ML20210F483

Insp Rept 70-1151/99-201 on 990628-0702.No Violations Noted. Major Areas Inspected:W Commercial Nuclear Fuel Div,In Columbia,Sc,Hazard Identification & Assessment,Incident Investigation,Audits & Insps & Mgt of Change

ML20210F483
Person / Time
Site:	Westinghouse
Issue date:	07/22/1999
From:	Ting P NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20210F464	List: ML20210F460 ML20210F483
References
70-1151-99-201, NUDOCS 9907300192
Download: ML20210F483 (11)

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• 1 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS l

I inspection Report No. 70-1151/99-201  ;

Docket No. 70-1151 Facility Name: Westinghouse Electric Corporation Observations at: Columbia, SC Inspection Conducted: June 28 - July 2,1999 Inspectors: Candice Drummond, Chemical Safety inspector, FCOB William T. Troskoski, Senior Chemical Safety inspector, FCOB Albert Wong, Chemical Safety inspector, FCOB Approved by: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS Enclosure 9907300192 990722 PDR ADOCK 07001151 C PDR

2 EXECUTIVE

SUMMARY

WESTINGHOUSE COLUMBIA PLANT NRC INSPECTION REPORT 70-1151/99-201 The Nuclear Regulatory Commission (NRC) performed e routine announced chemical safety inspection at the Westinghouse Commercial Nuclear Fuel Division, Columbia SC, on June 28 -

July 2,1999. The plant production operations were ongoing during the time of the NRC inspection.

The chemical process portion of the inspection focused on the identification and control of UF, and bulk chemicals process risks. The major functional areas reviewed were hazard identification and assessment, maintenance and inspection, incident investigation, audits and inspections, and management of change.

Results and Conclusion The licensee's Integrated Safety Analysis (ISA) of the uranyl nitrate bulk storage tanks and chemical receipt, handling and storage systems were thorough in identifying i potential hazards, the significance of potential hazards, and preliminary recommendations for reducing the likelihood or severity of potential hazards. The safety significant controls identified in the ISAs were properly flowed down to the plant personnel responsible for the operation and maintenance of the systems. A good practice was observed regarding the manner in which safety significant controls, ,

associated operability, and reporting requirements were identified to the plant staff.

The licensee's Process Hazard Analysis on the anhydrous ammonia system was revalidated within the appropriate frequency required by 29 CFR 1910.119. Risks {

associated with that system had been identified and properly risk ranked.

The licensee carried out the preventive maintenance of the safety significant controls from the ISAs in a timely manner with no maintenance backlog.

• The licensee tracked and addressed injury and performance incidents in a timely manner through use of their Record of Occupational injury or illness and " Red Book" systems. Performance incident entries were prioritized according to risk and reviewed by management.

- The licensee had performed self audits of appropriate scope to the Process Safety Management program. The findings had been prioritized in accordance with the licensee's risk ranking process and were being tracked for closure.

The licensee had established an administrative system to ensure that the validity of the l safety analysis was not adversely impacted due to process modifications. j

3-1 REPORT DETAILS I

1.0 Hazard Identification and Assessment (88057)

a. Scope 1

The Process Hazards Analysis (PHA) and selected Integrated Safety Analyses (ISAs) J were reviewed to verify that the licensee had taken appropriate actions to identify the potential chemical safety hazards associated with covered chemicals and systems used for the processing of special nuclear material. I

b. Observations and Findinas PHA License Application Chapter 7, Chemical Safety, addnesses the chemical safety program requirements at the Columbia Fuel Fabrication Faciuty (CFFF). Among the program elements is a requirement to systernatically evaluata the safety of chemical operations and to use the Process Safety Management regulations (29 CFR 1910.119) as the foundation for the chemical safety program. Currently, anhydrous ammonia is the only chemical above the minimum thresholds specified in 29 CFR 1910.119.

j The inspectors walked down the anhydrous ammonia system, conducted discussions with I the responsible process engineer and reviewed the PHA associated with that system. It l was determined that the licensee had revalidated the PHA within the required 5-year j frequency. A review of the recommendations showed that they had been appropriately prioritized according to a 5 by 5 risk matrix (frequency vs. consequence). No previously unidentified risks were found. As a result of the PHA, the inspectors determined that the i licensee had identified all of the significant risks associated with the process and the safety controls necessary to prevent or mitigate those risks. The inspectors determined that the overall material condition of the system was good. The licensee was found to be operating and maintaining the anhydrous ammonia system in a safe manner so as to minimize the overall safety risk.

Inteorated Safety Analysis flSAs)

License Application Chapter 4, Integrated Safety Analysis, addresses the development and maintenance of iSAs to identify process controls and safety features that are relied on for protection of the environment and the health and safety of facility employees and the neighboring public. ISAs for all systems processing licensed material are required to be completed within 5 years of the date of the application (November 5,2000). The licensee has currently completed 6 ISAs and upgraded 9 of 13 Criticality Safety Evaluations (CSEs) that will be used to " feed" into the ISA process. Discussions with plant management indicated that the licensee expects to complete most of the ISAs by this fall.

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4 The inspectors reviewed the Guidelines for Preparing a Baseline ISA, as well as portions of the ISAs for the conversion process, uranyl nitrate (UN) bulk storage, and chemical receipt, handling and storage systems (ISA-03, -02, and -06, respectively). Each system was walked down and interviews were conducted with the responsible engineering and operations persrM:td. No material condition problems were observed by the inspectors.

The ISA methodology employed the HAZOP and "what-if" check lists (for human factors and siting issues), and a fault tree analysis for crl(icality contingency identification. The analysis methodology was in accordance with license commitments and appeared to be technically sound cnd thorcugh.

The Guidelines identified and described the details in performing the various analyses, such as Chemical Safety within an ISA. The proper terms were defined and the development techniques were identified for performing each analysis. The references were documented in addition, the expectations of each analysis were included to verify that it was properly done. The Guidelines provided an adequate basis for performing an ISA. While the ISAs did not identify any previously unknown significant safety issues that would require immediate corrective actions, they did identify a number of recommendations to improve the existing safety margins. For instance, the UN bulk storage ISA determined that the chemical safety in the area of interest was less than adequate because of two chemical hazard potentials: (1) personnel exposure to UN solution in the event that the rupture disc (s) at the UN tank (s) released the solution into the dike during emergency, and (2) tank (s) overfill. The ISAs recommendations were: (1) to j revise the emergency response procedures to specify additional personal protective equipment (PPE) for people responding to the incident, and (2) to install high-high alarms in the UN tanks to prevent oveifill. The first recommendation was being tracked through the risk ranking process. The second recommendation had already been accepted and closed. High-high alarms were installed in the UN tanks to alert control room personnel of pending tank overfill. Per interview with personnel in both the Ammonium Diuranate (ADU)

Conversion and Uranium Recovery and Recycling System (URRS) control rooms, the operators were trained to respond to tank high-high alarms.

Overall, the recommendations were prioritized into three generic groups based on risk: (1) those that required action, (2) those that would be performed at management's discretion ,

and (3) those that would be administratively closed without further action. A review of  !

selected recommendations that fell into the first two groups showed that the licensee was conservative in identifying the overall risk. The inspectors also found that the licensee was i using the risk matrix to prioritize old legacy issuts that were being tracked. The licensee's l method for prioritizing safety issues based on risk was found to be acceptable.

l Each ISA ldentified a number of safety significant controls. These controls involved both active (interlocks, etc.) and passive engineered controls as well as administrative. The inspectors found that the safety significant controls were being Towed down' to the plant personnel responsible for their operation and maintenance through two basic systems:

(1) the MAPCON system for scheduling routine maintenance and testing, and (2) Operating Procedure Sketches. The sketches identified the specific control ID number, the control function / failure condition / action, the operating and maintenance procedures, '

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5 preventive maintenance and calibration requirements, funcijonal testing, and post maintenance / repair testing requirements.

During tours of the ADU Conversion and URRS control rooms, the inspectors observed a good practice in the method used by the licensee to identify the safety significant controls and operability requirements to plant personnel responsible for their operation and maintenance. Laminated placards were posted that addressed the specific operability, maintenance, and reporting requirements in a clear and succinct manner. In addition, the operating procedure sketches were similarly posted for quick reference. Discussions with several operators indicated that the instructions were well understood.

c. Conclusions The PHA and ISAs completed by the licensee in accordance with the license schedule were found to be technically sound and thorough. The safety recommendations were prioritized in accordance with risk and were being addressed in a timely manner. The ISA process was effective in identifying appropriate safety significant controls. The inspectors observed a good practice in the manner in which the safety significant controls and associated operability and reporting requirements were identified to the plant staff.

2.0 Maintenance and Inspection (88062)

a. Sgo_pjlt The inspectors reviewed the licensee maintenance and inspection programs to determine whether appropriate actions were implemented to assure the availability and reliability of safety significant controls identified through the ISA process.

b. Findinas and Observations License Application Chapter 7, Chemical Safety, addresses the chemical safety program requirements at CFFF. Among the program elements is a requirement to address l Mechanical Integrity.

The licensee currently had implemented MAPCON, a computerized maintenance tracking system. The system covered maintenance for the entire facility which was inclusive of the Conversion, Solvent Extraction. Hot Oil System, Pelleting, and Uranium Recovery. The MAPCON system maintains maintenance records, and functionality verification forms for the various areas.

The UN Bulk Storage Tanks ISA listed three activity monitors as active engineered controls (AECs) and s!x gamma monitors and data cards as administrative controls with computer or alarm assist (ACs). Review of the maintenance records indicated that all AECs and ACs had received periodic functional testing. The emergency diesel generator

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was listed as the only AEC for the chemical receipt / handling / storage. The maintenance record for the emergency diesel was als current and up to date. Any deficiencies were promptly reported and corrected.

To ensure the integrity of the UN storage tanks, the licensee conducted visual tank inspections at a semiannual basis. Review of maintenance data indicated thai the tank inspections were current. The inspectors also reviewed a recent UN storage tank ultrasonic test report (Ref: " Report of UT Thickness Survey" prepared by Carolina Testing Company, Inc., CTCl File # 98-007, December 18,1998). Test results indicated there was little material loss despite the age of the tanks (approximately 20 years). The' licensee indicated they would use the test report as the baseline data to establish a tank thickness testing schedule in the near future.

The UN tanks were equipped with rupture disks to release the solution in case of an emergency. The rupture disks were destructively tested and replaced with a new assembly every 2 years. The rupture disks were fabricated in house by the licensee's maintenance personnel. Based on the rupture disk assembly design and the up-to-date maintenance history, the inspectors concluded that the rupture disk assembly was likely to function properly when activated.

The preventative maintenance (PM) for the anhydrous ammonia system was also reviewed. The inspectors performed a walk through of the anhydrous ammonia tank farm.

The licensee currently has three ammonia storage tanks, with one filled and the other two empty in case of an emergency situation. The ammonia system is currently on a preventative maintenance schedule of having the pressure relief valves replaced every 5 years, and ultrasonic testing of the storage tanks every 3 years by an outside vendor. The licensee was current with both schedules. The pressure relief valves were replaced May 11,1999, and the ultrasonic testing took place on March 13,1997. The work orders were reviewed to verify the scheduled maintenance.

Regarding the issue oi a maintenance backlog, there was no backlog of any maintenance items (safety significant or otherwise) at the time of inspection. Furthermore, the licensee indicated that the status of all the maintenance items was reviewed weekly by the ,

maintenance department to prevent the accumulation of overdue maintenance items. )

c. Conclusions The licensee has performed all periodic testing and service to the safety significant controls. Minimal material loss was noted in recent UN tank thickness testing. The i licensee was vigilant in minimizing the maintenance backlog. j i

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3.0 incident investigations (88065)

a. Eggga The licensee's incident investigation process was reviewed to determine whether problems

. with significant safety controls were being identified, evaluated, and corrected in a timely manner.

. b. Findings and Observations License Application Chapter 7, Chemical Safety, addresses the chemical safety program requirements at CFFF. Among the program elements is a requirement to address incident Investigation The licensee had procedures for reporting and investigation of injuries, illnesses, and incidents. The inspectors reviewed procedures SYP-104 Reporting and Investigation of injuries, lilnesses, Revision 5, dated November 30,1995 and RA-111 Safety Significant incident Investigations, Revision 3, dated November 13,1997. The precedures both included identifying the root cause, developing recommendations, taking corrective action, and the formation of an investigation team.

Procedure SYP-104 had individual procedures for the affected employee, Regulatory Engineering and Operations, Medical Department, and Supervision. The in'spectors reviewed a selection of the licensee's Record of Occupational injury or lilness. The entries tracked immediate and final corrective actions. Selected entries were reviewed in the field to verify that the corrective actions had been completed. The inspector's review identified no significant injury / illness incident that had not been adequately addressed in a timelf manner by the licensee. The procedure was appropriate for handling injury investigation.

Procedure RA-111 initially instructed the formation of an incident review committee to determine if an incident is safety significant, notifiable, and/or required the conduct of a root-cause analysis. The committee reviews and approves findings, recommendations, and corrective actions relevant to the incident, which is then followed with approved closure of the incident investigation. The performance incidents are tracked through the

" Red Book". The inspectors reviewed the licensee's " Red Book" reports for the conversion and anhydrous ammonia processes for the last year. Entries had been made for problems identified with various safety significant controls. The entries tracked immediate and final correchve actions. Selected entries were reviewed in the field to verify that the corrective actions had been completed. Entries involving other process problems or recommendations were prioritized using the ISA risk ranking tables. The inspectors' review identified no -ignificant safety issue that had not been adequately addressed in a timely manner by the licensee. Recommendation backlogs were being acceptably f controlled through the risk ranking process.

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c. Conclusions L The licensee adequately tracked and addressed injury and performance incidents in a timely manner through use of their Record of Occupational injury or illness and " Red Book" ~ systems. Performance incident entries were prioritized according to risk and j reviewed by management.

4.0 Audits and Inspections (88066) a.- Sggga Self audits of the Process Safety Management (PSM) Program were reviewed to verify that the licensee was periodically assessing the overall program effectiveness, including each of the program elements, and that safety recommendations were appropriately disposed by management.

b. ' Findinas and Observations License Application Chapter 7 Chemical Safety, addresses the chemical safety program i requirements at the CFFF. Among the program elements is a requirement to l systematically evaluate the safety of chemical operations and to use the Process Safety )

Management regulations (29 CFR 1910.119) as the foundation for the chemical safety l program elements. Under the Compliance Audit element,~ the licensee is required to i evaluate: " compliance with the provisions of this section at least every three years.....".

The inspectors reviewed the two most recent audit reports dated May 1996 and May 1999.

The May 1996 report covered the required sections of the PSM regulation. The findings of

' the individual sections were appropriately documented. The inspectors tracked the recommendation conceming the missing ASME stamp / nameplate for Tank A-9, which 1 required that the tank be taken out of service untilit could be recertified. During the {

ammonia tank farm walk through, the inspectors noted that Tank A-9 was being '

maintained out of service while the licensee sought recertification.

The inspectors had discussions with personnel who conducted the last PSM audit in May 1999 and reviewed the audit report which had been forwarded to corporate management.

The audit covered all of the applicable areas and identified no significant safety issues.  !

Recommendations had been prioritized according to the licensee's risk table and were being tracked. The inspectors identified no concems. j

c. Conclusions The licensee conducted the PSM audits within the required frequency, and the resulting recommendations were prioritized and forwarded to management for review, i

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5.0 Manaoement of Chance (88063)

a. Scope The Management of Change program was reviewed to determine whether the licensee was implementing adequate measures to maintain the validity of the various facility safety analyses after initial completion.

b. Findinas and Observations The licensee has established administrative procedures to ensure that safety significant controls are not modified unless specifically approved through the configuration control program. RA-108, Safety Significant Controls, covers those controls identified in the ISA and other regulatory documents. These controls are specifically identified in ' sketches' for each plant area, which are listed in the procedure. Any changes to these controls are conducted under TA-500, Configuration Control. Discussions with licensee management indicated that the ISA Summaries would be kept up to date under this process and that management / engineering judgement would be used to determine whether a formal re-analysis would have to be performed.

During the walk down of the anhydrous ammonia system and through discussions with the system engineer, the inspectors determined that there have been no significant modifications made to the system during the last several years and that the PHA remained valid.

c. Conclusions The licensee has established administrative controls to ensure that modifications do not impact the operability of safety significant controls and to maintain the validity of the safety analyses throughout the modification process.

6.0 inSDector Follow-up Item (IFI)

IFl 70-1151/98-203-01 was generated to track the status of the improvement steps the licensee agreed to implement following a personnel exposure to hydrofluoric acid (HF) incident in 1998. The licensee has revised the HF handling procedure (Ref:

COP-836003, " Hydrofluoric Acid Handling", Revision 13, February 18,1999) to clarify PPE requirements under different work conditions. The inspectors verified that personnel using this procedure had been trained to the PPE requirements. In addition, placards listing the PPE requirements and other pertinent safety information had been posted in the HF storage tanks area. This IFl is considered closed.

10 7.0 Exit Meetina Summary The inspectors met wdh Westinghouse management and representatives throughout the inspection. The inspectors presented the inspection findings to members of the licensee management and staff during the exit meeting on July 2,1999. At the exit meeting, Westinghouse management and staff acknowledged the results presented. No proprietary information was discussed at the exit meeting.

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I1 ITEMS OPENED. CLOSED. AND DISCUSSED Closed 70-1151/98-203-01 IFl Licensee to evaluate the personal protective requirements for personnel handling hydrofluoric acid.

LIST OF ACRONYMS USED AC Administrative Controls with computer or alarm assist ADU Ammonium Diuranate AEC Active engineered control ASME American Society of Mechanical Engineers CFFF Columbia Fuel Fabrication Facility CFR Code of Federal Regulations CSE Criticality Safety Evaluation CTCl Carolina Testing Company, Inc.

HAZOP Hazard and Operability Study HF Hydrofluoric acid IFl inspector Follow-up Item ISA Integreted Safety Analysis PHA Process Hazard Analysis PM Preventive Maintenance PPE Personal Protective Equipment PSM Process Safety Management UN Uranyl Ni' rete URRS Uranium Recovery and Recycling System i

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