ML20210F399

Summarizes in-depth Insp of C-E Windsor,Ct Facility on 860818-22,covering Safety Aspects of Licensed Fuel Fabrication Facility Operations & Operational Effectiveness

ML20210F399
Person / Time
Site:	07001100
Issue date:	09/16/1986
From:	Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 8609250211
Download: ML20210F399 (7)

Text

e OF SEP 19 B86 MEMORANDUM FOR: W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS FROM: Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, ~NMSS

SUBJECT:

INSPECTION OF COMBUSTION ENGINEERING, INC., WINDSOR, CONNECTICUT FACILITY (DOCKET N0. 70-1100), AUGUST 18-22, 1986 I. PURPOSE The purpose of the in-depth inspection program was to review all safety aspects of the operations of licensed fuel fabrication facilities and to determine the operational effectiveness. Based on " lessons learned" from the January 4,1986, rupture of the uranium hexafluoride cylinder at the Sequoyah Fuels Corporation Facility near Gore, Oklahoma, a recommendation was made to review the non nuclear (e.g., fire protection and process) as well as the nuclear (e.g., radiation, nuclear criticality, and process) safety of the operations at uranium. fuel cycle facilities. The Combustion Engineering, Inc., Windsor Facility (CE) is the first one being reviewed by the NRC under this program. The inspection consisted of the following:

A. Process review B. Safety program review.

C. Recommendations'to improve the program D. A'dd license conditions, if needed E. Adequacy of the inspection program Members of the NRC inspection team and the areas of review were as follows:

1. Jerome Roth, Region I, Fuel Facility Inspector (Operations)

2. Norman J. Blumberg, Region I, Operations Engineering (Operations and Procedures)

3. Craig Z. Gordon, Region I (Radiological Contingency Plan)

4. Richard R. Keimig, Region I, Chief, Safeguards Section 8609250211 860916 PDR ADOCK 07009190 C PDR ,

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5. Norman Ketzlach, NMSS Project Manager (Nuclear Criticality and Process Safety)

6. Aristidis G. Krasopoulos, Region I, Fire Protection Specialist (Fire Protection)

7. John R. McFadden, Region I (Health Physics and Industrial Safety)

8. Douglas Sly, IE, Safeguards and Materials Programs Branch (Senior Health Physicist)

The following were the CE Management contacts:

1. Harold V. Lichtenberger, Vice President - Manufacturing

2. Geoffrey H. Chalder, Plant Manager, Nuclear Fuel Fabrication

3. Paul Hubert, Manager, Engineering

4. James Limbert, Radiological-Engineer

5. Gary Kersteen, Manager, Production and Materials Control

6. Gary Buddenhagen, Pellet Shop Supervisor

7. G. E. Cody, Manager, Facilities and Engir.eering Services

8. George Palmer, Process Engineer

9. Robert Sheeran, Manager, Nuclear Licensing, Safety, Accountability, and Security (NLSA&S)

10. Joseph Vallaro, Supervisor, Health Physics and Safety II. DISCUSSION A. Review of Operations Team members carried out their assignments individually and as a team member with one or more of the other individuals on the team. All members toured the facility operations and associated grounds where both nuclear and non-nuclear materials are stored. This report will concentrate on the inspections and reviews conducted by N. Ketzlach.

B. Building 17, Fuels Manufacturing Facility The UO2 powder receipt area was cluttered with plastic bags containing contaminated materials (e.g., rags, kimwipes) resulting from the maintenance performed during the recent plant vacation shutdown period.

Against one wall, there were stacks of " empty" UO2 containers piled up with little visible positive evidence the containers were empty. The

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. 3 SEP 191986 containers hid the empty signs on the wall so the signs were not visible to the personnel. This is a poor practice. All labels and signs should be visible at all times.

There is a fire door in front of the virgin powder prep storage vault which "shall close automatically on activation of the fire alarm and upon electrical power failure" to assure the vault is water-free during activation of the sprinklers outside the vault (a nuclear criticality safety requirement).~ The license specifies that the door's automatic closing feature be verified quarterly and records maintained of the door's performance. Although upon activation of the alarm (with release of water from the sprinklers) the door's operation is checked monthly, the operation of the roll door, under power failure conditions, had not been tested since January 3, 1984 (definitely a violation of the license condition). Although the tests are performed by maintenance personnel, responsibility for assuring that they are tested is a grey area. There appears to be a lack of an upper management written policy identifying this responsibility as well as other safety-related responsibilities (observed by other team members). This particular safety control item does not appear to be checked by any level of management from the Health Physics and Safety Supervisor to the Nuclear Power Systems Division Nuclear Safety Committee (see discussion below).

The U02 powder blender-drier was operating with powder having a U-235 enrichment >3.5 percent and all nuclear criticality safety controls for the operation (e.g., inspection of the wiper blade, powder plenum, and drying belt being checked at least weekly). The proper cylindrical press feed hoppers were used for this enrichment range.

The larger cylindrical hoppers, used with powder having enrichments

<3.5 percent are to be stored under lock and key (a license condition) during the processing of the high-enriched powder. Although there was a locked chain surrounding the larger hoppers, the intent of i

the requirement for the lock and key is to make the larger hoppers unavailable to the operators. However, the chain surrounding the hoppers was so loose that cans could be removed without unlocking the chain.

Because of nuclear criticality safety considerations, fire hoses are not permitted in the Fuel Manufacturing Building (No.17). However, water sprinkler systems (wet and dry) are permitted in some areas.

Chemical extinguishers are permitted in'any area within the building.

Ari Krasopoulos identified several sprinklers which were blocked from effectively performing their intended function (see his report).

Most of the operators have been informed not to use the portable dry l chemical extinguishers but to leave the facility in the event of a fire. CE has no fire brigade. The American Nuclear Insurers, in its i

Inspection Report dated May 14, 1982 (submitted to the NRC during the most recent SNM renewal process), recommended the previously existing fire brigade be re-instituted, along with periodic drills and training.

CE decided against the recommendation.

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SEP 191986 Several recent nuclear criticality safety analyses for requested changes in operations were reviewed. The original analyses were not always suf ficiently detailed'to permit an independent review.

Moreover, the independent second party reviewer neither documents the basis for his concurrence with the results of the initial analysis nor the method used to reach his conclusion. His approval signature appears on an approval sheet which also contains the signature of the original reviewer (not found anywhere on the analysis sheets) and finally that of the Manager, NLSA&S.

In one analysis reviewed (#214) during this inspection, the calculated UO2 mass of 184 kg/ drum was referenced as 184 lbs U0 2 (non-conservative).

The computer input, based on 184 kg or lbs UO2 , was unavailable to check whether the calculated k f for the array of drums of UO2 was in error (whether 184 kg or 18% fbs/ drum were used). The reviewer did not clearly specify his recommendation for a safe array (Analysis

1. 224) after he rejected the requested array design. One could not determine the relative position of two slabs separated by 1 foot or the arrangement of all the containers in the suggested safe array.

Recent audit reports by the Manager, NLSA&S, the nuclear safety consultant to the Nuclear Safety Committee, and by the Nuclear Safety Committee, were reviewed. None of them reviewed the records to determine whether the required administrative controls were followed (e.g., checking the operability of the virgin U02 storage vault fire door under accident conditions). This is a weakness in the adminis-tration of an effective nuclear criticality safety program.

The licensee was queried as to the availability of outside-of-reactor nuclear criticality safety standards. The only standard the Manager, NLSA&S, had on file was an outdated copy of ANS-8.1 (ANSI N16.1-1975),

" Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors," which has been superseded by ANSI /ANS-8.1-1983.

It could not be verified, but it appeared the appropriate nuclear safety standards may have been available to the nuclear safety consultant to the Nuclear Safety Committee. Among other standards, ANSI /ANS-8.19-1984, " Administrative Practices for Nuclear Criticality Safety" would have been useful to CE nuclear safety personnel in developing an effective nuclear criticality safety program. Needless to say, a set of the Regulatory Guides related to nuclear safety, as well as other applicable safety issues (e.g., radiation safety),

should also be available.

During a tour of Building 02, it was noted that some natural uranium rods were being stored on top of the maximum-safe approved slab (3.7 inches high). It appears that neither a safety review was made nor approval given to store the natural uranium rods on top of a " safe" slab. R. Sheeran, Manager, NLSA&S, is reviewing the event to determine why approval procedures were not followed and plans to take corrective action to prevent its reoccurrence.

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l III. Recommendations A. All work! stations, whether they are authorized to contain SNM or only to store empty SNM containers, should be clearly identified and posted with a sign that is clearly visible to operations personnel.

B. Responsibility should be delegated by management in writing for inspecting the presence and operability of all controls (mechanical and administrative) related to plant and operational safety. The audit functions (e.g., NLSA&S, nuclear safety consultant to the Nuclear Safety Committee, and the Nuclear Safety Committee) should include the review of the records that document the checking of the controls at the required frequencies.

C. The inspection and audit functions should include the review of compliance with all administrative safety controls (e.g. , properly maintaining the large cylindrical hoppers at the powder blender-dryer station under lock and key when required).

D. The criginal nuclear criticality safety analysis should be documented in sufficient detail to permit an independent review of the analysis, the assumptions made, and the basis for concluding the proposed operation is or is not safe. The nuclear safety specialist performing l the analysis should affix his signature.

E. The nuclear safety consultant to the Nuclear Safety Committee, who performs'the independent second party review of the analysis, should

' document what his review included and the basis for his concurrence

, with the' initial reviewer. He, too, should sign the documentation.

F. Up-to-date copies of all applicable nuclear criticality safety standards snould be available.

IV. Conclusion The in-depth team inspection of the CE facilities identified a number of disciplines resulting in a more thorough and complete safety inspection which may not have been accomplished as well by individual independent inspections. This trip report, togetter with those made by other team members, provides a good basis for the integrated inspection report and assessment of operational safety at CE.

Original Signed by N. Ketslach Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

6 SEP 191986 DISTRIBUTION:

FCUP r/f FCUF NMSS r/f NKetzlach (2)

VLTharpe WTCrow Docketc.Noa

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70-1100 JRoth, RI DSly, IE PDR Region I MHorn RECunningham

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NAME:NKetzlach:ht :VL rpe :WTCrow  :  :  :

DATE:09//6/86 :09/f/86 :09//[/86  :  :  :

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