ML20206B043

Insp Rept 70-0036/99-202 on 990405-09.No Violations Noted. Major Areas Inspected:Chemical Safety Insp Focused on Identification & Control of Process Risks Identified by Licensee ISA Program

ML20206B043
Person / Time
Site:	07000036
Issue date:	04/26/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20206B041	List: ML20206B037 ML20206B043
References
70-0036-99-202, 70-36-99-202, NUDOCS 9904290127
Download: ML20206B043 (10)

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COMBUSTION ENGINEERING, INC.

NRC INSPECTION REPORT 70-36/99-202 Docket No. 70-36' License No. . SNM-33 Report No. 70-36/99-202 License Holder: Combustion Engineering, Inc.

Location: 3300 State Road P Festus, MO 63028 Dates: April 5-9,1999 Inspectors: M, N. Baker, Chemical Process Engineer A. Wong, Chemical Process Engineer NRC Headquarters Approved by: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS Enclosure

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EXECUTIVE

SUMMARY

ALLIEDSIGNAL METROPOLIS PLANT NRC INSPECTION REPORT 70-36/99-202 Introduction The NRC conducted a routine, announced chemical safety inspection of ABB-CE on April 5-9, 1999. The inspection was conducted by NRC Headquarters staff. The inspection focused on the identification and control of process risks identified by the licensee's Integrated Safety Analysis (ISA) program, concentrating on the following functional areas:

Hazard identification and Assessment (88057)

• Standard Operating Procedures (88058)

• Maintenance and inspection (88062)

• Management of Change (88063)

The inspectors focused or: three plant areas becaute new ISAs had been performed for them.

The areas were: Oxide Convertion Plant, Hydrogen Fluoride (HF) Absorber (Scrubber), and uranium hexafluoride (UF.) Cylinder Wash and Recertification Station.

Results and Conclusions

- The ISA program was being implemented in accordance with the license requirements and was adequately managed. The overall quality of the individual hazard analyses was good.

• The management of change program appeared to provide satisfactory control of the hazard analyses.

- Licensee actions to assure the availability and reliability of controls implemented by the ISA program to reduce process risks to an acceptable level were generally satisfactory.

However, two items (i.e., a bulk chemical storage tank pressure relief valve and a scrubber quench water valve), identified as important to HF absorber safety, were incorporated into the plant preventive maintenance (PM) program after the inspectors had discovered that they were inadvertently left out of the PM program.

- The emergency diesel generator that the facility relied on for emergency power was regularly tested and properly maintained.

- An apparent weakress was identif;ed in that the licensee had no formal Open Items tracking program to ensure that actions identified by the ISA process were completed. The

-lack of such a program had been identified in previous inspecticns. The licensee stated that plant staff had been assigned the task of implementing a risk-prioritized Open items tracking system.

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3 The inspectors closed out two previously identified open issues: (1) a Violation

~( VIO) No. 70-36/95-201-03: the Oxide Plant monitors were not calibrated at set frequency and the calibration data sheets were not available, and (2) an Inspector Followup Item (IFI) No. 70-36/97-202-02: a hazard analysis had not been performed for the wet HF absorber system that the licensee was planning to install. They were closed after the  !

inspectors reviewed appropriate paperwork to support the closure of these two items.

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4 REPORT DETAILS 1.0 Hazard identification and Assessment (88057)

a. Scope The licensee's three ISAs were reviewed to verify that (1) they ware being accomplished in accordance with regulatory requirements, (2) completed ISAs were technically adequate, and (3) the risks from handling, processing, and storing licensed material were identified and appropriately addressed.

b. Observations and FMdinas The "what if" technique was used in the Oxide Plant ISA. The last update was in 1997. The hazard operability methodology was used in the HF Absorber and uranium hexafluoride (UFe) Cylinder Wash and Recertification Station ISAs. The latter two ISAs were issued in 1998 and 1999, respectively. The Oxide Plant and HF Absorber ISAs were generated in-house with personnel from operations, engineenng and maintenance and equipment vendor (HF Absorber only). The UF. Cylinder Wash and Recertification Station ISA team veas led by a Scientech contractor with input from engineering, health physics and safety departments.

All three ISAs appeared to be complete with notes, piping and instrumentation diagrams (P&lDs), and action items / recommendations generated from the review process. A spot check of the Oxide Plant ISA indicated that all action items had been completed. No hazards ranked " urgent" were identified in the HF Absorber ISA. An action item from the HF Absorber siting review for the facility was to mount placards listing incompatible materials (e.g. nitric acid) on the outside of the absorber dike. There was no such placard in the field. When asked, the licensee responded that the prohibition was stated in the operating procedure. This was verified by the inspectors to be in O.S. 604.05 (HF Absorber Operation, Rev. 6, March 17,1999), Section 4.5. The UFe Cylinder Wash operation was divided into two phases. Phase 1 included washing, drying, and leak testing the cylinders.

Phase 2 consisted of the steps required for storing and processing the wash solutions. The urgent and high priority action items listed for Phase 1 had already been completed prior to the system being brought on line. The Phase 2 high priority action items will be completed before that part of the operation is put in service.

Appendix H of the Oxide Plant ISA listed items important to safety. Three HF detectors, RIS-1, RIS-2, and RIS-4, were included in Appendix H of the ISA as items important to chemical safety. RIS-1 was located in the cylinder loading dock area above the steam chests. It was prone to false alarms, particu;arly in cold months, due to steam condensing as " fog." The licensee was evaluating the option of relocating RIS-1 to a location inside the Oxide building to reduce the incidence of false alarms. RIS-2 and RIS-4, intended to detect UF. leaks from the reactors, had never worked satisfactonly and were currently not in se vice. The licensee substituted a leak check by the operations (Ref: Startup Procedure O.S. 601.03, Section 5.2, Rev 9, November 19,1998). In addition, Health Physics put the

5 area under respirator protection when the system was down and during the initial startup period. These compensatory measures went through the plant management of change program (referred to as CMR), but they were not reflected in the ISA.

At the time of the inspection, two of the UF. reactors (R2 and R3)were being replaced. The new reactors were similar to the previous design, but would feature a " center displacement tube" which would modify the critical geometry of the vessel, reducing the likelihood of a criticality. The licensee indicated that all the affected P&lDs and procedures were in the process of being revised. However, the licensee also indicated that they did not intend to revise the ISA to reflect the as-built conditions in the field. Nevertheless, the licensee was in the process of evaluating the need to keep the ISA as a living document.

c. Conclusion The ISAs for the Oxide Plant, HF Absorber, and the UF Cylinder Wash and Recertification Station adequately identified the hazards in the respective area. Urgent and high priority action items, generated from the hazard reviews were closed out prior to the systems being put in service. The ISAs, once published, did not receive periodic updates to reflect the field conditions.

2.0 Standard Operating Procedures (88058)

a. Scope Operating procedures from the two plant areas were examined to verify that (1) they

' implemented the administrative controls identified in the respective ISA, and (2) they were clear and current.

b. Observations and Findinas Procedures for startup (Ref: 0.S. 601.03 Start Up, Rev. 9, November 19,1998) and  !

continuing operation (Ref: O.S. 0601.04 Pyrohydrolysis and Process Cycle Operations, Rev. 7, December 10,1998) of the system were verified to be up to-date. They contained j safe operating limits for key variables (e.g., temperature, flow) and alarm response instructions. The process was controlled by a Taylor MOD 300 Distributed _ Control System (DCS) that annunciated alarms and interlocks associated with this system (Ref: O.S.

604.19 Control System - ABB MOD 300 Process Controller, Rev. 2, March 30,1998).

A spot check by the inspectors confirmed that no operating procedures were issued until they had been reviewed and authorized. The inspectors also noticed that current data

. sheets, where applicable, were on hand at work areas for work in progress.

Applicable procedures for operation of the HF absorber were reviewed: (1) 0.S. 604.05 HF Absorber Operation, Rev. 6, dated March 17,1999, and (2) O.S.1006.00 Truck Transfer Operation, Rev. 4. February 11,1999. Review of the procedures confirmed that they were clear and usable, and were readily available to workers at all times. Interviews with licensee personnel confirmed that the system was being operated in accordance witn l

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6 the procedures, and the procedures reflected the current operating practices. The procedures contained instructions for startup, shutdown conditions, alarms and interlocks.

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and troubleshooting. Recommendations from the ISA were included in the procedures in l the areas of chemical and nuclear criticality safety. A spot check of the personal protective l equipment and emergency HF first aid supplies indicated that they werc readily available in )

the work area. Safety shower and eye wash station were verified to be functional.

c. Conclusion By reviewing the selected operating procedures from the Oxide plant and the HF Absorber area, the inspectors confirmed that (1) the procedures indeed implemented the administrative controls called for in the ISAs, and (2) they were up-to-date. No deficiencies were identified in this area.

l 3.0 Maintenance and Inspection (88062)

a. Scope i

Items and equipment important to safety were identified either in the ISAs or in the license. j The inspection team examined the maintenance records of selected items to verify that they {

had received appropriate maintenance to ensure reliability. )

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b. Observations and Findinas  !

The equipment important to safety identified in the Appendix H of the Oxide Plant ISA properly flowed down to O.S. 4101.00 Oxide inspection and Alarm Calibration / Testing, Rev. 9, February 7,1998. O.S. 4101.00 covered the following instrumentation:

(1) moisture probes, (2) temperature alarms, (3) reactor bed temperature indicators, (4) oxide pressure indicators. (5) low temperature steam shutoff indicators, (6) UF / steam interlock HS-4 and (7) vaporizer /UF detectors.

The inspectors examined five sets of biannual calibration records representing the past two years of maintenance history and found them to be complete. Any out-of-calibration entries were promptly resolved by the cognizant engineer in addition, the cognizant engineer confirmed that the DCS back-up power batteries were replaced in 1997.

The Oxide Plant was equipped with four emergency shutoff (panicj buttons located at different egress routes. The operators were instructed to push the buttons in the ever,? of an emergency evacuation from any cause. These buttons functioned to close UF shutoff valves from the cylinder and cracked ammonia shutoff valves to the R2 and R3 reactots.

Activation of an emergency shutoff button placed the Oxide plant in an " idle" mode. If placed in " idle" for an extended period, the plant will eventually shut down by other interlocks. The inspection and functional testing of these emergency shutoff buttons were also covered under O.S. 4101. Review of O.S. 4101 data sheets from the past two years indicated these devices had been properly maintained and tested.

7 The HF Absorber ISA listed a number of items as important to safety: (1) absorber emergency quench water valve to flood the first stage absorber upon high temperature or low level, (2) bulk chemical storage tank pressure relief valve (PRV), (3) day tank valve which diverted flow from the product tanks to surge tanks upon high level in the product tanks, (4) several hand operated system valves, (5) safety shower and eyewash station, and (6) duplicate uranium samples. License Condition 1.6.e, states, in part, that equipment important to safety be included in programs for testing, calibration, and inspection. The hand operated valves were operated, and therefore tested, each time the system was used.

Duplicate uranium samples are taken each time the day tanks are filled. However, the bulk tank PRV and quench valve did not appear in any test or inspection program. Upon inquiry from the inspectors, the licensee promptly added these two valves to the plant PM system as items M-186 (bulk tank PRV) and M-187 (quench valve), respectively. They will receive annual functional testing / inspection in the future. The inspectors noted that it would be beneficial to the licensee to have a plant-wide tracking system to prioritize (based on risk-ranking) and track the items identified in the ISA to closure. The licensee replied that similar observations had been made in previous NRC inspections. An engineer had already been assigned the task of developing such a tracking system.

The HF Absorber safe,ty shower and eyewash tests were found to be in the licensee's PM system for monthiy testing (activity number M-124). Although the tests had been performed, the tags had fallen off the shower handle and the eyewash station. The licensee agreed to replace the tags with a tag to be kept in the adjacent operators' change room and office area.

In accordance with Chapter 2 of the Emergency Plan and Chapter 10 of the Safety l Demonstration, the licensee conducted weekly and monthly checks on their emergency diesel generator per O.S. 4004.00, Electrical Power Distribution Equipment, Rev. 4, November 17,1997. Maintenance records from the last three months were reviewed to confirm that appropriate maintenance and testing had been performed to the diesel generator.

c. Conclusion With the exception of two valves in the HF Absorber Area, items / equipment important to safety identified in the ISAs/ license had been properly maintained. Once the licensee was made aware that two items had been inadvertently left out of the maintenance program, they were promptly added back to the PM li.st. The licensee was currently deve!oping a tracking system to avoid recurrence of similar events in the future. Ne deficiencies were identified in this area.

4.0 Management of Change (88063)

a. Scope The inspectors reviewed the licensee's management of change process, specifically the Change Management Request (CMR) process. This process described a systematic

8 means of reviewing planned changes to the facility. The inspectors reviewed a number of anticipated changes and changes in progress from the ISAs to confirm that the system was working as written.

b. Observations and Findinus impacts of change on employee safety and health were addressed by appropriate health physics and criticality safety personnel. Changes were authorized by appropriate plant management.

All process and safety interlocks were controlled by the DCS. Programming changes to the DCS were procedurally controlled by MIS 0007.00, Oxide MOD 300 Control System, Rev. O, October 29,1996. The inspectors also reviewed a temporary change that was in force in the Oxide Plant to confirm that it had been written, reviewed, approved, and issued properly.

License Condition 1.6.e requires that the licensee's Regulatory Affairs Manager reviews all major plant modifications to determine if a new ISA is needed. The review was accomplished through an electronic CMR program. This CMR system was used to review, in part, changes made to items referenced in the ISA. CMR number H.98.330.104 for Phase 1 of the UF, Cylinder Wash and Recertification System was reviewed in its entirety.

The review indicated that (1) all approvals and conditions were being documented satisfactorily, (2) embedded documents and calculations were properly attached, and (3) approval signatures, including those of any acting managers or designees, were password protected.

c. Conclusion The licensee had an existing CMR program to control changes made to those items in the ISAs.~ Review of an arbitrarily selected CMR package indicated that changes made to the ISA items / processes were effectively controlled. No deficiencies were found in this area.

5.0 Followup of Open items

1. VIO No. 70-36/95-201-03 had identified the fact that monitors in the Oxide Plant had not been calibrated and that the calibration data sheets were not available. Upon the request of the inspectors, the Oxide system engineer produced the past two years' O.S. 4101 calibration data sheets for the alarms identified as important to safety. This VIO is considered closed.

2. IFl No. 70-36/97-202-02 had identified the fact that an ISA had not been performed for the wet HF Absorber (scrubber) system that the licensee was planning to install. The

ISA had been performed, and the system was operating at the time of this inspection.

.This IFl is considered closed.

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9 d.0 Exit Meeting An exit meeting was held between NRC Headquarters inspectors and the licensee management and staff on April 9,1999. No proprietary or classified information was identified.

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10 PARTIAL LIST OF PERSONS CONTACTED Bill Sharkey* (Regulatory Affairs)

Earl Saito* (Health Physics)

Mike Eastburn* (Criticality)

Kevin Hayes * (industrial Safety)

Doris Wallace (Central Document Control)

Don Underwood (Engineering)

Jamie Long (Engineering)

Bob Griscom (Engineering)

Bill Altier(Engineering)

John Kraus (Maintenance)

Frank Tidd (Maintenance)

• Attended exit meeting LIST OF ACRONYMS CMR Change Management Request DCS Distributed Control System HF Hydrogen Fluoride IFl Inspector Followup Item ISA. Integrated Safety Analysis P&lD Piping and Instrumentation Diagram PM Preventive Maintenance PRV Pressure Relief Valve VIO Violation t- UFs Uranium Hexafluoride

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