ML20137P130

Insp Rept 70-1257/97-03 on 970303-07.No Violations Noted. Major Areas Inspected:Aspects of Plant Operations, Engineering,Maint & Surveillance Testing

ML20137P130
Person / Time
Site:	Framatome ANP Richland
Issue date:	04/04/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137P127	List: ML20137P122 ML20137P130
References
70-1257-97-03, 70-1257-97-3, NUDOCS 9704090146
Download: ML20137P130 (9)

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t ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION REGION IV f Docket No.: 70-1257 License No.: SNM-1227 Report No.: 70-1257/97-03

. Licenseo: Siemens Power Corporation (SPC)

Facility: . Siemens Power Corporation -

Location: Richland, Washington Dates: March 3-7,1997 inspectors: C. A. Hooker, Senior Fuel Facility inspector, Region IV T D. Reidinger, Senior Fuel Cycle inspector, Region lil Approved By: Frank A. Wenslawski, Chief Materials Branch j

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Attachment:

Supplemental Inspection Information j I

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J I 9704090146 970404 PDR ADOCK 07001257 C PDR f

2 EXECUTIVE

SUMMARY

Siemens Power Corporation NRC Inspection Report 70-1257/97-03 This routine announced inspection included aspects of plant operations / engineering, and maintenance and surveillance testing.

Plant Operations /Enaineerina

• The inclusion of a summary of accident er.alyses for chemical, radiological, and fire safety in criticality safety analyses was considered to be consistent with an integrated approach in the performance of safety analyses (Section 1.1).

• The licensee's oversight of contractor activities for the new Dry Conversion Facility (DCF) appeared good, and newly installed equipment and instrumentation were consistent with the piping and instrument diagrams (P&lDs) (Section 1.1).

• The use of a designator on the DCF P&lDs to identify items used as a criticality safety control was considered a new good practice (Section 1.1).

• No discrepancies were identified between the P&lDs and installed equipment for the new mop powder dissolution process (Section 1.2).

• The lack of some employees understanding the fundamentals of their thermoluminescent dosimeters (TLDs) indicated a need for the licensee to enhance its training program (Section 1.3).

• Licensee management promptly responded to the inspector's identification of an unsafe work practice related to the f ailure of an individual to use fall protection equipment (Section 1.3).

Maintenance / Surveillance Testina

• The licensee was adequately implementing its surveillance program for the criticality accident monitoring system (Section 2).

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, I Report Details - l i

Summarv of pia' nt Status The plant was operating both of its wet chemical conversion lines and the existing pilot dry . b conversion process. Fuel pellet production was'also in progress. There was no fuel rod ~

fabrication or fuel bundle assembly operations in progress. Ongoing building construction

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consisted of continuing with the new DCF and an addition to the Lagoon Uranium -

Recovery (LUR) process.

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i 1 Plant Operations / Engineering l 1.1 RCE <

l l a. lnsoection' Scope (88020)  ;

l' The inspectors toured the DCF with cognizant licensee personnel to observe and l discuss the installation of equipment and process systems. The inspection also 1 included a review of one completed criticality safety analysis (CSA) No. D810,

- Revision 0, " Dry Conversion Vaporization System," dated February 7,1997. The l inspection also included verification of installed equipment against P&lDs. ]

I b. Observations and Findinas 1

The inspectors noted that the CSA for the vaporization system adequately described the vaporization process and associated equipment, assumptions important for the evaluation, accident conditions that could lead to a potential criticality, and barriers against a::cidental criticality. The criticality limits and controls required to demonstrate the double contingency principle were adequately described. The required instrumentation and surveillances, design features, and applicable drawings were also detailed in the CSA. The calculated safety margin (K.,,) for both normal

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and abnormal conditions was adequately defined and in conformance with the a license requirements. As a new feature, the CSA also included a basic summary of accident analyses for chemical safety, radiological safety, and fire safety. The e

source of the hazard, detection method, containment / protective feature and intervention were conveniently tabulated in the CSA. An independent review of the CSA was performed by a qualified individual, and the CSA provided sufficient detail J for peer review. - .

Although some of the minor piping, valves,.and instrumentation had not been

installed in the vaporization system at the time of inspection, the inspectors did not  !

identify any inconsistencies between the installed equipment and the P&lDs or {

deviations from the CSA during walkdowns of the system. The inspectors also j noted that the licensee utilized a designator ("[C)") on the P&lDs to identify items '

used as a criticality _ safety control. When all of the valves and instrumentation have e

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been installed, the criticality safety component plans to revisit the system to ensure there are no changes that would affect the CSA.

The inspectors noted that the responsible system engineer and project management were actively observing and inspecting the installation process equipment and systems being installed by the contractors.

Since none of the systems had been completed, there were no functional or acceptance tests to review during this inspection. The review of pressure tests conducted for certain portions of the dry conversion reactor off gas and calciner off gas systems, and certain portions of the steam and condensate systems did not reveal any concerns with the integrity of these systems at the current phase of construction. Startup testing of one of the new dry conversion lines was scheduled for early May 1997.

Table 1-4.1, Part I of the license, provides a matrix of major system components requiring criticality safety controls and the types of controls applied to those components. By letter dated February 21,1997, the licensee requested that the autoclaves for the DCF be included in Table 1-4.1. The inspectors noted that the licensee's revision for Table 1-4.1 was not complete as it only referenced controls for the dry conversion pilot plant, and did not include a reference to the new DCF.

This matter was discussed with the licensee. By letter dated March 7,1997, the licensee submitted to the NRC a change to Table 1-4.1 to include the new DCF.

The inspectors noted that the licensee was actively working on the development of new operating procedures for the DCF. The licensee had assigned two lead operators to work with the responsible system engineers in the development of the procedures. Currently, approximately 18 operating procedures were in various stages of draft form.

The inspectors brought to the attention of the licensee, the buildup of empty cardboard boxes and packaging materials that reduced the fire safety of the facility.

The licensee acknowledged the inspectors' observation and planned a general cleanup of the facility. The inspectors also noted the appearance of considerable dust and similar debris from welding and grinding operations and discussed the benefits of protecting openings in piping systems, vessels, and other equipment from such materials. This matter was also acknowledged by the licensee,

c. Conclusions The inclusion of a summary of accident analyses for chemical, radiological, and fire safety in the CSA was considered consistent with an integrated approach in the performance of safety analyses. No discrepancies were identified between installed equipment and the P&lDs or from equipment described in the CSA. The identification of criticality safety control items on the P&lDs was considered a new good practice. Licensee oversight of contractor activities appeared good.

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l 1.2 Other Facility Modifications and Additions

a. insoection Scoce (88020)

Inspection Report 70-1257/97-01, dated January 30,1997, described the licensee's construction of a new building for the existing LUR facility and the installation of a new mop powder processing system. The above report also described the review of engineering change notices (ECNs) associated with the new projects. The status of the LUR facility had not substantially changed from that previously described, therefore the inspectors focused on reviewing the installction of the new mop powder processing system. The review also included a walkdown of the system with the project engineer and verifying equipment installation against the applicable P&lDs. Although the CSA had not been completed, general aspects of criticality safety for this system were dist ssed with the criticality safety component.

b. Observations and Findinas The inspectors noted that a majority of the piping and process equipment had been installed. The installed piping systems and equipment appeared consistent with the P&lDs at this phase of the project. Related to this new process, one part (unfavorable geometry poisoned rotary drum filters) of the process was considered as a new major component not included in Table 1-4.1, Part 1 of the license. The licensee acknowledged that the filter needed to be added and approved in the license prior to startup of the system. No concerns were identified at this stage of construction of this new process.

c. _Qonplusions No discrepancies were identified between the P&lDs and installed equipment or configuration of the process.

1.3 Miscellaneous Operational items

a. Inspection Scone (88020)

The inspectors toured various plant areas to observe ongoing worker and operational activities.

b. Observations and Findinas During facility tours, the inspectors observed that storage of special nuclear material (SNM) was in accordance with the licensee's posted criticality safety limit cards. SNM storage containers were adequately labeled with the uranium content and enrichment. Spacing of SNM within and between other SNM storage arrays was consistent with the licensee's criticality safety specifications and postings.

The integrity of chemical processing systems appeared adequate. With the exception of that described above for the new DCF, housekeeping was generally good throughout the licensee's facilities.

Interviews by the inspectors regarding the fundamentals of dosimetry indicated that employees were not fully cognizant of the type of radiation their TLDs measured.

When questioned by the inspectors, several employees stated that the TLDs measured alpha, beta, gamma and neutron radiation. Part 1, Section 3.5.2 of the license states, in part, that persons requiring radiation exposure monitoring shall wear beta-gamma sensitive dosimeters. The beta-gamma dosimeters shall be supplemented, as appropriate, by neutron dosimeters. The licensee informed the inspectors that the' would review the matter and conduct refresher training as warranted.

During a tour of the Engineering Laboratory Operations building, the inspectors observed two individuals using a crane to remove a large piece of equipment from the basement of the building to the upper floor level (10 to 15 feet between floor levels). The inspectors noted that the fall protection guard rails had been removed from the edge of the opening on the upper floor level, and one of the individuals was working at, and over the edge of the opening on the upper floor level with no fall protection (lifeline). The inspectors immediately brought this matter to the workers attention. When asked by the inspectors, the workers acknowledged the requirements for fall protection. This matter was immediately brought to licensee management's attention who quickly took command of the situation. The licensee subsequently informed the inspectors that appropriate actions would be taken to preclude recurrence. The inspectors had no further questions related to this matter.

During a tour of the incinerator f acility early in the inspection, the inspectors observed considerable liquid in the exhaust stack air sample flowmeter, down stream of the sample filter. The licensee was aware of the problem and was changing the sample filter daily while engineering was evaluating the matter. The incinerator was subsequently shut down to enable further investigation of the heat j trace system. The licensee found that the thermostat for the heat trace system had 1 failed. The licenst;a determined that the heat trace on an unused sample line may have overloaded the thermostat. Licensee tests indicated that the liquid in the sample flowmeter did not affect the calibrated flow rate of the sample, and the sample filter was being appropriately dried prior to counting. The licensee planned to disconnect the heat trace to the unused sample line and make improvements to the system to eliminate the moisture problem. The inspectors determined that the licensee was adequately addressing the problem and had no further questions on the matter.

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c. Conclusions The posting of criticality safety administrative controls appeared adequate. The  ;

failure to use fall protection equipment was considered as an unsafe work practice.

The lack of individuals understanding the fundamentals of their TLDs indicated a need for the licensee to enhance its training program. ,

2 Maintenance / Surveillance Testing

a. Insoection Scope (88025 and 88020)

The inspectors reviewed selected documents and discussed a proposed plant installation of additional nuclear criticality detector alarms with the responsible project engineer. The inspectors also conducted a walkdown of the criticality alarm system and reviewed the criticality alarm system surveillance records. The inspectors also reviewed the licensee's electrical prints for the critical detectors and alarm systems. Specific procedures and licensee documents reviewed were:  ;

• EMF Procedure No. 30, " Nuclear Criticality Safety Standards," Rev. 28, dated December 27,1996.

• ANF Instruction Manual No. 394, " Criticality Alarm System," Rev. 2, dated December 20,1994.

• Nuclear Criticality Detectors (NCD) Calibration Procedure No. 300, Rev.1, dated January 10,1997.

• NCD Calibration Procedure No. 300, dated October 18,1985.

• Instrument Repetitive Maintenance (IRM) No.1344, " Calibration Data Results," dated May 1,1996.

• P&lD No. EMF-601-685, " Criticality System Comparator input Power," dated September 9,1993.

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b. Observations and Findinas Criticality alarm instrumentation appeared consistent with license requirements regarding installation and location. The NCD calibration reports for 1996 indicated that the annual calibration and surveillance tests, and quarterly reliability tests of the criticality monitoring system were performed at the required frequencies and in accordance with licensee procedures. The licensee had reduced the frequency of the current quarterly system tests to semi-annual by counting the semi-annual evacuation drills as a quarterly test. The new test schedule is anticipated to reduce the amount of time the howlers are actuated. In turn, less damage would occur to

' the howlers which currently are in short supply.

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1 The evacuation drills test the reliability of the entire system. The reliability tests included verification of the failure alarms, indicators on the NCD comparator panels, and verification of each howler alarm. The licensee's records indicated that no unusual conditions had been identified.

The licensee has planned to install additional howler alarms at the south end of the plant site to provide additional audibility coverage for the new LUR building and mobile waste processing facility.

The inspectors noted that although the calibration steps in NCD Calibration Procedure No. 300, Revision 1, and NCD Calibration Procedure No. 300 did not ,

. sequentially match some of the corresponding steps in the associated calibration data sheets, all steps were completed as required. The licensee agreed to revise the data recording sheets as warranted.

The configuration of the criticality alarm panels were reviewed and no anomalies were noted. However, the inspectors noted that the electrical breaker for input power supply to the NCD comparators was rated at 40 amps on the electrical print. l The inspectors observed that the actual breaker installed was rated at 30 amps. l The licensee indicated that the electrical print was incorrect and revised the print.

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c. Conclusion The licensee was adequately implementing its surveillance program for the criticality ,

accident monitoring system.

1 Exit Meeting Summary i The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 7,1997. The licensee acknowledged  ;

the findings presented.

l Although proprietary information was reviewed during this inspection, such information is not knowingly described in this report. l l

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l ATTACHMENT i i

SUPPLEMENTAL INSPECTION INFORMATION ,

i PARTIAL LIST OF PERSONS CONTACTED i Licensee B. F. Bentley, Manager, Plant Operations  ;

J. B. Edgar, Senior Engineer, Licensing j B. N. Femreite, Vice President, Engineering and Manufactunng E. L. Foster, Supervisor, Radiological Safety i J. W. Helton, Manager, Plant Engineering ,

- L. J. Maas, Manager, Regulatory Compliance l C. D. Manning, Lead Criticality Safety Specialist  !

J. J. Payne, Supervisor, Chemical Operations l

. J. H. Phillips, General Supervisor, Chemical Operations  !

.T. C. Probasco, Manager, Safety .  ;

l. J. Urza, Manager, Manufacturing Technology l R. E. Vaughan, Manager, Safety, Security and Licensing ,

G. N. Ward, Manager, Manuf acturing Engineenng  !

l INSPECTION PROCEDURES USED IP 88020: Operations Review IP 88025: Maintenance / Surveillance Testing )

. LIST OF ACRONYMS USED CSA criticality safety analysis DCF Dry Conversion Facility ECN engineering change notice LUR Lagoon Uranium Recovery NCD nuclear criticality detector P&lD piping and instrument diagram SNM special nuclear material TLDs thermoluminescent dosimeters l

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