ML20199F374
| ML20199F374 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 01/12/1999 |
| From: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-1257-98-204, LJM:99:001, LJM:99:1, NUDOCS 9901210304 | |
| Download: ML20199F374 (6) | |
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SIEMENS I
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~ January 12,1999 j
LJM:99:OO1 i
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
Gentleme.1:
Subject:
Reply to a Notice of Violation (License No. SNM-1227; Docket No. 70-1257)
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Ref.:
Letter, P. Ting (US NRC) to B. N. Femreite (SPC), "NRC Inspection Report No. 70-1257/98-204 and Notice of Violation", dated December 14,1998 Attached is Siemens Power Corporation's (SPC's) reply to the Notice of Violation accompanying the referenced letter, if you have any questions regarding this reply or require more information, please contact me at (509) 375-8537.
Very truly yours, o
drf.v W
L. J. Maas, Manager Regulatory Compliance
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Enclosures I
cc: U. S. Nuclear Regulatory Commission Regional Administrator, Region IV Arlington, TX l
I, D P. Ting, Chief AN Fuel Cycle Operations Branch
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j Division of Fuel Cycle Safety and Safeguards j
9901210304 990112 PDR ADOCK 07001257 C
PDR Siemens Power Corporation 21o1 Horn Rapids Road Tel:
(509) 375-8100 Richland, WA 99352 Fax:
(509) 375-8402
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Attachment Violation Safety Condition S-1 of License SNM-1257 [ note: SPC's NRC license is actually SNM-1227; the docket is 70-1257) requires the use of licensed material in accordance with the statements, representations, and conditions of the License Application and supplements.
License Section 2.5 states, in part, that "Siemens Power Corporation (SPC) is committed to controlling activities involving speciti nuclear rnaterials in accordance with these approved written procedures, standards and guides."
Licensee Criticality Safety Specification UO50 Section IB.2 requires that "an operator visually verify that any equipment disassembled is free from visible uranium before staging it with other disassembled equipment."
Contrary to the above, on September 21,1998, during a routine walkthrough, the licensee discovered approximately 100 feet of ductwork containing 9.2 kilograms of uranium mixed with ammonium nitrate, that had been removed and staged with other disassembled equipment without being verified to be free from visible uranium.
Backaround Information The subject violation occurred during the dismantling, by outside contractor personnel, of a long-standing plant process system, namely Ammonium Diuranate Line 1 (Line 1 ADU).
Pertinent information on the transition of this system from operational status to a dismantle / decontaminate (D&D) status is provided below as background.
SPC operated the Line 1 ADU process for over 28 years. Following successful startup of the Dry Conversion Facility, planning began to dismantle and decontaminate (or dispose of) Line 1 of the ADU system. Prior to approval of the Engineering Change Notice (ECN) under which these activities were to be controlled, several preparatory actions were taken. These actions included establishment of additional criticality safety controls. SPC criticality safety engineers reviewed the proposed D&D activities and modified the Criticality Safety Specifications (CSSs) as appropriate to suppc,rt them. Some of the key requirements established in the CSSs included:
"An operator shall visually verify that any equipment disassembled is free from visible uranium before staging it with other disassembled equipment."
" Visual U-bearing compounds shall be transferred to a 5-gallon or less container and handled e
as moderated."
"The D&D activity shall be covered by a standard operating procedure (SOP) approved by e
Criticality Safety."
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Criticality Safety approved the SOP that covered the Line 1 ADU D&D activity before it commenced. This SOP required, among other things, the following duct inspections and clean-out activities:
inspect all ductwork inspection ports for uranium accumulations per inspection list.
e Clear, m.:t dryer and dryer vent lines; acid wash the dryer.
Clean out main process off-gas (POG) duct to the Y-section. Do not re-assemble.
Clean out and acid wash the Y-section. Do not re-assemble.
Complete the K-10 HVAC system preventative maintenance surveillance and sample any material found between Tank 18 (containing POG scrubber purge solution) and the K-10 systern MPA filters for percent uranium and U enrichment.
SPC operations personnel comp!?ted all the activities required by the SOP prior to the contractor D&D crews commencing work. This ensured that the equipment had minimal holdup of U-bearing material and the ductwork complied with the applicable uranium mass limit. Howevec, as noted in the Notice of Violation, SPC failed for a period of time during the D&D activities to implement the critica!!ty safety requirement for a process operator to visually verify that any equipment disassembled was free from visible uranium before Maging it with other disassembled equipment. The fact that these verifications were not being conducted was discovered by an SPC criticality safety specialist who, on a routine walk-through, noted approximately 100 feet of ductwork stacked in the Line 1 ADU area. He further noted approximately 1.5 liters of solid material in the end of one piece of ductwork, along with a thin scale (~1/8 inch) of solids on some of the other sections. SPC's internal investigation indicated that the gap in implementation of this required verification was from three to five days in duratiori.
Reason for Violation This violation of criticality safety control requirements was investigated by a forma! SPC Incident investigation Board (llB). Incident root causes identified by the hB included " Procedures Not Followed", " Communications / Turnover Less Than Adequate", and " Training / Understanding Less Than Adequate."
The " Procedures Not Followed" root cause involved a breakdown in commuriications among the SPC project engineer, SPC process operators, SPC air balance personnel, and contractor D&D personnel. Informed by an SPC Operations shift supervisor of the temporary unavailability of operators to perform the required inspections, the project engineer directed the contractor personnel to request this support from SPC air balance personnel. The project engineer crroneously assumed that air balance technicians could provide this service. When contacted by the D&D personnel, the air balance personnel indicated that they were not authorized to perform these inspections as called for in the CSS but that they would enlist process operator
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support. D&D personnel subsequently noted process operators passing through the work area
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in the course of performing :,ther duties. They assumed the operators were performing the i
inspections pursuant to the request of the air balance staff. This was not the case, leading the contractor D&D personnel to mistakenly assume that the procedure was being followed when in fact it was not.
The " Communications / Turnover Less Than Adequate" root cause involved weaknesses in the turnover of responsibility for the Line 1 ADU D&D job from one project engineer to another. The
Page 3 ne'wly assigned project engineer was on vacation at the time of this transfer. While the CSSs governing the Line 1 ADU D&D work were a part of the turnover package, a less-than-formal job turnover did not assure effective communication of this information.
The " Training / Understanding Less Than Adequate" root cause referred to both the newly e m gned project engineer and the contractor personnel and is closely linked with the communications deficiencies involved in the previously discussed " Procedures Not Followed" root cause. The project engineer's understanding of the CSSs was less than adequate in that he believed that the requirement for a trained operator could be met by an air balance technician since these individuals routinely handle contaminated HEPA filters. The contractor D&D personnel were less-than-adequately trained and/or monitored in that, failing to recognize that the inspections were not being performed by the process operators, they proceeded with the demolition work in the absence of the required accompanying inspections.
Corrective Steos Taken A number of corrective steps were taken to provide an immediate response to the discovered i
condition, as well as to allow restart and continued safe conduct of these activities.
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All work on the Line 1 ADU project was stopped until the incident could be fully investigated and necessary corrective actions irnplemented.
Visible solids were removed from the ductwork under the direction of the criticality safety p
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specialist. Analysis of the 34 kg of material recover ~ed indicated the presence of 9.2 kg of low-enriched uranium, approximately 58 percent of the 15.8 kg process controllimit for this equipment.
Because it has similar ductwork, Line 2 ADU was shut down until that ductwork could be inspected for solids accumulation per existing preventive maintenance procedures. The
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inspection revealed no significant solids accumulation.
All Manufacturing Engineering and Plant Operations staff associated with this work reviewed the incident and were retrained to the applicable safety requirements, including all applicable criticality safety requirements.
Contractor D&D personnel were retrained to the safety requirements of the D&D work, inc!uding pertinent CSSs.
Corrective Steos to Avoid Further Violations Th following actions have been or are being undertaken to avoid recurrence of this violation or violations of a similar sort:
Manufacturing Engineering, via the project engineer, will conduct pre-job briefings before initiating any new process equipment disassembly associated with the Line 1 ADU D&D project. The briefing will incluos Plant Support supervisors, operators, and contractors as appropriate. Qnaoing.
Facilities Engineering will evaluate relocation of the Line 2 ADU K-32 HEPA filters closer to the scrubbers and replacement of the current ductwork with favorable geometry duck work.
Evaluation complete. Desian in orcoress: installation croiected for March 1999.
Plant Engineering will evaluate a non-destructive external measurement method to provide in-place ductwork inspections m lieu of the current visual inspection via inspection ports.
Evaluation emolete (visual inspection still considered most appropriate).
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Manufacturing Engineering will revise EMF-858, Manufacturing Engineering Procedures and i
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Practices, to define pre-job briefings and require them on all non-routine maintenance E
activities that require a Maintenance Work Permit (MWP). Additionally, the application of MWPs will be expanded to include specific systems outside of the radiological controlled 4
areas that are deemed to pose significant safety hazards during maintenance activities.
Proiected imolementation, Aoril 30,1999.
Date When Full Comoliance Will Be Achieved i
The Line 1 ADU D&D activities are nearly complete and SPC is currently in full compliance with all criticality safety reouirements for this activity.
Other SPC Actions Relative to Control of Contractor Activities in the referenced letter, the NRC speA.mally requested that SPC address any actions taken or planned to assure that future contract,r activities will be conducted in accordance with established nuclear criticality safety con'.rols. SPC recognizes the need to carefully and i
consistently control the work of contractors in all SPC work arers, and in particular where licensed materialis processed or stored. Outside construction contractors (per the broad OSHA i
construction definition) utilized at SPC are covered under EMF-P65,544, "Outside Construction Contractor Health and Safety Requirements." Under this program,.ch contractor enters into a signed Construction Contractor Health and Safety Agreement and is controlled by a designated SPC contractor coordinator. It is the responsibility of the SPC contractor coordinator to assure that contractor employees are enrolled in site health and safety orientation training (which includes criticality safety and configuration control training) as well as specific followup safety training dictated by the work being performed by the contractor. Training requirements for all j
categories of employees working onsite (SPC employees, SPC contractors, general contractors, etc.) are defined in EMF-P65,541, "New Employee Health and Safety Orientation Training."
These procedures / programs are established and ongoing.
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As noted in the corrective actions discussed above, contractor employees involved in the Line 1 ADU D&D project have been retrained to the safety requirements of the D&D work, including pertinent criticality safety specifications. Furthermore, the project engineer is condzting pre-job briefings including contractor personnel prior to initiating any new process e J!pment disassembly associated with this project. Additionally, as a generic implicationi measure and as a matter of sound maintenance practice, Manufacturing Engineering it revising its EMF 458 procedures to expand its current Maintenance Work Permit program, a?d thn to supplement that program with required pre-job briefings which wCl include safety issues. This program, projected for full implementation by April ?O,1999, will give special attention to maintenance activities performed utilizing centractor personnel. SPC believes that these maintenance program enhancements, con 9,ined with SPC's established contractor management and training j
protocols, will provide the level of contractor control demanded by SPC and desired by the NRC.
As a final note, SPC wishes to address a subsequent internal criticality safety violation that occurred in the Line 1 ADU werk area due to the action of a contractor employee. As noted in the NRC inspection report, ths incident, reported on an SPC Criticality Safety Corrective Action Report on October 8,1998, involved the unauthorized movement of a storage grid rack containing two containers of licensed material. Although this violation was related to the cited violation in that it occurred in the Line 1 ADU D&D area and involved a contractor, it did not
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sh,are the " communication / understanding less than adequate"' issues implicated with the 2
ductwork inspection violation. The individual who moved the grid rack was deemed to have
' been adequately trained and was' dismissed from the site as a result of this violation.
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