DEFENSE NUCLEAR FACILITIES SAFETY BOARD
                                                 January 10, 1994

MEMORANDUM FOR:     G. W. Cunningham, Technical Director

COPIES:             Board Members
               
FROM:               Larry Zull, DNFSB Staff

SUBJECT:            Trip Report for Staff Visit to the Savannah
                    River Site (SRS) Replacement Tritium Facility
                    (RTF), December 8-10, 1993

1. Purpose:  The purpose of this site visit was to conduct followup
   technical reviews on various topics as the RTF approaches the
   completion of the Startup Test Program.  Reviews were also
   conducted to closeout several open items identified in the DNFSB
   Staff Topic Papers. The review team for this trip consisted of
   Ajit Gwal, Herb Massie, and Larry Zull.

2. Summary:

   a. The facility is nearing completion of the Startup Test
      Program, with only 24 of approximately 450 total startup and
      integrated system operations tests remaining. All testing
      necessary to load production reservoirs on one loading line
      has been completed. Reviews by the design agency, the Sandia
      National Laboratory, to certify the loading of the first
      reservoir type for production are scheduled for January 5-7,
      1994. 

   b. Testing of the Thermal Cycling Absorption Process (TCAP),
      which separates tritium from deuterium, and the In-Bed
      Accountability Process (IBA), which determines the amount of
      tritium stored on the hydride beds, is in progress, with
      completion expected by March 15, 1994. These tests are being
      performed in parallel with the program to certify the
      loading and unloading of reservoirs for war reserve
      production operations. If the TCAP system cannot separate
      deuterium and tritium to the required purity levels, the
      cryogenic separation process in the existing tritium
      facility can be used to provide the tritium and deuterium
      necessary for RTF to process reservoirs for war reserve
      production.  
   
   c. Several concerns were identified during the reviews,
      including the following:
   
      1.  Fire water tanks have not yet been connected to piping
          leading to the RTF. The fire water tanks are seismically
          qualified, but the connecting piping is not seismically
          qualified. WSRC intends to connect the piping prior to
          war reserve production, which is currently scheduled for
          March 1994. However, RTF has not conducted fire drills to
          demonstrate the ability to fight fires using the water in
          these tanks in the event piping unavailability. Good
          commercial practice in such a situation would include the
          planning and conduct of fire drills.

      2.  The environmental qualification report for Seismic
          Tritium Confinement System (STCS) components has been
          revised to impose administrative controls to prevent
          equipment from exceeding design temperature limits,
          instead of qualifying the components to the anticipated
          abnormal conditions. Although the use of such
          administrative controls is an acceptable approach, it is
          not the preferred approach, and sole reliance on
          administrative controls is not considered good commercial
          nuclear practice. Also, the probability and consequences
          of a common mode failure of the valves due to a loss of
          ventilation system temperature excursion has not been
          evaluated.

      3.  An electrical safety violation incident occurred when an
          electrical mechanic failed to check that the terminals of
          a switch were not energized before lifting leads. The
          worker was not injured, but the RTF Ventilation system
          was shutdown. This is the third electrical safety
          violation at the Savannah River Site in the last 4
          months.

3. Background:  The RTF has been involved in a startup test program
   since the Secretary of Energy approved the introduction of a
   small amount of tritium to begin low concentration leak testing
   of the process piping and components in June 1993. Following the
   completion of facility modifications and open items, including
   completion of the Seismic Tritium Confinement System (to limit
   the accidental releases of material from the facility), and the
   development of seven Technical Safety Requirements to limit the
   tritium inventory in the facility, the DOE approved an increase
   in the tritium inventory on October 8, 1993. 

4. Discussion: 

   a. Startup Test Program - On October 10, 1993, RTF began leak
      testing of piping and components using approximately a 50%
      concentration of tritium gas. All startup tests required for
      reservoir loading on one loading line have been completed.
      There are 24 of approximately 450 total startup and
      integrated system operations tests remaining, including four
      tests on the Thermal Cycling Absorption Process (TCAP) and
      the In-Bed Accountability (IBA) Process. The completion of
      these system tests is expected in March 1994. These tests
      are being performed in parallel with the program to certify
      the loading and unloading of reservoirs for war reserve
      production operations. If the TCAP system cannot separate
      deuterium and tritium to the required purity levels, the
      cryogenic separation process in the existing tritium
      facility can be used to provide the tritium and deuterium
      necessary for RTF to process war reserve production
      reservoirs. 

   b. Preparation for Design Agency Reviews - To date, twelve
      reservoirs of one type have been test loaded in preparation
      for review and acceptance of the process by the design
      agency, the Sandia National Laboratory. Weld integrity and
      fill gas composition of ten reservoirs have been evaluated
      at SRS, and found to satisfy the design agency standards.
      The two other reservoirs will be shipped to Mound for
      independent evaluation. 

      Formal design reviews of the production loading process for
      the first reservoir type will be conducted at RTF on January
      5-7, 1994. RTF plans to certify four reservoir types, which
      will allow eight reservoir models to be processed.  The last
      design agency review is scheduled for March 15, 1994.    

   c. Fire Protection - RTF has two seismically-qualified fire
      water tanks. Although filled with water, the tanks are not
      yet connected to piping leading to the building. However,
      the connecting piping is not seismically qualified. WSRC
      intends to connect the piping prior to war reserve
      production, which is currently scheduled for March 1994. 
      However, RTF has not conducted fire drills to demonstrate
      the ability to fight fires using the water in these tanks in
      the event of piping unavailability. Good commercial practice
      in such a situation would include the planning and conduct
      of fire drills.
          
   d. Environmental Qualification of Nuclear Safety (NS)
      Components -  During its review of the latest revision of
      the environmental qualification report for the Seismic
      Tritium Confinement System (STCS) components, the DNFSB
      staff observed that instead of qualifying components to
      anticipated abnormal conditions, RTF has used administrative
      controls to prevent operation of the STCS under conditions
      that could cause temperatures to exceed the design ratings
      of some components (e.g., the solenoid valves). 

      The ASCO pilot solenoid valves are important for maintaining
      operability of the STCS. Initially, the valves were to be
      replaced every 5-1/2 years based on equipment qualification
      concerns of temperature aging. The latest revision of the
      equipment qualification report states that administrative
      controls will be used to enforce the temperature limit.  The
      report now states that the qualified life of the solenoid
      valves is indeterminate; therefore, the valves will not be
      replaced until after they fail. Although the use of such
      administrative controls is an acceptable approach, it is not
      the preferred approach, and sole reliance on administrative
      controls is not considered good commercial nuclear practice.

      As part of the Component Operability Readiness Evaluation
      (CORE) Program, actuation of the solenoid valves will be
      tested monthly. This should be adequate in the short term,
      but the Staff believes that the solenoid valve environment
      bears close monitoring to ensure that temperatures are
      effectively controlled over the long term. Also, the
      probability and consequences of a common mode failure of the
      valves due to a temperature excursion caused by a loss of
      the glovebox stripper systems has not been evaluated. The
      DNFSB staff intends to review the changes to the STCS
      equipment qualification program in detail, including WSRC's
      expected actions if the temperature limit is exceeded.

   e. Electrical Safety - Occurrence Reports written during the
      last 2 months were discussed. An issues management group has
      been formed to trend equipment problems and personnel
      errors. The DNFSB Staff was also briefed on an electrical
      safety incident which occurred during their visit on
      December 8, 1993. An electrical maintenance mechanic removed
      power to test a barometric pressure switch, but did not
      verify the absence of voltage before lifting leads. The
      switch had an alternate power source, which was not
      identified on either the work package or the available
      drawings. Loosening of the first lead blew a 2 amp fuse in
      the alternate power feed, which resulted in the closure of
      tornado dampers and shutdown of the RTF HVAC system. The
      mechanic was not injured, but violated safe electrical
      working practice procedures. A review of the incident was
      held, and the mechanic was disciplined by time off without
      pay. A similar event happened at F-Canyon the previous week,
      and in the 700 Area several months ago. RTF management is
      proposing to add a caution statement to every electrical
      procedure to check voltages before performing work. The
      DNFSB Staff was given an electrical safety videotape, which
      has been shown to all electrical workers.    

   f. Status of Other Activities and Concerns - Information on the
      status of other programs and activities at RTF, and
      additional concerns identified by the DNFSB staff, are
      provided in the Attachment.

5. Future Staff Actions:  The DNFSB Staff intends to conduct
   followup reviews of the technical concerns identified in this
   memo. WSRC progress in addressing these concerns will be
   discussed during the next DNFSB Staff review trip to the RTF,
   currently scheduled for February 1994. The DNFSB Staff will also
   continue to follow scheduled RTF activities.  

                           Attachment

    Status of Other RTF Activities and Additional DNFSB Staff
Concerns

This Attachment presents information on the status of other
programs and activities at RTF, and additional concerns identified
by the DNFSB staff during the December 8-10, 1993 site visit.

1. Status of Other Activities: 

   a. Technical Safety Requirements - Procedures to implement
      Technical Safety Requirements (TSR's) 3.7.1 through 3.7.7
      regarding the tritium inventory limits were reviewed. A
      procedure which cross-references TSR requirements with the
      applicable surveillance procedures was also reviewed. The
      documents reviewed appeared to adequately address the
      multiple TSR tritium inventory limits.  Work is also in
      progress to revise TSR's to make them more user friendly and
      clarify their implementation. 
   
   b. Component Operability Readiness Evaluation (CORE) Program -
      The CORE Program is defining in-service inspection
      requirements for nuclear safety (NS) and Critical Protection
      (CP) components. Data sheets for the inspection of all NS
      components have been completed. However, the development of
      requirements for CP components is behind schedule. A total
      of about 1,900 CP components in about 500 groups exists.
      WSRC plans to prioritize the development of inspection
      requirements for these items based on their relative safety
      significance. 

   c. Mix Tank Leak Identification - Review of a leak in the Tank
      106F mix tank in the existing tritium facility illustrated
      that tritium monitoring is more effective than ultrasonic
      testing (UT) for detection of leaks. Hence, the staff does
      not object to WSRC taking credit for tritium monitors within
      the gloveboxes for the detection of leaks from RTF
      components.  

   d. Operational Readiness Review (ORR) Observation Closures -
      The status of closeout actions from WSRC Operational
      Readiness Review (ORR) Observations for War Reserve
      Production was reviewed. To date, 127 of 259 observations
      have been closed.
   
   e. Cable Marker Fire Test Report - A WSRC-prepared test report
      presenting the results of flammability testing of electrical
      cable with cable markers utilized in the STCS relay cabinets
      was reviewed and found acceptable by the DNFSB Staff.

   f. Low Level Waste - On October 10, 1993, RTF elected to cease
      all Low Level Waste (LLW) shipments to the Solid Waste
      Disposal Facility until full WSRC Waste Certification and
      Minimization (WCAM). The WCAM plan was expected to be
      approved by December 8, 1993. However, DOE has requested an
      independent assessment of the plan, which will certify only
      RTF, not LLW generated by the existing tritium facility. The
      independent assessment is expected to be completed by
      January 21, 1994.  
   
   g. Safety Analysis Report (SAR) Update - WSRC expects to have
      a copy of the first annual SAR update to DOE in August 1994.
      Current plans are to incorporate Volumes 17-20 (questions
      and responses) into the applicable sections; incorporate all
      SAR change requests through February 1994; and provide
      updates on conduct of operations, radiation protection, and
      other program changes.  

2. Additional DNFSB Staff Concerns:
             
   a. Lightning Protection - WSRC is depending on the use of
      building steel structural components (e.g., rebars, columns,
      etc.) to dissipate the energy from any lightning strikes. 
      The DNFSB staff does not concur with this approach. WSRC has
      not adequately demonstrated RTF's capability to withstand
      lightning strikes, especially the diesel generator building,
      electrical sub-station, stack, ventilation system equipment
      on the roof, and distributed control system (DCS)
      components.

   b. Ventilation in the battery room to prevent hydrogen buildup
      - WSRC has not yet demonstrated conformance with applicable
      codes and standards related to battery area ventilation to
      prevent hydrogen buildup. The DNFSB Staff referred WSRC to
      the following applicable standards:  ANSI C2-1993, Article
      142, "Ventilation"; NFPA 70, Article 48, "Storage
      Batteries"; and IEEE - 450, "Recommended Practice for
      Maintenance, Testing, and Replacement of Lead Storage
      Batteries". Also, the potential for an explosion in the
      battery room if the ventilation system becomes inoperable
      has not been evaluated.

   c. Electrical Calculations and Isolation Devices - WSRC has not
      yet completed calculations for voltage profile and
      grounding, and a design modification is being prepared by
      WSRC for the application/deletion of isolation devices.
      Voltage profile calculations are required by DOE Order
      6430.1A, General Design Criteria.

   d. Emergency Lighting - While reviewing the completed procedure
      for loss of power, the Staff noted that there is no
      discussion of the interim action requiring the use of
      flashlights for emergency lighting. WSRC agreed to have
      flashlights available in the facility until the emergency
      lighting supports have been seismically qualified. WSRC will
      revise the procedure to include the use of flashlights.

      The DNFSB staff clarified to WSRC that the concern about
      seismically qualified lighting supports is limited to the
      battery-powered emergency lights (battery packs); it does
      not include emergency lights fed from diesel generators.