UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II

245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257

April 30, 2012 Mr. David Precht Manager, Columbia Plant Westinghouse Electric Company Commercial Nuclear Fuel Division 5801 Bluff Road, Drawer R Columbia, SC 29250 SUBJECT: WESTINGHOUSE ELECTRIC COMPANY- NRC INTEGRATED INSPECTION REPORT NO. 070-1151/2012-002 AND TEMPORARY INSTRUCTION 2600/015 INSPECTION REPORT NO. 070-1151/2011-007

Dear Mr. Precht: The U.S. Nuclear Regulatory Commission (NRC) conducted announced, routine inspections between December 12, 2011, and March 31, 2012, at your Columbia, South Carolina facility. The enclosed report presents the results of the inspections. At the conclusion of the inspections, the results were discussed with members of your staff at exit meetings held on December 15, 2011, and February 17 and March 22, 2012. The enclosed integrated inspection report documents the inspection results. The inspections were an examination of activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. The inspections consisted of facility walk-downs; selective examinations of relevant procedures and records; interviews with plant personnel; and plant observations. Throughout the inspections, observations were discussed with your managers and staff. Based on the results of the inspections, no violations of regulatory requirements were identified. In addition, from December 12 through 15, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed a review at Westinghouse Electric Company in accordance with Temporary Instruction (TI) 2600/015, EVALUATION OF LICENSEE STRATEGIES FOR THE PREVENTION AND/OR MITIGATION OF EMERGENCIES AT FUEL FACILITIES. The objective of this TI was to independently evaluate the preventive and mitigative strategies and associated procedures to minimize the consequences of selected safety/licensing bases events and to review the adequacy of those emergency prevention and/or mitigation strategies for dealing with the consequences of selected beyond safety/licensing bases events. Results were discussed on December 8, 2011, with M. Rosser and other members of your staff. The NRCs Enforcement Process will be used to further evaluate any identified issues to determine if they are of regulatory significance. You are not required to respond to this letter.

D. Precht

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If you have any questions, please call me at (404) 997-4629. Sincerely, /RA/ Marvin D. Sykes, Chief Fuel Facility Inspection Branch 3 Division of Fuel Facility Inspection Docket No. 070-1151 License No. SNM-1107 Enclosure: NRC Inspection Report w/Attachment: Supplementary Information cc w/encl: Marc Rosser Manager Environment, Health and Safety Commercial Nuclear Fuel Division Electronic Mail Distribution Susan E. Jenkins Assistant Director, Division of Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution

D. Precht

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the public without redaction. If you have any questions, please call me at (404) 997-4629. Sincerely, /RA/ Marvin D. Sykes, Chief Fuel Facility Inspection Branch 3 Division of Fuel Facility Inspection Docket No. 070-1151 License No. SNM-1107 Enclosure: NRC Inspection Report w/Attachment: Supplementary Information cc w/encl: Marc Rosser Manager Environment, Health and Safety Commercial Nuclear Fuel Division Electronic Mail Distribution Susan E. Jenkins Assistant Director, Division of Waste Management Bureau of Land and Waste Management Department of Health and Environmental Control Electronic Mail Distribution
*see previous concurrence PUBLICLY AVAILABLE G NON-PUBLICLY AVAILABLE G SENSITIVE NON-SENSITIVE ADAMS: Yes ACCESSION NUMBER: ML12122A083 SUNSI REVIEW COMPLETE FORM 665 ATTACHED OFFICE SIGNATURE NAME DATE E-MAIL COPY? RII:DFFI /RA/ GGoff 4/30/2012 YES NO OFFICIAL RECORD COPY REV 7.DOCX RII:DFFI /RA by MDS for MT/ MThomas 4/30/2012 YES NO RII:DFFI /RA/ OLopez 4/30/2012 YES NO NMSS:FCSS /RA via email/ DMarcano 4/25/2012 YES NO NMSS:FCSS /RA via email/ TMarenchin 4/25/2012 YES NO YES NO YES NO =

DOCUMENT NAME:

G:\DFFI\REPORTS\FINAL REPORTS\WEST\2012\WEST IR 2012-002

D. Precht

Letter to Mr. David Precht from Marvin D. Sykes dated April 30, 2012 Subject: WESTINGHOUSE ELECTRIC COMPANY- NRC INTEGRATED INSPECTION REPORT NO. 070-1151/2012-002 AND TEMPORARY INSTRUCTION 2600/015 INSPECTION REPORT NO. 070-1151/2011-007

Distribution w/encl: M. Sykes, RII M. Thomas, RII O. Lpez, RII R. Johnson, NMSS C. Ryder, NMSS M. Baker, NMSS PUBLIC

U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: License No.: Report No.: Licensee: Location: Dates: 70-1151 SNM-1107 070-1151/2012-002 Westinghouse Electric Company Columbia, South Carolina December 12 through 15, 2011 February 13 through 17, 2012 March 19 through 23, 2012 G. Goff, Fuel Facility Inspector (Section A.1) M.Thomas, Senior Fuel Facility Inspector (Section B.1 and 2) O. Lpez, Senior Fuel Facility Inspector (Section D.1, 2, and 3) T. Marenchin, Criticality Safety Inspector (Section D.1, 2, and 3) J. Marcano, Structural Engineer (Section D.1, 2, and 3) M. Sykes, Chief Fuel Facility Branch 3 Division of Fuel Facility Inspection

Inspectors:

Approved by:

Enclosure

EXECUTIVE SUMMARY Westinghouse Electric Company NRC Inspection Report No. 70-1151/2012-002 This is a quarterly integrated inspection report that includes routine, announced inspections that were conducted by NRC regional inspectors in the areas of operational safety, management organization and controls, and operator training/retraining. These routine, announced inspections consisted of a selective examination of procedures and representative records, observations of activities, walk-downs of items relied on for safety (IROFS), and interviews with personnel. During the inspection period, normal production activities were ongoing. Operational Safety The inspectors reviewed the implementation of selected IROFS and their management measures to ensure they were able to perform their intended safety function. No findings of significance were identified. (Section A.1) Management Organization and Controls The inspectors reviewed facility organization, procedure controls, internal reviews and audits, plant safety committees, and program management for operational safety, radiation protection, fire protection, and quality assurance programs. No findings of significance were identified. (Section B.1) Operator Training/Retraining The inspectors determined whether the licensee was complying with regulations and license requirements related to the training of licensee employees and other personnel and was implementing an adequate training program. No findings of significance were identified. (Section B.2) Temporary Instruction The inspectors reviewed the licensees strategies and procedures for the prevention and/or mitigation of emergencies at fuel facilities adequate for dealing with the consequences of natural phenomena hazards. Two unresolved items were identified. (Section E.1, 2, and 3)

Attachment List of Persons Contacted List of Items Opened, Closed, and Discussed Inspection Procedures Used List of Acronyms Documents Reviewed

REPORT DETAILS Summary of Plant Status The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide and fabricates fuel assemblies for use in commercial nuclear power reactors. During the inspection period, normal production activities were ongoing. A. 1. Safety Operations Plant Operations (IP 88020)

a. Inspection Scope and Observations Inspectors evaluated the process waste areas of Scrap Uranium Processing; Uranium Recycling and Recovery Services (URRS) which includes the incinerator and solvent extraction (SOLX) process; and Wastewater Treatment (WWT), which includes the Water Glass process. As part of the inspection effort, the most current Integrated Safety Analysis (ISA) for these areas was reviewed. Select IROFS, corresponding management measures, accident scenarios, risk assessments, configuration changes, calibration/functional testing, and operator training in these areas were inspected/reviewed in order to determine whether the licensee's plant operations are being conducted safely. The inspectors conducted several field activities that included the following: Tours of the URRS, WWT, and Scrap Uranium Processing areas noting IROFS, other safety controls, signs/postings, operators performing routine duties, and housekeeping. Complimentary tours of the Integral Fuel Burnable Absorber (IFBA) area and the erbium (ERBIA) area. Walk-down of the WWT area. This walk-down included a climb to the top of Waste Tanks 1160-A, B, and C. Walk-down of the SOLX and URRS (including the incinerator) noting IROFS and other safety controls. Observed shift turnover and management meetings. Reviewed log book entries in control rooms. Interviewed four operators in URRS (outdoor portion) and one operator in URRS (indoor portion). Reviewed training records for the same four operators in URRS (outdoor portion).

Specifically, the inspectors reviewed the pertinent chapters of the ISA for Scrap Uranium Processing, URRS including the incinerator and SOLX, and WWT. Reviewed changes that were made to the current revision did not diminish the effectiveness of the ISA. Furthermore, the inspectors walked down select IROFS in each of the aforementioned areas and confirmed the presence and location of each. Both active engineered and passive engineered IROFS were observed. Electronic records for calibration and functional testing (where applicable) of IROFS were viewed and confirmed to be performed at the required frequency with satisfactory results.

2 To add, the inspectors reviewed revised configuration management/control of the SOLX area by walking down two process and instrumentation drawings (P&IDs). The inspectors noted that the IROFS were congruent with the drawings. Furthermore, the inspectors interviewed four URRS operators in regards to their training. Each operator spoke favorably about the content, thoroughness, frequency, and effectiveness of the training provided. Noteworthy was the effectiveness of the Green Book system. Two operators discussed licensee managements promptness and comprehensiveness of the resolution of potential safety concerns using this system. In addition, the Red Book system was also stated as being effective at rectifying actual safety issues. Also, a fifth operator was interviewed in the plant, specifically at the incinerator. The inspectors asked to observe his actions when he operated the incinerator. With the applicable procedure in hand, the inspectors verified that this operator performed the required steps outlined in the procedure. The inspectors observed communications within three control rooms. The communications were clear and easily understood among the operators, technicians, and management. The inspectors observed communications at the shift turnover meeting and the station meeting. Communications were clear, organized, and easily understood. While in the control rooms, inspectors reviewed log book entries. No safety issues were identified. In addition, the inspector(s) reviewed four internal audits of the waste processing area. All audits appeared to be thorough and comprehensive. All were performed at the required frequency. b. Conclusions No findings of significance were identified. B. 1. Facility Support Management Organization and Controls `(IP 88005)

a. Inspection Scope and Observations The inspectors interviewed a selection of senior managers, intermediate managers, and supervisors, to verify that the management team had an understanding of the plant policy for safety and management responsibilities as defined by the license application. The inspectors reviewed changes in personnel that occurred within the past year. The inspector verified that the personnel selected met the qualifications as required by the license application. Through interviews, the inspectors verified that newly appointed individuals were aware of and implemented their assigned responsibilities and functions. Furthermore, inspectors confirmed newly appointed individuals who did not have at least two years of nuclear experience had been assigned a mentor.

3 The inspectors verified the licensees control of procedures through discussions with licensee staff. The inspectors reviewed selected procedures which were revised in the past year to ensure that they were reviewed and approved in accordance with the license application and the licensees procedure CA-002, Columbia Plant Electronic Training and Procedure System (ETAPS), Revision 46. The inspectors reviewed the licensees problem identification and resolution program to determine if the program was being conducted in accordance with approved procedures and the license application. The inspectors interviewed selected staff to verify their knowledge of the problem identification and resolution program. The inspectors reviewed the audits of the following programs: Radiation Safety, Criticality Safety, Chemical & Industrial Safety, Environmental, MC&A, Fire Protection, and Emergency Preparedness and determined that the audits were conducted at the frequency required by the license. The inspectors reviewed recent event and incident investigations conducted by the licensee and determined that they were conducted in accordance with the license application section 3.7, Incident Investigation. The inspectors reviewed safety committee meeting minutes and verified that the committees were operating per the requirements of the license application and implementing procedures. The inspectors also interviewed selected staff to verify that they were using the internal safety reporting systems. The inspectors verified that the licensees quality assurance program was being implemented in accordance with section 3.3 of the license application. Through these interviews and examinations of records, the inspector determined that the licensee was performing the appropriate tests on systems and components important to safety. b. Conclusions The inspectors determined that the program audits met the license application requirements; covered a wide range of safety concerns; and were generally self-critical. The qualifications of the new management complied with license requirements. The identification, tracking, and closure of corrective actions were performed in accordance with established procedures. Revisions to operating procedures and facility equipment changes were being properly initiated, revised, reviewed, approved for release, and controlled. No violations of NRC requirements were identified. 2. Operator Training/Retraining (IP 88010)

a. Inspection Scope and Observations The inspectors reviewed the Operator Training program and evaluated the program against the license application. The inspectors interviewed the licensee on changes to the training program in the past year and reviewed applicable procedure revisions. The inspectors determined that changes made were in accordance with the license application.

4 The inspectors reviewed seven implementing procedures. The inspectors determined that the license application requirements of section 3.4.2 had been incorporated into each of these implementing procedures. The inspectors discussed and observed training with selected staff encompassing a variety of positions. The inspectors observed Nuclear Safety Qualification Training (NSQT). The inspectors interviewed class participants on the content of the training material and the frequency that this training was required. The inspectors also interviewed the training instructor on the same topics and, as a result, determined that the training was in accordance with the license application and approved procedures. Through observation of the NSQT the inspectors determined that the training course incorporated the requirements in 10 CFR 19.12. The inspectors interviewed plant operators and determined that the operators were knowledgeable of their operating processes and the testing requirements for the IROFS. Changes to a procedure or changes to a process were readily identified by operators through the computerized system for controlling these activities. Key safety actions required for continued qualification were accomplished and acknowledged by the operators in a timely manner and as required by site procedures. The inspectors viewed the crane training video and reviewed the accompanying examination. The inspectors verified that key points from the video were incorporated into the examination. The inspectors determined that trainee understanding and command of learning objectives were evaluated as required by the license application. b. Conclusions The training program elements reviewed by the inspectors were in compliance with license requirements and regulations. Training requirements were implemented and maintained for licensee employees and contractors in accordance with license requirements. Training material and examinations were adequate to measure the knowledge level of the workers and were current. No violations of NRC requirements were identified. No findings of significance were identified. C. Special Topics Follow-up on Previously Identified Issues

1.

a. (Closed) Licensee Event Report 2011-003: Dimension of Special Nuclear Material (SNM) carrying pails different from value in safety analysis. The inspectors reviewed the corrective actions, interviewed personnel cognizant of this event (Event Notification 47330), and observed the digital caliper used to measure the SNM one and a half gallon carrying pails. The licensee had revised procedure QCI310905, Inspection of Items Relied on for Safety (IROFS) - Common Containers, Revision 8, to require the measurement of the widest part of the pail to be taken using a digital caliper locked to the acceptable value. This event report is closed. D. TI 2600/015, Evaluation of Licensees Strategies for the Prevention and/or Mitigation of Emergencies at Fuel Facilities

5 1. Evaluation of licensing basis for accident sequences and consequences associated with natural phenomena hazards.

a. Inspection Scope and Observations The inspectors performed a review of licensing basis documents and safety analysis to determine the facility design and licensing bases as they relate to natural phenomena hazards (NPH). Specifically, the inspectors evaluated the following hazards: earthquakes, high winds, flooding, and extended loss of power and water. The Westinghouse Columbia Fuel Fabrication Facility (CFFF) consists of three primary buildings in which the majority of operations occur. The original manufacturing building was designed in 1968 as a one-story building. Two building additions were constructed in 1978 and 1986. A summary of the evaluated license basis events and potential consequences is presented below: Earthquake The Westinghouse (hereafter referred to as the licensee) stated in their integrated safety analysis (ISA) that the original fuel manufacturing building complied with the Southern Standard Building Code, 1965 Edition, and was designed to meet Seismic Zone 1 criteria. Two other building additions constructed in 1978 and 1986, were designed to comply with the Southern Standard Building Code, 1977 and 1983 Editions, respectively. However, the inspectors noted that there was an incomplete traceability of documentation associated with the design of the facility. The inspectors reviewed the available documentation related to the design of the building structures and were not able to verify that the facility was built and constructed in accordance with the Southern Standard Building Code. This observation was discussed with the licensee. In 2003, the licensee had contracted design engineering support and conducted a preliminary walkthrough review of the fuel manufacturing building and equipment. The overall goal of the review was to obtain a preliminary assessment of the survivability of the fabrication facility structure and the internal equipment. The review was intended to (1) identify building characteristics that, based on past earthquake experience, were known to perform poorly and (2) identify areas needing additional evaluation or improvement. The walkthrough review revealed that a severe earthquake could result in toppling of equipment and collapse of structural walls and members resulting in 1) a potential release of uranium to the environment and 2) possibly a nuclear criticality accident, a high consequence event (as defined in 10 CFR 70.61). Because the seismic review was only a screening review and detailed fragility analyses had not been performed, the licensee determined that it was not possible to reliably estimate what peak ground acceleration (PGA) earthquake would result in severe damage to the building structure. The seismic engineers who performed the screening review estimated, based on the walk-down results, that the building should withstand an earthquake of up to 0.05g PGA. For the Columbia region, the United States Geological Survey (USGS) had estimated a PGA of 0.07g at a 500-year return period.

6 Recommendations to improve the buildings structure and equipment performance during a seismic event were provided. However, the licensee was unable to provide evidence that any of these recommendations had been scheduled or implemented, nor was an explanation provided for the inaction. The licensee entered the observation into their corrective action program as Issue Report # 11-349-C001: Documented Evidence of CFFF Evaluation of the Risk Assessment Recommendations cannot be found. Flooding The licensee stated in their ISA that the estimated 100-year flood elevation is 130 feet based on the U.S. Corp of Engineers flood map. The floor of the main manufacturing building sets at 142 feet above Mean Sea Level (MSL). The licensee also stated that a large flood could impact the low-lying, undeveloped areas of the site but concluded that there was a very low probability that a large flood would result in uranium releases or a nuclear criticality accident. Should a large rainfall event result in flooding in the area, appropriate time would be available to take appropriate preventive and emergency management measures, including evacuating employees and shutting down manufacturing operations, if necessary. The licensee evaluated the potential of flooding from upstream dam failure and concluded that it was highly unlikely. High Winds The licensee stated in their ISA that the main manufacturing building (and its additions) was designed for a wind loading of 20 pounds force per square foot (psf), equivalent to 90 mph winds. High wind events could result in damage to equipment located on the roof (primarily ventilation fans and filters). The licensee estimates that it would take an F2 tornado (113-157 miles per hour) or greater to result in structural damage to cause a possible criticality event or release of uranium hexafluoride (UF6). The licensee estimated a frequency of 5 x 10-4 per year, or approximately a 2000 year return. Consequently, the licensee considered it unlikely that high winds would result in failures of the building walls or other structural items resulting in the aforementioned events. Extended Loss of Power and Water The licensee relied on AC power and the public water supply to ensure that chemical fumes from the fuel manufacturing process were safely removed. The inspectors noted that event scenarios involving exposure to chemical fumes had been analyzed in the ISA and could result in an intermediate consequence to the workers. The inspectors noted that IROFS were in place to mitigate the consequences. Based on documentation reviewed and interviews, the inspectors determined that extended loss of power and water would not exceed the performance requirement thresholds for public safety. Extended loss of power at CFFF could also potentially affect the ability to maintain recirculation in the liquid uranyl nitrate (UN) tanks as part of the concentration control to prevent an inadvertent criticality accident. This system is connected to a backup generator. Response procedures were in place to implement compensatory measures for a complete loss of power scenario. In addition, process interlocks were installed to fail safe upon loss of power, and procedures were in place to secure hazardous materials and shutdown the process.

7 On-site emergency generators and uninterruptable power supplies (UPSs) provide backup power for critical loads, including crucial process equipment; emergency lighting systems; cooling system pumps; all fire alarms, hazard alarms, the criticality accident alarm system, other designated safety alarm systems; conversion control room alarms; health physics sampling systems; and emergency ventilation systems, including scrubbers. Safety Significant Control (SSC), (CHEM-1-1), and preventive maintenance were in place to check the automatic start up feature of the backup generators when normal power is lost. The emergency generators were not SSCs, but the controls to verify their start up were SSCs. Process interlocks will fail safe upon loss of power, and procedures were in place to secure hazardous materials and shutdown the processes. b. Conclusions The inspectors determined that process buildings design specifications were consistent with assumptions used in the analysis of natural phenomena events with the exception of seismic-related events. The inspectors reviewed the available documentation related to the design of the building structures and were not able to verify that the facility was built and constructed in accordance with the Southern Standard Building Code. 2. Verification of the adequacy of emergency prevention and/or mitigative strategies for the consequences for safety/licensing bases events.

a. Inspection Scope and Observations The inspectors verified that procedures, personnel, and equipment credited in the licensees mitigation strategy were properly implemented. In addition, the inspectors verified that the licensee ensured that the emergency prevention and/or mitigation strategy from each selected licensing bases event was appropriate. The inspectors verified that the licensee had procedures in place to respond to NPHs events. The procedures reviewed included procedures credited for safe shutdown of the facility during emergencies; established conditions for re-entry into the evacuated buildings; and damage assessment. The inspectors verified that personnel had been trained to the procedures. The inspectors noted that part of the emergency response training included sessions on techniques for addressing two concurrent, severe events and the development of effective mitigative strategies. The inspectors also verified that agreements and contracts with offsite organizations were present and effective to mitigate the consequences of NPH events. The inspectors reviewed a consequence analysis regarding the potential UF6 releases after a severe earthquake event: Calculation CN-SB-07-01, Revision 1, UF6 Release Consequence Analysis. The inspectors noted that the licensee did not perform a bounding consequence calculation for a severe earthquake. Instead, a realistic consequence calculations was performed. The analysis evaluated a severe earthquake event which breached the UF6 lines from all five (5) vaporizers to the hydrolysis columns and the steam to the vaporizers was lost. The team noted that Westinghouse did not have bases to justify the assumptions used to define the realistic conditions of the

8 analysis. The inspectors noted that the seismic review was only a screening review and detail fragility analyses have not been performed to reliably determine failure modes and building response to seismic loads. In the analysis reviewed, an Intermediate Consequence event for the facility worker (onsite receptor) and a low consequence event for public receptors were identified. The licensee used the Radiological Assessment System for Consequence AnalysisRASCAL, Version 3.0.5, May 2009, to calculate the consequence of the release using different meteorological conditions and release times. The inspectors reviewed the calculations performed as part of the analysis. The inspectors noted that RASCAL 4: Description Models and Methods, dated June 2, 2010, Section 3.2 UF6 Releases from Cylinders, stated that earlier versions of RASCAL (v3.0.5 or previous) used the release rate for the total UF6 inventory, not per cylinder. Thus, if the user wanted to use three cylinders leaking at 10 kg/s, it was necessary to enter a leak rate of 30 kg/s. The inspectors, however, noted that the calculations performed with RASCAL were not representative of the actual conditions that the licensee tried to model because the specified release rate was not multiplied by the number of cylinders. The purpose of the analysis was to model a UF6 release from five vaporizers (i.e., five liquid UF6 cylinders). The inspectors noted from the RASCAL input file that, instead of analyzing a release from five UF6 liquid cylinders, the licensee analyzed a release from one large liquid cylinder with an equivalent mass of five UF6 liquid cylinders. The inspectors performed the same calculations using the appropriate method and determined that the estimated consequence changed from intermediate to high for the workers and from low to intermediate for a public receptor. Based on the results of the original consequence analysis, the licensee determined that a severe earthquake could result in an intermediate consequence event for the workers. As a result, IROFS had to be established to ensure compliance with the requirements of 10 CFR 70.61. The licensee designated IROFS CONV-SEP-901, Personnel Evacuation, and IROFS CONV-SEP-902, Training on IROFS CONV-SEP-901. The expected action noted in CONV-SEP-901 was the incident commander activates the Site Emergency Plan to protect personnel and, from CONV-SEP-902, the incident commander maintains competency on the Site Emergency Plan. The licensee assigned a failure probability score of -2 to each IROFS. Based on the ISA, a score of -2 represents a protection by a trained operator performing a routine task. The inspectors questioned the reliability and the effectiveness of the designated IROFS (implementation of the Site Emergency Plan) to mitigate the consequences of a seismic event since the effectiveness of the IROFS could be impacted by other incidents occurring after the onset of the seismic event. The licensee had not performed a detailed evaluation of the potential consequences of a seismic event and the identified IROFS relied heavily on the knowledge of the Incident Commander in order to complete the mitigating actions. Section 3.4 of the License Application, states, in part, that procedures, training, and qualifications are management measures. Furthermore, Chapter 3.0 of the License Application states, in part, that management measures are applied to Safety Significant Controls (SSCs) designated as IROFS to provide reasonable assurance that they are designed, implemented, and maintained, as necessary, to ensure they are available and reliable to perform their intended functions when needed. Therefore, IROFS CONVSEP-902 could not be designated as an IROFS because it is a management measure

9 for IROFS CONV-SEP-901. In addition, the inspectors considered that activities performed while responding to an emergency (i.e., UF6 release as a result of an earthquake) to be non-routine tasks. According to the ISA, the inspectors determined that the maximum failure probability score that could be assigned to IROFS CONV-SEP901 was -1. A score of -1 represented protection by a trained operator performing a non-routine task. The inspectors noted that the licensee assigned a score of -2 as the occurrence rate for a severe earthquake. 10 CFR 70.61(b) states, in part, the risk of each credible high-consequence event must be limited. Engineered controls, administrative controls, or both, shall be applied to the extent needed to reduce the likelihood of occurrence of the event so that, upon implementation of such controls, the event is highly unlikely. The licensees ISA stated that the accident sequence is calculated by adding the initiating event index plus the mitigating event index(es). For an accident sequence to be considered highly unlikely the result must be less than or equal to -4. Based on the occurrence rate for a severe earthquake (-2), the reassigned failure probability score (-1) for IROFS CONV-SEP-901, and taking in consideration that the event could result in a high consequence event, the inspectors determined that the licensee did not meet the performance requirement for this accident sequence (-2 +-1 = -3). An unresolved item, URI 70-1151/2011-07-01, was opened to review the licensees response to failing to ensure that the risk of a credible high-consequence event was reduced to highly unlikely. The licensee stated in their ISA that a severe earthquake could result in toppling of equipment and collapse of structural walls and members, possibly resulting in a release of uranium to the environment and/or a nuclear criticality accident. The licensee used Criticality Safety Evaluations (CSEs) to document each process within a system to determine that sufficient defenses of one or more controlled parameters, including bounding assumptions, criticality safety limits, and criticality safety constraints were sufficient to maintain the minimum subcritical margin against an initiating event. 10 CFR 70.61 (d) states, in part, that in, addition to complying with paragraphs (b) and (c) of this section, the risk of nuclear criticality accidents must be limited by assuring that under normal and credible abnormal conditions, all nuclear processes are subcritical, including use of an approved margin of subcriticality. Preventive controls and measures must be the primary means of protection against nuclear criticality accidents. Furthermore, the criticality accident alarm system (CAAS), which is a secondary means of protection used by the licensee, may not be able to withstand the effects of an earthquake. If the CAAS was inoperable at the licensees facility, re-entry into the buildings will be done in accordance with procedures in order to ascertain that a nuclear criticality has not occurred within the building. The inspectors determined that the licensee had not evaluated whether the risk of nuclear criticality accidents was limited by assuring that, under an earthquake scenario, all nuclear processes would be subcritical. The licensee did not formally document this evaluation but was able to discuss their compliance with 10 CFR 70.61(d) with the inspectors. The licensee generated a corrective action (#12-024-C012) to formally document their compliance with 10 CFR 70.61 after such a natural phenomena event. An unresolved item, URI 70-1151/2011-07-02, was opened to review the licensees evaluation regarding whether all nuclear process under an earthquake scenario were subcritical. The licensee had determined that the bounding accident from a criticality would be from the UN Bulk Storage Tanks. This bounding accident covers all liquid and dry system criticality accidents. This bounding accident could potentially have an off-site

10 consequence range to a distance of 3.85 miles from the site. At this distance the levels of total effective dose equivalent (TEDE) exposure will be below the limits of 10 CFR 20.1301. The inspectors observed that the UN Bulk Storage Tanks require AC power to mix the UN stored in the tanks. The mixing is done to preclude uranium in solution from precipitating out of solution and accumulating on the bottom of the unfavorable geometry tanks potentially resulting in a criticality. During an extended loss of electrical power, if the temperature in the area was at or below freezing, the water in the solution could freeze while the uranium would collect at the bottom of the tank. The licensee was aware of this potential issue and had determined that there were strategies in place to address an extended loss of power that included: power from the diesel-drive electric generators, mixing of the tanks by hand, heating of the tank by various methods, and dumping the tanks so that the liquid will form a safe slab geometry. b. Conclusions The inspectors determined that procedures and strategies credited by the licensee for responding to natural phenomena events were adequate to mitigate potential consequences. An unresolved item, URI 70-1151/2011-07-01, was opened to review the licensees response for failing to ensure that the risk of an earthquake was limited by applying sufficient engineered controls, administrative controls, or both, to the extent needed so that, upon implementation of such controls, the event was highly unlikely. Another unresolved item, URI 70-1151/2011-07-02, was opened to review the licensees evaluation regarding whether all nuclear processes impacted by an earthquake would remain subcritical. 3. Evaluation of beyond licensing basis for accident sequences and consequences associated with natural phenomena hazards.

a. Inspection Scope and Observations The inspectors postulated and selected a sample of beyond safety/licensing bases events. The events reviewed were selected based on the licensees safety analysis, engineering analyses, and safety/licensing information. The postulated events included: An event that resulted in the loss of AC power, public water supply, and limited water supply to the ammonia scrubbers. An event that resulted in the loss of mixing ability for the UN tanks.

For the postulated beyond safety/licensing bases events, the inspectors evaluated: 1. Whether the emergency equipment needed to prevent and/or mitigate the consequences for the selected beyond safety/licensing bases events would be available and functional. Whether existing procedures would be sufficient to prevent and/or mitigate the consequences for the selected beyond safety/licensing bases events.

2.

11 3. Training and qualifications of operators, on-site emergency response personnel, and support staff needed to implement procedures for the selected beyond safety/licensing bases events. Whether the requirements or commitments for off-site support or assistance, including agreements and contracts, would be sufficient to address the consequences for the selected beyond safety/licensing bases events.

4.

The inspectors did not identify any issues of significance with the reviewed beyond safety/licensing events. However, the inspectors could not fully evaluate beyond safety/licensing basis events due to the lack of design information for buildings and structures. b. Conclusions The inspectors did not identify any issues of significance with the reviewed beyond safety/licensing events. However, the inspectors could not fully evaluate certain beyond safety/licensing basis events due to the lack of detailed design information for buildings and structures. E. Exit Meeting On December 15, 2011, February 17 and March 22, 2012, the inspectors presented the inspection results to David Precht, Plant Manager, and other members of the licensee staff. No dissenting comments were received from the licensee. Proprietary information was discussed, but not included, in this report.

SUPPLEMENTAL INFORMATION 1. List of Persons Contacted Name R. Bates P. Bartman R. Byrd S. Carver E. Cauley, Jr. D. Colwell G. Couture D. Crone S. Culler B. Faris A. Goldberg D. Graham T. Gregg K. Merrit T. Northcutt J. Peterson D. Precht E. Prytherch M. Rosser C. Snyder R. Taylor J. Watkins 2. Title Maintenance and Equipment Improvement EHS Quality Assurance Lead Team Manager of Instrumentation and Control EHS Emergency Preparedness Manager Area Team Manager (2nd shift) ESH Operations Manager/Radiation Safety Officer EHS Licensing and Regulatory Programs Manager Structural Engineer ESH Records Coordinator Manufacturing Principle Engineer (ISA Engineer) URR Services Process Engineer EHS Technician URR Services Manager Product Assurance Chemical Operation Acting Manager of Nuclear Fuel Continuous Improvement Site Maintenance Manager Plant Manager Maintenance and Equipment Improvement EHS Manager EHS Engineering Manager EHS Engineering Product Assurance Manager

List of Items Opened, Closed, and Discussed Item Number URI 70-1151/201107-01 Status Open Description Review Westinghouses response to the failure to ensure that the risk of an earthquake was limited by applying sufficient engineered controls, administrative controls, or both, to the extent needed to so that, upon implementation of such controls, the event was highly unlikely. Review Westinghouses evaluation regarding whether all nuclear process under an earthquake were subcritical. EN 47330 DIMENSION OF SNM CARRYING PAILS DIFFERENT FROM VALUE IN SAFETY ANALYSIS

URI 70-1151/201107-02

Open

LER 2011-003

Closed

Attachment

2 3. Inspection Procedures Used IP 88005 IP 88010 IP 88020 TI 2600/015 Management Organization and Controls Operator Training/Retraining Operations Evaluation of Licensee Strategies for the Prevention and/or Mitigation of Emergencies at Fuel Facilities

4.

List of Acronyms Used ADAMS ADU CAAS CFFF CSE ED EN ERBIA EH&S ETAPS IC IFBA IROFS ISA MC&A MSL NSQT NRC P&IDs PM PGA psf QA QC RASCAL SSC TDS TEDE UF6 UN UPS URI URRS USGS SOLX WWT Agency-wide Document Access and Management System Ammonium diuranate Criticality accident alarm system Columbia Fuel Fabrication Facility Criticality safety evaluation Emergency director Event notification Erbium process area Environmental Health & Safety Electronic Training and Procedure System Incident commander Integral fuel burnable absorber Item(s) relied on for safety Integrated safety analysis Material control & accountability Mean sea level Nuclear Safety Qualification Training Nuclear Regulatory Commission Process and instrumentation drawings Preventive maintenance Peak Ground Acceleration Pounds force per square foot Quality assurance Quality control Radiological Assessment System for Consequence Analysis Safety significant control Training Delivery System Total effective dose equivalent Uranium hexafluoride Uranyl nitrate Uninterruptible power supply Unresolved item Uranium Recycling and Recovery Services United States Geological Survey Solvent extraction Wastewater Treatment

3 5. Documents Reviewed Integrated Safety Analysis (ISA) Summary, ISA-11, Scrap Uranium Processing System, Revision 6 Integrated Safety Analysis (ISA) Summary, ISA-13, Low Level Radioactive Waste System, Revision 6 Integrated Safety Analysis (ISA) Summary, ISA-07, URRS Solvent Extraction System, Revision 6 Integrated Safety Analysis (ISA) Summary, ISA-15, Wastewater Treatment System, Revision 6 Configuration control print-outs of various safety-related equipment, including IROFS, in the waste processing areas. Drawing 622F01PI01 Sheet 5, Revision 5, Area: UN Storage Pad / UN Storage System. Title: Uranyl Nitrate Transfer Valve Manifold Drawing 301F06PI01 Sheet 1, Revision 3, Area: Solvent Extractor / Misc. Process Util./Serv. Title: SOLX Storage Tank COP -830210, Incinerator Operation, Revision 36 Mechanical Area Formal Compliance Audit, EHS-AUDIT-11-16, 10/14/2011 Environment Health & Safety Audit of URRS Area Lagoon Sampling; EHSAUDIT-11-12, 07/07/2011 Emergency Eyewash and Safety Showers Audit; EHS-AUDIT-11-19, 11/23/2011 Environmental Health & Safety Audit for Hazardous Waste Management; EHSAUDIT-11-21, 12/02/2011 Training records for four URRS operators Electronic calibration/functional testing records for IROFS (computer screen viewing only) Three control room log books (one each in Waste Water Treatment, Solvent Extraction, and Scrap Uranium Processing control rooms) CA-002, Columbia Plant Electronic Training and Procedure System (ETAPS), Revision 46 CA-006, Columbia Plant Training Delivery System (TDS), Revision 23 CA-014, Orientation Process, Revision 6 CA-018, Orientation and Training of Craft Employees, Revision 8 CA-033, Systematic Approach to Training, Revision, 0 CA-220, Nuclear Safety Qualification Training, Revision 2 CA-300, WMS Training and Learning Form Usage, Revision 2 CCF-10632, Install UPS power feeds to Criticality Stations 14, 15, 16, and 17, Revision 0 CN-RRA-98-32, :Hot Oil System Fire Hazard Analysis, Revision 0 CN-SB-07-01, UF6 Release Consequence Analysis, Revision 1 COP-815020, Scrap Recovery Scrubber S-1030, Revision 7 COP-815413, Ammonia Fume Ventilation System, Revision 16 COP-836015, Normal Operation of UN Storage Tanks, Revision 26 COP-836016, UN Tanks Emergency Procedures, Revision 13

4 CPE-RUH-10-005, Hot Oil System and Hot Oil Dryer Preliminary Process Hazard Analysis Final Report, June 11, 2010 CSE-2-A, Uranyl Nitrate Bulk Storage and HF Spiking Station, Revision 4 Drawing 504F03EL01, Criticality Alarm Schematics, Revision C1 Drawing 510F08EL04, Electrical Emergency Panel Schedules, Revision C1 Drawing 510F14EL04, Motor Control Center MCC-1101, Revision 14 Giffels and Rossetti Job No. 6705714 JBFA-LR-391-1-98, Off-site Consequence Analysis Review and Results of Accidental Release of Bulk Chemicals At Westinghouses Columbia Facility LTR-RAC-07-20, Response to natural phenomena and external event request for additional information MI0002, Criticality Alarm System Supported by Portable UPS Units, Revision 0 OM85004, UN Storage Tanks 6 month OM, Revision 0 PM20261, Safety Emergency Generators, Start-Up, Revision 0 Procedure No. 202082, Excess Flow Valves, Revision 4 Project No. 1693329, Westinghouse Natural Gas Pipeline Rupture Explosion Study, March 7 2007 RA-108-4, General Entire Chemical Area, Revision 28 RA-134, Columbia Plant Safety Event Response Guidelines Report No. 282-2-05, Summary of Westinghouse CFFF NPH Risk Assessment, October 2004, Rev. 0 SEP-001, Emergency Response Organization, Revision 6 SEP-002, Classification, Revision 4 SEP-002-01, Classification Logic Flow Chart, Revision 0 SEP-003,Emergency Response Team, Revision 1 SEP-004, Emergency Equipment Supply, Revision 8 SEP-014, Response to Extreme Environmental Conditions, Revision 2 SEPF-001-009, Hazardous Weather, Revision 0 SEPF-001-06, Explosion, Revision 1 SEPF-001-08, Hazardous Material Release, Revision 1 SEPF-001-10, Loss of Utilities, Revision 0 SEPF-001-12, Radioactive Powder/Liquid Release, Revision 1 SEPF-009-10, UF6 Release Conversion Area SEPF-009-13, Tornado Response SEPF-014-020, Severe Weather Shelter Areas SEPF-014-08, Conversion Area Severe Weather Preparation SEPF-014-19, Earthquake Extreme Environmental Conditions, and WSTD-CP-03-7, Maximum UF6 Release Model and Calculations