these controls in the fi eld to verify their presence and condition, and reviewed drawings and mainten ance records.

• IROFS VENT-S2A2B-116, -117, and -118 which are passive IROFS controlling the credited geometry, absorption, and reflection p roperties of the scrubber sump. The inspectors walked down these control in the field to verify their presence and condition and reviewed maintenance records.

• IROFS ADUSCRA-147 and VENT-S2A2B-131 which are credited as act ive and passive IROFS to prevent backflow. The inspectors walked do wn these controls in the field, reviewed drawings and maintenance record s.

• IROFS VENT-S2A2B-107 and -108 which are administrative IROFS t o prevent foreign objects from causing blockages in the scrubber. The inspectors walked down portions of these controls and reviewed procedures and maintenance records.

• IROFS VENT-S2A2B-109 which is an administrative IROFS to perfo rm a routine inspection and cleanout. The inspectors reviewed mainte nance records and condition reports.

• IROFS VENT-S2A2B-110 and -124 which are administrative IROFS controlling concentration in the scrubber sump through routine sampling, the inspectors walked down the lab that processes the samples, inte rviewed lab personnel, and reviewed procedures and sample results.

• IROFS VENT-901 which is an administrative IROFS that limits ma ss accumulations through routine gamma surveys of selected ductwor k; the inspectors also interviewed licensee staff and reviewed applica ble procedures, survey records, and related drawings.

Criticality Operational Oversight (IP Section 02.03)

The inspectors assessed the NCS staffs oversight of plant oper ators, procedures, and operations of systems involving special nuclear material to ver ify compliance with 10 CFR 70 and applicable sections of the license application. Specific ally, the inspectors performed the following activities:

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

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

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• Reviewed Criticality & Radiation Safety NSQT, dated September 30, 2020, which is NCS training that covers criticality control parameter s, past accidents and other NCS topics.

• Observed a licensee NCS engineer conduct a weekly Facility Wal kthrough Assessment (FWA) in the Scrap Cage area and reviewed the FWA sc hedule and FWA records for 2021.

Criticality Programmatic Oversight (IP Section 02.04)

The inspectors reviewed NCS program procedures, and NCS staff q ualification records to verify compliance with 10 CFR 70 and applicable sect ions of the license application, including 6.1.3.3, and 6.1.10. Specifically, the i nspectors interviewed licensee NCS staff, reviewed the following documents, and conducted a wa lkdown as described below:

• COP-815023, "S-2A and S-2B Inspection and Clean Out," Rev. 4, which provides instructions for the periodic inspection and cleanout of the inside of scrubber system components and includes the implementation of I ROFS VENT-S2A2B-108, -109, -111.

• Various WOs related to the surveying, inspecting, and cleaning ductwork and scrubber systems (e.g., WO 874993).

• COP-814325, "Scrubbers 2A & 2B," Rev. 31, which includes instr uctions for taking the IROFS VENT-S2A2B-110 and -124 concentration samples of the scrubber sump water.

• RAF-125-5, "Nuclear Criticality Safety Engineer Training Check list," dated March 30, 2021, which documented the training and qualification of a recently qualified licensee NCS engineer.

• Licensee NCS program procedures, RA-303, RA-305, RA-313, and R A-315 which the licensee recently revised.

• The inspectors also walked down the laboratory where the scrub ber sump samples are analyzed for uranium concentration and interviewed lab personnel.

Criticality Incident Response and Corrective Action (IP Section 02.05)

The inspectors reviewed the licensees criticality accident ala rm system (CAAS) and corrective action program (CAP) to verify compliance with 10 CF R 70 and applicable sections of the license application, including 6.1.8. Specifica lly, the inspectors reviewed documents, and/or interviewed licensee staff concerning the fol lowing:

• NCS-related corrective action records, including IR-2021-2474, IR-2021-3870, IR-2021-4738, IR-2021-4957, and IR-2021-5048

• the evaluation and use of portable criticality detection devic es

RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities

The inspectors evaluated select aspects of the licensees Trans portation Activities program to determine whether the licensee has established and is maintaini ng an effective, management-

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

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

• receipt contamination surveys, physical inspections, and off-l oading of full 30B cylinders from their UX-30s (overpacks) and placement into a UF6 storage yard

• inspection/removal of tamper indicating devices (seals) from U X-30 overpacks

• removal of the UX-30 overpack lids

• receipt, inspections, and off-loading of incoming LR-230 urany l nitrate hexahydrate (UNH) contents

• shipment of three truckloads of fuel assembly traveller shippi ng packages

Preparation of Packages for Shipment (IP Section 02.01)

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

• traveller package refurbishment bay including spare parts, pro cedures, and calibrated tooling

• ongoing preparations of a traveller package

• Nuclear Material Transaction form 741 for Manifest 52-2140933

• Nuclear Material Transaction form 741 for Manifest WS-53455 149

• TR-501 Shipment of Liquid Low Enriched Uranium, Rev. 7

Delivery of Completed Packages to Carriers (IP Section 02.02)

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

• Shipping Manifest WS-53457-0-001, shipment of LSA-1 waste mate rials

• Shipping Manifest ISEU (000001-219 through 000023-221), shipme nt of LSA-1 waste materials

• Shipping Manifest ISEU (000012-229 through 000039-232), shipme nt of LSA-1 waste materials

6 Receipt of Packages (IP Section 02.03)

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

• COP-836047, "Uranyl Nitrate Offloading from LR-230 Containers"

• CF-83-239, "LR-230 Offload Checklist"

• TR-300, "Unload UF6 Cylinders"

Records and Reports (IP Section 02.04)

The inspectors examined the licensees recordkeeping and report s to verify compliance with the regulations above. Specifically, the inspectors reviewed th e following:

• Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 3, 2021

• Certificate of Disposal, Receipt LSA-1 waste for disposal, dat ed March 14, 2021

General License Requirements (IP Section 02.05)

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

• Certificate of Compliance No. 9291 for the LR-230 container

• Model UX-30 Certification Type B (U) F Fissile Package Design Certificate USA/9196/B (U) F-96, Rev. 34

• Model 30B Certification Type AF Fissile Package Design Certifi cate USA/0411/AF-96, Rev. 12

Management Controls (IP Section 02.06)

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

• COLUMN MC&A Software Guide, Form 741, Domestic UF6 Gas Receipt s

• LCTP-20-06, "Management Assessment of the LR-230 Packaging," R ev. 0, dated December 21, 2020

• LCPT-21-02, "Management Assessment of the Traveller Packaging, " Rev. 0, dated March 30, 21

• LCTP-21-04,"Management assessment of UF6 incident during trans port,"

Rev. 0, dated June 2, 2021

Indoctrination and Training Program (IP Section 02.07)

The inspectors conducted interviews, reviewed training, and ind octrination documentation, and observed activities for shipping container engineering staf f involved in transport

7 activities to verify compliance with Chapter 3 of the License A pplication. Specifically, the inspectors:

• reviewed ESH-015 DOT Radioactive Materials training records, c lassroom training required every three years, for employees 4889 and 30696

Quality Assurance Program (IP Section 02.08)

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

• COP-831010, "Shipping Low Level Radioactive Waste," Rev. 33, d ated May 14, 2020

• LCPT-21-02, "Nuclear Fuel Transport assessment"

• LCPT-20-06, "Management assessment of the LR-230 packaging"

Audit Program (IP Section 02.09)

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

• LCPT-21-04, Management assessment of UF6 incident during tran sport

• Incident Report 2020-4142

• Incident Report 2020-11489

Procurement and Selection of Packagings (IP Section 02.10)

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

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

Rev. 8, dated November 5, 2019

• Sketch 938603-22, "Traveller Shipping Container," Rev. 11, iss ued August 10, 2017

Preparation of Packages for Shipment (IP Section 02.11)

The inspectors examined the licensees package markings and doc umentation to verify compliance with applicable parts of the federal regulations abo ve. Specifically, the inspectors reviewed:

• MOP-500153, "Pack and Unpack Fuel Assembly - traveler package, " Rev. 3, dated July 30, 2020

• MOP-730753, "Pack Fuel Assembly - traveler package," Rev. 54, dated May 13, 2021

8 Periodic Maintenance of Packagings (IP Section 02.12)

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

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

Rev. 8, dated November 5, 2019

• Traveller Refurbishment Verification Checklist, Package Serial Number TX-200, completed June 12, 2021

• TR-229, "Traveller Recertification," Rev. 2, dated June 21, 20 21

Records, Reports, and Notifications (IP Section 02.13)

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

• 938603-22, "Traveller Shipping Container Checklist"

• Licensee Investigation Report 2020-13034, "LR-230 discovered p ackage defect," dated November 12, 2020

• Licensee Investigation Report 2020-4142, "LR-230 tamper seal d iscovered to be improperly applied," dated March 26, 2020

• Licensee Investigation Report 2021-1944, "MCC container discov ered cracked during preparation for loading," dated February 16, 202 1

INSPECTION RESULTS

No issues were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

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

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