ML20136H684

Insp Rept 70-1151/97-202 on 970210-14.Violations Noted. Major Areas Inspected:Chemical Safety Program at W & Selected Areas That Focused on High Risk Chemicals & Use of Chemicals

ML20136H684
Person / Time
Site:	Westinghouse
Issue date:	03/14/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20136H670	List: ML20136H666 ML20136H675 ML20136H684
References
70-1151-97-202, NUDOCS 9703190250
Download: ML20136H684 (10)

Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS I

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i Docket No.: 70-1151 l' License No.: SNM-1107 j Report No.: 70-1151/97-202 l Licensee: Westinghouse Electric Corporatio~n j Location: P.O. Drawer R Columbia, SC 29250

. Dates: February 10 - 14, 1997 i i Inspectors: Garrett Smith, Inspector, NRC Headquarters Approved By: Philip Ting, Chief Operations Branch j Division of Fuel Cycle Safety 1 and Safeguards, NMSS 9703190250 970314 PDR ADOCK 07001151 C PDR -s

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EXECUTIVE

SUMMARY

WESTINGHOUSE ELECTRIC CORPORATION NRC INSPECTION REPORT 70-1151/97-202 1.0 Inspection Summary Areas Inspected NRC performed a routine, unannounced chemical safety inspection of the Westinghouse Electric Corporation Columbia Fuel Fabrication Facility (CFFF) in Columbia, SC on February 10 - 14, 1997. The focus of this inspection was on the chemical safety program at Westinghouse and selected areas that focused on the high risk chemicals and their use. During the entrance meeting, the inspector asked CFFF engineers and management to identify what they viewed as the highest risk chemicals. Their response was anhydrous ammonia (AA) [an l Occupational Safety and Health Administration (OSHA) Process Safety Management (PSM) covered chemical], Uranium Hexafluoride (UF6 ), and Ilydrofluoric Acid (HF),

i Major programmatic portions of the chemical safety program which were reviewed at CFFF included:

Audits and Inspections Chemical Training Emergency Procedures Results The material condition of the Westinghouse facility during the inspection was excellent. Areas where chemicals are used are kept clean and uncluttered.

The inspector found an apparent deviation from of OSHA and National Electric Code (NEC) requirements with respect to work space clearance in front of live electrical panels, and the licensee agreed to evaluate the condition and determine whether any corrective action was required.

CFFF management and regulatory engineers have developed an extensive and comprehensive chemical safety training program. The effort, and

resources that CFFF has devoted to chemical safety training is commendable. The realism associated with the emergency drills provides the emergency team with excellent experience in responding to potential events.

The Site Emergency Plan is an excellent document that provides clear and concise guidance for emergency responders.

The licensee does not have their emergency procedures approved by management, specifically the Regulatory Component Manager, prior to issuance, as required by the approved License Application.

The Process Safety Management Compliance Audits Program is adequate to meet the license requirements.

DETAILS 2.0 General Plant Tour and Information

a. Scope The inspector toured the facility, concentrating on the ammonium diuranate (ADU) production area (including the UF6 vaporizer bay), the bulk chemical storage area, and the safe geometry dissolver area. The purpose of the tour was to observe plant operations and to review the areas where the higher risk chemical hazards (HF, liquid UF6 , and AA) are stored and used.

b. Observations and Findines The inspector noted that general plant conditions were excellent. The chemical operations areas were uncluttered, and dikes in the bulk chemical storage area were clean and clear. Safety showers were available, and the units located outside were slowly dripping water to prevent freezing of the water lines.

During the tour of the vaporization bay, the inspector noticed that electrical panels along the north wall had signs requiring 36 inches of working space in front of the panels. The inspector measured the actual working space and determined that in some places as little as 22 inches of

4 space existed. As part of the tour, the inspector discussed this information with several plant personnel. The area foreman, the electrical foreman, and an electrician who is regularly assigned to this area all stated that there is enough room to work in the area, when required.

During the exit meeting, licensee management agreed to evaluate and document what OSHA and NEC requirements apply to this area and determine the status of their compliance to those requirements. Based on that evaluation, a determination would be made as to whether any safety concerns existed, and what, if any, corrective actions would be taken.

' NRC is opening Inspector Follow-up Item 97-202-01 to review this documentation during a future' inspection.

c. Conclusions The material condition of the Westinghouse facility during the inspection was excellent. Areas where chemicals are used are kept clean and uncluttered.'

The inspector found an apparent deviation from of OSHA and National Electric Code (NEC) requirements with respect to work space clearance in front oflive electrical panels. The licensee agreed to evaluate the condition and determine whether any corrective action was required.

3.0 Chemical Safety Trainine (88061)

a. Scope The inspector reviewed the facility's training program, including how operations personnel and emergency responders are trained with respect to chemical safety.

b. Observations and Findings CFFF operations personnel are required to undergo extensive training.

Specifically, Procedure CA-006, " Columbia Plant Training Policy,"

requires that manufacturing personnel receive training for applicable health, safety, safeguards, and regulatory aspects of their job.

Additionally, the chemical area Regulatory Training Manual contains chemical safety information that is presented to the conversion personnel as part of their training. Topics include safety equipment, such as safety showers and personnel protective equipment, and general emergency response criteria for plant personnel, i

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l 2 j The inspector also reviewed the AA Converter training guide. The guide I

provides an excellent source ofinformation to train operations personnel. I j It contains a combination of actual photographs of the converter and written training information. The safety / regulatory section of the manual I discussed the hazards of the ammonia, the safe handling of spills, the i Materials Safety Data Sheet (MSDS) for AA, and personnel protective

{ equipment requirements. Furthermore, the manual addressed and showed 4

actual photographs of the engineered safety devices that are relied on for safety in the AA system.

During the last 7 months, the CFFF regulatory function has sponsored i training of operations personnel, by offsite companies, on the chemical y hazards associated with HF and AA. The training included specific

response requirements needed to mitigate personnel exposure to those i chemicals. Also, specific attention was given to the delayed health effects i of HF, including the fact that clinical signs and symptoms of HF exposure j at low concentrations may be delayed as long as 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

i In addition to the operations training, plant emergency responders received additional training to better equip them to respond to potential

plant emergencies. Section 3 of the Site Emergency Plan outlines specific response requirements for postulated releases of hazardous material and

! toxic fumes, and the emergency responders have received appropriate l training to effectively respond to these chemical accident situations. As

! part of that training, the regulatory engineers developed comprehensive 4

emergency response drills to simulate massive nitric acid and AA line a breaks. These drills included props modeled to resemble actual plant

[ chemical piping systems, and the responders were required to shut down

[ the system to stop the leaks (line breaks). Additionally, the emergency responders have received offsite training in structural firefighting.

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c. Conclusions i.

CFFF management and regulatory engineers have developed an extensive and comprehensive chemical safety training program. _ The effort, and j resources that CFFF has devoted to chemical safety training is e commendable. The realism associated with the emergency drills provides the emergency team with excellent experience in responding to potential events.

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4.0 Emercency Procedures (88064)  !

a. Scope j i

i The licensee's emergency plan and procedures were reviewed to ensure l l that adequate guidance has been developed to address the likely chemical i hazards found onsite, and to maintain a state of readiness to deal with those eventualities, l

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b. Observations and Findings l The Inspector reviewed the facilities Site Emergency Plan, Hazardous Material Emergency Response and Best Management Practices (BMP)

Plan, and Emergency Procedures to verify that adequate guidance was provided for contending with emergency situations involving the high risk j chemical safety concerns identified by the licensee (UF 6

, AA, HF).

Section 3 of the NRC approved Emergency Plan discussed postulated accidents that were deemed credible at CFFF and provided response procedures for releases of UF6 , hazardous materials or toxic fumes.

Additionally, several Emergency Procedures delineated the specific

responsibilities for all levels of emergency responders. These Emergency

, Procedures provided a clear and concise checklist to help all levels of emergency responders quickly oversee all aspects of the emergency. In general, the procedures are set up in four sections. The first section prompts the responders to communicate, evacuate, and evaluate the emergency. This section allows CFFF responders to evacuate personnel out of the effected areas, muster the appropriate response personnel, and evaluate the extent of the emergency. The next section allows for requesting offsite assistance, if needed, classification of the event, and notification of offsite agencies (including NRC). Then, the emergency procedures provide guidance to respond to and control the event. Finally, the procedures prompt the responders to terminate the event after all cleanup and recovery actions are completed and then draft and submit an incident report to the appropriate regulatory agencies.

Section 3.4.1 of the License Application (LA) defines Category-1 procedures as procedures for use by the Regulatory Component that are also prepared by the Regulatory Component. Additionally, this section defines Category-2 procedures as procedures for use by individuals outside of the Regulatory Component but are still prepared by the

. Regulatory Component. Emergency Procedures are written and prepared

{- for issuance by the regulatory component and they are either used by the l regulatory component or by individuals outside the regulatory component, l depending on the specific procedure. Clearly, Emergency Procedures are either Category-1 or Category-2 procedures, depending on the end user of

the procedure. Additionally, the LA states that both Category-1 and l . Category-2 procedures will be reviewed and approved for issuing by the cognizant Regulatory Component Manager.

Contrary to this, the inspector noted that as of February 14,1997, 4

Emergency Procedures are modified by a regulatory engineer then issued for use. After several procedures have been issued, they are grouped

, together for the appropriate management approval (including the i

cognizant Regulatory Component Manager). CFFF engineers and managers indicated that the practice of issuing Emergency Procedures prior to management approval had been ongoing and that it was not recognized that the license required management approval of the 2

Emergency Procedures prior to issuance. The failure to have the 4 emergency procedures approved by the regulatory component manager j prior to issuance is Violation 97-202-01.

The NRC approved Site Emergency Plan, Section 7.5, " Review and j Updating of the Plan and Procedures," states that the Emergency

Procedures will become effective once they are approved by the j Emergency Director. This practice appears to conflict with the level of management approval specified in Section 3.4.1 of the LA and has been i brought to the attention of the NRC Project Manager and licensee

management for resolution. The resolution of this item will be tracked as

Inspector Follow-up Item 97-202-02.

. The inspector also reviewed the procedures that discussed NRC

. notification required per 10 CFR Parts 20.2202,70.22, and 70.50.

Emergency Procedure A-06, " Notifications," and Procedure RA-107, l " Internal Reporting and NRC Notification of Unusual Occurrences" i document the facilities reporting requirements. The inspector noted that L the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reporting requirements defined in 10 CFR 20.2202(b) were

! not referenced in either procedure. The licensee concurred with this observation and agreed to update the appropriate. procedure to include

' this requirement. This item will be tracked as Inspector Follow-up Item 97-202-03.

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c. Conclusions The Site Emergency Plan is an excellent document that provides clear and concise guidance Ihr emergency responders.

3 The licensee does not have their emergency procedures approved by I

] management, specifically the regulatory component manager, prior to issuance.

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5.0 Audits and Inspections (88066) ,

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j. a. Scone 1 l To review CFFFs PSM audits as defined in Procedure SYS-111, l j- " Chemical Sar ety Program Definition." l i i l b. Observations and Findines l

Chapter 7 of the NRC approved License Application states that the  ;

purpose of the Chemical Safety Program at the CFFF will be to minimize  !

the risk of exposure of workers or members of the general public to

{ hazardous chemicals -- in particular, those that contain or involve licensed

material. The program will at a minimum ensure that all processes and

operations comply with applicable federal and state regulations pertaining

to chemical safety. CFFF has issued Procedure SYS-111 to implement this program.

1 AA is the only chemical at CFFF that is stored or used at or above the a specified threshold quantities. Therefore, it is a " covered chemical" under the requirements of 29 CFR 1910.119.

The inspections, audits, and appraisals program element of SYS-111

requires CFFF to evaluate compliance with OSHA PSM requirements at least every 3 years to verify that the procedures and practices developed are adequate and are being followed. To implement this requirement,

] CFFF has established Procedure RA-112. " Process Safety Management Compliance Audits."

I This procedure provides guidance for the audit team members to ensure the audits meet the requirements of the standard.

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During 1993 CFFF completed the Process Hazard Analysis (PHA) for the AA System. During May 1996, the licensee completed a ]

comprehensive audit of AA System to ensure compliance with applicable federal and state regulations and procedure RA-112. This audit was completed by a team of qualified auditors from corporate and site l personnel that are knowledgeable in the process.

This audit identified four minor recommendations to improve the  ;

chemical safety program for AA. Responsibility to close these items has l been assigned and their closure is being tracked in the Safety Margin Improvement Tracking Program.

c. Conclusions i J

The Process Safety Management Compliance Audits Program is adequate to meet the license requirements.

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! 4 MANAGEMENT MEETINGS

- Exit Meetine Summary

, inspectors met with CFFF management throughout the inspection. An exit meeting was held on February 14,1997. No classified or proprietary information was identified. The following is a partial list of exit meeting attendees:

Westinnhouse Electric Corporation Wilbur Goodwin, Regulatory Affairs Manager

Bob Williams, Regulatory Affairs

! Jim Heath, Regulatory Engineering Affairs Manager l Nancy Parr, Chemical Process Engineering Manager i

3 LIST OF ACRONYMS USED CFFF Columbia Fuel Fabrication Facility OSHA Occupational Safety and Health Administration AA Anhydrous Ammonia

- UF. Uranium Hexafluoride -

HF Hydrofluoric Acid PSM Process Safety Management NEC National Electric Code '

ADU Ammonium Diuranate MSDS Materials Safety Data Sheet LA Licensee Application BMP Best Management Practices PHA Process Hazard Analysis

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