ML20217D733
| ML20217D733 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/27/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20136C177 | List: |
| References | |
| 70-1113-97-01, 70-1113-97-1, NUDOCS 9703110301 | |
| Download: ML20217D733 (16) | |
Text
_ _ _ _ _ _ _ _ _ _ _ _ _ -
t U. S. NUCLEAR REGULATORY COMMISSION REGION 11 Docket No.:
70 1113 i
License No.:
SNM 1097 l
Report No.:
70 1113/97 01 Licensee:
General Electric Company Facility:
Nuclear Energy Production location:
Wilmington, North Carolina Dates:
Januuy 27 31, 1997 Inspector:
G. L. Troup Sr. Fuel Facilities Inspector Accompanying Personnel: D A. Ayres Fuel Facilities Inspector C. A. Blanchard fuel Cycle Inspector, Region 111 Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 97Osllogoq g
L
I EXECUTIVE
SUMMARY
General Electric Nuclear Energy Production NRC Inspection Report 70 1113/97 01 This routine, announced inspection was focused on management controls, I
operations, training, review of previously reported events, status of the new DCF and follow up on previous inspection findings, Back shift inspections were conduct <d on January 29 and 30.
The inspection was focused on the safe operation of the facility.
Plant Operations l
l Corrective actions to resolve the undocumented " idling" of process e
alarms have been completed and implemented, l
The licensee had implemented an effective program to control the keys e
for AECs, which is now covered by a document specifying how the program is to be implemented.
The short corrective actions necessary for restart of the calciners were e
satisfactorily completed. Two long term actions remain to be completed, honacement Oraanization and Controls Persons appointed to positions described in the license application mot e
the educational and experience reouirements. Other persons were qualified for the position.
Maintenance / Surveillance The criticality monitoring system has been calibrated and functionally e
tested as required by the license and procedural requirements.
New criticality monitors have been installed to provide adequate coverage of the facility and properly calibrated, Work is in progress to resolve previously identified problems with e
warning horns and the associated wiring circuits.
Trainina New employee nuclear safety training and refresher training have been e
adequately implemented in accordance with regulatory requirements DCF Pro.iect Facility construction is nearing completion. Testing of the e
instrumentation and control circuits has begun.
)
2 The Hazards Analysis is complete, The licensee is implementing a
=
readiness review for the facility prior to management approval of the final hazards list.
l 61.tachments Partial List of Persons Contacted Inspection Procedures used List of Items Opened, Closed and Discussed List of Acronyms i
l 6
l
REPORT DETAILS Summary of Plant Status This report covers a one week period. During the uranium recovery operations were running normally. period, fuel production and Powder production operations were shut down on January 27 to resolve an identified problem with Plant Process Alarms in the chemical area which were found to be in the " idle" condition. This is discussed further in Paragraph 1.a.(1). Operation of the process lines resumed on January 30.
Construction activities for the new powder production facility (DCF) were progressing.
Pre operational activities. such as instrumentation and control system loop checks and continuity checks had begun.
A new warehouse and refurbishment facility for shipping containers has been completed and released for use.
No other NRC inspections occurred during this period.
1.
ElantOoerations(03)(88020) a.
Imolementation of Process Safety Controls (03.03)
(1)
Process Control Alarms (a)
Inspection Scope The inspector reviewed the licensee's investigation into the cause of certain process alarms be in the
" idle" mode and the corrective actions taken.
(b)
Observations and Findings On January 28, 1997, licensee representatives informed the inspector of a condition concerning inoperable alarms on the chemical systems. On January 24, a
" flame out" had occurred on a calciner. The introduction of process gases was stopped by an Active Engineered Control (AEC), but an alarm did not activate to alert the operator so feed material continued to be fed to the calciner.
The initial investigation revealed that the Plant Process Area (PPA) alarms were in the " idle" condition rather than " operate" or " active." Hanagement became aware at this time that the alarms could be accessed through the control system key board by typing several functions or " commands" without the need for a password or supervisory ap>roval (this is how the system was set up rather tlan some anomaly).
v
2 Normall Mode," y, the control systen, is accessed through " Tune which re documentation. quires written approval and After this particular PPA alarm was returned to " operate " other PPA alarms were checked.
Of the remaining 17 PPAs in the chemical area, all were found in the " idle" state. All process lines were shut down until the effect of the alarms being in
- 1dle" could be determined.
As part of the investigation it was determined that placing alarms in " idle" did not affect any of the controls for safety interlocks, AECs or signals which activated an alarm requiring operator response (OARS).
The PPA alarms were determined to be alarms which I
informed the operator of an off specification condition, but which did not affect automatic controls. However, there was no indication on the cont.rol console screen that the PPA alarms were in "icle." When the process lines were last shut down, the alarms were a e
nuisance alarms, pparently placed in " idle" to avoid such as a " low temperature" alarm when a calciner was cold.
After it was determined that placing PPA alarms in
" idle" did not affect any of the safety controls, it was decided to change the program to require formal approval to place PPA alarm in "idie" and to document such a condition. A Software Service Request (SSR) was approved by the system owner and the software engineer on January 29 to place the PPA under Tune Mode control, such that written approval on the Tune Mode form is required and the Area Coordinator has to release the console key to make the change.
Completion of the activity and return to " normal" is also documented. Operating Procedure (0P) 1010.01 was revised and approved on January 29, 1997, to require that, prior to start u), the Process Mana and PPA alarms had to >e verified as "on"gement Area or " operate" or " active" (must not be in " idle" before start up) and any changes had to be processed under the
- Tune Mode" control system.
Following revision of the OP and training of the operators, the systems were released for operation and were operating normally by January 30, 1997.
(c)
Conclusions While placing PPA alarms in " idle" did not override or shut down any safety functions, the shut down of the process lines until the condition could be evaluated Nas a proper safe act.
l I
)
4 i
3 3
1 Changes to the process control system were initiated
{
end approved in accordance with plant procedural requirements, l
j 2.
AEC Key Control i
(a)
Inspection Scope The inspe: tion consisted of a review of 3rocedural controls utablished for the control of ceys used for positive control over Active Engineered Controls (AECs),
(b)
Observations and Findings The control of AEC keys was reviewed in Inspection Report (IR) 70 1113/96 11. The inspector determined that the licensee had adequate controls for the keys, but there was no procedure which specified how the key control program was to be implemented.
i Licensee personnel stated that 'they initially considered issuing the controls as a Nuclear Safety Instruction (NSI). However, NSIs are used only by Nuclear Safety personnel and personnel in other departments are active participants with the keys.
On January 28, 1997, a Section Administrative Routine (SAR) was issued jointly by Manager, Chemical Product Line and the Hanager, Fuel Fabrication Product Line.
SAR 350 36, Rev, 0, " Key Control" describes how personnel are to obtain, use and return keys for AECs.
(c)
Conclusions The inspector concluded that the issuance of the SAR satisfactorily implemented the administrative controls for AEC keys.-
4 b.
Review of Previous Events (03.07)
(1)
Inspection Scope The inspector reviewed the licensee's corrective actions resulting from the failure of the tube in the Line 3 calciner.
(2)
Observations and Findings The Line 3 calciner tube failure reported to NRC on December 3,1996, and reviewed in NRC IR 70 1113/96 12, prompted the licensee to consider a number of long and
4 short term corrective actions to preclude a similar event.
1hese corrective actions were documented by letter to Director, Division of Nuclear Materials Safety, Region II, dated December 11, 1996. Attachment III of the letter lists nine corrective actions, the first five of which were to be completed prior to restarting each calciner. The corrective actions were listed in Attachment III of the letter as
- follows, i
1.
Tighten tolerance on tube rotation limit switch.
2.
Enhance the isolation of ADV to the calciner.
l 3.
Correct weaknesses in calciner stack monitoring data repsrting.
4.
Modify control system to require weekly calciner stack result input.
5.
Evaluate and formalize preventive maintenance program for calciner tubes.
6.
Revise Criticality Safety Analysis of the " tube break" accident condition.
7.
Revise vendor specification for rolled alloy calciner tubes.
8.
Revise change control process to emphasize impact of construction mcterial changes.
S.
Evaluate new technology to gamma scan uranium within calciner annulus.
Corrective action No. I was to be im)1emented by adjusting the timer settings on the switches tlat monitor calciner tube rotation. Corrective action No. 2 was to be imn emented by installing an electrically actuated three way vaTvetodivertthecalcinerwetADUfeedtoarecirculation loop upon loss of tube rotation on lines one through four.
Corrective action No. 2 also included automatically stopping dry, recycle material feed to the calciner upon loss of tube rotation on lines one through five. The inspector reviewed the calciner restart checklists and results of the functional tests for lines one through five. The inspector also observed the. presence of the three way valves-installed in the calciner wet ADU feed system. The inspector found that corrective action No. 1-and corrective action No. 2 for
4 5
wet ADV feed were documented as being completed and tested on or before December 12, 1996.
The documentation also showed that corrective action No. 2 for dry feed was i
completed and tested for lines one through five on or before January 22, 1997.
l Corrective action No. 3 was to be implemented by modifying ProVox to check for calciner stack emission results above a predetermined action level.
If an elevated result is
'i detected, ProVox was to prompt the control room operator to contact maintenance and ask the control room operator for a maintenance work order nuinber.
The inspector reviewed the calciner restart checklists for lines one thiaugh five and found that for those process lines, corrective action No. 3 was documented as being completed on or before December 6, 1996.
Corrective action No. 4 was to be implemented by modifying the ProVox system such that weekly calciner stack results for lines one through five had to be entered into the system i
to allow the calciners to continue to operate. The inspector reviewed the calciner restart checklists and results of functional tests and found that corrective action No. 4 was documented as being completed for lines one through five on or before December 12, 1996 4
Corrective action No. 5 was to be implemented by entering an automatic prompt in the MPAC system to alert the maintenance planners of the need for preventive maintenance based on material through)ut for each calciner tube on lines one through five. T1e inspector observed the text of the prompts on the HPAC system, reviewed the memo docume,1 ting rationale for frequency of preventive maintenance, and reviewed the calciner restart checklists. The inspector found that corrective action No. 5 was documented as being completed on or before December 10, 1996.
Corrective action No. 6 was to be implemer by explicitly modeling material accumulation within the caiciner annulus beyond 25 kilogram hemisphere previously analyzed in the criticality safety basis and by evaluating the addition of a new mass / moderation )arameter control to the existing basis for safety. As of tie inspection dates for this report, this item had not been completed, but was expected to be completed during February 1997.
Corrective action No. 7 was to be implemented prior to the next purchase of calciner tubes by specifying a final stress relief annealing step, and to assure that vendor quality assurance certifications meet this new requirement.
I 6
As of the inspection dates for this report, this item had not been completed and was not expected to be completed in i
the near future since no new tubes were expected to be l
- ordered, j
Corrective action No. 8 was to be implemented by revising the change control process with an emphasis on the impacts of material property changes essociated with changes in process equipment. As t.f the Inspection dates for this report, this item had not been completed, but was expected-to be completed during February 1997.
Corrective action No. 9 was to be implemented by evaluating a new technology for )otentially detecting uranium accumulation within tle calciner annulus via an exterior garama. scan device. The inspector reviewed an internal-memorandum dated January 24, 1997. from the licensee's radiation monitoring function explaining the difficulties that would be encountered in implementing a system for this type of measurement. Based on the content of the memorandum and discussions with licensee management, the inspector found that the use of a system to directly measure material accumulation in the calciner annulus would not be pursued further. This corrective action was considered to be completed as of the memorandum date.
4 (3)
Conclusions The short term corrective actions necessary for restart of'=
the calciner units were all completed for lines one through five. The calciner in line six was in an indefinite shut cown mode due to the scavenging of its parts for the other units. The line No. 6 calciner can not be restarted until all-ap)11 cable corrective actions have been implemented for it. T1e status of this unit will be followed until it is restarted or removed from service.
Long term corrective action No. 9 was completed.
Implementation of corrective actions six and eight were underway and will be followed until their completion.
Corrective action No. 7 is conditional upon tne purchase of new calciner tubes and may not ever be completed due to the expected phasing out of wet ADU processir.g. The status of corrective action No. 7 will be followed until it is -
implemented or the wet ADU process equipment is _ removed from service.
(Record Note: Subsequent to the end of the inspection, the licensee informed Region 11 that the purchase specification was revised on February.14, 1997).
7 2.
Qr_qtn_1LLtigna) Structure (05.01) (88005) a.
Inspection Scope The inspector reviewed changes in the organization since the last i
inspection, especiall l
license application. y as they apply to positions described in the b.
Observations and Findings A new Hanager, Environment. Health and Safety (EH&S) was appointed and assumed his responsibilities on December 18, 1996, following completion of a training program. The Manager, GE NE Quality, who had been acting in the EHIS position as well as the Quality position, resumed his Quality function full time.
The former Manager, Fuel and Chem Lab Quality, accepted a position in another aart of General Electric. On January 31, 1997, it was announced t1at the Team Leader. Uranium Recovery (URU), had been j
selected to be the Hanager, Fuel and Chem Lab Quality. An acting l
Team Leader. URV was also a> pointed. These. positions are not specifically described in tie license application.
Chapter 2, section 2.5.2 of the license application describes the license application describes the functions and qualifications for the position Area Manager. P/P 4016, ' Nuclear Safety Area Manager Responsibilities and Assignments" assigns each Area Manager for the plant arees. The inspector reviewed the changes for four Area Managers and determined that those appointed met the qualifications specified in the license application.
The Fuels and Facility Licensing group has developed an indoctrination program for new Area Managers. This program covers the responsibilities and functions as defined in the license application and P/P 40 16. The inspector reviewed the records and determined that all new Area Managers had completed the indoctrination program. This program was also presented to existing Area Managers in February and March, 1995.
c.
Conclusions Persons appointed to positions described in'the license application met the educational. and experience requirements. Other persons were qualified for the position.
The implementation of the new Area Manager indoctrination program is a positive step to assure that the new managers are aware of their responsibilities.
8 3.
Calibration of dauinment (F1.07) (88025) a.
Inspection Scope The inspector reviewed the criteria for the installation of l
nuclear criticality detectors in a new facility and the i
calibration of existing monitors, b.
Observations and findings Procedure NSI.0.4.0 specifies the requirements for the annual energy calibration of the nuclear criticality monitoring system detectors. The inspector reviewed the records for the calibration l
performed December 3 through 5, 1996, and confirmed that all detectors performed within specified limits. Also, all por'able units (SRM 100s) responded within specified limits.
Included in the review of the criticality system annual calibration were four new detectors installed in the new warehouse area. The new detectors were visually observed by an inspector, and the placement and orientation of the detectors within the new warehouse was reviewed with the licensee. The inspector reviewed licensee's diagrams as evidence of redundant coverage by the criticality detectors of all areas in the new warehouse. The inspector also reviewed previous calculations which demonstrate adequate coverage for detectors up to 250 feet from a criticality accident with no obstructions or shielding.
The inspector also reviewed the monthly test records for the criticality monitoring system for the seriod September 1996 through January 1997, and determined t1at the system responded within specified limits.
c.
Conclusions The inspector concluded that existing criticality monitors had been properly calibrated and functionally tested, and that the new monitors had been properly located to provide coverage in the new warehouse.
4.
10 CFR 19.12 Trainina (F2 01) (88010) a.
Inspection-Scope The inspector attended the annual radiation dorkers' refresher training, reviewed new employee training, and verified training instructor's qualifications.
In addition, the inspector interviewed workers to ensure training efforts were effective in meeting licensee and regulatory requirements.
9 b.
Observations and Findings Chapter 2. Section 2.6 of the license application recuires new employees to complete for nuclear safety training anc pass an examination prior to being granted unescorted access to the controlled area. Previously trained employees are required to be retrained every two years. in accordance with Practices and Procedures (P/P) 40 17. " Nuclear Safety Training."
Additionally, 10 CFR 19, Section 19.12 requires that all individuals who in the course of employment are likely to receive in a yeer an occupational dose -in excess of 100 mrem shall receive i
L instruction in various topics.
The inspector reviewed the new employee training course materials Contents of this course-included:
ployees course objectives.
to determine if they met the new em clear and concise course objectives:
e illustrations of evacuation routes for fire and criticality e
accidents throughout-the process building:
e -
requirements and the rights of workers enforced by NRC codes:
e detailed review of NRC Form 3:
procedures for dosimetry monitoring and method for obtaining e
a worker's dose:
criticality factors.and safety issues; e
proper uses and wearing of safety equipment to ensure e
radiological protection:
showed and discussed radiation precautionary procedures:
e A comprehensive final examination consisting of 75 questions was administered at the end of the course. The inspector reviewed the test results from the January 7 and 14, 1997 classes and found that all students had passed the class.
The inspector attended the 1997 radiation workers' refresher training (NSR97) course. The inspector observed that the instructors used several different teaching methods during this course. These instruction methods included:
simulation of an artificial criticality accident:
e-short video of the new UF, to 00, powder conversion process e
and the correct method for egress from the production.
facility during a criticality emergency:
e class exercises in following written instructions:
demonstration of how criticality factors affect the chances e
of a criticality accident:
e identifying-incorrectly worn safety clothing and house keeping techniques by a worker:
i 10 The licensee administrated a self graded quiz consisting of ten true or false questions at the end of the class, which was used as a training tool by discussing the answers while the students l
" graded" their test. However, the inspector's consultation with i
several employees, following this course, showed a general knowledge for nuclear safety, radiological protection, and the l
issuance of emergency procedures.
The licensee manages the training records and dosimetry results l
for workers on a computer program. This program data was current.
Several new employees who received the new employee training on l
January 14, 1997, had been entered in this computer database at the time of the inspection. The inspector discussed with the training coordinator and found that this computer program has been l-used to determine required training efforts and ensured that l
employees training requirements have been kept current.
The inspector also review the letters from nuclear safety and radiation protection approving various persons as instructors for the classes, as specified in Chapter 2, section 2.6 of the license application.
c.
Conclusion The licensee training program meets the requirements of the license and NRC regulations. The licensee's computer program used for training and dosimetry was adequate for retaining and managing training needs of employees.
Additionally, the new employee training seemed comprehensive and effective in meeting course objectives.
5.
DCF Proiect Facility Status (T1.01) LQQ02Q1 0
a.
Inspection Scope The inspector reviewed the status of the facility with licensee representatives, b.
Observations and Findings During tours of the DCF and the existing plant areas, the inspector observed the status of construction of the process lines as well as the modifications to permit the movement of powder containers through plant areas. As the powder from the.DCF will be moved in bulk containers, facility modifications are being made to provide for " moderation restriction" areas in existing process areas. The removal of ' existing structures and equipment to permit construction of moderation restriction transfer areas is addressed by the licensee's transition plan. The installation of the edge seal and-trim for the outer membrane of the roof is not yet completed.
11 The inspector observed that the piping systems and instrumentation is being completed and the lines turned over from the constructor.
Instrumentation checks w re in progress during the inspection in preparation for functional testing, i
1 The inspector discussed the status of the various technical i
documents for the facility with licensee management. Technical reports and operating procedures are still in " draft." but are nearing the point where they can be reviewed by the NRC. The Hazards Analysis is complete and resolution of findings is in progress. A summary of the analysis will be submitted to the NRC in February. There are some findings which are considered
" moderate risk" which may not be corrected. These will be submitted to the Wilmington Safety Review Council for_ review and approval. Licensee management informed the inspector that this review has been delayed until after a readiness review is conducted internally by several teams, c.-
Conclusions Work on the transition phase between the DCF and existing production facilities is progressing.
Construction of the DCF systems is complete for the first line and preoperational check. outs have begun.
6.
Follow uo on Previous Insoection Findinos (G1) (92701) a.
(Closed) IFI 96 09 01 This IFI concerns the revision of the training for individuals who are designated a " qualified reviewer." A qualified reviewer determines the need for review by-the functions in the Environment. Health and Safety group for new or revised operating procedures and temporary instructions.
Corrective actions were identified during the exit interview for IR 70 1113/96 09.- The inspector reviewed the implementation of those actions.
These changes were imalemented during the last training class for qualified reviewers w11ch was conducted in October.1996.
Individuals who attended the course on an." audit" basis were clearly identified in the class records. Five examinations were administered for the topics covered. Each set of examinations was graded by the applicable-safety function.
i
.We 9 M4W% tw '
rp.f'W F+-
4'W'FY-etw--
12 P/P 10 09. *0perating Procedures (ops). FH0." Rev. 2. was issued m-m on January 31, 1997. The inspector reviewed the P/P and E
determined that the corrective actions discussed in IR 70 1113/96-09 had been incorporated.
i This IFI is closed.
b.
(0 pen) IFI 96 11 01 This IFI concerns the long term corrective actions for the criticality warning system horns. The licensee's investigation resulting from incident repcrt ChPL 9649 identified five lor-actions to correct identified problems in the system.
The inspector discussed u1e status of these actions with i responsible supervisor. Two of the actions are in progres.
(evaluate horn audibility and update system drawings) are in progress. Tne remaining three items require completion of the first two items. Tempora.y Operating Instruction A 3647 was issued to conduct the identification and documentation of the tcrns.
Verification and marking of the horos has been completed for one of the nine loops.
Thin IFI remains open pending completiors of the long term corrcetive actions.
_Cicred) NCV 96 11 02
(
c.
This NCV resulted from the loss of geometry control in the URV Exhaust Scrubber Sump (T 065). Corrective actions were not complete at the conclusicc. of the inspection. The inspector reviewed the corrective actions taken to correct this problem.
A third set of stays was installed to maintain the dimension of the tank.
Following installation of the stays, the internal dimensions were checked using the ultrasonic method on October 23, 1996. One measurement was 4.55 inches, which was greater than the design value of 4.5 inches. However. a revised nuclear criticality safety analysis had demonstrated that a dimension up to b inches was acce) table. Nuclear Safety evaluated this condition as acceptaale.
The drawing of.the tant. s:as revised to reflect the "as built" condit nn.
Actions on this NCV are closed.
E mi.
i 13 7.
Exit Interview Sumary (H1)
On January 31, 1997, the inspection scope and findings were sumarized with licensee representatives. The inspector discussed in detail the areas inspected, the findings and concerns which had been identified.
There were no dissenting comments expressed by licensee representatives.
4
\\'
1 a
-4 ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED licensee Personnel
'*H Chilton, Hanager, Joint Conversion Project.
- S.. Dale, Team Leader, Compliance Auditing T. Flaherty, Manager DCP Operation
- R. Foleck,.Sr, Licensing Specialist
- J. Kline, Manager, Powder Product.Line
- A, Habry, Program Manager, Radiological; Safety
- C, Honetta,'Hanager, GE NE Environment, Health and Safety S Hurray, Team Leader, U0 Production Team
- L, Paulson, Manager, Nucle,ar Safety
- R. Reda, Manager Fuels and Facility Licensing G Smith,= Team Leader, FHO Haintenance Support C, Tarrer -Team Leader, Configuration Management and ISA
- K, Theriault, Team Leader, Uranium Recovery / Process C.- Vaughan, Project Manager, EH&S New Facility Licensing / Safety
-C. Williams, Team Leader, Waste Treatment
- Attended exit meeting on January 31, 1997, INSPECTION PROCEDURES USED IP 88005
-Management Organization and Control IP 88010 Operator Training / Retraining IP 88020 Operations Review IP 88025 Maintenance / Surveillonce Testing IP 92701-Follow up on Inspector Problems LIST OF. ITEMS OPENED, CLOSED, AND DISCUSSED
=
Opened None Closed Item Number Typft Descriotion 96 09 01 IFI Follow up on revisions to " Qualified Reviewer" training.
96 11 02 NCV Final actions on loss geometry control in a slab
. tank Discussed 96 11 01 IFI Follow up on long term ~ corrective actions for criticality system warning horns
I' LIST OF ACRONYHS AC Area Coordinator AEC Active Engineered 'Contro'i CFR Code of Federal Regulations ChPL Chemical Product Line CR Change Request l
CSA Criticality Safety Analysis DCF Dry Conversion Facility DCP Dry Conversion Project l
EH&S Environment, Health and Safety EN Event Number FNO Fuel Manufacturing Operation FTI Functional Test Instruction GE NE General Electric Nuclear Energy l
~GE NEP General Electric Nuclear Energy Production IFI-Inspector Follow up Item IP Inspection Procedure IR Inspection Report ISA Integrated Safety Analysis
-KGS Kilograms HC&A Material Control and Accountability NCS Nuclear Criticality Safety NCV Non Cited Violation 3
NRC Nuclear Regulatory Commission NSI Nuclear Safety Instruction NSR/R Nuclear Safety Requirements / Release ONHSS Office of Nuclear Materials Safety and Safeguards OP Operating Prccedure PA Public Address PHA Plant Management Area PPA Plant Process Area PPM Parts Per Hillion P/P Practices and Procedures Rev.
Revision-
.RP Radiation Protection SAR Section Administrative _ Routine SNH Special Nuclear Material SSR Software Service Request
-: STR
-Shift Technical Resource UCON Uranium Conversion UIR Unusual Incident Report 100.
Uranium Dioxide
- URIJ Uranium Recovery Unit
e-REGION !!
RITS AUDIT REPORT DATA THROUCN 02/15/77 SITE GENERAL ELECTRI REPORT No.
97001 INSPECTit EN"J DATE: 01/31/1997 LEAD INSPECTOR:
GLT WEEK DOCKET PROCEDURE IPE IMI REGULAR NONREGULAR PROCEDURE
. EMPLOYEE-EN0 LNG NO.
NO.
CODE CODE HOURS HOURS STATU$
1 eavesses amesse essesses amessesses esse sees seasses emessesse I
DAAYRES 01/25/1997 07001113 APP IRAD -
0.0 2.0 -
I 07001113 AT IRAD 9.0 8.0 07001113 88010 C0 IRAD 2.0 0.0 P
07001113 88020 C0 IRAD 32.0 0.0 P
07001113 88025 to IRAD 1.0 0.0 P
02/15/1997 07001113 APP ITNG 4.0 0.0 EMPLOYEE TOTAL >>
48.0 10.0 GLTROUP 01/25/1997 0 001113 APP IRAD 8.0 0.0 01001113 APP 1 RAD 0.0 1.0 07D01113 AT IRAD 7.0 0.0 07001113 88005 CO IRAD 2.0.
0.0 M
07001113 88010 CO IRAD 2.0 1.0 M
07001113 8802C C0 IRAD 26.0
$.0 M
07001113 88025 C0 IRAD 2.0 00 M
. 07001113 92701 CO -
IRAD 1.0 0.0 M
02/08/1997 ' 07001113 APP IRAD 6.0 0.0 07001113 APP IRAD 6.0 0.0 EMPLOYEE TOTAL >>
60.0 7.0 REPORT TOTAL >>
108.0-17.0
't HAVE REVIEWE0 THE A80VE DATA AND TO THE BEST of MY KNOWLEDGE THE TIME ALLOCAT!DNS FOR REPORT (CENERAL ELECTRI / 97001) ARE ACCURATE AND.REFLE Y A
UMENT4B IN THE INSPECTl0N REPORT LEAD INSPECTOR' SIGNATURE & DATE: ~
BRANCH CHIEF SIGNATURE & DATEt y
RETURN TO IMS after report is issued.
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ONE LINERS FOR FEBRUARY 28. 1997 1.
Fuel Facilities Status a.
Babcock and Wilcox (B&W)
NNFD There were no reportable events during the last two weeks.
Routine manufacturing and maintenance activities are being conducted in the Modified Fuel Process (MFP). Advanced Fuel l
Process (AFP) and the Research and Test Reactor Fuel Element (RTRFE) portions of the plant. The uranyl nitrate hexahydrate
-(UNH) conversion process, used to produce U 0,l proble s 3
for use as RTRFE l
feedstock, remains shut down due to mechanica m with l
sintering ovens. Routine development work is being conducted in the Compact Reactor Fuel (CRF) facility.
A routine Naval Reactors recovery campaign is being conducted in the Uranium Recovery Facility. Modifications to the Sapphire downblending facility have been completed and downblending operations have resumed.
The further dissolution of Sapphire materials remain on hold.
Bill Brach.. Deputy Director. Division of FCSS. Mike Weber Chief.
Licensing Branch, and Ed Flack. NNFD Project Manager, were onsite February 24 and 25 to tour the facility and meet with licensee management.
Bill Tobin, RII. DNMS was onsite February 25 28 for routine physical security inspection activities, b.
B&W Fuel Co. (Framatome Cocema Fuel)
There were no reportable events during the last two weeks.
Routine rod loading and production activities are being aerformed on two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts.
Routine decontamination and refuraishment activities are being conducted in the SERF facilities.
A CAL preventing the further downloading of NUKEH fuel assemblies remains in effect. A second shiament of NUKEM fuel assemblies remains at Norfolk. Virginia. -T1e CAL had to do with the loss of a fual assembly. The enforcement action for their accidental shipment of fuel to Germany will be issued on March 4 (see attached enforcement notice).
In addition to Scott Wilkerson being named as Manager of Manufacturing Mike Minor has been named Manager of Manufacturing Engineering and Jeff Whitt has been named Manager of Facilities and Tooling Design.
b <(\\
1
I One Liners 2
Mike Weber. Chief.' Licensing Branch, Division of FCSS, and Ed Flack, Project Manager, were onsite Monday, February 24, to tour the facilities and meet with licensee management.
Bill Tobin, Region II, DNHS, was onsite February 24 for routine physical security inspection activities, c.
Ger.eral Electric NEP There were no reportable events during the past two weeks.
All five lines are running on routine powder production. Line 5 is running hie recycle from Uranium Rocovery. Only lines 3 and 5 are operating over the week.end for hie powder. Rods and bundle assembly are working 5 days a week.
The second process line in the Dry Conversion facility was turned
'ver by the constructor this week. Heat up of the kiln is being done with the manufacturer's representatives on site.
The Decontamination and Volume Recovery Facility (DVRF) started operations this week using high pressure washing to remove contamination on cans. The compactor has not yet been put in service.
On February 12, the incinerator loading ram was bent, which shutdown incinerator operations. The ram was re on ram) and the incinerator is back in service, paired (bent sh d.
Nuclear Fuel Services. Inc.
During the week of February 24 the licensee received its second shipment of UF cylinders from the U. S. Enrichment Corporation g
Gaseous diffusion Plant in Portsmouth. Ohio. The second shipment of the 26 Type 5 B containers arrived without incident. After approval from the NRC, the licensee will recover the residual high enriched material in the cylinders.
The licensee continues to process the HEU material shipaed from the DOE facility in Rocky Flats with no significant pro 31 ems. The licensee was making preparations to commence excavation activities for source term removal in the North Site area.
Some of the preparation includes the relocation of the security fence. The licensee is waiting for approval to commence North Site remediation activities from NRC.
1
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j One Liners 3
e.
Westinohouse Commercial Nuclear Fuel Plant Conversion-Lines 1 and 5 are processing uranyl nitrate while i-Lines 2 4 are processing UF6 gas on a normal "just in time" schedule. Pelleting, rod loading URRS. IFBA, and the mechanical t
area are all operating on a normal schedule. No re problems have ]een noted during the past two weeks. portable An operations inspection was completed this week and no violations were noted. An NCV was identified for failure to have a preventive maintenance checklist or procedure for inspection of a ligh high level control and alarm on the boilers that supply steam for the conversion process.
The level control was being checked annually by a contractor as required by the PH schedule but there was no procedure, as specified by the license application, for y
this maintenance item.
The first shutdown for 1997 will start March 31 and will involve a i
physical inventory on April 1 and 2.
Maintenance will also be j
performed.
F 2.
North Anna Indeoendent Soent Fuel Storace Install'ation i
DNHS is in the final stages of preparation of an integrated inspection plan for the ccnstruction of the North Anna Inde>endent Spent Fuel Storage. Installation, Coordination of the plan.1as been accomplished 2
within Region II and is currently being coordinated with NHSS prior to i
submittal to the F.egional Administrator and forwarding to the program offices.
Finalization of the plan is targeted for next week.
It is anticipated that the licensee will begin construction of the storage pad-l in April of 1997.
. 3,-
National Hosoital Medical Center 4
On February 27.1997, a National Hospital Medical Center staff member notified Region II of the receipt of a contaminated radiopharmaceutical F
package. -The-package originated at-Syncor nuclear pharmacy-located in Silver Springs..Hd, A State of Maryland (Maryland is an Agreement State) inspector responded to' Syncor and_ did not' find that either the-driver, the truck used to convey the package, or the facility was l-contaminated. -Region II staff will conduct a special inspection at the-Hedical Center to follow up on the event. Attached is PNO II 97 011-Lwhich further describes the event.
4.
Nav'y 1
1 0n February 28.--1997 Region II received a request from the Secretary of-the Navy Radiation Safety Committee regarding attendance at a briefing i
- for Mr. Kazuyoshi Umemoto, Director of the-Japan United States Security j-1 Treaty Division, on March 4. -1997. The subject of the briefing is the L
December,1995/ January,1996 unauthorized firing of depleted uranium ll munitions.by a Marine aircraft at an Air Force gunnery range on a. remote l
4
1 1
One Liners 4
island 50 nautical miles west of Okinawa, Japan. Mr. Umemoto has requested that representatives from the Department of Defense, Navy and the NRC be present at the briefing. The DoD representative characterized the meeting as a low key, informal briefing involving staff level personnel to answer any questions Mr. Umemoto has regcrding i
I the incident and possibly the NRC's oversight of the Navy's license.
Region II is considering sending the Navy Master Material License Program Manager to attend the meeting.
5.
Professional Service Industries. Inc.
An enforcement panel was held on February 26, 1997, to review the violations identified during the AIT inspection on November 13 21, 1996.
The panel determined that escalated enforcement action should be taken based on the licensee's lack of management oversight that led to a i
l programmatic breakdown regarding training, and equipment and dosimetry use. The licensee will be requested to provide actions that wi
correct the violations at all of PSI's NRC licensed offices.
6.
Dr. Vazouez Eve Acq1icator Misadminstration Re&ords Search During March 3 7, 1997 H. Bermudez, Region II assisted by J. Ibarra, AE00 and V. Ibarra ADM will search 600 700 (Spanish) patient records, from the estate of Dr. Vazquez, to identify Sr-90 eye applicator misadminstrations.
A-ONE LINERS FOR MARCH 14. 1997 1.
Fuel Facilities Status a.
Babcock and Wilcox (B&W)
NNFO l
Routine manufacturing and maintenance activities are being conducted in the Modified Fuel Process (MFP), Advanced Fuel Process (AFP), and Research and Test Reactor Fuel Element (RTRFE) l portions of the plant.
A routine Naval Reactors recovery campaign is being conducted in the Uranium Recovery Facility. The uranyl nitrate hexahydrate (UNH) conversion process, used to produce U308 for use as RTRFE l_
fuel, is operating normally.
The licensee has resumed limited operations of the Sapphire downblending facility after a spill occurred on March 4.
A preliminary investigation of the spill has been completed and a more thorough root cause analysis is due within 30 days.
A meeting was held on March 10 in HQs between the licensee and ONHSS staff to discuss NNFD's industrial waste landfills decommissioning.
Five ONHSS staff members, including Mike Weber, Chief of the-Licensing Branch, will be on. site March 18 20 for a quarterly safeguards-licensing visit and to observe the annual security tactical-exercise.
t b.
?&W Fuel Co. (Framatome Cocema Fyg]l Routine rod loading and production' operations are being aerformed on two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts. Routine decontamination and refuraishment-activities are being conducted in the SERF facilities.
The CAL preventing further downloadirig of NUKEH fuel assemblies remains:in effect. A-second shipment: of NUKEH fuel assemblies remains at Norfolk, Virginia.
A three member inspection team is scheduled to be on site March 25 27 to determine if-the licensee has. implemented _ corrective-actions sufficient to prevent a repeat the inadvertent shipment of fuel. assemblies. - The team will be comprised of 2 ONHSS inspectors and the NNFD resident inspector, c.
General Electric NEP On March 7. GE reported that two BU J shipping containers received from ENUSA as " empty" actually contained uranium oxide. A third container was found after the initial notification. The three
-containers' have been sealed and are quarantined pending resolution
One Liners 2
with ENUSA.(see attached morning report)
On March 11, while working on connecting the criticality monitoring system in the Dry Conversion Facility (DCF), a mechanic placed one unit (" DAMS") in " maintenance" mode to replace a faulty I/O electronics board When he pulled the board, the criticality monitoring system for the Fuel Manufacturing Operation alarmed.
Personnel evacuated the building, including the radiological controlled areas. GE determined by monitoring the system panel and taking radiation surveys that a criticality had not occurred and allowed workers to return to their jobs. Surveys were conducted in the staging areas and evacuation routes: no contamination was found. DCF remained quarantined while the cause of the alarm was investigated. There was no SNM in the DCF. Boards in the existing DAMS can be removed in " maintenance" mode. However, the new DAMS were found to have a master relay circuit which acts as e power failure circuit. When the board was pulled, the relay acted as if a power failure bei occurred and tripped the alarm circuit. GE is reviewing the system with Eberline to develop a procedure to replace boards without activating the alarm circuit or taking the entire system out of service.
The State of North Carolina issued a license amendment on March 11 to permit GE to process natural uranium in the DCF. The processing of enriched uranium will require the NRC license renewal to be issued.
Two of the ADU lines are scheduled down. Two ADV lines are operating and the recycla lines are completing a powder recycle campaign (about 5,000.i ograms). While the powJer recycle c=ampaign is in progress, sohent extraction is down. The ceramics area is operating three shifts, 5 days a week. Bundle assembly is working 2 shifts, 5 days per week.
There has been a problem with powder, especially on the hie material. Two investigation teams are working on the cause. The problem may be due to air in leakage in the powder mill which is causing oxidation of the powder. This caused a powder shortage to the ceramics area.
There is a seven member inspection team (NRR Vendor Branch and contractors) on site this week conducting a fuel quality and engineering inspection.
GE will start a Readiness Review for the DCF using three teams.
The teams will include people from other GE facilities and contractors.
d.
Nuclear Fuel Services. Inc.
On March 12, 1997, the licensee received its fourth shipment of UF, cylinders from the U. S. Enrichment Corporation Gaseous
One Liners 3
i Diffusion Plant in Portsmouth, Ohio. The shipment of the Type 5 B containers arrived without incident. After approval from the NRC, the licensee will recover the residual high enriched material in the cylinders.
The licensee continues'to 3rocess the HEU material shipped from the DOE facility in Rocky :lats on schedule. NFS has completed processing approximately 50% of the UNH, The licensee has been l
processing a>out 225 liters of UNH per week (40 kg), or about 5 of the 11 litcr bottles per day. There have not been any problems to date in the processing, other than routine maintenance, The new Part 20 regulations has forced NFS to pay greater attention to i
minimizing airborne concentrations of uranium, particularly after the calcining operation. NFS anticipates completing the processing campaign in early May 1997.
The licensee was making preparations to commence excavation activities for source term removal in the North Site area. Some of the preparation includes the relocation of the security fence, The licensee is waiting for approval to cot..mence North Site remediation activities from NRC, e,
Westinchouse This week Conversion Lines 1, 3, and 4 were being used to process UF, gas.
Line 2 was shutdown because enou
+
produced according to Westinghouse's new "gh powder had been Time Based Management" concept.
Line 5, which is normally used to process uranyl nitrate recycle material, has been idle for two weeks. The pellet lines, rod loading, the recovery operation, and IFBA are all operating on-a normal schedule with no problems reported.
There have-been no process upsets during the past two weeks but the licensee did report one incident which involved an operator's hand being caught in a-pulley and gear mechanism inside.an enclosure while he was trying to change a light bulb; The. person was taken to the Richland Memorial Hospital where his wounds were treated. His hand and forearm were lacerated but no bones were broken, A Radiation Control Technician accompanied the injured operator and was able to collect all the contaminated dressings, etc. and take them back to the site. A survey of the man's hand following treatment indicated that all the contamination had been removed from the wounds and that none: remained on-the hand. The-injured-operator has been placed on a daily urir.alysis program for-the next week to 10 days to determine the~ extent of uptake of material.-if any, 2.
U S. Deoartment of Navy - I 125 Contamination-Event On March 12, 1997, Jay L. Henson, the Navy Master Materials License Program Manager, inspected the Navy Drug Screening Laboratory in Jacksonville, Florida. This reactive inspection was performed to review
One Liners 4
the events that lead to the delivery of the leaking package to Brooks Air Force Base. Mr. Henson identified four violations of DOT regulations and one 10 CFR Part 30 requirement regarding transfer of licensed material during the inspection.
Region II will review the violations to determine if escalated enforcement is warranted. (See attached PN).
3, Navy-Radiation Safety Committee Meetina B. Mallett and J. Henson will be attending the quarterly Navy Radiation Safety Committee meeting in Crystal City, VA on March 19, 1997.
6.
Agreement State Events No significant issues were identified by the Agreement States during the week except that the Troxler gauge reported last week near Delray Beach, l
FL was recovered by another contractor working on site. See attached-Horning Report.
l l
~X
PRIORITY ATTENTION REQUIRED MORNING REPORT - REGION II MARCH 10, 1997 Licensee / Facility:
Notification:
General Electric Company MR Number: 2-97-0015 Nuclear Energy Production Date: 03/10/97 Wilmington, North Carolina Dockets: 00701113 License No: SNM-1097 Subiect: SHIPPING CONTAINERS MARKED EMPTY FOUND TO CONTAIN MATERIAL Discussion:
On March 6, 1997, the General Electric fuel fabrication facility in Wilmington, NC received a 40 foot long tamper safed shipping container from Empresa Nacional del Uranio, SA (ENUSA) in Spain. The shipping papers indicated the container held 150 empty BU-J shipping containers.
As GE began unloading the shipping container on March 7, they observed that two of the inner BU-J containers were also tamper-safed with seals that appeared to belong to the shipper, ENUSA.
Upon opening the two BU-J containers, GE found two 5-gallon containers in each. In BU-J container M3171, the cans were labeled as containing 16.5 kilograms (kgs) and containing 4.4 kgs. In BU-J container M3200 the cans were labeled as containing 22.1 kgs and containing 19.7 kgs.
It is not clear at this point whether the weights refer to the oxide or uranium During a radiation survey, GE found 4000 disintegrations per contents.
minute per 100 square ccntimeters of alpha contamination on the outside of one of the 5-gallon cans, but the outsides of the BU-Js and the 40 foot container were clean. GE found no moisture in the BU-Js and there was no damage to the containers.
On March 7 at 4 :15 pm, GE notified the NRC of the above information. GE tamper-safed the 5-gallon cans and placed them in quarantine.
Subsequently GE found another BU-J containing material by performing radiation surveys cn1 the containers and notified the NRC at 8:55 pm on March 7. The third BU-J did not have a tamper seal in place but did have a piece of wire-through the bolt as if the seal had been broken. At approximately 8 pm on March 7, ENUSA notified GE that a review of their records indicated that a third SU-J had been shipped; this was the container that GE had identified by radiation surveys. The third BU-J was quarantined without opening. Once GE has obtained sufficient information from ENUSA to safely handle the material, they will prepare a Temporary Operating Instruction to cover the work. ENUSA had intended to ship this material at a later date for recovery.
ENUSA is licensed to possess uranium oxide up to 5 percent enrichment.
The ENUSA records for this material is that it has enrichments of 3.95 percent and 4.4 percent, and is scrap material to be recovered. ENUSA informed GE that they have notified CSN 'the Spanish regulatory agency) and EURATOM.
The Department of Transportation has been notified.
Recional Action:
Region II will review the GE and ENUSA incident routine inspection.
reports during the next
REGION II MORNING REPORT PAGE 2
MARCH 10, 1997 MR Number 2-97-0015 (cont.)
C ntact:
o L. Troup (404)331 5566 i
I
,j ONE LINERS FOR MARCH 28, 1997 1.
Fuel Facilities Status '
a.
Babcock and Wilcox (B&W)
NNFD A routine semi ennual MC&A physical inventory is being conducted this week. A routine HC&A inspection is scheduled for next week.
The inspection team will consist of two headquarter's HC&A inspectors and a contractor.
l Routine production activities are being conducted in the Resaarch and Test Reactor Fuel Element facility.
The Uranium Recovery facility is' shut down for inventory.
I Operations are scheduled to resume Sunday night with a routine Naval Reactor fuel contract.
l The Sapphire down blending facility rema',cs shut down due to intrusion of rainwater into a ventilation ductwork. This resulted in Lt LEU used in the down blending 3rocess being mixed-with naval 1
reactors HEU material in the ductwort. The licensee and NRC are l
currently evaluating corrective actions ir.cluding possible ventilation system modifications. By design, the water drains from the ductwork by carrying any accumulated enriched uranium to a safe geometry vessel.
IAEA inspectors were on site March 15 through 18 for a routine monthly audit of Sapphire down blending activities.
The Modified Fuel Process is shut down due to proc:uct quality -
concerns. Limited testing is being conducted-to resolve the -
Concerns.
The SRI will not be on site next week. Bassett and Ayres will-be at Framatome Cogema Fuels and able to respond to events.-
b.
B&W Fuel'Co. (Framatome Cooema Fuel)
Routine rod loading operations are being performed on two 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts. Rcutine decontamination and refurbishment activities are being conducted in the SERF facilities.
A three member inspection team, consisting of 2 NHSS inspectors and the NNFD SRI was on. site March 25 through 27. The team verified corrective actions stated in the-licensee's response to violations regarding the inadvertent shipment of a NUKEH fuel assembly. A Confirmatory Action Letter preventing the downloading of more-NUKEH fuel assemblies is expected to be rescinded by NHSS-next week.
b
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One Liners 2
c.
General Ele:tric Nuclear Enerov Production Robert Nardelli. President, GE Power Systems and Steve Specker, Vice President, Vice President, GE Nuclear Energy visited the facility this week to review the status of plant operations and tour the Dry Conversion Facility (DCF). An Open House for the DCF is being held on March 28 for )lant personnel. Most of the site will be shutdown for the long Easter weekend.
Pre operation testing of the DCF Line 1 vaporization process began on March 24. Testing of va>orization and conversion is being performed in accordance wit 1 the vendor's test procedure. Once this is completed, the Control System software will be set
(" frozen") and safety interlocks will be functionally tested.
(This should start about April 7).
ADU Lines 1 4 are currently operating, but only Line 3 (hie) will run over the weekend.
Line 5 and 6 are down.
Plant throughput for hie is currently limited by the ca)acity of the Mill, Slug, Granulation (MSG) step. Despite a lac ( of hie rods, bundle assembly is working two shifts. They are completing partial assemblies and storing them until rods are available, so either
'ine 3 or line 5 can run hie. A facility change is being made to upgrade the HSG on line 5 to handle hie. This should be completed next week. Solvent extraction in Uranium Recovery is shutdown l
until Line 5 can be started.
I On March 25. during a test of the horns for the Criticality Warning System in DCF, an amplifier board failed and two loops of horns did not sound.
In the event of this type of failurc, a failure alarm is supposed to sound in two offices and the circuit is supposed to shift to a back up board to maintain operability.
This did not occur. A contractor service representetive replaced the board and the system vas successfully tested. A GE representative will take the failed board to the manufacturer's facility next week and observe the investigation as to why it did not function properly. GE has advised the manufacturer that depending on the result of the investigation, it might be reportable under 10 CFR Part 21.
As further followup to the March 7 event where SNM was shipped from ENUSA to GE in containers marked " Empty," news articles i' Spain indicated that ENUSA is investigating and taking corrective actions for the incorrect shipment. The incident is also being reviewed by regulatory authorities in Spain, d.
Nuclear Fuel Services. Inc.
The licensee continues to receive about one shipment per week of UF; fusion Plant in Portsmouth. Ohio. cylinders from the U. S. Enrichment Corp Dif No problems have been encountered during the shipment thus far.
ee
One Liners 3
The licensee continues to arocess the HEU material shipped from the' DOE facility in Roc!:y :lats on schedule. NFS has completeu arocessing approximately 70% of the uranyl nitrate.
The 1 ;ensee las been processing about 225 liters of material per week (40 kg),
or about five 11 liter bottles per day. NFS anticipates completing the processing campaign around mid April.
During the )ast two weeks the licensee has experienced two incidents t1at has caused some delays in the HEU material processing. Following a heavy rainstorm, water leaked through the-roof and into a control switch box for a nitric acid pump.
l Operations had to be stopped until the switch bm and the roof leak were repaired. Also, an operator error caused an overflow of a vacuum scrubber column in the HEURF. The operator opened a valve and was trying to fill the column with water when he noticed that there was no flow. He went to check on the pump and found that the aower to the pump had been secured. After. turning the power bact on, the operator returned-to find that he had left the valve open and the column had overflowed. The operator was reinstructed to turn off the valve before leaving the area to check on any other equipment.
The facility will be shutdown on March 28 for Good Friday; operations will resume on Honday, March 31.
The licensee received a license amendment and the approval to commence North Site remediation activities from NRC. The-licensee-plans to begin excavation activities for source term removal in the North Site area on April 10. The site was being used to bury radioactive waste several years ago.
e.
Westinchouse The plant is currently in the process of shutting down for the Easter holiday and planned maintenance activity. The electricity-will be turned off on Friday for electrical maintenance. Other maintenance work is scheduled for next week and the annual physical inventory will be conducted-Tuesday and Wednesday of next week as well.
The facility will-not resume operations until Monday, April 7.
No problems, process u been reported during the past two weeks.psets, or accidents have The site was used to buy radioactive waste several years ago.
2.
Indeoendent Soent Fuel Storace Installations-a.
Arkansas Nuclear One and Oconee On 3/26/97, -ANO found a weld crack on the confinement boundary of a storage container during helium leak testing. The licensee uses the VSC 24 storage container designed by Sierra Nuclear Corporation.
Palisades and Point Beach also use the VSC 24.
During the exit at Sierra last Friday, the NRC inspection team 1
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,1 One Liners 4
questioned whether the design precluded Lamellar Tearing.
This finding is very significant since the containment boundary is 1
involved.
There are no containers of this type being used in f
Region.II.
b.
Oconee While performing a " dry run" of its spent fuel loading equipment, using simulated spent fuel, the license discovered that the welds on the rail carrying the device were undersized. These raiis are being installed to carry fuel-into new storage modules and may l
have cracked in an actual loading event. Duke is currently-evaluating the welding of the sub contractor who arovides these l
i rails. A possible violation is being-considered )y Region 11 for Duke's failure to follow its 0A procedure.
3.
Qq.uclear (Barnwell) and Tri State Trucking l
l-On March 27, 1997, individuals at the Hillstone nuclear power plant i-
, reported to the NRC Operations center that a container received at the site was missing a valve that was contaminated with radioactive materials. The valve was from a-vessel that was being transported by Tri State Trucking from the Barnwell disposal site'in South Carolina to
- the Hillstone site. The truck driver indicated that the valve was on the vessel when he left'the Barnwell site and was first noticed as missing at a fuel station in New Jersey.
)
Radiation surveys of the-vessel performed in the vicinity of the valve prior to transport indicated a radiation level of 60 mR/hr. Therefore, the missing valve should not emit levels above this value.
Region I notified the States where the truck traveled in that Region and
. Region II notified the States in Region II.
Region I also notified the Department of Transportation. Region II-is following up with the Barnwell site and will issue a P/N. Attached-is a diagram of the valve and location on the_ vessel piping.
4.
Heetino with Department of Health in San Juan. Puerto Rico On April 3, B. Hallett, H. Bermudez,- and D. Cool. Director Oivision of Industrial and Nuclear Material Safety,'NMSS, will be meeting with the Secretary of the Puerto Rico Department of Health in San Juan, Puerto -
Rico. The purpose of-the meeting is to establish a-plan for' followup of-patients that received overexposures due to miscalibrations and miscalculations in conjunction with eye therapy using Strontium 90. The total number of overexposure identified to date is 201.
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April 8, 1997-l General Electric Company ATTN: Mr. C. P. Kip), General Manager GE Nuclear inergy_ Production-P. O. Box 780 Wilmington, NC 28402
SUBJECT:
NRC INSPECTION REPORT NO. 70 1113/97 02-
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Dear Mr. Kipp:
-This refers to the inspection conducted on March 3 7 and March 17 21, 1997, at' l
the Wilmington facility. The surpose of the inspection was to determine l
whether activities authorized )y the license were conducted safely and in accordance with NRC requirements.
At the conclusion of. the inspection, the findings were discussed with those members of your staff identified in the report.
Areas examined during the inspection are identified in $he report.
Within these areas, the inspection consisted of selective examinations of procedures
-and representative records, interviews with personnel, and observation of activities in progress.
Within the scope of the inspection, violations or deviations were not
--identified.
In accordance with 10 CFR 2.790, of-the NRC's " Rules of Practice," a copy of this letter will be p'. aced in the NRC Public Document Room.
Should you have any questions concerning this-letter, please' contact us.
Sincerely, sS Edward J.- McAlpine, Chief Fuel Facilities Branch-Division of Nuclear Materials Safety Docket No.-70 1113 License No. SNM 1097-
Enclosure:
NRC-Inspection Report cc w/ encl:
(See page 2)
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cc w/ encl:
Dr. Ralph Reda. Manager
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i Fuels and Facility Licensing General-Electric Company P. O. Box 780. Mail Code J26 Wilmington, NC 28402 Dayne H. Brown Dire cor Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. O. Box 27687 Raleigh NC 27611 7687 Distribution w/ encl:
E. McAlpine RII G. Troup G. Shear. RIII C. Cain. RIV F. Wenslawski, RIV PUBLIC Distribution w/o enc 1:
License Fee Management Branch
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y V. S. NUCLEAR REGULATORY COMMISSION--
REGIONzII-Docket No.':
70 1113 License-No.:.
SNM 1097 Report No.:
70 1113/97 02 Licen'see:1 General Electric Company Facility:
Nuclear Energy Production Location:=
Wilmington, North Carolina i
Dates:
March 3 7. 1997 March 17 21, 1997 Inspector:
G. L. Troup Sr. Fuel Facilities Inspector
- Approved by:
E. J. McAlpine. Chief
-Fuel Facilities Branch Division ~of Nuclear Materials Safety.
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s EXECUTIVE
SUMMARY
General Electric Nuclear Energy Production NRC Inspection Report 70 1113/97 02
-This routine, announced inspection was focused on the status of the new Dry Conversion Facility (DCF), including operations. training, completion of
! construction, training and functional testing of systems. Review of previously identified items and reported occurrences was also conducted. Pack shift inspections ~ were conducted on March 17, 18, 19, and 20. The inspection was focused on the safe operation of the facility.
Within the scope of the inspection, no violations or new inspector follow up
' items-(IFIs) were. identified.
Plant Operations The long term corrective actions for.calciners were completed. The
-e-corrective actions for No. 6 calciner were also completed.
The actions to identify and control an improperly. identified shipment of radioacti.ve material from a foreign shipper was thorough and timely.
The actions to identify and quarantine possibly defective valves for UF, o
cylinders was thorough and timely.
Trainina The training program for the operators in the Dry Conversion Facility o
i has been completed and the pre qualification phase has started.
t Special training on hydrofluoric acid accidents, including emergency e
personnel and off site support-groups, is a positive action.
' Dry Conversion Facility Construction
' Construction of process.line 1 and the acid recovera facility is e.
- complete. Pre operational testing has begun, The adequacy of criticality warning system and the stationary air e-samplers has not been demonstrated.
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- Process Safety Analysis The safety analysis was a thorough in depth evaluation of potential hazards and safeguards against the hazards.
. Attachments Partial List of Persons Contacted
. Inspection Procedures Used List of' Items Opened. Closed and _ Discussed LList of Acronyms i
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REPORT DETAILS Summary of Plant Status This report covers two one week periods.
On March 11, the FM0/FM0X building was evacuated when the Criticality Warning System (CWS) alarmed, although it was a false alarm (Paragraph 1.d).
Construction and testing activities for the Dry Conversion Facility (DCF) were progressing.
The State of North Carolina materials license 065 017 1 was renewed on March 3, 1997. This renewal permits operation of the DCF with natural uranium.
An NRC Material Control and Accountability (MC&A) inspection was conducted on March 3 7, 1997 (report 70 1113/97 201). Additionally, the license reviewer for chemical safety was on site on March 18 19, 1997, as part of the license renewal review for license SNH 1097.
- 1.
Review of Previous Events (88020) a.
Calciner Tube Failure
~
(1)
Inspection Scope The inspector reviewed the licensee's corrective actions resulting from the failure of the tube in the Line 3 calciner.
(2)
Observations and Findings The Line 3 calciner tube failure reported to NRC on December 3, 1996, and reviewed in NRC Inspection Report (IR) 70 1113/96 12, prcmpted the licensee to consider a number of long and short term corrective actions to preclude a similar event. These corrective actions were documented by letter to Director Division of Nuclear Materials Safety.
Region II, dated December 11, 1996. Attachment III of the letter lists nine corrective actions, the first five of which were to be completed prior to restarting each calciner which processes wet material.
Implementation of the corrective actions was reviewed and documented in NRC IR 70 1113/97 01. At that time, three of the corrective actions had not been completed. During this inspection, the inspector reviewed the completion of these items and the completion of all items for No. 6 calciner.
Corrective action #6 was to be implemented by explicitly modeling material accumulations within the calciner annulus beyond the 25 kilogram (kgs) hemisphere previously analyzed.
The analysis (file no. CR #97.NRC) was completed and sD
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reviewed on March 19, 1997. The results of the analysis 4
show that with the tube y full of optimally moderated U0 j-powder at 5% enrichment and material. accumulated in the,
annulus up to 5.25 inches the entire length of the calciner, k, remains less than 0.97.
i th,isconfigurationis1.145kgs,Tne total mass of powder for 4
for the system, of which 736 kgs, are in the annulus. Tne previous actions to L
monitor the tube rotation and the off gas should identify upset conditions before this limit is reached, 4
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Corrective action #7 was to revise the purchase i
specification for replacement tuber to require a final stress relief after welding. During the review in January, 1997, it was not anticipated that any new tubes would be ordered in the near future.
However, the calciner tube is carried in the licensee's spare parts computer inventory. When the replacement tube was drawn from spare parts for installation in No. 3 calciner, the computer system initiated purchase of a new one since the inventory was now depleted. A purchase order was initiated in December, 1996. The' price quotation was received from the vendor on January 17, 1997. At the time, licensee representatives recognized that the specification had not been revised before the request for quotation had been sent out. On January 22, 1997, the vendor was advised by telephone that annealing after welding was required: this was confirmed by a FAX the same day. A revised quotation was received from the vendor on February 5, 1997, which stated that the tube would be annealed after welding.
The inspector questioned whether the corrective action had been completed, as-stated in the-licensee's letter of February 25,-1997, in response to the Notice of Violation in IR 70 1113/96 12. After discussions, it was determined that the purchase was not complete until the quotation was confirmed by a purchase order, and the: requirements had been changed in January, so the specification had been changed before the next tube was " ordered." However, licensee representatives acknowledged that the specifications for the tu)e in Stores File should be revised so that they would be ceect if it became necessary to' order another tube. On F.
7 5,1997, drawing-0166091, " Alloy Defluorinator Tube,"
U evised (Revision 3) to include " NOTE: General Electric requires annealing after roll tube final welds are completed." The Stores File was revised on March 6, 1997, to include Revision 3 of the-drawing and the requirement that " tube must be annealed after completion of welding" wa*
added to the specification.
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3 Corrective action #8 was to revise the change control system i
-to require review of any impacts of material changes in i
process, equipment. On February 11, 1997 -a mandatory i
modification was-issued to Practices and Procedures (P/P) 1010. " Configuration Hanagement Program Fuel Manufacturing," which requires that the Area Engineer is responsible to _" evaluate the impact of materials property 4
changes on identified failure modes and safety basis." This completed Corrective Action #8.
j No. 6 calciner was not modified when the others were because t
it was out of service and only processed dry material L
(recycled powder). No. 6 calciner was brought up to 1
standard by modifying the control system to automatically l
close the rotary airlock valve from the feed hopper if the tube rotation switch timed out. The control system was also modified to shut the rotary airlock valve if the necessary air sample data is not entered at the required frequency.
Software Service Request (SSR) 13937 was implemented for i
these control changes and approved by the software engineer on February 13, 1997, and accepted by the system " owner" on February 14, 1997. Functional Test Instructions (FTIs)-
3C80F8 and 3C8CF4 were performed on February 13, 1997, to verify that the system functioned. No. 6 calciner was approved to operate by the Area Engineer, Area Manager and Manager, Nuclear Safety on February 13, 1997, _ The inspector reviewed the FTI results, the check lists for the--
modification, the SSR, the revised technical report and operating procedure and had no further questions.
(3)
Conclusions The modification to No. 6 calciner was. completed in accordance with the licensee's commitments and internal procedures.
b.
Imoroner Material Shioment (1)
Inspection Scope The inspector reviewed the circumstances involving the receipt of improperly labeled material-from a foreign ~
shipper.
(2)
-Observations and Findings On March 7,1997, while unloading a seavan shipping container which contained 150 Model BU J shipping containers, licensee employees observed that two of the BU-Js had tampersafe seals attached to the bolting ring. These containers were su tampersafe seals. pposedly empty and did not require The employees notified the cognizant W,
1 4
personnel. The BU J containers were moved to a work area and opened. Both BU Js were found to have two 5 gallon cans inside which were labeled with the content weight. Surveys indicated that the contents were radioactive. A visual I
examination of the remaining BU Js did not identify any more which had tampersafe seals but subsequent radiation surveys identified an additional BU J which contained radioactive material. This container was moved to the work area and confirmed to have two 5 gallon cans inside containing material.
The licensee notified the shipper, Empresa Nacional del Uranio, SA (ENUSA), a Spanish company, when the two BU Js were found with the tam)ersafe seals.
ENUSA reviewed their records and confirmed t1at the two containers contained uranium material.
The ENUSA records search also identified the third container.
From the ENUSA records, a total of 102.41 kgs, of uranium oxide with a maximum enrichment of 4.4% had been ship >ed.
Following notification of the improper shipment ay the licensee. ENUSA notified the
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Consejo de Seguridad Nuclear, the Ministerio de Industria y Energia and EURATOM of the improper shipment. The licensee notified the NRC the Department of Transportation and the State of North C6.'olina.
The licensee installed tampersafe seals on the three BU Js and placed them in temporary storage. An Unusual Incident Report (UIR) DCP 9701 was generated and corrective actions identi fied.
At the conclusion of the inspection, the investigation report from ENUSA had not been received.
(3)
Conclusions The actions of the licensee employees to identify an unusual condition was exemplary.
The licensees actions to quarantine the shipment and to conduct surveys to identify any additional containers was thorough and timely.
c.
UF, Cylinder Valves (1)
Inspection Scope The inspector reviewed the licensee's action after being notified of a materials problem with valves which might be installed on UF, cylinders at the facility.
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1 (2)- - Observations and findings On March 14, 1997, the U. S. Enrichment Corporation (USEC) gaseous diffusion plant at Paducah, Kentucky notified the NRC Operations Office of a stress corrosion cracking problem with the packing nut on Hunt Valve Co.- valves (NRC event number EN 31954).
In particular. Hunt Valve Co. valves with j-the Jacking nut mede of Alloy 636 had ex of tie nut, had failed and, in one case,perienced cracking resulted in the j
release of UF.
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On March 21,1997. NRC Re9ma II notified facilities in the 4
region of the aroblem and requested that the licensees i
determine'if= t1ey had any of the valves in question.
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The licensee's initial action was to check all valves in the dock (parts inventory (55) and the cylinders on the loading spare about 30). All Hunt Valve Co. valves had nuts of Alloy 613 although some valves manufactured-by Superior or Descote had Alloy 636 nuts.
ThelicenseecontactedbothUSECPadubahandHuntValveCo.
and determined that the problem appeared to be limited to Hunt valves. Also. Hunt Valve Co. stated that they had switched to Alloy 613 nuts in about 1991.
During the week of March 17 the licensee inspected the valves on all UF cylinders on site (approximately 275) and
'found nine Hunt,alves-with nuts of Alloy 636. Eight were v
empty and will be returned to the owner for replacement of the valves. One full cylinder was subsequently placed in the cold trap and the valve replaced before it was sent to a vaporizer for processing.
3 USEC Paducah stated that they would not fill any cylinders with Hunt valves with Alloy 636 nuts..However. Hunt Valve Co. estimates that there could be u) to 5,000 valves in circulation with Alloy 636 nuts. T1e licensee issued a Temporary Operating Instruction (TOI) to inspect all incoming cylinders for the Hunt valves with Alloy 636 nuts -
because UF, cylinders come from sources other than USEC Paducah. -The-TOI will be evaluated after several months to determine if continued-action is necessary.
(3)
Conclusions The licensee took thorough and effective actions to -identify the scope of the problem and to take corrective actions to l
preclude the processing of cylinders with suspect valves.
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6 d.
CriticalityWarninaSystem (1)
Inspection Scope The inspector reviewed the cause and corrective actions taken after a false signal from the criticality warning system (CWS) in the Dry Conversion Facility (DCF) caused the j
evacuation of the fuel man ~.facturing facility on March 11.
4 (2)
Observations and Findings On March 11,199 a technician was trouble shooting a aroblem with the Data Acquisition Module (DAM) on the CWS in XF. He placed the control switch in " maintenance" to turn off the zwer, then pulled the suspect Input /0utput (I/0) board.
) lacing the switch in " maintenance" should have deactivated the DAM and given a signal in the Radiation Protection office and in the Emergency Control Center (ECC).
However, when the I/O board was pulled, the CWS for the fuel Manufacturing Operation activated and, sounded the plant evacuation alarm. All fuel operations were properly evacuated and the ECC was manned until the problem could be evaluated. Radiation surveys and review of the CWS detector read outs revealed that the alarm was false and no criticality had occurred.
The licensee's investigation and discussions with the vendor determined that the DAMS which had been provided included a redundant fail safe relay in the circuit. The licensee had requested that the vendor install the switch with
" maintenance" mode. However, the switch did not override the relay. The sub contractor who ordered the DAMS aaparently was not aware of the effect of the relay. With tie switch in " maintenance", detectors could be replaced but any maintenance on the DAM required that the system be shut down because of the relay. However, the licensee expected that the DAMS would activate on a true signal or upon a failure.
After discussions with the vendor, vendor representatives were on site on March 18, 1997, and removed the relay circuit from the DAMS. Now, the licensee can work on the boards using the " maintenance" mode on the switch.
(3)
Conclusions No defect was present in the equipment received.
The licensee's investigation as to the cause of the alarm was thorough and adequately resolved the problem.
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7 2.
Trainina (88010) a.
Doerator Trainias_
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-(1)'
Inspection Scope The1 inspector reviewed the training and qualification program to qualify supervisors, operators and technical
-support personnel for the Dry Conversion Facility (DCF).
(2)
Observations and Findingr The OCF represents a new process technology. Selected members of the staff were sent to the supplier's facility in France for initial training.
Operators and maintenance personnel assigned to the-operating shifts attended a training program consisting of approximately 450 hours0.00521 days <br />0.125 hours <br />7.440476e-4 weeks <br />1.71225e-4 months <br /> of= classroom instruction. This formal--training was completed on March 14.-1997. This i
training consisted of four general groups:
lay out, controls, general and supplemental. Lay out training was concerned with the facility and system arrangement.
Controls training concerned the various-controls associated with the operations and how the process operates. General training was training cn a variety of topics including the metric system, instrumentation, the Integrated Safety Analysis, Piping and Instrumentation Diagrams (P& ids) as well as a variety of subjects such as material control and accountability, radiation safety, nuclear criticality safety, and industrial safety. Supplemental training was additional training on specific topics. including additional training on chemical safety.
Each of the sessions was followed with a learning -
evaluation. The evaluation was similar to a written examination which was used to assess the learner's understanding of the subject material. The evaluations were used to determine subject areas which required additional
' individual instruction.
Once the classroom training was-completed and shift coverage began, the operators started work on the completion of qualification cards for eleven different stages. Because-no uranium or u'rility service were in use during ) art.of. this-
- stage. qualification _ was only " simulated" at t11s stage.
- When the classroom and simulated qualifications (in addition to additional supplemental-training) were completed, the pre qualification summary is signed by the Operations e
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Resource (OR) and the Area Manager.
(The OR acts as a coordinator 'for the shift team and performs many of the functions associated with the Area Coordinators (ACs) in other plant areas.)
Specialized training was also provided for instrument technicians (8 weeks) and maintenance personnel (2 weeks).
(3)
Conclusions The training program was a major effort which addressed the various safety and operations topics.
Completion of the training and pre cualification program appears to provide the basic knowlecge for the safe operation of facility.
b.
Specialized Trainina (1)
Inspection Scope The inspector reviewed the special tr'aining conducted in association with the start up and operation of the DCF.
(2)
Observations and Findings The DCF uses hydrogen gas and nitrogen gas and produces hydrogen fluoride, which is converted to concentrated hydrofluoric acid (HF). Specialized training was conducted for the safety of these materials.
The licensee contracted with outside experts to conduct specialized chemical safety training. On March 3, specialized training was conducted on safety for hydrogen gas and-nitrogen gas.
This' training was also given to members of the Emergency Response Team (ERT) and the Emergency Medical Team (EMT). On March 4, training, including practical exercises, was provided to the operators, EMT, ERT and other selected site personnel on HF.
In addition, members of the regional North Carolina Hazardous Materials (HazMat) team attended the training.
Specialized training on treating injuries associated with HF will be conducted for the local hospital personnel. This training is scheduled for early April.
(3)
Conclusions Specialized training in new chemicals associated with the DCF i.; a strong action by the licensee.
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9 The inclusion of emergency res)onse (EHT, ERT) personnel and off site personnel (state and lospital personnel) is a positive action by the licensee.
3.
Dry Conversion Facility Construction (88020) a.
Roof Construction (1)
Inspection Scope I
The inspector reviewed the status of the completion of the i
roof membrane and the installation of the leck detection system.
(2)
Observations and Findings The facility is designed as a " moderation exclusion" area where no moderating materials will be permitted, except under specifically designated conditions, in those areas where U0, f the " moderator exclusion" princi le is the s wder is produced or handled. A rincipal feature o construction of a roof which precludes' any eaks of rain I
into the facility. Details of the roof construction are described in JCC drawings in the A21 ARXX series of drawings j
and the roofing material supplier project description. The DCF roof is designed to provide multiple barriers to any leakage or seepage of external moisture into the DCF.
Details of the roof design and construction are discussed in IR 70 1113/96 02, Paragraph 4.
The inspector observed the installation of the ro;f edge seal and trim. The installation of the seal and trim appeared to be in accordance with the project drawings and detailed sketches provided by the contractor.
As part of the roof construction. a leak detection system is installed to indicate leakage through the first membrane and the u)per slab. The ins >ector observed that the drain piaes have 3een installed in tirec locations on the drain troug1.
However the drain collection columns have not yet been installed.
(3)
- Conclusions The roof upper membrane and edge trin were installed in accordance with the project drawings.
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10 b.
Process System Installation i
(1)
Inspection Scope The inspector reviewed the installation of the process systems in the DCF to determine that the systems were in accordance with the process drawings.
j (2)
Observations and Findings The inspector selected components and instruments which had been identified by the licensee as having a safety function.
This identification was based on the Active Engineered Controls (AEC) draft list or the hazards analysis evaluation.
The inspector then took the P&lDs for the various systems (vaporization, conversion, acid recovery, etc.) and walked down the systems for process line 1 to verify that the equipment was installed and was shown on the P&ID. The inspector also traced out flow pathways to confirm that the process lines were as shown.
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All of the valves, instruments and major components were l
installed as shown. The inspector also verified that switches or contacts which are used to align moveable equipment and permit valves to open when the equipment is in proper alignment (limit switches) were installed as shown.
In the Hydrofluoric Acid Facility, the inspector walked down the common system for process lines 1 and 2.
The inspector observed that a system modification had been made which incorporated an additional in line uranium monitor to the common process header. This provides two indeaendent measurements of uraniua concentration before t1e recovered acid is released to non favorable geometry tanks as the acid recovery line from each process line also has an in line
- monitor, In reviewing the systems for the powder cooling hoppers, the inspector observed that each hopper has a pressure relief valve to prevent overpressurization of the hopper. However, there is a manually operated valve located downstream of the relief valve where the discharge line connects into a vent header. The inspector questioned this installation because with the manual valve in the " closed" position, the relief valve would not function properly. Licensee representatives stated that all of the lines connecting to the vent header had isolation valves so the vents could be closed when a powder collection container had to be removed.
- However, they agreed that the relief valve discharge should not be blocked and stated that the subject valves would be locked to >
d 11 open until they could be removed.
(3)
Conclusions 1
The identified AECs and related instrumentation were installed as shown on the P& ids.
l The installation of a second in line monitor for recovered acid provides additional assurance that riuclear safety limits for the tanks are maintained.
j c.
Criticality Warnina System (1)
Inspection Scope l
The inspector reviewed the adequacy of the installation of criticality detectors and the status of system completion.
l (2)
Observations and Findings During walkdown of the process systems, the inspector also observed the location of the criticality warning system detectors to assess if they provided adequate coverage. The inspector reviewed the figures in Nuclear Safety Instruction 0.4.0 and compared the actual installation locations. Two detectors were found to have been installed in different locations than shown in the figures although they were within approximately ten feet of the location shown.
Licensee representatives stated that the figures would be revised to show the actual location during the current revision.
The process systems and major components are located in individual rooms. However, all but three of the detectors are located in open areas outside the equipment rooms. The structural walls will provide attenuation of radiation. The inspector asked for the documentation that demonstrates that the detectors are capable of meeting the requirements of 10 CFR 70.24 for criticality warning systems.
Licensee representatives stated that the analysis to demonstrate the adequacy of the location of the detectors had not been completed but would be performed.
(3)
Conclusions The adequacy of the criticality warning system has not been demonstrated.
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12' d.
Air Samolina System:
(1)
Inspection Scope The inspector reviend the basis for the installation of the air sampling system.
(2)
Observations and Findings Stationary air samplers (SAS) are installed in various locatiens to monitor airborne concentrations and to assess exposures of workers. The samplers have been installed throughout the DCF, The inspector discussed how.the locations were determined and how it was determined that values derived from the samplers would be representative of the actual exposures of the workers.. Licensee representatives. stated that the current locations for the Z:: was based on observations-of the equipment and the areas where workers would be relative to potential sources of airborne material. These were not necessarily the final locations as -tests will be made of air-
-flow patterns once the final balancing of the ventilation is complete. Checks will also be made as equipe.ent, such as i-the vawrizers, are heated up SASS will be relocated based on smote tests. - Until-the representativeness of the SAS values is determine, workers will also wear portable air samplers to assess their actual exposures.
(3)
Conclusions The stationary air sampling system has.not yet been demonstrated to provide representative sampling data.
4.
Functional Testina (88025) a.
Jest Administration and Control (1)
Inspection Scope The:-inspector reviewed the administrative controls for preparing and conducting functional-tests of AECs.
(2)
Observations and Findings The primary document is Practices and Procedure (P/P) 1012,
' Functional Test Instructions", which defines the requirements for the-procedure and the test program.
Section Administrative Routine (SAR) 050 28 ' Functional Test Administration" had been issued by the manae r of the Chemical Product-Line to implement the functionai test program. On March 5, 1997, revision 5 to the SAR was issued
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13 which makes it applicable to the Dry Conversion Product t.ine as well.
Functional testing for the DCF will be performed in accordance with the SAR.
(3)
Conclusions Adequate administrative controls are in place to implement the functional test program, b.
Functional Test Instructions (1)
Inspection Scope i
The inspector reviewed the status of the functional test instructions (FTIs) to perform tests of AECs and other safety interlocks.
j (2)
Observations and Findings During the ins?ection period, no FTIs for vaporization, conversion or 1F recovery had been approved or conducted.
The AEC List was being revised and up dated. The FTIs will change based on the AEC list. Also, the program code for the process control system was being ravised to implement controls over accessing and modifying the set points or actions controlled by the process control system.
Tests had been conducted on portions of the system controlled by programmable controllers. However, some controllers were being changed and the code was also being revised based on the initial test results. These tests will have to be conducted again.
Properational tests of the system using the vendor's procedure no. U01.1320, "Hanual for No Load Tests" were scheduled to begin for the vaporization portion of the system but this is dependent on completion of the revision of the program code for the process control system.
(3)
Conclusions Functional testing of the safety interlocks and controls is lagging due to changes in the process control system code and changes in the scope of the AEC list.
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14 5.
Process Safety Analysis (88020) a, Analysis Proaram (1) Inspection Scope The inspector reviewed the administrative program for conducting the safety analysis, documenting tne findings and resolving the findings.
(2)
Observations and Findings In the renewal a> plication for license SNH 1097, dated April 5,1996, tie licensee committed to conducting an Integrated Safety Analysis (ISA) for the Dry Conversion Process as well as other plant areas once a baseline is established. A P/P has been written to implement the ISA once the license is renewed.
The licensee conducted a Process Safety Analysis for the DCF systems and areas primarily using the Hazard and Operability Analysis (Haz0p) methods. This was in accordance with P/P 80 62, " Hazard and Operability Analysis." Other techniques were used in conjunction with the Haz0p.
The analyses were performed by teams with a wide range of expertise in safety and operations. For example, the analysis which was aerformed during March 1113 for the transition work in H0 and the installation of the Dry Recycle Facility consisted of eleven people. The evaluations of potential hazards and the identification of controls was very detailed and thorough. Evaluated hazards were then ranked according to the likelihood of occurrence and the severity of the consequence.
A summary of the DCP ISA was submitted to the NRC on February 19, 1997, in support of the license renewal.
(3)
Conclusions The safety analysis was conducted by qualified personnel using generally accepted evaluation methods.
The safety analysis was a very thorough in depth evaluation of the facility systems and potential operator actions.
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- l b.
Safety Analysis Imolementation -
(1)
Inspection Scope The inspector reviewed how the safety analysis findings were translated into safety controls.
(2)
Observations and Findings In the Safety Analysis worksheets, various items were identified as " safeguards" or actions which would occur when instrumentation sensed an upset condition to preclude the identified consequence.
The inspector. selected approximately fifteen of these safeguards from the safety analyses-for vaporization.
conversion and HF recovery and compared them to the draft AEC list. All of the identified safeguards were listed on the draft AEC list and identifed with FTIs to verify that the safeguard responded properly.
Verification that-the safeguards funcSion properly will be reviewed as part of pre operational testing. Those actions which require o>erator actions will be reviewed in conjunction wit 1 the operating procedure review.
(3)
Conclusions The safeguards appeared to be addressed in the test program.
However, the AEC-list and FTIs are still in-draft.
6.
Exit Interview Summary (88020)
On March 21.1997,. the inspection scope and findings were summarized with licensee representatives.
The-inspector discussed in detai1~ the
. areas inspected. the findings and concerns which had been identified.
.There were no dissenting comments expressed by licensee representatives.
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O 16 ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel
- H, Chilton, Manager, Joint Coaversion Project i
- T. Flaherty, Manager, DCP Operation
- R. Foleck, Sr. Licensing Sp6cialist C. Kipp, General Manager, GE NEP
- J. Kline, Manager, Powder Product Line A. Habry, Program Manager, Radiological Safety I
- R. Martyn, Manager Haterial Control and Accountability C, Monetta, Manager, GE NE Environment. Health & Safety
- S. Hurray, Tea.1 Leader. U0 Pro 6;; tion Team i
- L. Paulson, Manager, Nucle,ar Safety
- L. Quintana, Manager, Fabrication Product Line 1
- R. Reda, Manager Fuels and Facility Licensing
- G. Smith, Team Leader, FHO Maintenance Support
-*D, Snell, Manager, Service Components Product Line (Acting GM GE NEP on March 21, 1997)
C. Tarrer, Team Leader, Configuration Management & ISA' C Vaughan, Project Manager, EH&S New Facility Licensing / Safety
- Attended exit meeting on March 21, 1997.
INSPECTION PROCEDURES USED IP 88010 Operator Training / Retraining IP 88020 Operations Review
- IP 8802S Maintenance / Surveillance Testing LIST OF ITEMS CPENED, CLOSED, AND DISCUSSED Opened None Glosed None Qiscussed None e
--h
17 LIST OF ACRONYMS AC Area Coordinat'or AEC Active Engineered Control CFR Code of Federal Regulations ChPL Chemical Product Line CR Change Request CSA Criticality Safety Analysis CWS Criticality Warning System DCF Dry Conversion Facility DCP Dry Conversion Project ECC Emergency Control Center EH&S Environment, Health & Safety EHT Emergency Medical Team l
EN Event Number ENUSA Empresa Nacional del Uranio, SA ERT Emergency Response Team FHO Fuel Manufacturing Operation FTI Functional Test Instruction GE NE General Electric Nuclear Energy GE NEP General Electric Nuclear Energy Production.
HazHat Hazardous Materials t
I HF Hydrogen Fluoride pl Hydrofluoric Acid IFI Inspector Follow up Item IP Inspection Procedure IR Inspection Report ISA Integrated Safety Analysis JCC
-Joint Conversion Company KGS Kilograms HC&A Material Control & Accountability NCS Nuclear Criticality Safety NCV Non Cited Violation NRC Nuclear Regulatory Commission NSI Nuclear Safety Instruction NSR/R P.r' ear Safety Requirements / Release ONHSS Of fice of Nuclear Haterials Safety and Safegerds OP Operating Procedure OR Operations Resource PA Public Address P/P Practices & Procedures P&ID Piping and Instrumentation Diagram RP Radiation Protection SAR Section Administrative Routine SAS Stationary Air Sampler SNH Special Nuclear Material SSR Software Service Request TOI Temporary Operating Instructica UF Uranium Hexafluoride Ulk Unusual Incident Report U0 Uranium Dioxide USkt U. S. Enrichment Corporation
.4
=
April 18, 1997 l
I General Electric Company L
ATTN: Mr. C. P. Kipp, Gereral Manager 65 Nuclear Energy Production P. O. Box 780 Wilmington, NC 28402-
SUBJECT:
NRC INSPECTION REPORT NO. 70 1113/97 03
Dear Hr. Kipp:
This refers to the inspection conducted on March 24 27, 1997, at the Wilmington facility. The aurpose of_ the inspection was to determine whether activities authorized by tle license were conducted safely and-in accordance i
with NRC requirements. At the conclusion of the inspection, the findings were I
discussed.,ith those members of your staff identified in the report.
Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of-procedures and representative records interviews with personnel, and observation of activities in progress.
Within the scope of the inspection, violations or deviations were not identified.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of
- this letter and its enclosure will be placed in the NRC Public Document Room.
Should-you have any' questions concerning this letter, please contact us.
Sincerely,
/S Edward J. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Gafety Do'cket No. 70 1113 License No. SNH 1097
Enclosure:
NRC Inspection Raport cc w/ encl:
(See page 2) up
- % sc % s,r u. ;,
Y GE 2
- cc w/ encl:
Dr. Ralph Reda Manager fuels and Facility Licensing General Electric Company P. O. Box 780. Hail Code J26 Wilmington, NC 28402 i
Dayne H. Brown. Director l
Division of Radiation Protection i
N. C. Department of Environment, Health & Natural Resources P. O. Box 27687 Raleigh, NC 27611 7687 Distribution w/ encl:
E. McAlpine. RII G. Troup, RII R. Bellamy. RI G. Shear, RIII l
C. Cain. RIV F. Wenslawski, RIV PUBLIC Distribution w/o encl:
License Fee Management Branch
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U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:
70 1113 License No.:
SNM 1097 i
Report No.:
70 1113/97 03 Licensee:
General Electric Company Wilmington, NC 28402
(
Facility Name:
Nuclear Energy Production Dates:
March 23 27, 1997 Inspector:
W. Gloersen, Senior Radiation Specialist Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure mmaar mes
1 I
.e-Executive: Summary 6
General Electric Nuclear Energy Production NRC Inspection Report 70 1113/97 03 The primary focus of this routine unannounced inspection was the observation and evaluation of the licensee's environmental protection and waste management
-1 programs.
In addition, the status of the new Dry Conversion Facility (DCF) was reviewed with respect to radiation protection, radioactive effluent waste management and functional testing of sampling systems. The report covered a one week period and included the results of inspection efforts of one regional fuel facility inspector.
- Based upen the results of this inspection, the licensee's environmental protection and waste management programs were acceptable. Within the scope of the inspection, on's non cited violation was idaitified for the failure to collect and analyze a vegetation sample as required by the license application. There was one new inspector follow up item being tracked
>ertaining to reviewing the iicensee's: internal dose assessment of the CaF,
>asin excavation equipment operators.
- RADIATION PROTECTION Installation and functional testing af the stationary air sampling equipment associated with the Dry Conversion Facility had not been completed and therefore the 1kensee could not demonstrate air sampling representativeness, Radiation protection posting and access control requirements had not e
been completed for the Dry Conversion Facility.
. A high volume air sample indicated elevated gross alpha airborne
- e concentrations in-the vicinity CaF, excavation of the south basin.
ENVIRONMENTAL PROTECTION
- Anaiytical results from the various surface environmental samples e
collected = indicated that' there was no radioactive material -from plant operations accumulating or concentrating at-the sample location.
- e.
One isolated example for the failure to collect a vegetation sample during the second half of -1996 was~ identified.
' Elevated concentrations of uranium in certain samples from groundwater wells-in-the vicinity of. the CaF, pits was identified.
e-The 1996-external-audit of the environmental arotection' function was thorough, however, the audit was lacking in tlat it provided no
. assessment of performance for the licensee.-
er /
.e.-.
= - - -
s WASTE MANAGEMENT The licensee had effectively implemented the required stack sampling
=
program.
1 Total quantities of radioactive liquid and gaseous emissions from the I
e facility have been decreasing since 1994, Eauipment installation, functional testing, and procedure development o
for the collection and analysis of gaseous and liquid samples associated with the Dry Conversion Facility were not ready to support operation of the facility.
Attachments:
Partial List of Persons Contacted Inspection Procedures Used List of Items Opened, Closed, and Discussed List of Acronyms i
4 4 9 g.
Report Details I. Introduction
- A.
-Inspection Overview 1.
Purcose This inspection was conducted to determine the adequacy of the licensee's environmental protection and waste management programs. This
-roatine inspection was conductcd through a review of selected records, l
interviews with personnel, and direct observation of work activities in L
_the areas of facility operations, environmental protection, and waste management.
2.
Maior Areas of Emohasis j
Areas inspected included:
Environmental Protection Program Implementation o
Effluent Waste Management Program e
DCF Operational Readiness in the areas of Radiological Protection l
-e and Radiological Effluent Controls B.
Summary of Plant Status This report covered a one week period. There were no unusual plant operational-occurrences during the onsite inspection. Construction and testing activities for the DCF were progressing.
-II. Radioloaical Controls 4
A.
Radiation Protection (83822) 1.
' Radiation Protection Proaram Eouioment a.
Insoection Scope The inspector examined the stationary air sampling system and other radiation protection equipment necessary_to support
-operations in the new DCF.
b.
Observations and Findinas During tours of the DCF, the inspector noted that most of the-stationary air samplers-(SAS) had been installed, however, it was also noted that several air sampling heads were missing; the system had not been functionally tested: and the final locations-e
2 for air samplers had not been determined (see Inspection Report No. 70 1113/97 02)'. The licensee incHcated that at DCF startup, 25% 50% of the workers will be issued lapel air samplers to-evaluate personnel exposures, I
The inspector also r.oted that the licensee had established a DCF radiation protection action item chccklist, which required that F
the action items be closed before DCF startup. The completion of the installation, testing, and procedures for the SAS was included on the action item list. -In addition, the action item list I
included the establishment of a radiation protection work area in the DCF with necessary counting equipment and instrumentation:
adequate respiratory protective clothing; protection equipment and sup) lies of and adequate supplies of hipa volume, low u
volume, and lapel air samplers.
c.
Conclusions Installation and functional testing of the stationary air sampler (SAS) equipment had not been completed and therefore the licensee could not demonstrate air sampling representativeness. The licensee's radiation protection action item list to support DCF operations was acceptable.
2.
Internal Exoosure Controls a.
Insoection Scooe The inspector examined work' activities associated with 'he CaF t
r Basin source removal and relocation project to determine if adequate radiation protection controls were in place, b.
Observations and Findinos During a tour of the CaF, Basin source removal and relocation project on March 25, 1997, the inspector observed excavation activities of the south basin'(Basin #1). The excavation activities involved the removal of the CaF using heavy machinery.
a During dry conditions :the potential for diuty conditions existed.
The inspector noted that the heavy equipment operator was not wearing a lapel air sampler, nor was a lapel air sampler required by the )rocedure. ' CaF Project Health and Safety Plan, Revision t
1,= Marc 1 11, 1997, indicated that personnel radiation exposure is monitored by-(1) thermoluminescent dosimeters (TLDs): (2) in vitro bioassays; and (3) area' radiation monitoring. After the observation by the inspector, the licensee requested that-a high volume air sample be collected. -The high volume air sample result was 0.96E 11 pCi/ml.. The inspector discussed the result with licensee representatives who indicated that the excavators will be a
d
e..
A e
3 4
issaed lapel air samplers so that any potential internal exposure 4
could be evaluated.
The inspector-indicated that the results of the internal exposure assessment will be tracked as an inspector followup item (IFI 70 1113/97 03 01).
c.
Conclusjons
]
By collecting a'high volume air sample, the licensee detected i
elevated gross alpha airborne concentrations in the vicinity CaF, i
excavation of the south basin. No conclusions can be made until L
more data are collected and assessed.
l l
3.
Postinas. Labelina. Access Control a.
Inspection Scoot The' f nspector examined DCF to determine if adequate postings-and access control measures were in place to support operations in the new Dry Conversion Facility.
b.
Observations and Findinas During tours of the DCF, the inspector noted that the facility was in the final construction stages and therefore the necessary radiation protection )ostings and radiation control area access had not been establis1ed. As noted above, the licensee had established a'DCF radiation protection action item checklist, DCF posting and access control requirements ure included on the action item-checklist.
c.
Conclusions-
~
Although the necessary radiation protection posting and access-control requirements had not been completed, the licensee's system for tracking these items for completion before DCF startup was.
acceptable.
B.
Environmental Protection (88045) 1.
Monitorina Procram Results a.
Insoection Scoce
- The inspector reviewed the licensee's: environmental protection program with respect to program implementation. Table 5.1 of' Chapter 5 of the License-Application specifies sampling frequency, parameters analyzed, action levels, minimum detectable concentrations (MDCs). ~and sampling types collected. - Figures 5.3, 5.4, 5.5, 5.6, and 5.7 of the same cha)ter contained maps showing.
the locations of_ sampling sites througiout the area.
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4 b,
Observations and Findijhui The environmental monitoring program provided representative i
measurements of radioactivity in the lighest potential exposure I
pathways and verification of the accuracy of the effluent monitoring program of environmental exposure pathways.
Accumulation of radioactivity in the environment can thereby t;-
i measured: trends assessed, to determine whether the radioactivity l
resulted from plant operations: projections made of potential dose to off site populations based on the cumulative measurements of any plant originated radioactivity: and detection of unanticipated pathways for the transport of radionuclides through the l
environment.
l The program was designed to detect the effects, if any, of plant operation on environmental radiation levels by monitoring radiation pathways in the area surrounding the plant l
site.
It also verified that the measurable concentrations of l
radioactive materials and levels of radiation were not higher than expected on the basis of the effluent measurements.
The inspector reviewed selected sampling results from weekly environmental stationary air samples and surface water, sediment, l
and soil samples collected quarterly in 1996 as part of the licensee's routine environmental monitoring 3rogram. Most of the l'
sampling locations around the facility were 3elow the a action level specified in Table 5.1 of the Application.pproprkte The inspector did note that, in the first, second and fourth quarters 1996, a few onsite and offsite soil sam)le locations had slightly elevated total uranium concentrations tlat exceeded the licensee's action level of 0.7 ppm as specified in Table 5.1, In those cases, the licensee issued an Environmental Action Level (EAL) investigation. The inspector reviewed selected EAL investigations that documented elevated soil sample results that occurred in 1996.
The EAL investigations were adequately documented and part of the licensee's followup action was to watch the trend.
The inspector indicated that additional appropriate actions might include a review of sampling procedures and techniques and a review of the analytical procedures used in the CHEMET laboratory where the environmental samples were analyzed. The licensee acknowledged the inspector's comments.
During the review process, the insrector noted that the results for the vegetation samples scheduled for collection in Fall 1996 were not available. Table 5.1 of the license application recuires the licensee to collect vegetation samoles twice pe? year anc to be analyzed for fluorides.. By the end of the onsite inspection, the licensee was still in the process of locating the sample results. In a subsequent-telephone call on April 7,1997, the e
licensee informed the inspector that the vegetatfon sample was not collected in the Fall 1996.
Apparently, the sample was inadvertently missed and it was not included on the licensee's overcheck list.
In addition Table 5.1 did not sp:ify an action level for-vegetation samples. The corrective actions included the
- e %
v
5 issuance of an Action Level Investigation Form, collection of a vegetation sample and the analysis (in addition to the first half I
1997 sample), and update the overcheck list to include vegetation sampling. The licensee was informed on April 15, 1997 that the failure to collect the vegetation sample was a violation of Safety Cor jition S 1. Sections 5.2.2.3 and Table 5.1 of the Applicat, ion.
However, this violation will not be subject to enforcement action because the violation was of minor cnvironmental concern, the I
licensee's efforts in correcting the violation were prompt, and the violation met the criteria specified in Section IV of the E Enforcement policy for a Non Cited Violation (NCV 70 1113/97 03-02),
The inspector also reviewed the results of the licensee's groundwater monitoring arogram.
Table 5.1 of the license application specified t1e sampling locations, collection frequencies, analytical parameters, ano action levels.
In 1996, most of the groundwater monitoring results were below the license application cction level. However, the inspector noted that groundwater sample results for total uranium from the wells installed downgradient from the CaF pit relocation project ranged from approxiniately 2 to 3181 pCi/ liker. The maximum concentrations occurred during the excavation activities.
The licensee met with representatives of the State of North Carolina's Department of Environment, Health and Natural Resources (DHENR) on i
3 December 19, 1996 to discuss the results of the CaF well I
monitoring data, TheStateDHENRrepresentativesnol.edthatsince thc groundwater sample results were in excess of State groundwater quality standards, the licensee was required to fully assess the vertical and horizontal extent of the affected groundwater and propose a corrective action to restore the groundwater.
In a letter dated March 3,1997 from the licensee to the State of North Carolina, the licensee transmitted a schedule for actions to address the issues raised by the DHENR. The inspector indicated that further review of the licensee's progress in addressing the groundwater issues will be made during subsequent inspections.
The inspector also noted that groundwater samale results from Well PL 13A, which was installed east of the NE Ca fl to basin and became operational on January 30, 1195, ranged from 4 21,600 pCi/ liter during the period January 30, 1995 to February 17, 1997. The sample result collected on February 17, 1997 was approximately 920 pCi/ liter. The licensee believed that this well may have been drilled into a vein of CaF,t from PL 11A sludge. The licensee instelled two additional wells downgradien To date, the sample results from those wells indicated background
- levels, c.
Conclusions In general, the analytical results from the various surface environmental samples collected indicated that there was no
6 concentrating at the sample location.
There was one isolated cxample for the failure to collect a vegetation sample during the second half of 1996. The licensee had detected eleva'ed concentrations of total uranium in certain groundwater wells in the vicinity of the CaF, tion of the CaF, during the source term pits. The elevated activity was most likely due to the excava relocation project in 1996.
2.
Hanecement Audits. Inspections, and Controls a.
Inspection Scope The inspector reviewed the licensee's environmental protection audit program and results. The requirements of the environmental protection internal audits were specified in Section 2.8.2 of the license application.
The requirements for external audits were specified in Section 2.8.3 of the application, b.
Observations and F_indinos The inspector randomly examined records of both internal and external environmental protection audits. The last external audit was conducted the week of September 23 27, 1996 by the licensee's cross business unit. The audit covered management and organization, operating permits, air emissions, waste water, waste management, radiation protection, soil and groundwater contamination, and procedures.
The audit was comarehensive, however, a heavy emphasis was placed on OSHA and EPA regulatory.
compliance. The audit findings were formally tracked, including the corrective actions and issue date: assigned to a person or organization for closure action: identified an action completion date: and identified the closure status, The inspector did note, however, that the external audit provided no assessment of licensee performance in the environmental protection area.
The inspector also reviewed the quarterly internal audits conducted in 1996. Each of these audits focused on a ) articular aspect of the Health and Safety program, including, tie environmental protection function, training, waste storage, and radiological protection. The last quarterly environmental audit was conducted during the first quarter 1996. There were no audit findings identified.
The inspector noted that for the other quarterly audits conducted in 1996, there was no apparent formalized tracking system for audit findings.
c.
Conclusions The 1996 external audit of the environmental protection function was thorough, the audit findings _were tracked, and the, assignment of responsibility for closure was acceptable. However, the audit 6s
7 was lacking in that it provided no assessment of performance for the licensee.
In ' addition, a more formalized system to track internal audit findings was noted as an area for improvement.
3.
Decommissionina Activities. CaF, Relocation Proiect a.
Inspection Scopa The inspector reviewed the licensee's progress in evaluating the residual radioactivity remaining in the burial trenches of the northwest CaF,torage facility in the Controlled Access Area (C storage area after relocation of the material to an above ground s 4
In addition, the insxctor reviewed the progress in removing the CaF, from three basin areas, b.
Observations and Findinas As of the end of July 1996, the licensee had essentially completed the excavation and relocation of the CaF, from the northwest storage area. The licensee was in the process of implementing the Final Status Survey and Release Plan for the Northwest CaF Area (FSS Plan) in order to demonstrate that residual radioactiv concentrations at the northwest CaF storage area satisfied the NRC criteria for future use without, licensing restrictions and radiological controls. The inspector indicated to the licensee that a representative number of samples should be split.
preserved, and stored for possible future NRC analysis for confirmatory meacurement purposes.
-The inspector also noted that the licensee had initiated the Caf, removal from the South Basin (or Basin # 1) and relocation to an above ground storage facility. The licensee estimated that 29.970 cubic feet (ft') of CaF, was in the basin.
In addition, the licensee had planned to remove Caf
- 2 37,690 ft ) and the Outer Basin, in both the North Baf).n (Basin (Basin #3 34.280 ft Although the licensee's goal was to remove the CaF, source term, the licenses had not planned to release these areas without licensing restrictions and radiological controls due to their proximity to the operating site process lagoon system. The licensee's request to delay " free release
- of the CaF, basin area was still being reviewed by the NRC.
- c.
Conclusions The licensee had comoleted excavation of the CaF, in the Northwest Storage Area well with in the schedule and was progressing acceptably toward implementation of the Final Status Survey and Release Plan.
-@+
8 C.
Waste Management (88035) 1.
Monitorina Procram Results a.
Inspection Scopj The inspector reviewed and assessed records and reports of gaseous and liquid effluent discharges from the facility during the last calendar year and compared those discharges to discharges from previous years.
10 CFR 70.59 requires the licensee to submit a report to the NRC Region !! office, within 60 days after January 1 and July 1 of i
each year, specifying the quantity of each the of the principal radionuclides released to unrestricted areas in liquid and gaseous i
effluents during the previous six months of operation.
If the quantities of radioactive materials released during the reporting periods are significantly above the licensee's design objectives previously reviewed as part of the licensing prucess, the report shall cover this specifically, b.
ObservationsandFindinos The inspector reviewed the Semiannual Effluent Release Reports for i
the period January 1. 1996 through December 31, 1996, and verified that they were submitted within the required time frame. During the onsite inspection, the inspector noted that the report for the second half of 1996, dated February 25, 1997, incorrectly made reference to the first half of 1996. The inspector verified the date were representative of the second half of 1996. The licensee immediately corrected the typographical error and resubmitted the second half 1997 semi. annual effluent release report in a letter to the NRC dated March 24. 1997. Although the minimum reporting requirements of 10 CFR 70.59 were met, the inspector observed that the licensee used only selected portions of the report format i
guidance sxcified in Regulatory Guide 4.16. Monitoring and Reporting ladioactivity in Releases of Radioactive Haterials in Liquid and Gaseous Effluents From Nuclear Fuel Processing and Fabrication Plants and Urani.a Hexafluoride Production Plants.
- Rev. 1. December 1985. Subsequent semi annual reports will be reviewed against the reporting format guidance in Regulatory Guide 4,16 The inspector compared the-total quantities of liquid and gaseous effluent discharges in 1996 with previous years. The data are summarized in Table 1 below.
- O e 9e
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Table 1:
Effluent Summary for General Electric Company Nuclear Energy Production (1993 1996)
Quantity Released (microcuries, yCi)
Effluent Nuclide E
D14 HH M93 Gaseous U 234 7.31E401 1.04E+02 9.56E+01 9.42E+01 U 235 2.85E400 4.06E+00 3.84E400 3.71E+00 U 236 2.54E 02 3.69E 02 1.84E 02 1.21E 01 U 238 1.16E+01 1.65E+01 1.60E401 1.44E+01 Total-8.76E+01 1.25E+02 1.15E+02 1.12E402 Liquid U 234 8.19E+04 7.19E404 6.51E+04 4.97E+04 U 235 3.19E+03 2.81E+03 2.61E+03 1.96E+03 U 236 2.89E+01 2.54E+01 1.21E+01 6.42E+01 U 238 1.30E+04 1.14E404 1.11E+04 7.60E+03 Total 9.81E+04 8.61E+04 7.88E+04 5.93E+04 The total quantity of uranium discharged in gaseous effluents in l
1996 was 112 pCi.
Since 1994, there has been a slight decrease in the total quantity of uranium discharged in gaseous effluents.
By using the USEPA's COMPLY code, the licensee estimated an offsite dose of approximately 0.2 mrem. The estimated dose was based on the total quantity of gaseous effluents released from the facility in 1996 to a maximally exsosed receptor. This estimated dose was significantly less than tie NRC's new dose constraint of 10 mrem for air emissions, as specified in 10 CFR 20.1101(d).
The total quantity of uranium discharged in liquid effluents in 1996 was 5.93E+04 Ci.
Since 1993, there has been a decrease in the total quantity of omnium discharged in liquid effluents. The licensee did not calcui,e a dose based on the total quantity of liquid effluents released from the facility in 1996, c.
Congh:31gns Total quantities of radioactive liquid and gaseous emissions from the facility have been decreasing since 1994 In 1996, the estimated dose to a maximally exposed offsite receptor was less than 10% of the 10 CFR 20.1101(d) dose constraint which indicated that the licensee's gaseous releases were ALARA.
2.
Effluent Controls. Procedures. and Instrumentation a.
Inspection Scope The inspector reviewed the licensee's controls and procedures for sampling and analyzing liquid and gaseous discharges from the facility.
In addition. the inspector reviewed the licensee's readiness for samplina and analyzing effluent discharges from the DCF which was currently in the final stages of construction.
pe
)
10 4
The licensee was required to sample and analyze discharges via the i
gaseous and liquid pathways in accordance with Chapter 5. Part I of the license application. Specifically, Section 5.1.1 outlined airborne effluents and exhaust systems from the uranium processing areas. Each exhaust stack from uranium processing areas was required to be continuously sampled from a >oint between the final i
HEPA filter and the discharge to the atmospiere. Table 5.1 of the i
Application specified the collection frequency, parameters of i
interest, action levels, and detection limits. Depending on the particular stack, the filters in the stack samplers were required to be collected at least daily or weekly and measured for gross alpha and beta activity. Additionally, Section 5.1.2 of the 4
i Application described the treatment process, sampling and analytical controls for treated process liquid waste.
j b.
Observations and Findinas (1)
Fuel Manufacturing Operations (FHO)
The inspector reviewed selected procedures and verifled that the action levels and provisions for collecting and analyzw liquid i
and gaseous effluent samples were in accordance with the license application, i
In addition, the inspector reviewed selected weekly composited
\\
analytical results from January 1996 to February 1997 for 4
- discharged liquid effluent from the final process lagoons, i
aeration basin and the site dam. The inspector noted that total uranium, gross al>ha, and gross beta concentrations in the samples were well below.tle specified action levels.
L The inspector selectively reviewed weekly stack program reports covering the period from September 1996 February 1997. Based upon the records reviewed, the inspector noted that the specified J
action level had been exceeded during the seriod January 1016, 1997 on the stack associated with the new 0econtamination and Volume Reduction Facility (DVRF). The weekly average sample result for the DVRF stack was 9.73E 10 pC1/cc which exceeded the licensee's weekly average action level of 3.0E 12 C1/cc. The high activity was probably due to the disturbance of the settled material in the ductwork during-system startup. The material in the ductwork had setcled due to the long period of inactivity.
The licensee's corrective actions were acceptable.
In addition, the inspecter reviewed the quarterly quantities of gaseous waste effluents released in 1996 and-the first quarter-of 1997. The inspector verified that-the gaseous release quantities were less than the license application limit of 1250 pCi/ quarter.
In 1996, the maximum quarterly quantity release w6s 34.1 pCi which i
occurred during the third quarter. The total quantity of uranium ee g
_..,.. - _. ~ -. _,
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...~-.-.,,---_-,,m.._,,,,-_
11 released during the first quarter of 1997 was 36.1 pC1.
From the data above. it was apparent that the licensee was well below the license application's quarterly limit.
(2)
Ory Conversion facility (DCF)
In addition the inspector toured the DCF to determine if adequate l
i gaseous and liquid sampling equipment and procedures were installed, functionally tested and operationally ready for startup.
The inspector noted that there will be three gaseous release.
aoints from the DCF:
(1) HVAC discharge from the DCF main l
Juilding (uranium and HF samples): (2) discharge from the washing column (uranium and HF samples): and (3) discharge from the emergency scrubber (HF sem)1e). The DCF HVAC system exhausts building air to the atmosp1ere through a single stack mounted i
along the side and roof of the building. The stack did not penetrate the roof of the building due to the potential concerns for-water intrusion. Air is )assed through two sets of high efficiency particulate air (HIPA) filter banks before it is exhausted to the atmosphere. The four foot' diameter stack was designed to carry 28.645 cubic feet per minute (cfm) of air. The sampling points for HF and particulate matter (uranium) were located in the horizontal section of the duct and approximately 20 feet (ft) downstream of the 90 degree bend where the duct penetrated the DCF building wall. The licensee indicated that a single point sampling probe located in the center of the duct for the collection of partict. late matter should be sufficient for obtaining a representative sample due to the turbulent flow in the duct. The inspector reviewed the licensee's evaluation, which made appropriate references to applicable ANSI standards and use of chemical engineering references. Based on.the assumptions of the rated efficiencies of HEPA filters for the removal of particles. the average size of the > articles remaining in the exhaust stream after passing throug1 the HEPA filters should be much smaller than five microns. Assuming that the inertial effects for particles less than five microns will be negligible, the particulate matter in the air stream may be considered as a gas. The licensee also predicted that the exhaust air in the stack will be turbulent and therefore the particulate matter containing the uranium is expected to be evenly distributed across the stack diameter. The insaector verified the licensee's calculation of the Reynolds iumber which predicted the turbulent flow. Although collecting a sample from a horizontal section of a duct is not ideal, tha licensee's analysis justifying the sample probe location appeared to be acceptable.
While tracing the sam)1e delivery line from the HVAC discharge back to the DCF main Juilding. the inspector noted at least three 90 degree bends that could have been avoided. The licensee made note of the observation and indicated that the problem would be
t
(.
J 12 a
J corrected.
From discussions with a licensee HVAC specialist, the inspector noted that the velocity profile measurements across the i
duct diameter had not been completed and the air flow probes had 1
not been installed.
In addition, the ins)ector noted that Dwyer rotameters had been installed, however, tle licensee's rotameter e
i calibration equipment was only compatible with Wallace-rotameters.
The HVAC specialist indicated that the Dwyer rotameters would have 5
to be replaced with equipment compatible with the licensee's calibration equipment.
In addition, the licensee had not completed revision to the surveillance, sampling and analysis procedures for the DCF.
The inspector also traced the sample delivery line associated with the discharge from the washing column. Although unnecessary 90 1 --
degree bends were not observed, the inspector did note similar concerns as discussed above for the HVAC discharge.
The inspector also toured the hydrofluoric acid tank system i
facility and noted that installation of the liquid sampling equipment had not been completed.
In addition, sampling and analysis procedures were still in the development process. The i
licensee was also evaluating what modifications to make for transporting ten percent HF acid solutions to the Waste Water Treatment Facility.
c.
Conclusions Releases of gaseous radioactive materials from the facility were significantly less than the license a) plication quarterly limit.
p In addition, total uranium, gross alpla, and gross beta concentrations in liquid effluent samples were well below the specified action levels. Both of these parameters indicated that 1
licensee's effluent control program was effective.
Equipment installation, functional testing, and procedure development for the collection and analysis of gaseous and liquid samples associated with the DCF were not ready to support i
. operation of the facility, j
- 3.-
Information Notices (92701)
J a.
Insoection Scooe r
The inspector reviewed the following Information Notice (IN) to determine if the information:had been received by the licensee:
4 e
IN 97 04:
Implementation of a New Constraint on
. 3 Radioactive Air Effluents, dated February 24 r
1997.
4 4
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13 l
b, Observations and Findinas The inspector determined that Information Notice 97 04 had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate, was taken or scheduled.
c.
Conclusi.QD The licensee's actions were appropriate.
4.
EpilowuoonPrevious1vIdentifiedIssues(92701) a.
Inspection Scoce The inspector reviewed the following unresolved item (URI):
70 1.113/96 07 01: Determine whether or not the strong tight container identified as DOT 128 30 satisfied the packaging recuirements s)ecified in 49 CFR 173.410 and 173.411 for an incustrial paccage Type 1.
b.
Observations and Findinas The inspector reviewed the licensee's evaluation of the )ackaging requirements.
It was determined that the DOT 128 30 paccage conformed to 49 CFR 173.410 requirements. The container in question was equivalent to a 4G container. The 128 30 container was made from fiberboard that incorporated an inner container consisting of a one gallon metal can. The shipment in question involved a limited quantity of radioactive material. Therefore, the packaging requirements for limited quantity shipments were not required to be transported via IP 1 classified containers (49 CFR 173.411), but were required to be shipped in accordance with 49 CFR 173.410, c.
Conclusions The licensee's analysis was acceptable. This item is closed.
we
i 14 III. Manaaement Hectinas A.
Exit Interview The inspection scope and results were summarized on March 27, 1997, with those persons indicated in the Attachment. The inspector described the areas inspected and discussed the inspection results, including the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report. Dissenting comments were not received from the licensee.
During a telephone conversation on April 7, 1997, the licensee informed the inspector that a vegetation sample required by the license application to be collected semi annually was not collected in November 1996.
The licensee was contacted telephonically on April 15, 1997, and informed that the failure to collect and analyze the vegetation sample would be identified as a non cited violation of license application requirements.
4 e e 49
0 15 ATTACHMENT 1.
PERSDNS CONTACTED Licensee Personnel
- D. Brown Team Leader Environmental Project
- T. Crawford. Senior Environmental Engineer
- D. Dowker Team Leader, Environmental Process Team
- R.. Foleck, Senior-Licensing Specialist G. Fornasiero, Enginee., Packing and Transportation
- A.- bbry Principal Nuclear Safety Engineer
- C, Monetta, Manager, GENE Environmental Health and Safety (EH&S)
- L. Paulson, Manager, Nuclear Sefety
- L, Quintana, Manager, Fabrication Product Line l
R. Reda, Manager, Fuels and Facility Licensing
- G. Sbrocco, EH&S Engineer
-*H.= Shaver, Nuclear Safety Engineer
- H. Strickler, Manager, Site _EH&S
- *K. Theriault Manager, Quality Assurance and Chemet Laboratory C. Vaughan, Project Manager EH&S New Facility Licensing / Safety
)
Other licensee employees contacted included engineers, technicians, production staff, security, end office personnel.
- Denotes those present at the exit meeting on March 27, 1997.
2.
INSPECTION PROCEDURES USED IP 83822 Radiation Protection IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 9?701 Followup
- 3.
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Descriotion 70 1113/96 07 01 Closed URI Determine whether or not the strong tight container identified as DOT 12B30 satisfied the packaging requirements specified in 49 CFR 173.410 and 173.411 for an industrial package Type-1.
3 n.
4
)
c.'
16 70 1113/97 03 01 Open IFI. Review licensee's internal dose assessment of the CaF equipment operators., basin excavation 70 1113/97 03 02 Closed NCV Failure to collect a vegetation sample in accordance with Sections 5.2.2.3 and Table 5.1 of the Application.
4.
LIST OF ACRONYMS CAA Controlled Access Area I
- CaF, Calcium Fluoride cfm cubic feet per minute i
DCF=
Dry Conversion Facility DHENR Department of Health. Environment, and Natural Resources -
DVRF Decontamination and Volume Reduction Facility-EAL Environmental _ Action Level EH&S Environment,-Health & Safety
. EPA-Environmental Protection Agency FM0 Fuel Manufacturing Operations FSS Final Status Survey
'GE NE General Electric Nuclear Energy GE NEP General Electric Nuclear Energy Production HF Hydrofluoric Acid HVAC Heating, Ventilation.-and Air Conditioning IFI Inspector Follow up Item IP Industrial Peckage IR Inspection Report HDC
-Hinimum Detectable Concentration NCV Non Cited Violation OSHA-Occupational Safety and Health Administration ppm parts per million-SAS Stationary Air sempler-URI Unresolved Item i
.,