ML20206S515

Insp Rept 70-0036/99-201 on 990118-22.No Violations Noted. Major Areas Inspected:Items Related to Fire Safety Performance Re Safe Plant Operations

ML20206S515
Person / Time
Site:	07000036
Issue date:	02/05/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20206S513	List: ML20206S509 ML20206S515
References
70-0036-99-201, 70-36-99-201, NUDOCS 9902100340
Download: ML20206S515 (22)

Text

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U.S. N UCLEAR REG ULATORY CO)1 MISSION

- OFFICE OF NUCLEAR MATERI AL SAFETY AND SAFEGUARDS Docket No.: 70-36 License No.: SNM-33 Report No.: 70-36/99-20i Licensee: ABB Combustion Engineering Location: IIematite, MO inspection Dates: ' January 18 - 22, 1999 Inspectors: Peter L.ee Fire Safety Inspector, NRC Ileadquarters Dennis Morey, Criticality Safety inspector, NRC Headquarters Frank Gee, Criticality Safety inspector. NRC Hee <1gt:siters Doug Outlaw, Consultant, SAIC i

Approved Byi Philip Ting, Chief >

Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS I

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Enclosure  !

9902100340 990205 ,

PDR ADOCK 07000036 I C- PDR I

AHH COMHUSTION ENGINEERING -

p NRC INSPECTION REPORT

! 70-36/99-201 EXECUTIVE SUMM ARY Introduction The Nuclear Regulatory Commission (NRC) conducted routine, announced fire protection and criticality safety inspections of ABB Combustion Engineering on January 18 - 22, ~1999. The inspections were conducted by NRC Headquarters staff and an NRC contractor. The inspections focused on the highest risk activities in the oxide conversion, recycle and recovery, and pellet -

manufacturing areas.

The fire safety inspection focused on items related to fire safety performance concerning safe plant operations. The major areas of fire safety performance elements reviewed included the plant's engineered fire protection systems, the inspection, testing, and maintenance (ITM) of fire protection systems, the control of flammable and combustible material, and inspector followup

items. The criticality safety inspection focused on the areas of validation, analysis, and reliability of controls along with open item review.

Results Fire Safety

• The design basis for the automatic sprinkler systems in the storerooms and warehouse was adequately maintained to assure system safety performance.

• A weakness was noted in the licensee's management system that assures completion of corrective actions for important self-identified fire safety issues.

• The licensee has implemented adequate controls for storage of fiammable liquids and gases to minimize potential fire hazards. The general storage of combustibles was adequate.

• The ITM performed by the licensee for fire protection systems was consistent with industry standards and provided adequate assurance that fire protection systems will meet their intended safety functions.

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Criticality Safety The inspectors identified a weakness with the licensee investiga: ion of a material accumulation event in that the investigation was still not complete six months after the event.

The inspectors noted that implementation of criticality safety limits and controls in the plant has improved.

The licensee has failed to devote sufficient resources to the Criticality Safety Program Update (CSPU) and the Integrated Safety Assessment (ISA) activities and has failed to meet commitment schedule.

The licensee system to investigate and appropriately document non-reportable occurrences was being performed in accordance with procedures.

The inspectors noted that the licensee document control system has improved.

REPORT DETAILS Fire Safety (88055) 1.0 Engineered Fire Protection Systems

a. Scone The inspector reviewed combustible loading and storage configurations to assure that the design capability of the existing sprinkler systems protecting the facility storerooms and warehouse were not exceeded. The inspector also reviewed the impact of the Year 2000 -

(Y2K) concem on the plant fire alarm system. Engineered fire protection systems are safety significant because they are relied on to mitigate and limit consequences.

b. Observations and Findines Plant Conditions and Maintenance of Sprinkler Systems Design Bases The licensee has installed automatic sprinklers in storerooms in Building 256-2, and in the warehouse in Buildin; 230, to assure that a fire in these areas would not propagate into the production and manufacturing areas of the plant. The inspector performed a walk-through of the storerooms and warehouse and observed that combustible loading and storage configurations were adequately managed to prevent exceeding the design 3

and performance capabilities of existing automatic sprinkler systems. The inspector determined that the licensee posting of allowable combustible storage heights was an improvement in the control of combustibles.

Plant Fire Alarm System - Year 2000 Concern The facility emergency (fire) alama system is a Notifier Model AM-2020 with remote panels. The licensee indicated that the fire alarm system safety functions would not be afTected by the Y2K concern. The licensee also indicated that a manufacturer software upgrade for date dependent features of the fire alarm system had been requested. The inspector determined that the licensee had taken appropriate actions to address the potential Y2K concern.

Maintenance of Fire Harrier Walls and Protection of Openings The licensee has designated one-hour fire walls to separate the facility into fire areas.

The inspector noted that the licensee had completed upgrades of personnel type fire doors to assure protection of openings in fire walls but had not completed necessary corrective actions to properly seal all penetrations, verify overhead roll-type fire door's automatic actuation, and provide additional fusible links where required. The fire walls were intended to separate high combustible loading areas (e.g., Incinerator Room, Decontamination Area, etc.), and assure that a fire would not spread to adjacent processing and manufacturing areas. The licensee committed to completing corrective actions required for the potential high combustible loading areas by March 31.1999.

Based on review of overhead roll-type fire doors, the locations of fire wall penetration weaknesses, and potential fire propagation to adjacent areas, the inspector concluded that the weaknesses noted did not present an imminent danger to workers and did not significantly reduce the intended margin for fire safety. The inspector determined that the lack of management attention to completion of corrective actions for self-identified deficiencies important to the fire safety was a weakness.

c. Conclusions The design basis for the automatic sprinkler systems for the storerooms and warehouse was adequately maintained to assure system performance. The licensee had made improvements to assure adequate control of combustibles in these areas. A weakness was noted in the failure to correct fire wall problems.

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2.0 Control of Flammable and Combustible Material

a. Scone The inspector perfomied walk-throughs to observe the licensee's control of flammable liquids, gases and combustibles. Due to the lack of engineered fire suppression systems protecting all areas of the facility and the general restriction on the use of water for fire suppression (due to criticality safety concerns), the licensee relies on control of combustibles to assure fire safety.

b. Observations and Findines Control of Flammable Liquids and Combustible Liquids The licensee has provided flammable storage cabinets at locations where flammable liquids were used. The flammable liquids were limited to small quantities, and good storage and housekeeping was observed by the inspector during tours of the facility.

The licensee indicated that an isopropyl alcohol dispensing system has been established with the supply tank located outside of the building. The inspector noted that the licensee actions, as part of the effort to reduce waste generation and decontamination requirements, resulted in reducing overall combustible loading inside the facility. The inspector noted that the bulk isopropyl alcohol tank was stored in a fire rated enclosure to address potential spills and protect against an exterior fire exposure hazard to the facility. The inspector also noted that adequate control of combustibles was provided for areas surrounding the isopropyl alcohol storage enclosure.

Control of Combustibles The inspector determined that general control of combustibles in the facility was adequate to minimiu the potential for a significant fire. The inspector identified weaknesses in licensee procedure NIS 215.00, Fire Protection, which had not established requirements for acceptable control of combustibles and had not established requirements for separation of combustibles to minimize fire severity and fire propagation in areas of potential high fire loading (i.e.. Incinerator Room of Building 240, Decontamination Area of Building 253). The inspector noted that as found conditions for combustible material stored in the incinerator Room and Decontamination Area were not severe fire loading and would not exceed the one-hour duration designated for the fire walls. The licensee committed to revise the procedure by March 31.1999.

The inspector toured the area of the uranium hexafluoride (U F,,) cylinder storage pad and anhydrous ammonia storage tanks. The inspector observed that general control of combustibles around the UF. cylinder storage pad was adequate. No combustibles, other 5

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9 than wood or plastic saddles used for storing UF6cylinders. were found on the storage pad. The inspector noted that the use of electric or propane driven forklifts for movement of UF cylinders and the lack of vehicle traffic inside fenced facility perimeters minimized the potential for a flammable liquid pool type fire in the area of the storage pad. The inspector also noted good control of combustibles and natural

. vegetation to minimize fire hazards or fuel loading around the anhydrous ammonia storage tanks.

c. Conclusions The licensee has implemented adequate controls for th'e storage of fiammable liquids and gases to minimize fire hazards. The general storage of combustibles was adequate to limit potential fires and consequences: however, the inspector identified procedural weaknesses in assuring acceptable control of combustibles and separation of combustibles to minimize fire severity and fire propagation in areas of potential high fire loading.

3.0 Fire Protection System inspection, Testing and Maintenance (ITM)

a. Scone The inspector reviewed records and procedures for ITM of the automatic sprinkler system, fire alann systems, fire pumps, and fire hydrants, and performed a walk-through to determine the material condition of fire protection systems and components. The appropriate implementation ofITM is necessary to assure the reliability and nvailability of fire protection systems.

- b. Observations and Findines Fire Protection System Inspection, Testing, and Maintenance In general, the inspection. testing, and maintenance (ITM) of water-based fire suppression systems or components (e.g., fire hydrants, post indicator valves, automatic sprinkler systems, fire pump, etc.) and the fire alarm system (e.g., smoke detectors, heat detectors, pull stations. etc.) at the facility was consistent with accepted industry standards. The inspector noted that the licensee was in the process of updating procedures to incorporate changes in industry standards and improve documentation of ITM. The inspector determined that the following ITMs were not consistent with industry standards and had not been included in proposed procedures:

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• Calibrations of gauges by checking with an inspector's gauge (i.e.. a calibrated gauge) or by replacement with a calibrated gauge at a 5-year frequency had not been performed National Fire Protection Association ((NFPA) 25, Chapter 2.3.2).

+ Industry standard NFPA 25, Chapter 4-3.1 requires performance of flow tests to determine the internal condition'of water mains used for fire protection at a 5-year frequency.

The licensee acknowledged the need to perform the ITM items above and committed to revise the procedure for the calibration of gauges by March 31,1999. The water distribution flow test every 5 years would be addressed with future fire pump tests or fire hydrant maintenance.

Annual Fire Pump Test The inspector reviewed the licensee's annual fire pump test performed on July 13,1998.

' The inspector compared the fire pump test results with original fire pump performance ,

data from the manufacturer dated November 25,1991, end found no significant deterioration of the performance of the pump.

Fire Protection System Operability and Impairments The inspector performed a tour of fire protection systems and components at the facility to observe and note their material condition. The inspector did not observe obvious impairment of the automatic sprinkler systems, fire pump, fire hydrants, post-indicator valves (PIVs), and fire alarm systems and components. ITM record reviews did not indicate a concern for the material condition and operability of any fire protection system or component.

c. Conclusions The inspector concluded that ITM performed by the licensee for fire protection systems was consistent with accepted industry standards and provides adequate assurance that fire protection systems will meet their intended safety functions. No impairmeras or significant concerns for material conditions were identified. The water supply (including the fire pump) was adequately maintained to assure water flow and pressure required for plant fire protection systems and manual fire suppression.

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Criticality Safety (88015) 4.0 Plant Operations .

a. Scone The inspectors toured the facility to determine whether administrative and engineered controls were in place and being effectively implemented.- The inspectors focused on a -

performance challenge identified in the March 3,1998, Licensee Performance Review,

. that involved previous weaknesses with the implementation and maintenance of criticality safety limits and controls.

The inspectors also reviewed program level implementation oflicense requirements, the licensee response to a recent 91-01 event, and implementation of double contingency requirements.

- b. Observations and Findings The inspectors performed several facility walkdowns during the inspection and did not

' identify any perfom1ance or safety issues. The criticality safety evaluations for several higher risk systems were reviewed to identify the limits and controls necessary to ensure safety. These systems were then walked down to confirm that the specific controls identified in the criticality _ safety evaluation were in place and functional. No new problems were identified. The inspectors determined that the overall state of the facility in the area of compliance with operational controls was good and has improved since the last inspection.

Material Accumulation Limits As reported in inspection report 98-203, on August 7,1998, the licensee made an NRC Bulletin 91-01 notification for an event involving fissile material accumulation in a heat exchanger associated with the waste incinerator. The inspectors noted that the event resulted, in part, from the failure of operating procedures to establish when the removal of accumulated material would be perfomied. Due to the lack ofinformation, operators who observed material accumulating in the heat exchanger relied on their own judgment to determine whether or not to remove it.

License Section 2.9 requires that events reportable to the NRC be investigated and documented. The licensee has not yet completed the investigation of the heat exchanger material accumulation event nearly six months after the event so that root cause analysis and corrective action development and implementation cannot be reviewed. Therefore, 8

the inspectors cannot determine whether sufficient corrective actions have been identified and taken. The inspectors reviewed a summary of corrective actions and determined that adequate safety for the system had been restored.

The inspectors were ii. formed by the licensee that a root cause of the event was the failure of work procedures to require the removal of accumulated material so that operators relied on personaljudgement when fissile material accumula: ions were encountered. Tlw licensee indicated that work procedures were changed as a result of the preliminary event investigation but full documentation of corrective actions was not yet complete. The inspectors were concemed about the adequacy of work procedures and the extent to which procedural requirements were reviewed in the licensee investigation. Completion of the material accumulation event ir.vestigation will be tracked as Inspector Followup Item (IFI) 70-36/99-201-01.

Raschig Rings Inspection Report 98-203 identified raschig ring filled tanks as " Single Parameter Double Contingency." Unresolved item (LIRI) 70-36/98-203-01 was opened to determine whether items identified as " Single Parameter Double Contingency" had to be specifically authorized in License Section 1.6. License Section 4.1.l(a) requires that a process design which does not meet double contingency criteria must be explicitly approved in License Section 1.6.

The inspectors reviewed License Section 4.1.1(a) and determined that it requires items that do not meet double contingency to be listed in License Section 1.6. The NRC has accepted multiple controls on a single parameter as meeting double contingency when those controls are independent and robust and otherwise provide adequate protection from criticality. The inspectors also noted that other licensee systems such as the conversion reactors which are obviously single parameter situations are not listed in License Section 1.6.

The NRC considers that " Single Parameter Double Contingency" is a process design for which all controls affect a single parameter such as moderator. Examples of systems at the licensee facility which clearly fall into the category of " Single Parameter Double Contingency" would be the conversion reactors and the powder hoppers because in both of these systems, monitoring for the presence of moderator is the only control method.

On the other hand, raschig rings control both volume and poison content. Also, in this case, the raschig rings cannot be remosed by any credible single act or event which would leave the tank capable of containing solution. The inspectors determined that a raschig ring filled tank meets double contingency criteria without recourse to the distinction " Single Parameter Double Contingency" Therefore, URI 70-36/98-203-01 is closed.

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c. Conclusions The inspectors identified a weakness with the licensee investigation of a material accumulation event in that the investigation was still not complete six months after the event.

The inspectors did not identify any performance issues during facility walkdowns and found that the implementation of criticality safety limits and controls was adequate.

5.0 Criticality Analysis

a. Scope 1

The inspectors reviewed licensee efforts to document the basis for classification of fissile systems as Safe Individual Units (SIU). The licensee relies extensively on SIU detennination to avoid fonnal criticality analysis of fissile material operations when those operations can be shown to be always substantially suberitical under any credible conditions. Therefore, the SIU determination is a safety significant aspect of the licensee's criticality safety basis.

b. Observations and Findinus An SIU is a fissile system that has been determined to be critically safe under all credible conditions and is listed in Table 4.5 of the license. Exactly how the SIU determination was made is not clear in all cases. The licensee made a commitment during inspection 98-201 to establish the analytical basis for SIU determinations during the CSPU upgrade of plant analysis.

The inspectors determined that licensee criteria for SIU designation are subjective. For example, the inspectors noted that in licensee analyses reviewed to this point, the

- licensee has used arguments based upon data in cases that appeared substantially suberitical on the order of 15% to 20% Ak. For example, the license might refer to tabulated data from an accepted source which indicates that a column of certain dimensions is always suberitical with 5 wt% enriched uranium and conclude that no further analysis is necessary. The inspectors determined that the licensee practices associated with documenting SIU determinations to date were acceptable but these determinations should be closely monitored during the course oflicensee CSPU i activities.1.icensee actions to document the basis for determination of SIUs will be tracked as IFl 70-36/99-201-02.

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c. Conclusions The inspectors determined that licensee SIU determinations that have been documented to date were adequate. The inspectors also concluded that SIU determinations are subjective and should be monitored for adequacy.

6.0 Criticality Safety Program Update and Integrated Safety Assessment

a. Scone In order to remedy serious performance issues raised by the NRC during previous inspections, the licensee committed to a Criticality Safety Program Upgrade (CSPU) project. The CSPU performs the safety significant task of defining the criticality safety basis by requiring the licensee to perform formal criticality analysis of all fissile systems. The inspectors reviewed licensee progress in meeting CSPU and ISA commitments in both of these areas.

b. Observations and Findines License Application Section 1.6(e) requires the licensee to perform ISAs for plant processes in accordance with a schedule that has been submitted to and approved by the NRC. The schedule includes completing the CSPU in accordance with a plan submitted on September 20,1996, and perfomiing ISAs for plant systems and processes at the facility in accordance with the plan submitted November 12,1996. The NRC Licensee Performance Review of March 30,1998, indicated that completion of the CSPU plan commitments and the ISA in a timely manner were " projected challenges to performance." During the most recent NRC inspection, the licensee appeared to be on schedule.

The inspectors found that progress made in calendar year 1998 was far less than indicated in the plans accepted by the NRC in 1996. Review of commitments indicated that a completed ISA for the Recycle / Recovery Area was due November 30,1998. The schedule called for piping and instrumentation diagrams (P&lDs) and drawings for the Recycle / Recovery Area to be prepared in 1997, with completion of the evaluation, analysis update, and ISA in 1998. That ISA was to have included updated criticality safety evaluations for the processes in the Recycle' Recovery Area.

Discussions with the criticality safety staffindicated that progress for the Recycle / Recovery Area in 1998 had been quite limited. The licensee indicated that the P&lDs were approximately 90% complete, the drawings had been reviewed, and a draft design basis document had been prepared. The licensee also indicated that the evaluation scheduled for completion on April 3,1998, was approximately 25% complete and that the analysis update scheduled Ihr completion on July 10.1998, had not been 11 J

fully initiated. The licensee further indicated that the ISA scheduled to begin after the analysis update and completed by November 30,1998, had not been fully initiated.

. The licensee stated in the September 25,1998, Criticality Safety Program Update Semi-Annual Status Report that " progress on the CSPU for this period has fallen behind schedule due primarily to diversion of resources. To address this problem, the licensee has contracted an additional criticality safety specialist and plans to be back on schedule by the next reporting period." The NRC acknowledged receipt of this progress report on October 31,1998. The inspectors noted that the next reporting period is March of 1999.

Discussions v.ith licensee staffindicated that a single criticality safety specialist had been scheduied to do much of the work on the evaluation and analysis update activities for the Recycle / Recovery Area during 1998. The ISA plan and schedule requires most of the analyst's criticality evaluation activities to be completed prior to preparation of the ISA. The analyst was assigned to another activity, analysis of shipping containers, for six months during 1998. Discussions indicated that it will be very challenging to get the CSPU/ISA programs back on schedule. Most of the activities by criticality safety staff scheduled for CYl998 were not performed. Consequently, the sequential activities that followed, including the ISA, were not performed.

The schedule also called for P81Ds. drawings, and basis documents for the Pellet Plant Front End to have been completed by July 6,1998, December 30,1998, and December 31,1998, respectively. These activities were not completed on schedule and have only recently been initiated. The evaluation scheduled for initiation on January 4,1999, has not been started. The licensee committed to be in compliance with the schedule by September 1999.

c. Conclusions The inspectors found that the licensee has failed to devote sumcient resources to the Criticality Safety Program Update and the Integrated Safety Assessment activities and has failed to meet the identified commitments. No immediate safety concerns were identified by the inspectors 7.0 Internal Audits and Inspections

a. Scone f Identifying, tracking and correcting criticality safety issues is a risk significant activity at the licensee facility due to the licensee reliance on administrative controls. The inspectors reviewed Criticality Safety Event Reports prepared over the last 12 months to confirm that the intemal reporting system was working as intended and as required by the license. The inspectors also reviewed the Radiological and Criticality Safety 12

Inspection Reports for the first, second, thud. and fourth Quarters of 1998 to determine whether the licensee inspection program was adequate to find and correct criticality safety-related problems occurring during plant operations.

b. Observations and Findines Non-Reportable Occurrences License Application Section 2.9 requires that the licensee investigate and appropriately document non-reportable occurrences. Plant procedure NIS 0205.00," Nuclear Criticality Safety Event Reporting" contains the specific licensee procedural requirements for internal reporing and investigation.

The inspectors determined that nuclear criticality safety (NCS) Event Reports were maintained in the licensee Central Documents Center. Review of files for the last 12 months indicated that this system was being appropriately utilized. These records indicated that 32 event reports were filed in CY 1998. including one that was identified by the annual criticality safety audit conducted in March 1998. Only one event was determined by the licensee to be reportable in accordance with NRC Bulletin 91-01.

The inspectors did not identify any safety or compliance issues with the licensee tracking system.

Quarterly Internal Audit Reports The inspectors reviewed four quarterly reports from 1998 and observed minor housekeeping findings with no significant problems in the criticality area reported by licensee staff. The license audit program met license requirements, but the inspectors questioned the depth of audit efforts. The inspectors felt that, based on the scope of licensee fissile material activities and operational issues recently raised by the NRC, the licensee audit should identify some criticality safety items. The inspectors encouraged the licensee to perform a more intrusive audit to identify criticality risks in plant operations.

The inspectors observed that the retrieval of documents was easy and accurate. During the inspection, all records requested were retrieved successfully. The inspectors determined that the licensee has significantly improved the document control system.

c. Conclusions The inspectors found that the licensee system to investigate and appropriately document t

non-reportable occurrences was being performed in accordance with license I requirements. The inspectors further determined that the licensee performs and reports 13 i

6 quarterly audits, but no major audit findings in criticality safety were identified.

The inspectors determined that the licensee document control system has improved significantly from previous inspections.

8.0 Maintenance and Calibration for Criticality Safety

a. figgag Calibration is safety significant at the licensee facility due to reliance on instruments to provide double contingency protection through monitoring of a single parameter and maintenance ofinstrumentation is a key factor in maintaining the risk of criticality at an acceptable level when instruments are the principle or only control.

The inspectors reviewed maintenance records of calibration instruments that are used at the licensee onsite laboratory for calibration of equipment which measures criticality safety control parameters in the plant. The inspectors also reviewed maintenance records of the oxide conversion process instrumentation which, in several cases.

provides multiple controls on a single parameter to provide double contingency protection. Finally, the inspectors reviewed the records of ma ntenance of the criticality accident alann system to verify that ma.ntenance was being timely performed in accordance with established procedures to assure proper functioning of that system,

b. Observations and Findines Laboratory Operations The licensee onsite laboratory calibrates equipment that can potentially affect criticality safety controls and thus affect risk at the facility. Procedure O.S. 1502.00. " Calibration of Gage and Measuring Equipment," Revision 2, provides the instructions to calibrate and adjust tools, gages, and other measuring devices used in activities affecting quality.

The inspectors also reviewed the calibration record for the Max-2000 Moisture Analyzer which was perfc rmed on November 14,1998. In addition, the inspectors reviewed the calibration of the analytictl balance which was calibrated on January 18,1998. The calibration interval for both instruments is six months. The inspectors determined that calibration had been performed for both instruments in accordance with license requirements. i Criticality Controls Procedure O.S. 4101.00, " Oxide Inspection and Alarm Calibration / Testing," Revision 9, specifies inspection, calibration, and testing requirements for controls that monitor the oxide process and maintain process parameters within established criticality safety 14 l

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r limits. The oxide process controls are required to be inspected every six months.

Controls consist of pressure alarms, reactor temperature alarms, vaporizer temperature alarms, UF,, detector, Building 254/255 and oxide air supply hygrometers, oxide cooler moisture monitors, and vaporizer conductivity sensors. The inspectors reviewed the l maintenance data sheets performed in August and September 1998 on the oxide pressure l transducer check. steam shut-off checks, vaporizer and UF detector checks, low temperature superheated steam shut-off check, dew point moisture probe checks, and l UF. emergency shutoff and CO, emergency cooling. The inspectors found that the licensee performed the maintenance according to procedural and license requirements.

l l In the oxide area, criticality safety is assured through the redundancy of the l thermocouples which are tested, like the others, on a six-month schedule. Moisture is l

excluded from the reactors and the presence of moisture in the reactors is detected by

redundant thermocouples. In addition, the source of moderation, the steam supply, is interlocked with the temperature to prohibit condensation of steam; the oxide procedure requires that the reactor bed be dumped as low as possible prior to any extended shutdown; and if the reactor bed is at or below the approximate height of the outlet pipe, approximately 25.7 liters. criticality is not achievable in the reactor.

Criticality Accident Alarm System HP Procedure 316.00," Instrument Calibration,"is the governing procedure for calibration ofinstruments for radiation detection and measurement. Radiation detection instruments are required to be calibrated every six months except for the Eberline radioactive air monitors (RAMS), which are calibrated on an annual basis. The procedure includes alarm check, filter paper check, precautions, high-voltage calibration.

and the general instrument inspections for the continuous alpha air monitors; Ludlum Model 3; scintillation alpha counter, Model SAC-4; and Eberline R.M-15 and -20.

l In addition, the other procedure in the criticality accident alarm system is HP Procedure 317, " Alarm Testing," includes the instructions for testing, evacuation, and emergency alarm annunciators and documenting these tests. The procedure requires monthly tests of two criticality detector locations and one emergency alarm pull station.

The procedure also defines the associated duration of the test and the kind of check source used for the evacuation and emergency alarm tests with the reporting requirements of the failed instrument to the proper management chain.

The inspectors reviewed the records of the " Nuclear Alarm Checklist" procedure '

performed in 1998 and found that all tests were performed on schedule for the locations required. The inspectors also reviewed the " Detector Assembly and Electronic Chassis l

l Changcout Log" for January to September 1998 and found that the task had been adequately performed.

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= c. Conclusions

The licensee has established and implemented a system to assure that instruments

- important to safety are adequately calibrated and maintained. Further, no maintenance backlog exists, indicating that the licensee has allocated sufficient resources and management attention to this area.

9.0 Open item Review IFl 70-36/96-202-09 This IFI concerned review of the licensee's actions to address 1995 Annual Audit findings and recommendations. The inspectors reviewed the corrective actions taken to address each of the 1995 findings. These corrective actions were also reviewed during

. subsequent 1996 and 1997 annual criticality safety audits. The 1997 audit performed in March 1998 reviewed the status of findings from the 1994,1995, and 1996 annual audits and the adequacy of the corrective actions for each finding. That audit found that all the open 1995 audit findings had been effectively closed. Review of the documentation and discussions with licensee staff confimied that these findings had been closed. This IFl is l: , considered closed.

! IFI 70-36/97-204-01

! This item tracks licensee actions to ensure appropriate documentation ofidentified fire safety issues and the assurance of appropriate attention and commitment by licensee's

. management to correct important fire safety issues. The inspector found that the licensee had documented fire safety issues and recommended corrective actions in the l_

annual fire safety audit conducted in February 9-11,1998, and was aware of other fire safety recommendations identified in the insurer property inspection report, dated September 23,1998. The inspector noted that a performance weakness continued to exist due to the apparent lack of formal management commitment and tracking of l identified fire safety issues. For example, weaknesses in the integrity of fire barriers l (discussed in Section 1.0 above) had been known to the licensee since 1990 and 1995 and the licensee had not completed all corrective actions to address the weaknesses. The

[ licensee indicated that a comprehensive facility commitment and tracking system was being developed, but did not provide estimated completion date for such a system. This item remains open.

L IFI 70-36/97-204-02 This item tracked the licensee annual fire safety audit to assess the effectiveness of the licensee's fire protection performance. The inspector reviewed the licensee's fire safety audit performed between February 9-11,1998. The licensee's annual audit, in 16 L: 1 1

combination with the licensee's insurer inspection, provides an adequate assessment of fire protection performance at the facility. This item is considered closed.

IFl 70-36/97-204-03 This item tracked the licensee's action to ensure that the design bases and performance capabilities of automatic sprinkler systems at the facility are maintained. The licensee had implemented combustible controls and provided assurance through postings for maintaining facility conditions within design bases of automatic sprinkler systems protecting the warehouse and storerooms. This item is considered closed.

IFI 70-36/97-204-04 This item tracks the licensee's actions to update and improve implementation and documentation oflTM of fire protection systems at the facility to reflect current industry codes and standards. The licensee has not completed actions on this iterr.. The licensee committed to completing final review, approval and implementation of two new and one revised procedure by the March 31,1999. This item remains open.

IFI 70-36/97-204-05 This IFl tracked the determination of root causes and corrective actions for the licensee's failure to promptly address the potential degradation of a critical fire safety component (i.e. fire pump overheating). The licensee had taken corrective action but had detennined that no root cause analysis was required. The inspector identified weaknesses that might have been investigated such as failure to test a fire pump following maintenance and completion of required annual fire pump test. The licensee acknowledged the weaknesses. Because the pump is working and no additional corrective actions are planned, this item is considered closed.

IFl 70-36/97-204-06 This IFI tracked the establishment of additional combustible control reouirements to assure reliable implementation to reduce potential fire severity or hamrds. The licensee's issuance and implementation of updates of the controF mg procedure to improve combustible controls will be combined with follow-up 4 IFl 70-36/97-204-04.

This item is considered closed.

IFI 70-36/97-204-07 This IFl tracked licensee review of the need for criticality safety analysis to address a f

postulated fire involving empty combustible fuel shipping containers and their impact on 17 j C I

the criticality safety of polyethylene drums and over-packs in the Building 230 Warehouse. Discussion with the licensee indicated that consequence of polyethylene and over-pack failure due to fire would not result in additior.at criticality safety concerns and analysis of spills bounds potential scenarios. The licensee further indicated that the previous filtrate inventory had been properly dispositioned and storage of filtrate in that manner was no longer required. This item is considered closed.

IFI 70-36/97-204-08 This IFl tracked actions by the licensee to address life safety upgrades related to additional means of egress from upper-level decks of the production facility. The licensee determined that the deficiency was not ofimmediate danger and was awaiting resources to take corrective actions. Licensee management ofidentified fire protection deficiencies (as it related to life safety concerns) will be combined with follow-up ofIFI 70-36/97-204-04. This item is considered closed.

URI 70-36/97-204-09 This item addressed the adequate development, implementation, and maintenance of emergency plan commitments. The NRC notified the licensee by letter on June 1,1997, that the item was closed. This item is considered closed.

IFI 70-36/98-201-08 This IFl concerned the unavailability for review of criticality-safety related training records for plant staff due to the hospitalization of a key licensee staff member. During this inspection, it was found that the licensee had changed the methods for maintaining and controlling access to training records. Primary copies of these documents are now stored in the Central Document Center. Access to the qualification status of operators is now computerized. Multiple people now have access to the records so that the unavailability of a single individual should no longer limit access. Review of the criticality safety training records indicated that all but one operator has the required criticality safety training. That operator had been injured and is not currently back to i work. Review of specific criticality safety training records for selected individuals l

indicated that the level of knowledge of the operators was adequate. This item is considered closed.

IFI 70-36/98-201-09 l

This IFl conceiaed the failure to include potential problems and deficiencies identified in quarterly criticality safety inspections in the nuclear criticality safety event report system.' Review of the 1997 llematite Annual Radiological and Criticality Safety Audit.

performed March 23-27,1998, indicated that one finding, regarding the lack of 18 l

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4 documented criticality safety analyses for ventilation systems. required immediate, further action. Review of the Nuclear Criticality Safety Event Report Dies indicated that a NCS Event Report was issued and an evaluation performed. Review of the NCS Event reports for the last year indicated this was the only event that had been identified in the quarterly and annual inspections. Review of the 1998 quarterly criticality safety inspection reports did not identify any specific problems that required inclusion in the NCS Event Reporting system. The licensee has briefed the staff on the potential problems with not tracking, investigating, and documenting issues identified in quarterly and annual inspections, and there were no additional occurrences of the identified problem. Therefore, this item is considered closed.

VIO 70-36/ 98-201-10 This violation concemed the failure of the licensee to perfonn two independent samples for a system that relied on dual independent sampling for double contingency. The licensee responded to the violation in a letter dated March 13.1998, and committed to revise operating and laboratory procedures to eliminate the common mode issue. The licensee also committed to evaluate whether a single operator presented a common mode concern. The inspectors detemiined that the licensee has adequately completed corrective actions. The licensee has purchased new equipment so that samples are placed into dissimilar containers and processed in physically difTerent counters. The inspectors determined that the licensee has adequately responded to this violation as committed and the corrective actions adequate to insure independent sampling. This item is considered closed.

URI 70-36/98-203-01 This URI concemed the failure to identify UN tanks in License 1.6 as " single parameter double contingency." As discussed in Section 4.0 above, the inspectors determined that this item is not a safety or regulatory concern and is considered closed.

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ITEMS OPENED Cl OSED, AND DISCUSSED ltems Onened IFl 70-36/99-201-01 Tracks completion of the material accumulation event investigation.

IFl 70-36/99-201-02 Tracks licensee actions to document the basis for determination of SIUs.

Items Closed IFI 70-36/96-202-09 This item tracked actions to address 95 annual audit findings and recommendations.

IFI 70-36/97-204-02 This item tracked the incensee annual fire safety audit to assess the effectiveness of tb licensee's fire protection program.

I IFI 70-36/97-204-03 This item tracket the licensee's action to ensure the design bases and performance capabilities of automatic sprinkler systems at the facility are maintained.

IFI 70-36/97-204-05 This item tracked the determination of root causes and corrective actions for the licensee's failure to promptly address the potential degradation of a critical fire safety component (i.e., fire pump overheating).

I IFI 70-36/97-204-06 This item tracked the establishment of a combustible control program to assure reliable implementation of requirements to reduce potential fire hazards.

IFl 70-36/97-204-07 This item tracked licensee review of the need for criticality safety analysis to address a postulated fire involving empty combustible fuel shipping containers and its impact on nuclear criticality safety for the storage of filtrate in polyethylene drums and over-packs in the Building 230 Warehouse.

IFl 70-36/97-204-08 This item tracked appropriate actions by the licensee to address life l

safety upgrades related to additional means of egress from i upper-level decks of the production facility.

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UR) 70-36/97-204-09 This item addressed the adequate development, implementation, and maintenance of emergency plan commitments.

- IFl 70-36/98-201-08 This item tracked the plant staff training records review.

IFI 70-36/98-201 This item tracked the failure to report a criticality safety violation.

VIO 70-36/98-201-10 This violation concerned the failure to provide dual independent sampling.

URI 70-36/98-203-01 This item concemed the failure to identify raschig ring filled uranyl nitrate tanks as single contingency control.

Items Discussed IFl 70-36/97-204-01 This item tracks licensee actions to ensure appropriate documentation ofidentified fire safety issues and the assurance of appropriate attention and commitment by licensee's management to correct important fire safety issues.

i IFl 70-36/97-204-04 This item tracks the licensee's actions to update and improve j implementation and documentation ofITM of fire protection l systems at the facility to reflect current industry codes and standards.

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e M AN AGEMENT MEETINGS The NRC Inspectors met with facility management periodically during the inspection. The inspectors presented the inspection findings to members of the licensee management and staff during the exit meeting on January 22.1999. No classified or proprietary information was discussed. At the exit meeting, Combustion Engineering management and staff acknowledged findings presented, and committed to take appropriate actions as discussed above.

PARTI AL LIST OF PERSONS CONTACTED Michael Eastburn Criticality Safety Robert Freeman Criticality Safety Gilles Page Director, Uranium Operations Robert Sharkey Director. Regulatory Affairs Philip Weaver Manager, Production K.Ilayes Engineer, Industrial Safety E. Saito llealth Physicist L. Tupper MC&A Engineer LIST OF ACRONDIS CSPU Criticality Safety Program Upgrade IFI inspector Followup Item ISA Integrated Safety Analysis ITM Inspection, Testing, and Maintenance KENO Criticality Module in SCALE NCS Nuclear Criticality Safety NCV Non-cited Violation NFPA National Fire Protection Asso-iation NRC Nuclear Regulatory Comrr .on PI&D Piping and Instrumentation Diagram PlVs Post-Indicator Valves RAM Radioactive Air Monitor SIU Safe Individual Unit UF 6 Uranium Hexafluoride UO, Uranium Dioxide URI Unresolved item Y2K Year 2000 Ak Fraction of the Multiplication Factor 22