ML23202A147
| ML23202A147 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/24/2023 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | Pope A Westinghouse |
| References | |
| IR 2023002 | |
| Download: ML23202A147 (1) | |
Text
July 24, 2023 Annette Pope Plant Manager Westinghouse Electric Company 5801 Bluff Road Hopkins, SC 29061
SUBJECT:
WESTINGHOUSE COLUMBIA FUEL FABRICATION FACILITY - INTEGRATED INSPECTION REPORT 07001151/2023002
Dear Annette Pope:
This letter refers to the U.S. Nuclear Regulatory Commission (NRC) inspection activities conducted from March 1 to June 30, 2023, for the Westinghouse Columbia Fuel Fabrication Facility. On April 20 and June 15, 2023, the NRC inspectors discussed the results of this inspection with you. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Signed by Michel, Eric on 07/24/23 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
ML23202A147 X Non-Sensitive X Publicly Available X SUNSI Review Sensitive Non-Publicly Available OFFICE RII/DFFI RII/DFFI RII/DFFI NAME J. Raudabaugh T. Vukovinsky E. Michel DATE 07/21/2023 07/24/2023 07/24/2023 U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number: 07001151 License Number: SNM-1107 Report Number: 07001151/2023002 Enterprise Identifier: I-2023-002-0048 Licensee: Westinghouse Electric Company Facility: Westinghouse Columbia Fuel Fabrication Facility Location: Hopkins, SC Inspection Dates: April 17 to 20, 2023 June 12 to 15, 2023 Inspectors: J. Grice, Fuel Facilities Inspector C. Oelstrom, Fuel Facilities Inspector J. Raudabaugh, Fuel Facility Inspector J. Rivera Ortiz, Sr. Fuel Facility Project Inspector T. Sippel, Sr. Fuel Facility Project Inspector P. Startz, Fuel Facilities Inspector T. Vukovinsky, Sr. Fuel Facility Project 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 monitoring the licensees performance by conducting an integrated inspection at Westinghouse Columbia Fuel Fabrication Facility in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities. Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items None.
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INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees operational safety program to verify compliance with selected portions of Title 10 of the Code of Federal Regulations (10 CFR) 70, Domestic Licensing of Special Nuclear Material, including 70.24, 70.61, 70.62, and chapter 3, Management Measures, of the facilitys license application, and applicable licensee procedures.
Identification of Safety Controls and Related Programs (IP Section 02.01)
The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety (NCS), radiation safety, and/or chemical safety based on the information provided in the integrated safety analysis (ISA) summary. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
ISA-9, "Uranium Recovery Recycle System (URRS) Cylinder Wash System" ISA-15, "Wastewater Treatment System" Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected above including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
IROFS reviewed:
o WT-905, "Incinerator Filter," active engineering control (AEC) o WT-152, 167, "Backflow Preventer," AEC o WT-906, 907, 908, 909, "Gamma Monitor," AEC 3
o WT-910, 911, "Tank Samples," administrative control (AC) o WCD-114, 115, "Backflow Preventer," AEC o WCD-129, "Gamma Monitor," AEC o WCD-113, "Vessel Spacing," passive engineering control (PEC) o WCD-116, 117, "Vacuum Break or Overflow," AEC o WASH-101, "Crane Stops," PEC o WASH-102, "Overflow on V09 Glass Column," PEC o WASH-103, "UF6 Bay/UF6 Pad Scale Calibration," AC o WASH-106, "Cylinder Heel Weight Verification," AC o WASH-116, "Fill Control Valve FV-01 Interlock," AEC o WASH-122, "Passive Overflow Tanks V-1006 A/B," PEC o WASH-125, "Keyed Cover for Scale Controls," AC o WASH-127, "Second Overflow on V-09 Glass Column," PEC o WASH-128, "Second Passive Overflow Tanks V-1006 A/B," PEC o WASH-144, "P-09 to V-07A Elevation," PEC o WASH-146, "Passive Overflow Elevation Tank V-07A," PEC ISA-9, "Uranium Recovery Recycle System (URRS) Cylinder Wash System" ISA-15, "Wastewater Treatment System" Criticality Safety Evaluation (CSE)-9A, "UF6 Cylinder Cleaning and Surveying System" CSE-9B, "Cylinder Wash" CSE-15A, "Waste Treatment Tanks T-1147, 1148, and 1149" CSE-15D, "Warm Caustic Waterglass Cake Dissolution System" Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and chapter 3 of the license application. This review was performed to verify that selected safety controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:
interviewed operators and performed walkdowns to verify implementation of IROFS listed above performed walkdowns of the cylinder wash and wastewater treatment system areas as well as an overall plant walkdown reviewed operational and maintenance procedures for IROFS listed above (documents listed in the documents reviewed list) reviewed NCS postings in the waterglass and cylinder wash areas reviewed calculations documenting the basis of IROFS WASH-102, WASH-122, WASH-127, and WASH-128 reviewed piping and instrumentation drawings for selected IROFS to verify consistency of the drawings with the actual plant configuration 4
Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and section 3.0 of the license application. Specifically, the inspectors conducted the following:
reviewed preventative maintenance, functional test instructions, and work order (WO)/dispatch packages for the IROFS listed above (specific documents listed in the documents reviewed section) reviewed corrective action program (CAP) entries and tracking records of IROFS degradation/failures for the previous 6 months for the cylinder wash and wastewater treatment systems reviewed LTR-EHS-23-23, "2022 Redbook Failure Evaluation Report," for IROFS failures and degradation for the last 12 months reviewed EHS-AUDIT-23-7, "Regulatory Component Audit for the Integrated Safety Analyses Program" reviewed training qualification records for six operators in the cylinder wash and wastewater treatment areas reviewed safety-significant changes to implementing procedures for the selected IROFS to verify consistency with the licensee's procedure revision process reviewed staffing changes in organizational groups responsible for operational safety activities to verify compliance with the position-specific requirements in the license application FACILITY SUPPORT 88050 - Emergency Preparedness The inspectors evaluated selected aspects of the licensees emergency preparedness program to determine whether the program is maintained as required by the emergency plan, the license and license application, and NRC requirements in 10 CFR Part 70.
Emergency Preparedness Program Review and Implementation (IP Section 02.01)
The inspectors selected the following elements that support the implementation of the licensees emergency preparedness program to verify compliance with 10 CFR 70.22(i)(3),
chapter 9, "Emergency Management Program" of the license application, and the emergency plan. Specifically, the inspectors conducted the following inspection activities:
reviewed SEP-002, "Classification," Revision (Rev.) 7, focusing on recent changes to natural phenomenon hazard classification as well as other emergency plan implementing procedures listed below reviewed training records including certificates and attendance rosters for three incident commanders reviewed training records including certificates and attendance rosters for five emergency response team members 5
reviewed the current offsite support agreements that the licensee has with Columbia-Richland Fire Department, Richland County Sheriff's Department, and other offsite support agencies interviewed the Division Chief of Special Operations, Columbia Fire Department, to verify that the licensee provided effective information exchange, training opportunities, current emergency plan, and opportunities to enhance interoperability knowledge observed the 2023 biennial exercise reviewed records from the June 2022 tabletop, the January 2023 tabletop, and the March 2023 drill reviewed records from the November 2022 evacuation drills walked down emergency equipment storage locations and interviewed emergency team member and site nurse about the equipment inspected the licensee's emergency response facilities and equipment including the firefighter practice "burn building" and confined space rescue training area, emergency response station, emergency operations center (EOC), fire truck, and HAZMAT truck inspected multiple emergency response supply cabinets within the conversion production area, interviewed licensee staff, and reviewed completed forms to verify that licensee staff were monitoring supplies as required by CF-81-230, "1st Shift Conversion Weekly Safety Checklist," Rev. 7 reviewed the last two annual audits of the emergency preparedness program that were conducted by a licensee contractor, EHS-AUDIT-21-02 and EHS-AUDIT-22-02 Identification and Resolution of Problems (IP Section 02.02)
The inspectors reviewed the licensees identification and resolution of emergency preparedness issues to verify compliance with the license requirements. Specifically, the inspectors interviewed licensee staff and reviewed the following CAP entries and audits:
IR-2022-1549, IR-2022-1826, IR-2022-3195, IR-2022-4388, IR-2023-0096, IR-2023-2057, IR-2023-4006, and IR-2023-4681 which includes CAP entries that resulted from audits, entries that resulted from drill performance, and entries that resulted from events EHS-AUDIT-21-02 and EHS-AUDIT-22-02 88051 - Evaluation of Exercises and Drills The inspectors observed and evaluated the licensees graded biennial exercise conducted on June 14, 2023, as well as briefings and critiques involving both onsite and offsite participants, to verify compliance with 10 CFR 70.22(i)(3)(xii), the emergency plan, and chapter 9 of the license application. The scenario included an earthquake that resulted in damage to the site including a spill of contaminated oil, an ongoing spill of acidic contaminated liquid, injury of a contaminated employee, a release of argon, and persons involved in confined space entry that need rescue.
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Exercise Planning (IP Section 02.01)
The inspectors reviewed the emergency exercise scenario, discussed the exercise scenario and objectives with licensee personnel, observed the controller/evaluator briefing and the safety briefing, and walked down the plant areas before the exercise to verify compliance with the emergency plan, emergency plan implementing procedure, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:
the frequency of exercises conducted by the licensee the scenario and past exercise scenarios as they relate to testing all elements of the emergency plan and most probable accidents pre-staging of equipment in preparation for the exercise duties and responsibilities for exercise personnel including controllers, simulators, evaluators, and observers measures taken to maintain the confidentiality of the scenario and objectives Exercise Execution and Emergency Plan Implementation (IP Section 02.02)
The inspectors observed the initiation of the emergency exercise, the activation of the EOC and the emergency response team, communications issued by the EOC, personnel accountability, briefings by the EOC members, and other activities in the EOC to verify compliance with the emergency plan, emergency plan implementing procedure, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed or observed the following:
the licensees analysis of plant conditions including assessment and classification of the accident scenario staffing for all EOC positions drafting of offsite notifications including time of issuance onsite communication to occupational workers as it related to protective action recommendations occupational workers participation in protective actions and the process to conduct personnel accountability press release preparation emergency director command and control of the EOC use of the radiation survey results and environmental monitoring during assessment of the accident scenario response coordinators recommendations regarding conditions for terminating the event and restarting normal operations recovery and re-entry recommendations implemented by the emergency response team members of the licensees emergency response team assembly at designated assembly areas and the arrival of offsite emergency responders including fire and emergency medical technician emergency response teams actions including search and rescue activities for casualties, assessment of the affected areas, initial treatment of contaminated victim, and contamination control measures response to emerging situations to address the exercise scenario and meet the exercise objectives the incident commander command and control of the emergency response team and coordination of actions with offsite emergency responders 7
Critiques, Exercise Control, and Identification and Resolution of Problems (IP Section 02.03)
The inspectors observed the staff hot washes and critiques of the emergency exercise and reviewed the licensees related CAP entries to verify compliance with the emergency plan, emergency plan implementing procedure, and 10 CFR 70.22(i)(3)(xii). The inspectors reviewed the following:
initial hot washes conducted by participating licensee staff immediately following the emergency exercise critiques conducted by the licensee to determine if exercise objectives were met deficiencies identified during critiques including items planned for entry into the licensees CAP INSPECTION RESULTS No issues were identified.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On April 20, 2023, the inspectors presented the operational safety inspection results to Jeffrey Ferguson, Environmental, Health, and Safety Manager, and other members of the licensee staff.
On June 15, 2023, the inspectors presented the emergency preparedness and evaluation of exercises and drills inspection results to Roy Stutts, Operations Manager, and other members of the licensee staff.
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DOCUMENTS REVIEWED Inspection Type Designation Description or Title Revision or Procedure Date 88020 Calculations PSEDoc-0005404 Vessels V-1006A and V1006B Overflow and Pressure Basis Rev. 0 Calculations PSEDoc-0007253 WASH-101 Passive IROFS Verification Rev. 0 Calibration QC Form 974 Balance Calibration Report (Scale S/N CM8115) Performed Records Tool Overview - CM, Toledo Scale 2000LB (974) 03/23/23 and 09/20/2022 Corrective Action IR-2022-10425 Various Various Documents IR-2022-11377 IR-2022-9959 IR-2022-11427 IR-2023-001 IR-2023-477 IR-2023-1154 Corrective Action IR-2023-3941 Addition of a Periodic Inspection for the Crane Stop Passive 04/20/2023 Documents Engineering Control Resulting from Inspection Drawings 333F03PI01 Precipitation Tanks V-1006A/V-1006B and Filter Press FP- Rev. 47 1058, Sheet 1 372F07PI02 UF6 Cylinder Wash System, Sheet 1 Rev. 23 372F07PI02 UF6 Cylinder Wash System, Sheet 2 Rev. 02 Engineering PSEDoc-0005404 Vessels V-1006A and V-1006B Overflow and Pressure Basis Rev. 0 Evaluations Calculations PSEDoc-0006808 Glass Holding Vessel, V-09, Passive Overflow (WASH- Rev. 0 102/127)
PSEDoc-0007218 East Lagoon - T-1160 Dike Volume Calculation Report Rev. 0 PSEDoc-0007538 Passive IROFS Basis Documentation Extent of Condition Rev. 0 Review PSEDoc-0007538 ALOHA Analysis for 1160 Dike Rev. 0 PSEDoc-0009972 V-1006A/B Secondary Passive Overflow Capacity Rev. 0 Calculation WASH-125 Procedures COP-814529 Weigh Scale Measurement Control - CSR Area Rev. 32 9
Inspection Type Designation Description or Title Revision or Procedure Date COP-833010 Cylinder Cleaning System Rev. 69 ISA-09 ISA-09 Uranium Recovery Recycle System (URRS) Cylinder Rev. 17 Wash System ISA-15 ISA-15 Wastewater Treatment System Summary Rev. 17 MCP-108241 Backflow Preventers - Inspection and Testing Procedure Rev. 3 OP-830210 Incinerator Operation Rev. 58 PM20628 Hoist and Trolley Periodic Inspection and Preventive Maintenance (13 Weeks)
TR-305 Weigh Scale Measurement Control - UF6 Pad Rev. 13 Self-Assessments LTR-EHS-23-23 2022 Redbook Failure Evaluation Report 4/17/2023 RAF-106 Regulatory Component Audit for the Integrated Safety Rev. 0 00075, EHS- Analyses Program AUDIT-23-7 Work Orders CF-83-062 Cylinder Wash Log (work performed on 04/10/2023) Rev. 27 CF-83-192 Cylinder Wash Re-rinse Log (work completed on 11/14/2022) Rev. 12 CF-83-195 UF6 Cylinder Internal Inspection Status (work performed on Rev. 7 11/04/2022)
CF-83-251 UF6 Cylinder High-Pressure Lance Administrative Safety Rev. 8 Controls (work performed on 04/07/2022)
OM 85151 Dispatch 22599: 52 Weeks SI-Safety, V07A Primary and Closed on Redundant Vent (IROFS WASH-146) 05/11/2022 OM81246 Dispatch 120442: 26 Weeks SI-Safety, V1006 A and B Completed Passive Overflow (IROFS WASH-122/-128) 07/05/2022 OM81246 Dispatch 155214: 26 Weeks SI-Safety, V1006 A and B Closed on Passive Overflow (IROFS WASH-122/-128) 01/05/2023 OM81246 Dispatch 81920: 26 Weeks SI-Safety, V1006 A and B Closed on Passive Overflow (IROFS WASH-122/-128) 01/05/2022 OM85056 Dispatch 151303: 52 Weeks SI-Safety, Cylinder Wash Closed on Weight Interlock (IROFS WASH-116) 12/12/2022 OM85056 Dispatch 18538: 52 Weeks SI-Safety, Cylinder Wash Weight Closed on Interlock (IROFS WASH-116) 12/15/2020 OM85056 Dispatch 80238: 52 Weeks SI-Safety, Cylinder Wash Weight Closed on Interlock (IROFS WASH-116) 12/09/2021 OM85150 Dispatch 122942: 26 Weeks SI-Safety, V-09 Column Closed on 10
Inspection Type Designation Description or Title Revision or Procedure Date Overflow Verification (IROFS WASH-102/-127) 07/12/2022 OM85150 Dispatch 156439: 26 Weeks SI-Safety, V-09 Column Closed on Overflow Verification (IROFS WASH-102/-127) 01/09/20223 OM85150 Dispatch 87603: 26 Weeks SI-Safety, V-09 Column Overflow Closed on Verification (IROFS WASH-102/-127) 01/17/2022 OM85151 Dispatch 22599: 52 Weeks SI-Safety, V07A Primary and Closed on Redundant Vent Functional Verification (IROFS WASH-146) 01/26/2021 OM85151 Dispatch 41404: 52 Weeks SI-Safety, V07A Primary and Closed on Redundant Vent Functional Verification (IROFS WASH-146) 05/12/2021 OM85151 Dispatch 109459: 52 Weeks SI-Safety, V07A Primary and Closed on Redundant Vent Functional Verification (IROFS WASH-146) 05/11/2022 Work Order Various Various (Dispatch) 141101, 106859, 32349, 14883, 88050 Corrective Action IR-2022-1549 EP-Related CAP Entries Various Documents IR-2022-1826 IR-2022-3195 IR-2022-4388 IR-2023-0096 IR-2023-2057 IR-2023-4006 IR-2023-4681 Miscellaneous March 2023 Drill Records Various EOC Training/Event Roster, Tabletop - Bomb Threat 06/07/2022 January 2023 Tornado Drill Records Various EOC Training/Event Roster, EOC Earthquake Discussion 09/13/2022 Evacuation drill records for all shifts 11/21/2022, 11/22/2022 EOC Criticality Tabletop Records 01/10/2023 Incident Safety Officer Training 2019 Columbia Fuel Fabrication Facility Site Emergency Plan Rev. 23 Form CF-81-230 1st Shift Conversion Weekly Safety Checklist MOU Fire Memorandum of Understanding with Richland County Fire 01/03/2023 11
Inspection Type Designation Description or Title Revision or Procedure Date Department Department MOU Prisma Agreement for Medical Treatment of Contaminated Patients 01/03/2023 Hospital MOU Richland Memorandum of Understanding with Richland County 02/21/2023 ESD Emergency Services Department MOU SCDHEC Memorandum of Understanding With South Carolina 01/03/2023 Department of Health and Environmental Control MOU Sheriff's Memorandum of Understanding with Richland County 01/03/2023 Department Sheriff's Department TRN-001-1 Polies and Guidelines, Site Security, ARC, CAP, Redbook, 2023 Lightning Safety and Recording Devices TRN-095 Emergency Operations Center (EOC) Refresher Training Procedures RA-107 Corrective Action Process for Regulatory Events Rev. 28 RA-120-24 Decontamination of Potentially Contaminated Injured Rev. 1 Personnel ROF-07-001-15 Health Physics Response to Radiological Releases Rev. 1 ROF-07-001-2 Health Physics Response to Contaminated Injury/Ill Victim Rev. 7 ROP-05-028 Employee Work Restrictions Rev. 23 ROP-07-001 Health Physics Response to Emergency Events Rev. 14 SEP-001 Emergency Response Organization (ERO) Rev. 9 SEP-002 Classification Rev. 7 SEP-004 Emergency Equipment and Supplies Rev. 14 SEP-007 Notification Guidelines for NRC and Other Agencies Rev. 57 SEPS-003-1 ERO Training Matrix Rev. 2 Self-Assessments EHS-AUDIT-21-2 Emergency Preparedness Program Audit 04/20/2021 EHS-AUDIT-22-2 Emergency Preparedness Audit 02/25/2022 88051 Corrective Action IR-2023-5813 NRC Inspector Observations from Biennial Emergency 06/15/2023 Documents Preparedness Exercise Inspection Resulting from Inspection Miscellaneous Westinghouse CFFF Biennial Exercise June 14, 2023 Controller/Evaluator Manual Westinghouse Preliminary Scenario and Date for 2023 04/04/2023 Emergency Response Exercise 12
Inspection Type Designation Description or Title Revision or Procedure Date After Action Report Westinghouse CFFF Biennial Exercise - Rev. 0 2023 Procedures CERG-003 Instructions for Conducting Drills and Exercises Rev. 3 SEP-003 Emergency Response Team Rev. 7 SEP-014 Response to Extreme Environmental Conditions Rev. 5 SEP-018 Emergency Operations Center (EOC) Operations Rev. 5 SEPF -018-3 EH&S Checklist SEPF-018-04 Regulatory Checklist Rev. 4 SEPF-018-1 Emergency Director Checklist SEPF-018-13 Seismic Event - Department Actions SEPF-018-2 Safety Checklist 13