ML20212R149

Insp Rept 70-1100/86-04 on 860818-22.Violations Noted: Failure to Check Quarterly Operation of Fire Door on Virgin Powder Storage Area Under Power Failure Conditions & to Conduct Nuclear Criticality Safety Evaluation for U Rods

ML20212R149
Person / Time
Site:	07001100
Issue date:	01/16/1987
From:	Blumberg N, Craig Gordon, Keimig R, Ketzlach N, Krasopoulos A, Mcfadden J, Roth J, Sly D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212Q990	List: ML20212Q988 ML20212R004 ML20212R149
References
70-1100-86-04, 70-1100-86-4, NUDOCS 8702020516
Download: ML20212R149 (33)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-1100/86-04 Docket No. 70-1100 License No. SNM-1067 Priority 1 Category ULFF

- Licensee: Combustion Engineering, Incorporated P.O. Box 500

Windsor, Connecticut 06095 Facility Name: Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor, Connecticut Inspection Conducted: August 18-22, 1986 Inspectors: [x f20"[k- ///M 7 l J. th,' Project Engineer, RI ' date

--c Y } 5~ k'7 N. . Blumberg, Leud Reactor Engineer, RI dat'e A.'

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G.'Krasopoulos, Reactor Engineer, RI IIHf0?

' da t'e

},M hy C. (W. Gordo'n, Emerfency Preparedness

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' date 1pecialist, RI

. bNdbEWWW

. R. McFadden,, Radiation Specialist, RI t'

/ date

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/!/J. &7 1 aP N. (4tzlach, LicensAng Project Manager, date' NMSS

,ll8 by ///f 7 D. g,' Sent'or Hea J1' Physicist, IE dater

. G w/ /-is J'7 4

4 R. R. Keimig Chief,, feguards Section, RI date Approved by: .

/ / - /4 -#7 R. R. Keim ~,' Chief y eguards Section date

/- Division of Radi ti n Safety & Safeguards 8702020516 870121 PDR 3

C ADOCK 07001100 1

PDR

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Inspection Summary: Inspection on August 18-22, 1986 (Inspection Report No.

70-1100/86-04)

Areas Inspected: Special, announced inspection by a team composed of Region I and headquarters personnel to review conditions at the licensee's facilities to determine whether there are potential safety hazards that, when combined with routine facility operations, could impact upon public health and safety.

Results: Two violations of NRC requirements were identified. In addition, 38 observations were made that resulted in 23 recommendations to improve safety conditions at the Windsor site. Violations: failure to check quarterly the operation of the fire door on the virgin powder storage area under power failure conditions, (Paragraph 5f(1)); and failure to conduct a nuclear criti-cality safety evaluation for the storage of natural uranium rods on top of a safe slab in the Building 2 vault, (Paragraph 5f(1)). A summary of the safety observations and recommendations is contained in Paragraph 3 of the report. >

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1 Details 4

1. Persons Contacted .

• H. V. Lichtenberger, Vice President-Manufacturing

• • G. H. Chalder, Plant Manager, Nuclear Fuel Fabrication P. Hubert, Manager, Engineering

, G. Kersteen, Manager, Production and Materials Control j G. Buddenhagen, Pellet Shop Supervisor G. E. Cody, Manager, Facilities and Engineering Services j **R. Sheeran, Manager, Nuclear Licensing, Safety, Accountability and

] Security j J. Vo11aro, Supervisor, Health Physics and Safety j J. Limbert, Radiological Engineer G. Palmer, Process Engineer l  !

• Present at exit interview

• • Present at entrance and exit interview

Other employees were also interviewed during the course of this review.

l 2. Background J

As a result of the accident involving the release of uranium hexafluoride from Kerr-McGee's Sequoyah Fuels Facility in Gore, Oklahoma, on January 4, 1986, the NRC decided to conduct an operational safety review at selected fuel cycle and byproduct material facilities. The scope of the review, as outlined below, is defined in the Office of Inspection and Enforcement's i

Temporary Instruction No.2600/1 " Inspection of Plant Operations at Uranium Fuel Fabrication and Conversion Facilities".

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The operational safety review is designed to evaluate existing conditions at each facility and to determine whether there are potential safety hazards that, when combined with facility operations, could impact upon public health and safety. Further, the review will assist the NRC in <

j determining if additional license conditions are needed to deter such

impact. The review team determines whether the licensee has systems and procedures in place to identify and correct in plant industrial safety

• i problems that could result in radiological safety consequences, and i determines whether the licensee is adequately implementing those proce-dures which exist to prevent or mitigate such problems. The areas ,

reviewed include personnel training, waste management, and facility i operations, and encompassed procedure control, equipment maintenance,

non-radioactive chemical control, fire protection, and emergency planning.

1 Upon completion of the review, based upon observations made during the i review, recommendations were made to the licensee. Those observations

and recommendations will also be forwarded to the appropriate NRC Program Offices for their consideration in effecting program changes.

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3 The operational safety review of the nuclear fuel manufacturing facility of Combustion Engineering, Windsor, Connecticut was conducted from August 18-22, 1986. A summary of findings, including general observa-tions, recommendations and violations, is provided in paragraph 3. A detailed discussion of each area reviewed is presented in paragraphs 4, 5, and 6.

3. Summary of Observations, Recommendations and Violations In general, the NRC review team found that the licensee had adequately addressed the procedures, training, work control, contingency planning and overall management controls required by the NRC facility license.

However, very little evidence was found that the licensee had considered the need for a formal industrial and fire safety program at the Windsor Site. The review team considers that this is due to a lack of corporate or divisional policies in this regard. Thirty-eight observations were made that resulted in 23 recommendations to improve management controls over facility operations, general facility safety, equipment safety, fire safety and emergency response to incidents involving radioactive and l non radioactive hazardous materials. Two violations of NRC requirements were also identified.

a. Observations Observations concerning the operations, facilities, equipment, and procedures examined are as follows:

(1) Chemical, Explosion, and Fire Safety (a) The Review Team did not identify a chemical, explosion or fire hazard associated with facility operations that could result in a significant impact on public health and safety.

However, a minor impact on public health and safety could occur from a fire involving uranium oxide powder, or an explosion of the anhydrous ammonia tanks on site, with or without the involvement of uranium oxide powder. Paragraph 4.a.

4 (b) There does appear to be a potential for a significant i impact on workers in the manufacturing facility (Building 17), and in other facilities on the Windsor Site, from the hazards indicated in (1)(a) above. Paragraph 4.a.

(c) The anhydrous ammonia tanks, adjacent to Building 17, appear to be the largest single source of toxic chemicals on the Windsor Site. They are also in close proximity to I

radioactive material (uranium oxide powder) and pyrophoric material (zircalloy chips). Paragraph 4.d. and e.

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4 (d) The storage of zircalloy machining wastes (swarf and turnings) near Building 17 is a significant fire hazard in close proximity to radioactive materials (uranium oxide powder). Paragraph 4.e.

(e) There are no procedures for the control of flammable and combustible materials used in Building 17. Paragraph 5.f.(2)(b).

(f) Fixed fire extinguishing system sprinkler heads in the Building 17 Pellet Shop are not installed to NFPA-13 standards. Paragraph 5.f.(2)(d).

(g) Portable fire extinguishers in Building 17 are not easily accessible or strategically located. Paragraph 5.f.(2)(d).

(h) An incorrect emergency telephone extension number was posted in the zircalloy machining area of Building 17. ,

Paragraph 4.b.

(i) Zircalloy machining wastes are retained in large containers during machining operations, at the machining site. Paragraph 4.e.

(j) The Windsor Site fire brigade was disbanded in 1982.

Paragraph 5.f.(2)(c).

(k) Generally, explosive gas cylinders are not protected from exposure to the elements on the Windsor Site. Paragraph

5. f . ( 3) .

(1) Generally, outside storage areas for hazardous liquid materials do not provide for confinement of spillage or leakage on the Windsor Site. Paragraph 5.f.(3).

(2) In'dustrial and Radiological Safety (a) Specific industrial safety policy / procedures do not exist (except for toxic wastes) and requirements are not included in manufacturing operations procedures. Paragraphs 4.a.

and 5.b.

(b) The ambient temperature in the Building 17 Pellet Shop is excessively high. Paragraph 5.f.(3).

5 (3) Housekeeping (a) Generally, housekeeping in the Building 17 Pellet Shop, Pellet Shop Annex, Cold Shop Mezzanine, and Building 2 High Bay areas was inadequate in that large quantities of com-bustible trash and spilled paint was allowed to accumulate, and there were oil leaks in the hydraulic systems of the pellet presses. Paragraphs 4.c. and 5.f.(2)(a).

(4) Audits and Reviews (a) No independent audits are conducted to assure that equip-ment tests required by the NRC license are completed.

Paragraph 5.f.(1).

(b) Administrative controls for criticality safety, other than posted signs and floor markings, are not routinely reviewed during nuclear safety audits. Paragraph 5.f.(1).

(c) No independent review or audit program has been established for Health Physics, industrial safety or the implementation of the Radiological Contingency Plan. Paragraphs 5.c. and 6.a.

(5) Inspection / Tests / Maintenance Activities (a) There is no apparent routine inspection and/or preventive maintenance program established for the anhydrous ammonia storage tanks and equipment, the ammonia disassociators and equipment, and process equipment located in Building 17.

Paragraphs 4.d. and 5.e.

(b) Neither of the anhydrous ammonia storage tanks, which are located outside and exposed to the elements, were grounded.

Paragraph 4.d.

(c) Tests for operability of the preaction valve on the dry fire sprinkler system and the rate-of-rise heat detectors in the manufacturing areas are not conducted. Paragraph 5.f.(2)(d).

(6) Personnel Training (a) Only Health and Safety personnel in Building 17 are given training in fire fighting. There is a general prohibition against other personnel using even a portable fire extinguisher. Paragraph 5 f.(2)(c).

6 (b) Generally, workers involved in the manufacturing process were not aware of the location of manufacturing operations procedures. Paragraph 4.a.

(7) Emergency Planning (a) Limited capability exists for obtaining immediate meteorological information at the Windsor Site. Paragraph 6.b.

(b) The Emergency Control Center (ECC) is small, is equipped with only one telephone line and there is no alternate ECC designated. Paragraphs 6.b. and 6.c.

(c) The Emergency Action Levels and Classification schemes specified in the Radiological Contingency Plan are not consistent with the emergency classifications used by the NRC and the State of Connecticut. Paragraph 6.a.

(d) There is no formal distribution of the Radiological Contingency Plan to offsite authorities. Paragraph 6.a.

(e) Some emergency telephone numbers in the Radiological Contingency Plan and the Site Emergency Plan are incorrect or are not current. Paragraph 6.a.

(f) An exercise of the overall Windsor Site Emergency Plan has never been conducted. Paragraph 6.a.

(g) Security of emergency equipment lockers is not adequate to preclude equipment removal for non-emergency use. Para-graph 6.b.

(h) There is no pre printed incident description / documentation form available for use by emergency response personnel.

Paragraph 6.c.

(i) Offsite support groups (police, fire etc.), who tre directly involved in an emergency response, are not trained in or familiar with the contents of the Radiological Contingency Plan and have not been provided with copies of the plan or the implementing procedures. Paragraph 6 d.

(j) Written letters of agreement are in place with local support groups with one exception. Paragraph 6.d.

(k) Qualification and training criteria for key emergency response personnel (Emergency Directors etc.) have not been established. Paragraph 6.e.

7 (1) Emergency drills do not routinely exercise site emer-gency response personnel in a variety of radiological or non-radiological accident scenarios that could have offsite impact, do not include the entire Windsor Site, nor do they include offsite support groups that would be expected to respond. Paragraph 6.e.

(m) Emergency drills and tests conducted at each of the facilities handling radioactive or nonradioactive hazardous materials are not designed to test all aspects of the emergency plans. Paragraph 6.e.

(8) Nuclear Criticality Safety (a) Out-of-use uranium oxide powder blending hoppers were not adequately secured to preclude inadvertent use by operators. Paragraph 5.f.(1).

(b) Initial nuclear criticality safety analyses are not always sufficiently detailed to permit an independent review, nor does the independent reviewer document the basis for concur-rence or the method of analysis used. Paragraph 5.f.(1).

b. Recommendations Recommendations concerning the operations, facilities, equipment, management controls, and procedures reviewed are as follows:

(1) Chemical, Explosion, and Fire Safety (a) Evaluate (1) the impact of a fire involving uranium oxide powder and (2) a failure of the anhydrous ammonia tanks, both with or without the involvement of uranium oxide powders, on the health and safety of the Windsor site workers and the general public.

(b) Establish a program and implementing procedures for the control of flammable and combustible materials in Building 17, to include:

storage of zircalloy machining wastes protection for cylinders containing explosive gases confinement methods for spilled hazardous liquids dispensing of flammable liquids

8 venting and grounding of flammable liquid storage lockers.

(c) Establish a Fire Protection Program for Building 17, to include:

correction of the installation of sprinkler heads in fixed systems to make them in accordance with NFPA-13 standards placement of fire extinguishers in easily accessible and strategic locations installation of ionization or photoelectric smoke detectors daily collection and disposal of combustible trash, accumulated hydraulic fluids, and cleanup of spills.

(d) Reestablish the Windsor Site Fire Brigade.

(2) Industrial and Radiation Safety (a) Establish an Industrial Safety Program, to include:

specific industrial safety policies and procedures incorporation of industrial safety precautions in manufacturing operations procedures evaluation of the high ambient temperature in the Building 17, Pellet Shop and its effect on worker safety.

(b) Evaluate the adequacy of the Building 17 respirator fit test program.

(3) Housekeeping (a) Establish a program and implementing procedures to assure adequate housekeeping in the Building 17 manufacturing facilities and the Building 2 high bay area.

9 (4) Audits and Reviews 1

(a) Establish a program to assure that reviews and audits in the following areas are conducted by persons not associated with the operations (i.e., knowledgeable, '

but independent):

NRC license requirements and equipment tests health physics program industrial safety program implementation of the Radiological Contingency Plan.

(b) Assure that all established administrative controls i effecting nuclear criticality safety are reviewed during routine nuclear safety audits.

l (S) Inspection / Test / Maintenance Activities (a) Establish an inspection / testing program and a preven-tive maintenance program for the anhydrous ammonia storage tanks and equipment, the ammonia disassociators and equipment, the fire sprinkler systems, and other process equipment located in and around Building 17.

(b) Provide the anhydrous ammonia storage tanks with electrical grounding protection.

I (6) Personnel Training

, (a) Establish a fire fighting training program for facility personnel, other than Health Physics Technicians.

(b) Instruct Building 17 manufacturing process workers on

! the content of operations procedures and their locations in the vicinity of the work stations.

(7) Emergency Planning s

(a) Evaluate the Windsor Site Emergency Control Center to determine whether:

it is properly sized to accommodate the required emergency response support staff an alternate Emergency Control Center is necessary 1

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s. 10 an adequate number of telephone lines is available.

(b) Review the Radiological Contingency Plan to determine whether:

the Emergency Action Levels and the Classification scheme need to changed to be consistent with those used by the NRC and the State of Connecticut procedures for distribution of plan revisions should be incorporated copies of the Plan should be provided to off-site support groups written agreements have been executed with and are understood by all required off-site support groups 9 .

qualification criteria for emergency response a

personnel have been established

.a W

_ the assessment regarding a chemical accident

_ involving anhydrous ammonia is still valid >

the telephone numbers listed on the emergency call-in and notification lists are checked periodically to assure they are accurate. -

(c) Provide training in the requirements of the Radiological Contingency Plan and its implementation to:

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• site emergency response personnel, including

, Emergency Directors N ,

off-site support groups.

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(d) Demonstrate through drills that:

The Windsor Site Emergency Plan can be implemented for credible radiological and non-radiological accident scenarios off-site support groups can adequately respond to

, emergencies all aspects of the emergency plans and procedures are adequate.

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11 (e) Install meteorological measurement equipment at the Windsor Site.

(f) Establish one central emergency telephone number for s use throughout the Windsor Site.

(g) Establish controls over security of emergency equipment cabinets to provide reasonable assurance that equipment cannot be removed for non-emergency purposes.

(h) Prepare a pre printed message form for use by emergency response personnel.

(8) Nuclear Criticality Safety (a) Re-examine the technique used for the storage of out-of-use uranium oxide powder blending hoppers.

(b) Assure that initial nuclear criticality safety analyses are documented in sufficient detail to permit an independent review and that the independent reviewer documents the basis for concurrence.

c. Violations Violations of NRC license conditions were identified as follows:

(1) The operation of the door'on the virgin powder storage area under electrical power failure conditions was not checked quarterly between January 3, 1984 and August 18, 1986, as re-quired by Section 4.3.2 of the NRC-approved license application.

4 Paragraph 5.f.(1).

(2) A nuclear criticality safety evaluation for the storage of

, natural uranium rods on top of an NRC-approved 3.7 inch safe slab of uranium oxide in the Building 2 vault was not conducted as required by Section 2.2.2 of the NRC-approved license ap-plication. Paragraph 5.f.(1).

4. Process Review I

a. Pellet Shop Fuel pellets are manufactured in a controlled access area of Building

17. The process consists of mixing uranium oxide powder, forming fuel pellets, removing volatiles from the pellets in an electric furnace, and sintering the pellets in another electric furnace. The hydrogen atmosphere supplied to both these furnaces is provided by the disassociation of ammonia. (The disassociation of ammonia is discussed in detail in Paragraph 4.d. of this report.) The sintered j pellets are then centerless ground, dried, stacked, and placed into l fuel rods.

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12 Procedures for each step of the process are located at each proces-sing work station; however, personnel generally perform their tasks from memory. Occasionally, the procedures are used by the operators for reference.

In general, there appears to be no chemical or explosive hazards in the process area that could significantly affect the general public, or the workers on the Windsor Site, except for those in the immediate vicinity of an accident. Potentially hazardous materials include uranium oxide powder, hydraulic oil for the pellet presses, and organic cleaning solvents stored in drums. Hydrogen and natural gas, which are piped into the building, can be shut off at the point of use. In addition, other shutoff valves are located on a mezzanine near the location where the piping enters the building. Although flammable, the natural gas and hydrogen enter the building in small quantities and are burned immediately either in the furnace or at burnoff points; therefore, the opportunity for a significant accumu-lation of gas, with the resultant potential for an explosion, appears remote. However, because hydraulic fluid is used in the pellet presses, and because there is an ignition source in this area, the potential for a fire exists. A fire in the pellet shop could result in the release of radioactive material to the environment because of the uranium oxide powder stored in the facility. However, due to the inherent properties of uranium oxide, the release could be expected to be localized. Additional fire hazards present in the Pellet Shop are discussed in Paragraph 5.f.(2).

During a tour of the Pellet Shop, the inspectors found that written operations procedures available in the area provide instructions to operators concerning radiological and criticality safety, but contain essentially no instructions relative to industrial safety.

Through discussions with operators, the inspectors determined that an operator working at the powder mixing station, who was new on the job, had received on-the-job operations training from an experienced worker. Although he had been well trained in the operation, this new worker had not read the operations procedure for his work station, nor was he aware that it is posted at his work station. Other workers interviewed were only vaguely aware that operations proce-l dures were available at their work stations. Some of the workers l stated that they had not read the procedures for about one year and l others only used them occasionally, for reference. As a result, the I

inspectors recommended that the workers be trained in the content and location of the procedures and be required to review them periodi-

, cally. As a minimum, they should read and familiarize themselves

! with the contents of the procedures before being considered qualified to work independently at process work stations.

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b. Cold Shop Operations Sealed rods containing fuel pellets are assembled into fuel assem-blies in the Cold Shop. Portions of this process involve the treat-ment of metal components in small vats of nitric acid or a mixture of hydrofluoric and nitric acids. While these chemicals are hazardous, they do not pose a significant danger to workers, or the general public, beyond the immediate area. In addition, these chemicals are not flammable or stored in a way that could lead to an explosion.

Zircalloy is machined in the Cold Shop area of Building 17. Zircalloy chips and dust are highly pyrophoric. Observation of the zircalloy machin-ing operation by the inspectors indicated that the zircalloy chips and shavings are stored under water and in closed containers, as required by established procedures.

The inspectors noted that emergency instructions posted in the zircalloy machining area listed the emergency phone number as extension 2982. The inspectors determined that this extension is in the Building 17 guardhouse and that the guardhouse is occasionally unattended. The inspectors recommended that the posted number in the machining area be changed to extension 5555, which is the central emergency number for the site and is specified in the Radiological Contingency Plan. This would be consistent with other site emergency instructions and would speed up the process of obtaining help, since this extension is attended 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

c. Building 2 Complex and Building 5 The inspectors examined the Building 2 (Nuclear Services Operations) and Building 5 (Nuclear Laboratories) facilities and, except for inadequate housekeeping, cramped storage space for equipment, and one violation of NRC requirements involving failure to analyze a storage configuration in the Building 2 vault, no other significant observations were made.

Prior to examination of the Building 2 facilities, the inspectors were told by personnel in other buildings on site to "really examine what they are doing in Building 2." As stated above, during examina-tion of the Building 2 Complex (including Buildings 1, 1A, 2 and 2A),

with the exception of the violation noted above and in Paragraph 5.f.(1),

the inspectors did not identify any other significant hazards asso-ciated with operations conducted in that area. This was discussed at the exit interview with the licensee. The inspectors recommended that site management provide its employees with information regarding the activities conducted in these buildings, since it appeared that the lack of krowledge of those activities is causing anxiety among the site workers.

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d. Anhydrous Ammonia Storage and Use The fuel pellet process utilizes calcining and sintering furnaces that are provided with a hydrogen-nitrogen mixture as a cover gas. The cover gas is supplied by the catalytic disassociation of 4 anhydrous ammonia into its component parts of hydrogen and nitrogen.

The anhydrous ammonia is stored in two tanks of 6000 and 8000 gallons capacity, respectively, that are located just outside the fuel pellet manufacturing building (Building 17). In addition to the tanks, there are two ammonia disassociators that are located between the tanks and the manufacturing building. After disassociation, the hydrogen and nitrogen mixture is piped into the furnaces in the Pellet Shop.

A continuous flame at each furnace burns off the excess hydrogen, thus preventing the accumulation of this explosive gas.

The ammonia tanks are the largest single source of toxic chemicals on the Windsor Site. A tank rupture during working hours could result in the release of sufficient ammonia to cause severe injury to per-sonnel in and around Building 17 and ill effects to other personnel working on the site. Because of the distance to offsite residences, dilution should minimize any appreciable health hazard to? people living beyond the site boundary, but this potential has not been evaluated by the licensee. Although the ammonia tanks contain no radioactive material, they are located sufficiently close to the storage area for uranium oxide powder (incoming shipping containers of uranium oxide powder and the virgin powder storage area) that a tank rupture could result in the entrainment of uranium oxide powder with the resulting potential for release to onsite or offsite areas.

The inspectors recommended that this potential be evaluated.

The inspectors observed that the ammonia tanks and disassociators contain several safety devices, including safety relief valves. The licensee takes credit for the protection offered by these relief valves as follows:

The On-Site Radiological Contingency Plan states, in part, "...

The exposure of the tanks to an intense fire would result in operation of the relief valves, designed to bleed overpressure...,. Ammmonia vapors could reach high concentra-tions, but it is felt that vapors would be rapidly dispersed and have no permanent effect on personnel or the immediate environ-ment."

The Environmental Impact Study states, in part, "The chemicals potentially subject to spills include nitric acid, anhydrous ammonia, liquid n'itrogen, ... and spent acid. The applicant has employed the following measures to ensure the integrity of chemical storage tanks: proper design and operation, safety relief valves, remote location, and routine visual inspection by trained plant personnel.."

15 In addition to the two relief valves on each ammonia tank, the inspectors noted that the catalytic disassociators also have relief valves. Other safety devices are also installed. Based on inspector observations of equipment and discussions with plant engineers responsible for the equipment, the following were noted:

The relief valves installed on the tanks have never been tested (although one set of two has been replaced). Manufacturer's literature recommends periodic inspection and testing of these valves. The two relief valves on each tank are installed such that each valve can be removed and tested individually, while the other remains in service.

Each relief valve is covered with a heavy duty plastic cap to protect it from dust and dirt. These caps were very tight fitting and could not be removed by hand. Although the licensee 4

stated that these caps would blow off if the tanks were to reach relief pressure, this has never been tested and it appears that the caps could initially exert sufficient backpressure to change the effective relief setting of the valves. In addition, the installed protective covers are different from those shown in the manufacturer's manual, which fit internal to the valve -

cylinder, and appear to exert much less backpressure. Use of the existing protective caps should be evaluated and/or tested.

Neither of the ammonia tanks are grounded. A lightning strike could cause a rupture of the tank.

The tanks are provided with excess flow check valves in the fill and heater lines. These valves are designed to close on excessive reverse flow in case of a line break or rupture. The manufacturer recommends that the excess flow valves be checked at intervals not to exceed one year. However, the excess flow check valves have never been tested.

Each tank has an external electrical heating system designed to keep the ammonia at proper temperature during cold weather. Each tank heater has minimum temperature " cut-on" and maximum temperature " cut-off" controls, and a redundant maximum tank pressure " cut-off" control. Should heater temperature exceed 125* F or tank pressure exceed 150 psig, the heater is designed to shutoff automatically. If the heater shutoff controls should fail, the tank could overheat and cause the relief valve to lift or the tank to rupture. Based on discussions with facility personnel, there is no evidence that these control instruments have ever been calibrated or tested. However, a visual inspection of all the pressure and temperature instru-ments (which are enclosed in a weather-tight box) indicated no evidence of deterioration.

4 16 One ammonia disassociator has two relief valves and the other has one relief valve. These relief valves have never been tested.

Each disassociator has an automatic valve which shuts off flow from the disassociator to the plant in case of low temperature, high temperature, or loss of power. The temperature switches are calibrated, but automatic shutoff of the valve has never been tested. However, the licensee stated that the valve has been observed to close upon loss of electrical power. In addition, the inspector learned that periodic preventive main-tenance for the disassociators, as recommended by the operations manual, is not performed.

There appears to be little or no preventive maintenance on the tanks, other than painting. However, corrective maintenance is performed as required.

Thus, there appears to be little assurance that the integrity of the ammonia tanks is as described in the Environmental Impact Study.

Based on the inspector's observations, the following are recommended:

The safety relief valves on the ammonia tanks should be tested on a periodic schedule.

The heater pressure and temperature switches on the ammonia tanks should be calibrated periodically.

The ammonia tanks should be grounded.

Excess flow check valves on the tanks should be checked at least once per year. Excess flow check valves that cannot be isolated

! from the tanks should be checked, at a minimum, whenever the tanks are down for maintenance.

Preventive maintenance and testing of all safety devices on each

ammonia disassociator should be accomplished periodically, as recommended in the manufacturer's operations manuals.

The automatic function of the emergency shut-off valves for each disassociator should be tested periodically.

Plastic caps which are currently on the relief valve outlets should be confirmed as acceptable with the manufacturer or i

replaced with the type described in the manufacturer's manual.

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P 17 The licensee should formally evaluate the impact upon Building 17 personnel, those in other nearby buildings, remaining Windsor Site workers and the general public from a rupture of one or both ammonia tanks.

e. Zircalloy Chip Handling and Storage As stated previously, in Paragraph 3.b., zircalloy is machined in the Cold Shop area of Building 17. The resultant accumulation of chips and shavings from this machining operation is periodically removed from the tray beneath the lathe and transferred to a closed container filled with water, as required by established procedures. At the end of each day, the chips and shavings are removed from the closed con-tainers, allowed to drain, and then placed " dry" into 55 gallon con-tainers. These containers are removed from the building and stored, unprotected, in the yard area outside the northwest corner of Build-ing 17, about 150 feet from Building 17. The outside storage area is located under several large trees, the limbs of which extend over the storage area. The inspectors expressed concern about this method and location for the storage of zircalloy chips. As a result of these concerns, the inspectors reviewed the contents of the National Fire Protection Association " Standard for the Production, Processing, Handling, and Storage of Zirconium", NFPA 482-1982. The precautions in the Standard also apply to zirconium alloys. The following zircalloy storage and handling inadequacies were identified when compared to the standard:

Fines (including chips) produced in wet operations are not kept wet by storing under water or oil until ultimate disposal by recycling or burning.

Oily lathe turnings and swarf are stored in Building 17 in covered containers (approximately 30 gallon capacity) that are larger than the bucket size recommended by the NFPA standard and are not stored in protected, outside areas sufficiently remote from buildings.

"No smoking" signs are posted around the outside storage area, but not around the machining area inside the building.

Suitable extinguishing agents for zircalloy fires are not kept within easy reach and are located in the direction away from the emergency evacuation route.

During discussions of the above concerns at the exit interview, the licensee did not agree with the inspectors' assessment of the pyro-phoric hazards in handling and storing this material at the site.

Appendix B to the NFPA Standard 482-1982 provides the following information on the hazards of zirconium or zircalloy:

18 Section B-4.1 states, " Zirconium and its alloys do not present serious risk when handled in most forms in which they are ultimately used, i.e., tubes, bars, and sheets. However, finely divided chips, turnings, or powder may be easily - sometimes spontaneously - ignited and may burn very rapidly. Although other potential hazards exist during melting, those which have resulted in the most serious and lethal accidents have been associated with the handling of zirconium powders, finely divided scrap, and so-called black reaction residues. For this reason, special precautions must be observed during handling or disposal of these materials."

"Several companies have reported that fires have occurred while zirconium bars, plates, and other shapes were being chopped.

A number of fires have occurred when hot or burning chips fell into accumulations of moist fines on or under lathes or milling machines. The most violent reactions have occurred when burning chips fell into drums or deep containers partially filled with moist turnings or scrap."

Section B-5.2 states, "The burning rate of zirconium chips and turnings increases when water or water-soluble oils are present ,

as a surface coating. The burning rate also increases with increasing pile depth, degree of confinement, and increasing void space in the pile. Chips and turnings less than 0.003 in.

(0.8 mm) thick are particularly susceptible to rapid burning.

Other factors being equal, partially wet material ignites more easily and burns more rapidly than dry material."

Section B-5.3 states, "Small amounts of water tend to increase the risk of explosion. Additional heat is liberated on forma-tion of the hydrated oxide, thus increasing the chance of an explosion. Scrap that is fully immersed in water will generally not overheat because the water provides a substantial heat sink.

However, with tight packed, very finely divided zirconium, it would seem that some risk might still be present."

Based on the foregoing, it is recommended that the licensee review and revise its methods for the handling and storage of zircalloy waste materials.

i 5. Management Controls

a. Organization Four groups are responsible for various aspects of safety at the Windsor Site. These groups are totally independent of each other and, for the most part, do not interface with each other. The groups and their responsibilities are as follows:

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19 (1) Nuclear Fuel Manufacturing Nuclear Fuel Manufacturing is responsible for the radiological and industrial safety in the Building 17/21 Complex. Recently, as a result of a Nuclear Power Division reorganization, this group was also made responsible for safety in several labora-tories located in Building 5 and a vault located in Building 2.

This group is also responsible for implementation of the Radiological Contingency Plan required by the NRC special nuclear materials license number SNM-1067.

(2) Nuclear Services Operations Nuclear Services Operations personnel are responsible for the radiological and industrial safety in the Building 2 Complex and the remainder of Building 5.

(3) Facilities and Engineering Services The Facilities and Engineering Services (maintenance) group is responsible for the development and implementation of the overall Windsor Site emergency plan.

(4) Power Systems Group Office The Power Systems Group Office provides information (model safety programs, training, and procedures) and services (audits) upon request by the other site groups. This office also reviews the results of safety audits performed by the Nuclear Safety Committee (Nuclear Fuel Manufacturing) and the facility safety committees (Nuclear Services Operations). The Power Systems Group Office reviews these audit reports and provides feedback on the reports, as necessary,

b. Safety Program Implementation Implementation of the safety programs at the two site locations where most of the licensed radioactive material is utilized (Building 2 Complex and Building 17/21 Complex) is accomplished differently.

These differences are due to the fact that each department is indivi-dually responsible for implementation of a safety program of its own design. There is no corporate or divisional policy and procedures manual which provides direction for the establishment and execution of a safety program.

At the Building 2 Complex, individual supervisors are responsible for developing and implementing a safety program and the Manager, Health Physics is responsible for ensuring compliance. There are no written industrial safety procedures, except for those covering toxic waste

~

20 management. At the Building 17/21 Complex, the Health Physics and Safety Supervisor is responsible for developing, implementing and auditing the industrial safety program. Several industrial safety procedures / checklists and an industrial safety training program have been implemented. The training is based on information obtained from the corporate safety office.

Based on the above, the inspectors recommended that the licensee establish and execute a corporate or divisional industrial safety program at the Windsor Site.

c. Quality Assurance /Ouality Control Programs The licensee has committed to the applicable requirements of 10 CFR 50, Appendix B, for the manufacture of nuclear fuel only. The Quality Assurance (QA) program is routinely reviewed by the NRC Vendor Inspection Program Branch of the Office of Inspection and Enforce-ment. The QA program includes plant audits, vendor audits, source inspections, receipt inspections, and extensive Quality Control (QC) inspections at various stages of the fuel manufacturing and assembly process. A QA manual has been developed and extensive QC specifica-tions exist to ensure the quality of the product. The QA organiza-tion is independent and reports to the Vice-President, Nuclear Fuel Manufacturing, not to the manufacturing facility manager. The emphasis of the facility QA/QC program is on process control and product quality. QA personnel perform no audits or overview of health physics, plant safety, or general industrial safety. The inspectors recommended that an audit / surveillance program be estab-lished by QA, or some other independent organization, to provide periodic overview in these areas.

d. Document Control The adequacy of the licensee's document control program was reviewed by the inspectors. The licensee maintains a Central Document Control Center (CDCC) which provides controlled distribution for operations sheets (process procedures), specifications, drawings, and shop travelers in accordance with document control procedure MFG-14-15,

" Central Document Control Procedures", (currently, Revision 2, June 10, 1986). Based on the review conducted by the inspectors, the program appears to adequately assure that current and correct revisions of procedures are posted at the locations where they are to be used.

The inspectors reviewed a sample of 34 operations sheets at various process stations in the nuclear fuel manufacturing facility. All were found to be the latest revision, properly approved, and stamped

" Released for Manufacturing", as required by procedure MFG-14-15. In addition, several QC specifications maintained by the calibration laboratory in Building 5 were also sampled and found to be the proper revision.

-_m_._ . _ _ . _ _ _ _ _ , _ _ . _ , , _ _ _ _ _ _ _ _ , . . - . . _ _ _ . _ _ _ , _ . _ __. -

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e. Calibration Control ,

The inspectors reviewed the licensee's calibration program. The licensee's Manufacturing Engineering group performed an evaluation of all process control instruments to determine calibration requirements and to establish calibration program requirements and specifications for each area of the facility. Instrument calibration requirements were established based upon engineering judgement and the possible effect of the instruments on the quality of the products. Those instruments that do not require calibration are so designated in procedures and are labeled as such in the plant.

However, calibration and/or testing does not appear to be conducted on many devices that have safety functions. As noted previously in paragraph 4.d, safety devices on the ammonia tanks and disassocia-tors, with one exception, were not calibrated. Therefore, the inspectors recommended that the licensee review all primary and auxi-liary process related instruments that perform safety functions and establish periodic calibration and test requirements for those instruments,

f. Operational Safety (1) Nuclear Criticality Safety Controls During examination of the uranium oxide powder receipt area, the inspectors observed that there were stacks of reportedly empty uranium oxide containers piled up against a wall, with little positive visible evidence that the containers were empty.

" Empty" signs, posted on the wall behind the containers, were hidden from operating personnel by the containers. This was identified by the inspector as a poor practice in that safety related signs should be visible at all times.

Section 4.3.2 of the criteria section in the NRC-approved li-cense application states that the fire door in the virgin powder preparation storage area shall close automatically on activation of the fire alarm and/or upon electrical power failure (in case the failure precedes or is incident to a fire). The automatic closing feature of the door on the virgin powder storage area is to be verified quarterly and records of its performance are to be maintained. These nuclear criticality safety requirements were incorporated into the facility license to assure that the storage area will not become wet in the event of activation of the fire sprinklers located outside the storage area. In dis-cussions with licensee representatives and through review of licensee records, the inspectors determined that the operation l

22 of the door on activation of the fire alarm is checked monthly, but the operation of the door under power failure conditions had not been tested since January 3, 1984. This was identified as a violation of NRC requirements. The inspectors noted that, although the tests are to be performed by maintenance personnel, the responsibility for assuring that the tests are completed is assigned to the Health Physics and Safety Supervisor, with no apparent program to assure that the tests are performed.

The inspectors noted that uranium oxide powder, enriched to greater than 3.5?; U-235, was being processed in the facility at the time of this inspection. The small press feed hoppers were being used for this enrichment as required by the facility license. The larger press feed hoppers, used with powder enriched to less than 3.5?; U-235, were supposedly being stored under lock and key, as required by the facility license. How-ever, the inspectors noted that the chain around the hoppers was so loose that any or all of the hoppers could be removed without disturbing the lock. The inspectors were informed, by operators and other licensee representatives, that it was under-stood by all personnel that the hoppers were not to be used as long as they were surrounded by a chain. The inspectors inform-ed the licensee that a more positive control was envisioned by NRC when the license was so conditioned. The inspectors suggested that a ring attached to each hopper, with the chain attached to the ring, would provide a positive restraint against inadvertent removal of a hopper from the storage area.

The inspectors examined several recent nuclear criticality safety analyses to determine whether a second party independent review and approval process was being conducted, as required by NRC license conditions. The inspectors found that, while it appeared that an independent analysis was being conducted, the original analysis was not always sufficiently clear to permit a meaningful independent review. Moreover, the indepen-dent reviewer did not document the basis for concurrence with the results of the initial analysis or the method of analysis used. The inspectors informed the licensee that the independent reviewer, in addition to the foregoing, should sign the analysis and approval sheet.

The inspectors also noted, during a review of audits conducted by the Manager, Nuclear Licensing, Safety, Accountability and Security, the Nuclear Safety Committee, and the Nuclear Safety Consultant, that none of the audits included a review of required administrative controls, other than signs and floor markings. This was identified by the inspectors as a weakness in the administration of an effective nuclear criticality safety program.

23 During a tour of the Building 2 Complex, it was observed that natural uranium rods were being stored on top of an NRC-approved 3.7 inch safe slab of uranium oxide. Through discussions with licensee representatives, the inspectors determined that a nuclear safety evaluation was not completed for this condition, as required by Section 2.2.2 of the NRC-approved license appli-cation. A nuclear safety evaluation for this storage condition is required because the original evaluation of the slab was based on water and concrete reflection, not natural uranium, which is a better reflector. This was identified as a violation of NRC requirements.

(2) Fire Protection In order to assess the licensee's fire protection program, the inspectors examined plant housekeeping conditions for the accum-ulation of combustible materials and the licensee's methods for controlling flammable, combustible, and otherwise hazardous materials.

The inspectors also reviewed the training given to employees involved in the fuel manufacturing process. In addition, the inspectors reviewed the condition of fire-fighting equipment, including sprinkler systems, portable fire extinguishers, fire detection systems, alarms, and hose stations. The results of this review are as follows:

(a) Housekeeping The inspectors observed that housekeeping in Building 17 was in need of improvement. The licensee allowed large quantities of combustible trash to accumulate in several areas of the facility, such as the Pellet Shop Annex and the Cold Shop Mezzanine. In addition, oil leaks from the hydraulic pellet presses, spilled paint, and open paint cans, on the platform above the belt dryer, were identified as potential fire hazards. The inspectors advised the licensee that clean-up of the oil leaks, paint spills, and the removal of the trash, at the end of each shift, will significantly enhance the facility fire protection and prevention program.

(b) Control of Combustible and Flammable Materials

! The inspectors determined that the licensee has not estab-lished procedures for the control of flammable and combus-tible liquids. The inspectors observed alcohol and other solvents throughout the plant in containers not approved

24 for such use, e.g., plastic bottles. In addition, lockers for the storage of flammable liquids were not installed in accordance with the manufacturer's or the National Fire Protection Association recommendations, in that they were neither grounded nor vented.

As previously discussed in Paragraph 4.e., the inspectors observed large quantities (about 50 drums) of zircalloy chips stored in the yard area outside the northwest corner of Building 17. The zircalloy was not stored under cover or in a remote area. The inspectors found that this con-dition presents an explosion and fire hazard to the nuclear fuel manufacturing facility.

(c) Training of Employees in Fire Fighting The inspectors found that the licensee does not provide its manufacturing facility employees, with the exception of Health and Safety personnel, any training in fighting fires because of personal liability and insurance concerns. The licensee prohibits all employees, except Health and Safety personnel, from fighting fires-and even from using portable fire extinguishers. In the event of a fire, employees have been instructed to evacuate the facility immediately. The licensee has accepted the fact that, if a fire occurs, the entire facility could be destroyed. Since the licensee disbanded its fire brigade in 1982, all fire fighting must await the arrival of the local volunteer fire department, unless the fire can be extinguished by Health and Safety personnel when they are on duty.

The inspectors interviewed the Town of Windsor Fire Mar-shall who stated that the response time of the volunteer fire department, depending upon the time of day, can be as long as 20-30 minutes and, because the department consists of volunteers, only 2 to 3 firefighters may initially re-spond.

The inspectors concluded that, considering the quantity of combustible material in the facility, in the absence of a fire brigade, and with the prohibition against firefighting by general facility employees, the manufacturing facility could be completely destroyed as a result of a small and readily extinguishable fire. American National Insurers (ANI), the licensee's insurance carrier, recommended, in an Inspection Report dated May 14, 1982 (submitted to the NRC during the most recent SNM license renewal process), that the previously existing fire brigade be reestablished. The licensee did not adopt the recommendation. The inspectors

25 also recommended to the licensee that the fire brigade be reestablished and that employees receive fire-fighting training, especially in the use of portable extinguishers.

(d) Fire Protection System Hardware The licensee has installed several fire protection systems that consist of a wet sprinkler protection system, with a dry preaction sprinkler system installed in the hydraulic press area; a rate of rise heat detection system; and numerous portable fire extinguishers throughout the manu-facturing facility.

The inspectors observed that installation of some of the fixed sprinkler heads did not conform to the NFPA-13 requirements, in that the discharge of the heads was ob-structed by duct work and ceiling truss members. In addi-tion, the licensee has not performed a test of the preac-tion valve to verify its operability, at an established frequency, since its installation in early 1985. The NFPA standards require such a test.

The licensee also does not have a testing program to verify the operability of the rate-of-rise heat detectors. The inspectors noted that these heat detectors are appropriate for use in the hydraulic press area, however, the licensee is also using this type of detector throughout the remainder of the facility. The inspectors suggested that photoelectric or ionized particle detectors would be better suited for the type of fire hazards observed in the facil-ity, except in areas where rapid heat development is anti-cipated, such as in the hydraulic press area.

The portable extinguishers installed in various locations in the facility were suitable for the potential hazards involved. However, the inspectors observed that some of the extinguishers (e.g., in the zircalloy machining area) are not strategically located along an exit path and other extinguishers (e.g., in the fuel assembly storage room) were not easily accessible. The inspectors also noted that the licensee had failed to perform the monthly inspection of fire extinguishers located in the Building 17/21 Complex during July 1986. This deficiency was immediately correc-ted by the licensee. The other findings noted above were brought to the attention of licensee management representatives.

26 (3) Radiation Protection / Industrial Safety During examination of the facilities at the Windsor Site, the inspectors observed the following potential industrial safety concerns that could impact directly or indirectly on licensed activities involving radioactive materials.

The inspectors noted that operators were working in a high ambient temperature condition (about 107 F) in the Pellet Shop, that liquid hazardous chemicals (acids and flammables) were stored in outside areas and were not provided with spillage controls or flow directors (curbing), and that pressurized gas cylinders were stored outside without provisions to prevent exposure to direct sunlight or the elements. The inspectors recommended that the licensee examine possible methods of correcting these conditions.

The inspectors also reviewed the licensee's respiratory protec-tion program after observing that a guard, who may be required to wear respiratory protection during emergency conditions, had a full face beard. The inspectors found that the procedure for use of respirators (HP-221), which includes the fit test pro-gram, is only marginally adequate when compared with criteria in NRC Regulatory Guide 8.15 (October 1976), NUREG-0041, and ANSI 288.2 (1980). The inspectors recommended that the licensee review the adequacy of the respirator fit test program using these NRC and ANSI documents, even though the licensee has not formally committed to them.

6. Emergency Planning

a. Radiological Contingency Plan, Windsor Site Emergency Plan, and Implementing Procedures The inspectors reviewed the Windsor Site Radiological Contingency Plan (RCP). The Manager, Nuclear Licensing, Safety, and Account-ability in Nuclear Fuel Manufacturing is responsible for carrying out the major functions of the emergency preparedness program and for ensuring implementation of the RCP. In response to a 1981 NRC Order requiring a Contingency Plan, Revision 2 of the RCP was submitted to the NRC and approved in 1982. An update to the Plan (Revision 3) was completed in 1983, but was not submitted to Plan holders or the NRC, since the licensee does not have a formal distribution process. The inspectors also reviewed the Windsor Site Emergency Plan (dated 3/86) developed for various types of emergencies (e.g., fire, medical, severe weather, mechanical / electrical failures, plane crash, hazard-ous waste accidents). Together, these two Plans appear to adequately cover the organization, resources, and planning arrangements neces-sary for response to a wide spectrum of accidents at the facility. A significant amount of overlap was found between the two Plans, and

27 it was unclear which Plan would be implemented for radiological emergencies. Through discussions held with licensee representatives, the inspectors found that audits of the Plans are performed by per-sonnel directly involved in maintaining the Plans, rather than by an independent individual or audit group. Several other deficiencies were identified in these Plans.

The following are recommendations that should be considered by the licensee:

Formalize distribution of the Radiological Contingency Plan to ensure that key members of the licensee's emergency organiza-tion, the NRC, and offsite support organizations have current revisions.

Page 3-2 of the RCP concludes that a chemical accident involving anhydrous ammonia would have no offsite or environmental impact; therefore, emergency planning for such an accident has not been established. This conclusion should be re-evaluated, with consideration of the information presented in Paragraph 4.d. of this report. ,

The Emergency Action Levels and subsequent classification scheme in the RCP are not consistent with the four emergency classifications used by the State of Connecticut and the NRC.

They should be consistent.

Appendix F, " Generalized Notification List", of the Windsor Site Emergency Plan identifies an NRC " Compliance Office" with an in-correct telephone number. Also, an "NRC Assistance Team" is identified that, when called, was found to be an outdated listing for the Radiological Assistance Program (RAP) team at Brookhaven National Laboratory. These listings should be corrected.

Audits of the Plan should be conducted by independent personnel who do not have direct responsibility for developing and main-taining the Plan. Audits should cover major RCP and Site Emergency Plan content in sufficient depth to evaluate the ade-quacy of stated onsite and offsite responses to any type of accident.

Although drills and exercises have been conducted to test the RCP for onsite radiological and medical emergencies, the licensee has not demonstrated that the overall Windsor Site Emergency Plan can be effectively implemented. First, the -

licensee should either integrate the two Plans or establish how the Plans will be used for each specific emergency response.

Second, exercises should be conducted that take into account how the overall Windsor Site Emergency Plan will be implemented, l

28 particularly with respect to worker health and safety and potential offsite impact resulting from a release of chemicals or toxic substances.

Changes to the RCP are reviewed annually by the Nuclear Fuel Manufacturing facility production and engineering managers. The inspectors noted that no significant changes have been made to the RCP, facilities, and equipment since the plan was initially issued in 1982. A call-out list was being maintained and is readily available to all key emergency personnel and at emergency stations throughout the site.

Letters of Agreement with offsite agencies have been updated period-ically without substantive changes.

b. Facilities and Equipment The inspector toured the following facilities designated for emer-gency response: Fuel Fabrication Facility (Building 17), R&D Lab (Building 5), Building 2 Complex, onsite/offsite medical facilities, Emergency Control Center (ECC), and the Building 17 access control point (near the Building 6 assembly area). Emergency kits and lockers, communications equipment, criticality monitoring equipment, radiological survey instruments, respiratory protection, first aid supplies, and vehicles designated for emergency use were also examined. Facilities and equipment were as described in the RCP and are adequate to respond to criticality and other nuclear material related incidents at these facilities. However, since Page 3-7 of the RCP indicates that a release of uranium oxide will occur after a major fire or explosion, arrangements should be in place to allow for continuous assessments (meteorological, radiological etc.) and determinations of the impact of the release.

Equipment lockers are strategically located around the site in the health physics office, ECC, development laboratories, and the Building 17 guard house. Inspection of lockers indicated that equip-ment was maintained in operable condition. Lockers are inventoried monthly by the licensee, but the security of the lockers was found to be inadequate, since the key to each locker was either taped or tied to the locker door. Some equipment and supplies were available for dealing with toxic gas release and chemical spills as described in the Windsor Site Plan. Acid showers and eye wash fountains were inspected and found to be operable.

1 The major areas of concern associated with implementation of the Windsor Site Emergency Plans are:

Limited capability exists for making meteorological measurements and near real-time predictions of atmospheric transport to offsite areas following a radiological or chemical release.

,-,cna ,, - - - n

29 The Emergency Control Center (ECC) is limited in size and may be inadequate as an emergency response facility to accommodate additional support staff.

In the event the ECC and assembly area become uninhabitable due to elevated radiation levels or presence of toxic materials, an alternate ECC (AECC) has not been designated. An AECC should be designated in a location remote from where the incident could be expected and should include all capabilities for directing and controlling the response.

The security of emergency lockers should be improved to provide reasonable assurance that equipment cannot be removed for non-emergency purposes.

c. Notifications and Communications The primary method used for communication throughout the site is a CE-owned telecommunication network. For emergency purposes, an

" Emergency 5555" number is identified for use by onsite personnel.

This number connects the caller to the Central Security Control Center. Security personnel are instructed to notify emergency i response personnel listed on the callout form, which includes outside support organizations, via telephone or an emergency hot line. A paging network and portable radios are designated as backup communi-cation sources.

Primary and backup communication systems are adequate for emergency response purposes, but the following recommendations for improvement were made by the inspectors:

The single telephone line in the ECC, for use by the Emergency Director and other key responders, has the potential to signi-ficantly inhibit information flow, particularly with regard to incoming calls. This should be reconsidered.

Consideration should be given to developing a pre printed message form for use during notifications to offsite authori-ties. The form should include relevant information on the description and type of incident, emergency classification, whether a release of radioactive or toxic material has occurred, event cause, prognosis of accident, etc.

d. Coordination with Offsite Groups The inspectors reviewed Section 4 of the RCP and Letters of Agreement with offsite agencies and support personnel, and then contacted five representatives of these agencies to verify their understanding of the agency's role and responsibilities in response to an incident at j

the Windsor Site. Offsite support groups contacted by the inspec-tors, and their primary emergency function, were: Windsor Police -

30 local traffic control; Mt. Sinai Hospital - treatment of chemical injuries; Windsor Fire Dept. - onsite firefighting; St. Francis Hospital - criticality and radioactively contaminated injured victims; and the Connecticut State Police - traffic control of interstate highways and reporting of events to the Governor's office. All representa-tives expressed a clear understanding of their agency's role and responsibility in response to emergencies at the Windsor Site. The inspectors found that arrangements for technical and administrative support with each group were consistent with the language specified in the Letters of Agreement. No letter of agreement had been pre-pared for Mt. Sinai Hospital, which is identified to care for pa-tients exposed to chemicals or other toxic substances.

Further, the inspectors noted that a close working relationship had not been established with each offsite group, so that an emergency response could be efficiently and effectively coordinated. Repre-sentatives of the offsite groups, who were interviewed, did not have a clear understanding of the licensee's operation, its organization, and types of hazards present onsite. This appears to be a training and/or coordination deficiency. However, all of the representatives were aware that there was a potential for radiation overexposures and other, non-radiological, incidents at the site, and were prepared to provide support upon request. Licensee representatives stated that support groups would be invited to attend a site tour and orientation in the near future.

Training of offsite organizations, to outline the implications of major credible accidents that could be encountered at the site, had not been provided. Drills / exercises have not been conducted with each off-site group, but police, fire, and hospital personnel had previously participated in emergency exercises held at nuclear faci-lities other than Combustion Engineering (i.e., Millstone and Haddam Neck nuclear power plants and the Knolls Atomic Power Laboratory).

Controlled copies of the RCP are not distributed to or maintained by offsite groups. The inspectors reviewed the procedure manual and observed facilities and resources used by the hospitals for handling accident victims from the Windsor Site and determined that adequate treatment could be provided to deal with accidental chemical, acid, and radiological exposures.

Licensee representatives indicated that consideration would be given to the distribution of the RCP and applicable procedures to each group.

The following are recommendations for improvement made by the inspec-tors:

Offsite support groups who will be directly involved in emer-gency response should be trained and familiarized with the RCP and its implementation. Emphasis should be placed on how each l

31 respective group will function and be used in response to an incident.

Arrangements to treat injured personnel sent to Mt. Sinai Hospital should be formalized.

Copies of the RCP and applicable emergency procedures should be provided to each offsite group expected to participate in emergency responses.

e. Training, Drills, and Exercises Initial training in nuclear criticality safety requirements is '

provided to new employees by a health physics representative who conducts a walkthrough session with the individual, using the employee training manual as a guide. The manual briefly describes safety, security, and radiological aspects of the manufacturing operation. During the training session, the representative plays a prerecorded tape of the fire, security, and criticality alarms and ensures that the employee understands the evacuation routes.

Requalification of employees is performed annually. The inspectors interviewed workers in the Pellet and Cold Shop areas and determined that initial and requalification training for immediate employee response to emergencies appears to be effective. Training of employees, other than Health Physics technicians, to carry out emer-gency functions consists of participation in drills and exercises.

However, qualification criteria for each specific emergency duty have not been established.

Personnel are selected as Emergency Directors (EDs) based upon their background and experience. During the day shift, a member from upper level management would act as the ED, but on backshifts and weekends, a representative of the health physics office (health physics techni-cians) would assume the ED role until plant management arrives on-site. The inspectors recommended that some formal training be carried out for non-management EDs to assure that they are aware of, at least, the general response actions that would be expected and supported by management.

Drills are conducted at regular frequencies to evaluate emergency personnel capabilities in response to evacuation, medical, and criti-cality scenarios. Drills at each building onsite are held separately, and the inspectors expressed concern that the drills were not comprehensive and did not simultaneously test the integrated capability of all basic elements of both the RCP and Windsor Site Emergency plans. Two deficiencies were identified with drills held at Building 5. First, the licensee has not established a method to assure that all individuals have been accounted for following a building evacuation. Second, portable communications equipment is

32 not tested during simulated search and rescue efforts. Offsite support organizations have not had the opportunity to respond to drills, since the scope of scenarios is primarily limited to onsite exercises. Review of drill records indicates that weaknesses are identified during the critiques and the Manager, Nuclear Licensing, Safety, Accountability and Security implements recommendations for improvements through appropriate RCP and procedure revisions.

The following are recommendations for improvement made by the inspectors:

Qualification criteria for key emergency response functions (EDs, etc.) should be established.

All personnel identified as Emergency Directors should be trained and qualified to make key decisions (i .e., recommenda-tions for protective measures, evacuation, etc.) and these decisions should be based on general response actions that would be expected and supported by management.

Exercises that test the integrated response by site personnel to a wide variety of simulated radiological and non-radiological accidents having offsite impact should be conducted. Drills and exercises should include all corporate and offsite support '

groups expected to be involved when a significant incident occurs.

Building drills should test all aspects of the emergency procedures, including communications capability, search and rescue, donning of SCBA, and accountability of missing individuals to ensure that response activities will be carried out effectively.

7. Exit Interview The inspectors met with the licensee representatives denoted in Paragraph 1 at the end of the inspection on August 22, 1986. The inspector summarized the scope and findings of the inspection.

No written information was supplied to the licensee by the inspector during this inspection.