ML20154R728
| ML20154R728 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 09/26/1988 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| NUDOCS 8810040340 | |
| Download: ML20154R728 (2) | |
Text
.
- 4 SEP 2 61933 Docket. No. 70-1100 Combustion Engineering, Inc.
ATIN: Dr. P. L. McGill Vice President - Nuclear Fuel Manufacturing Nuclear Power Systems 1000 Prospect Hill Road Windsor, Connecticut 06095-0500 Gentlemen:
Subject:
Inspection No. 70-1100/86-M This refers to your letter dated '
1938, in response to our letter dated January 21, 1987.
Thank you for informing us of t'.
ective and preventive actions documented in your letter concerning the observations and recommendations made during the Operational Safety Review.
These actions will be examined during future inspections of your licensed program Your cooperation with us is appreciated.
Sincere 1',
O I'In3I SI8"Cd OYI p;na'd R. Detamy Stewart D. Ebneter Director Divisior, of Radiation Safety and Safeguards CC:
A. E. Scherer, Director, Nuclear Licensing C. B. Brintean, Manager, Washington Nuclear Operations Public Document Room (PDR) local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
State of Connecticut es 1
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l OFFICIAL RECORD COPY RL CE $6 C001.0.0 l
09/21/83 1
SEP 2 61938 bec:
Region I Docket Room (w/ concurrences)
Robert J. Bores, DRSS J. Roth, DRSS G. Bidinger, AMSS t
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0FFICIAL RECORO COPY RL CE 86 0001.1.0 09/21/88 i
n
's SOMBUSTION ENGINEERING May 27,1988 LD-88-036 Docket No. 70-1100 License No. SNM-1067 Mr. William T. Russell Regional Administrator U.S. Nuclear Regulatory Commission Region !
475 Allendale Road King of Prussia, PA,19406
Subject:
Inspection Report No. 70-1100/86-04
Reference:
Letter. T. T. Martin (NRC) to 11. V. Lichtenburger (C-E), January 21, 1987
Dear Mr. Russell:
This letter provides Combustion Engineering's responses to observations and recommendations made by NRC staff members as a result of an Operational Safety Review of the Windsor Fuel Fabrication Facility fmm August 18-21,1986 (Reference).
The Attachment to this letter contains information related to the action that has been, is being or will be taken regarding each observation and recommendation.
In each of our responses we have attempted to address the NRC staff's concern, as we understood it.
If there are any cases where your review determines that we have not fully addressed the observations and/or recommendations, then we would like to request a meeting where we can receive and provide additional clarification.
We where confident that, with the benefit of a better understanding of the basis for the concern, that each remaining issue can be quickly resolved.
Power Systems 1000 Proscect H s Road (203) E481911 Comtoston Ergneenng. Inc Post 0"ce Box 500 Tetex 932'37 Wnosor. Connectcut C6095-0500 Y~D i ~-f
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Mr. William T. Ru:::ll LD-88-036 May 27,1988 Page 2 If such a meeting is determined to be desirable, please feel free to contact me or Mr. C. M. Molnar of my staff at (203) 285-5205.
Very truly yours, COMBUSTION ENGINEERING. INC.
Y /'14/Af/
A. 5 cherer Director Nuclear Licensing AES:ss
Attachment:
As Stated xc: J. Roth (NRC)
G. Bidinger (NRC) l i
l
Atttchn nt LD-88-036 pago 1 of 23 Resoonses to NRC Ooerational Safety Review Observations Chemical. Exolosion. and Fire Safety 3.a.1.a - Observatient The Review Team did not identify a chemical, explosion or fire hazard associated with facility operations that could result in a significant impact on public health and safety. However, a minor impact on public health and safety could occur from a fire involving uranium oxide powder, or an explosion of the anhydrous ammonia tanks on site, with or without the involvement of uranium oxide powder.
Essponse:
The following response is offered in two parts: fire involving uranium oxide powdot, and explosion of the anhydrous ammonia tanks.
The consequences of a fire inside the Building 17 facility involving uranium oxide powder or stored fuel rods were evaluated as Class 3 accidents.
The maximum consequences for the events analyzgd resulted in 0.014% and 0.000013% of the derived standards for lung and bone at the nearest residence to the Windsor Site, respectively.
A fire outside of the facility involving uranium oxide powder would have even less of an impact since the uranium oxide powder resides only in NRC approved UNC-2901 or CE-250-2 protective shipping containers.
These protective shipging containers are designed to withstand a temperature of 1475 F for 30 minutes.
Furthermore, the shipping containers are only outside, on the shipping pad, on an interim basis during loading and unloading operations.
At other times, they are either inside Building 17 or inside the shipping trailer.
I The employees and management of the Windsor Fuel Fabrication Facility recognize the hazards associated with the use and storage of anhydrous ammonia and controls are in place to minimize the hazard potential.
These controls have been subject to periodic review and inspection by personnel from American Nuclear Insurers and the Fire Marshall of the Town of Windsor.
The tanks are surrounded by Jersey barriers and a chain link fence to minimize danger from collision and missiles.
The tanks have relief valves which are replaced annually to ensure that they are in working order. The tanks and piping are inspected and painted at regular intervals.
A compretensive preventive maintenance system, which will include the anhydrous ammonia storage system, is currently being developed with implementation expected by the fourth quarter of 1988.
Reference:
AttcchaOnt LD-88-036 Pago 2 of 23 Postulated accidents for the system include leaks and small scale rupture of a tank seam.
These events pose a minimal risk to the general public.
The neareast residence is approximately one half mile from the Windsor Site and it is expected that dilution of released ammonia would minimize the health hazard.
Furthermore, ammonia is non-flammable which further reducea the l
consequences of postulated ammonia leaks and it is only a moderate explosion hazard when exposed to flame.
It is unlikely that the uranium oxide would become involved in any scenario involving ammonia leakage since it is in protective L
shipping containers which are only located outside, on the shipping pad, for a short time as discussed above.
The shipping pad is at least 25 feet from the anhydrous ammonia 1
storage tanks to minimize the potential for any interaction.
4
- 3. a.1. b - Observatien t t
There does appear to be a potential for a significant impact on 1
workers in the manufacturing facility (Building 17), and in other facilities on the Windsor Site, from the hazards i
indicated la (1)(a) above.
i Resnonset 1
]
Based on the discussion addressing observation 3.a.l.a, there does not appear to be any significant radiological impact on j
workers onsite from uranium oxide located outside of Building 17.
As discussed, the uranium oxide located outside i
of the facility is stored in NRC approved shipping containers on an interim basis.
These protective containers provide an r
appropriate level of protection from potential fire hazards.
]
The impact of anhydrous ammonia tank leaks or small scale seam I
ruptures would be localized since anhydrous ammonia vaporizes at atmospheric conditions and diffuses rapidly.
In addition, a smoke test was performed on a day when the wind direction was
,l toward Building 17, indicated that the corner of Building 17
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acted to shear the wind flow, thereby, precluding the smoke from being drawn into the building via the ventilation system l
1 which is located on the roof.
From this test it was concluded that the likelihood of ammonia vapor being drawn into Building 17 was negligible.
As such, Building 17 personnel would be directed to stay indoors in the event of an ammonia leak.
Suf ficient control of pedestrian and automobile traf fic can be I
established by facility security personnel to preclude entry
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i into the area should an incident involving the ammonia storage l
tanks occur i
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Attcchacnt LD-88-036 Pega 3 of 23
- 3. a.1. c - observatien t The anhydrous ammonia tanks, adjacent to Building 17, appear to be the largest single source of toxic chemicals on the Windsor t
Site.
They are also in close proximity to radioactive material (uranium oxide powder) and pyrophoric material (zircalloy chips).
t Resoonset Nuclear Fuel's management understands that three hazardous materials (anhydrous ammonia, uranium oxide and zircalloy machining waste) are stored in the same general area at the back of the facility.
Each of these materials has its own i
special handling and storage requirenants and precautions are taken to ensure adequate separation of the three materials in order to minimize any potential interaction..
In that vain, the anhydrous ammonia tanks are surrounded by Jersey barriers and a chain link fence, the uranium oxide in the area is always in NRC approved UNC-2901 or CE-250-2 protective shipping containers (which are outside on the shipping pad for only 4
short periods) and the zircalloy machining waste is sealed in I
55 gallon drums.
A physical separation of at least twenty five (25) feet with a minimum of intervening combustibles is maintained at all times between these materials, including during shipping operations. The UNC-2901 or CE-250-2 protective i
shipging containers can withstand sustained temperatures of 1475 P for at least 30 minutes.
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3.a.1.d - Observationt l
The storage of zircalloy machining wastes (svarf and turnings) near Building 17 is a significant fire hazard in close l
proximity to radioactive materials (uranium oxide powder).
j Responset 1
l The aircalloy machining waste stored at the back of the i
Building 17 facility is not of a small particle size (powder),
rather, it is for the most part better characterized as turnings.
As such, it does not represent an explosive hazard.
As mentioned in Observations 3.a.1.a and 3.a.1.c, a physical separation of at least 25 feet is maintained between this material and the uranium oxide powder and anhydrous ammonia stored in the area to minimize the potential for the spread of l
I fire should one occur.
Nevertheless, an evaluation of the fire hazard associated with storage of the zircalloy machining wante l
in its present configuration will be undertaken.
This l
evaluation will be completed by the fourth quarter of 1988.
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Attcchm nt t
l LD-88-036 l
Pcg3 4 of 23 l
- 3. a.1. e - Obse rvat ion t There are no procedures for the control of flammable and combustibic materials used in Building 17.
Rcseonngl Flammable waste materials are minimized in the Building 17 facility by dispocal on a daily basis.
Flammable liquids used in the manufacturing process are stored in 55 gallon drums away from the main f9eility and are properly vented.
Such liquids are diopensed stom grounded drums into grounded receptacle containers.
All in-shop storage / dispensing containers for flammable liquids are of an approved type.
Fire resistant cabinets, properly grounded and vented, are strategically located throughout the facility for interim storage of these materials as necessary for use in the manufacturing process.
Nevertheless, procedures which formally address the above practices will be written and incorporated into a facility industrial safety pecgram.
These procedures wi)1 be completed by the second quarter of 1989,
- 3. a.1. f
_ observat ien t Fixed fire extinguishing system sprinkler heads in the Building 17 Pellet Shop are not installed to NFPA-13 standards.
Resoonset The discrepancies identified dealt with obstructions to the sprinkler heads.
These obstructions have been removed.
Quarterly audito are being performed to verify that the system remains unobstructed.
14a.1.c - Observatien t Portable fire extinguisherc in Building 17 are not easily accessible or strategically 1ccated.
EtsponsA1 A reassessment of portable firo extinguisher locations was performed by fccility persor.nel and reviewed by the Site Fire Marshall.
This reausessment included consideration of fire type, extinguisher type, and extinguisher location consistent with the area fire potential.
As a consequence of this reassessment, fire extinguishers have been relocated, where necessary, and extinguisher locations have been marked with color codings and signs to make them easily identifiable.
t Attcchm:nt j
Pcgo 5 of 23 l
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3.a.1.h - observationt i
1 An incorrect emergency telephone extension numb 6r was posted in L
i the zircalloy machining area of Building 17.
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j Responset The emergency telephono number has been changed to 5555. This l
number is the site security office which is manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
All emergency telephone postings have been changed and i
are consistent with the 5555 extension.
l 2a.1.1 - observAtient
)
Zircallo during.y machining wastes are retained in large containers l
j achining operations, at the machining site.
l 1
Responsti, i
Zircalloy machiring waste is initially stored in 30 gallon I
containers with sufficient water such that the waste material is covered. This method of storage is consistent with that i
recossended on the Material safety Data Sheet for airca*loy.
i These proceduros provide an appropriate level of control for j
j the safe handling and storage of zircalloy machining waste at j
1 the machining site.
Removal from the 30 gallon containers l
generally occurs at least once per day.
l j
3.a.i.i - Observatient j
The Windsor Site ftre brigade was disbanded in 1982.
i f
1 Responsit, i
b Combustion Engineering dettralr.ad in 1982 that disbcnding the fire brigade would have no significant impact on facility fira 4
preparedness.
Bailding 17 is constructed and arranged such j
that there is a minimal amount of combustible material in the i
production area.
The facility also includes a functional i
]
sprinkler system.
Minor firer. can be combatted by facility j
personnel and most Building 17 personnel have received fire I
)
fighting training conducted with the assistance and active f
participation of the Fire Marshall of the town of Windsor.
The
(
I
)
training included proper use of various fire extingaishers, familiarization with the four classsa of fires, and proper i
i response to each class of fire.
This training will be repeated
[
j annually for Building 17 personnel.
2' t
j Protection from larger fires is provided by the Toun of Windsor j
Fire Department.
Since the start of operations some 20 years I
ago, it has never been necessary to call on the Windsor Fire j
Department or the Combuntion Engineering fire brigade (when in
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~
Attcchm:nt i
Pogo 6 of 23 l
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existence) for assistance.
The Windsor Fire Department has, i
however, cuoperated fully in preparing itself in case of a fire J
onsite.
The department hos participated in onsite seminars with other offsite groups in discussing site emergency contingencies.
The department has been provided a detailed list of onsite hazards, including types and locations of l
hazardous materials.
The department understands the hazards as demonstrated by periodic inspection of the facility by the Town of Windsor Fire Marshall.
The department is equipped and trained to meet a wide variety of fire scenarlow, including 1
those which involve hazardous material.
Given the level of j
readiners and training of the Windsor Fire Department, Combustion Engineering believes that adoquate ceasures have J
been taken with respect to the threat of a fire at the Windsor 4
facility.
3.a. tak - observation Generally, explosiva gas cylinders are not protected from i
expocure to the elements on the Windsor Site.
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Reseonsg1 I
The only explosive gas used in the Building 17 is hydrogen.
t l
These cylinders are stored in an enclosed facility which
{
provides protection from the elementa.
Other gas cylinders are i
outside the Building 17 boundary and are under the control of i
7 the Manager of Site Facilities / Maintenance.
These cylinders i
are located approximately 100 yards from the Building 17 and pose no threat to ths health and safe *y of personnel in the j
i j
facility n: to the operation of the tacility, j
3.a.1.1 - Observatient
{
\\
j Generally, outside storago areas foc hazardous liquid materials i
do not provide for confinement of spillage or leakage on the l
Windsor Site, j
Besconset I
r The following hazardous liquids are currently stored at l
I Building 174 spent acid aclutions, perchlorethylene remnants, and alcohol.
All of these solutions' containers are stored I
within berms which provide for confinement of the material in l
the event of spillage or leakage.
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AttCchment LD-88-036 PCg3 7 of 23 j
Industrial and Radiolocical Safety
- 3. a. 2. a_ - ol;ute rvat ioni_
Specific industrial safety policy / procedures do not exist (except for toxic wastes) and requirements are not included in manufacturing operations.proceduros.
Resoqqtti The need for broadening the facility's industrial safety procedures is recognized.
Manufacturing operttions and travelers are being reviewed and upgraded as a part of a more comprahensive safety program.
Implementation of tnis program is expected by the first quartir of 1989.
La.2.b - ohp rvatient Tho ambient temperature in the Building 17 Pellet Shop is excessively high.
Rednonnet An inspection of the ventilation system was conducted subsequent to the NRC inspection, and specific discrepancies were identified and corrected, resulting in a decrease in ambient temperature in Building 17. The ventilation system in the Pellet Shop was also recently modified, resulting in a further reduction of the a'tbient temperatures.
- Finally, periodic logs of ambient temperatures throughout Building 17 are now being maintained to monitor ambient temperature trends, i
tiousekeening i
3.a.3.a - observatient F
Generally, housekeeping in the Building 17 Pell.gt Shop, Pellet
[
Shop Annex, Cold Shop Mezzanine, and Building 2 High Bay areas vas inadequate in that larg6 quantities of combustible trash and spilled paint was allowed to accumulate, and there vore oil l
leaks in the hydraulic systems of the pellet presses.
l Responggi Housekeeping practices have been improved in the Building 17 Pellet Shop, the Building 5 High Bay, and Pellet Shop Annex.
Storage of combustible trash in these areas is minimized and is j
- It is not clear whether the inspection report is referring to the Building 5 High Bay area or ar.other area in Building 2.
The response assumes that the Building S High Bay is what was meant in the inspection report.
(
Attcchmsnt LD-88-036 Pags 8 of 23 aqw removed as necessary so as not to create a fire hazard.
Contaminated solid waste is packaged and held (outside the facility) until a sufficient quantity is acquired to remove from the site in proper contaminated waste disposal shipping containers.
Spill pans, used to collect hydraulic fluid leakage from process equipment, are emptied when half full.
The Building 17 Cold Shop Mezzanine is much improved, but is still used as an interim storage area.
Increased attention by facility supervisory personnel insures that material is stored in the Cold Shop Mezzanine in a safe and orderly manner.
The existence of a sprinkler system and rate-of-rise heat detectors also decreases the likelihood of a fire hazard in this area.
In addition, an assessment of the adequacy of fire detection sensors in these areas will be conducted and new sensors will be installed, as appropriate.
This assessment will be completed by the first quarter of 1989.
Audits and Reviews 3.a.4.a - Observation:
No independent audits are conducted to assure that equipment tests required by the NRC license are completed.
Response
A review of the license was performed by facility management in order to identify equipment tests which fall into this category. Only one such test (the fire door to the virgin powder storage area) was identified.
This fire door has an automatic closing feature wh'ch is now verified quarterly to be capable of performing its intended function.
The test is performed by Maintenance department personnel using a test procedure which requires that Health Physics and Safety personnel witness the test and sign the test results.
A permanent record of the test results is maintained on file.
Since the test is witnessed and signed by personnel independent of the Maintenance Department, Combustion Engineering believes that this accomplishes the same purpose as an audit.
- 3. a. /. b - Observation _:
Administrative controls for criticality safety, other than posted signs and floor markings, are not routinely reviewed during nuclear safety audits.
Rosconset, An annual audit is performed by a consultant to the Nuclear Safety Committee.
Administrative controls are part of this review.
Attcchm:nt LD-88-036 Pcg3 9 of 23 3.a.4.c - Observation:
No independent review or audit program has been established for Health Physics, Industrial Safety or the implementation of the Radiological Contingency Plan.
Resoonse:
Health Physics audits are conducted annually by a consultant to the Nuclear Safety Committee.
Independent review of the Industrial Safety Plan and Radiological Cc.;3ingency Plan are performed by various insurance organizations which hold policies that involve the Windsor site and its facilities.
Inspection / Tests / Maintenance Activities 3.a.5.a - Observation:
There is no apparent routine inspection and/or preventive maintenance program established for the anhydrous ammonia storage tanks and equipment, the ammonia disassociators and equipment, and process equipment located in Building 17.
ResDonse A comprehensive preventive ma'ntenance system is currently being established and is expe.ted t,be fully implemented by the fourth quarter of 1988.
This system will include the components described above.
Aspects of the system have already been implemented on the anhydrous ammonia tanks, the spent acid tanks and nitrogen tank. (See response to Observation 3.a.l.a for related information.)
3.a.5.b - Observation:
Neither of the anhydrous ammonia storage tanks, which are located outside and exposed to the elements, were grounded.
ResDonse Grounding cables have been installed on both anhydrous ammonia storage tanks.
Attnchmsnt LD-88-036 Pags 10 of 23 3.a.5.c - Observation:
Tests for the operability of the preaction valve on the dry fire sprinkler system and the rate-of-rise heat detectors in the manufacturing areas are not conducted.
Resoonse:
operability testing is now performed as follows:
Dry fire sprinkler preaction valve: annually Rate-of-rise heat detector: semi-annually Equipment trips asseciated with rate-of-rise heat detector, annually The above tests are performed by the site Maintenance Department. A permanent record of the test results is maintained on file.
Personnel Trainina 3.a.6.a - Observation:
Only Health and Safety personnel in Building 17 are given training in fire fighting.
There is a general prohibition against other personnel using even a portable fire extinguisher.
Resconse:
There is no general prohiiition against fire fighting.
Employees are, however, d.rected not to attempt to fight large fires not readily handled by fire extinguishers.
Most Building l
17 personnel have received fire fighting training conducted I
with the assistance and active participation of the Fire l
Marshall of the Town of Windsor. The training included proper use of various fire extinguishers, familiarization with the four classes of fires, and proper response to each class of fire.
This training will be repeated annually for Building 17 personnel.
(Refer to the response to Observation 3.a.l.j for further discussion of site fire preparedness.)
3.a.6.b - observation:
Generally, workers involved in the manufacturing process were not aware of the location of manufacturing operations procedures.
ResDonse:
Training on manufacturing procedures and their location had been given to all employees.
Retraining of all personnel, however, has since been conducted.
9 Attachm0nt LD-88-036 Pago 11 of 23 Emeraency Plannina 3.a.7.a - Observation:
Limited capability exists for obtaining immediate
- meteorological information at the Hindsor Site.
Response
Instrumentation for measuring both wind direction and wind speed is currently installed on the roof of Building 17.
More detailed information is available from National Weather Service personnel at the Bradley International Airport which is located approximately five (5) miles from the Windsor site.
Similar weather instrumentation will be installed on the Building 4 i
roof when that building is designated as an alternate Emergency control Center (ECC). (See response to observation 3.a.7.b.)
i 3.a.7.b - Observation:
The Emergency Control Center (ECC) is small, is equipped with only one telephone line and there is no alternate ECC designated.
l Ersponse:
)
Combustion Engineering intends to designate a facility existing in Building 4 as an alternate ECC for use in managing emergencies at Building 17.
This facility was designed to assist utilities who operate Combustion Engineering supplied Nuclear Steam Supply Systems in evaluating and mitigating the consequences of plant problems.
The Building 4 facility is larger, and much better equipped than the existing Building 6 facility.
Building 4 will be designated the alternate ECC with Building 6 as the primary ECC to be used during the initial phase of an emergency.
Long term emergency management would be accomplished from Building 4.
Dssignation of Building 4 as an alternate ECC will be accomplished by the first quarter of 1989.
3.a.7.c - observation:
The Emergency Action Levels and Classification schemes specified in the Radiological contingency Plan are not consistent with the emergency classifications used by the NRC and the Stcte of Connecticut.
Response
The Combustion Engineering Radiologiccl Contingency Plan uses the same Emergency Action Level and Classification designations as the NRC.
The State of Connecticut designations are, however, not the same as those used by the NRC.
A matrix will be developed to cross reference the designations used by
Attrchm:nt LD-88-036 PCgo 12 of 23 Combustion Engineering, the NRC, and the State of Connecticut.
Copies of this matrix will be developed by the second quarter of 1989.
3.a.7.d - Observation:
There is no formal distribution of the radiological contingency plan to offsite authorities.
Ecsnonse:
Combustion Engineering does not distribute the facility Radiological Contingency Plan directly to offsite authorities since it deals only with onsite activities.
The Windsor Site Emergency Plan, which requires coordinated action with offsite authorities, is provided to the State of Connecticut Department of Civil Preparedness, which maintains the State Emergency Response Plan (including a Combustion Engineering Appendix).
The Windsor Site Emergency Plan incorporates the facility Radiological Contingency Plan in abbreviated form.
The State of Connecticut Department of Civil Preparedness has responsibility for distribution of the State Emergency Response Plan to the various offsite aupport groups which Combustion Engineering might call upon in an emergency.
In order to proclude confusion regarding applicable versions, combustion Engincoring does not independently distributa emergency plans to offsite groups.
3.a.7.e - Observation:
Some omorgency telephone numbers in the Radiological Contingency Plan and the Site Emergency Plan are incorrect or are not current.
Rosconse:
A list of emergency telephone numbers is now maintained separately from the sito omorgency plan and is updated on a monthly basis.
This list is promulgated to facility and site security, Windsor Fuel Fabrication Facility uppor managemunt, Product Development Facility management, Health and Safety Management, and the Emergency Control Contor.
3.a.7.f - Observation:
An exorcise of the overall Windsor Sito Emergency Plan has never been conducted.
Resnonser Exorcisos involving Building 17 personnel and security are conducted twice each year.
Exorcisos which would involvo the entire Windsor sito havo not been conducted because the
Attechncnt LD-88-036 Paga 13 of 23 consequences of postulated accidents at Building 17 are limited to personnel within the building.
Exposures to personnel outside of Building 17 are expected to be negligible.
To confirm this expectation, however, an evaluation of the postulated dose at the Building 17 boundary will be performed and it will include other areas situated within the Windsor Site Boundary, as appropriate.
This assessment will be completed by the first quarter of 1989.
3.a.7.c - Observation:
Security of emergency equipment lockers is not adequate to preclude equipment removal for non-emergency use.
Resconser Emergency equipment lockers are now secured with locking devices which are inspected daily by facility Health and Safety Personnel to verify that emergency equipment lockers have not been used for non-emergency use (i.e., locking devices are intact).
The locking devices can be easily broken away for access during an emergency.
An inventory of locker contents is conducted on a monthly basis by Health and Safety Personnel.
3.a.7.h - Observation:
There is no pre-printed incident description / documentation form available for use by emergency response personnel.
Resconset Pre-printed incident description / documentation forms are now available for use by emergency response personnel.
These forms are of a "fill in the blanks" style and are designed for various types of incidents.
3.a.7.1 - Observation:
Offsito support groups (police, fire, etc.), who are directly involvea in an emergency response, are not trained in or familiar with the contents of the Radiological contingency Plan and have not been provided with copies of the plan or the implementing procedures.
ResDonse:
Information is distributed as discussed in the response to Observation 3.a.7.d.
Furthor, Combustion Engineering gathors members of offsite support groups yearly for a seminar on omorgency planning for the Windsor Site.
At this seminar, "table top exercisos" are reviewed to familarize each group with the role it may be called upon to perform.
This allows all parties to understand the implementation of the Windsor i
q Attachmsnt LD-88-036 Paga 14 of 23 Site Emergency Plan. The seminar given to offsite support groups in 1987 included representatives from the Town of Windsor police and fire departments, the State Police, the State of Connecticut Office of Civil Preparedness, local hospital representatives, and representatives from the Combustion Engineering site medical and security staffs.
3.a.7.i - Observation:
Written letters of agreement are in place with local support groups with one exception.
Resconse:
A written letter of agreement with the one remaining support group (a hospital intended as an alternate source of medical care) is expected to be in place by the fourth quarter of 1988.
A letter of agreement with the primary source of medical care is on record.
3.a.7.k - Observation:
Qualification and training criteria for key emergency response personnel (Emergency Directors etc.) have not been established.
Resconset Shift personnel who may act as Emergency Directors receive training in evacuating facility personnel, reentering the facility, and other contacting facility management.
It is intended that other management proceed to the ECC and assist the Emergency Director in implementing further steps in the emergency plan.
Formal qualification and training acceptance criteria will be developed by the second quarter of 1989.
- 3. a. 7.1 - Observation :
Emergency drills do not routinely exercise site emergency response personnel in a variety of radiological or non-radiological accident scenarios that could have offsite impact, do not include the entire Windsor Site, nor do they include offsite support groups that would be expected to e
respond.
Resconse:
The Windsor Fuel Fabrication Facility conducto exercises on a semi-annual basis.
Since the responses are essentially the same, drills for fire (the most likely) and criticality (the most adverse) are combined in these exercises.
Onsite participation includes facility and security personnel.
Communication's links to offsite authorities are exercised during these drills.
As indicated in the response to i
Attachmtnt LD-88-036 Pago 15 of 23 Observation 3.a.7.1, "table top exercises" are conducted in a seminar type environment on a yearly basis with offsite support groups.
In the future, the NRC will be provided prior notice of the date of the drills and seminars so that they may attend if desired.
3.a.7.m - ObservC hit 11, Emergency drills and tests conducted at each of the facilities handling radioactive or nonradioactive hazardous materials are not designed to test all aspects of the emergency plans.
Resoonse This facility presently drills twice a year.
Since the responses are essentially the same, drills for fire (the most likely) and criticality (the most adverse) are combined in these exercises.
The drills address radiological aspects, communication, facility evacuation, and manning of the Emergencf Control Center.
Accident scenarios involving hazardous materials will be incorporated into the facility drills (for spill team members only) after training is completed for the handling of such materials.
This training is expected to be complete by the fourth quarter of 1988.
Nuclear Criticality Safety 3.a.8.a - Observation:
Out-of-use uranium oxide power blending hoppers were not adequately secured to preclude inadvertent use by operators.
Sasconse!
Metal loops have been welded to the hoppers and the hoppers are chained closed when not in use.
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3.a.8.b - Observation:
i Initial nuclear criticality safety analyses were not always sufficiently detailed to permit an independent review, nor does the independent reviewer document the basis for concurrence and the method of analysis used.
Resconse:
Greater detail is now being provided in the nuclear criticality safety analyses.
A formal statement by the independent reviewer has also been added to document the basis for concurrence and the method of analysis.
Further, a filing system has been implemented for these analyses which allows for improved accountability / record keeping.
Attcchm2nt LD-88-036 Paga 16 of 23 Resconses to NRC Operational Safety Review Recommendations Chemical. Exolosion. and Fire Safetv 3.b.1.a - Recommendation:
Evaluate (1) the impact of a fire involving uranium oxide powder and (2) a failure.of the anhydrous ammonia tanks, both with or without the involvement of uranium oxide powders, on the health and safety of the Windsor site workers and the general public.
Response
There is no expected adverse impact due to fire outside of the facility involving properly stored uranium oxide powder.
As discussed in the response to observation 3.a.l.a, uranium oxide powder located outside the facility is stored in NRC approved shipping containers only on an interim basis.
Furthermore, the shipging containers are designed to withstand a temperature of 1475 F for 30 minutes.
Combustion Engineering believes that adequate controls are in place to minimize the potential for credible incidents involving the anhydrous ammonia storage tanks as discussed in response to Observations 3.a.l.a, 3.a.l.b and 3.a.l.c.
Furthermore, catastrophic failure of the storage tanks is not believed to be a credible event.
As such, extraordinary procedures to deal with such an event are not considered to be necessary.
3.b.1.b - Recommendation:
Establish 3 program and implementing procedures for the control of flammable and combustible materials in Building 17, to include:
o storage of zircalloy machining wastes protection of cylinders containing explosive gases o
confinement methods for spilled hazardous liquids o
o dispensing of flammable liquids o
venting and grounding of flammable liquid storage lockers
Response
A flammable and combustible material control procedure will be developed and incorporated into a facility industrial safety program.
Although steps have already been taken to address some of the specific areas noted in the recommendation (see responses to observations 3.a.l.d, 3.a.l.e, 3.a.l.1, 3.a.l.k and 3.a.l.1), a complete review to assure the acceptability of present practices will be included as part of the procedure development effort.
The flammable and combustible material control procedures will be completed by the second quarter of 1989.
Attachm:nt LD-88-036 Page 17 of 23 3.b.1.c - Recommendation:
Establish a Fire Protection Program for Building 17, to include:
correction of the installation of sprinkler heads in o
fixed systems to make them in accordance with NFPA-13 standards placement of fire extinguishers in easily accessible o
and strategic locations installation of ionization or photoelectric smoke o
detectors daily collection and disposal of combustible trash, o
accumulated hydraulic fluids, and cleanup of spills Resconse:
As discussed in the responses to Observations 3.a.1.f, 3.a.1.g and 3.a.3.a), steps have already been taken to address some of the specific items noted in the recommendation.
Nevertheless, fire protection will be reviewed in conjunction with writing flammable and combustible material control procedures for inclusion as part of the facility industrial safety program.
This review will address appropriate actions necessary to minimize the risk of fire in Building 17.
This review will be completed by the second quarter of 1989.
Industrial and Radiation Safety 3.b.2.a - Recommendation:
Establish an Industrial Safety Program, to include:
specific industrial safety policies and procedures o
incorporation of industrial safety precautions in o
manufacturing operations procedures o
evaluation of the high ambient temperature in the Building 17, Pellet Shop and its effect on worker safety Resoonse:
The Combustion Engineering, Inc. industrial safety program will be reviewed for applicability to the activities conducted in Building 17.
A facility specific industrial safety program will be established to assure proper integration of various individual safety related elements.
This program will be completed by the second quarter of 1989.
Steps to address the ambient temperatures in the Pellet Shop have already been taken as discussed in responses to Observation 3.a.2.b.
Attcchm:nt LD-88-036 PCga 18 of 23 3.b.2.b - Recommendation:
Evaluate the adequacy of the Building 17 respirator fit test program.
Response
The respiratory protection. program was reviewed and a respirator qualitative fit test chamber has been installed.
All personnel who are designated to use respirators in accordance with guidance specified in NUREG-0041 and ANSI Z88.2-1980 have been fit tested and trained.
Housekeenina 3.b.3.a - Recommendation:
Establish a program and implementing procedures to assure adequate housekeeping in the guilding 17 manufacturing facilities and the Building 2 high bay area.
Resoonse:
While housekeeping practices have been irproved as discussed in response to observation 3.a.3.a, space is at a premium at the present time.
A program will be developed to assure that appropriate practices are followed in the day-to-day upkeep, storage and disposal of materials used to support shop operations.
As part of this program, a review will be conducted of the adequacy of present facility storage space and disposal practices relative to the amount of available storage and the acceptability of designated spaces for the types of materials being stored or discarded.
This effort will be completed before the fourth quarter of 1988.
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It is not clear whether the inspection report is referring to the Building 5 High Bay area or another area in Building 2.
The response assumes that the Building 5 High Bay is what was meant in the inspection report.
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Attachm0nt LD-88-036 Pag 2 19 of 23 Audits and Reviews 3.b.4.a - Recommendation:
Establish a program to assure that reviews and audits in the following areas are conducted by persons not associated with the operations (i.e., knowledgeable, but independent):
NRClicenserekuirementsandequipmenttests o
o health physics program industrial safety program o
implementation of the Radiological Contingency Plan o
Response
The specific areas noted in the recommendation were addressed in response to observations 3.a.4.a and 3.a. 4.c.
3.b.4.b.
- Recommendation:
Assure that all established administrative controls affecting nuclear criticality safety are reviewed during routine nuclear safety audits.
Resoonse:
Administrative controls affecting nuclear criticality safety are reviewed as part of the routine audits performed by the consultant to the Nuclear Safety Committee (see renponse to Observation 3.a.4.b).
Insoection/ Test / Maintenance Activities 3.a.5.a - Recommendation:
Establish an inspection / testing program and a preventive maintenance program for the anhydrous ammonia storage tanks and equipment, the ammonia disassociators and equiprent, the fire sprinkler systems, and other process equipment located in and around Building 17.
Resoonse:
A comprehensive preventive maintenance program, which will include inspection and testing, is currently being developed as discussed in response to observation 3.a.5.a.
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Attcchm:nt LD-88-036 Pago 20 of 23 3.b.5.5 - Recommendationt Provide the anhydrous ammonia storage tanks with electrical grounding protection.
Response
The enhydrous ammonia storage tanks have been grounded.
Personnel Trainina 3.b.6.a - Recommendationt Establish a fire fighting training program for facility persennel, other than Health Physics Technicians.
Ransonne:
As discussed in response to observations 3.a.1.j and 3.a.6.a.
fire fighting training has been provided to most Building 17 personnel.
3.b.6.b - Recommendation!
Instruct Building 17 manufacturing process workers on the content of operations procedures and their locations in the vicinity of the work stations.
Responses As discussed in the response to observation 3.a.6.b, training on manufacturing procedures and their location has been conducted.
Emeraency Plannina 3.b.7.a - Recommendationt Evaluate the Windsor site Emergency Control Center to determine whether it is properly sized to accommodate the required o
emergency response support staff an alternate Emergency Control Center is necessary o
o an adequate number of telephone lines is available
Response
As discussed in response to observation 3.a.7.b, an alternate Emergency Control Center (ECC) will be designated at an existing and much better equiped facility located in Building 4.
The Building 6 ECC will remain thea primary ECC for dealing with the initial phases of an emergency.
Attcchm nt LD-88-036 Paga 21 of 23 3.b.7.b - Recommendation:
Review the Radiological Contingency Plan to determine whether:
o the Emergency Action Levels and the Classification scheme need to be changed to be consistent with those used by the NRC and the State of Connecticut procedures for distribution of plan revisions are o
incorporated copies of the Plan are provided to off-site support o
groups written agreements have been executed with and are o
understood by all required off-site support groups I
qualification criteria for emergency response o
personnel have been established o
the assessment regarding a chemical accident i
involving anhydrous ammonia is still valid the telephone numbers listed on the emergency call-in o
and notification lists are checked periodically to assure they are accurate l
Resoonset Responses to the recommendations noted are discussed in response to the following observations 3.a.7.c, 3.a.7.d, 3.a.7.e, 3.a.7.1, 3.a.7.j and 3.a.7.k.
As indicated in response to Recommendation 3.b.l.a, catastrophic failure of the anhydrous ammonia storage tanks is not believed to be credible.
As such, a detailed assessment of the impact on Windsor site personnel and the general public does not appear to be warranted.
I t
3.b.7.c - Recommendation:
Provide training in the requirements of the Radiological Contingency Plan and its implementation tos l
site emergency response personnel, including o
Emergency Directors h
o off-site support groups l
i Resconse Training of personnel as noted in the recommendation was discussed in response to Observations 3.a.7.d, 3.a.7.1 and 3.a.7.k.
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LD-88-036 Pago 22 of 23 3.b.7.d - Recommendation:
Demonstrate through drills that:
the Windsci-Site Emergency Plan can be implemented o
for credible radiological ar.d non-radiological accident scenarios off-site suppoit groups can adequately respond to o
emergencies all aspects of the emergency plans and procedures are o
adequate
Response
Information related to the recommendation was discussed in response to observations 3.a.7.f, 3.a.7.1, 3.a.7.j, 3.a.7.1 and 3.a.7.m.
Nevertheless, a review of all emergency plans and procedures will be initiated by the fourth quarter of 1988 to assure their acceptability.
3.b.7.e - Recommendation!
Install meteorological measurement equipment at the Windsor Site.
Responset Meteorological instrumentation will be installed as discussed in response to Observation 3.a.7.a.
3.b.7.f - Recommendation Establish one central emergency telephone number for use throughout the Windsor Site.
Response
One central emergency telephone number (Ext. 5555) has been established.
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,.c AttEchm2nt LD-88-036 Pago 23 of 23
_3.b.7.c - Recommendation!
Establish controls over security of emercancy equipment cabinets to provide reasonable assurance that equipment cannot be removed for non-emergency purposes.
Responset controls as discussed in the recommendation have been I
implemented as discussed in response to observation 3.a.7.g.
3.b.7.h - Recommendationt Prepara a pre-printed message form for use by emergency response personnel.
Responset Pre-printed incident description / documentation forms are E
available as discussed in response to observation 3.a.7.h.
Nuclear Criticality Safety 3.a.8.a - Recommendation Re-examine the technique used for the storage of out-of-use uranium oxide powder blending hoppers.
r ResDonse:
1 Out-of-use uranium oxide powder blending hoppers are now secured as discussed in response to observation 3.a.8.a.
3.b.8.b - Recommendationt Assure that initial nuclear criticality safety analyses are documented in sufficient detail to permit an independent review and that the independent reviewer documents the basis for L
i 1
concurrence.
Enscense t j
As indicated in response to observation 3.a.8.b, greater detail i
is now included in nuclear criticality safety analyses.
Further, a statement by the independent reviewer as to the basis for concurrence and the method of review are also
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i incorporated.
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