ML19225C413
| ML19225C413 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 05/11/1979 |
| From: | Book H, Cooley W, Fong F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19225C408 | List: |
| References | |
| 70-0025-79-03, 70-25-79-3, NUDOCS 7907300260 | |
| Download: ML19225C413 (17) | |
Text
U. S. NUCLEAR REGUI.ATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION V Report No.
70-25/79-03 Docket No.
70-25 License No. _SNM-?1 S.,feguards Group-1 L.ensee:
Energy Systems Group
_Rockwell International Corporation Canoqa Park, California 91304 Facility Narne:
Headquarters Site and Nuclear Development Field Laboratory Inspection at:
Headquarters Site and Nuclear Development Field Laboratory Inspection conducted:
March 26-30. 1979 Y/iG/N/
//y/77 Inspectors:
W. J. Cooley, E6el Facilities Inspector Dat'e Signed
&'//>
9tW O, J
F. F. 'Fong,yRa'diation Specialist Date Signed Date Signed Approved By:
U N
/!7f H. E. Book, Chief, Fuel Facility and Materials Date. signed Safety Branch S urrma ry :
Inscection on March 26-30. 1979 (Report No. 70-25/79-03)
Areas Inspected: Modifications and changes to facilities and Lystems; internal review and audits; safety committee activities; procedure control criticality safety; environmental programs; emergency planning; radiation protection; review of operations; confirmatory measurements; and transportation program. The inspection involved 70 inspector-hours onsite by two NRC inspectors.
Results:
No apparent items of noncompliance or deviations were identified witnin the subject areas inspected.
790750czee RV Form 719 (7) 434 19g
DETAILS 1.
Persons Contacted
- R. G. Jones, Vice President and CenHiler, Finance and Administration
- M. E. Remley, Managerc Health, Safety anu Radiation Services Dept.
V. J. Shaubert, Manager, Nuclear Materials Management
- J. D. Moore, Enginear, Radiation and Nuclear Safety Unit F. F. Couture, Fire Protection Engineer and Emergency Coordinator J. A. Chapman, M.D., Medical Director R. R. Garcia, Health PhyGicist, and Criticality Safeguards Coordinator D. Owens, HSRS Represenative, Building 55 F. H. Badger, HSRS Representative, Building Q G. A. Speight, Health Physics Analyst J. H. Wallace, HSRS Representative, Buildlng 001 F. W. Begley, Health Physics Analyst J. Harris, Assistant Manager, Radioactive Material Disposal Facility G. F. Johnson, Manager, Engineering Support, Nuclear Development Field Laboratory K. Johns, Manager, Facility Industrial Engineering, NDFL D. J. Aubuchon, Manager, Manufacturing C. F. Hof, Traffic Administrator R. L. Jaseph, Quality Assurance Audits and Cor<trols, Quality Assurance Department K. D. Miller, Packaging Engineer, Facilities and Industrial Engineering P. F. Higgins, Quality Assurance Program Adminit.trate, Quality Assurance Department K. E. Buttrey, Physicist, Chairman of Criticality Subcommittee of the Nuclear Safeguards Review Panel R. R. Dominek, Vault Attendant, Nuclear Materials Management D. C. Allen, Nuclear Materials Management
- Deno'.es those attending the exit interview.
2.
Modifications and Changes to Facilities and Systems The licensee has redesigned many fuel storage locations in the Desoto Avenue main vault and has reanalyzed the vault for criticality safety. The remodeled vault was placed in use in the latter part of December, 1978.
Concurrently, fuel from the ATR vault in Building 001 was moved to the main vault. The former ATR vault is presently in use as a contaminated equipment storage area.
Plans for that former vault ar:1 are to convert it to a powder preparation line.
Changes in the main vault are discussed in more detail below under the heading Criticality Safety.
The licensee has completed the removal of four glove boxes from the Building 55 facilities. Those glove boxes were inerted, packaged and shipped for burial frCm the licensee's Nuclear Field Development Laboratory.
fh 3.
Internal Review and Audit / Safety Committee Activities Condition 18 of the subject license requires the preparation of radiation safety plans and nuclear safety analyses for all new operations and changes in operations conducted by the licensee.
Condition 19 of the subject license requires an annual review to determine that those plans are kept up to date and also requires documentation of each review on each plan.
This inspection included reviews of the criticality study, nuclear safety analysis and radiation safety plan which the licensee had prepared for the Advanced Test Reactor (ATR), Test, Research and Training Reactor (TRTR); and the Hallam Fuel Decladding Programs.
That review indicated the analyses and plans were maintained in a current status as determined from an index of changes which indicated the date of the change and its required approvals.
The Radiation Safety Plan for ATR powder and fuel element production had received an annual review and that review is documented on the plan.
The nuclear safety analyses for the ATR powder and fuel production had last been revised with revisions approved during September, 1977.
In December,1978 the Fuels Committee of the Nuclear Safety Review Panal made its annual inspection of the Desoto Avenue plant and the Nuclear Field Development Laboratory with attention to the adequacy of the nuclear safety analyses for each area inspected. A report of that inspection made reference to the nuclear safety analyses and to the fact that they had been reviewed.
The NRC inspection review was also addressed to the criticality safety study and nuclear safety analysis associated with the Desoto Avenue main vault changes which have been mentioned above in this report.
That review indicated the criticality study had begun in approximately July,1978 and that the study and its results, had been presented to the Fuels Committee of the Nuclear Safety Review Panal about October, 1978. That communication with the Fuels Committee exhibited approvals by the Chairman of that committee and indicated review and concurrence by a Reactor Physicist.
The review indicated that a nuclear safety ani21ysis had been draf ted and reviewed by the Criticality Adviser but that it had not yet been published in final form.
Some details of the 1icensee's standard operating policies and radiation safety p'ans are given below in this report in Section 4, Procedure Gontrol. Additional details on the criticality safety study regarding Desoto Avenue main vault changes are given below in Section 5, Criticality Safety.
4.
Procedure Control The licensee's Standard Operating Policy establishes the broad policies for Energy System Group work.
Standard Operating Policy B-14 Radiological Safety - Criteria and Resconsibilities, issued S.f August 13, 1974, delineates the responsibilities of various groups.
Operating supervision is responsible for adherence to the Safety Manual, notification of Personnel (Training) for specialized education, requests for personnel monitoring services, and assurance of handling and stortge approval by Health Safety and Radiation Services (HS&RS) and/or the Nuclear Safeguards Review Panel (NSRP).
NSRP is charged to evaluate existing or proposed designs and pro-posed plans and procedures for handling, use and storage of special nuclear material. The evaluations of the NSRP are recommendations and final approving authority lies with operations.
Responsibilities for Training, Medicine, Protective Services and HS&RS are also given.
Standard Operating Policy B-16 Nuclear Criticality Control issued August 13, 1974 was also reviewed.
A completed NSA consists of step-by-step description of operations, room layout, and a descrip-tion of the process operating line.
This description details the room, number and location of work stations, description of work at each station, and the processing operating limit at each station.
Signatures required on a completed NSA are those of the requester, immediate supervisor, supervision of all areas in which material will or may be moved, Nuclear Material Management, Criticality Safeguards, Operational Safety and the Chairman of the Fuels Committee.
Pol %y B-16 also provides procedures for license amendment submittal and operating personnel orientation.
Changes to existing procedures may be approved by Criticality Safeguards only if work stations are odded or relocated according to pre-viously approved criteria or if storage rack redesign is based upon previously approved criteria.
The Radiation Safety Plans for the ATR Fuel Fabrication (N065 SRR 205-003 dated August 11,1978) and for the Hallam Fuel Decladding were also reviewed.
The ATR Radiation Safety Plan detailed the responsibilities of Radiation and Nuclear Safety, Facility Super-vision, Operations Personnel, Nuclear Material Management, and Criticality Safeguards.
General Radiation Safety Procedures detailed area designation, posted areas, survey frequency, removable contamination limits, survey reports, signs and warning devices, facility ventilation, evaluation of airborne contamination, limits, records, personnel monitoring devices, area radiation monthly surveys, bioassay, protective clothing, instruction of personnel, employee quali fi-cations, instrumentation, decontamination, removal of equipment from controlled areas, posted areas, use of the Restricted Access Area Entry Permit, filter changes, emergency evacuation, and radioactive waste handling.
The Hallam Radiation Safety Plan detailed the process and facility, process and facility safeguards, operator qualification and training, and waste disposal and material control.
Both reviewed plans appeared to have adequate written procedures for the conduct of safe operations.
f
..-c-5.
Criticality Safety As stated above in this report the storage configuration of fuel in the Desoto Avenue main vault was modified at the end of l'178.
That modification permitted the climination of the ATR vault in that the modification provided space for that fuel storage and released the ATR vault to other manufacturing purposes.
This inspection included a visit to the Desoto Avenue main vault as well as a review of the criticality safety study for the new vault configuration.
Prior to the modification of the Desoto Avenue main vault storage configuration fuel was store primarily in sealed one-quart metal cans. Those cans were stacked vertically, the vertical column being stabilized with three tie rods.
The vertical columns were spaced at about 23 inches center-to-center.
That configuration was used, in general, on both the north and south walls of the vault.
The vault racks were of very heavy steel construction, anchored to the vault walls, and analyzed for seismic activity.
Af ter the modification the heavy steel racks rernain aloig the south wall of the vault but are now fitted with collars to act,mmodate sealed five-inch diameter metal cans, stacked one high rather than in vertical columns. The center-to-center spacing of the collars has remained the same. The south vault racks have also been equipped with open top trays approximately 72 inches long.
Those trays are used for the horizontal storage of sealed metal cans and also for the storaSe of solidified waste. The trays acccmmodate eight cans each and the maximum weight per can is three kilograms uranium 235. The trays are each provided with four drain holes in the event of water addition. Both prior to and af ter the modifi-cation water has been excluded from the vault. The vault is equipped with a dry fire supression system.
The array of vertical columns of sealed metal cans of fuel has been eliminated frcm the north wall of the vault.
That configuration has been replaced with a series of horizontal drawers fixed in an array twenty-four columns wide and six rows high.
The drawers measure six inches by six inches anc are spaced surface to surface at approximately twelve inches both vertically and horizontally.
The drawer unit cell measures 17.4 inches by 18.6 inches by 72 inches long. The drawers are equipped with a latched, gasketed cover to provide a water-tight seal.
All fuel configurations at both the north and south walls are provided with eight inch spacing from the vaul t, concrete walls. The configurations have been studied for seismic activity.
The density analog method for analysis of arrays of fissile material was used in the criticality safety study for the modified vault configuration. That calculation included a factor of.45 on the calculated allowable namber of units in t configuration.
A 4 Add factor of 2.5 was used for interspersed moderation (possibly from sprinklers) and a factor of 13 was provided for close, infinite, water reflection of the overall array. No credit was takan for the boron carbide in some of the fuel product or for the cloride in polyvinyl claride sleeves used to protect those products.
The hydrogen content in the polyvinyl cloride was included in the calculations. Appropriate re'lection of individual units ranged from minimal to nominal.
The criticality study then assigned a criticality index to each type of fuel to be stored as calculated from the density analog method for each type of fuel. The total allowable numbers of storage locatio1s thus calculated were 6083 for seven kilogram units of uranium 235 on approximately twelve inch center-to-center spacing and 2378 allowable locations for ten kilogram units of uranium 235 at the same spacing.
The licensee then assigned an estimated number of required locations for each type of fuel.
In the cases of ATR plates 57 locations (in drawers) were assigned for a total storage of 2737 ATR plates. ATR fuel elemen a were assigned to 30 drawers. TRTR fuel plates were assigned tu 21 locations for a total of 2016 plates.
TRTR fuel elements were assigned to 15 locations and an additional 21 locations were allowed as spares.
The above array ioading was for the vault north wall drawer array. A fully loaded north wall drawer array had an estimated criticality index of 0.62 using nominal reflection of individual drawers.
The vault south wall arrays contributed 0.025 index fce cans of r,aw stock, 0.031 index for laboratory samples, and 0.001 index for solidified laboratory waste for a total of 0.057 criticality index.
The analysis also permits the storage of 58 00T model 6L, 6J, and 6M shipping containers in an isolated array located centrally between the north and south wall arrays in the vault.
I t was observed during a visit to the Desoto Avenue main vault that criticality limits had been posted for each type of array loading a t appropriate cations.
The visit to the Desoto Avenue main vault included a review of cri tical i ty li'it posting. Posting indicated the limit of 48 ATR plates or one ATR element per drawer on the north wall.
The post.cg a so in'dicated the limit of 96 TRTR plates per drawer or 2 TRTR t uel elements per drawer.
One-inch diameter drain holes, two per drawer, were observed in the north vault wall drawer array.
Limits of one, one-gallon can per collar were spaced at a minimum of twelve inches surface to surface on shelves along the south wall of the vault.
Limitations of ten kilograms per container were posted.
Typicai sealed can loadings as judged from can labels was five to six kilograms per storage location.
Horizontal trays mounted on shelves at the south wall of the vault were provided with four drain holes per tray.
Typical loading of the trays was eight, one-gallon, sealed cans per tray at three kilograms uranium 235 per can.
Criticality limit posting also indicated four bottles of solidified waste per tray at the rate of 50 grams fissile material per bottle.
An isolated array of 6L and 6M shipping containers was located centrally between the north and south arrays in the vault.
Label s on those shipping containers indicated contents ranged from approxi-mately 600 to 3000 grams L;anium 235 per 6M container.
The array contained eight 6M shipping containers. The array aise contained twelve 6L type drums each containing some 100 to 300 grams uranium 235 as indicated by container labeling.
6.
Environmental Procrams License Amendment 1, Condition 42 specifies that the licensee will sample the water from the Santa Susanna site pond for tritium prior to release and take daily sewage outflow samples from the Desoto site for monthly tritium analysis.
This condition provides further that if the maximum concentration determined on a twelve month basis is 4 5% of the applicable limits specified in 10 CFR 20, sampling IEay be discontinued.
To meet this specific requirement, the licensee purchased an ISCO sewage sampler. This liquid sampler was used at the Desoto site to take a 40 ml sample every 160 minctes between the hours of 6:00 a.m.
and 6:00 p.m.
The composite monthly sample was about five liters.
The 5% limit for the Desoto site was determined to be 5 x 10
-4 uCi/ml and for the Santa Susanna site to be 1.5 x 10 uCi/ml.
The maximum concentration as analyzed by the U.S. Testing Company for any month was 6.3 x 10- uCi/ml (October,1978) for the Desoto site and 1 x 10- uCi/ml (December, 1977).
Since no monthly tritium analysis for a twelve month period exceeded the 5% limit of 10 CFR 20, the licensee notified on fiarch 22, 1979 the Division of Fuel Cycle and Material Safety that Energy Systems Group is discon-tinuing the sampling and analysis for tritium.
Also during this inspection no operation was observed which could have a significant potential for release of tritium.
An environmental report for the year 1978 is in the process of publication. Preliminary data are summarized as follows:
- 43s, Soil Pu Radioactivity in ugm/gm for 1978 6/8/78 Sampling Results Sample Location Pu 238 Pu 239 + 240 S-56
(-2.90 1 2.3)l0-9 (1.04 1 2.3)l0-9
-9 S-57
(-2.13 1 2.2)l0-9 (1.1412.2)l0
-9
-9 S-58
(-3.59 1 2.3)l0 (1.4613.0)l0-9 S-59
(-3.61 1 2.3)10-9 (3.1013.4)l0 S-60
(-2.71 1 3.2)l0-9 (3.35 1 3.9)l0-9 12/13/78 Sampling Results Sample Location Pu 238 Pu 239 + 240 S-56 (2.61 1 230)l0-II (9.05 1 3.6)l0-9 S-57
(-7.74 1 24)l0-10 (6.21135)l0-9 S-58
(-2.61 1 21)l0-10 (5.54 1 2.8)l0-9 S-59 (1.2212.4)l0-9 (5.98 1 2.8)l0-9 S-60
(-3.66 1 1.7)10-9 (8.24 1 4.4)l0-9 Soil Radioactivity Data in uCi/gm for 1978 Location Analysis Number of Gross Average Maximum Samples Value Observed Value Onsite a
144 (6.5 1 1.5)10-7 9.9 x 10 -7
-5
-5 Onsite f
144 (2.4 1 0.09)10 4.8 x 10
-7
-6 Offsite 6-48 (5.1 1 1.4)l0 1.0 x 10 (2.4 1 0.09)l0-5 3.4 x 10-5 Of fsi te
{
48 Domestic Water at Santa Susanna Field Laboratory in uCi/ml for 1978 Analysis Number of Samples Concentration Maximum Observed Value (42.612.8)l0-10 4.4 x 10-10 d
24 24 (3.0 1 0.8)l0-9 3.6 x 10-9 434 Air Radioactivity Data in uCi/cc for 1978 Location Analycis Number of Average Maximum Samples Value Observed Value
-I4 Desoto d-713 (48.4 + 8.1)l0-15 9.5 x 10
-I4
-12 Onsite 4
713 (49.111.7)l0 1.4 x 10 NDFL 1724 (4.7.2 + 7.9)l0-15 2.1 x 10-I4 d
-12 Onsite 1724 (4.8.8[1.7)l0-I4
- 1. 5 x 10 15
-I4 NDFL 4
327 (47.3 + 7.3)l0 I4 4.4 x 10-12 Sewage Treatment Plantp 327
('8.4[1.6)l0-1.2 x 10 Offsite SSFL 351
(/_7.1 + 7. 3)l0-15 3.4 x 10-I4 Offsite f
~
1.3 x 10-I2 Control Center cA-351 (c8.9 + 1.6)l0-I4
^ MDL = 6 x 10-15 uCi/cc
( BMDL = 1.2 x 10-I4 uCi/cc 6.
Emergency Planning a.
Coordination With Offsite Agencies The licensee appeared to have close working relations with offsite agencies. As a State of California licensee for the possession of byproduct material, continual contact is main-tained riith the California Radiological Health and California OSHA. The Los Angeles Police Department is in daily radio signal and telephone contact with Energy Systems Group.
On March 20, 1979 a group of policemen headed by Sgt. Rehm was indoctrinated in the security plan.
Commander Stanley M. Borden of the Los Angeles Fire Department, Battalion 15 "B"
- Platoon, detailed the fire department response in the letter dated October 3,1977. The yearly training course for 50 LAFD personnel is planned for next week.
Mr. G. Stanley of the County of Ventura Disaster Services provided the county emergency response to NDFL in the letter dated November 29, 1977.
Mr. R. M. Mastaler, Hospital Administrator, in his letter of March 27, 1978 reconfirmed that the West Hills Hospital, 7800 Medical Center Drive, Canoga Park, California, (213)884-7060, will provide hospital support to radiologically related incidents.
$4
-Y b.
Planning - Facilities, Equioment. Procedures The Emergency Plan for Atomics International Facilities Licensed,under Special_ Nuclear Materials License SNM-21 (Al-78-14) issued April 10, 1978 was found acceptable with the issuance of SNM-21, Amendment 4 dated October 4,1978.
The facility emergency plan for Building 001 issued January 23, 1976 was reviewed by D. Aubuchon on December 5, 1978.
The Building 004 emergency plan was reissued on April 1978.
The Building 20 was reviewed by W. R. McCurrin and dated December 15, 1978.
~
On January 9,1979, Dr. Jean A. Chapman replaced Dr. L.J. Jahr.'en as the Director of the Medical Department.
Dr. Chapman stated that in her absence, Dr. Louis flanas
' physician in private 4
practice, may act in the Medical Dep= nent.
Also medical backup is provided by the staff at the West Hills Hospital.
Equipment for emergency response has been described in NRC Inspection Report 70-25/77-08 and 70-25/77-09.
Currently twelve transmitter / receivers have been purchased for use.
Wind socks have been procured and will be installed at every emergency assembly site.
Portable air samplers for emergency purposes will be ct nyerted for car battery operation due to unreliable gasoline powered electric generators.
The Medical Decontaminc. tion Facility (Building 114) at NDFL had an autopsy table anc mobile side shields with four glove port. Toilet and shower facilities and an office area where four cots may be placed were also available.
Miscellaneous' medical and decontamination supplies were observed.
Liquids from the autopsy table and bathroom are ducted to an under-ground tank. The Manager of Facility Industrial Support reported that the tank has a 200 gallon capacity.
Emergency electric power may be provided by a portable electric generator.
c.
Drills and Tests Emergency drills were conducted at Building 20 on June 23, 1978, at Building 172 on December 1,1978, at Building 001 on December 5, 1978, and Building C04 on December 6, 1978.
After each drill a critique attended by the ' responsible participants was held.
Corrective actions were assigned.
Twelve items for action were reported for the drill at Building 001, and five items were noted for Building 004. On December 15, 1978, Building 001 ventilation system was tested for shut down capability.
Eight problem areas were identified and assign-ments made for correction. At the time of this inspection the status o. all corrective actions was not available to the A3A 20F emergency coordinator. Since there is no requirement for followup assessment of corrective actions discovered from emergency drills and tests, an iten of noncomplianc.e was not cited. The problem of followup after emergency drills and tests was brought to the attention of the management during the exit interview.
Emergency electric generators were reported to be tested weekly.
Interviews with HS&RS representatives at various buildings disclosed their generators were so tested.
For Building 114, the records of Engineering Support Services (ESS) showed the generator was tested monthly.
The manager of ESS stated that starting April 1979, Building 114 emergency electric generator will be tested weekly.
The Fire Protection Engineer published a document Fire Protection Equipment and Testing Requirement ef fective July 1, 1977.
This detailed the equipment, reference and test pro-cedure, and the frequency of inspection.
d.
Fire Prevention The four levels of internal fire prevention were reported in Inspection Report 70-25/77-03.
Nuclear Energy Liability and Property Insurance Association conducted an inspection on June 26 and August 17, 1978.
Industrial Risk Insurers in-spected the non-nuclear facilities on June 22, August 7, and August 17, 1978. The American Nuclear Insurers inspected Buildings 001, 004 and facilities at NDFL on June 23, August 7, and August 17, 1978. The American Risk Management was onsite conducting a fire inspection. All fire inspections to date have identified no areas for correction.
7.
Radiation Protection a.
External E4posures All radiation workers we e issued film badges and the film badges were processed by a. S. Landauer, Jr. and Company.
For work assignments in radiation areas where external radiation could be a problem, film badges and/or pocket dosimeters were used.
Pocket dosimeters were calibrated at a six-month frequency by Health Physics personnel.
Summary of exposures had been reported per 10 CFR 20,407.
The personnel in Building C01 change film badges quarterly and about 50 persons were so badged.
In 1978 the highest exposure was 430 mrem.
For Building 003, 35 persons have their film badges changed quarterly and the maximum exposure was 140 mrem for 1978. Six persons were issued monthly film badges in 434 206 Building 55 and the highest exposure in 1978 was 910 nPa...
For January,1979, an individual showed an exposure of iiu mrem. Twenty-seven personnel in Building 20 were issued film badges on a monthly frequency and the highest exposure was 2660 mrem for 1978.
For badging up to February 28, 1979, the highest exposure was 350 mrem.
b.
Internal Exposure The licensee's program for internal dose assessment was reviewed in Inspection Report 70-25/78-02.
On March 8, 1979, an assessment of the uranium isotopic composition for t!
ATR fuel mix showed the MPLB, as detected by in-vivo lung cc. ting for U-235, to be 245 ugm.
For the year 1978 the followir,. is a summary of internal deposition data:
Analysis Total Number Positive llegative Type of Samoles Results Resul ts Flurometric Uranium 321 13 308 In-Vivo Lung Count (U-235) 48 11 37 Radiometric Uranium 318 0
318 Pu (A) 27 0
27 The highest IVLC was 28.2% MPLB and that same individual was recounted on January 18,197? with no detectable lung deposition.
The highest U excretion showed 2.25 ugm of uranium, which is 0.15% MPBB.
In January, 1979, 16 persons were lung counted and three positive indications were identified at 22%,19% and 16% MPLB.
For uranium urinalysis results received up to !1 arch 2, 1979, one positive was seen at 0.3 ugm/ day (40 d/m/ day).
8.
Operation Review The inspection included visits to Building 20, Building 55, Building 1 ATR Production Facility and the main vault.
Building 20 operations are continuing with the Hallam Fuel Decladding in the hot cells.
Survey meters were observed to be timely calibr ited.
Survey wipes and radiation measurements were routinely made.
Air sample results from decladding operations have been normal, and
}
-12 maximum air concentration where workers may be present'was 8 x 10 uCi-hr/cc.
Posting was adequate to meet regulatory requirements.
During the inspection of the outside of the building two 55-gallon drums were brought out to the west loading dock for survey.
A dose rate of 40 d/hr was measured at the building exterior wall and 5 mR/hr at about twelve feet. The drums were transported to RMDF for subsequent shipping.
Building 55 had been retooled for work with depleted uranium.
Depleted uranium was initially used in the glove bcxes on March 19, 1979. Four Pu contaminated boxes had been removed from the line in late 1978 and new replacement boxes were being added.
HS&RS repre-sentatives reported that all controls established for Pu will still be applicable for present use of the building.
tio plutonium was observed in the storage vault or in the boxes except for residual contamigtion. Alpha air sample maximum concentration remained at 9 x 10-uCi-hr/cc.
Routine daily and weekly alpha wipe surveys, air flow measurements, and constant air sample measurements were being made. The log book of HS&RS operations was reviewed and no report of unusual occurrences was F.oted.
Building 001 ATR Production Facility was inspected.
A new vault storage configuration was in place and a new production line was in preparation. The old vault was also being used for temporary storage of equipment prior to installation or disposal.
Review of lapel air sampling, wipe surveys, in-place air sampling data and log books identified no loss of radiat Maximum lapel air concentration recorded was 2 x 10 jon control.
uCi-hr/cc.
(Subsequent bioassay showed no detectable internal deposition.)
Highest in.
sample concentration identified was at the arc melter place ai (3x10-T0 uCi-hr/cc) during times when the melter was opened.
Posting appeared adequate.
The manager of manufacturing was interviewed relative to the location of procedures on the floor for each operation.
He stated that each location / job has a written operating procedure and is found in a blue binder.
He then walked over to the welding station and produced the written procedure for that operation.
9.
Confirmatory Measurements 2
Twelve 100 cm wipe samples were taken at the licensee's facilities.
The samples were counted in a Region V gas proportional counter.
All samples counted for,4.and g radiations showed no detectable activi ty. The locations of the wipes were as follows:
Building 55 Entrance to Room 119 Between sinks in Room 117 Building 20 Clean service galler)
Operating gallery Cell # 3 face area North end of Cell # 4 West Dock Building 001 New vault D-E Aisle Room 119-42, Ten feet from roped area Rocm 119-36, Entrance to Powder Room Entrance to Men's Room at Post 3 Entrance to Room 119-44 (HS&RS Office)
Building 004 Men's Change Room at Step-off Pad 10.
Transportaion Program The licensce's transportation program is established in a number of issued Standard Operating Policies contained in the licensee's Standard Operating Policy Manual. Among those SOPS which pertain to shipping and receipt of radioactive materials are:
50P J-22, Procurement and Receiving of Radioactive Materials and Radiation Producing Devices SOP J-24, Special Nuclear Materials-Forecasting, Procurement and Receiving 50P K-12, Disposition of Nuclear Material Scrap and Waste and Other Radioactive Waste SOP K-14, Shipping Radioactive Materials SOP K-17, Audit of Special Nuclear Material Centrol and Radioactive Shipping Systems SOP K-44, Shioping Following is a brief outline of the content of those SOPS as they pertain of the receipt and shipment of radioactive material.
SOP J-22 prescribes the methods of requisitioning byproduct material and radiation producing devices along with the special requisition forms required.
It also provides for the receipt and storage of those radioactive materials.
It covers the acquisition of internally produced radioactive material (by activation methods).
In each care it requires the review and approval of Health, Safety and Radiation Services Department for the receipt of radioactive material.
kbh 2e0$
S0P J-24 provides for the prccurement and receipt of source and special nuclear material for use under DOE contracts.
The S0P addresses the required requisition forms, review and approval by HS&RS, monitoring of incoming deliveries of the material by Traffic and Warehousing, reporting of radiation or contamination levels which exceed government regulations, verification of package contents, proper labeling, Quality Assurance tests as required, and proper storage of the material.
50P K-12 is similar to S0P J-24 except that it applies specifically to the responsibilities for the disposition of radioactive materials scrap and waste.
50P K-14 presents details for the determination of shipping require-ments and acquisition of special shipping containers.
To that end the 50P points out the functions of Packaging Engineering verifi-cations and approvals to be determined by HS&RS, and the submission of plans, designs, and procedures as required to government regulatory agencies througn HS&RS or Traffic and Warehousing.
Further details regarding the shipment include the preparation of required shipping forms (notably Form 710-S-1) and the required approvals for shipment which appear on that form.
Responsibilities of the department performing the packaging are stated and include coordination with QA to determine required inspection of the package, proper identification of the package contents, required monitoring and tagging by HS&RS, and required approval signatures on Form 710-S-1.
The 50P K-14 details the responsibility of Packaging Engineering.
including assurance that packaging designs, specifications and procedures conform to requirements and that the shipping instruction Form 710-S-1 includes the proper packaging, transportation pro-tection designs, and specifications.
The responsibilities of HS&RS include serving as an interface with state, federal, and customer safety offices for the proper trans-mittal of shipping notifications and reports, determination that the consignee is authorized under NRC Pegula' to receive this shipment, and arrangements for the measuremei.._ aad recordings of the element and isotopic content for shipment of source and special nuclear material.
Quality Assurance is required to inspect packaging and vehicle loading and tiedown to Packaging Engineering approval requirements and to indicate acceptance on Forn 710-S 1 The responsibilities of Trafffc and Warehousing are also detailed in 50P K-14.
Those responsibilities include interfacing with federal and state regulatory bodies, the inspection, repair, and turnaround of reusable shipping containers by coordinating with the radioactive materials decontamination facility, HS&RS, Plant Services, Manufacturing, and Quality Assurance.
Traffic and 43 Wo n
Q' Warehousing is required to maintain an inventory of reusable shipping containers and to arrange for transportation services.
Traffic and Warehousing arranges for final crating, palletizing and labeling of packages; coordinating with Criticality Safeguards for the shipment of fissile materials; providing final assurance that material shipping instruction Form 710-S-1 has been completed and approved; witnessing loading and tiedown operations; assuring that written instructions are provided to carriers; notification of ETA; tracing lost shipments; preparing of additional shipping documents; and providing Nuclear Material Management with shipping information required by NMN for reporting to NRC.
In actual practice many of the Traffic and Warehousing requirements are being performed by Nuclear Materials Management in the case of shipments of source and special nuclear materials.
50P K-17 is addresseo to audits of special nuclear material control and radioactive material shipping systems. Much of that policy statement is addressed to the spec 11 nuclear material account-ability system audits and the special nuclear material physical protection audits both of which are required annually. A section of the S0P K-17 is addressed to an annual audit for conformance with Energy Systems Group policies, procedures, records, and practices as they relate to safety protection for radioactive shipments and receipts. A written report of that audit is required by the Vice President and Controller-Finance Administration each year.
In addition, selective operations significant to the safety of the shipments and receipts are reviewed at intervals of three months.
Nonconformances are required to be reported to concerned supervision.
The audits required by 50P K-17 are performed by the Quality Assurance Department of the licensee. This inspection included e discussion of that audit program with a representative of the licensee's Quality Assurance Department.
That individual produced a schedule of audits several of which pertain to the receipt and shipment of radioactive materials. Those audits were categorized as repetitive, program, and general. Repetitive audits are those which are highly objective, performed from a preplanned checklist, require approximately one-man day to accomplish, and are conducted quarterly.
Program audits are those which review compliance with procedures, e.g., the ATR and TRTR fuel manufacturing programs.
General audits are those which would include a broad review of shipping and receiving of radioactive materials.
The Quality Assurance Department has developed a number of pro-cedures addressed to the inspection, maintenance, and Quality Assurance verification of the adequacy of shipping containers.
Documents of that type include:
Receiving and Maintenance Inspection of Fuel Element Containers QAP-065-302-023
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Shipring Inspection of ATR Fuel Elements QAP-065-302-014 Packaging and Inspection Procedures for Shipping University of Missouri Fuel Elements N263QAP-14 Packaging and Inspection Procedures fer Shipping University of Michigan Fuel Elements N262QAP-14 A review of those procedures indicated they are addressed to (among other things) packaging procedures, packaging inspection and receiving inspection.
SOP K-44 is addressed to shipping in general.
It appears to be a detailed summary of all aspects of shipping materials from the licensee's sites and between local sites. 50P K-44 makes appropriate reference to the applicable SOPS for special forms and approvals required for shipments of radioactive and hazardous materials.
The licensee makes routine use of a limited number of shipping container models. They include models 660 and 660E (Certificate of Compliance 9033, Revision 2), models 680 and 680E (Certificate of Compliance 9035); model D34710-1 (Certificate of Compliance 5088),
DOT specification models 6L, 6J, and 61; and a special ATR fuel shipping container identified by Certificate of Compliance No. 5905 issued by ERDA-ID and dated June 30, 1975. A review of the licensee's files regarding shipping containers indicated that a complete set of backup material was available for each of the models used con-sistent with the referenced material appearing in the Certificates af Compliance forms.
This inspection included a review of Shipping Form 710-S-1 as it applied to four recent shipments of fissile material from the licensee's premises. That review indicated that Form 710-S-1 revised January, 1978 was being executed completely.
The executed form identifies the shipping requester's name, his supervisor's approval, and the signature approval by Nuclear Materials Manage-ment and Criticality Safeguards. The form also identifies the package being used and tne certification by Operations and Quality Assurance personnel that inspections have been accomplished verifying the material loading, package integgity, and final transport loading.
The form includes a description of 41e material being snipped, the name of the consignee and his address, and appropriate signatures of the shipper's representative and receiver's representative. Records for the shipments reviewed included the results of radiation con-tamination and direct reading surveys.
- 11. Management Interview The results of the inspection were discussej with licensee repre-sentatI9es at the conclusion of the inspection on 11 arch 30,1978.
Those individuals were informed that no items of noncompliance or deviations were observed within the scope of the inspection.
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