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On March 15, 2018 during an NRC inspection … On March 15, 2018 during an NRC inspection of the Solvent Extraction area, an inspector identified a potential credible scenario which is not adequately addressed in the applicable Criticality Safety Evaluation (CSE). Plant Environmental Health and Safety (EH&S) staff reviewed the issue and at 1130 (EDT) determined that, based on the available information, the scenario did not appear to be properly analyzed in the CSE and thus the Integrated Safety Analysis (ISA). The scenario is associated with the Uranium Recovery and Recycle System (URRS) 706 hood operation. The process performed in the 706 hood is the transfer of low concentration residues into a container for disposal at a Low Level Radioactive Waste (LLRW) facility. There was no actual event, and no impact to public health and safety, the workers, or the environment.</br>The issue revolves around the lack of a specific analysis controlling the handling, transport and replacement of the container, a 55 gallon drum, used in that process. A criticality event for the scenario of an inadvertent container handling upset was identified as incredible in the safety basis documents. However, the accident sequence does not meet the definition of incredible as defined in the license application, and thus appears to be an improperly analyzed scenario.</br>While not properly documented, unlikely, independent, and concurrent changes in process conditions would have to occur to result in a criticality accident. Procedural controls and process barriers which are in place were not identified as Items Relied On For Safety (IROFS) for this scenario. There are, however, passive and administrative IROFS in place for other chemical, fire and criticality safety accident sequences that can be applied to this scenario. These IROFS include requirements for mechanical integrity and spill protection techniques to preclude significant loss of uranium bearing liquid material that would have to accumulate in an improperly handled container. Examples of existing IROFS that control process leaks include SOLX-903 and WASH-119, degradation resistant design to prevent leakage from tanks/vessels; SOLX-503, structural integrity of piping; ADUHNP-901, flange guards; ADUHFS-507 and SOLX-505, valve alignments to prevent spills; and DPH-104, piping integrity. In addition, there is annual training and testing on the proper handling of non-favorable geometry containers. </br>The hood and associated container were removed from service while the scenario is being evaluated. Issue Report 2018-7306 was entered into our Corrective Action Program, and an extent of condition was performed.</br>Based on the extent of condition, the cylinder wash area has been identified for additional evaluation.</br>* * * UPDATE ON 3/16/18 AT 1643 EDT FROM NANCY PARR TO DAVID AIRD * * *</br>Based on evaluation of the extent of condition, a similar scenario was identified with the wet combustible trash system in the Uranium Recovery and Recycle System (URRS) area. This event report is updated to include a 24 Hour Event Notification for the wet combustible trash system based on 10 CFR 70 Appendix A(b)(1) 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis, and which results in failure to meet the performance requirements of 10 CFR 70.61.'</br>The issue revolves around the lack of a specific analysis controlling the handling and transport of containers, 55 gallon drums, used in the wet combustible trash process. A cylinder wash operation is in the area where the wet combustible trash drums are used. Cylinder wash operations were shutdown to preclude significant loss of uranium bearing liquid material that would have to accumulate in an improperly handled drum. Similar procedural controls, process barriers and IROFS from other accident sequences can be applied to this scenario. Wet combustible trash collection may continue since the potential source of liquid material (cylinder wash) has been shut down.</br>Notified R2DO (Nease) and NMSS (via email).n.
Notified R2DO (Nease) and NMSS (via email).
15:30:00, 15 March 2018 +
53,266 +
11:16:00, 16 March 2018 +
15:30:00, 15 March 2018 +
On March 15, 2018 during an NRC inspection … On March 15, 2018 during an NRC inspection of the Solvent Extraction area, an inspector identified a potential credible scenario which is not adequately addressed in the applicable Criticality Safety Evaluation (CSE). Plant Environmental Health and Safety (EH&S) staff reviewed the issue and at 1130 (EDT) determined that, based on the available information, the scenario did not appear to be properly analyzed in the CSE and thus the Integrated Safety Analysis (ISA). The scenario is associated with the Uranium Recovery and Recycle System (URRS) 706 hood operation. The process performed in the 706 hood is the transfer of low concentration residues into a container for disposal at a Low Level Radioactive Waste (LLRW) facility. There was no actual event, and no impact to public health and safety, the workers, or the environment.</br>The issue revolves around the lack of a specific analysis controlling the handling, transport and replacement of the container, a 55 gallon drum, used in that process. A criticality event for the scenario of an inadvertent container handling upset was identified as incredible in the safety basis documents. However, the accident sequence does not meet the definition of incredible as defined in the license application, and thus appears to be an improperly analyzed scenario.</br>While not properly documented, unlikely, independent, and concurrent changes in process conditions would have to occur to result in a criticality accident. Procedural controls and process barriers which are in place were not identified as Items Relied On For Safety (IROFS) for this scenario. There are, however, passive and administrative IROFS in place for other chemical, fire and criticality safety accident sequences that can be applied to this scenario. These IROFS include requirements for mechanical integrity and spill protection techniques to preclude significant loss of uranium bearing liquid material that would have to accumulate in an improperly handled container. Examples of existing IROFS that control process leaks include SOLX-903 and WASH-119, degradation resistant design to prevent leakage from tanks/vessels; SOLX-503, structural integrity of piping; ADUHNP-901, flange guards; ADUHFS-507 and SOLX-505, valve alignments to prevent spills; and DPH-104, piping integrity. In addition, there is annual training and testing on the proper handling of non-favorable geometry containers. </br>The hood and associated container were removed from service while the scenario is being evaluated. Issue Report 2018-7306 was entered into our Corrective Action Program, and an extent of condition was performed.</br>Based on the extent of condition, the cylinder wash area has been identified for additional evaluation.</br>* * * UPDATE ON 3/16/18 AT 1643 EDT FROM NANCY PARR TO DAVID AIRD * * *</br>Based on evaluation of the extent of condition, a similar scenario was identified with the wet combustible trash system in the Uranium Recovery and Recycle System (URRS) area. This event report is updated to include a 24 Hour Event Notification for the wet combustible trash system based on 10 CFR 70 Appendix A(b)(1) 'Any event or condition that results in the facility being in a state that was not analyzed, was improperly analyzed, or is different from that analyzed in the Integrated Safety Analysis, and which results in failure to meet the performance requirements of 10 CFR 70.61.'</br>The issue revolves around the lack of a specific analysis controlling the handling and transport of containers, 55 gallon drums, used in the wet combustible trash process. A cylinder wash operation is in the area where the wet combustible trash drums are used. Cylinder wash operations were shutdown to preclude significant loss of uranium bearing liquid material that would have to accumulate in an improperly handled drum. Similar procedural controls, process barriers and IROFS from other accident sequences can be applied to this scenario. Wet combustible trash collection may continue since the potential source of liquid material (cylinder wash) has been shut down.</br>Notified R2DO (Nease) and NMSS (via email).n.
Notified R2DO (Nease) and NMSS (via email).
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00:00:00, 16 March 2018 +
SNM-1107 +
Modification date"Modification date" is a predefined property that corresponds to the date of the last modification of a subject and is provided by <a rel="nofollow" class="external text" href="https://www.semantic-mediawiki.org/wiki/Help:Special_properties">Semantic MediaWiki</a>.
22:49:47, 24 November 2018 +
11:16:00, 16 March 2018 +
0.824 d (19.77 hours, 0.118 weeks, 0.0271 months) +
15:30:00, 15 March 2018 +
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