ML20059K252
| ML20059K252 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 11/10/1993 |
| From: | Milstein R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9311150253 | |
| Download: ML20059K252 (4) | |
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UNITED STATES t
[g.)l. '1[. j NUCLEAR REGULATORY COMMISSION W AsHINGTON. D.C. 20555-0001 j
g, ' v j' NOV 1 01993 ME10RANDUM FOR:
Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS THRU:
Michael Tokar, Section Leader Licensing Section 2 Licensing Branch i
Division of Fuel Cycle Safety i
and Safeguards, NMSS FROM:
Richard Milstein i
Licensing Section 2
)
Licensing Branch i
Division of Fuel Cycle Safety and Safeguards, NMSS
SUBJECT:
SITE VISIT TO COMBUSTION ENGINEERING (CE) HEMATITE FACILITY (OCT. 18-21, 1993)
Attendance Richard Milstein, NRC William Troskoski, NRC Phuoc Le, SAIC Peter McKnight, SAIC Padmavati Chitrapu, SAIC Harold Eskridge, ABB Robert Griscom, ABB Mark Michelsen, ABB James Rode, ABB (exit meeting)
Backaround The Nuclear Regulatory Commission has contracted with Science Applications International Corporation (SAIC) for technical assistance in the area of chemical safety.
In particular, subtasks 2.2 and 2.3 in the contract' call for SAIC to develop criteria for evaluating chemical safety at t
' Modification 2 to task crder 15 under contract no. NRC-02-90-009 was D
signed on September 30, 1993.
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9311150253 931110 g
1 0081 PDR ADOCK 07000036 F C
PM d
NOV ! ole Robert C. Pierson 2
NRC licensed facilities and to review chemical safety programs at selected NRC licensed facilities.
The visit to CE Hematite on October 18-21, 1993 was the first in a series of five planned visits to NRC licensed facilities. The other facilities that will be visited are Siemens Power Corp. (Richland, WA).
Allied-Signal Inc. (Metropolis, IL), Westinghouse Electric (Columbia, SC), and Babcock and Wilcox NNFD (Lynchburg, VA).
Site Visit On October 18, 1993, the NRC/SAIC team held an entrance meeting with the licensee's staff.
NRC explained that the purpose of the visit was to gather information about the licensee's chemical safety program and was not to conduct an inspection.
It was noted that the information gathered would be used for two purposes.
First, the NRC was interested in evaluating the licensee's chemical safety program, as part of the general evaluation required for renewing CE's license.
Secona, the NRC was interested in developing acceptance criteria for chemical safety that could be used in future evaluations.
The scope of NRC's interest in chemical safety was briefly discussed.
It was noted that NRC was concerned about two potential sets of chemical hazards:
those posed by licensed nuclear material, such as UF6 (and its hazardous reaction product, HF), and those posed by non-licensed materials (toxic release, fire, and explosion) that could have a significant effect on the adiological safety of the facility.
Following the entrance meeting, the NRC/SAIC team was given a tour of the facility.
In preparation for the visit, SAIC developed a checklist to structure their information gathering activities.
The cheulist was derived from several sources including OSHA's Process Safety Management regulation (29 CFR 1910.119), EPA's Risk Management Program regulation (40 CFR 68), New Jersey's Toxic Catastrophe Prevention Act (TCPA), California's Risk Man &gement and Prevention Program (RMPP), and Delaware's Extremely Hazardous Substances Risk Management Act (EHSRMA).
The areas covered included hazard identification and assessment, process safety information, standard operating procedures, site-wide safety procedures, training, maintenance, management of change, incident irivestigation, emeigency planning, detection and monitoring, and audits and inspections.
Using the checklist, SAIC interviewed various plant personnel to determine the status of the licensee's program in the different areas identified.
Although SAIC has not yet submitted a detailed trip report on the site visit (it is currently in preparation), it was possible to form some general
NOV 1 0 1993 l
Rober t C. Pierson 3
impressions.
First, the two strongest parts of the licensee's chemical safety program were the standard operating procedures and the emegency response p.ogram.
Second, there was a lack of formal documentation for several program elements including the hazard identification program, site-wide safety procedures, and incident investigation program.
Third, a set of design specifications for the facility was not generally available.
Finally, the hazard identification and assessment program concentrated on criticality issues rather than chemical safety issues.
At the exit meeting on October 21, 1993, SAIC and NRC discussed tceir findings with the licensee. CE expressed some concern over the potential effort required to meet the new chemical safety requirements and suggested that the regulatory impact might, in itself, have a negative impact on safety.
It was noted that, regardless of the criteria developed by NRC, CE will have to meet the requirements of OSHA's Process Safety Management regulations and EPA's Risk Management Program, when it becomes effective.
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' Richard Milstein Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS cc:
Mr. J. A. Rode, Plant Manager Hematite Nuclear Fuel Manufacturing Combustion Engineering, Inc.
P.O. Box 107 Hematite, MO 63047 Mr. J. F. Conant, Manager Nuclear Materials Licensing Combustion Engineering, Inc.
NOV 101993 Robert C. Pierson 3
impressions. First, the two strongest parts of the licensee's chemical safety program were the standard operating procedures and the emergency response program.
Second, there was a ack of formal documentation for several program elements including the hazard identification program, site-wide safety procedures, and incident investigation program. Third, a set of design specifications for the facility was not generally available.
Finally, the hazard identification and assessment program concentrated on criticality issues rather than chemical safety issues.
At the exit meeting on October 21, 1993, SAIC and NRC discussed their findings with the licensee.
CE expressed some concern over the potential effort required to meet the new chemical safety requirements and suggested that the regulatory impact might, in itself, have a negative impact on safety.
It was noted that, regardless of the criteria developed by NRC, CE will have to meet the requirements of OSHA's Process Safety Management regulations and EPA's Risk Management Program, when it becomes effective.
ViW Signed &f Richard Milstein Licensing Section 2 Licensing Branch Division of Fuel Cycle Safety and Sateguards, NMSS cc:
Mr. J. A. Rode, Plant Manager Hematite Nuclear Fuel Manufacturing Combustion Engineering, Inc.
P.O. Box 107 Hematite, MO 63047 Mr. J. F. Conant, Manager Nuclear aterials Licensing Combustion Engineering, Inc.
Distribution Docket 70-36 PDR/LPDR NRC File Center FCLB R/F FCLS2 R/F NMSS R/F FCSS R/F Region III Region III ETenEyck Madams HZibulsky 0FC FCLB E
FClg FCLB Af., I RMilsteh4 Ndarpe MTEr NAME 5
DATE 11//0 /93 11/\\ /93 11//o/93 C = COVER E = COVER & ENCLOSURE N = NO COPY G:\\HETRIP
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