ENS 48375
ENS Event | |
|---|---|
14:00 Oct 4, 2012 | |
| Title | Unanalyzed Accident Scenarios for Certain Consequences of Concern |
| Event Description | This notification is based on 10CFR70 Appendix A (b)(1), 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis (ISA), and which results in failure to meet the performance requirements of 10CFR70.61.'
Westinghouse Columbia Fuel Fabrication Facility routinely enters external NRC event notifications and issues into the Corrective Actions Program (CAPs) for external operating experience. Westinghouse Environment, Health and Safety (EHS) staff and the Issue Review Committee evaluated the AREVA NP, Inc. Richland NRC Event Report #48366 for applicability and impact on compliance for the Columbia plant. This evaluation identified a regulatory noncompliance. The ISA currently identifies Items Relied on for Safety (IROFS) for scenarios based on Emergency Response Planning Guidelines (ERPG) (i.e., airborne concentration criteria) for chemical consequences. However, the Process Hazards Analysis (PHA) conducted for the ISA, with minor exceptions, did not specifically identify high or intermediate events that may or may not require additional IROFS for dermal or ocular exposures from the plant's chemical processes subject to 10 CFR 70 requirements. This report is intended to cover all potential chemical dermal or ocular exposures within those systems covered by the plant's ISA. There is no actual safety significance, and the potential safety significance of this issue is low due to the following: - An extensive number of IROFS are currently in place to prevent chemical spills that could lead to airborne concentrations above ERPG limits, and these same IROFS can be readily utilized to prevent most dermal/ocular exposure accident sequences. - SNM-1107 License Application, Section 7.0 - Chemical Safety Program, as well as the governing Occupational Health and Safety (OSHA) regulations, already contain requirements for worker protection from these hazards. The Columbia plant recognizes these hazards through its PHA and Job Safety Analysis (JSA) processes and identified the need for controls, where applicable. - Robust procedures, training and appropriate Personal Protective Equipment (PPE) are in place to ensure worker safety from these types of hazards. However, failure to specifically identify the dermal/ocular exposure as potentially high or intermediate consequence events in accident sequences in the framework of the ISA process led to these sequences not being included in the ISA Summary, and therefore, IROFS were not designated for these sequences as required by 10 CR 70.61. As noted above, this issue has been entered into CAPs (IR 12-277-C001). Until the PHA and JSA are reviewed for identification of specific IROFS, the applicable elements of our license-required Chemical Safety Program will be treated as IROFS for purposes of compliance with 10CFR70.61 and reporting under 10CFR 70 Appendix A. |
| Where | |
|---|---|
| Westinghouse Electric Corporation Columbia, South Carolina (NRC Region 2) | |
| License number: | SNM-1107 |
| Reporting | |
| Part 70 App A (B)(1) | |
| Time - Person (Reporting Time:+1.53 h0.0638 days <br />0.00911 weeks <br />0.0021 months <br />) | |
| Opened: | Gerald Couture 15:32 Oct 4, 2012 |
| NRC Officer: | Howie Crouch |
| Last Updated: | Oct 4, 2012 |
| 48375 - NRC Website | |
Westinghouse Electric Corporation with Part 70 App A (B)(1) | |
WEEKMONTHYEARENS 561992022-11-01T15:29:0001 November 2022 15:29:00
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