ML19208B381
| ML19208B381 | |
| Person / Time | |
|---|---|
| Site: | 07000135 |
| Issue date: | 01/25/1979 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19208B364 | List: |
| References | |
| 70-0135-78-25, 70-135-78-25, NUDOCS 7909200123 | |
| Download: ML19208B381 (13) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-135/78-25 Docket No.70-135 License No.
SNM-145 Priority 1
Category UR Licensee:
Babcock and Wilcox Comoany Nuclear Materials Division P. O. Box 1260 Lynchburg, Viroinia 24505 Facility Name:
_ Apollo Uranium Facility Inspection at:
Apollo, Pennsylvania Inspection conducted: December.5-8, 1978 Inspectors:
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,. ! 7 Ff W.'W. Kinney, P*' ject / nspector date' signed I
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Approved by:"H. W. 'frocker, Cief, /uel Facility
' / da% sigsfed Projects Section, FF&MS Branch Inspection Summary:
Inspection on December 5-8, 1978 (Report No. 70-135/78-25)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of licensee action on previous inspection fi.1 dings; organization; operations; nuclear safety; Safety Advisory Board activities; and nonroutine events.
The inspection involved 30 inspector-hours onsite by one NRC inspector.
Results: Of the six areas inspected, no items of noncompliance or deviations were identified in two areas. One apparent item of noncompliance was identified in the organization (infraction - the licensee failed to perform all the evalua-tions and approvals required by section 4.6.1 of the specification, when a new Manager of Technical Control was appointed on October 15, 1978; and the licensee failed to perform any of the evaluations and approvals required by section 4.6.1 of the specification, when a new Acting Manager of Comp)liance was appointed for an indefinite period on October 17, 1978 - Paragraph 3. Three apparent items ofnoncompliancewereidentifiedintheoperationsreview(infraction,,phe
}Jg Region I Form 12 gg (Rev. April 77)
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Inspection Summary licensee failed to have cardboard containers of out-of-confinement, contaminated, combustible waste stored in covered metal containers - Paragraph 4.a; infraction -
the licensee failed to measure glovebox static pressure to assure that the glovebox static pressure is maintained at a minimum of 0.25 inch of water (negative) - Paragraph 4.b; deficiency - the licensee failed to review the Manufacturing Instructions for the HEU wet scrap recovery processes at least annually - Paragraph 4.c). One apparent item was identified in nuclear safety (deficiency - the licensee failed to require operating technicians to follow a posted nuclear satety specification - Paragraph 5.a). One apparent item was identified in the Safety Advisory Board activities (deficiency - the Manager of Compliance failed to serve as the Secretary to the Advisory Board - Paragraph 6).
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DETAILS 1.
Persons Contacted
- W. F. Heer, Manager, Pennsylvania Operations W. F. Wieland, Manager, Employee Relations
- M. A. Austin, Manager, Technical Control
- R. D. Corridoni, Manager, Health and Safety
- T. A. Bauman, Supervisor, Health and Safety
- D. K. Sgarlata, Nuclear Safety Officer
- C. R. Wilson, Compliance Auditor The inspector also interviewed a process engineer, two manufacturing foremen, the industrial safety officer, and an operating technician during the course of the inspection.
denotes those present at the exit interview. Also present were the uranium manufacturing manager and another compliance auditor.
2.
Licensee Action on Previous Inspection Findings (Closed) Infractions (78-13-01; 78-21-01): A transfer cart in the H-vault did not provide the minimum center-to-center spacing of 30 inches between containers of special nuclear materials.
On June 6,1978, the cart provided about 27 inches of c_. iter-to-center spacing and on September 27, 1978, the cart provided about 28-1/2 inches of center-to-center spacing.
The inspector verified that a strong rigid spacing device was welded to the cart.
Also a centering device for the container transported in the cart was installed on the cart.
The cart now provides the required 30 inch center-to-center spacing.
(Closed) Infraction (78-21-02):
A posted storage area allowing the storage of 55 gallon drums containing uranium bearing solutions was located in a nonexempt area within 12 feet of the CRP-1 evaporator equipment.
The inspector verified that the nuclear safety posting permitting the storage of the 55 gallon drums of solution in a nonexempt area was removed.
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3 3.
Organization Currently, the incumbents of the organizational key functions described in the license reporting to the Manager of Pennsylvania Operations are as follows:
Manager of Pennsylvania Operations - W. F. Heer Manager of Nuclear Material Control and Accountability - W. P. Neal Manager of Security - J. M. Shields Manager of Technical Control - M. A. Austin Manager of Quality Assurance - R. M. Jackman Manager of Plutonium Manufacturing - E. M. Benson Manager of Uranium Manufacturing - R. V. Carlson M. A. Austin was named Manager of Technical Control effective October 15, 1978.
Since Mr. & 3 tin did not meet the " professional qualifications" for the Manager of Technical Control given in Specification I-4.2.l(C) of the approved license application, the licensee's Safety Advisory Board performed an evaluation and subsequently approved the appoint-ment of M. A. Austin as Manager of Technical Control in accordance with Soecification I-4.6.l(D) of the approved license application.
The head of the Nuclear Materials Division also approved the appoint-ment in accordance with the foregoing specification.
The professional qualifications for the Manager of Technical Control given in Specification I-4.2.1(C) requires"
" Baccalaureate Degree in science or engineering field; and, ten (10) years experience in the nuclear industry (or other regulated and controlled industry);
including five (5) years of technical management." Mr. Austin has a Master of Science in Hygiene awarded August 1974.
Mr. Austin has three (3) years of experience in the nuclear industry at the Babcock and Wilcox Pennsylvania Operations.
The licensee's evaluation was that Mr. Austin's evaluation, which exceeds the required qualifications; his relevant work experience in the Pennsylvania Operations; and his close access to the Manager of Pennsylvania Operations for adminis-trative assistance, as necessary, justified Mr. Austin's promotion to Manager of Technical Control.
Currently, the incumbents of the organizational key functions described in the license reporting to the Manager of Technical Control are as follows:
Manager of Technicei Control - M. A. Austin Manager of HLith and Safety - R. D. Corridoni Manager of Compliance - F. T. Foster (Acting)
Licensing and Nuclear Safety Specialist - Vacant Licensing Specialist - M. A. Austin Q (y
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4 Nuclear Safety Specialist - personnel from Lynchburg Nuclear Criticality Safety Group Training and Development Coordinator - G. R. Osborne Regulatory Projects Coordinator - D. G. Ortz As shown above, as Manager of Technical Control, Mr. M. A. Austin has been responsible for the Licensing function of the Licensing /
Nuclear Safety Function since October 15, 1978.
This is because the Manager of Technical Control has been performing this function, according to the licensee, since the former Licensing and Nuclear Safety Specialist left Pennsylvania Operations as of August 25, 1978.
Also, Mr. F. T. Foster was appointed Manager of Compliance effective October 17, 1978.
Both of these organizational changes are in non-compliance with Specification 4.0, Organization, as explained below.
Specification 4.0, Organization, states, in part, that, "The profes-sional qualifications statements detailed in this specification are minimum (basic) academic and experience requirements for the in-cumbent without any unique qualifications for the position described.
In special cases, unique qualifications such as extended service in the facilities involved, superior academic attainment, provided access to a former incumbent to the position and/or access to an individual (s) with the minimum academic and experience requirements, etc., may be substituted for the base requirements.
In such special cases, an individual may hold the position, provided the evaluations and approvals required by section 4.6.1 of this specification are met."
In order to fulfill the Licensing function, Mr. Austin must meet the professional qualification statement detailed in the specification for the function. According to Specification 4.2.4(C), Professional Qualifications of Licensing and Nuclear Safety Specialist, for the Licensing function, the incumbent must have a Baccalaureate Degree in a science or engineering field; and five (5) years experience in obtaining licenses and permits from Regulatory Agencies.
Mr. Austin does not have five (5) years experience in the nuclear industry; and his three (3) years of experience at the B&W Pennsylvania Operations did not include experience in obtaining licenses and permits from Regulatory Agencies.
The evaluation for Mr. Austin's promotion to Manager of Technical Control did not address the justification for Mr. Austin to perform the Licensing Specialist function while being Manager of Technical Control.
As pointed out, Specification 4.0, Organization, requires the evaluation and approvals required by section 4.6.1 of the specification to be performed for Mr. Austin to fulfill the Licensing function.
Failure to follow Specification 4.0 in this regard is part of an item of noncompliance (78-25-01).
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5 The appointment of Mr. F. T. Foster as Acting Manager of Compliance is of concern because the duration of this assignment has not been defined by the licensee.
Since this assignment could be effective for months, stric+, attention to license conditions concerning such an organizational change are warranted. The professional qualifi-cations for the Manager of Compliance are given in Specification 4.2.3(C). These qualification are as follows:
"A Baccalaureate Degree in Science or Engineering; and, five (5) years of nuclear industry experience in the area of health and safety, nuclear materials control, and/or physical security, including two (2) years of supervisory experience." Mr. Foster does not have a Bac-calaureate Degree in Science or Engineering. Mr. Foster does have 20 years of experience in the nuclear industry as an industrial safety engineer, a fire marshal, and a compliance auditor for in-dustrial and fire safety. Mr. Foster has not been intimately involved in the radiation protection, i.e. health physics, aspects of health and safety. He has had no immediate experience in nuclear materials control or physical security.
Since Mr. Foster's qualifi-cations do not meet the professional qualifications statement detailed in this specification, the evaluation and approvals required by section 4.6.1 of the specification should have been made.
Failure to follow Specification 4.0 in this regard completes the item of noncompliance concerning lack of evaluations and approvals required by section 4.6.1 of the specification (78-25-01).
Mr. Corridoni was named Health and Safety Manager effective December 4, 1978. Mr. Breuer resigned from B&W with December 1,1978, being his last day as Manager of Health and Safety. Mr. Corridoni meets the professional qualifications requirements of the Health and Safety Manager position. Mr. Corridoni formerly was the Health and Safety Coordinator, a position reporting to the Health and Safety Manager. The Health and Safety Coordinator is a key function described in Specification I-4.2.6.2, Health and Safety Coordinator, of the approved license application. Therefore, the licensee must take appropriate action to fill this position. This action will be inspected during a future inspection.
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6 4.
Review of Operations The inspector inspected all the facilities under License No. SNM-145, including the laundry.
a.
Contaminated Combustible Waste During the inspection, the inspector noted many cardboard containers holding out-of-confinement, contaminated, com-bustible solid wastes throughout the facility which were not in covered metal containers. There were 14 combustible waste standard boxes stored in the low enriched uranium counting area in CF-1 area which were not stored in metal containers.
There were 14 cardboard boxes of contaminated waste in the CP-1 area outside the incinerator area which were not in metal containers. There were many boxes of contaminated waste stored in the CP-1 annex.
There was a cardboard box by the filter cut up glovebox in the high enriched uranium area and a cardboard box in the old maintenance area in the high en-riched uranium area which were not contained in covered metal boxes.
This is an item of noncompliance with Specification 5.1.4A, Fire Safety, which requires that, "Out-of-confinement, contaminated, combustible solid wastes (in process areas) shall be stored in covered metal containers" (78-25-02).
The prevention of fire in the process areas, i.e., contaminated areas, is important.
Water is not available for fighting fire in the contaminated areas of the facility; and C0, ABC, and/or 2
dry chemical fire extinguishers must be relied on for fire fighting in the contaminated areas of the facility.
b.
Differential Pressure Measurement on Gloveboxes During the inspection, the inspector noted gloveboxes in the low enriched uranium processing areas which did not have gauges or manometers installed to measure the differential pressure between the glovebox atmosphere and the room atmosphere.
Some of the gloveboxes noted were the pellet trial glovebox complex in CF-1 area, the Trent furnace glovebox, the CP-1 blender glovebox, the weight adjustment glovebox and the Hevi-Duti furnace glovebox.
These are representative of an item of non-compliance with a license condition.
Specification 5.1.2.G, Enclosures and Ventilation, states, in part, that,"Glovebox
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7 static pressure shall be maintained at a minimum of 0.25 inch of water (negative) unless a documented evaluation by Health and Safety shows that radioactive material can be maintained at a lesser negative, or positive, pressure." Health and Safety had not performed and documented evaluations showing that the 0.25 inch negative pressure was not required to control the radioactive materials inside the containment gloveboxes discussed above (78-25-03).
c.
Manufacturing Instructions The inspector examined some of the Manufacturing Instructions (mis) located at the processing equipment for the scrap recovery operations for high enriched uranium, since the scrap recovery operations will be performed while the high enriched uranium equipment is being dismantled and removed from the Apollo facility. The inspector noted that the MI-7.0, Revi-sion 3, Ammonium Diuranate Precipitation, was dated June 6, 1977; MI-4.0, Revision 2, Solid Drying Hood, was dated October 18, 1977: and MI-2.0, Revision 2, Dissolution of Scrap Material, was dated October 29, 1976.
The fact that the procedures had not been reviewed and revised as necessary during the year from the date on the MI is an item of noncompliance with Specification 5.2, Administrative Policies and Procedures, which requires that, "Long term procedures, such as the Manufacturing Instructions and the Health and Safety Manual, shall be reviewed for updating at least annually." (78-25-04).
The inspector examined the mis for the laundry facility.
The mis were available to the operating personnel.
Seven of the nine mis were dated October 12, 1977. The other two were dated February 21, 1977. The Manufacturing Instructions were in the final stages of the review and revision process at the time of the inspection. The seven mis dated October 12, 1978, will be dated November 15, 1978, when they are completely approved and reissued.
One of the mis dated February 21, 1977, will have a March 21,1978 date. The other MI dated February 21, 1977 is still being revised at the time of the inspection.
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Compliance with a Manufacturing Instruction The inspector reviewed MI No. 2.0, Revision 4, dated September 18, 1978, Dissolution, for CRP-1, Low Enriched Scrap Recovery. The MI was reviewed for safety aspects of the operation. The opera-tion was then discussed with the operating technician operating the dissolver.
The Manufacturing Instruction contained extensive Special Hazards and Precautions and Nuclear Safety sections. The content of these sections was well conceived and operating personnel were supplied a good safety tool with these instructions.
The inspector observed the operating technician as the technician performed some of the dissolution activities.
The technician wore a face shield and rubber gloves as required by the procedure while performing the work.
Discussion of the nuclear safety aspects of the operation disclosed that the operating technician was not completely aware of the nuclear safety instructions given in the MI.
In all instances, the operator inoicated a more rigorous approach to nuclear safety than was required in the MI.
During the discussion, the operator questioned the need for Instruction 8.12.
This instruction called for turning off the dissolver feed screw if the low level alarm on the nitric acid feed line sounded.
According to the cperating technician, the material to be dissolved is added in batches rather than continuously and the material is added to acid already in the dissolver.
This comment was pointed out to the licensee by the inspector.
e.
Caution Signs The licensee has a caution sign on the main entrance to the Apollo Uranium Facility which says, CAUTION RADI0 ACTIVE MATERIALS Any Area or Container Within this Plant May Contain Radioactive Materials The inspector pointed out that License Condition 14 of the renewed SNM-145 license requires a sign with a specific legend to be posted at entrances to each building in which radioactive materials are used, stored or handled.
This condition applies to the laundry building also.
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9 5.
Nuclear Safety a.
Compliance with Nuclear Safety Postings During the inspection of the facility, the inspector noted that the licensee was mainly complying with the posted nuclear safety specifications. However, the inspector noted one instance where a 55 gallon drum with a contaminated jaw crusher and a cart with an 11 liter bottle were stored in an area posted with a nuclear safety specification calling for storage of empty containers of a maximum 55 gallon size.
This is an item of noncompliance (78-25-05).
b.
Storage of 55 Gallon Drums Containing Uranium The licensee has many locations throughout the low enriched uranium processing areas where 55 gallon drums containing uranium bearing solutions with less than 4.5 grams U-235 per liter are stored.
Each of these locations is posted with a nuclear safety posting stating that the concentration of liquid placed in 55 gallon drums must be less than 4.5 grams per liter.
Nor.e of the 55 gallon drum storage locations were delineated as a criticality zone as called for in Specifica-tion 5.1.3.B(iv), Interaction, of the approved license appli-cation. The inspector inquired why the criticality zones for the drums were not delineated.
The licensee replied that 55 gallon drums containing solutions with less than 4.5 grams U-235 per liter could be stored anywhere and would not have to be considered in the interaction of individual subcritical units. Therefore, no delineated criticality zones were needed for the storage of 55 gallon drums containing solutions with less than 4.5 grams of U-235 per liter.
c.
Vacuum Cleaners According to the description in the " demonstration" portion of the licensee's application given in item 4.14 on page II.1.B.14(k),
the borosilicate raschig rings used in the vacuum cleaners are used as the primary means of criticality control.
According to the license specification 5.1.3.E(i), "Borosilicate glass raschig rings that are used as a primary means of criticality control shall be used in accordance with ANSI N16.4 "Use of Borosilicate Glass Raschig Rings as a Neutron Absorber in Solutions of Fissile Material."
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10 During the inspection of the facility the inspector noted the inside of a vacuum cleaner located in tha high enriched uranium area. The borosilicate glass raschig rings were packed with sludge.
The contents of the cleaner appeared to be sludge and rings instead of solution and rings.
ANSI N16.4-1971, states in the Foreword, "This Standard pro-vides guidance for the use of borosilicate glass raschig rings as a neutron absorber for criticality control in plants pro-cessing fissile materials.
It recommends concentrations of homogenous solutions of uranium and plutonium in vessels of unlimited size when packed with rings." The inspector asked the licensee how they could consider the vacuum sweeper ap-plication to be an application meeting ANSI N16.4-1971 when the uranium picked up by the sweeper would not be in the form of a homogenous solution. The material picked up by the vacuum cleaner is dirt, concrete, etc., along with uranium bearing material. The uranium bearing material picked up by the vacuum cleaner would probably be uranium oxide or ammonium diuranate solids picked up as a slurry with cleaning water.
The licensee indicated they would study the issue.
They might' attempt to meet section 6.2.2 of ANSI N16.4-1971.
Section 6.2.2, Determination of Fissile Solids on Rings, states,
" Rings shall be removed from representative regions on the vessel and any solids disposited on their surface shall be analyzed for fissile material content.
If the solids deposited on the surface of the rings contain more than 50 grams of fissile solids per liter of glass, the rings in the vessel shall be cleaned." The licensee also indicated that they may decide to attempt to justify the use of the borosilicate glass raschig rings in the vacuum cleaner as a secondary means of criticality control.
This situation will be inspected during a future inspection.
6.
Safety Advisory Board The minutes of the monthly Safety Advisory Board (SAB) meetings for March through November 1978 were reviewed.
The Apollo Uranium Faci-lity was inspected by the SAB for housekeeping and " fugitive con-tamination" during the last of March 1978.
The SAB concluded that L)) l)
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11 elimination of the carrousel used for blending of uranium oxide powder would help reduce contamination levels in the low enriched uranium manufacturing area.
During the June meeting, the SAB recommended that the stack from the high enriched dissolver residue drying hood be continuously monitored for radioactive contamination.
This was prompted by a fire on June 21, 1978, in the offgas venti-lation system for this unit. M uring the TeptEnber meeling,'the-SAB considered the high enriched uranium equipment dismantling and cleaning activities.
During the November meeting, the Apollo emergency brigade was discussed.
Review of the mirutes showed that since the September 1978 meeting the Manager of Compliance has not been acting as sec:etary to the Safety Advisory Board. According to the license, the Manager of Compliance is to serve as secretary to the Safety Advisory Board.
This is an item of noncompliance (78-25-06).
The inspector inquired as to the method the Safety Advisory Board used to keep abreast of the activities of the various Ad Hoc Com-mittees.
The Chairman indicated they would have a copy of all the Ad Hoc Committee meeting minutes sent to the SAB, and the SAB would review the minutes of the meetings in order to keep abreast with the activities of the various Ad Hoc Committees.
7.
Nonroutine Events The inspector reviewed the licensee's files on nonroutine events which occurred in the Apollo Uranium Facility during February through November 1978.
Date Event February 4, 1978 Operating technician had nose smear > 100 dpm (114 dpm)
March 25, 1978 Operating technician had nose smear > 100 dpm (132 dpm)
April 1, 1978 Operating technician had nose smear > 100 dpm (102 dpm)
April 19,1978 Release of airborne radioactive contamination to an unrestricted area from the CRP-4 scrubber stack in excess of limits
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12 Date Event June 21, 1978 Fire in residue drying hood offgas ductwork June 28,1978 Emergency generator failed to start after a power failure June 30, 1978 Two operating technicians had nose smears >
100 dpm (828 and 108 dpm)
July 18,1978 Two UF leaks in low enriched uranium process 6
area August 28, 1978 Alpha radiation alarm sounded October 10, 1978 Fire in laundry facility The licensee investigated the circumstances concerning each of the nonroutine events and either have taken or are taking corrective action.
8.
Exit Interv h The inspeccor met with the licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on December 8,1978.
The inspector summarized the scope and findings of the inspection.
The findings concerning the organization were discussed further during a telephone discussion between Mr. Heer and Region I Deputy Director J. M. Allan on December 20, 1978, and during a telephone discussion between Mr. Heer and Messrs. Crocker
.d Kinney on December 21, 1978.
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