ML20210M716
| ML20210M716 | |
| Person / Time | |
|---|---|
| Site: | Erwin, 070143O |
| Issue date: | 08/02/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210L968 | List: |
| References | |
| 70-0143-99-06, NUDOCS 9908100156 | |
| Download: ML20210M716 (34) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION ll Docket No.:
70-143 j
i License No.:
SNM-124 Report No.:
70-143/99-06 Licensee:
Nuclear Fuel Services, Inc.
Facility:
Erwin Facility Location:
Erwin, TN 37650 Dates:
June 7-18,1999 Inspectors:
W. Gloersen (Tearn Leader), Senior Fuel Facility inspector (Ril)
F. Gee, Criticality Safety insp t (NMSS)
C. Hughey, Senior Resident 1 pector (BWXT/Ril)
G. Humphrey, Senior Resident inspector (NFS/Rll)
D. Morey, Criticality Safety inspector (NMSS)
A. Wong, Chemical Safety inspector (NMSS)
Accompanying Personnel:
C. Dean, NRC Contractor (SAIC)
D. Outlaw, NRC Contractor (SAIC) l Approved by:
E. J. McAlpine, Chief, Fuel Facilities Branch l
Division of Nuclear Materials Safety l
Enclosure 99081G0156 990802 PDR ADOCK 07000143 i
'C PDR L
EXECUTIVE
SUMMARY
Nuclear Fuel Services, Inc.
NRC Inspection Report 70-143/99-06 l
This report is a summary of the integrated inspection efforts that involved a special operational readiness review team inspection of the licensee's proposed operation of a manufacturing process. Specifically, the NRC inspection team concentrated on the licensee's operational readiness in areas 300-500 of the manufacturing process. The operational readiness review inspection was conducted during a two week period from June 7-18,1999, with specialized inspectors from the NRC Office of Nuclear Materials Safety and Safeguards (ONM3S) and Region ll (Rll). The results of the operational readine'ss review (ORR) inspection are contained in the Report Details section of this report. The Report Details section has been prepared to exclude the use of information the licensee identified as proprietary and for which the licensee submitted an affidavit pursuant to 10 CFR 2.790. The inspection was conducted through a review of selected records, procedures, interviews with personnel, and direct observation of equipment testing and work activities in the areas of criticality safety, chemical safety, fire protection, radiation protection, operations, and maintenance.
The operational readiness review inspection involved a review of the licensee's newly installed equipment in areas 300-500 and the proposed operation to process high-enriched uranium. No safety significant problems were noted in the areas of operations, maintenance, chemical safety, nuclear criticality safety or radiological controls.
.j CHEMICAL SAFETY The licensee had adequately analyzed the chemical hazards in the 300/400/500 Areas.
In addition, the controls in place were sufficient to protect plant personnel from hazardous chemicals (Section 1.c).
CRITICALITY SAFETY Controls associated with the 300/400 process area were available and the process was bounded by appropriate safety basis assumptions (Section 2.a).
- Safety-related equipment (SRE) in the 500 process area was properly labeled, identified, and maintained. The maintenance staff was knowledgeable in the equipment and operations. The 500 process area had safety significant activities which may be safely i
performed within the stated limits. The criticality risks in the 500 process area were
. adequately minimized by licensee controls (Section 2.a).
The licensee had implemented adequate controls against the release of material into unsafe geometry utility vessels (Section 2.b).
A weakness was identified associated with the practice of using draft references to support the technical safety basis of a final evaluation. The criticality safety evaluation for portable containers provided an adequate basis for safe start-up and operation of the proposed production process (Section 2.c).
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2 The procedures for handling of uranium samples in the laboratory were adequate to safely support the proposed operation. The laboratory relied extensively on administrative controls and perman,ent criticality postings were not yet posted in the laboratory; however, the licensee indicated that these postings will be in place when the laboratory is in use (Section 2.d).
The ventilation ducts had appropriate and adequate Nondestructive Assay (NDA) monitoring points to assure that fissile material accumulations would be detected (Section 2.e).
A question was raised conceming whether the seismic response of some of the partitions supporting the storage racks were engineered to the seismic robustness of the remainder of the building. The licensee provided design information on these partitions to the NRC licensing function. Safety Conditions S-28 and S-29 were issued by the NRC licensing function requiring additional future evaluation and response by the licensee (Section 2.f).
The process vessel content description used to develop limits and controls for the proposed 300 complex operations was adequately conservative such that operations were well bounded by safety basis assumptions. The control of glass equipment composition was assured by licensee controls so that adequacy of safety basis assumptions associated with the composition was assured. The licensee had adequate double contingency protection against criticality occurring from damage to the glass equipment (Section 2.g).
The criticality safety evaluations and resulting limits and controls for the 80G. and 6,000-gallon waste water tanks provides an adequate basis for safe start-up and operation of the fuel production process (Section 2.h).
The licensee had implemented sufficient controls on the handling of dry fissile material contaminated waste to support the safe start-up of the proposed operation (Section 2.i).
Additional compensatory measures were required for fire safety prior to introduction of special nuclear material. The compensatory measures and requirement of additional supporting analyses were required by the NRC licensing function in Safety Conditions S-41 and S-42 (Section 2.k and 5.a).
All safety related equipment for the 300,400 and 500 process areas were properly labeled. Periodic testing of this equipment had been developed and implemented and was adequate to ensure the reliability and availability of the equipment to perform intended safety functions (Section 2.1).
FACILITY OPERATIONS 9
The piping process and instrumentation diagrams were found to accurately depict the process equipment and systems as installed (Section 3.a).
3 The procedures for operating the Naval fuel process were determined to provide adequate instructions for a safe operation (Section 3.b).
MANAGEMENT ORGANIZATION AND CONTROLS The managers and engineers responsible for the operation of the Naval fuel process had adequate training and experience to manage the operation in a safe manner (Sectinn 4.a).
FIRE PROiECTION The licensee's Fire Hazard Analysis (FHA) adequately captured the potential consequences of fire involving Areas 300-500, but were not addressed in the integrated safety analysis (ISA) (Section 5.a).
The licensee continued to make progress in the installation (4 a smoke detection system and establishment of 2-hour fire walls for fire protection of Building 302. The facility fire brigade was adequately trained for industrial firefighting and was adequately equipped for emergency response to a fire in Building 302 (Section 5.b)
RADIATION PROTECTION There were no radiation protection start-up issues identified during this r' ase of the inspection. The inspectors concluded that the licensee was able to administer an effective radiological safety program (Section 6.b).
The licensee successfully modified the Building 300 complex ventilation system to insure that the air flow from less contaminated areas to more contaminated areas be maintained (Section 6.b).
ENVIRONMENTAL PROTECTION AND WASTE MANAGEMENT The effluent and environmental monitoring programs provided reasonable assurance
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that effluents to the environment would be less than regulatory limits and that any significant impacts of plant emissions on the surrounding environment would be adequately quantified (Section 7.b).
Attachments:
Partial Listing of Persons Contacted inspection Procedures Used List of items Opened, Closed, and Discussed List of Acronyms
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I REPORT DETAILS
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1.
Chemical Safety (88056-88066) a.
Inspection Scope The inspectors reviewed the integrated safety analysis (ISA) documentation and walked down the 300/400/500 Areas of the manufacturing processes to evaluate the adequacy of controls in place to protect plant personnel from hazardous chemicals, and to hasure that the proposed process had been sufficiently prepared for operation.
b.
Observations and Findinas Process Safety Information (88056)
The inspectors reviewed the material safety data sheets (MSDSs) for chemicals used in 300/400/500 Areas and determined that they were accurate and complete. Furthermore, interviews with operators from different shifts indicated that they were aware of the locations of MSDSs and the safety information in them.
The inspectors also reviewed the piping and instrumentation diagrams (P&lDs) for the 400 Area and determined that the orawings were current, accurate, and complete.
Moreover, all safety related critical equipment was clearly identified. Interviews with licensee personnel who had performed the field verification of the P&lDs confirmed that f
all P&lDs agrnd with the as-built conditions.
The process material containment was made of stainless steel, perfluoroalkoxyalkane copoly*mer (PFA) and Tygon" tubing. Stainless steel and PFA (a material similar to Teflon ) exhibited good corrosion resistance in the existing environment and Tygon" tubing provided the needed flexibility. Based on the licensee's field experience and previous experimental work, Tygon" was determined to be suitable for the particular i
application and was contained inside a glass enclosure, thereby, reducing the likelihood of personnel contact with the hazardous chemicals.
The piping and tubing in iSe process area were installed by a subcontractor using the licensee's engineering standard (Ref: Division 15 - Mechanical Section 15060 " Pipe, Fittings, Valves and Accessories", Rev. 3, February 23,1998) traceable to the American Society for Testing and Materials and other standards. Supplemental instructions were provided by the material's vendor (Ref: Swagelok Catalog MS-01-05, "PFA Tube Fittings," 1996). Interviews with construction personnel indicated that the licensee's standard and the vendor's instructions were adhered to during the construction of the piping system. Furthermore, the tightness of the tube fittings were randomly checkeo by both the subcontractor and the licensee during and after the piping construction. The licensee also leak tested the piping / vessel systems prior to a::cepting the work from the subcontractor (Ref: NFS-ENG-005," Inspection of Construction Activities, Rev.1, May 1, 1997). Review of the licensee's testing records indicated that tne system had been properly leak tested.
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2 Hazard Identification and Assessment (88057)
The inspectors reviewed the ISA summary for the 300/400/500 Areas. The specific documents reviewed included what-if tables, chemical interaction matrices, safety evaluation, recommendations and responses. The scope and depth of the what-if tables and safety evaluations were comprehensive enough to address the chemical risks in the 300/400/500 Areas. The ISA generated 19 recommendations for the 300 Area,'21 recommendations for the 400 Area and 21 recommendations for the 500 Area. All recommendations were resolved and properly closed.
The 400 Area ISA identified that the overflow cr failure of two chemical tanks in the breezeway could potentially lead to an air concentration of the chemical exceeding both the Occupational Safety and Health Administration's permissible exposure limit and National Institute of Occupationa; 3afety and Health's immediately dangerous to life or health limit. Some of the more predominant tank failure mechanisms included: (1) over pressurization, (2) failure under vacuum and (3) failure due to impact from an external force. The tanks were at atmospheric pressure and were located in an area not easily accessible to fork lift trucks, so the tanks were unlikely to fail under the aforementioned conditions. There were procedures in place to prevent operators from overfilling the tanks. Therefore, the probability of a chemical accident having serious consequences in the 400 Area was considered low.
A certain process material containment in the 500 Area was outside the glass enclosure.
To prevent possible process material contact with the adjacent instrumentation valves, the licensee planned to install splash deflectors near the instrumentation valves. When the inspectors raised the question of personnel protection, the licensee agreed to consider the installation of additional shields to protect the operators in that area.
The licensee relied on operatoi Wgilance to detect and stop minor leaks and releases in the process area. Interviews with operations personnel from different shifts confirmed that the operators had been instructed to stop minor leaks and to notify supervision if leaks / releases were detected.
Management of Change (88063)
Processes in the 400/500 Process Area were controlled by a series of programmable logic controllers. The set points of the programmable logic controllers were set by the engineers. The operators were instructed that any changes to the set points and process parameters (except those explicitly permitted by the procedures) must be submitted to the Safety and Safeguards Review Committee (SSRC) for review and approval. SSRC membership consisted of engineering, operations, safety, security, and MC&A. Interviews with operations personnel confirmed that the operators were aware of the requirements.
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c.
Conclusions Based on the program elements evaluated by the inspection team, the inspectors concluded that the licensee had adequately analyzed the chemical hazards in the 300/400/500 Areas. In addition, the controls in place were sufficient to protect plant
. personnel from hazardous chemicals.
2.
Criticality Safety (88015) a.
Process Areas 300-500.
(1).
Inspection Scooe The inspectors reviewed Nuclear Criticality Safety Analysis (NCSA) 54X-99-0038 which covered proposed operations for the 300 process area, NCSA 54X-99-012 for the 400 process area, and NCSA 54X-98-0032 for the 500 process area to confirm the overall adequacy of the established safety basis, validity of assumptions, and availability and reliability of controls. The inspectors focused on bounding contents, the 301/401 process enclosure, and adequacy of administrative controls. The inspectors performed walkdowns of the process equipment and interviewed operators and engineers to confirm that the installations were in accordance with design drawings and the analytical basis.
(2)
Observations and Findinas
. 300 Area The inspectors walked down the 300 process area operations and determined that the operations were well bounded by analytical assumptions and that required criticality safety controls were in place.-
The inspectors observed that production considerations limit the amount of fissile v
material available for credible upsets in the 301 process enclosure. The licensee had based safety limits on a model of the process which used approximately 20 times the amount of fissile material normaily available. The inspectors determined that the proposed limits and controls would provide substantial criticality safety margin for this portion of the process.
j 400 Area Very limited amounts of fissile material will be available for credible upsets in the 400
. process area. The inspectors reviewed controls on the 401 enclosure such as postings and engineered safety features and determined that controla were adequate for the j
y operation, which was now relatively low risk compared to the previously planned j
process. The inspe tors determined that substantial safety margin against credible upsets in the 401 enclosure exists for the planned operations.
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4 500 Area The 500 process area consisted of several process vessels of varbus sizes which may contain significant amounts of fissile material during the proposed operations. The process was automatically controlled with an option for manual control.
Some portions of the 500 process area involved criticality safety risks which were adequately mitigated by engineered safety features. The inspectors determined that these safety features were available and were under a preventive maintenance schedule to insure operability. The licensee stated that the periodicity of maintenance was sufficient to make the probability of equipment failure unlikely.
The release of fissile material out of particular process vessels under certain conditions appeared to be the most safety significant aspect of the 500 area operations. The licensee conducted an experiment to address inadvertent release of material from these process vessels. The licensee obtained an experimental dimension of the released material and identified several factors affecting the geometry of the released material.
These factors were the type of release and the surfaces where the release collects, the flatness and smoothness of the surface upon which the material collects, and the kinetic energy of the material upon impact with the collecting surface. The licensee placed a collection pan under the process vessels. The pan had an approximately 1/8 inch opening at the bottom to let moderator drain out to prevent subsequent moderation of released material. In the unlikely event that one of the process vessels breaks, the licensee determined that the system would remain suberitical as demonstrated by conser/ative KENO calculations when considering the worst case release. Other KENO calculations demonstrcled subcriticality due to releases of different geometry, releases into the pans below the accountability vessels, and releases onto the floor. According to the calculations, hands and arms were permitted within the barrier. The physical barrier prevented increased reflection conditions due to personnelin the immediate area of a release under the process vessels. The inspectors determined that the licensee assumptions adequately bounded the proposed operations and that controls were adequate to assure suberiticality.
(3)
Conclusions The inspectors determined that controls associated with the 300/400 process area were available, the process was bounded by appropriate safety basis assumptions, and the process may be safely operated as proposed.
The inspectors also determined that safety-related equipment (SRE) in the 500 process area was properly labeled, identified, and maintained. The licensee maintenance staff was knowledgeable in the equipment and operations. The 500 process area had safety significant activities which may be safely performed within the stated limits. The criticality risks in the 500 process area were adequately minimized by licensee controls.
5 b.
Potential Unwanted Releases (1)
Inspection Scope The inspectors reviewed licensee safety basis documentation concerning the potential for unwanted release of materialinto unsafe geometry utility equipment vessels. The inspectors performed walkdowns of process and utility equipment and conducted interviews of criticality safety and production staff to determine the adequacy of equipment and procedures intended to prevent the unsafe release of material.
The inspectors reviewed NCSA 54X-99-0044, NCSA 54X-99-0033, NCSA 54X-99-0037, NCSA 54X-99-0035, NCSA 54X-99-0043, and NCSA 54X-98-0044 to ensure that uranium would not be released into unfavorable geometry equipment. The inspectors walked down portions of the systems to confirm the overall adequacy of the evaluations and the proposed controls and to ensure that the processes can be operated safely, and in conformance with the double contingency principle.
(2)
Observations and Findinas The inspectors observed that the licensee had implemented a system of overflow lines to prevent process system pressure from causing material to enter unsafe geometry utility vessels. Overflows were either directed to the process off-gas (POG) or the floor. The two controls for double contingency protection were the initial failure of the process system causing pressurization and concurrent failure of the overflow vents or POG system causing release into the utility lines. The inspectors determined that the credible scenarios were unlikely.
The inspectors conducted walkdowns of portions of systems described in NCSA 54X-99-0044, NCSA 54X-99-0033, NCSA 54X-99-0037, NCSA 54X-99-0035, NCSA 54X-99-0043, and NCSA 54X-98-0044 with operations, technical, and criticality safety staff. No additional criticality scenarios were identified by the inspectors during these walkdowns. Selected controls identified in the NCSA were reviewed during the l
walkdowns to confirm their appropriateness and adequacy. The inspectors determined that these controls were adequate. Review of the approaches taken to demonstrate subcriticality under normal and abnormal conditions were adequate, and modeling assumptions were observed to be conservative.
(3)
Conclusions The inspectors determined that the licensee has implemented adequate controls against the release of materialinto unsafe geometry utility vessels.
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c.
Portable Containers
-(1)
Insoection Scooe The inspectors reviewed NCSA 54X-98-0024, " Handling Fissionable Material in Portable g
Containers," to determine the adequacy of the criticality safety limits and controls to
. support safe start-up and operation of the fuel production process. This evaluation
. covered the use of portable containers throughout all of the fuel production process areas. The inspectors also toured the process areas during the inspection, focusirg on l
areas 300,400,500, and auxiliary processes.
(2)
Observations and Findinas The detailed review of the criticality safety evaluation identified no significant technical or safety issues. However, a weakness was noted in that the evaluation referenced several draft, unapproved analyses to support the basis for safety of the operation. Referencing
- a draft analysis may lead to errors in the technical safety basis due to changes made to the draft documents during the review and approval cycle. Since the portable container evaluation was issued, these references have been finalized and approved. Based on this review, the referenced analyses remain valid for the portable container evaluation.
Referencing draft documents in an NCSA that was considered final was noted as a program weakness.
Criticality safety for this process was primarily provided by container size limitations and on administrative controls on interaction and container usage. The bases for safety identified in the contingency analysis were adequately captured in the limits and controls for the process and implemented in the field based on the implementation checklist.
i (3)
Conclusions j
i No significant technical issues were identified. However, a weakness was identified associated with the practice of using draft references to support the technical safety
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basis of a final evaluation. The criticality safety evaluation for portable containers i
provided an adequate basis for safe start-up and operation of the proposed production process.
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Laboratorv.
(1)~
Inspection Scooe The inspectors' reviewed the handling of uranium samples in the laboratory. The inspectors also verified that criticality safety limits and controls are adequate to minimize.
criticality risk in the laboratory operations supporting the 300 Complex.
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(2)
Observations and Findinas The inspectors reviewed NCSA 03-02-12, " Nuclear Criticality Safety Analysis for 105/302/303 Laboratory of the Production Fuel Facility." For operations with fissile material, samples would be passed directly from the production line through a double-door air lock to the laboratory complex. Products attributes would be tested and then eventually sent back to the production line or disposed of as waste. The safety of handling, storing, and disposing of fissile materialin the laboratory was based primarily upon adherence to administrative controls and limits.
The inspectors toured the laboratory to observe criticality safety practices. The i
inspectors observed that the floors were clearly marked with tape to identify the distinct boundary for sample carts. Work stations veere separated with a marked boundary to separate the adjacent stations with a buffer zone. Sinks had physical barriers to guard against accidental spillage of sample containers. Sample bottles were color-coded to identify the enrichment percentage. Geometry and volume of the sample containers were controlled to limit the mass and size. Limitations were placed on tha movement and storage of special nuclear material (SNM) in the laboratory. Work stations and j
workbenches were uranium mass limited. Waste products were disposed of into waste cylinders or waste drums, or to the drains to the dedicated waste collection tanks.
Samples were stored in dedicated containers called " rockets" with separation controls for the shelving to reduce interactions.
At the beginning of this inspection, the licensee indicated that the laboratory was not finished. The inspectors observed there were not any permanent nuclear criticality postings in the laboratory. This was due to the large number of postings that would have to be placed and then covered up. The licensee indicated that upon receipt of the license amendment authorizing operation of the naval fuel process, the permanent i
postings would be installed.
.(3)
Conclusions The inspectors determined that the handling of uranium samples in the laboratory was adequate to support safely the proposed operation. The laboratory relied extensively on administrative controls and permanent criticality postings were not yet posted in the laboratory; however, the licensee indicated that these postings would be in place when the laboratory was in use, e.
-Ventilation (1)
Inspection Scoce The inspectors walked down the ventilation ducts and reviewed the maintenance data on accumulation of uranium in the ducts. The inspectors also reviewed the duct geometry to insure that possible locations for potential uranium accumulation in the 300 Complex ventilation exhausts had been identified.
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-(2)
Observations and Findinas Standard Operating Procedures (SOP) 401, Section 11, " Monitoring and Servicing of i
Area Process Ventilation Systems," was the governing procedure for maintenance and monitoring the area process ventilation systems. The procedure included instructions for ventilation duct condensate handling and a ventilation duct clean out. The procedure required the nuclear criticality safety (NCS) staff to be notified if any SRE was found to be inoperable. Also, operators were required to report to the NCS staff any release into and out of the process ventilation collection columns and out of any process vessels.
The inspectors walked down the ventilation condensate drain line in the Building 300 Complex and determined that condensate could collect in the ventilation ducts from various process areas and outside air. The operators were required to check the condensate lincs at least once a day to see whether draining was required. The nondestructive assay (NDA) specialist was required to monitor for uranium accumulation in the ventilation ducts using gamma detection methods. The monitoring frequency was i
determined by coordination between NCS and Nuclear Material Control. The licensee permitted only qualified operators to make NDA measurements, l
Designated locations in the POG system were NDA scanned quarterly. Clean-out was j
required if the action limit of 175 grams U-235 is reached. NCS was to be notified if the limit was exceeded. In addition, the 300 complex scrubber system would be scanned weekly. The inspectors walked down the ducts in the Building 300 Complex and noted i
the existing locations and the newly marked designated locations for NDA. The j
inspectors concluded that the chosen locations of potential traps, sharp bends, and the converging points were adequate regarding the potential for uranium accumulations. In the review of NDA data taken in April 1999, the licensee stated that the data have been constant for the recent past with readings below the 175 gram limit.
(3)
Conclusions The inspectors determined that the ventilation ducts had appropriate and adequate NDA monitoring points to assure that fissile material accumulations would be detected.
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f.
Material Storaae (1) inspection Scope The inspectors reviewed NCSA 54X-99-0023 covering the South Rack Storage and NCSA 54X-98-0038 covering Vault Bin Storage. The inspectors also reviewed the proposed operations to confirm the overall adequacy of the evaluations and the proposed controls, and to ensure that the processes can be operated safely. Specific areas of inquiry included the adequacy and completeness of the criticality safety evaluations for anticipated operations, validity of the assumptions based on the existing system and the safety envelope identified in the draft Safety Evaluation Report (SER), appropriateness and adequacy of the proposed controls, and compliance with the double contingency principle.
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~(2)
Observations and Findinog l
South Rack Storage Area Operations The inspectors conducted walkdowns of the South Rack Storage Area with operations and criticality safety staff. During the walkdown, the inspectors were concerned with the concrete block partition walls en which some of the racks were placed. These partitions were four feet (ft) apart and were constructed of solid eight inch-thick concrete blocks, extending 9.5 to 13.5 ft high. No restraints to limit lateral motion of the partitions during minor earthquakes were noted. The licensee provided design information on these i
partitions to the NRC licensing function. Safety Conditions S-28 and S-29 were issued by l
the NRC licensing function requiring additional future evaluation and response by the
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l licensee.
No additional criticality scenarios were identified by the inspectors during these walkdowns. Selected controls identified in the NCSA were reviewed during the walkdowns to confirm their appropriateness and adequacy. The inspectors determined that these controls were adequate, South Rack Storage Area Analysis The inspectors reviewed Revision 1 of the South Rack Storage Area NCSA (NCSA 54X-99-0023, NCS-03-05-02, dated March 24,1999) which was a complete rewrite.
Review of the approaches taken in the revision to demonstrate subcriticality under normal and abnormal conditions were adequate, modeling assumptions were conservative, and controls adequate to assure safety of the storage configuration, Vault Bin Storage Area Operations The inspectors conducted walkdowns of the Vault Bin Storage Area with operations and criticality safety staff. No additional criticality scenarios were identified by the inspectors during these walkdowns. Selected controls identified in the NCSA were reviewed during the walkdowns to confirm their appropriateness and adequacy. The inspectors determined that these controls were adequate.
Vault Bin Storage Area Analysis The inspectors reviewed the NCSA for the Vault Bin Storage Area and found the analysis I
to be adequate. Review of the approaches taken to demonstrate subcriticality under
. normal and abnormal conditions were adequate and modeling assumptions were conservative.
l The analysis included an interaction analysis of both the South Rack Storage area and the Vault Bin Storage area. The interaction analysis was also performed using " Oak Ridge" concrete, which is assumed to contain 0.62 wt percent hydrogen. This concrete was more conservative than the actual NFS concrete. The effect of use of this concrete
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l 10 was less than in the South Storage Racks such that interaction was not significantly affected.
(3)
Conclusions A question was raised concerning whether the seismic response of some of the partitions supporting the storage racks were engineered to the seismic robustness of the remainder of the building. The licensee provided design information on these partitions to the NRC licensing function. Safety Conditions S-28 and S-29 were issued by the NRC licensing function requiring additional future evaluation and response by the licensee.
g.
Operational Assumotions (1)
Inspection Scooe The inspectors reviewed NCSA 54X-97-0010 which.u s concerned with the licensee development of bounding process vessel contents. The inspectors interviewed licensee criticality safety analysts to determine the adequacy of bounding content assumptions and confirm that in-place systems and operations were actually bounded.
The inspectors reviewed NCSA 54X-98-0013 concerning glass equipment and NCSA 54X-98-0021 concerning breaking or other damage to glass equipment. The inspectors also conducted walkdowns of the process equipment to confirm assumptions and review in-place controls.
(2)
Observations and Findinas Process Equipment Contents The licensee performed a parametric analysis to establish the bounding contents of proposed process operations. The licensee's model was conservative in mass content for all areas. The inspectors determined that the contents, as modeled, clearly bound the proposed operations that were observed during system testing.
Glass Equipment The content of glass equipment was certified by the vendor to be within required limits.
The licensee inspected glass equipment upon receipt to assure that dimensions were within required limits. The vendor also supplied the licensee with samples for destructive analysis. The inspectors determined that glass process equipment was doubly contingent against inadequate constituents because a failure of the vendor quality assurance along with the licensee receipt inspection would be required to compromise content assumptions.
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The inspectors reviewed licensee controls to prevent corrosive material from entering the glass process equipment. The inspectors also reviewed licensee configuration controls f
on the glass equipment such as piping configurations and elevations. Breaking of the
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11 glass or other damage to a single piece of glass equipment may release fissile material but will not result in exceeding the safety limit of k.d0.95 under credible circumstances; I
therefore, the glass equipment was doubly contingent against breaking or other damage causing criticality.
(3)
Conclusions The licensee process vessel content description used to develop limits and controls for the proposed 300 complex operations was adequately conservative such that operations were well bounded by safety basis assumptions.
The inspectors determined that control of glass equipment composition was assured by licensee controls so that adequacy of safety basis assumptions associated with the composition was assured. The inspectors also determined that the licensee has adequate double contingency protection against criticality occurring from damage to the glass equipment.
h.
Waste Tanks (1)
Insoection Scope The inspectors reviewed NCSA 54X-99-0027 and NCSA 54X-99-0030 which covered waste tanks and sump. The inspectors focused on the adequacy of controls for preventing inadvertent transfers of fissile material from process area waste streams into l
these unsafe geometry tanks. The inspectors performed walkdowns of the tank areas and transfer lines and observed a dual sampling operation. The inspectors evaluated the adequacy of the criticality safety limits and controls to support safe start-up and operation of the production process.
(2)
Observations and Findinas NCSA 54X-99-0027 The tanks collected waste from process areas and laboratory operations prior to transfer to the larger tanks. The tanks were 800-gallon, unsafe geometry vessels which were formerly filled with Raschig rings. The inspectors interviewed licensee analysts and i
production staff to determined the adequacy of controls used to replace tne Raschig l
rings. Two concerns existed for the tanks: (1) the inadvertent single transfer of a critical mass of fissile material, and (2) the inadvertent accumulation of a critical mass of fissile l
material in the tank due to multiple transfers. The inspectors determined that the nature l
of the proposed process and the types of controls employed by the licensee made the i
accumulation of material the higher risk scenario. In order to preclude accumulation, the licensee planed to wash and inspect the tanks after each transfer downstream. The washing process would be less effective with Raschig rings present so the licensee elected to remove the absorbers.
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12 The licensee relied on dual sampling of upstream transfer batches and an in-line monitor to prevent transfer of fissile material into the tanks. Also, a valve in the transfer line would block the transfer until sampling was complete. The inspectors observed sampling of a test batch and determined that licensee controls against inadvertent transfer were adequate.
NCSA 54X-99-0030 NCSA 54X-99-0030 covers the accumulation and staging of waste water in the tanks and subsequent transfer of this waste water to the site Waste Water Treatment Facility. The inspectors reviewed the evaluation and discussed apparent deficiencies with the plant NCS staff. Changes to the evaluation were generated to correct the identified deficiencies.
The bases for safety in the contingency analysis of the tanks were adequately captured in the limits and controls for the process and implemented in the field, based on the implementation checklist.
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Conclusions The criticality safety evaluations and resulting limits and controls for the tanks provided an adequate basis for safe start-up and operation.
1.
Waste Handlina l
(1)
Inspection Scope l
The inspectors reviewed NCSA 54T-98-0027 which concerned the handling and disposal of waste that was potentially contaminated with fissile materialin the 300 Complex. The inspectors interviewed criticality safety staff and walked down the waste assay and drum loading areas to determine that assumptions were valid and controls were available and reliable.
(2)
Observations and Findinas Potentially contaminated trash in the 300 Complex was disposed of in 5-inch diameter plastic bags which were assayed to determine fissile content and then packed into 55-gallon drums for disposal. The trash material was not compressed into the drums.
The licensee prohibited gross surface and liquid contamination in the 5-inch bags as the i
first barrier and considered the assay of each bag prior to loading into drums as the second barrier, thus providing double contingency protection against a criticality in the waste drums. Fissile material was limited to 175 grams per drum which assured that l
arrays of drums would always be subcritical.
The licensee stated that drum arrays with a uniform fissile material load would remain subcritical with 1050 grams per drum (over five times the limit) based on areal density calculation. The inspectors determined that the licensee has implemented adequate 1
(
L
. ~.
13 controls against introducing significant quantities of fissile material into drums such that the fissile material cannot become lumped in a manner that would violate safety basis assumptions. CriticaRy safety was, therefore, assured in the handling and disposal of fissile material contaminated dry waste.
(3)
Conclusions i
The licensee had implemented sufficient controls on the handling of dry fissile material contaminated waste to support the safe start-up of the proposed operations.
J.
Interaction (1)
Insoection Scope The inspectors reviewed NCSA 54X-98-0037 and proposed operations to confirm the overall adequacy of the evaluation and the proposed controls to ensure that the l
processes could be operated safely, and compliance with the double contingency principle.
(2)
Observations and Findinas The licensee provided the inspectors with NCSA 54X-98-0037 that evaluated the individual areas, the neutronic interaction for the total fuel production area, and the interaction between the specific areas. The neutron interactions were modeled both with l
and without a nominal 1-inch water reflection around the units. The analysis also showed I
that no statistically significant interaction between the individual areas were found. The l
methods, models, and approaches used to evaluate the interaction among the process l
areas in the main room appear reasonable. There was substantial margin of safety under i
normal conditions.
l 1
(3)
Conclusions The inspectors determined that the proposed 300 Complex operation would meet license conditions with regard to interaction between equipment during operations.
1 k.
Fire NCSA (1)
Inspection Scope The inspectors reviewed NCSA 54X-98-0027 which the licensee prepared to support the contention that fires were unlikely in the 300 Complex.
(2)
Observations and Findinos The inspectors noted that certain assumptions in the fire safety analysis were not I
adequately supported. An independent fire hazards analysis commissioned by the l
licensee indicated that a room-type fire was credible and recommended automatic l
l l
l
i
. ~.
i 14 suppression. Of particular concern to the inspectors was the potential for a criticality following a room fire and subsequent suppression efforts. Criticality safety was assured because the material volumes and equipment and floor designs were such that material could not accumulate to greater than a safe-slab height.
The inspectors were concerned about two potential scenarios. First, it appeared that process enclosures were designed such that more than a safe slab could accumulate if fire suppression water, even in the form of fog, were directed into the enclosures and the material had released. The licensee has committed to the NRC to install drain holes in the Area 300/400 enclosure to prevent the accumulation of more than a safe slab of material there. Secondly, it was not obvious where the mixture of fire suppression water and material might accumulate after being released onto the process area floor. The process area floor had been demonstrated to be adequately flat. It was not apparent, however, what might happen to combinations of fire suppression water and material during and after the fire and whether it would always accumulate in a safe manner.
Additional compensatory measures were required for fire safety prior to introduction of special nuclear material. The compensatory measures and requirement of additional supporting analyses were required by the NRC licensing function in Safety Conditions S-41 and S-42.
(3)
Conclusions Additiona' compensatory measures were required for fire safety prior to introduction of special nuclear material. The compensatory measures and requirement of additional supporting analysee were required by the NRC licensing function in Safety Conditions S-41 and S-42.
l.
Safety Related Eouioment (1) insosction Scope i
The inspectors performed a walkdown of SRE in the 300,400 and 500 process areas and reviewed the periodic testing of this equipment.
(2)
Observations and Findinos The inspectors conducted several field walkdowns of the 300,400, and 500 process areas and found that all SRE was properly labeled and easily identifiable. Numerous glass columns used in the process were not individually labeled but separate postings at the process clearly indicated that these columns were SRE.
Periodic tests for all SRE in the areas had been developed and implemented. The inspectors reviewed these tests and their established frequencies and concluded they were adequate to ensure the reliability and availability of the equipment to perform intended safety functions. Several minor discrepancies noted by the inspector were addressed and resolved by the licensee prior to the end of the inspection period.
I 15 All tests had also been placed in the computerized maintenance control system by the end of the inspection period. In addition, all testing had been succe : sfully completed within the required frequency.
(3)
Conclusions All safety related equipment for the 300,400 and 500 process areas were properly labeled. Periodic testing of this equipment had been developed and implemented and was adequate to ensure the reliability and availability of the equipment to perform i
intended safety functions.
3.
Plant Operations (88020) a.
Pioina and Instrumentation Diaarams (1)
Inspection Scope The inspectors performed a partial walkdown of the P&lDs for process areas 300,400 and 500 to determine the accuracy of the drawings as compared to the configuration of the equipment installed in the process.
(2)'
Observations and Findinas The inspectors performed a walkdown of the process areas 300,400 and 500 to determine the accuracy of the P&lDs. The walkdown consisted of a major portion of the each applicable drawing and each piece of equipment was highlighted on the drawing as the walkdown was completed. At the completion of the walkdown, the inspectors determined the P&lDs to depict accurately the equipment as installed within the system. However, the numbering system appeared to be confusing in that many of the valves, tariks, columns and other equipment items had the same number with only a different letter designation such as an "A", "B", or a "0" to differentiate between them. There were designators utilized to differentiate between the equipment items in the numbering scheme.
(3)
Conclusion The Process and Instrumentation Diagrams were found to accurately depict the process equipment and systems as installed, but the numbering system appeared to be confusing with the possibility for an operstor to operate the wrong piece of equipment.
b.
Procedure Reviews (1)
Insoection Scope The inspectors reviewed selected portions of the procedures for operating the 300,400 and 500 process areas to evaluate their accuracy and safety that would be provided to the operation of the process when properly utilized.
i-16 l
(2)
Observations and Findinos.
The inspectors review of selected portions of the procedures for operating the 300,400 I
and 500 process areas. The minor procedure discrepancies were brought to the attention of the process management and each issue was resolved.
.' onclusions C
(3)
?
The procedures reviewed by the inspectors for operating the Naval fuel process were determined to provide adequate instructions for a safe operation.
4.
Manaaement Oroanization and Controls (88005. 88010)
- a.
Manaaement Personnel Experience and Trainina (1)
Inspection Scope i
The inspector reviewed the management structure for operating the Naval fuel process.
Management experience and familiarization with the process were reviewed as part of the inspection scope.
(2)
Observations and Findinas The company Vice President responsible for the operation of the process had been extensively involved in the process during the previous operations of the facility and was familiar with all parameters involved in the development, equipment installation and material production. The Fuel Materials Manager, responsible to the Vice President for the process production and personnel supervision, was also involved in the management of the previous operation and had been involved in the equipment design, installation and
{
testing.
i The fuel process had been scheduled to operate on three shifts per day and five oays per
)
week. One shift supervisor per shift had been assigned to manage each shift operation.
and a second supervisor has been scheduled to assist on the day shift operation. All the shift supervisors had previous experience in the operation of the process and had been involved in procedure and drawing walkdowns and validations. In addition, the supervisors had been instrumental in the startup and checkout of the equipment to verify performance to design standards and instrumental in the development and performance of tests for SRE.
.The process engineers assigned to the area were involved in the design, startup, and preoperational testing of the process equipment. Design and process deficiencies that were revealed during testing were resolved to insure that product quality would be maintained throughout the process.
m s
l.
17 (3)1 Conclusions
'1 The management and engineers responsible for the operation of the Naval fuel process had adequate training and experience to manage the operation in a safe and productive manner.
b.
Ooerator Exoerience and Trainina
~(1)
Insoection Scope The inspectors reviewed cperator experience and training to determine the capability of the operators to safely operate the Naval fuel process.
(2)
Observations and Findinas
]
Several of the operators that were to be utilized in the Naval fuel process were involved in the startup and checkout of the equipment. Those activities included drawing and procedure walkdowns to verify their accuracy for depicting the as-built condition of the plant and operating the process safely. However, additional operators were required to operate the facility and those individuals were unable to obtain the experience as those involved in the initial plant startup and testing.
Training classes and on-the-job training was required for all operators involved in the j
operation of the Naval fuel process and must be completed prior to those individuals performing operator duties. This effort was not completed prior to the end of the inspection period and will be identified as an Inspector Followup Item, IFl 70-143/
99-06-01, Completion of Required Operator Training.
(3)'
Conclusions 1
Completion of operator training will be tracked as an inspector Followup Item.
- 5.
Fire Protection (88055) a.
Identification of Fire Hazards and Required Safety Controls for Areas 300 through 500
.(1)
Inspection Scooe'
~ The inspectors reviewed the licensee's identification and evaluation of potential fire j.
hazards. The inspectors also reviewed the adequacy of engineered controls that would
~ be relied on to minimize the potential consequences of a fire. The inspectors performed l
walkthroughs of Areas 300-500, conducted interviews with plant personnel, and reviewed licensee's ISA and fire hazards analysis (FHA).
7 L.
l1 L
I 18 l
(2)
Observations and Findinas l'
l.
Potential Fire and Consequences for Areas 300-500 The inspectors reviewed the licensee's ISA for Areas 300-500 and FHA prepared for the 300 Complex. The inspectors determined that neither the ISA nor the FHA had identified or discussed the potential fire hazards associated with the use of combustible materials in Areas 300-500. As a result, the licensee underestimated the overall combustible loading in Building 302 and did not identify the potential of a pool fire hazard. The inspectors identified this as a weakness. However, the inspectors noted that the major fire scenario described in the FHA would adequately bound consequences resulting from a pool fire involving combustible material and plastics found in Areas 300-500. As a result, the inspectors determined that the potential consequences of a fire involving Areas 300-500 were adequately captured in the FHA.
Engineered Fire Suppression System (s)
The licensee's FHA for the 300 Complex identified the concern for a significant combustible loading in Building 302, and recommended sprinkler protection to protect the entire building, with the exception of areas where moderation control for criticality safety was required. The inspectors noted that the FHA recommendation was consistent with requirements of National Fire Prevention Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Material, to install fire suppression -
system (s) to protect fire hazards associated with the use of combustible materials and material. However, at the time of this inspection, the licensee had not installed or committed to provisions for a fire suppression system in Areas 300-500. The inspectors determined that the level of fire protection was not adequate. The level of protection was contrary to accepted industry standards and NRC expectations for defense-in-depth protection for Areas 300-500. Additional compensatory measures were required for fire safety prior to introduction of special nuclear material. The compensatory measures and requirement of additional supporting analyses were required by the NRC licensing function in Safety Conditions S-41 and S-42.
(3)
Conclusions
. The licensee's FHA adequately captured the potential consequences of fire involving 1
- Areas 300-500, but were not addressed in the ISA.
Additional compensatory measures were required for fire safety prior to introduction of special nuclear material. The compensatory measures and requirement of additional supporting analyses were required by the NRC licensing function in Safety Conditions l
S-41 and S-42.
l-19 b.
.. Building 302 Smoke Detection System, Fire Walls, and Plant Fire Brigade J
(1).
Insoection Sqggg Th'e inspectors interviewed licensee's staff and walked down Building 302 to evaluate the installation of a smoke detection system anc' the integrity of fire walls. The inspectors i
also interviewed the licensee's fire brigade training coordinator to evaluate the adequacy of fire brigade training and readiness for emergency response to a fire in Building 302.
(2)
~ Observations and Findinas Building 302 Smoke Detection System i
The licensee indicated that the installation of the smoke detection system in Building 302 was near completion and a functional test of all smoke detectors and components would be performed prior to declaring the system operational. The licensee indicated that the i
j activation of any smoke detector would annunciate an alarm at the plant's secondary alarm station. The inspectors observed that 48 smoke detectors were installed for fire j
detection throughout the Building 302. The inspectors determined that the smoke I
detectors were adequately spaced and have accounted for NFPA 72, National Fire Alarm Code, requirements for high air flows expected in Building 302.'
Building 302 Fire Walls i
The licensee's FHA for the 300 Complex recommended the establishment of 2-hour fire barrier walls for Building 302. The inspectors observed that most wall penetrations had been sealed with fire resistant material that would prevent propagation of smoke or fire.
However, a number of penetrations remained to be sealed. The licensee indicated that all
- penetrations would be sealed in the near future to meet the expected license condition for fire barriers in the NFS license renewal.
Plant Fire Brigade Training and Readiness The licensee has established a fire brigade for initial on-site response to a fire. The licensee used volunteer employees to staff the fire brigade. Each fire brigade member received a 24-hour initial training. The licensee also provided quarterly 8-hour training in
- firefighting operations and conducted exercises to maintain and develop firefighting skills of the fire brigade members. The training also addressed plant procedure requirements to consult the plant Emergency Control Director prior to using water for firefighting in areas where SNM may be present. The inspectors determined that the fire brigade training was consistent with minimum requirements of NFPA 600, Standards on Industrial Fire Brigades. The inspectors also noted that appropriate protective equipment and self contained breathing apparatus for firefighting have been provided to the plant fire brigade.
The inspectors further reviewed the availability of fire brigade members to respond to a fire. The licensee indicated that the current membership on the fire brigade was 24. The licensee indicated that the targeted staffing of the plant fire brigade at any given time was i
l I
b
20 a minimum of eight. However, the licensee acknowledged that a weakness existed during the off-shifts (from 12:00 a.m. to 7:00 a.m.) when the staffing of the fire brigade was approximately four to five members. The ' licensee indicated that efforts were being taken to increase the fire brigade membership during the off-shift and that all fire brigade members have been instructed to request immediate off-site fire department assistance in the event of a fire. The licensee also indicated that the off-site fire department response would be relied on during the weekends when fire brigade members would not be available.
Due to the weaknesses of the plant fire brigade availability existed during the off-shift and weekends, the inspectors followed up the capability of the off-site fire department (s) to provide emergency response to a fire. The Unicoi County Southside Fire Department (UCSFD) was the nearest off-site fire department was located approximately 0.5 mile from the plant. The UCSFD indicated an average response time was approximately five minutes to the plant gate, after the receipt of a request for assistance. The UCSFD indicated that the off-shifts time period was their best staffed and was likely to have the greatest number of firefighters responding to a request for assistance. The UCFSD also indicated that other nearby fire departments (e.g., City of Erwin, other Unicoi County fire department, Johnson City, etc.) could respond under mutual aid agreements established among off-site fire departments. The inspectors determined that the nearest offsite fire department response would be timely and firefighting operations could be established within 15 minutes after the plant requested off-site fire department assistance. The inspectors determined that the weaknesses of the plant fire brigade staffing during the back-shift and lack of fire brigade members during weekends were adequately compensated by the close proximity of the UCFSD and the availability of other off-site fire department resources for assistance.
(3)
Conclusions The licensee continued to make progress in the installation of smoke detection system and establishment of 2-hour fire walls for fire protection of Building 302. The plant fire brigade was adequately trained for industrial firefighting and was adequately equipped for emergency response to a fire in Building 302.
6.
Radiation Protection (83822) a.
Insoection Scope The inspectors reviewed the status of implementing the licensee's radiation protection program to ensure that the necessary equipment and procedures were in place to support operation of the manufacturing process in process areas 300 - 500.
b.
Ooservations and Findinas The inspectors discussed with licensee representatives the operational readiness of the facility's radiation protection program to support the operation of the fuel manufacturing process. Although the licensee had installed additional stationary air
~.
21 samplers to collect and monitor radiological airborne data in the process area, the licensee will assign lapel air samplers to each operator and supervisor to monitor individual airborne exposure. For visitors in the process area, the licensee had planned to assign the supervisor's lapel air sampler result, adjusted for the time in the area. The inspectors verified that an adequate supply oflapel air samplers were available to support the operation.
The inspectors also walked down the various process enclosures and hoods in process areas 100-700 to verify that the licensee had identified the various hoods and enclosures and included them in licensee procedure NFS-HS-B-44, Process Enclosure Face Air Velocity Meas"ements, Revision 6, March 8,1999. Specifically, Attachment C of NFS-HS-B-44 ~,ncorporated the 26 enclosures in the process area. These enclosures l
were required to be maintained at a minimum average flow rate of 100 linear feet per minute. The licensee was required by the license application to perform the air flow measurement checks at least monthly.
The inspectors also reviewed the modifications to the building ventilation system to ensure that the occupied areas in the Building 300 complex would meet the building ventilation requirements specified in license application Section 3.2.2. At the time the previous fuel manufacturing process ceased operation, the licensee had identified that the 105/103 laboratory complex operated a pressure significantly lower than the adjacent 302 production area, causing infiltration from the production area into the laboratory. This condition was contrary to the requirements specified in Section 3.2.2 of the license application that air flow from less contaminated areas to more contaminated areas be maintained. At the time this problem was discovered, the measured air fiow deficit was approximately 7000 cubic feet per minute (cfm). The low air pressure in the laboratory complex was a result of a deterioration in the make up air capacity due to equipment i
failures and modifications in equipment operation intended to correct heating, ventilation and air conditioning problems. The inspectors discussed with the licensee the l
modifications that were made to the building ventilation system in order to maintain the 105/103 laboratory at a higher pressure. Part of the modification included speeding up the main laboratory air handling unit to 10,000 cfm. The licensee had also installed a remote building zone differential pressure (aP) panel at the entrance to the process area.
The three readouts monitored building 6Ps at three locations: (1) Building 304 to outside; (2) Building 302 to lab; and (3) Building 302 to entrance hallway. Section 3.2.2 of the license application requires that measurement checks be performed at least monthly to insure compliance with the occupied area ventilation requirements. With the addition of this 6P panel, compliance with this surveillance requirement should be straight forward.
During this inspection, the inspectors verified that the 105/103 laboratory complex was a greater pressure than the adjacent 302 production area.
c.
Conclusions There were no radiation protection start-up issues identified during this phase of the inspection. The inspectors concluded that the licensee was able to administer an j
effective radiological safety program.
l l
22 The licensee successfully modified the Building 300 complex ventilation system to insure that the air flow from less contaminated areas to more contaminated areas be maintained.
7.
Environmental Protection and Waste Management (88035 and 88045) a.
Insoection Scope The inspectors reviewed the licensee's environmental protection and waste management programs to ensure that the necessary equipment and procedures were in place to support operation of the manufacturing process in process areas 100 - 700 and to verify that those programs were in accordance with the (draft) SER.
b.
Observations and Findincs Based on discussions with licensee representatives, a review of procedures, and equipment, the inspectors noted that the licensee's existing waste management and i
environmental protection programs were sufficient to support operation of the manufacturing process in process areas 100 - 700.
The inspectors also noted that the licensee had installed two new above ground liquid waste storage tanks in December 1998. These tanks had a capacity of 6000 gallons each and were declared operational on April 5,1999. The licensee had discontinued the use of the two underground tanks due to criticality safety concerns. The licensee also indicated that the liquid waste delivery lines to the old underground tanks had been disconnected. The inspector noted that the removal and decommissioning of the underground tanks was not included in the licensee's five year operating plan. The licensee was aware of the decommissioning timeliness rule specified in 10 CFR 70.38(d).
Although the underground tanks will no longer receive high enriched uranium (HEU) waste from the Naval fuel process, at the time of this inspection, the licensee had not decided to cease principle activities associated with the underground tanks.
In addition, the inspectors reviewed with licensee representatives the anticipated amounts of each radionuclide expected to be released in airborne and liquid effluents and solid waste. In a letter dated June 8,1998 from NFS, Inc. (T. Baer) to NRC Office of Nuclear Materials Safety and Safeguards, the licensee documented the expected release rates and concentrations of radioactive materials in airborne and liquid release pathways for the Naval fuel process. After reviewing the data, there were no apparent indications that either the airborne or liquid effluents generated from the Naval fuel process would involve a change in the type of radioactive effluents released. in addition, the quantities of airbome and liquid effluents expected to be generated did not represent a significant change in the quantity of effluents previously released off site. The estimated volume of solid radioactive waste expected to be generated during the operation of the Naval fuel process was 170 cubic feet per month. The licensee did not expect to generate hazardous waste from the process.
The inspectors also reviewed the (draft) Renewal SER dated May 10,1999 and verified that the licensee's effluent and environmental monitoring programs were as described in
L 23 the aforementioned document. Basically, the licensee had already developed effluent and environmental monitoring programs to establish a basis for evaluating potential health impacts, to comply with NRC regulatory requirements, and to identify mitigative measures as appropriate.
c.
Conclusions The inspectors reviewed the effluent and environmental monitoring programs and determined that they would provide reasonable assurance that effluents to the environment would be less than regulatory limits and that any significant impacts of plant emissions on the surrounding environment would be adequately quantified.
8.
Review of Previously identified Issues (92701,92702) j a.
Inspection Sco.p_e The inspectors reviewed actions taken by the licensee to address the following items and to verify that the corrective actions, if applicable, were adequate, and had been completed.
b.
Observations and Findinas (1)
(Closed) IFl 70-143/98-03-03: Review licensee's ability to maintain the fire protection valves in the pit vaults in reliable and credible condition.
The licensee evaluated the accumulation of water on fire protection valves in pit vaults located in the northwest and northeast section of the plant. The licensee pumped water from the pits, examined the conditions of the valves and piping, and performed preventive maintenance to assure that the fire protection valves were functional. The licensee indicated that inspection of the valve pits wou:d be conducted quarterly to verify conditions and operability of the fire protection valves. The licensee indicated that the availability of two sources of water supply and other water supply isolation valves would maintain the continuity of water supply for fire protection in the event of a failure at a valve pit. The inspectors concluded that licensee's commitment to increase inspection and maintenance, including replacement of valves and piping as warranted, was adequate.
The inspectors concluded that the water supply for fire protection at the plant would not be significantly degraded in the event of single break. No further issues were identified.
This item is considered closed.
(2)
(Closed) IFl 70-143/99-02-01: Program implementation of NCS Requirements.
This item tracked program implementation of NCS requirements. The inspectors reviewed the latest versions of the NCS program procedures. These included NFS-GH-61, " Nuclear Criticality Safety Program," NFS-HS-A-62, " Implementation of Nuclear Criticality Safety Evaluations," NFS-HS-A-58, " Nuclear Criticality Safety Evaluations," NFS-GH-44, " Guidelines for Implementing Internally Authorized Changes (IACs)," NFS-HS-A-63, " Verification and Validation of Nuclear Criticality Ssfety Analysis
T 24 Codes," and NFS-GH-43, " Safety-Related Equipment Control Program." The procedures were reviewed against the commitments in the license. Based on this review, it appeared that the revised program procedures addressed the activities conducted by the Criticality Safety Function as required by the license. This item is considered closed.
(3)
(Open ) IFl 70-143/99-02-02: Review the process for performing code validations and maintaining configuration control of the code.
This item tracked completion of the process for performing code validations and maintaining configuration control of the code. The inspectors reviewed a specific-use validation for criticality calculations using a special neutron absorber. This validation utilized 17 benchmark cases that included the absorber and highly enriched uranium in a form and configuration similar to the production process application. In the previous inspection, the inspectors noted that failure to validate the code for application to this absorber was an example of inadequate definition of the area of applicability for the criticality code. The specific-use validation for the absorber appeared to demonstrate that the code cculd be used to adequately model the reactivity of configurations using this material. Thus, the deficiency related to use of this absorber identified in the previous inspection was resolved. While this specific vulnerability has been addressed, generation of this specific-use validation did not resolve the original issue of failure to provide adequate technical support for calculation of the code bias and for definition of the area of i
applicability of the code. Discussions with the NCS staff and confirmatory analysis of the benchmark data did not identify any cases where a safety limit based on criticality safety calculations would be exceeded. As a result, this does not represent a start-up issue for the proposed production process. However, the current code validation still fails to comply with the license requirement to describe the area of applicability. Specifically, the area of applicability was overly broad and extensions of benchmark data were not technically justified. This item remains open.
(4)
(Closed) IFl 70-143/99-02-03: Review the structural issue concerning the steel support columns and the floor flatness.
Part of the issue of IFl 70-143/99-02-03 was structural supports for the process vessels.
The structural supports prevent the risk of criticality by maintaining the separation between process vessels. The other issue was floor flatness, which was reviewed and closed in Report 70-143/ 99-05, Section 6.b.(9).
In this inspection, the inspectors walked down the equipment to confirm that final installation was in accordance with as-built drawings. Also, inspectors reviewed documents, to verify the soundness of the technical justifications,54T-98-0109, NCS-03-02-32, " Nuclear Criticality Safety Analysis for the Structural Integrity of Column and Enclosure Supports and Ficsile Material Storage Racks of the 300 Complex,"
Revision 0.
The structure comprised cross supports of the process vessel bearing plates and vertical legs. The cross supports and vertical legs were secured to the floor with at least two
e s.
e
..j 25 1
bolts. The slip-on structural fittings were used to secure the cross supports to the legs.
All supports were fabricated in accordance with approved drawings.
The licensee had established a design safety factor of three at the normalloads and a design safety factor of one at the credible accident loads. The licensee used trained and certified construction personnel in installing the structural supports. The licensee engineering staff provioed the oversight during equipment installation and pre-operational I
functional testings to ensure proper functioning. In addition, the nuclear criticality safety inspections were required to insure that the equipment was installed in accordance with the applicable nuclear criticality safety requirements.
The inspectors determined that the licensee had installed the structural supports adequateiy in accordance with the approved drawings, and designed the structural supports with adequate safety margins. This IFl item is considered closed for the structural supports.
- (5)
(Closed) IFl 70-143/99-05-01: Review process equipment cooling water system with respect to leakage of water into the 601 process vessel or elevator pit.
This item tracked the interaction of the process cooling water system with the 600 area process vessel. The process cooling water system was not available for review during inspection 99-05 even though it's effect on the 600 area process vessel was covered by the 600 area Nuclear Criticality Safety Evaluation (NCSE). The inspectors reviewed the cooling water system interface with the 600 area and determined that assumptions and conclusions regarding the safety of the equipment were valid. The 600 area process vessel can be safety operated within the established safety basis. Therefore, this item is closed.
(6)
(Closed) IFl 70-143/99-05-02: Review the licensee's revised spilled materials nuclear criticality safety evaluation prior to process startup.
This item tracked upgrades to the criticality safety evaluation for released materials. The inspectors reviewed the corrective actions taken to address the quality problems associated with the released material evaluation, NCSA 54X-98-0041. The NCS staff provided page changes to the NCSA. These changes included corrections to the hazard evaluation to ensure that the limits and controls are consistent with the double contingency arguments. A description of the vacuum cleaner to be used for housekeeping in the process area was added. Additionally, the double contingency arguments were modified to remove weaknesses involving a comparative analysis using critical experiment data. The inspectors concluded that these modifications resolve the open issues identified during the previous inspection. The criticality safety evaluation for released materials now appears to provide an adequate basis for safe start-up and operation of the fuel production process. Therefore, this item is closed.
1 26
]
(7)
(Closed) IFl 70-143/99-05-03: Review the ventilation, fire suppression, and open container transport systems as they pertain to the 600 and 700 process area equipment.
The inspectors had determined that several criticality-safety significant areas interrelated to the 600 and 700 area processes were not ready for inspection during the May 3-9, 1999, inspection. These areas included the ventilation, fire suppression, and open container transport systems. Several of the NCSAs reviewed during that and previous inspections also listed items considered open at the time and required closure prior to startup of the process. Each of these systems could have direct impact on the operational assumptions and process area equipment.
During this inspection, the inspectors reviewed the exhaust ventilation system NCSA and found it to be adequate. The inspectors also reviewed the open container transport j
issues and found that the licensee had prepared an NCSA on portable containers. This NCSA was reviewed during this inspection and found to be adequate. The inspectors discussed the fire suppression systems with licensee staff. The systems for fire suppression or mitigation have not been finalized. This area will be reviewed during subsequent inspections. For tracking purposes, this item will be closed.
(8)
(Closed) IFl 99-05-04: Review SOP-401 to ensure that operators physically verify the operation of the automatic valves to shut off the flammable gas supply to the 600 processing area.
The inspector reviewed SOP 401, Revision 2, dated May 21,1999, and verified that the procedure had been revised to include independent verification of the flammable gas supply closure. This procedure was also revised to include a requirement for immediate notification if water or SNM is found around the elevator pit. This item is closed.
(9)
(Closed) IFl 70-143/99-05-05: Review the licensee's additional testing and verification of SRE related to preventing fires or explosions in the 600 process area prior to process startup.
The licensee performed additional tests to verify the switching of electrical power from primary to backup electrical power and the automatic shutoff of a flammable gas control valve upon the loss of primary electrical power. The tests were completed on May 25, 1999. The licensee also indicated that alarm indication for detection of flame-out condition for the 600 Area process equipment was not SRE, and SRE documentation of functional testing was not required. No further issues were identified. This item is considered closed.
c.
Conclusions Based on observations and reviews, the licensee's actions were appropriate for closure of the applicable open items noted above. As noted above, one item remained open pending licensee completion of certain actions.
4
e
.a 27 9.
Exit Meeting The operational readiness inspection scope and results were summarized on June 18, 1999, with those persons indicated in the Attachment. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report. No dissenting comments were received from the licensee.
I
I ATTACHMENT 1.
Partial Listina of Persons Contacted Licensee Personnel
- G. Athon, Director, Technical Services T. Baer, Vice President, Safety and Regulatory L. Bagby, Process Operator
- C. Brown, Materials Manager B. Clouse, Health Physicist i
A.' Cure, Health Physicist
'J. Drake, NFS Planning
'B. Drane, Engineering Director
'R. Droke, Safety Director
- D. Ferguson, President and Chief Operating Officer B. Fore, SRE Testing Engineer J. Greene, Environmental Safety Manager
~K. Guinn, Vice President / Principal Scientist D. Hopson, Nuclear Engineer i
- C. Hrabal, Nuclear Criticality Operations Manager T. Huston, Health Physicist
'R. Kegley, Plant Facilities Director W. Lewis, Facility Manager
'R. Maurer, Nuclear Criticality Safety Engineer C. Miller, Nuclear Criticality Safety Engineer
'R. Montgomery, Nuclear Criticality Safety Manager
'M. Moore, Director Environmental and Health Physics J. Nagy, Health Physics Manager
- J. Parker, industrial Safety Manager F. Peters, Director, HEU Operations J. Poole, Fire Protection Engineer "J. Stout, Security Director
'G. Tapp, Industrial Safety Specialist
- S. Walker, Training Manager "C. Woodhall, Vice President of Technical Development NRC Personnel
- D. Collins, Director, Division of Nuclear Materials Safety (Rll)
- 7. Cox, Project Manager, Fuel Cycle Licensing Branch (NMSS)
- C. Emeigh, Chief, Fuel Cycle Licensing Branch (NMSS)
'J. Olencz, Fuel Cycle Operations Branch W. Smith, Fuel Cycle Operations Branch
- D. Whaley, Fuel Cycle Operations Branch
' Indicates those attending the exit meeting on June 18,1999.
1 2
2.
Insoection Procedures Used IP 83822 Radiation Protection IP 88015 Criticality Safety-IP 88020
- Plant Operations IP 88025 -
Maintenance / Surveillance' iP 88035 Waste Management IP 88045:
Environmental Protection IP 88055 -
Fire Protection IPs 88056-88068 Chemical Safety IP 92701 Review of Previously Identified Follow-up Items IP 92702 Review of Previously Identified Violations 3.
List of items Ooened. Closed. and Discussed item Number Status Description and Discussion 70-143/98-03-03
.C!osed IFl; Review licensee's ability to maintain
. the fire protection valves in the pit vaults in reliable and credible condition (Section 8.b.1).
70-143/99-02-01 Closed IFl: Program implementation of NCS requirements (Section 8.b.2).
70-143/99.-02 Open IFl: Review the process for performing code validations and maintaining configuration control of the code (Section 8.b.3).
70-143/99-02-03 Closed IFl: Resolve structural issue concerning the j
steel support columns and the floor flatness (Section 8.b.4).
70-143/99-05-01 Closed IFl: Review process equipment cooling water system with respect to leakage of j
water into the 601 process vessel or elevator i
pit (Section 8.b.5).
'70-143/99-05-02 Closed IFl: Review the licensee's revised spilled materials nuclear criticality safety evaluation prior to process start-up (Section 8.b 6).
70-143/99-05-03 Closed IM: Review the ventilation, fire suppression, and open container transport systems as
3 they pertain to the 600 and 700 process area equipment (Section 8.b.7).
70-143/99-05-04 Closed IFl: Review SOP-401, Section 6 to ensure that operators physically verify the operation of the automatic valves to shutoff the flammable gas supply into the 600 process area (Section 8.b.8).
70-143/99-05-05 Closed IFl: Review the licensee's additional testing and verification of SRE related to preventing fires or explosions in the 600 process area prior to process start-up (Section 8.b.(9)).
70-143/99-06-01 Open IFl: Completion of Required Operator Training (Section 4.b.(2)).
4.
List of Acronyms Used CFR Code of Federal Regulations FHA Fire Hazard Analysis HEU High Enriched Uranium IFl Inspector Followup Item ISA Integrated Safety Analysis k,
Effective multiplication factor MSDSs Material Safety Data Sheets NCS Nuclear Criticality Safety NCSA Nuclear Criticality Safety Analysis NCSE Nuclear Criticality Safety Evaluation NDA Nondestructive Assay NFPA National Fire Prevention Association NFS Nuclear Fuel Services, Inc.
NRC Nucicar Regulatory Commission ONMSS Office of Nuclear Materials Safety and Safeguards ORR Operational Readiness Review P&lDs Process and instrumentation Diagrams PFA Perfluoroalkoxyaikane copolymer POG Process off-gas Rev.
Revisicn Ril Region !!
SER Safety Evaluation Report SNM Special Nuclear Material SOP Standard Operating Procedure SSRC Safety and Safeguards Review Committee SRE Safety-related equipment UCSFD Unicoi County Southside Fire Department I
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