ML20211F369
| ML20211F369 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/17/1987 |
| From: | Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8702250064 | |
| Download: ML20211F369 (5) | |
Text
m..
& b-FEB 171987 MEMORANDUM FOR:
W. T. Crow, Acting Chief Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety-FROM:
Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety
SUBJECT:
OPERATIONAL SAFETY ASSESSMENT OF BABC0CV,& WILC0X (B&W)
COMMERCIAL NUCLEAR FUEL PLANT (CNFP, DOCKET NO.
70-1201) FEBRUARY 2-6,.1987 I..
Purpose The purpose of the in-depth assessment is to review all safety aspects of the operations of. licensed fuel fabrication facilities and to detennine the operational effectiveness.
Based on " lessons learned" from the January 4,1986, rupture of the uranium hexafluoride cylinder at the Sequoyah Fuels Corporation Facility near Gore, Oklahoma, a recommendation-was made to review the non-nuclear (e.g., fire protection and process) as well as the nuclear (e.g., radiation, nuclear criticality, and process) safety of the operations at uranium fuel cycle facilities.
II. Review Team Members of the assessment team were:
A.
Region II - NRC 1.
Gerald L. Troup, Team Leader 2.
Anne Tabaka, Radiation Safety Specialist (Emergency Contingency Planning) 3.
Gerald Wiseman, Fire Protection Engineer (Fire Protection)
B.
Headquarters - NRC 1.
Douglas Sly, Office of Inspection and Enforcement (Management Controls) 2.
Norman Ketzlach, Nuclear Criticality Safety As a team, we met with B&W nanagement, as well as those more directly involved in the operations. This report will deal with those contacts that are more directly related to the nuclear criticality safety assessment.
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W. T.~ Crow 2
III. Personnel Contacted 1.
W. T. Engelke, Manager, Qualii.y and Safety 2.
K. E. Shy, Health Physicist 3.
J. T. Ford, Manager, Fuel Manufacturing -
IV. Plant Operations A tour was made of the areas covered by the SNM-1168 license. The areas included the fuel fabrication facilities using uranium oxide pellets as starting material and the storage of UF cylinders and uranium oxide 6
powder and pellets for outside customers.
All fuel fabrication operations were identified with work and storage station limit signs, and procedures for each step of the operation were available to the operators. Several poor practices were noted and will be discussed under Nuclear Criticality Safety (functional assessment and the adequacy of controls).
V.
Nuclear Criticality Safety A.
Analyses The prccess for approval of procedures and changes thereto were reviewed. The following observations were made:
Pre-operational safety evaluation package records were found to be complete and included:
a.
Pre-operational reviews and approvals Analyses made by Health-Safety)and/or the Nuclear b.
Criticality Safety Group (NCSG c.
NCSG evaluttions included those made by the cualified independent reviewer d.
License amendment and related Safety Evaluation Report (when license amendment required)
In some cases, the Health-Safety Supervisor has been authorized to perform, without NCSG approval, specific nuclear criticality safety evaluations (e.g., based on approved surface density criteria) before implementing the results of the analysis. The NCSG had informally informed the Health-Safety Supervisor to have a second party indepen-dently " check the arithmetic" before the results of calculations are implemented. Recent Health-Safety surface density calculations made were not initialed by a checker although the Health-Safety Supervisor stated the checker had not only reviewed the calculations but also the applicable drawing indicating the layout of the proposed work station locations. Since the NCSG may not review the calculations and analysis until his next quarterly review (as much as 3 months may pass before the NCSG checks the results) and the guidance for the Health-Safety Supervisor for determining the analyses he is authorized
W.-T. Crow 3
to make is not clearly defined, it is recommended a procedure be pre-pared and approved by the NCSG that specifies the analyses the super-visor is authorized to perform without NCSG approval prior to imple-menting the results, the quality assurance requirements for checking the calculations, and the confirmation requirements for checking the calculations.
The Safety Review Board (SRB) Procedure (AS-1134) specified the organization making the reviews as well as the review and approval process related to nuclear criticality and radiation safety. However, the review requirements for hazardous chemicals are not included.
It is recommended the SRB review and approve procedures for the handling and storage of hazardous chemicals similar to the procedures it uses for handling and storing radioactive materials (including SNM).
B.
Fuel Handling and Storage Procedures There was an inconsistency in the instructions located in the work areas for fighting fires.
No fire hoses are allowed in the fuel rod assembly and fuel assembly storage areas. However, the use of a single hose may be authorized by a knowledgeable management represen-tative of the plant emergency response organization.
In the fuel assembly storage area, instructions require approval by supervision.
In the fuel rod assembly area, approval by Health-Safety is required.
There should be a consistency between the approval requirements for the use of a fire hose, where otherwise prohibited, between the fuel rod assembly and fuel rod storage areas and the license condition.
It was also noted that Con-Yankee " skeletons" (containing no SNM) were stored in the aisles between fuel assemblies (at an elevation no higher than the bottom of the fuel in the assembly) and within the rows of assemblies (where fuel assembly storage is authorized). There was no approved written procedure for such storage.
It is not con-sidered good practice to store materials in the aisles of fuel assembly storage arrays, certainly without a written approval.
It is recommended that if no other location for the storage of the non-SNM materials is found, a review of the materials to be stored be made, nuclear criticality safety criteria (e.g., materials to be stored, storage locations within the array) be developed to be sure no potential hazard is introduced (e.g., introduction of moderation), and procedures be written and approved before their implementation.
Safe transport carts are used for fuel rods, poison rods, and fuel rod trays (with or without fuel rods).
It is recommended a procedure be developed for the multipurpose use of safe carts with no more than one type material on the cart at any given time.
For example, stacking fuel rod trays no higher than four high whether loaded or unloaded would remove the nuclear criticality safety concern.
The Health-Safety audit procedure (AS-1125, Rev. 6) references Exhibit A as the form being used by the outside CNFP independent
O W. T. Crow 4
auditor when in fact it is not used by him.
Exhibit B, however, for use in reporting Health-Safety weekly audits is not mentioned in the procedure text.
It is recommended this audit procedure be rewritten so that it reflects CNFP practices, as well as meets CNFP and NRC requirements.
C.
Audits and Inspections A Health-Safety technician performs a daily inspection of the facility (for conformance to both radiation and nuclear criticality safety operating procedure requirements). Reports of his findings, as well as the weekly safety audit reports prepared by the Health Physicist and the quarterly audit reports prepared by a member of the NCSG (Lynchburg Research Center), were reviewed.
The inspection and audits made met the requirements of the license.
It was noted, however, the NCSG audits do not include a review of the Health-Safety supervisor's weekly audits.
It is recommended the quarterly NCSG audits include a review of the weekly audits to assist the group ir, determining whether there are any trends that may compromise nuclear criticality safety.
The quarterly audits reviewed (2/28/85-11/17/86) contained no recom-mendation for corrective action (none were required). However, a review made of action taken on a recommendation made in a quarterly independent health physics audit indicates prompt action taken on the recommendation.
Documentation on the action taken was submitted to the Plant Manager. The latter's comments on the action taken were reported to the individual responsible for taking the corrective action. However, a copy of the report on the action taken should be given to the independent reviewer making the recommendation so the latter can provide assurance that his recommendations have not been risinterpreted.
VI. Accident Scenarios It is difficult to develop a practical criticality accident scenario.
All operations are performed dry and the license limits the SNM to 44.05 percent U-235 enrichment (except for up to 100 gm contained U-235 oT any enrichment used for analytical purposes and for UF storage which may g
have a U-235 enrichment up to 5.0 percent).
Unmoderated U-235 enriched fuel having an enrichment no greater than 5.0 w/o cannot be made critical independent of quantity and/or configuration.
VII. Recommendations I.
A procedure should be prepared and approved by the Nuclear Criticality Safety Group (NCSG) that specifies the analyses the Health-Safety Supervisor is authorized to perform without NCSG approval prior to implementing the results, the quality assurance requirements for checking the calculations, and the confirmatory requirements for checking the calculations.
O W. T. Crow 5'
2.
The Safety Review Board (SRB) should review and approve procedures for the handling and storage of hazardous chemicals similar to the procedures it uses for handling and storing radioactive materials (including SNM).
3.
A review should be made of the instructions for receiving authoriza-tion to use fire hoses (where otherwise prohibited) to fight fires, and the authorization requirements standardized.
4.
A review should be made of the storage requirements for non-SNM materials and if storage between or inl place of SNM units in storage arrays is necessary, nuclear safety criteria (e.g., materials to be stored, storage locations, and positions within the array) should be developed to ensure no potential hazard (e.g., introduction of modera-tor materials), and procedures should be written and approved before their implementation.
5.
Review the multipurpose use of safe transport carts for need of a procedure to remove the possibility of their misuse (e.g., for combination use of a safety cart for loaded and unloaded fuel rod trays).
6.
The Health-Safety Audit Procedure (AS-1125, Rev. 6) should be revised to reflect CNFP practices as well as CNFP and NRC requirements.
7.
The NCSG quarterly audits should include a review of the weekly Health-Safety supervisor's audits to determine that trends are not developing that may compromise nuclear criticality safety.
8 Consideration should be given to providing a copy of the memorandum to the independent auditor (NCSG and Radiation Safety) on the correc-tive action taken on recommendations made based on the quarterly audit.
Original signed By:
Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety DISTRIBUTION IDocketz70 120 C VLTharpe Region II SH0 NMSS R/F NKetzlach/(2)
GLTroup, RII FCUP R/F DSly, IE PDR OFC: FCUP
- FCUF NAME:NKettlach/as:VOTharpe:
DATE:2/f7/87
- 2/ \\h87:
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