ML20249A214
| ML20249A214 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 06/04/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20249A207 | List: |
| References | |
| 70-1201-98-02, 70-1201-98-2, NUDOCS 9806160185 | |
| Download: ML20249A214 (20) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1201 License No.: SNM-1168 Report No.: 70-1201/98-02 Licensee: Framatome Cogema Fuels. Inc.
Facility: Lynchburg Manufacturing Facility Location: Lynchburg, VA Dates: May 11-15, 1998 Inspectors: D. A. Ayres. Senior Fuel Facility Inspector D. A. Seymour Senior Fuel Facility Inspector Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 2 9806160185 980604
{DR ADOCK 07001201 PDR
EXECUTIVE
SUMMARY
Framatome Cogema Fuels NRC Inspection Report 70-1201/98-02 This routine, unannounced inspection focused on the observation and evaluation of the licensee's operations, maintenance, training. transportation, and waste management programs. The report covers a one week period and includes the results of inspection efforts of two regional fuel facility inspectors.
' Based upon the results of this inspection, the licensee's operations.
maintenance, training, transportation and waste management programs were acceptable. Violations of license requirements were found in the areas of transportation and waste management. The inspection identified the following aspects of the program as outlined below:
Plant Ooerations
- The licensee was meeting requirements for storage of special nuclear material. Labeling of outdoor containers was somewhat inconsistent, but was within license and procedural requirements (Section 2.a).
- Housekeeping had improved compared to past inspections. However, one partially blocked emergency exit path, three unrestrained compressed gas cylinders, and rusting latches on fire extinguisher cabinets were identified as problem areas (Section 2.b).
Waste Manaaement
- The licensee's management controls of liquid waste did not take into consideration the solubility of uranium in the water of the retention tanks before the water was transferred to the municipal water treatment facility. A. violation was identified for this issue (Section 5.a).
Transportation e The licensee demonstrated initiative in performing a thorough and detailed root cause investigation for a shipment from Framatome Technologies. Inc., which arrived at its destination with damage to the shipping container. An non-cited violation was identified for the failure to use the proper packaging for the shipment (Section 6.a).
Maintenance / Surveillance e Maintenance of safety systems were being performed in accordance with internal procedural requirements. Certain instructions for performing air flow audits and operability checks ware not included in the applicable safety procedure. An inspector followup item on this lack of instruction was identified (Section 7.a).
Trainina e- The licensee's General Employee Training included the topics required by the License Application (Section Ba).
t REPORT DETAILS l
- 1. Summary of Plant Status !
l This report covered the efforts of two regional inspectors during a one j week period. However, the inspectors spent portions of two days during i the week at the adjacent BWXT plant to provide coverage for the absent l Resident Inspector. Rod loading operations were shut down at Framatome during the entire week. There were no unusual plant operational occurrences during the onsite inspection.
- 2. Plant Doerations (IP 88020) (03) j
- a. Implementation of Storaae Safety Controls (03.04)
(1) Insoection Scoce Safety controls identified for storage of pellets, rods, assemblies, and contaminated equipment were reviewed for compliance with requirements in procedures and postings.
(2) Observations and Findinas The inspector observed the storage of completed assemblies I in the fuel assembly storage racks. The ins)ector also observed licensee personnel performing assem)1y handling operations to place a completed assembly into the storage racks. The inspector noted that the operators used good handling techniques and did not allow the assembly being moved to pass too close to stored assemblies. The inspector noted no departure from posted requirements for storage or handling of fuel assemblies.
The inspector observed storage of boxes of pellets to be loaded into fuel rods. The inspector also observed fuel assembly packages being readied for shipment. All boxes of pellets and packages of assemblies were observed to meet posted safety requirements.
The inspectors observed outdoor storage of surface contaminated objects (SCO) destined for decontamination in one of the Service Equipment Refurbishment Facilities (SERF). The ins)ectors observed that each SCO container included a tag tlat indicated the amount of radioactivity associated with the container's contents. The inspectors noted that a few of the tags were weathered such t1at the information on them was illegible. The inspectors notified licensee management of the )roblems with reading some of the container tags and the weatlered tags were replaced before the end of the inspection.
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The inspectors observed outdoor storage of forty (40) steel 55-gallon drums that were not labeled as to their contents.
Each drum was found to contain a few hundred kilograms of contaminated soil removed from a wet weather stream as part of a recent restoration effort. The inspectors discussed this labeling issue with licensee management who agreed that labeling the drums was a good practice even though the licensee had obtained an exemation from the labeling requirements in 10 CFR 20. Tie drums were labeled to incicate their contents before the end of the inspection.
(3) Conclusions The licensee was meeting requirements for storage of special nuclear material. Labeling of outdoor containers was i somewhat inconsistent, but was within license and procedural l requirements.
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- b. Housekeeoina (03.06)
(1) Insoection Scone Routes of egress and access to safety equipment were reviewed to verify obstructions did not exist to hinder their use.
(2) Observations and Findinos During facility tours, the inspectors observed routes of egress for emergencies and found that such emergency routes for occupied areas were clear. However, the inspectors observed that an emergency route from the Pellet Loading Room (PLR) was mostly blocked by a portable welding apparatus. The PLR was not in use during the week of this inspection, but was )lanned for use the following week.
The licensee moved tie welding equipment from the path before the end of the inspection.
The inspectors observed that the outdoor areas of the site directly behind the Lynchburg Manufacturing Facility (LMF) was less cluttered than observed in previous inspections.
This was largely due to the removal of equipment trailers and debris. However, hundreds of containers of contaminated equipment for SERF jobs remained stacked throughout most of the outdoor areas.
The inspectors observed three compressed gas cylinders being stored outdoors without chain restraints. The inspectors also observed that certain fire extinguishers that were
( 3 l stored outdoors in metal cabinets were difficult to access i duo to the rusting spring-loaded latches on the cabinet doors. The licensee placed proper restraints on the compressed gas cylinders and revised the instructions for performing monthly fire extinguisher inspections to include lubricating the latches.
i (3) (Arlusions Overall. housekeeping had improved compared to past ins)ections. However, one partially blocked emergency exit pat 1. three unrestrained compressed gas cylinders, and rusting latches on fire extinguisher cabinets were problem areas.
- c. Followuo on Previousiv Identified Issues (1) Insoection Scoce Corrective actions in response to Violation 97-03-06 .
Failure to Control Access to Tam 3erseals per the Fundamental Nuclear Material Control (FNMC) )lan, were reviewed to verify completion.
(2) Observations and Findinas The inspector reviewed the corrective actions taken by the licensee in response to Violation 97-03-06 where a 4 tamperseal cabinet was found unlocked and the keys in an i uncontrolled status. The inspector reviewed the retraining l records of the operator involved in the incident and the revised training to all employees on procedural compliance.
In addition, the inspector was informed that the requirement to kee) tamaerseals in a locked cabinet had been removed from tie FNiC Plan. Since keeping tamperseals in a locked cabinet was not a regulatory requirement at this facility (except for the fact that it was in the FNMC Plan), the inspector found that the actions taken were ap)ropriate and !
would preclude recurrence of the violation. Tierefore, l Violation 97-03-06 was considered closed. '
(3) Conclusions The licensee *s actions in response to Violation 97-03-06 were appropriate and adequate to prevent recurrence.
Violation 97-03-06 can be considered closed, i
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- 3. Fire Safety (IP 88055) (04)
- a. Followuo on Previously Identified Issues (IP 92702) (04.11)
(1) Insoection Scoce Implementation of corrective actions associated with previously identified fire safety issues was reviewed for completion and adequacy .
(2) Observations and Findinas The inspector reviewed the actions taken by the licensee in response to Violation (VIO) 97-04-02. Failure to Audit Fire Safety Program Semiannually. The licensee determined that lack of ownership for the fire safety audit was a factor in the failure to perform the audit. The licensee *s corrective actions included identifying the individual responsibilities within Safety and Licensing, and development of a Safety and Licensing Audit Matrix for the audits required by the Licensee Application (LA). This matrix was maintained by the Manger of Safety and Licensing, and was reviewed on a monthly basis to ensure audits were performed as required by the LA.
The inspector reviewed the completed Safety and Licensing Audit Matrix and determined that fire safety audits were performed in July 1997, and November 1997. The inspector reviewed the November audit report and concluded that the November 1997 fire safety audit was in-depth, thorough, and detailed. Based on this review, the inspector determined the corrective actions were complete and adequate.
Violation 97-04-02 is considered closed.
Inspection Report (IR) 97-04 also documented Non-cited Violation (NCV) 97-04-01 Failure to Conduct Quarterly Meetings of the Safety Review Board. The IR's " List of Items Opened. Closed, and Discussed." erroneously indicated the status of this NCV as "open" (NCVs. by definition. are opened and closed within the same IR). The " List of Items Opened. Closed, and Discussed." in this report will correctly identify the status of this item as " closed."
(3) Conclusions The licensee's actions in response to VIO 97-04-02 were complete and adequate. This item is considered closed. The
" List of Items Opened. Closed. and Discussed." in this IR will also correctly identify the status of NCV 97-04-01 as
" closed."
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- 4. Manaaement Organization and Controls (IP 88005) (05)
- a. Followuo on Previously Identified Issues (IPs 92701 & 92702)
(05.06)
(1) Insoection Scone Implementation of corrective actions associated with previously identified management controls issues were reviewed for completion.
(2) Observations and Findinas The inspector reviewed the actions taken by the licensee related to timeliness clarifications in the licensee's procedure for conducting independent safety audits. The inspector observed that licensee procedure SL-1150. " Health-Safety- Audits" now included instructions- for timeliness of audit reports once an audit had been competed. Inspector Followup Item (IFI) 97-06-03 is closed.
The inspector reviewed the actions taken by the licensee in response to Violation 97-06-02 that ildentified semi-annual safety audits not being completed in accordance with procedural and license requirements. The inspector observed that licensee procedure SL-1150, " Health-Safety Audits" now included new sections of detailed guidance for conducting, documenting' and responding to the semi-annual safety audits. The inspector also noted that a recent audit performed under the new instructions adequately addressed procedural requirements. Violation 97-06-02 can be considered closed.
(3) Conclusions The licensee's actions in response to issues tracked by Inspector Followup Item 97-06-03 and to Violation 97-06-02 adequately addressed the issues. Both items are closed.
- 5. Waste Manaaement (IPs 84850 and 88035) (R3)
- a. Followuo on Previously Identified Issues (IP 92701) (R312)
(1) Insoection Scone j The inspector reviewed information associated with a previously identified issue in waste management.
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6 (2) Observations and Findinas The inspector reviewed the information collected by the licensee in response to Unresolved Item (URI) 97-06-04.
Review the Licensee's Solubility Assessment to Determine if the Disposal of the Fuel Rod Wash Water from the Retention Tanks into the Municipal Sanitary Sewerage System was Authorized by 10 CFR 20.2003(a).
An inspector noted, during an earlier inspection (IR 97-06),
that fuel rod wash and rinse water (rod wash system) was sent to two approximately 1000 gallon retention tanks. The tank's contents were periodically trans)orted to the Lynchburg Water Treatment Facility (LWT ). The licensee began making these transfers to the LWTF in 1993, on an approximately monthly basis (approximately 1800 gallons per transfer) . Late in 1997, the transfers occurred on an approximately weekly basis (approximately 1000 to 1600 gallons per transfer). As noted in IR 97-06. the licensee would only be authorized to dispose of this liquid waste by transporting it to the LWTF if the four disposal conditions specified in 10 CFR 20.2003(a) were satisfied. The -
inspector noted that the licasee had not determined if the radioactive material (uranium) in the retention tank water i was readily soluble in water as required by 10 CFR 20.2003(a)(1) one of the four disp 0 sal criteria. Since ,
additional information was needed to determine if the licensee was authorized to make this type of disposal, the URI was opened to track this issue.
In February 1998, the inspector contacted the licensee by j telephone to determine what they had done to resolve this !
issue. The ins)ector determined that the licensee had I continued to mate these releases, but had not determined if insoluble materials (in this case insoluble uranium) was present in the releases.
On February 17. 1998, the licensee stopped using the rod :
wash system, and terminated any transfers of liquid from the '
retention tanks to the LWTF.
During the current inspection, the inspector reviewed the I licensee *s efforts to resolve this issue. The inspector verified that the rod wash system was removed from service (the system was partially dismantled), and walked down selected portions of the system.
The licensee also verified the path of the contaminated water from the rod wash system, and determined it was part i L of the process water system. The licensee also determined f that the flow path from the rod wash system to the retention
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7 tanks passed through several micron-size cartridge filters and resin cartridges.
The licensee sampled the water in the retention tanks and had the samples analyzed for solubility in accordance with the American Public Health Association's Method 7110, Gross Alpha and Gross Beta Radioactivity (Total. Suspended, and Dissolved) as specified in NRC Information Notice 94-07.
Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10 CFR Part 20. The results for the retention tank samples were below the minimum detectaule 1 activity (MDA) for the two samples. I The licensee sampled and analyzed the piping systems and tanks that were in the process water system that had the potential to be contaminated, to determine if they were contaminated. The tanks were emptied and cleaned. The interior of the tanks were sampled and analyzed. The tank contamination levels were either below the MDA or below the ,
limit for release as uncontaminated (the limit for release l' at Framatome as uncontaminated is 200 disintegrations per minute per 100 centimeters squared (dpm/100cmz ) gross alpha l smearable: the highest measurement for the tanks was 2
16 dpm/100cm gross alpha smearable). 1 After termination of rod wash system and as part of the contamination check of the process water system, the licensee transferred the retention tank water, and the water from the other tanks in the system, to a tanker. The licensee sampled and analyzed the tanker water per Standard Methods 7110 to determine if it met the criteria for release to the LWTF. The results were less than MDA, and the tanker contents were transferred to the LWTF.
The licensee sampled and analyzed nine filters (one bag filter and eight micron filters ranging in size from one micron to 20 microns) that were used in the process water system. Typically. Framatome purchased these filters new.
used them, and sent them back to the manufacturer for disposal. The manufacturer disposed of the filters as hazardous waste because of potential contamination (non-radioactive) from portions of the manufacturing process (metal finishing). The filters had been used, but not sent back to the manufacturer for disposal. These filters were approximately three feet in length and approximately five l inches in diameter.
The filters were cut up and individually analyzed by gamma s)ectroscopy. The count time was 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> 40 minutes.
T1e highest reading obtained was 7.18 E-05 micro curies per filter (vC1/ filter). This is equivalent to 71.8 picocuries l
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l per filter. The average value was 2.87 E-05 pCi/ filter, t
The " empty cave" background was 8.94 E-06 pCi/ filter. As a l basis for comparison, the NRC's criteria for acceptable soil contamination levels for unrestricted release of soil is 30 picocuries per gram total uranium. The inspector considered the low levels of uranium in the filters (highest value was 71.8 picocuries per filter, each filter weighting a few pounds) to not present a radiological hazard, i
The licensee sampled and analyzed 23 resin cartridges that had been used in the process water system. Typically, these cartridges were obtained from the manufacturer, used, and sent back to the manufacturer for regeneration. The type of resin cartridge used for this process was " industrial grade." 1.e.. not used for processing potable water, etc.
The resin was di3-sampled" from the bottom three inches of the cartridges, w1ich, based on flow through the resin, would be expected to have the highest potential concentration. The samples were measured for gross alpha using a gas proportional counter. The results were less than the MDA for the 23 samples.
When the licensee completed this work, they restored the process water system to operation, with sources of uranium contamination (the rod wash system) eliminated. as a non-contaminated water system. This occurred on March 6.
1998. l The licensee also discussed with the inspector, data that indicated that the amount of uranium contamination possibly present in the rod wash system was considered by the licensee prior to the onset of the transfers to the LWTF in 1993. This data indicated that the potential for introduction of uranium into the rod wash system, although present, was negligible. The inspector reviewed this data. .
and concluded that it dealt with potential surface l contamination of fuel rods, and did not address the solubility issue. I The inspector also considered the corrective actions taken ;
by the licensee for this issue-since February 1998.
Although the amount of effort taken by the licensee, and thoroughness of the corrective actions, were commendable.
the results of the samples taken were only representative of conditions that existed for a finite amount of time in early 1998. No data existed to verify that this data represented the conditions for all the releases since their onset in 1993.
The retention tanks were sampled and analyzed quarterly for total uranium (this analysis does not differentiate between
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9 soluble and insoluble uranium). The quarterly sample results for 1997 for the retention tanks for total uranium )
ranged from 0.5 picocuries per liter to 36.6 picocuries per liter. The type of uranium present at Framatome is insoluble uranium. These results indicate that the I potential existed for the release of insoluble uranium to the LWTF.
Part 20 of Title 10 of the CFR. Section 1501(a) requires, in part that each licensee shall make or cause to be made.
surveys that may be necessary for the licensee to comply with the regulations in Part 20: and are reasonable under the circumstances to evaluate the concentrations or quantities of radioactive materials. Information Notice .
94-07 was issued by the NRC on January 28, 1994. Framatome. I upon review of the IN. should have conclusively determined i if they met the criteria specified in 10 CFR 20.2003(a) for release of material to sanitary sewerage, with respect to soluble versus insoluble materials, by performance of appropriate surveys.
4 The inspector concluded, based on this review, that i Framatome failed to perform surveys to determine that they were not releasing insoluble materials to the sanitary l sewerage in releases made from 1993 to February 1998. This '
failure is identified as a violation (VIO) for failure to perform an adequate survey (Violation (VIO) 98-02-01).
Based on the licensee's extensive corrective actions for this issue, no response to the violation is required. Based l on this review, and on the issuance of VIO 98-02-01. '
URI 97-06-04 is closed.
(3) Conclusions A violation was identified for the failure to perform adequate surveys demonstrating that insoluble uranium was not being released to the LWTF. Framatome's corrective actions for the violation were extensive and complete thus no response is required.
- 6. Transportation (IP 86740) (R4)
- a. Followuo on Previously Identified Issues (IP 92701) (R4. 0Z.).
(1) Insoection Scoce The inspector reviewed the information associated with a previously identified issue in transportation.
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10 (2) Observations and Findinas On March 18. 1998. Davis Besse Nuclear Power Plant reported to the NRC and to Framatome, that they had received a shipment from Framatome Technologies. Inc. (FTI). with damage noted on the exterior of the shipping container L (a sealand). When the sealand was opened. Davis Besse l personnel discovered that some equipment in the sealand (reactor stud tensioners) had shifted and punctured several small holes on one side of the sealand, and a five by ;
1/2 inch on the other side of the sealand. The licensee surveyed the sealand near the damage. the vehicle, and the truck bed and did not identify any contamination.
The sealand was shipped from the Service Equipment Refurbishment Facility-4 at FTI on March 17. 1998, and I contained five reactor vessel (RV) stud tensioners, four RV l stud handling tools, one RV stud cleaning machine, two steam '
generator manway tensioners, a box containing two incore cutters, and a pump. ,
Framatome Technologies. Inc.'s resident engineer at Davis l Besse observed the sealand prior to it being unloaded, and i noted that cribbing was not used to secure the RV stud l tensioners, and that the stud tensioners were not restricted from movement during transit. Framatome Technologies. Inc.
sent two engineers to assess the damage.
Framatome Technologies. Inc. decided to perform a root cause investigation. The REASON, Root Cause Analysis Software was used to identify the root causes and causal factors that contributed to the incident. Several root causes were identified. including: a final inspection of the internal loading of the sealand was not performed, a loading plan was not available, and there were no procedures for packing and shipping heavy equipment. Several causal factors were also identified, including: the individuals who loaded the sealand were not the individuals who unloaded the sealand when it arrived from Davis Besse, additional cribbing material was not available and FTI employees did not attempt to obtain additional cribbing. FTI equipment is normally shipped in dedicated packages, and an adequate pre-job briefing was not provided.
The corrective actions taken (or scheduled to be taken) by FTI included: preparation of a packing procedure or working l
instructions which will include a guideline or checklist with signoffs by the person performing the packing and the person verifying the packing: training for individuals responsible for packing and shi) ping equipment (task leaders): use of the Stop. Thinc. Act, and Review (STAR)
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principle: and designation of supervisors. Logistics and Shipping Specialists or the Safety and Licensing staff to inspect the internal loading of each sealand prior to shipment. The inspectors reviewed the licensee's root cause investigation re) ort and corrective actions and concluded that they were t1orough, detailed, and demonstrated initiative by the licensee.
Part 173 of Title 49 of the CFR, Section 475 (a) requires.
in part, that before each shipment of any Class 7 (radioactive) materials package, the offeror must ensure, by examination or appropriate tests. that the packaging is proper for the contents to be shipped. The shipment made to Davis Besse from FTI on March 17, 1998, did not meet these requirements in that the sealand container was not proper for'the contents shipped (unrestrained RV stud tensioners).
as evidenced by the damage caused to the sealand by the RV stud tensioners during shipment.
This non-repetitive, self disclosing, and corrected violation is being treated as a non-cited violation (NCV),
consistent with Section VII.b.1 of the NRC Enforcement Policy, and will be identified as NCV 98-02-02, Failure to use Packaging Proper for the Contents Shipped.
(3) Conclusions The licensee demonstrated initiative in performing a l thorough and detailed root cause investigation for a l shipment from FTI which arrived at its destination with damage to the shipping container. An NCV was identified for the failure to use the proper packaging for the shipment.
- 7. Maintenance / Surveillance (IP 88025) (F1)
- a. Conduct of Maintenance (F1.01) l Surveillance Testina (F1.06) )
Calibrations of Eauioment (F1.07) !
(1) Insoection Scoce ;
1 Maintenance activities were reviewed to determine compliance I with licensee internal procedures for conducting maintenance, performing surveillance tests, and calibrating {
equipment.
l (2) Observations and Findinas i
The inspector reviewed the maintenance activities important to safety with the Maintenance Manager for electronic i l systems. The inspector observed the computerized procedures Il
12 for performing electronic maintenance and toured the l associated areas of the LMF. The inspector reviewed the Seriodic maintenance requirements for the facility's Jninterruptible Power Supply (UPS) system that ensured the L operability of the criticality detection and alarm system.
l as well as other safety related items throughout the plant.
l during a power outage. The inspector observed the UPS equipment and recent records of its maintenance and surveillance testing. No discrepancies with applicable procedures were noted.
The inspector reviewed the periodic maintenance requirements and surveillance tests for the facility's ventilation systems. The maintenance requirements included review of pressure drops across High Efficiency Particulate Air (HEPA) filters, the changing of filters when needed, and verification of the automatic lubrication system operability. No discrepancies with applicable procedures were noted.
The surveillance testing for the facility's ventilation systems included measurements of airflows at specific uranium handling stations. The inspector observed that these measurements were taken weekly by safety personnel.
The ins)ector reviewed the air flow surveillance records and found tlat an outdated version of the form was being used to record the measurements. Revision C of form SL-1230-5. " Air Flow Audit Record" was approved for use in January 1998 but Revision A was being used to record the measurements in February through April 1998. The inspector observed that the minimum flow criteria for each station was printed on the back of Form SL-1230-5 and that the required flows had been modified with each revision of the form. The inspector noted that the average flow measured for the Pellet Loader Table - South was below the minimum requirement of 500 l linear feet per minute for measurements taken on January 6 and January 30, 1998, with no corrective actions taken. The inspector noted that the same station was below the minimum air flow requirement again on February 4.1998, when ;
Maintenance 'was notified to investigate and correct the !
situation. The inspector reviewed procedure SL-1230.
" Airborne Radioactivity" that required the taking of air flow measurements and found that no instructions were provided for responding to a low air flow reading. The inspector noted that License Ap)lication Section 2.6 L " Operating Procedures" stated tlat procedures "shall be such that operations are clearly detailed and specific directions are provided for operation under both normal and abnormal ;
conditions." The inspector foun( that although this Safety and Licensing procedure is a supplementary administrative procedure, it could affect the safety of plant operations
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conditions encountered during surveillance and testing l actions. The inspector discussed the need to include such (
instructions with licensee management. The licensee agreed that some additional instruction was warranted. The
' revision of Procedure SL-1230 to include details on responding to abnormal conditions was identified as Inspector Followup Item (IFI) 98-02-03.
The inspector reviewed the licensee's records of quarterly verification of representative sampling for controlled area effluent stacks and controlled area air recirculating systems. The inspector reviewed Procedure SL-1230 and Form SL-1230-4 for instruction on and documentation of these checks. The inspector observed that Procedure SL-1230 cnly instructed the safety technician to perform a verification and document it on Form SL-1230-4. The inspector also observed that Form SL-1230-4 provided some guidance on taking cross-sectional air flow measurements and performing j a calculation to determine the proper flow rate to ensure '
isokinetic sampling. However, the inspector found that no instructions were given in the procedure nor on the l verification form for correcting the sampling systems when the calculated and actual flows were not the same. The inspector discussed this issue with the licensee and found that the " verification" form was actually a form for determining adjustments to the samale Jump flow rate to ensure isokinetic sampling, even t1ougl no written instructions to make such adjustments existed. The inspector found that as part of IFI 98-02-03, instructions ,
for adjusting sample pump flow rates as part of the l verification of isokinetic sampling should be included in Procedure SL-1230.
The inspector reviewed licensee Form SL-1230-3. " Filter .
Differential and Area Negative Pressure Audit Records" that were also controlled by Procedure SL-1230. In this case, the inspector observed that some instruction was provided in the procedure for when to perform actions such as changing filtcrs and performing investigations for correcting problems associated with the ventilation systems.
(3) Conclusions Maintenance of safety systems were being performed in accordance with internal procedural requirements. Certain instructions for performing air flow audits and operability checks for isokinetic sampling of effluent stacks were not included in the applicable safety procedure. An inspector
<- followup on this lack of instruction was identified as IFI 98-02-03.
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- 8. Trainino (IP 88010) (F2) l a. 10 CFR 19.12 Trainina l
(1) Insoection Scope-General Employee Training (GET) was reviewed to verify compliance with Section 2.5, Training, of the license application (LA).
(2) Findinas and Observations The inspector attended sessions of the licensee's GET, Fire Safety Training and Personal Protective Equipment Training.
This training is required for an individuals who wish to have unescorted access to the LMF and SERF facilities. The training primarily consisted of industrial safety concepts and included emergency procedures, chemical safety and fire safety. Safety principles and good safety practices were I emphasized in the class. The inspector considered the I training in-depth and thorough.
(3) Conclusions The inspector concluded that the training met the requirements (where applicable) of Section 2.5. Training, of the LA. The training was in-depth and thorough.
- b. Followun on Previously Identified Issues (IP 92701) (F2.07)
(a) Insoection Scoce Implementation of corrective actions associated with previously identified training issues were reviewed for completion.
(2) Observations and Findinas The inspector reviewed the actions taken by the licensee in .
response to IFI 97-06-05. Instructions to Em)loyees Required i by 10 CFR 19.12(a)(4) are to be Included as part of GET. l This instruction requires that employees "shall be !
instructed of their responsibility to report promptly to the !
licensee any condition which may ' lead to or cause a ,
violation of Commission regulations and licenses or J unnecessary exposure to radiation and/or radioactive I material." The inspector verified, by attending GET. that i employees were instructed of their responsibilities to make !
reports of this nature. Based on this review, IFI 97-06-05 j is closed.
4 (3) Conclusions !
Inspector Followup Item 97-06-05 is closed based on the l inspector *s review of GET.
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- 9. . Exit Interview The inspection scope and results were summarized on May 15, 1998. with those persons indicated in the Attachment. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary information is not included in this report.
Dissenting comments were not received from the licensee.
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ATTACHMENT I
- 1. PERSONS CONT /4TED Licensee Personnel
- T. Allsep. Health Physicist
- D. Driscoll. Senior Regulatory Compliance Officer G. Elliott. Manager. Safety and Licensing
- D. Gordon. Senior Health Physicist
- A.-Jenkins. Manager. SERF 3&4 Facilities
- G. Lindsey. Health Physicist G. Map). Training Instructor
- J. Matleson. V.P., Operations
- A. McKim. Manager. Quality / Health / Safety I
- C. Vandegrift. Mechanical Maintenance Supervisor !
- J. Whitt Manager. Facilities Other licensee employees contacted included. engineers. technicians, security, and office personnel.
- Denotes those present at the exit meeting on May 15. 1998 l
'2. INSPECTION PROCEDURES USED IP 88010 Operator Training / Retraining IP 88020 Regional Nuclear Criticality Safety Inspection Program l IP 88025 Maintenance and Surveillance Testing IP 92701 Followup IP 92702 Followup on Corrective Actions for Violations and Deviations
- 3. LIST OF ITEMS OPENED, CLOSED,'AND DISCUSSED Ooened l
Lack of Instructions in Safety Procedures for 70-1201/98-02-03 IFI Handling Abnormal Conditions (Section 7.a) l.
Closed 70-1201/97-03-06 VIO Failure to Control Access to Tamperseals per FNMC Plan (Section 2.c) 70-1201/97-04-01 NCV Failure to Conduct Meetings of the Safety Review Board (Section 3.a) 70-1201/97-04-0: VIO Failure to Audit Fire Safety Program Semiannually (Section 3.a)
2 70-1201/97-06-02 VIO Failure to Perform Semi-annual Safety Audits in Accordance with
.acedural Requirements (Section 4.a) and License 5 70-1201/97-06-03 IFI Clarification Safety of Instructions Audits (Section 4.a) for Timeliness of 70-1201/97-06-04 URI Review the Licensee's Solubility Assessment to Determine if the Disposal of the Fuel Rod Wash Water from the Retention Tanks into the Municipal Sanitary Sewerage Systam was s Authorized by 10 CFR 20.2003(a) (Section 5.a) 70-1201/97-06-05 IFI Instructions to Employees Required by 10 CFR 19.12(a)(4) Are to Be Included as Part of General Employee Training (Section 8.b) 70-1201/98-02-01 VIO Failure to Perform Adequate Survey of Releases to Sanitary Sewerage (Section 5.a)
) 70-1201/98-02-02 NCV Failure to Ensure Proper Packaging for Shipment of Contaminated Objects (Section 6.a'
- 4. LIST OF ACRONYMS CFR dpm/cm2 Code of Federal Regulations FCF Framatome Ccgema FuelsDisintegrations per minute per 100 c FNMC FTI Fundamental Nuclear Material Control Framatome Technologies. Inc.
GET HEPA General Employee Training IFI High Efficiency Particulate Air IP Inspector Followup Item Inspection Procedure IR Inspection Report LA License Ap311 cation LMF LWTF Lynchburg Manufacturing Facility MDA Lynchburg Water Treatment Facility NCV Minimum Detectable Activity NRC Non-Cited Violation PLR Nuclear Regulatory Commission Pellet Loading Room RV SCO Reactor Vessel SERF Surface Contaminated Object STAR Service Equipment Refurbishment Facility Stop. Think. Act. Review pC1/ filter microcuries 3er filter UPS URI Uninterruptiale Power Supply VIO Unresolved Item Violation