UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

REGION II 

245 PEACHTREE CENTER AVENUE NE, SUITE 1200 

ATLANTA, GEORGIA 30303-1257

August 12, 2016 

Mr. Bruce Phillips 

Interim Vice President, Columbia Fuel Operations 

Westinghouse Electric Company 

5801 Bluff Road 

Hopkins, SC 29061 

SUBJECT: WESTINGHOUSE ELECTRIC COMPANY – NUCLEAR REGULATORY 

COMMISSION INSPECTION REPORT NO. 70-1151/2016-006 

Dear Mr. Phillips: 

The Nuclear Regulatory Commission (NRC) conducted an announced inspection during the 

week of July 11, 2016, at the Westinghouse Columbia Fuel Fabrication Facility in Hopkins, SC. 

The purpose of the inspection was to perform Temporary Instruction (TI) 2600/16, Inspection of 

Activities Associated with NRC Generic Letter 2015-01, Treatment of Natural Phenomena 

Hazards in Fuel Cycle Facilities. The enclosed report presents the results of the inspection. At 

the conclusion of this inspection, the results were discussed with you and members of your staff 

at an exit meeting on July 14, 2016. 

During the inspection, NRC staff examined activities conducted under your license as they 

related to public health and safety, and to confirm compliance with the Commission’s rules and 

regulations, and with the conditions of your license. Areas examined during the inspection are 

identified in the enclosed report. Within these areas, the inspection consisted of selected 

examination of procedures and representative records, observations of activities, and interviews 

with personnel. 

The inspection allowed the staff to independently verify compliance with regulatory requirements 

and applicable license conditions regarding the treatment of natural phenomena hazards (NPH) 

as described in your Integrated Safety Analysis (ISA). No findings of significance were 

identified. 

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of NRC’s “Rules 

of Practice and Procedure,” a copy of this letter and enclosure will be made available 

electronically for public inspection in the NRC Public Document Room, or from the NRC’s 

Agencywide Documents Access and Management System (ADAMS), which is accessible from 

the NRC Website at http://www.nrc.gov/reading-rm/adams.html. 
B. Phillips 2 

If you have any questions, please call me at (404) 997-4703. 

 Sincerely, 

 /RA/ 

 

 Omar Lopez-Santiago, Chief 

 Safety Branch 

 Division of Fuel Facility Inspection 

Docket No. 70-1151 

License No. SNM-1107 

Enclosure: 

NRC Inspection Report 70-1151/2016-006 

 w/Supplemental Information 

cc: (See page 3) 

 
B. Phillips 3 

cc: 

John Howell 

Manager 

Environment, Health and Safety 

Electronic Mail Distribution 

Nancy Parr 

Manager 

Licensing 

Electronic Mail Distribution 

Christine Kneece 

Manager 

Industrial Safety 

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 

 
B. Phillips 2 

If you have any questions, please call me at (404) 997-4703. 

 Sincerely, 

 

 /RA/ 

 Omar R. López-Santiago, Chief 

 Safety Branch 

 Division of Fuel Facility Inspection 

Docket No. 70-1151 

License No. SNM-1107 

Enclosure: 

NRC Inspection Report 70-1151/2016-006 

 w/Supplemental Information 

cc: (See page 3) 

DISTRIBUTION: 

E. Michel, RII 

T. Vukovinsky, RII 

P. Glenn, RII 

R. Johnson, NMSS 

C. Ryder, NMSS 

M. Baker, NMSS 

PUBLIC 

 PUBLICLY AVAILABLE NON-PUBLICLY AVAILABLE SENSITIVE NON-SENSITIVE 

ADAMS: Yes ACCESSION NUMBER: ML16225A386 SUNSI REVIEW COMPLETE FORM 665 ATTACHED 

OFFICE RII:DFFI RII:DFFI RII:DFFI RII:DFFI NMSS 

SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ 

NAME BAdkins TVukovinsky DAnderson JMunson JMarcano 

DATE 8/12/2016 8/12/2016 8/12/2016 8/12/2016 8/12/2016 

E-MAIL COPY? YES NO YES NO YES NO YES NO YES NO YES NO YES NO 

OFFICIAL RECORD COPY DOCUMENT NAME: G:\DFFI\REPORTS\DRAFT INSPECTION REPORT 

FOLDER\WESTINGHOUSE\CY 2016\WEST 2016-006 NPH.DOCX 

 
U. S. NUCLEAR REGULATORY COMMISSION 

REGION II 

Docket No.: 70-1151 

License No.: SNM-1107 

Report No.: 70-1151/2016-006 

Licensee: Westinghouse Electric Company 

Facility: Columbia Fuel Fabrication Facility 

Location: Hopkins, SC 29061 

Dates: July 11 through July 14, 2016 

Inspectors: B. Adkins, Senior Fuel Facility Inspector (Sections A.3, A.5, A.6, and B.1) 

 T. Vukovinsky, Senior Fuel Facility Inspector (Section A.1) 

 J. Munson, Fuel Facility Inspector (Sections A.4 and B.2) 

 D. Anderson, Fuel Facility Inspector (Sections A.2, A.3, A.5, and A.6) 

 J. Marcano, Structural Engineer (Sections A.1 and A.4) 

Approved by: O. López-Santiago, Chief 

Safety Branch 

Division of Fuel Facility Inspection 

Enclosure 
EXECUTIVE SUMMARY 

Westinghouse Electric Company 

Columbia Fuel Fabrication Facility 

NRC Inspection Report 70-1151/2016-006 

July 11 through July 14, 2016 

The inspection implemented Temporary Instruction (TI) 2600/16, Inspection of Activities 

Associated with Nuclear Regulatory Commission (NRC) Generic Letter 2015-01, Treatment of 

Natural Phenomena Hazards in Fuel Cycle Facilities. The purpose of the inspection was to 

independently verify that licensees are in compliance with regulatory requirements and 

applicable license conditions regarding the treatment of natural phenomena hazards (NPH) 

events as described in the Integrated Safety Analysis (ISA). The inspection was conducted by 

NRC regional inspectors and headquarters (HQ) technical staff during normal shifts in areas of 

permanent plant modifications, chemical safety, nuclear criticality safety, fire protection, and 

emergency preparedness. The inspectors performed a selective examination of license 

activities that were accomplished by direct observation of safety-significant activities and 

equipment, tours of the facility, interviews and discussions with licensee personnel, and a review 

of facility records. No findings of significance were identified. 

Assessment of the Potential Accident Sequences, Consequences, and Prevention and/or 

Mitigation Strategies as a Result of Impacts to Facility Structures and Internal 

Components from NPH 

The licensee’s ISA adequately considered credible: 

• NPH events with the potential for a release of uranium hexafluoride (UF6) to the worker 

and/or public (Paragraph A.1); 

• Seismic-induced fire/explosion resulting in a release of UF6 to the worker and/or public 

(Paragraph A.2); 

• Seismic-induced releases of hazardous chemicals to the worker and/or public 

(Paragraph A.3); 

• NPH events that could result in a potential criticality and high consequence dose to the 

worker (Paragraph A.4); 

• Flooding events (Paragraph A.5); and 

• Events including the potential for high winds, tornadoes, or hurricanes. (Paragraph A.6.) 

Special Topics 

• Closure of Unresolved Item (URI) 2011-07-01, “Review Westinghouse’s response to the 

failure that the risk of an earthquake was limited by applying sufficient engineering controls, 

administrative controls, or both, to the extent needed to so that, upon implementation of 

such controls, the event was highly unlikely.” (Paragraph B.1) 
2 

• Closure of Unresolved Item URI 2011-07-02, “Review Westinghouse’s evaluation regarding 

whether all nuclear processes under an earthquake were subcritical.” (Paragraph B.2) 

Attachment: 

Key Points of Contact 

List of Items Opened, Closed, and Discussed 

Inspection Procedures Used 

Documents Reviewed 

 
REPORT DETAILS 

Summary of Plant Status 

The Westinghouse Facility converts uranium hexafluoride (UF6) into uranium dioxide using a 

wet conversion process and fabricates fuel assemblies for use in commercial nuclear power 

reactors. During the inspection period, normal production activities were ongoing. 

The inspection implemented Temporary Instruction (TI) 2600/16, Inspection of Activities 

Associated with Nuclear Regulatory Commission (NRC) Generic Letter 2015-01, Treatment of 

Natural Phenomena Hazards in Fuel Cycle Facilities. The purpose of the inspection was to 

independently verify that licensees are in compliance with regulatory requirements and 

applicable license conditions regarding the treatment of natural phenomena hazards (NPH) 

events as described in the Integrated Safety Analysis (ISA). The inspection was conducted by 

NRC regional inspectors and headquarters (HQ) technical staff during normal shifts in areas of 

permanent plant modifications, chemical safety, nuclear criticality safety, fire protection, and 

emergency preparedness. The inspectors performed a selective examination of license 

activities that were accomplished by direct observation of safety-significant activities and 

equipment, tours of the facility, interviews and discussions with licensee personnel, and a review 

of facility records. No findings of significance were identified. 

A. Assessment of NPH Accident Sequences, Consequences, and Mitigation/Prevention 

Strategies 

1. Seismic-Induced UF6 Release

a. Inspection Scope and Observations 

The ammonium diuranate (ADU) Conversion area includes both steam chest vaporizers 

and autoclaves. The steam chest vaporizers and autoclaves are used to heat a UF6

cylinder and convert the UF6 to the gas phase. The licensee determined that a seismic 

event could damage the vaporizers or attached piping and result in a UF6 gas release. A 

leak of UF6 out of a cylinder could result in UF6 being released into the atmosphere or 

UF6 bay trench. Modifications were made to the steam and UF6 vapor piston actuated 

valves and their control solenoids, the emergency stop (E-STOP) pushbuttons, and the 

relays that trip direct current (DC) power to the valve solenoids. The modifications made 

included both passive and active engineering controls. Specifically, the inspectors 

reviewed items relied on for safety (IROFS) ADUVAP-945, -946, -947, -948, -949, and -

950 and their corresponding accident sequences. 

The inspectors conducted walk downs of the modifications, reviewed installation and 

procurement records, and post installation testing of the equipment. The UF6 shutoff 

valves were installed on the outlet of each vaporizer. These shutoff valves (-10 valves) 

are designed to automatically fail closed upon loss of plant air and/or loss of power. 

Additionally, new steam shutoff valves were installed for each vaporizer to also shutoff 

the steam supply in the event of loss of air and/or power. The new UF6 shutoff valve and 

steam supply valves were tied to the Line E-Stop and All Line E-Stop pushbuttons to 

stop UF6 flow and remove the heating source to the vaporizers. The UF6 shutoff valves 

were located on the side of the vaporizer such that there is no exposed UF6 piping 

between the vaporizer and the associated UF6 valves. The UF6 shutoff valves also had 
2 

a steel enclosure installed around them to shield them from falling debris. New 

vaporizers lid assemblies were installed to preclude damage to the UF6 cylinder valve 

operator and pigtail from falling debris. 

Additionally, during some vaporization campaigns, it is necessary to remove a UF6

cylinder from a steam chest before it is emptied to the point of becoming a heeled 

cylinder. During the time period that a cylinder is being disconnected, the cylinder valve 

could be impacted by falling debris during a seismic event. Controls credited to prevent 

this event include ADUVAP-951 and -952. These controls minimize the time that the 

steam chest lid is open, thus minimizing the exposure to any seismic induced debris. 

The inspectors reviewed these controls and verified that operators were using these 

controls as stated in their operating procedures and in the ISA. 

The inspectors reviewed the above referenced controls and their associated accident 

sequences. The inspectors reviewed the configuration change packages, purchase and 

installation documents, and post installation testing for each of the above controls. Walk 

downs of the physical changes were conducted and the inspectors interviewed plant 

operators on the operation of the safety equipment and the use of the E-Stop 

pushbuttons. The inspectors verified that the All Line E-Stop pushbuttons were labeled 

in the control room, and that the licensee conducted training for all operators in the form 

of a Training Bulletin for Seismic Criticality Safety Evaluation (CSE). 

The inspectors reviewed the technical documentation for the seismic qualification of 

equipment in the vaporization area. The internal components that were evaluated in the 

seismic qualification include the steam and UF6 vapor piston actuated valves and their 

control solenoids, the E-STOP pushbuttons, and the relays that trip DC power to the 

valve solenoids. The valves used for the vaporization are pneumatic operated and will 

fail safe on a loss of power or air. The procedure for seismic qualification of these 

components was based on the Institute of Electrical and Electronics Engineers (IEEE)-

344 (2004), IEEE Recommended Practice for Seismic Qualification of Class 1E 

Equipment for Nuclear Power Generating Stations. The components were qualified 

based on seismic experience (Chapter 10 of IEE-344). The inspectors walked down a 

sample of the components that were seismically qualified to verify that the analysis 

adequately characterized the as-built conditions at the site. The inspectors also verified 

that sample components were adequately attached to the structure, when necessary, 

and that no signs of degradation existed that would hinder their performance under 

seismic loads. 

While performing walk-downs of the internal components that were evaluated in the 

seismic qualification the inspectors noted that some of the relays were moved from the 

vaporization area due to a new project to relocate all safety components. The relays 

were moved to cabinets that were also analyzed in the seismic qualification or to sheet 

metal enclosures bolted to structural post which were connected to the floor and meet 

the inclusion criteria in the seismic qualification. The licensee demonstrated that with 

these controls in place, the performance requirements of 10 CFR 70.61 for high 

consequences events were satisfied. 

b. Conclusion 

No violations of NRC requirements were identified. 
3 

2. Seismic-Induced Fire/Explosion 

a. Inspection Scope and Observations 

The licensee evaluated the consequences from seismically induced fires and explosions 

and concluded that any potential failures of process equipment containing flammable 

gases or liquids such as hydrogen, natural gas, and hot oil were bounded by existing 

accident sequences analyzed in the ISA. The inspectors reviewed existing ISA accident 

sequences to determine if the sequences remained valid during a credible NPH event. 

The inspectors reviewed in association with the Hot Oil Room, the accident sequences 

and associated IROFS ADUFIRE-901, ADUFIRE-902, which are administrative controls 

related to the fire protection program, and ADUHOS-907, which refers to the structural 

integrity of hot oil system components. The inspectors conducted walk downs of the Hot 

Oil Room and inspected hot oil safety shutoff valves between hot oil room and ADU 

dryers, which fail closed upon loss of power and require manual reset. The inspectors 

reviewed the Fire Barrier and Map line Rotation for the Hot Oil Room and Incinerator 

Room. The inspectors discussed fire mitigating practices with fire brigade personnel and 

the emergency director. The inspectors also reviewed the annual preventive 

maintenance procedure and completed work orders for the hot oil systems emergency 

shut down and hot oil isolation valves. 

The inspectors performed walk-downs of the hot oil room. The seismic analysis of the 

facility does not specifically evaluate the performance of the hot oil room, however the 

walls are credited as fire walls with a 2 hour rating. The contractor who performed the 

seismic analysis of the facility provided a qualitative analysis to support the conclusion 

that the walls will not fail due to the configuration of the room. The walls are composed 

of concrete masonry unit (CMU) walls, with a roof attached to the top and thus providing 

an anchoring point for the CMU walls. Given that the room acts like a box with a lid the 

contractor qualitatively concluded the hot oil room will survive the evaluation basis 

earthquake. 

The inspectors also conducted walk downs to verify the installation of manual isolation 

valves in the hydrogen and natural gas supply piping. The inspectors conducted 

interviews with operators regarding the hydrogen supply tank high level alarms and 

associated limits. The inspectors noted that operators were able to physically identify 

the location of the shut off valves in the case of an event. 

The inspectors observed quarterly fire brigade training. This quarter one of the focus 

areas was the Site Emergency Procedure Sketch (SEPS)-009-14, Manual Valves to 

Isolate Seismic Induced Chemical Hazards, Revision 1. During this training the fire 

brigade toured the facility and physically identified each valve in the procedure and its 

purpose. 

b. Conclusion 

No violations of NRC requirements were identified. 
4 

3. Seismic-Induced Chemical Release (non-UF6) 

a. Inspection Scope and Observations 

The inspectors evaluated credible NPH accident sequences involving the release of 

NRC-regulated bulk chemicals to determine if the sequences were properly indexed in 

accordance with the licensee’s approved ISA methodology. The accident sequences of 

concern were determined to be a seismic event followed by structural failure of process 

equipment/tanks and a subsequent release of (1) dilute ammonia from the Q-tanks, (2) 

perchloroethylene from the solvent extraction system, and/or (3) hydrogen fluoride (HF) 

from the HF tank. These sequences had the potential to result in either high or 

intermediate consequences to the worker depending upon the chemical of concern; 

however, there were no sequences that resulted in either high or intermediate 

consequences to the public. The inspectors reviewed the basis for the initiating event 

frequency (IEF) to verify it was consistent with the evaluation basis earthquake (2% 

exceedance in 50 years) as described in the ISA. The inspectors noted that the IEF was 

conservatively reduced from -4 to -3 since equipment/piping that were determined to fail 

during the evaluation basis earthquake could also fail during a lower magnitude 

earthquake. The inspectors reviewed the licensee’s chemical consequence analysis to 

determine if the modeling assumptions were conservative and the results were 

consistent with the information submitted in the ISA Summary. 

The inspectors reviewed the IROFS selected for the seismic-induced chemical spill 

sequences which included PLANT-SEP-901 and 902. These controls include training 

and execution of the Site Emergency Plan to mitigate exposure to facility workers in the 

event of a seismic-induced chemical spill. Based on the NRC’s review of the licensee’s 

generic letter (GL) submittal, the NRC concluded that the licensee could not credit 

PLANT-SEP-902, training on the Site Emergency Plan, because it was considered to be 

a management measure for IROFS PLANT-SEP-901, execution of the Site Emergency 

Plan. This issue was documented in the staff’s evaluation of the GL dated July 7, 2016. 

In a letter dated July 6, 2016, Westinghouse agreed to submit an updated ISA Summary 

by January 31, 2017, which will replace PLANT-SEP-902 with a new IROFS PLANTSEP-903, See and Flee. At the time of the inspection, the licensee had not yet 

implemented PLANT-SEP-903; therefore, implementation of this IROFS will be verified 

during a future permanent plant modification inspection in calendar year 2017 following 

submittal of the revised ISA Summary in January 2017. 

With respect to the implementation of PLANT-SEP-902, the inspectors conducted 

interviews with the emergency director, incident commanders, and emergency response 

personnel to assess their ability to invoke the Site Emergency Plan including a site 

evacuation following an NPH event. The inspector reviewed the corresponding 

emergency response procedure to determine if adequate procedural guidance was inplace to execute a site evacuation. Specifically SEP-005, Evacuation, Accountability 

and General Response, Rev. 6. In addition, the inspectors reviewed annual refresher 

training for the Site Emergency Plan and observed training of the fire brigade per SEPS009-14, Manual Valves to Isolate Seismic Induced Chemical Hazards, Rev. 1 to ensure 

cognizant personnel were able to mitigate a chemical release resulting from a NPH 

event. 
5 

The inspectors also verified the completion of HAZCOM training for employees and 

inspected the designated HAZMAT vehicle. In addition inspectors confirmed that all 

active Hazmat team members were up to date with required training. The inspectors 

toured the on-site medical clinic and interviewed the attending nurse regarding protocol 

to handle HF exposures to ensure the on-site medical clinic was prepared to handle HF 

exposures. 

The inspectors also reviewed controls credited as defense-in-depth in the licensee’s ISA 

with respect to a seismic-induced chemical release. The inspectors conducted walk 

downs to verify the licensee’s ability to isolate chemical supply sources (e.g., manual 

valves or excess flow valves) including argon, nitric acid, aqueous ammonia, uranyl 

nitrate (UN), and HF following a seismic event. The inspectors reviewed mechanical 

integrity (MI) reports including ultrasonic thickness measurements for the HF and 

aqueous ammonia storage tanks. The inspectors conducted interviews and reviewed 

procedures to confirm that perchloroethylene is a batch operation. The inspectors 

conducted walk downs in the solvent extraction area to confirm the presence of flange 

guards to control/limit leakage in the event of a pipe leak. The inspectors observed the 

presence of a berm around the Q-tanks and conducted operator interviews to verify that 

only one bank of Q-tanks is in-service at any one time. The inspectors reviewed 

electrical schematics to determine if the building ventilation shuts down on loss of offsite 

power and will not restart on backup power. The inspectors reviewed design drawings 

and performed walk downs to determine if the tanks were constructed of corrosion 

resistant materials such as polyethylene and stainless steel. The inspectors reviewed 

operating procedures and drawings, and conducted a walk down of the UN tanks to 

confirm the presence of a tank outlet isolation valve, computer assist interlock on tank 

high level, instrumentation to limit uranium concentration, and that the dike around the 

UN tank is constructed of a concrete pad to limit corrosion. 

b. Conclusion 

No violations of NRC requirements were identified. 

4. Seismic Induced Criticality 

a. Inspection Scope and Observations 

The inspectors evaluated the adequacy of the licensee’s nuclear criticality safety (NCS) 

program and analyses to assure the safety of fissile material operations and compliance 

with respect to NPH events. The inspectors reviewed select NCS documents (listed in 

Section 4.0 of the Attachment), including the newly developed NCS evaluation 

concerning NPH events (CSE-99-M). The inspectors verified the technical basis for 

NCS limits and assumptions, evaluated potential NPH-related criticality accident 

sequences, and verified that the licensee performed evaluations to assure sub-criticality 

of processes under all normal and credible abnormal conditions. 

The inspectors reviewed NCS evaluations and analyses to determine whether the 

licensee evaluated normal and credible abnormal conditions for NCS, reviewed the 

associated criticality accident sequences, reviewed the purpose and technical basis for 

any controls implemented to prevent these criticality accident sequences, verified that 

controls identified to prevent these criticality accident sequences would be effective and 
6 

independent, verified that these controls were installed and/or implemented as intended, 

and evaluated whether the likelihood of these accident sequences was limited to 

regulatory limits. 

The inspectors performed walk downs of the assembly wash pit, UF6 area, bulk UN 

storage area, and general conversion areas. The inspectors interviewed Operations’ 

staff and NCS engineers before and during walk downs. The inspectors visually verified 

that controls identified in the applicable NCS evaluations were installed and/or 

implemented as designed. The inspectors verified that certain management measures 

designed to maintain IROFS were being performed within their assigned frequency and 

in accordance with procedures. Specifically, the inspectors observed Operations’ staff 

perform a surveillance to verify conversion area floor flatness. 

The inspectors noted that for several accident sequences the licensee relied on the 

flatness of the floor to disperse any material that may be spilled from the process 

equipment following a seismic event. As such, the floor flatness is credited as an IROFS 

in certain areas of the facility, including the conversion area. The inspectors observed 

that the surveillance is mostly focused on identifying any holes or pits in the floor, but 

does not place emphasis on the wall-to-wall lateral floor flatness. The inspectors 

determined that, based on the large surface area of the conversion area floor and the 

associated predetermined safe slab height documented in the applicable NCSE, that a 

visual inspection would not be effective in identifying a slight slope in the floor capable of 

exceeding a safe slab height if large volumes of uranium-bearing solution were to be 

spilled such as in an NPH event. Based on this observation, the inspectors determined 

that this issue was a minor violation of 10 CFR 70.62(d) which states, in part, [e]ach 

applicant or licensee shall establish management measures to ensure compliance with 

the performance requirements of § 70.61...[t]he management measures shall ensure 

that engineered and administrative controls and control systems that are identified as 

[IROFS] pursuant to § 70.61(e) of this subpart are designed, implemented, and 

maintained, as necessary, to ensure they are available and reliable to perform their 

function when needed....” Specifically, the licensee failed to establish adequate 

management measures to ensure wall-to-wall lateral floor flatness of the conversion 

area would remain available and reliable during an NPH event. This violation was 

determined to be minor because it did not exceed any general or area specific screening 

criteria in MC 0616 Appendix B. This failure to comply with 10 CFR 70.62(d) constitutes 

a minor violation that is not subject to enforcement action in accordance with Section 

2.3.1 of the NRC Enforcement Policy. This condition was entered into their corrective 

action program as CAPAL 100397271, Review of Chemical Area Spill during an 

Earthquake. 

The inspectors reviewed a modification (PSEDoc-0001705) that the licensee completed 

in the wash pit area to provide an enclosure (fuel bundle enclosure) around the bottom 

of the fuel assembly to prevent it from sliding off the inspection stand during an 

earthquake, potentially violating NCS spacing requirements. The inspectors noted that 

the wash pit was not analyzed in the seismic analysis of the facility due to the 

deteriorated and corroded condition of the tanks, supports, and concrete pit and thus 

had a lack of defendable material properties to use in a seismic evaluation. The 

inspectors noted that visual inspections completed by Westinghouse Electric 

Corporation (WEC) personnel of the wash pit area in 2013 identified the deterioration of 

the structural elements supporting the inspection stands and wash tanks. The 

documentation of inspection surveillances indicated that the stainless steel tanks are 
7 

supported by carbon steel I beams that show signs of moderate to heavy surface 

corrosion. The 2013 inspection also indicated that the legs supporting the inspection 

stands did not appear to be secured or anchored to the floor of the pit. 

The inspectors interviewed WEC personnel in charge of the design of the wash pit. 

WEC personnel clarified that the structural support system for the two tanks for final 

inspection of the assemblies are connected to each other by structural angles. WEC 

personnel pointed out that the top grating on the wash pit serves as a limiting factor for 

horizontal movement of the assemblies in the case of earthquake induced vibration. 

The lack of a seismic analysis of the structural elements supporting the inspection 

stands and the reported potential degradation of the materials in the wash pit raised 

questions on the reliability of the fuel bundle enclose under seismic loads. The expected 

safety function of the fuel bundle enclosure is to maintain the fuel assemblies in place 

and prevent sliding under earthquake vibrations. The inspectors were not able to 

confirm that the enclosure will perform its intended safety function because (1) it is 

attached to a structural support systems that is not seismically qualified and (2) the 

structural support system shows signs of degradation. As such, the inspectors 

determined that the engineered spacing controls could not be assured to remain 

available and reliable during an NPH event. 

Based on the observation noted above, the inspectors identified a second example of a 

minor violation of 10 CFR 70.62(d), which states, in part, [e]ach applicant or licensee 

shall establish management measures to ensure compliance with the performance 

requirements of 10 CFR 70.61...[t]he management measures shall ensure that 

engineered and administrative controls and control systems that are identified as 

[IROFS] pursuant to § 70.61(e) of this subpart are designed, implemented, and 

maintained, as necessary, to ensure they are available and reliable to perform their 

function when needed....” Specifically, the licensee failed to establish adequate 

management measures to ensure that engineered spacing controls in the wash pit would 

remain available and reliable during an NPH event. This violation was determined to be 

minor because the amount of time when this condition exists (only disconnected from 

seismically qualified crane 20 min per shift for 2 shifts per day) does not appreciably 

impact the overall risk of the accident sequence and did not exceed any general or area 

specific screening criteria in MC 0616 Appendix B. This failure to comply with 10 CFR 

70.62(d) constitutes a minor violation that is not subject to enforcement action in 

accordance with Section 2.3.1 of the NRC Enforcement Policy. This condition was 

entered into their corrective action program as CAPAL 100397272, Review of Final 

Assembly Wash Pit during an Earthquake. 

The inspectors also performed walk downs of the wash pit area to verify other conditions 

that may lead to accident sequences in the wash pit area. The inspectors walked-down 

the structural support system for the trolley that moves the assemblies into the wash pit. 

The inspectors verified that structure was adequately supported and connected to the 

structure. In addition the inspectors looked at the wash pit cleaning process, it was 

noted that the assemblies once they are removed from the trolley they are attached to 

an arm mechanism that hold the fuel bundles at the top. The mechanisms connect to 

the top of the assembly using a pin connection. The mechanism has a horizontal arm 

that is connected to a vertical post welded to the floor. This mechanism provides a layer 

of protection to support the assemblies and maintain spacing in the case of seismic 

induced failure of the legs. 
8 

The inspectors verified that the licensee evaluated the ability of the criticality accident 

alarm system (CAAS) to remain operational following a seismic event. 

The inspectors reviewed the Emergency Plan to ensure that mitigative actions with 

regard to an inadvertent criticality due to flooding and other natural phenomena were 

evaluated. 

b. Conclusion 

No violations of significance were identified. One minor violation of 10 CFR 70.62(d) 

with two examples was identified. 

5. Flooding 

a. Inspection Scope and Observations 

The ISA Summary states that the facility is situated above the estimated 100 year and 

500 year flood elevations. The licensee’s analysis concluded that a large flood could 

impact the low-lying, undeveloped areas of the site, but concluded that is highly unlikely 

that a large flood would result in uranium releases or a nuclear criticality accident. 

Should a large rainfall event occur, sufficient time would be available to take appropriate 

preventive and emergency management measures, including evacuating employees and 

shutting down manufacturing operations. 

The inspectors reviewed Site Emergency Procedure (SEP)-014, Response to Extreme 

Environmental Conditions, Rev. 3; SEP-005, Evacuation, Accountability, and General 

Response, Rev. 6; and the suite of area checklists related to severe weather preparation 

to ensure proper evacuation and shutdown of manufacturing operations. Inspectors 

conducted interviews with the emergency director and incident commanders regarding 

the aforementioned procedures to assess their ability to take appropriate preventative 

and emergency management measures. 

b. Conclusion 

No violations of NRC requirements were identified. 

6. High Winds, Tornadoes, and Hurricanes 

a. Inspection Scope and Observations 

Based on the licensee’s ISA Summary, the licensee stated that the main manufacturing 

building (and its additions) are designed for wind loading of 20 pounds per square foot, 

equivalent to 90 mph winds. Due to the design of the building, the licensee concluded 

that it is highly unlikely that high winds would result in failures of the building walls or 

other structural items, causing a release of uranium. Also, there were no accident 

scenarios identified resulting from a release of stored hazardous chemical due to high 

winds that would result in an accident involving licensed material with intermediate or 

high consequences as defined in 10 CFR 70.61. 

With respect to tornadoes, the licensee used NUREG/CR-4461 Rev. 2 to obtain an 

estimate of the probability that the building is struck by a tornado as 4 x 10-4 per year to 
9 

an ISA frequency score of -4 which is considered to be highly unlikely. The licensee 

performed a qualitative analysis to compare the wind pressures associated with a 

tornado to the wind pressures used for the design of building structures. An estimate of 

the capacity of the exterior cladding to withstand impacts from defined tornado missiles 

was also performed. 

Even though accident sequences associated with high winds, tornadoes, or hurricanes 

were determined to be highly unlikely, the licensee did state in their response to GL 

2015-01 that appropriate emergency management measures would be activated by 

employees either sheltering in place or evacuating. The inspectors reviewed these 

emergency management measures to verify that procedures were in place to respond to 

potential high wind events outside of the analyzed event in the ISA. 

Specifically, the inspectors reviewed procedure SEP-014, Response to Extreme 

Environmental Conditions, Rev. 3. This procedure is intended to assist the Emergency 

Response Organization (ERO) in preparing for and responding to an environmental or 

weather related threats such as tornados, hurricanes and earthquakes. The inspectors 

conducted interviews with the emergency director and incident commanders regarding 

the implementation of this procedure as well as the use of Site Emergency Procedure 

Form (SEPF)-009-13, Command Check Sheet – Tornado Response, Rev. 5. The 

inspectors also discussed the availability of fire brigade personnel and firefighting 

equipment after a tornado or hurricane event. The inspectors also verified the licensee 

had compensatory measures in case of loss of access to the fire water tanks. The 

emergency director identified the use of a turbo draft as an alternative water supply 

device that could allow them to tap into static sources such as lakes, ponds, and 

streams. The inspectors reviewed the procedure and test results from the most recent 

test of the turbo draft pump. 

b. Conclusion 

No violations of NRC requirements were identified. 

B. Special Topics 

1. Follow-up on Previously Identified Issues 

a. (Closed) Unresolved Item (URI) 2011-07-01, Failure 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 

Following the earthquake at the Fukushima Dai-ichi nuclear power station in March 

2011, the NRC conducted TI 2600/015, Evaluation of Licensee Strategies for the 

Prevention and/or Mitigation of Emergencies at Fuel Facilities, in December 2011 to 

confirm compliance with applicable regulatory requirements and license conditions; and 

to evaluate licensee’s readiness to address NPH events and other licensing bases 

events related to NPH. The NRC was unable to verify that Westinghouse was in 

compliance with their licensing basis and regulatory requirements with respect to NPH. 

Specifically, the inspectors could not confirm that all credible external events (accident 

sequences) involving process deviations or other events internal to the facility (e.g., 

consequential explosions, spills, and fires resulting from NPH event) were properly 

considered in the ISA. The inspectors opened Unresolved Item (URI) 2011-07-01, 
10 

“Failure 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,” to track this potential 

noncompliance. 

Following the completion of TI 2600/015, the NRC concluded that this was a generic 

issue and subsequently issued NRC Generic Letter (GL) 2015-01, “Treatment of Natural 

Phenomena Hazards in Fuel Cycle Facilities,” in June 2015. The GL requested 

licensees to provide additional information to support a determination with regard to 

proper evaluation of NPH impacts at fuel cycle facilities. Westinghouse submitted a 

response to the GL in June 2016 and the response was accepted by the NRC in July 

2016. 

The NRC reviewed this open URI to verify that the licensee had complied with regulatory 

requirements and applicable license conditions regarding the treatment of NPH events in 

the ISA. The results of the inspection are documented in Section A of this inspection 

report. Based on the inspections performed, the NRC has concluded that Westinghouse 

is in compliance with regards to the regulatory requirements specified in 10 CFR Part 

70.61, Subpart H, with respect to the assessment of NPH hazards in the ISA. This URI 

is considered closed. 

b. (Closed) URI 2011-07-02, Review Westinghouse’s evaluation regarding whether all 

nuclear processes under an earthquake were subcritical 

During a post-Fukushima-Dai-ichi NPH inspection in December 2011, the inspectors 

opened URI 2011-07-02 to document that Westinghouse had an incomplete evaluation 

regarding whether all nuclear processes under an earthquake were subcritical. The 

NRC reviewed this open URI to determine if the ISA adequately addresses the potential 

for nuclear criticality following a seismic event. 

The inspectors evaluated the adequacy of the licensee’s NCS program and analyses to 

assure the safety of fissile material operations and compliance with respect to natural 

phenomena events. The inspectors verified the technical basis for NCS limits and 

assumptions, evaluated potential NPH-related criticality accident sequences, and 

verified that the licensee performed evaluations to assure sub-criticality of processes 

under all normal and credible abnormal conditions. The inspectors reviewed NCS 

evaluations and analyses to determine whether the licensee evaluated normal and 

credible abnormal conditions for NCS, reviewed the associated criticality accident 

sequences, reviewed the purpose and technical basis for any controls implemented to 

prevent these criticality accident sequences, verified that controls identified to prevent 

these criticality accident sequences would be effective and independent, verified that 

these controls were installed and/or implemented as intended, and evaluated whether 

the likelihood of these accident sequences met regulatory limits. 

Based on the inspections performed, the inspectors determined that Westinghouse 

adequately evaluated that all nuclear processes under an earthquake were subcritical. 

The NRC identified one minor violation with two examples for failure to meet 10 CFR 

70.62(d). Specifically, the licensee failed to establish adequate management measures 

to ensure the availability and reliability of the IROFS designed to control floor flatness 

and engineered NCS spacing in the assembly wash pit. This violation with two examples 
11 

was determined to be of minor significance and is discussed in detail in Section A.4.a of 

this report. No other violations of significance were identified. This URI is considered 

closed. 

C. Exit Meeting 

The inspection scope and results were summarized on July 14, 2016, to Bruce Phillips 

and staff. The inspectors received no dissenting comments from the licensee. 

Proprietary and security-related information were discussed but not included in the 

report. 
SUPPLEMENTAL INFORMATION 

1. KEY POINTS OF CONTACT 

Name Title 

G. Byrd Licensing Engineer 

S. Carver Emergency Preparedness Manager 

T. Graves Conversion Engineer 

J. Howell Environmental, Health and Safety (EH&S) Manager 

C. Kneece Industrial Health & Safety Manager 

N. Parr Licensing Manager 

B. Phillips Interim Vice President, Columbia Fuel Operations 

D. Wilkerson Team Manager, Conversion 

Other licensee employees contacted included engineers, technicians, production staff, 

and office personnel. 

2. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED 

Closed 

70-1151/2011-07-01 URI Failure 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 

70-1151/2011-07-02 URI Review Westinghouse’s evaluation regarding whether all 

nuclear processes under an earthquake were subcritical 

3. INSPECTION PROCEDURE USED

TI 2600/16, Inspection of Activities Associated with NRC Generic Letter 2015-01 

IP 88015, Nuclear Criticality Safety 

IP 88020, Operational Safety 

IP 88050, Emergency Preparedness 

IP 88055, Fire Protection 

IP 88070, Permanent Plant Modifications 

4. DOCUMENTS REVIEWED

Records: 

CCF 13630, “Seismic Restraining Device Wash Pit Inspection Stands,” Nov 2013 

OM81088 - Hot Oil Isolation Valves – Annual OM 

PM 73061, “SI-Safety, Inspection Stand Seismic Restraint Inspection 3 Year PM” 

PM 81109 – Function Test – All Stop 

PM81016 - SI – Safety – Hot Oil Systems Emergency Shut-down – Annual PM 

WO 673554 

WO 705647 

Attachment 
2 

WO 635032 

WO 693494 

WO 656899 

WO 716732 

Change Control Forms (CCF): 

13475 

13630 

Procedures: 

COP-810099, UF6 Vaporizor, Revision (Rev. 25 

COP-814532, General Safety Requirements – Conversion, Rev. 24 

MOP-730503, Fuel Assembly Vacuuming, Rev. 38 

SEPF-009-01, Command Checksheet – Uranyl Nitrate (UNH) Solution Release 

Westinghouse Nuclear Fuel Columbia, SC, Rev. 1 

SEPF-009-13 Tornado Response, Rev. 5 

SEPS-009-14 Manual Valves to Isolate Seismic Induced Chemical Hazards, Rev. 1 

Condition Reports Review: 

CAPAL 100360284 

Condition Reports Written as a Result of this Inspection: 

CAPAL 100397271, Review of Chemical Area Spill during an Earthquake, dated July 11, 

2016 

CAPAL 100397272, Review of Final Assembly Wash Pit during an Earthquake, dated 

July 11, 1016 

CAPAL 100397295, Seismic Induced Fire for Hot Oil System, dated July 11, 2016 

Other Documents: 

ABCO MTR Package 

CF-83-056, Uranyl Nitrate Daily Operation Sample Log Sheet, Rev. 18 

CN-CRI-06-35, Rev 5, April 2013 

CN-CRI-07-2, Rev 4, April 2013 

CN-CRI-07-2, Rev 2, Sept 2008 

CN-SB-10-07, Rev 0, Sept 2010 

CSE-99-M, Rev 0, Dec 2013, “CSE for the Columbia Fuel Fabrication Facility Design 

Basis Seismic Event” 

CSE-17-B, Rev 4, April 2013, “CSE for Final Assembly Wash Pit” 

Drawing 335F01Pl01 

Drawing 335F11EL01 

Drawing 335F05EL01 

Drawing 335A01LS01 

Drawing 622F01CC01, Uranyl Nitrate/Storage System UN Concrete Assessment & 

Details, Rev. 2 

Drawing 622F01P101, Outdoor Uranyl Nitrate Storage Tanks, Rev. 4 

Drawing 622F01EQ01, Uranyl Nitrate/Storage System 7500 gal Storage Tank (T-1040), 

Rev. 15 

Drawing 448F07EQ03, Wash Pit No. 1 Inspection Stands Seismic Restraining Device, 

Rev. 1 

No. 448F07AR01 Rev 2 “Cleaning Pit Trap Door Arrangement” 
3 

FCSS-018 Seismic Design Specifications, Rev 0 

NSA-TR-COL-13-53, Seismic Evaluation of Equipment and Tanks at the Columbia Fuel 

Fabrication Facility (CFFF), Rev. 0. 

NSA-TR-COL-13-59, UF6 -10 Valve Guard and Steam Chest Lid Evaluation, Rev. 0 

NSA-TR-COL-13-60, Seismic Qualification of Components Required for Isolation of UF6 

Vapor from Evaporators at the CFFF, Rev. 0 

PSEDoc-0001544, Internal Inspection of the FA Washpit #1, Rev. 0, dated October 7, 

2013 

PSEDoc-000175, Inspection stands in final assembly wash pit had restraining devices 

added per CCF 13630, Rev. 0 

SYF-219-6, Inspection of a weld that was made to repair a crack in the wash tank shell, 

dated April 6, 2010 

RA-108-04, General-Entire Chemical Area 

RAF-314-1, Rev 13, Nov 2013 

Roberts Company Document Package - Vaporizer Lids 

Sketch 836038-1, Chemical Operating Procedure Sketch URRS Area, Rev. 96 

SYF-219-6, Visual Inspection of the Wash Tanks and the piping on the lower end of the 

tanks to determine the overall external condition of the system, dated April 30, 2010 

Training Bulletin for Conversions, dated July 13, 2016 

4500615760 Lids PO CN1 The Roberts Co., dated October 1, 2013 

NRC/Westinghouse Generic Letter Communications: 

NRC Generic Letter 2015-01, Treatment of Natural Phenomena Hazards in Fuel Cycle 

Facilities, dated June 22, 2015, ADAMS ML14328A029 

LTR-RAC-15-43, Subject: Westinghouse Response to NRC Generic Letter 2015-01 

Treatment of Natural Phenomena Hazards in Fuel Cycle Facilities (Docket 70-1151), 

dated August 26, 2015, ADAMS ML15238B643 

NRC Request for Supplemental Information, 02/22/16, ADAMS ML16005A112 

LTR-RAC-16-22, Subject: Westinghouse Response to NRC Request for Additional 

Information (Cost Accounting Code Number L33337), dated June 21, 2016, ADAMS 

ML16173A375 

Staff Evaluation of Westinghouse Columbia Fuel Fabrication Facility Response to 

Generic Letter 2015-01, “Treatment of Natural Phenomena Hazards in Fuel Cycle 

Facilities (Cost Accounting Code Number: L33337), dated July 7, 2016, ADAMS 

ML16182A314 & ML16180A423 

LTR-RAC-16-39, Subject: Westinghouse Natural Phenomena Hazard (NPH) Generic 

Letter 2015-01 Follow-up, dated July 6, 2016