Information Notice 1989-24, Nuclear Criticality Safety

Nuclear Criticality Safety

ML031180568
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	03/06/1989
From:	Cunningham R NRC/NMSS/IMNS
To:
References
IN-89-024, NUDOCS 8902280162
Download: ML031180568 (7)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 March 6, 1989 NRC INFORMATION NOTICE NO. 89-24: NUCLEAR CRITICALITY SAFETY

Addressees

All fuel cycle licensees and other licensees possessing',ore than critical mass

quantities of special nuclear material.

Purpose

This information notice is being provided to alert addressees to potential

problems resulting from inadequate administration and application of the

double contingency principle in establishing nuclear criticality safety limits

and controls. It is expected that licensees will review the information for

applicability to their facilities and consider actions, as appropriate, to

avoid similar problems. However, suggestions contained in this information

notice do not constitute U.S. Nuclear Regulatory Commission (NRC) requirements;

therefore, no specific action or written response is required.

Description of Circumstances

The double contingency principle, as used in ANSI/ANS-8.1-1983*, states that

"Process designs should, in general, incorporate sufficient factors of safety

to require at least two unlikely, independent, and concurrent changes in process

conditions before a criticality accident is possible.' Proper application of

the double contingency principle provides assurance that no single error or

loss of a control will lead to the possibility of a criticality accident.

In March 1988, an NRC licensee was authorized to operate a new pilot plant

operation involving highly enriched uranium solution. Provisions were made

to remove liquid scrap in 2.5 liter bottles from the operations area (Area 1).

Because of increased quantities of scrap solution and lack of temporary storage, an alternate liquid-handling process was established. The alternate method

allowed both dilute and concentrated scrap solution to be stored in 11-liter

bottles in the same area.'-After an analysis of a single sample, the 11-liter

bottles of dilute scrap solution were to be transferred to an adjacent area

(Area 2) and emptied into mass-limited 55-gallon drums.

• American National Standard For Nuclear Criticality Safety in Operations With

Fissionable Materials Outside Reactors, ANSI/ANS-8.1-1983.

IN 89-24 March 6, 1989 During an inspection in July 1988, NRC personnel recognized that an operator

could inadvertently transfer an unsafe quantity of scrap solution into a drum

by either selecting the wrong bottle of solution or as a result of an erroneous

sample analysis. Such an unsafe transfer could have been effected with only

one unlikely, independent, and concurrent change in process conditions (viz.,

selecting the wrong bottle, recording the wrong analysis or using the wrong

sample analysis, etc.) and hence, the double contingency principle was not

satisfactorily implemented. Because this method of handling 11-liter bottles

was somewhat similar to the handling method contributing to the Wood River

Junction accident in 1964, the NRC inspectors expressed concern. The licensee

immediately ceased all scrap handling and subsequently shutdown the entire

process area to review the safety limits and controls.

Further review disclosed that the nuclear criticality safety-analyst who had

analyzed the process before startup was not familiar with the alternate scrap- solution-handling procedure. Administrators within the licensee's safety group

had approved the change because a safe mass limit had been imposed on each drum

in Area 2. The licensee claimed that the alternate method of solution-handling, permitted by procedure, had not been used because the material control and

accounting restrictions made the method inefficient.

NRC personnel also noted that Area 2 contained several open 55-gallon drums.

Area 2 was used to remove solids from Raschig ring filled drums which were

used-in Area 3 (scrap recovery). Raschig ring filled drums and drums of

chemicals were taken from Area 2 into Area 3. Because a 55-gallon drum was

involved in the Oak Ridge Y-12-accident, NRC personnel expressed-concern with

the lack of controls on open drums. The licensee immediately shutdown Areas 2 and 3 so that the nuclear criticality safety limits and controls could be re- examined.

Discussion:

These events highlight the need for continuing vigilance in providing a sound

nuclear safety program. Some of the licensee's actions taken after the inspec- tion are discussed here. Licensees are encouraged to review these actions and

their own vigilance in assuring nuclear criticality safety.

A team led by a safety director from another of the licensee's nuclear facili- ties conducted an immediate audit of the three areas. The team consisted of

safety and production personnel. The audit team confirmed NRC's findings and

identified other safety items.

All nuclear criticality safety analyses were reviewed to ensure proper appli- cation of the double contingency principle. Documentation of analyses has been

revised to provide explicit consideration of the double contingency principle.

The nuclear criticality safety analysis group now reviews all changes to nuclear

criticality limits and controls. The administrative group can no longer approve

seemingly simple changes such as authorizing new mass limits for work stations, based on established safe mass limits.

IN 89-24 March 6, 1989 Production personnel were not involved in establishing nuclear safety limits

and were not familiar with the above-mentioned nuclear criticality accidents.

The safety training program has been revised to include selected accident

histories.

All involved personnel, including production operators, have reviewed all

procedures. Before startup of Areas 1, 2, and 3, procedures were revised to

include nuclear safety limits and controls. Procedures in other plant areas

will be revised to include safety limits.

Liquid scrap from Area 1 is now collected in favorable geometry containers.

After analysis, the solution is transferred to a favorable geometry quaran- tine tank for a second analysis. Then the solution is transferred to uniquely

identified favorable geometry containers, for transfer to the drums in Area 2.

Most 55-gallon drums in Area 2 have been eliminated by engineering redesign.

Barriers and other controls are in place to prevent unauthorized transfer of

drums into Area 3. Engineering studies are underway to eliminate or reduce

the use of all unfavorable geometry containers in Area 3.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact the technical contacts

listed below or the Regional Administrator of the appropriate regional office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Gerald Troup, Region II

(404) 331-5566 George Bidinger, NMSS

(301) 492-0683 Attachment: List of Recently Issued NRC Information Notices

U-i

/_'ichment

IN 89-24 March 6, 1989 Paze I of I

LIST OFRECENTLY ISSUED

NRCINFORHATION NOTICES

Infornmtl-. I---*t ".

Notice no. SubJect Issuance Issued to

89-23 Environmental Qualification 3/3/89 All holders of OLs

of Litton-Yeam CIR Series or CPs for nuclear

Electrical Connectors power reactors.

89-22 Questionable Certification 3/3/89 All holders of OLs

of Fasteners or CPs for nuclear

power reactors.

89-21 Changes In Performance 2/27/89 All holders of OLs

Characteristics of Molded. or CPs for nuclear

Case Circuit Breakers power reactors.

88-73, Direction-Dependent Leak 2/27/89 All holders of OLs

Supplement I Characteristics of Contain- or CPs for nuclear

ment Purge Valves power reactors.

89-20 Weld Failures in a Pump 2/24/89 All holders of OLs

of Byron-Jackson Design or CPs for nuclear

power reactors.

89-19 Health Physics Network 2/23/89 All holders of OLs

or CPSfor nuclear

power reactors. and

the following fuel

facilities: Nuclear

Fuel Services of Erwin, General Atomic, UNC

Montville. BW LRC

Lynchburg, and BIM

Lynchburg.

89-18 Criminal Prosecution of 2/22/89 All holders of OLs

WIrongdoing Couumtted by or CPs for nuclear

Suppliers of Nlulear power reactors.

Products or Services

89-17 Contamination and Degra- 2/22/89 All holders of OLs

dation of Safety-Related or CPs for nuclear

Battery Cells power reactors.

OL

• Operating License

CP- Construction Permit

UNITED STATES

NUCLEAR REGULATORY COMMISSION FIRST CLASS MAIL

POSTAGE S FEES PAID

WASHINGTON, D.C. 20555 USNRC

PERMIT No. 0-47 OFFICIAL BUSINESS

PENALTY FOR PRIVATE USE. $300

IN 89-24 March 6, 1989 Production personnel were not involved in establishing nuclear safety limits

and were not familiar with the above-mentioned nuclear criticality accidents.

The safety training program has been revised to include selected accident

histories.

All involved personnel, including production operators, have reviewed all

procedures. Before startup of Areas 1, 2, and 3, procedures were revised to

include nuclear safety limits and controls. Procedures in other plant areas

will be revised to include safety limits.

Liquid scrap from Area 1 is now collected in favorable geometry containers.

After analysis, the solution is transferred to a favorable geometry quaran- tine tank for a second analysis. Then the solution is transferred to uniquely

identified favorable geometry containers, for transfer to the drums in Area 2.

Most 55-gallon drums in Area 2 have been eliminated by engineering redesign.

Barriers and other controls are in place to prevent unauthorized transfer of

drums into Area 3. Engineering studies are underway to eliminate or reduce

the use of all unfavorable geometry containers in Area 3.

No specific action or written response is required by this information notice.

If you have questions about this matter, please contact the technical contacts

listed below or the Regional Administrator of the appropriate regional office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Gerald Troup, Region II

(404) 331-5566 George Bidinger, NMSS

(301) 492-0683 Attachment: List of Recently Issued NRC Information Notices

• SEE PREVIOUS PAGE FOR CONCURRENCE

OFC:IMUF:* IMUF:* IMSB:* DD/IMNS* D/IMNS*

NAME:GHBidinger: VLTharpe: LCRouse: GSjoblom: RECunningham:

DATE:2/24/89 2/21/89 :2/24/89 :2/24/89 :2/24/89 OFFICIAL RECORD COPY

IN 89- February , 1989 Production personnel were not involved in establishing nuclear safety limits

and were not familiar with the above-mentioned nuclear criticality accidents.

The safety training program has been revised to include selected accident

histories.

All involved personnel, including production operators, have reviewed all

procedures. Before startup of Areas 1, 2, and 3, procedures were revised to

include nuclear safety limits and controls. Procedures in other plant areas

will be revised to include safety limits.

Liquid scrap from Area 1 is now collected In favorable geometry containers.

After analysis, the solution is transferred to a favorable geometry

quarantine tank for a second analysis. Then the solution is transferred to

uniquely identified favorable geometry containers, for transfer to the drums in

Area 2.

Most 55-gallon drums in Area 2 have been eliminated by engineering redesign.

Barriers and other controls are in place to prevent unauthorized transfer of

drums into Area 3. Engineering studies are underway to eliminate or reduce the

use of all unfavorable geometry containers in Area 3.

No specific action or written response is required by this Information

Notice. If you have questions about this matter, please contact the technical

contacts listed below or the Regional Administrator of the appropriate

Regional Office.

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Gerald Troup, Region II

(404) 331-5566 George Bidinger, NMSS

(301) 492-0683 Attachment: List of Recently Issued NRC Information Notices

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OFC:IMUF: IMUF: IMD'$ N

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NAME:GH er: VLI9arpRouse: * om: R Fning

________________________________________ ____----------

DATE:2/a2489 :2kAL/89 :2/ 89 :2Uq-/89 :2/ 89 OFFICIAL RECORD COPY

IN 89- February , 1989 age 3 of 3 Liquid scrap from Area 1 is now collected in favorabl geometry containers.

After analysis, the solution is transferred to a fay.rable geometry

quarantine tank for a second analysis. Then the solution is transferred to

uniquely identified favorable geometry container4 for transfer to the drums in

Area 2. 7 Most 55-gallon drums in Area 2 have been eli nated by engineering redesign.

Barriers and other controls are in place t prevent unauthorized transfer of

drums into Area 3. Engineering studies e underway to eliminate or reduce the

use of all unfavorable geometry containers in Area 3.

No specific action or written response is required by this Information

Notice. If you have questions about this matter, please contact the technical

contacts listed below or the Regiohtal Administrator of the appropriate

Regional Office. /

Richard E. Cunningham, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts: Ge aId Troup, Region II

( 04) 331-5566 eorge Bidinger, NMSS

(301) 492-0683 Attachment: List Recently Issued NRC Information Notices

EKraus

OFC:IM Ig IMUF: IMSB- DD/IMNS D/IMNS

NAME:GHBi r> VLTI pe: L e: GSjoblom: RECunningham:

DATE:2 /89 :2/ "89 :2/ Z789 :2/ /89 :2/ /89

1 OFFICIAL'RECORD COPY