ML20217D765
| ML20217D765 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 09/29/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20217D764 | List: |
| References | |
| 70-7002-97-206, NUDOCS 9710060127 | |
| Download: ML20217D765 (19) | |
Text
OFFICI Al, RECORD COPY U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No :
70 7002 Certificate No.:
GDP 2 l
Cenifichte lloider:
United States Enrichment Corporation l
Location:
Portsmouth Gaseous Diffusion Plant Piketon, Ohlo Dates:
July 21 to 25,1997 August 25 to 29,1997 Inspectors:
Dennis Morey, Lead Inspector, NRC 1leadquarters Jack Davis, inspector, NRC licadquarters Chris Tripp, inspector, NRC lleadquarters Sandra Larson, Contractor, Battelle Approved 11y:
Philip Ting, Chief Operations 13 ranch Division of Fuel Cycle Safety and Safeguards, NMSS
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4 UNITED STATES ENRICllh1ENT CORPORATION PORTSh10UTil GASEOUS DIFFUSION PLANT NRC INSPEC110N REPORT 70-7002/97 206 liXIKUIlYliSUhthMlO' Arcatimpccled An NRC lleadquarters team performed an announced criticality safety inspection of the Portsmouth Gaseous Difrusion Plant (PORTS) in Piketon, Ohio on July 21 to 25,1997 and on August 25 to 29,1997. The inspection was conducted using staff from NRC licadquarters and one NRC contractor. The focus of this inspection was to determine the level of nuclear criticality safety (NCS) through review of NCS program implementation as described in Part 76, the certification application, and the compliance plan.
Major programmatic portions of the NCS program (IP 88015) which were reviewed at PORTS included:
Management and Administrative Practices for NCS Nuclear Criticality Safety function hiaintenance for NCS NCS Inspections, Audits, and investigations Criticality Alarm hionitoring System NCS Emergency Response Iknills One Level IV violation was identified during this inspection concerning a safety issue involving the failure to flowdown firefighting instructions into emergency packets (Section l l.0.E).
Two Level IV violations were identified during this inspection concerning compliance issues involving the failure (1) to identify the technical basis for the 10 foot spacing between Planned Expeditious Handling equipment in an approved nuclear criticality safety approval (Section 2.0 C) and (2) to establish a Technical Safety Requirement (TSR) for singly contingen; operations (Section 2.0.D).
Program weaknesses were identified in the areas of(l) maintenance backlog (Section 7.0) and (2) Criticality Accident Alarm System (CAAS) coverage and documentation (Section 10.0).
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DETAll4 1.0 ManagelnenlandAdmini11ratirefracliccLfeLKCS A.
Inspector Follow up item (IFI) 97 203 13 (Closed)
Inspectors reviewed IFl 97003 13 which concerned Part 76 68 change reviewt PORTS management explained their policy conceining these reviews and stated that their procedures required the reviews and that NRC concurrence would be sought when appropriate. llecause no specific instances ofimproper changes have been identified, this ite.
. considered closed.
II, 9101 Reportable Event SCDPc inspectors reviewed the PORTS response to an NCS event concerning the use of unauthorized rasatig rings inspectors visited the facility where the rings were found and interviewed the operators who identified the deficiency along with operators involved in corrective actions.
Oh5cD'AllDD5 PVC raschig rings were found in the lluilding 342 oil interceptor in v;alation of Safety Analysis Report (SAR) and TSR requirements to use borosilicate glass rings. The bottom of the pit had become blocked by a corroded metal plate, and the PVC rings were not seen and removed during a plant wide replacement effort earlier in the year. Operators removed the PVC rings, replaced them with glass rings, and conducted a plant wide review of raschig ring locations consisting of document reviews and physical inspections to insure that PVC rings were not in use anywhere else. Ilecause the issue was self-identified, promptly corrected, and oflow safety significance, it will be treated as a Non-Cited Violation (NCV) 70-7002/97-206-01.
Conclusions The PORTS response to the discovery of the PVC raschig rings was prompt and adequate, The safety significance of the event is considered low because the neutron absorption properties of the PVC rings are sufliciently close to borosilicate rings.
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i 2.0 Nuc.latQilkality.SafelyAg(10.0 A.
Unresolved item 97 203 04 (closed)
- Inspectors reviewed URI 97 203 04 which concerned Solid Angle calculations of cascade gas cooler interaction and used a single unit multiplication factor of 0.85 when the SAR requires 0.80. Facility proposes to revise calculation to comply with the SAR. SAR revision willincorporate new calculation into accident analysis The failure to adjust the solid angle calculations to the new SAR requirements will b; treated as NCY 70-7002/97 206 02 due to the immediate corrective action and low safety significance. Corrective actions concerning the solid angle calculations will be tracked as IFI 70 7002/97-206 03.
H.
Unresolved item (URI)97-203 10 (closed)
Inspectors reviewed URI 97 203 10 which concerned review of Engineering Specification Data Sheets (ESDS). Inspectors questioned why NCS does not review these documents.
Facility management responded that NCS establishes the design requirements for equipment but is not involved in reviewing the preparation of specifications. CM staffis preparing procedure XP2 EG EG'076 to formalire review of ESDS. This item is considered closed. Establishing a formal proccdure for review of ESDS will be tracked as IFl 70-7002/97-206 04.
C.
NCS Evaluations (NCSEs) and Documentation Sconc Technical Safety Requirement (TSR) 3.11.2 requires that "All operations involving uranium enriched to 1.0 wt.% or higher U 235 and 15 gms or more of U 235 shall be based upon a documented nuclear criticality safety evaluation." inspectors reviewed NCSEs to ensure adequate analysis and documentation of NCS controls and limits. Field verifications were also conducted to ensure adequate reliability of the controls.
Ohcrxalions The technical basis for the 10 foot spacing between PEH equipment could not be found.
A technicaljustification for the 10 foot spacing requirement was written by NCS personnel between the first and second weeks of the inspection. Calculations showed the reactivity of a single, highly reactive sphere increased by 1% when placed ten feet from a second identical sphere, inspectors believe this calculation is nonconservative because the use of slabs in this calculation will result in a greater reactivity increase.
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I 15e removal and cleaning of Planned Expeditious llandling (PEll) equipment is a singly contingent operation which allows greater than a safe mass of fissile material (defined as 43.5% of the minimum fissionable mass)in unsafe geometry equipment. The inspectors found that the 10 foot spacing requirement between two pieces of PEli equipment as required in NCS Analysis (NCSA) PLANT 028 was not analyzed in the corresponding NCSE, and NCS personnel were not able to find a documented basis for the spacing requirement. NCS personnel traced the requirement back to a 1950's memo and believed that it has been in use for so long that the basis is no longer retrievable. The failure to document the basis for the 10 foot PEli spacing requirement is Violatlon (YlO) 70 7002/97 206 05.
Coridu3 ions The inspectors found one case of an unanalyzed NCS condition with wspect to the spacing requirement between two pieces of PEll equipment. This instance, along with the solid angle example ofIFl 97 206 01, shows a reliance upon historicallimits and analyses without verification of the adequacy of the technical basis.
D, NCSE Approvalliasis Ss2ps TSR 311.5 states that the double contingency principle, as described in the SAR, shall be used as the basis for the design and operations of processes using fissionable materials. In those instances where double contingency is not met, TSRs shall be established, implemented, and maintained to prevent criticality from occurring. Inspectors reviewed NCSEs to ensure that TSRs were maintained for all singly contingent operations.
Obsmations The NCSEs for the Tails Withdrawal Station (NCSE-0330 007.E00) and the Low Assay Withdrawal (LAW) Station (NCSE-G333 017.E00) noted that double contingency cannot be demonstrated for these operations with respect to wet air and oil in leakage into the compressors. No TSR is in place for this scenario in the withdrawal station equipment.
NCS personnel assumed that TSR 2.2.3.15, which addresses moderation control for compressors in the cascade, covered the withdrawal station compressors. The inspectors' review of the S AR description and the TSRs for the withdrawal stations clearly indicates that the compressors are within the withdrawal station boundary and are not cc ered by TSR 2.2.3.15..The failure to implement TSRs for a!! singly contingent operations n.
VIO 70 7002/97 206 06.
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The NCSEs for the Tails and LAW Withdrawal Station were revised between the fu st and second weeks of the inspection to demonstrate double contingency for wet air in leakage without additional NCS controls Therefore, the safety concern for this case is low. The inspectors noted that the documentation of the technical assumptions and arguments in the revisions was an improvement over previously reviewed NCSEs.
Conclusions TSRs are required to elevate the awareness of NCS controls on operations that do not meet the double contingency principle. The inspectors identified one violation concerning the identification of a single contingency operation in the withdrawal station NCbEs which did not have a corresponding TSR. In general, there is a higher safety concern for s5gle contingency operations than double contingency operations. Ilowever, the safety concern for this case is low because double contingency could be shewn using another approach.
7.0 Maintenantu.for NCS Scope The hiaintenance program was reviewed with respect to Q (quality) and AQ NCS (augmented quality.nuclew criticality safety) items. The inspectors conducted discussions with PORTS hiaintenance staff and reviewed applicable procedures for work control and preventive maintenance.
Ohictntinna.
The Boundary Dermition hianuals (IlDhis) are used to classify the equipment as Q, AQ.NCS, or AQ for work control, prioritizing Chi (corrective maintenance) and Phi (preventive maintenance), and other maintenance activities. The work controls are similar for Q and AQ.NCS items but less stringent for AQ and NS items. The inspectors noted the imponance of the accuracy of the llDhis to the Maintenance program.
The scheduling and work control processes are automated through the Computerized hiaintenance hianagement System (ChihiS), Although fullimplementhtion of the computer-based system is not required until September 30,1997, under Compliance Plan item 44, the system has been in use for several months and appears to ', beneficial. The ChihtS system reminds the work scheduler of preventive maintenance and calibration activities 21 days in advance of the duc date. Priority is given to Q and AQ-NCS items with respect to scheduling Phi and Chi. Work packages are created which include a system description, work instructions, post. maintenance testing requirements and applicable procedures and can be saved in the system. NCS must approve all work 6
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4 packages without an applicable procedure. Once the maintenance activity is complete, the work package is reviewed and verified by the Front Line hianager for the operation and by work control personnel. The activity is then noted as complete in Chih15 by two independent panies. An on line system can be used to verify that all work packages are closed on a specific piece of equipment.
Chih1S is also used to track performance indicators such as overdue Phi and time to complete Chi. Currently, the ratio of preventive maintenance to corrective maintenance activities is 20/80, v,hich is undesirable. In addition, the maintenance backlog on Q items is increasing. The overdue Phi tasks :ose from 4% in April 1997 to 29% in July 1997.
The target is 2%. Similarly, the average number of days overdue for Chi rose from 62 in April 1997 to 1$8 in July 1997. The target is 30 days. PORTS management responded that maintenance tracking sollware had not been correctly implemented and might be incorrectly inflating the backlog.
The Ph1 requirements for Q and AQ NCS components were baselined in January 1997.
Revisions to the Phi requiremt nts can be requested from the equipment owaer, operator, systems engineer, etc. Plans to trend problem reports on equipment failures to detentine Phi needs are also in progress. Calibration personnel wrote a problem report on the lack of trending of reports generated when portable equipment is outside of the calibration tolerance.
Reliability Engineering documents the technical basis for the Phi and the need for calibration using the Phi Basis Determination form. A procedure for using the form is currently being written. The inspector reviewed the Phi determinations for AQ NCS components in the X 333 and X 705 buildings. One exhaust fan required Phi although it was not classified as AQ NCS in the current revision of the DDht. Reliability Engineering
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personnel noted that the fan was probably classified as AQ NCS in the previous revision of the DDht. No instances of deficient Phi or chibration requirements were identified, inspectors noted that an in line mass spectrometer in product withdrawal is identified as AQ and should be AQ NCS. These instruments are used foi determining assay in the process gas and are safety related because they are relied on, along with sampling, to determine the enrichment of uranium produedust before it is placed in cylinders. The facility agreed to review classification of the mass spectrometers with respect to the
- appropriate NCSA/NCSE.
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'kencluspns The framework of the Maintenan:e program for Q and AQ-NCS components is intact.
The wc;k control prc2:ss is p;oceduralized and automated. Computerized trending naalvsis of prot >lem reports is aho planned Preventive mamtenance requirements have ben determir ed, and proccus are established for users of the equipment to request a change in the PM. Communication between Maintenance, Engineering, Operations and the Plant Shin Superir.todent L good. The backlog of overdue maintenance tasks is inereasmg aitJ uilitic t%6ed us IFl 70 7002/97 206 07 Review of mass spectrometer classifcation to determine whether it 4. properly AQ or AQ-NCS will be trackeJ as IFl 70-7002/97 206-06.
9.0 NClinfpWilonLhtditsJLndJnmligations Sws The inspectors reviewed tho.udit and inspection program to evaluate whether there are periodic audits of the NCS function and how these audit findings are addressed, and to verify that operat;ons are adequately inspected by the NCS stalTon a periodic basis and prompt and appropriate corrective actions taken.
Ohsst.igns A. Internal Audits The inspetors found that there are two institutionaliied forms of NCS audits: (a) audits conducted by the Independent Assessment Group (IAG)in all plant areas, including NCS, and (b) monthly walkdowas of operations conducted by the NCS function.
In the case of NCS audits by the I AO, the inspectors found that the entire NCS function was audited triennially and in accordance with the Audit Plan, with approximately one third of the program being audited annually. The inspectors verified that problems encountered during the audit process were tracked as part of the problem report system and that NCS reviewed the audit findings for conective action. The inspectors verified that inspection findings were screened for possible investigation. The inspectors did not examine the investigation process since there were no investigations related to nuclear criticality safety performed. The audit scheduling and problem tracking and resolution systems were adequate.
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' In the case of operations audits conducted by the NCS function, the inspectors found that facility walk throughs by the NCS stairwere scheduled by the NCS Documentation Clerk and conducted, as required in SAR Section 5.2. Ilowever, no procedure for conducting the walk throughs exists. These walk throughs consist of moathly walk-downs of operations. as well as field vtrification that the controls in a completed NCSA have been implemented. The inspectors reviewed the status of several commitments in this area made in the regulatee's response to Violation 97 203-05. In linclosure 1, the regulatee stated that they had increased the frequency of monitoring operations via the NCSA monthly walkdown program. The inspectors examined the monthly walk through schedule and discussed this issue with the Manager of Nuclear Criticality Safety and determined that the frequency of monitoring had not been increased as of the time of the inspection. The regulatec also committed so using the information collected from the NCSA monthly walkdown program to trend NCS non-conformances. This system of trending non-conformances has been developed as committed, but there was insullicient data to demenstrate its long term effectiveness. Further, the regulatec committed to deselop and distribute an NCS bulletin to communicate to the general plant population important NCS issues. This action will be completed by August 29,1997. On August 28,1997, the inspectors reviewed the first issue of the bulletin and verified that it would be issued the following day and as needed.
- 11. NCS Problem Follow up The follow up of the NCS function to problem reports was also examined. Problem repoi ts from various sources are entered into a centralized computer database for tracking pur}mses, the Ilusiness Prioritization System. The inspectors examined several NCS related problem reports from the month of August 1997, and found that most of them were addressed in a prompt manner, Problem Report PR PTS 97-7087, issued on August 5,1997, concerned changes to the cell voh.me data as used in the criticality calculation NCS-CALC 96-012, Determination of Dry Sub-Critical Mass at 20% 2"U.
The pioblem report noted non-conservative discrepancies in the internal volume of process cells and was originally issued as pR-PTS-97 1891 on February 24,1997.
Although the discrepancy concerned the configaratior; of process equipment containing enriched uranium, the problem report was not evaluated to determine the safety implications for more than five months. The inspectors determined that the reason for this was that the Plant Shift Superintendent.(PSS), who is responsible for screening the problem reports, did not recognize that this problem had NCS significance.
C. Dry Criticality Calcu!: tion NCS CALC 96-012 considered the amount of dry UF. (containing an ll/U = 0.08?) that would be required to sustain a nuclear criticality. The model conservatively considered i
ik amount of moderator to be the maximum permissible feed impurity, the material to bc r
in a spherical configuration, and the material to be surrounded by 12" water to simulate reflection by surrounding equipment. It was determined that I ton of dry UF. and 0,75 g
tons of dry UOh would be required to sustain a criticality. The cell volume was used along with the maximum theoretical density of the gas to determine the amount of material available to form a critical mass. On this basis, it was concluded that there was insullicient material in the cell to allow a criticality without losing moderation control. The volumes of X 25 and X 27 cells were found to be larger than the number that was quoted in the SAR and used in the above calculation. The reason for this discrepancy was that previously much of the associated piping and instrumentation lines coimected to the cells was ignored in the determination of cell volume. In particular, cell X 271 8 was found to more than double in volume when all the associated piping was included. When these new numbers were used, the X 27 cells could not be demonstrated to be incapable of sustaining a dry criticality.
The regulatee performed an additional calculation in which the contents of an individual l
stage were used rather than the contents of an entire cell, to show that the available mass was less than the minimum dry critical mass. Thejustification for reducing this mass by the number of stages in a cell was not provided in the calculation. Upon discussions with NCS stalT, the inspectors determined that this was based on thejudgement tbst the interaction between stages would be negligible The basis was Engineering Evaluation E%X 832 97-002, Rev. O," Justification of 10 Foot Spacing Requirement Be: ween Removed planned Expeditious llandling Equipment and Other Uranium bearing Equipment,"
llowever, this evaluation did not adequately bound the interaction between stages in a cell because the stages are ia some cases closer than the 10 feet addressed in the evaluation, and because of their larger size and therefore greater efTective solid angle than the equipment considered in the evaluation. The regulatee agreed to perform an interac; ion analysis using an :uray of discrete spheres containing in sum the corrected theoretical cell
- contents, C2nclusions The inspectors determined that the system for performing triennial audits on the NCS
' function and tracking audit fmdings was adequate. The system for tracking and performing monthly operations walkdowns by NCS staff was similarly found to be adequate, The long response time to resolve problem report PR-PTS 971891 shows a weakness in how these reports are screened for NCS review. The previous system of having the PSS review these reports for NCS significance has been replaced by having the NCS Documentation Clerk do the screening and this is expected to reduce the probability of having similar nuclear criticality safety issues unreviewed by NCS in the future. Once NCS received the problem report and new cell data, it responded promptly, although the conservatism of the initial calculations could not be demonstrated. Commitments made in 10
W the response to the Notice of Violation in Report 70 7002/97 203 were found to be
' incompletely implemented. Specifically, the commitment to increase the monthly walkdown frequency had not been implemented, and there was insuflicient data history to evaluate the trending of walkdown findings.
t Justification of the cascade dry criticality determination is being revised and will be tracked as IFl 70 7002/97 206-09 The safety signiGeance in this case is low.
10.0 QiticalityAarm ManjtoriogSystun Scep.c inspectors reviewed the placement and functional operation of criticality accident alarm detectors to insure that (1) coverage was adequate to detect the minimum accident of concern and such coverage was adequately analyzed, (2) audibility of the systein was adequate to facilitate an emergency evacuation of all affected personnel in a safe manner, and (3) alarm identification clearly indicated safe routes of evacuation.
ObsmAliOD3 A. CAAS Operability Testing The inspectors examined the procedure and system for testing the operability of the CAAS. The inspectors found tha' the schedule for testing the CAAS monitors existed, as required, and had been incorporated into the plant wide CMMS. The monitors on the cell floor are required to be changed out every three months, and ot'sr monitors every six months. There is a grace period of 31 and 61 days, respectively, aller which time no fissile material may be moved in that area. The inspectors examined the records and found that the changeouts were scheduled and performed, as required, and that no monitors had gone into the grace period this year. The inspectors examined the laboratory for testing the CAAS monitors and found that the monitors are tracked by unit number, as well as installation location, and that history files exist on each monitor. The units that are found to fail their functional tests are tagged and repaired prior to being reinstalled. The documentation and traceability of the individual monitors end the history files describing all tests, surveillance, and corrective etions were adequate.
B. TSRs for Facilities with CA.AS Part 76.87 requires TSRs for safety significant design features such as criticality alarms.
Buildings 700,720,744H,760, XT847 are covered by criticality alarms but do not have TSRs requiring the CAAS to be operable and audible. All fissile material has been moved from Building 74411 and facility management proposes to include the building in the CAAS exemption request. The other five buildings, will remain alarmed. A higher iI
maintenance priority is given to alarm clusters with TSRs. The facility will evaluate how to cover these " orphan" CAAS covered facia.h.
C. Adequacy of CAAS Coverage During the first week of the inspection, inspectors observed fissile material stored in Building 74411. CAAS coverage of Building 74411 is from a detector in lluilding 744G, which is a DOE building. Inspectors noted that Building 623 is between 74411 and 744G and is not included in the model for the analysis of CAAS coverage of the buildings.
Building 623 would likely afTect the result of the calculation because it contains three 6000-gallon water tanks and two 3000-pound charcoal filters. CAAS coverage of Building 74411 was not demonstrated due to the inadequate model. This conflicts with TSR 3.11.2 which requires that operations involving uranium enriched to 1.0 wt% or higher '"U be based upon a documented NCSE. A s:op work order has been in effect at Building 74411 since February 1997 and fissile material was removed from the building between the first and second weeks of the inspection. PORTS plans to include Building 74411 in the CAAS exemption request.
CAAS coverage is required for buildings that are not included in the CAAS exemption request such as Building 744L, which is used for handling legacy equipment, and Building 74411. PORTS management proposes to include Building 74411 and 744L in the CAAS exemption request.
D. TSRs for Safety Significant Features 10 CFR 76 87 requires that design features of systems, components, and structures of the plant which, if altered or modified, would have a significant etrect on safety to be included as TSRs. Ilowever, the inspectors noted that the Red Radiation Warning Lights and the building hern system are not incorporated into the TSRs even though they provide an important safety function. For example:
The red radiation warning lights are required for t:: aware personnel who approach a building aller na N2 horns have expired and the building horns have been reset (i.e.,
the N2 ho;ns run until the nitrogen tanks are empty, approximately eight minutes; the building hoins must be reset aller five minutes to preclude damage to the system).
Red radiation warning lights provide a significant safety function for slaved buildings during evacuation to allow plant personnel to determine the appropriate evacuation scenario and path (i.e., the building horn system is dual purpose for both fire and criticality; the red lights identify the accident as a criticality and determine the evacuation path depending upon which lights are illuminated).
The plant horn system provides the only audible alarm in certain slaved buildings 12
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which do not have N2 horns and provides for adequate sound levels for certain clusten ed facilities.
The inspectors determined through a review of plant records that surveillance and testing of both these systems are being completed at the TSR functional level even though they are not included in the plant's TSR list and i.o performance problems were identified.
Therefore, this concern is considered oflow safety significance.
Conclusion Maintenance and testing of the CAAS were adequate.
Coverage of orphan facilities by CAAS TSRs will be tracked as IFI 70-7002/97-206-10.
I 1.0 RCS_Etnergencyloppale r
kops The inspectors reviewed the emergency response function to verify that the Emergency Plan and the associated implementing procedures are adequate to assure the public health and safety in the event of a nuclear criticality accident. The inspectors reviewed the emergency drill program, emergency lighting equipment, and flowdown of appropriate nuclear criticality controls and limits into firefighting instructions and prefire plans.
Objien' Aliens A, implementing Procedures The inspectors reviewed the Emergency Plan and verified that it had been approved by management, and that it contained provisions for contacting on-site and off-site emergency response organizations The list of these emergency contacts and telephone numbers was maintained in the Plant Control Facility (PCF). The inspectors reviewed the following implementing procedures listed in Appendix A of the Emergency Plan:
XP2-EP-EP5031, Emergency Management Drill and Exercise Program XP2 EP-EP1056, Criticality and Radiation Emergencies XP2 EP-EP1037, Emergency Operations Center Concept of 0perations XP2 EP-EP1031, Evacuation 13
XP2 EP-EP1034, Activation of the Operational Assessment Team and Emergency Response Organization e
XP2 EP EP1049, Fire Piotection Procedure These implementing procedures were reviewed and found to be adequate to implement the provisions of the Emergency Plan. The procedures do not require the NCS function to be involved in the decision to activate the Emergency Response Organization (ERO).
Ilowever, the NCS function was found to be involved in the emergency response through its presence in the Technical Support Room in the Emergeticy Operations Center (EOC)
- 11. Medical Facilities The inspectors found that the capability of on site emergency personnel to deal with the medical results of a criticality accident was adequate. There is a small hospital that is staffed during normal working hours, and there are nurses and physicians who can be l
called in on the weekends or off normal hours. Through discussions with the llospital Administrator, the inspectors determined that the hospital contains equipment for isolating and deconisminating radiation victims, and that the medical staff has been trained in the I
Radiation En v2cncy Accident Training provided by Oak Ridge National Labolatory. In the event of a nuclear criticality, the hospital is capable of providing palliative aid to radiation casualties; however, it is not equipped to provide blood transfusions or other life saving treatments. The paramedics also receive similar medical training. Though there are several Letters of Agreement with local olT site hospitals, none of these have the specialists needed to treat these casualties. PORTS is currently developing an agreement with the University of Cincinnati llospital to air-litt radiation casualties there. The inspectors held discussions with stafrof the Nuclear Medicine Department and confirmed that they have a specialist capable of treating Acute Radiation Syndrome.
C. Letteis of Agreement The regulatee has a Letter of Agreement (LOA) with several olT site fire departments to provide additional on site support in the event of a fire emergency. The inspectors reviewed the LOA and confirmed that the off-site firefighters were required to act in a support role to the on site response under the Incident Commander. The inspectors did not directly discuss facility specific criticality safety firefighting precautions with the off site response personnel or examine their access to facility emergency packets.
D. Emergency Drills The inspectors examined the emergency drill program to determine whether the drills and exercises adequately tested the performance of plant personnel during NCS related 14
emergeacies The inspectors examined the final reports issued after completion of several exercises and found that a number of drills were conducted involving various
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criticality related scenarios, including one exercise vhere there was a suspected radiation casualty. Several drills were conducted shot.!y before or aller the regular day shift and !n periods ofdaikness and various weather conditions. These drills frequently involved activating the ERO and included one exercise outside the plant perimeter involving a traflic accident on the interstate. Several drills involved live fire exercises in which combustible materials were ignited at a specified test area to test the fire fighnng capability of the plant. Although no drills were conducted during late night or early morning hours, the drills appeared to be sufliciently detailed to give adequate t.ssurance that the emergency response function would function as required. Final reports were examined to verify that recommended changes were made to the drill and exercise program as lessons were learned, and that other items were tracked as problem reports.
E. Emergency Packets l
The emergency packets used as prefire plans were examined to determine whether they contained information on firefighting restrictions (primarily on the use of water as an extinguishing agent) as a result of NCS concerm The typical NCS concerns regarding the l
use of water are the potential introduction of unwanted moderator and the potential for i
high t>ressure streams to change the geometrical arrangement of fissile material. The i
packe.s for the X-705 building and X-340 complex were examined, because there are moderation control areas in these buildings where such fire fghting restrictions may be expected. In discussions with the inspectors, fire fighting personnelindicated that they were aware of restrictions on the use of water in these areas and expected to find i
instructions to that effect in the emergency packets. They also indicated that the packets did not contain sufiicient firefighting instructions to permit their eflicient use as prefire plans, and in particular lacked information regarding the location of hose cabinets and fixed fire protection systems. When the emergency packets in the EOC were examined, the emergency packet for the X-705 Building was found to contain a list of relevant NCSAs. In the event of fire an individual would need to determine which NCSA governed the particular area in concern, and then examine the analysis to make a judgement concerning the use of water. NCS restrictions on firefighting activities are not codified in the NCSAs, and must be deduced from controls and limits on moderation, spacing, and other parameters. Because of this, there are no specific postings regarding use of firefighting equipment in moderation control areas.
Procedure XP2 EP EP1049, Fire Protection Procedure Acv.1, requires that the emergency packets contain information on Designation of Nuclear Criticality Safety concerns and that copies of the packets are reviewed semiannually by the responsible Facility Cuetodian. The emergency packets in the EOC and X-300 buildings did not contain the required information for the X-340 complex and X-705 building. In the case of the X 340 complex, the appropriate information existed in the complex but was not s
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included in the copies available to the EOC and PCF. The 1:acility Custodian for this area had signed ofron these packets, as required, but did not ensure that they contained the latest infbrmation. Although the fire Oghting and NCS stafrappeared knowledgeable about fire fighting restrictions, identification of these restrictions was not formally documented in the case of the X 340 complex and is considered VIO 70-7002/97 20611.
PORTS took prompt corrective action to ensure that the identified packets were updated, and issued Problem Report PR PTS 97 7666 to review all remaining packets and initiate a discussion between nuclear criticality safety, emergency operations, und fire fighting stafr to evaluate the need for better listing of NCS related concerns and scenarios in the packets. FORTS rdso agreed to conduct additional training of the fire fighting stafras needed.
l F. Emergency 1.ighting and Evacuation Routes l
The inspectors walked down the X-333 process building to ensure the adequacy of emergency lighting and evacuation routes. The inspectors determined that evacuation f
routes are not fonnally posted in the Area Control Room, and are indicated on the cell and operating floor by posted exit signs. The routes appeared to be the shortest distance to the nearest wall, and then along the wall to the nearest exit. On the cell floor, the evacuation routes were to the nearest wall and then down the stairs on the outside of the building. The evacuation routes appeared to be the most reasonable ur. der most circumstances, although they could have evacuees rtmning into the source of a fire or criticality accident depending on the location of the hazard. The exit signs that were along the outer walls and those at the bottom of the internal stainvells were illuminated.
liowever, those in the central ponion of the building were not illuminated. The inspectors observed the emergency lighting in the process buildings and detennined that they appeared to provide adequate coverage of the operating and cell floors, although an internal audit found that there was less than adequate coverage of the shower rooms. The inspectors observed the schedule and piocedure for testing the emergency lighting system, and found that the procedure for testing the emergency lights tested both the actuation circuit and the light itself, and was adequate. This was continned by a test perfonned by the licensee in which the entire X-330 Building lost electrical power and the emergency lights were actuated. Drawings showing the specific location of emergency lights existed and showed full coverage of the cell and operating floors.
CushiSion l
The training of hospital, paramedic, and fire fighting stafrappeared adequate to ensure an effective response in the event of a criticality or radiological accident, and an agreement is under development to ensure that appropriate medical care will be available in the event of a criticality accident. The fire fighting staff had possession of and training in the use of specialized emergency response equipment, including radiation monitoring equipment.
16
m.
1 J
The module for training fire fighting personnel in NCS appeared adequate in content, and 3
'the staff was knowledgeable regarding general NCS issues in the plant.
- However, the emergency packets lack identification of nuclear criticality safety concerns L
that can affect fire protection actisities. ; This represents a potential safety-significant weakness in the emergency response program, in that the incident Coordinator and response personnel may not have access to appropriate information in the event of a fire in areas _containing fissile material [ Procedure XP2-EP EP1049 states that the packets are f
- vital io emergency responso. The packets serve as pre-fire plans and provide information
. that reduc.es the threat to safety and health. There appears to be a disagreement between Fire Support Services and the Emergency Response Organization regarding the' desired contents and utility of the packets, indicating a potential lack of communication between the various emergency functions. The packets that did contain NCS information did not -
s have a standarJ format for this information and the NCS concerns in some cases could not be read sufliciently quickly to permit its eflicient use in an emergency;
)_
The drill program adequately involved and exercised all aspects of the emergency response -
organization. The evacuation routes and emergency lighting system were adequate.
i PERSONS CONTACTED' fail Meeting Summary Inspectors met with PORTS management throughout the inspection,- A " mini exit" meeting was held with PORTS management on July 25,1997, to discuss issues and summarize the status of the inspection at that point ( An exit meeting was held on August 29,1997. No classified or proprietary information was identified. The following is a partial list of exit meeting attendees:-
U.Sc Enrichment Corocration -
l' Lee Fink, Nuclear Regulatory Affairs Sid Martin, Nuclear Regulatory Affairs
- Ron Gaston, Nuclear Regulatory AfTairs Portsmouth Gaseous Diffusion Plant Mark Hasty, Engineering Manager Ed Wagoner, Nuclear Safety Manager Russ Dunham, Criticality Safety Manager Charley Blackston, Nuclear Regulatory Affairs
~ Don'Rockhold, Nuclear Regulatory Affairs j,
17 i
4
NuckAtReguhtory Cominigion Dennis Morey, inspector, NRC 1leadquarters Chris Tripp, inspector, NRC Headquarters Charlie Cox, Senior Resident inspector, Portsmouth og Sandra Larson, Contractor, Ilattelle ITEMS OPENED, CLOSED, AND DISCUSSED
^
Item Status Description IFl 97-203-13 Closed Part 76.68 change reviews.
URI 203-04 Closed Solid Angle interaction calculations. See IFI 97 206-03.
URI 97 203-10 Closed NCS review of ESDSs. See IFl 97-206-04.
NCV 97 206-01 Opened PVC raschig rings NCV 97-206-02 Opened Failure to adjust solid angle calculations to SAR requirements.
IFl 97-206-03 Opened Follow up of corrective actions for URI 97-203-04.
IFl 97-206-04 Opened Follow up of corrective actions for URI 97-203-10.
VIO 97-206-05 Opened inadequate basis for ten foot spacing rule on PEli equipment.
VIO 97-206-06 Opened TSRs for Tails Withdrawal and LAW stations.
IFI 97-206-07 Opened Backlog of overdue maintenance.
IFI 97-206-08 Opened Review of mass spectrometer classification as AQ or AQ-NCS, IFI 97-206-09 Opened Justification of cascade equipment dry criticali y, t
IFl 97-206-10 Opened Coverage of orphan facilities by CAAS TSRs.
VIC 97-206-11 Opened Flowdown of firefighting instructions into emergency packets, 18
d
- LIST OF ACRONYMS AQ
- Augmented Quality 7 AQ-NCS
_ Augmented Quality-Nuclear Criticality Safety _
-BDM Boundary Definition Maaual CAAS Criticality Accident Alarm System
- CM
- Corrective Maintenance CMMS
_ Computerized Maintenance Management System -
- EOC Emergency Operations Center ERO Emergency Response Organization ESDS-Engineering Specification Data Sheet
.GDP Gaseous Diffusion Plant IAG Independent Assessment Group IFI Inspector Follow-up Item l
. LAW
' Low Assay Withdrawal l
LOA.
Letter of Agreement -
NCS Nuclear _ Criticality Safety
- NCSA Nuclear Criticality Safety Approval NCSE Nuclear Criticality Safety Evaluation I
PCFi
- Plant Control Facility
- PEH<
Planned Expeditious Handling PM Preventive Maintenance PORTS Portsmouth Gaseous Diffusion Plant PSS
' Plant Shift Superintendent Q
Quality _
1 SAR.
Safety Analysis Report -
TSR Technical Safety Requirement :
-Unresolved item 19