ML20035D341
| ML20035D341 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/23/1993 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| References | |
| EA-93-044, EA-93-44, NUDOCS 9304130094 | |
| Download: ML20035D341 (22) | |
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lN231993-q Docket No. 70-1151 l
License No SNM-1107 j
EA 93-044 i
Westinghouse Electric Corporation ATTN: Mr. J. A. Fi:i, Manager Columbia P1 ant Commercial Nuclear Fuel Division Drawer R l
Columbia, SC 29250 i
Gentlemen:
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SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
1 This letter refers to the Enforcement Conference held at our request on March 17, 1993. The meeting concerned activities authorized for your Columbia l
facility. The issues discussed at the conference related to the failure to i
perform nuclear criticality safety analyses for various non-favorable' geometry l
containers that you had been using at your plant, lack of justification for using the containers, an 25 g U - 235 / L IN SUMP I
I MAJOR TANK TANKS DUMPED LEAK
@ > 10 g U - 235 / L O
(NO IIISTURY)
(NO IIISTORY)
CONCENTRATION WmIOUT CONCENTImTION Wmf BASE ADDED BASE ADDED (NOT CREDIBLIO (NOT AVAILABIl3
UNH TANKS l
BARRIER PREVENT > 5 g U - 235 / L UNH FROM BEING TRANSFERRED TO TANKS CONTROLS
- BATCH DISCHARGE, WITH SAMPLING AND ANALYSES OF EACH BATCH
- ANALYSIS OVERCHECK BY 2nd PERSON PRIOR TO TRANSFER
- ALL TRANSFERS THROUGH PASSIVE ENGINEERED " SPOOL PIECES"
- DOUBLE FILTRATION OF UNH FROM DISSOLVERS
- GAMMA MONITORS IN TRANSFER LINES
UNH TANKS BARRIER PREVENT PRECIPITATION / SETTLING OF URANIUM IN TANKS CONTROLS
- SAMPLING AND ANALYSIS OF FREE ACID IN FEED MATERIAL
- ADMINISTRATIVE CONTROLS TO PROHIBIT INTRODUCTION OF UNAUTHORIZED MATERIALS
- PASSIVE ENGINEERED " SPOOL PIECES" TO PREVENT INTRODUCTION OF UNAUTHORIZED MATERIALS
- NO CAUSTIC LINES TO TANKS OR IN AREA
- CONTINUOUS IN-TANK AGITATION
- CONTINUOUS RECIRCULATION THROUGH GAMMA MONITORS
- RECIRCULATION LINES ARE HEAT TRACED
- UNH TEMPERATURE CHECKS
ROOT CALSE ANALYSIS - StMP CAUSAL SUMP EXCLUDED FROM CIIANGE AUTIIORIZATION FACTOR
+
PRIMARY DIFFICULTY SUPPORT DIFFICULTY SOURCE p
r IIEALTil PROTECTION AREA OF ORGANIZATION RESPONSIBILITY v
MAJOR ROOT CAUSE PROCEDURES CATEGORY
+
NLL NEAR ROOT CAUSE F
INCORRE Y
t v
LACK OF DETAILED ROOT CAUSE INSTRUCDONS /
REQUIREMENTS FIX: PROCEDURE RA - 104;
" CHANGE AUTHORIZATIONS";
TOTAL REVISION TO CLARIFY INSTRUCflONS / REQUIREMENTS; APPROVED FEBRUARY 1993
THE USE OF NFG CONTAINERS WAS SAFE 4
BUT THE SAFETY EVALUATION WAS LESS THAN ADEQUATE
- DETERMINISTIC FAULT TREE ANALYSIS
- ROOT CAUSE ANALYSIS
., ~
9 SAFETY ASALYSIS - NFG CONTAINERS (LIQUID SYSTEMS)
CRITICALITY CONDITION I
I MATERIAL CONCENTRA1TS SYFm M bTG CONTAINTR USED
> 25 g U - 2M / L IN SYSTEM LEAKS TO CDLLECT LEAK (NO IIISTORY)
(INFREQUENT)
(NO IllSTORY) l l
I I
TRAINING PROCEDURE FAILURE VIOLATED j
l
o SAFETY ANALYSIS - :S FG CONTALS ERS (NON-LIQUID SYSTEMS)
CRmCALITY CONDITION A
PROCESS UPSET NFO CONTAINER USE PROVIDES MOTIVE PROVIDES OPPORTUNITY (NO IIl5 TORY)
(ANALYSES SIIOW UNLIKELY) l I
ADVERSE SUFFICIENT ADEQUATB GEOMLTRY URANIUM MODERATION l
I I
TRAINING PROCEDURE FAIIURE VIOLATED
ROOT CAUSE AXALYSIS - NFG CONTAINERS l
CAUSAL GENERIC APPROVAL FOR NFG CONTAINERS l
FACTOR
+
l PRIMARY DIFFICULTY SUPPORT DIFFICULTY SOURCE r
IIEALTH PROTECTION AREA OF ORGANIZAT10N RESPONSIBILITY 1 r MAJOR ROOT CAUSE MANAGEMENT CATEGORY SYSTEMS h
lr 3}
SAFETY REVIEW NEAR ROOT CAUSE k
)
1 r
^
ROOT CAUSE LESS TIiAA E UATE FIX: MAJOR SAFETY REVIEW OF NON-FAVORABLE GEOMETRY CONTAINER PRACTICES IN PROGRESS SINCE AUGUST 1992; INCLUDES MINIMIZATION OF NUMBERS, AND SPECIFIC APPROVALS FOR ALL THAT REMAIN
PRIOR COMPLIANCE PERFORMANCE 1
(SANS NUCLEAR CRITICALITY SAFETY)
JULY 1990 - DECEMBER 1992 P
i NUMBER OF INSPECTIONS 18 SNM SAFEGUARDS 8
RADIATION PROTECTION 6
i OPERATIONAL SAFETY ASSESSMENT 1
l I
NUMBER OF VIOLATIONS 8
RADIATION PROTECTION 4 (IV)
SNM SAFEGUARDS 3 (V)
EMERGENCY PREPAREDNESS 1 (IV)
NUMBER OF REPEAT VIOLATIONS 0
H:\\HOME\\CALTM\\GOCDWIN\\ AGENDA.h7C
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PRIOR COMPLIANCE PERFORMANCE (NUCLEAR CRITICALITY SAFETY)
JULY 1990 - DECEMBER 1992 NUMBER OF INSPECTIONS 7
NUMBER OF VIOLATIONS 0
NUMBER OF REPEAT VIOLATIONS N/A l
i b
f I
H:\\HOME\\CALTM\\OOODWIN\\ AGENDA.NRC i
LICENSEE PERCEPTIONS e
NRC FEEDBACK ee COMMISSIONER CURTIS' VISIT ee REQUESTS FOR PLANT TOURS ee STATEMENTS
)
+ + " WESTINGHOUSE IS ONE OF OUR BEST LICENSEES."
+ + "NO SIGNIFICANT PROBLEMS"
+ + " RECORD OF COURTESY REPORTING IS GOOD. "
+ + " STAFF SPEAKS HIGHLY OF WESTINGHOUSE."
+ + "NO COMPLAINTS TO LOOK INTO"
++ "WHEN YOU DO QUALITY WELL, YOU DO SAFETY WELL."
++ " WESTINGHOUSE ORG ANIZ ATION AL STRUCTURE LOOKS SOUND DOES NOT CREATE SPAN-OF~ CONTROL PROBLEMS THAT HURT (ANOTHER LICENSEE)."
H:\\HOME\\CALTM\\GOODWIN\\ AGENDA.hTC
=_
LICENSEE PERCEPTIONS i
e PERFORMANCE LEVEL HAS CERTAINLY NOT DECLINED GOOD PERFORMANCE OVERALL ENFORCEMENT HISTORY PROACTIVE POSTURE CUSTOMER FEEDBACK OUR CONTINUOUS IMPROVEMENT AND "DOING THE RIGHT THINGS" PHILOSOPHY WILL GUIDE FURTHER IMPROVEMENTS I
UNDERSTANDING THAT THINGS HAVE CHANGED i
HEIGHTENED EXPECTATIONS CLOSER SCRUTINY 4
NEED EXISTS TO WORK CLOSELY WITH NRC TO UNDERSTAND WHAT IS EXPECTED l
t H:\\HOM E\\CALTMiGOODWIN\\AG END A.NRC
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l ENCLOSURE 3 2
During the Enforcement Conference, Westinghouse representatives pointed out two errors in the NRC Inspection Reports which discussed the problems with criticality safety analyses for non-favorable geometry containers and the use
-l of inadequate procedures by the licensee. The first error in the reports dealt with the " generic" approval of non-favorable geometry containers for use in the processing areas of the facility. The licensee indicated that generic approval was given for use of non-favorable geometry containers but only for collection and storage of slightly contaminated waste. The other uses of such containers had to be approved on a case-by-case basis.-
The second error dealt with the subject of inadequate reviews by licensee management which lead to the use of inadequate procedures.
The inspection reports indicated that a Chemical Operating Procedure, COP-814700, had been revised and reviewed and that a step to perform one of the two required i
confirmatory moisture analyses had been deleted. The licensee indicated that the procedure had been revised and that one of the types of analyses had been eliminated.
However, the type of analysis that was eliminated was an indirect i
measurement of moisture content in the product.
In a previous version, COP-814700 had required a direct measurement of moisture content in the product j
and an indirect measurement of moisture content, an oxygen to uranium (0/U) j ratio determination.
In the subsequent version of COP-814700, the procedure had been revised to require two direct measurements of moisture and the limit for the allowable percent moisture in an acceptable sample had been reduced from 0.6 percent to 0.4 percent. Although an administrative procedure was in effect that required both direct and indirect moisture analyses, the licensee t
indicated that it was their practice to authorize the use of an operating procedure with requirements that were more restrictive than the administrative procedure.
l After reviewing the reports and discussing the matter with the licensee, the i
NRC agrees that the reports contained errors. The corrections to these reports are listed below.
i Concerning the use of terminology connoting the " generic" authorization for the use of non-favorable geometry containers:
1.
Reference NRC Inspection Report No. 70-1151/92-04, Paragraph 4.c, page 34.
i The second and third sentences in the first paragraph read as follows:
j "Use of these containers was generically approved by the l
licensee in Regulatory Affairs Procedure No. RA-301-1, Rev.
8, ' Nuclear Control Criteria.' This generic approval did not provide adequate evaluation of accident scenarios as required by Section 2.3.1.10 of their license."
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ENCLOSURE 3 2
The sentences should read as follows:
"Use of these containers was approved by the licensee in Regulatory Affairs Procedure No. RA-301, Rev. 6, ' Nuclear Control Criteria,' Part RA-301-1.
This approval did not I
provide adequate evaluation of accident scenarios as i
required by Section 2.3.1.10 of their license."
2.
Reference NRC Inspection Report N' 70-1151/93-01. Paragraph 6.b.2), page 6.
The first sentence reads as follows:
l
" Attachment RA-301-1, ' Floor Storage Plan,' of Procedure RA-l 301, ' Nuclear Criticality Control Criteria,' Rev. 6, dated i
January 10, 1990, allowed generic authorization for the use of non-favorable geometry containers (i.e. 55-gallon drums) without requiring justifications for the containers and without criticality safety analyses of the various applications of the containers which included process upsets."
This sentence should read:
" Attachment RA-301-1, ' Floor Storage Plan,' of Procedure RA-i 301, ' Nuclear Criticality Control Criteria,' Rev. 6, dated January 10, 1990, authorized the use of non-favorable i
geometry containers (i.e. 55-gallon drums) without requiring justifications for the containers and without criticality safety analyses of the various applications of the l
containers which included process upsets."
Concerning Chemical Operating Procedure COP-814700:
1.
Reference NRC Inspection Report No. 70-1151/92-04, Paragraph 2.b.(3)(c), page 7.
i This sentence reads as follows:
" Procedure COP-814700, ' Bulk Handling / Moderation Control,'
was revised and the step to perform one of the required confirmatory moisture samples was deleted."
The entire sentence should be deleted.
i 2.
Reference NRC Inspection Report No. 70-1151/93-01, Paragraph t
3.b.2), page 2.
l This sentence reads as follows:
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" Procedure COP-814700, ' Bulk Handling / Moderation Control,'
)
Rev. 12, dated May 21, 1992, was revised and reviewed but a l
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ENCLO'URE 3 3
S step to perforn one of the required confirmatory moisture samples (required by Procedure RA-303, ' Control of Moderating Materials for Nuclear Criticality Safety,' Rev.
1, dated July 10, 1989) had been deleted."
i This sentence should be deleted and the first sentence in Paragraph 3.c. should read as follows:
"The above is an example of an inadequate procedure which was being used by the licensee."
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