ML20071H554
| ML20071H554 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/11/2020 |
| From: | Laura Dudes Region 2 Administrator |
| To: | Annacone M Westinghouse |
| References | |
| EA-16-173 IR 2020006 | |
| Download: ML20071H554 (12) | |
Text
EA-16-173 March 11, 2020 Mr. Mike Annacone Vice President, Columbia Fuel Operations and Manager, Columbia Plant Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061
SUBJECT:
WESTINGHOUSE ELECTRIC COMPANY - NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NUMBER 70-1151/2020-006 AND CONFIRMATION OF IMPLEMENTATION OF CONFIRMATORY ORDER EA-16-173
Dear Mr. Annacone:
This letter refers to inspections conducted from January 1 through March 3, 2020, at the Westinghouse Columbia Fuel Fabrication Facility in Hopkins, SC. The purpose of this report is to acknowledge Westinghouses letter dated March 3, 2020, detailing completion of required actions in Section V of Confirmatory Order (CO) EA-16-173 (Agencywide Documents Access and Management System (ADAMS) accession number ML20063M239), and to document completion of the NRCs inspections of your actions required by the CO.
The enclosed inspection report presents the results of this inspection and summarizes the results of previous inspections of CO commitments. At the conclusion of the inspections, the inspectors discussed their findings with members of your staff during an exit meeting held on March 4, 2020.
Based on the cumulative results of these inspections, the NRC has verified that the commitments detailed in the CO have been implemented and that no violations of more than minor significance were identified.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of NRCs Rules of Practice and Procedure, a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room, or from the NRCs ADAMS, which is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html.
M. Annacone 2 If you have any questions, please contact Eric Michel of my staff at (404) 997-4555.
Sincerely,
/RA/
Laura A. Dudes Regional Administrator Docket No. 70-1151 License No. SNM-1107
Enclosure:
NRC Inspection Report 70-1151/2020-006 w/Supplemental Information cc: Distribution via LISTSERV
ML20071H554 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE RII:DFFI/PB2 RII:EICS RII:DFFI/PB2 RII:DFFI RII:ORA NAME T. Vukovinsky M. Kowal E. Michel L. Suggs L. Dudes DATE 3/5/2020 3/4/2020 3/04/2020 3/5/2020 3/11/2020 E-MAIL COPY? YES NO YES NO YES NO YES NO U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70-1151 License No.: SNM-1107 Report No.: 70-1151/2020-006 Enterprise Identifier I-2020-006-0052 Licensee: Westinghouse Electric Company Facility: Columbia Fuel Fabrication Facility Location: Hopkins, SC 29061 Dates: January 1, 2020 through March 4, 2020 Inspectors: T. Vukovinsky, Senior Fuel Facility Inspector Approved by: Laura A. Dudes Regional Administrator Enclosure
EXECUTIVE
SUMMARY
Westinghouse Electric Company Columbia Fuel Fabrication Facility Nuclear Regulatory Commission Inspection Report 70-1151/2020-006 January 1, 2020 through March 4, 2020 The inspection was conducted by Nuclear Regulatory Commission (NRC) regional inspectors during normal shifts in areas associated with Confirmatory Order EA-16-173. The inspectors performed a selective examination of license activities that were accomplished by direct observation of safety-significant activities and equipment, tours of the facility, interviews and discussions with licensee personnel, and a review of facility records.
Other
- Acknowledgement of Westinghouses letter of implementation of Confirmatory Order commitments (Paragraph A.1)
- Review of completed Confirmatory Order commitments (Paragraph A.2, A.3)
- Summary of completed Confirmatory Order commitments (Paragraph B.1)
Attachment:
Key Points of Contact List of Items Opened, Closed, and Discussed Inspection Procedures Used Documents Reviewed Acronyms and Initialisms 2
REPORT DETAILS Summary of Plant Status The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a wet conversion process and fabricates fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing.
A. Review of Completed Confirmatory Order Commitments (Inspection Procedure 88020)
- 1. Review of Confirmatory Order Section V Item 11
- a. The inspectors reviewed the licensees actions regarding CO (ML17221A112),Section V, Item 11. This item required that the licensee submit a letter to the NRC discussing its basis for concluding that the CO had been satisfied. The letter was to be provided within three months of completing implementation of the terms of the CO. On March 3, 2020, Westinghouse provided the NRC with a letter discussing its basis for concluding that the Confirmatory Order (CO) has been satisfied (ML20063M239). The NRC acknowledges the receipt of this letter and inspectors have verified that the corrective actions detailed in Section V of the CO were implemented as described. The results of these inspections are detailed in the following sections of this report.
b. Conclusion
Based on the review of all completed actions, the NRC concludes that Westinghouse has completed implementation of actions detailed in CO Section V. The licensee has met the requirements stated in CO Section V, Item 11, and this item is considered closed.
- 2. Review of Confirmatory Order Section V Item 2 (Inspection Procedure 40100)
- a. Inspection Scope The inspectors reviewed the licensees actions regarding CO Section V, Item 2, which required the licensee to conduct an additional nuclear safety culture (NSC) survey by the Westinghouse corporate nuclear safety culture organization or an experienced independent third party, consistent with the depth and scope of the NSC survey completed under the Confirmatory Action Letter (CAL) dated August 11, 2016 (ML16224B082). Identified deficiencies shall be entered into the Corrective Action Program (CAP) for tracking corrective actions to completion.
The inspectors noted that the independent third-party nuclear safety culture assessment was conducted in October 2019. The survey was completed by Westinghouses global NSC organization, in accordance with BMS-NSC-3, Nuclear Safety Culture Surveys and Assessments Procedure. This organization was independent of the Westinghouse Columbia Fuel Fabrication Facility (CFFF). The assessment results were based on a pre-assessment survey of CFFF personnel and a week of direct interviews with selected CFFF personnel. The results of the survey were reviewed, and a gap analysis was performed by the Nuclear Safety Council Monitoring Panel (NSCMP). The areas identified in the gap analysis were entered in the CAP for tracking to completion. The inspectors reviewed the NSCMP meeting minutes and CAP entries to verify that any deficiencies were entered in the CAP and are being tracked under CAP 2019-16772.
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The inspectors interviewed the Employee Concerns Program (ECP) manager and noted that this position is now a full-time on-site position and that a healthy number of interactions were occurring within the ECP. In addition, the inspectors noted that numerous initiatives are underway to increase employee awareness of the ECP.
b. Conclusion
The licensee completed an independent nuclear safety culture survey and any identified deficiencies were entered into the CAP to track to completion. Based on a review of the NSC survey, NSCMP minutes, and interviews with licensee management, the NRC concluded that the licensee has met the requirements as stated in the CO,Section V, Item 2. This item is considered closed.
- 3. Review of Confirmatory Order (CO)Section V Item 3(3) (Inspection Procedure 88020)
- a. Inspection Scope The inspectors reviewed the licensees actions regarding CO Section V, Item 3(3), which required the licensee to implement improvements identified in the engineering evaluation of the calciner and calciner off-gas scrubber design and operation to determine methods to reduce uranium carry-over into the S-1030 scrubber.
For the calciner off-gas scrubber, the inspectors noted that the licensee had completed the engineering evaluation and had also completed the installation of improvements based upon the evaluation. The inspectors reviewed the evaluation and noted that the licensee completed installation of four improvements to the calciner system:
- i. Automatic pH Control - Installed online pH monitoring with display in the Conversion Control Room and means to control ammonia addition to maintain pH at the desired level.
ii. Off-Gas Condenser Spray Nozzle Flow Indication - Installed a flow meter with remote indication and low flow alarm in the Conversion Control Room. This provides indication of reduced or loss of flow to the spray nozzle at the off-gas condenser.
iii. Improved Scrubber Slab Tank Level Indication - Improved the ability to accurately monitor water level in the slab tank to assure appropriate level is maintained. Improved monitoring ability via means by adding an automatic flush on the level transmitter sensing line.
iv. Scrubber Solution Temperature Indication - Provided indication of scrubber solution temperature through a display in the Conversion Control Room and high temperature alarm. This provides enhanced capability to maintain scrubber solution within the optimal operating range.
The inspectors reviewed the completed new instrumentation and controls associated with the calciner and calciner off-gas scrubber and noted that these modifications were completed on time as required by the CO.
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b. Conclusion
The licensee has completed implementation of modifications to the calciner off-gas scrubber as required by CO Section V, Item 3(3). Based on the review of engineering evaluations and design changes, the NRC concludes that Westinghouse has met the requirements stated in CO Section V, Items 3(3), and this item is considered closed.
B. Summary of completed Confirmatory Order commitments The table below lists modifications to the SNM-1107 license as required by the CO and the corresponding inspection report which details the NRCs inspection of the CO Item:
CO Item Description Due Date Inspection Report (NOTE 1)
CO V.1 Westinghouse agrees to submit a written 9/9/17 IR 2017-004 statement or explanation to the Director, OE.
This reply should include the following for each of the four violations: (1) the reason for the violation; (2) the corrective steps that have been taken to restore compliance; and (3) additional corrective actions and enhancements taken to preclude repetition.
CO V.2 Westinghouse shall conduct an additional NSC 2/9/2019 - 2/9/2020 IR 2020-006 survey by the Westinghouse corporate nuclear safety culture organization or an experienced independent third party, consistent with the depth and scope of the NSC survey completed under the CAL dated August 11, 2016. Identified deficiencies shall be entered into the CAP for tracking corrective actions to completion.
CO An engineering evaluation of the calciner and 2/9/19 IR 2019-002 V.3(1) calciner off-gas scrubber design and operation shall be completed to determine methods to reduce uranium carry-over into the S-1030 scrubber.
CO An engineering evaluation of the Conversion 2/9/19 IR 2019-002 V.3(2) Scrap Cage Blue M oven shall be completed to determine methods to improve the functionality of the Blue M oven in a wet environment and improve accessibility for inspection and maintenance activities.
CO Within three (3) years of issuance of the CO, 8/9/20 The Blue-M V.3(3) improvements based on the engineering modifications evaluations described in V.3(1) and V.3(2) shall V.3(2), were be implemented. documented in IR 2019-002 Calciner modifications V.3(1), were 5
documented in IR 2020-006 CO V.4 Westinghouse shall notify the NRC within fifteen 15 days prior to Not Applicable (15) working days prior to implementing changes implementation of (N/A) to the modifications to the S-1030 scrubber modifications system, as discussed below. This requirement ends once the Regional Administrator determines that the CO has been satisfied. These modifications were incorporated as corrective actions prior to the October 20, 2016, system restart authorization (ML16294A296) and support, in part, the safety basis for the S-1030 scrubber.
CO V.5 Westinghouse shall develop and implement 8/9/19 IR 2019-004 additional methods to monitor system parameters that are early indicators of an abnormal accumulation in the S-1030 scrubber from a process upset that could challenge the accumulation rate and/or criticality safety mass limits. The methods will provide timely indications to enable the operators to take appropriate actions in accordance with approved procedures.
CO V.6 Westinghouse shall develop and implement a 2/9/19 IR 2018-005 criticality safety basis/IROFS database to maintain the proper flow down of the safety basis into implementing documents.
CO V.7 Westinghouse shall develop a method to 2/9/18 IR 2018-006 reinforce positive NSC leadership behavior and monitor for effectiveness in the NSC monitoring panel. Westinghouse shall implement such method for three (3) years, after which it may evaluate the need to continue this item.
CO V.8 Westinghouse shall develop and implement a 11/9/17 IR 2017-009 new metric or periodic report that creates an aggregate picture of the health of the criticality safety program. This shall include items such as IROFS challenges, trends, audit and inspection finding status, violations, and health of management measures and be made available for inspection. Identified deficiencies shall be evaluated in accordance with the CAP.
CO V.9 Westinghouse shall implement risk-informed 5/9/18 IR 2018-004 standards for the preparation of procedures and data sheets informed by appropriate guidance in INPO 11-003, Guideline for Excellence in Procedure and Work Instruction Use and Adherence. This shall consist of issuance of a procedure writers guide, procedure format template, and a procedure use and adherence standard.
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CO Westinghouse shall implement the remaining N/A IR 2018-004 V.10.a corrective actions to prevent recurrence (CAPR) identified in their Root Cause Analysis (RCA)
(detailed below).
CAL 1.1 Corrective Action to Prevent Recurrence (CAPR) N/A IR 2017-004 1: Revise TA-500, Config Control procedure (planning meeting).
Revise RA-104, Review of Config Change Authorizations procedure (detailed checklists)
CAL 1.2 CAPR2: Revise CA-002, ETAPS (formal N/A IR 2017-004 review for process changes to procedures)
CAL 1.3 CAPR 3: Revise TA-500, Config Control N/A IR 2017-004 procedure and FA-114, Independent Technical Reviews if a change modifies an SSC in a CSE CAL 1.4 CAPR 4: Conduct assessment IAW INPO N/A IR 2017-004 guidance for configuration management CAL 1.5 CAPR 5: Revise COP-815021, S-1030 N/A IR 2017-004 Inspection and Cleanout, to specify data to be recorded, and review of data.
CAL 1.6 CAPR 6: Develop or revise procedures to ID N/A IR 2018-004 personnel who need training on the safety basis for CSEs.
CO Westinghouse shall conduct effectiveness N/A IR 2019-003 V.10.b reviews of corrective actions to prevent recurrence as specified in their RCA.
CO Westinghouse shall evaluate the results of the N/A IR 2018-006 V.10.c independent third-party nuclear safety culture assessment (conducted on 5/2/2017), and any identified deficiencies will be entered into the CAP to track to completion.
CO V.11 Within three (3) months of completing CO completion + 3 IR 2020-006 implementation of the terms of the CO, months Westinghouse will provide the NRC with a letter discussing its basis for concluding that the CO has been satisfied.
NOTE 1: ADAMS accession numbers and hyperlink to documents are included in the supplemental information section of this report C. Exit Meeting The inspection scope and results were presented to members of the licensees staff at various meetings throughout the inspection period and were summarized on March 4, 2020 to Amanda Spalding and staff. Proprietary information was discussed but not included in this report.
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SUPPLEMENTAL INFORMATION
- 1. KEY POINTS OF CONTACT Name Title M. Cudd Employee Concerns Manager C. Hudson Conversion Area Manager A. Pope Director, Organizational Effectiveness A. Spalding Licensing Manager Other licensee employees contacted included engineers, technicians, production staff, and office personnel.
- 2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Closed CO Item 2 CO Westinghouse shall conduct an additional NSC survey by the Westinghouse corporate nuclear safety culture organization or an experienced independent third party, consistent with the depth and scope of the NSC survey completed under the CAL dated August 11, 2016. Identified deficiencies shall be entered into the CAP for tracking corrective actions to completion.
CO Item 3(3) CO Complete installation of improvements identified in the Calciner and Calciner off-gas scrubber engineering evaluation.
CO Item 11 CO Within three (3) months of completing implementation of the terms of the CO, Westinghouse will provide the NRC with a letter discussing its basis for concluding that the CO has been satisfied.
- 3. LIST OF PUBLICLY AVAILABLE DOCUMENTS IN ADMAS ASSOCIATED WITH THE CO Inspection Report Number ADAMS ML Number and Hyperlink AIT Report 2016-007 ML16301A001 Confirmatory Acton Letter ML16224B082 IR 2017-007 ML17058A448 Confirmatory Order ML17221A112 IR 2017-004 ML17303A023 IR 2017-009 ML17356A091 IR 2018-004 ML18284A095 IR 2018-005 ML19023A349 IR 2018-006 ML18089A060 IR 2019-002 ML19101A274 IR 2019-003 ML19212A687 IR 2019-004 ML19326C453 Attachment
- 4. INSPECTION PROCEDURES (IP) USED IP 40100, Independent Safety Culture Assessment Follow-up IP 88015, Criticality Safety IP 88020, Operational Safety IP 88070, Plant Modifications IP 88072, Plant Modifications (Triennial)
- 5. DOCUMENTS REVIEWED Procedures:
COP-811101, Calciner Off-Gas Scrubber, Rev. 84 Corrective Action Program Document Reviewed:
2019-16772 Other Documents:
CCF 19141, Conversion Line 1-5 Calciner Scrubber Confirmatory Order I&C/Elec/Mech Level Improvements CCF, 19131, Conversion Line 1-5 Calciner Scrubber Confirmatory Order I&C/Electrical PH Improvements Columbia Fuels Fabrication Facility (CFFF) NSC Survey Report, October 2019
- 6. ACRONYMS AND INITIALISMS ADAMS NRCs document system ALARA As Low as Reasonably Achievable CAL Confirmatory Action Letter CAP Corrective Action Program CAPR Corrective Action to Prevent Recurrence CFFF Columbia Fuel Fabrication Facility CFR Code of Federal Regulations CO Confirmatory Order ECP Employee Concerns Program IP Inspection Procedure IR Inspection Report IROFS Items Relied on for Safety N/A Not Applicable NRC Nuclear Regulatory Commission NSC Nuclear Safety Culture NSCMP Nuclear Safety Culture Monitoring Panel PM Preventative Maintenance RCA Root Cause Analysis REM Roentgen Equivalent Man Rev. Revision 2