ML19249B361
| ML19249B361 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/19/1979 |
| From: | Book H, Cooley W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19249B355 | List: |
| References | |
| 70-1257-79-06, 70-1257-79-6, NUDOCS 7909040327 | |
| Download: ML19249B361 (10) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND E.70RCEMENT REGION V 70-1257/79-06 Report No.
1 Stim-1227 Saf eguards Group 70-1257 ticense go, Docket No.
Licensee:
Exxon fluclear Company 2101 Horn Rapids Road Richland, Washington 99352 Facility Narre:
Richland Facility Inspection at:
Richland, Washington June 11-15,1979 Inspection conducted:
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W. J. Cooley, Fuel facilities Inspector Date Signed Date Signed Date Signed
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Approved By:
Dat'e Signed
/A H. E. Book, Chief, Fuel Facility and flaterials Safety Branch Sowary:
Inspection on June 11-15,1979 (Report tio. 70-1257/79-06)
Areas Inspected:
Facility changes and modifications; internal review and audit; Safety Committee activities; employee training; operations review; criticality safety; radiation protection; radioactive waste management; and transportation program.
The inspection involved 30 inspector-hours onsite by one inspector.
Results:
fio items of nonccmpliance or deviations were identified.
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DETAILS 1.
Persons Contacted
- R. B. Stevenson, Manager, UO Shop Operations 7
- R. H. Purcell, Manager, AuxiTiary Operations T. C. Probasco, Er.gineer, iluclear and Industrial Safety H. P. Estey, Manager, Licensing and Compliance, Richland Facility
- M. L. Smith, Senior Engineer, Radiological Safety
- R. L. Miles, Supervisor, Radiological Safety R. H. Schutt, Specialist, Criticality Safety J. B. Edgar, Manager, Traffic Operations
- Denotes those attending the exit interview.
2.
Facility Changes and Modifications At the time of this inspection the licensee was continuing refurbishing and expanding the chemical liquid waste lagoons.
Lagoon No. 4 was being R
constructed.
Lagoon No. I had been drained and a double lining of Hyperlon had been placed j'n that lagoon. A layer of sand had been placed between the two Hyperlon liners and sampling system of polyvinyl chloride tubing had been placed in the sand layer to permit sampling for leakage.
Lagoon fio. 2 had been drained and approxirately ten cores had been drilled in its base.
The licensee plans on analysing those cores for uranium beta ac tivi ty.
If a positive response to beta activity is obtained, the cores will be chemically analysed for uranium.
Sinilar refurbishing of Lagoon No. 3 is planned.
Similar lining and sampling ports will be placed in the nedly constructed Lagoon I;o. 4.
Further monitoring of the lagoons will be provided by 13 test wells.
Ten of those wells will be, generally, dovin strean of the ground water flow with respect to the lagoons.
One well will be located upstream of the lagoons and a final well located some distance from the lagoons providing background, ground water information.
The above work is planned for ccapletion in 1979.
Since the last inspection the licensee has relocated the Contaminated Material Storage building from the western perimeter of the site to a location near chemical waste storege Lagoon flo. 1.
During the reloca-tion the licensee has placed the fissile material content of the storage building in seven truck trailers.
Some fissile material had been placed in the relocated building which has been renamed the Packaged Radioactive Materials Storage building.
The former location of the contaminated materials storage building will be occupied by a maintenance shop to be ccnstructed.
There will be no use of radioactive materials in the new maintenance shop.
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In addition to the above facility changes which were in progress at the tire of this inspection, the licensee plans on increased fuel production capacity; improved capability to renove uranium frca liquid waste before discharge to the lagoons; installation of a temporary and subsequently a permanent uranium-contaminated clothing laundering facility; and the construction and operation of a waste uranium recovery facility.
Those changes and a number of others are projected for initiation during 1979.
The proposed changes in facilities and equipment have been submitted to the Nuclear Regulatory Commission (TRC), Division of Fuel Cycle and Material Safety for evaluation, along with the licensee's timely (May 31, 1979) renewal application for the subject license.
3.
Internal Review and Audit This inspection included the review of criticality safety audit reports dating from January to June,1979.
Those audits were conducted indepen-dently by the criticclity safety specialist and the nuclear safety special-ist on a nonthly and bi-nonthly frequency, respectively.
Our review indicated no problems with respect to criticality safety.
This inspection included a review of radiological safety audits conducted at a *:.onthly freque' :y by the Senior Engineer, Radiological Safety.
That review covered the period of January through June, 1979.
Recormmendations resulting fro:1 those audits included improved housekeeping in the scrap recovery area; and sone required decontamination effort in Room 100, scrap recovery area, and blending room.
The audits included an extensive wipe survey throughout the mixed oxide building.
The audits treated as a significant problem relatively high airborne concentrations of uranium in the men's change room of the UO building.
7 Those concentrations were attributed to narginal filtered exnaust air flow; location of air sampling equipment between the contaminated clothing bin and t!.e filtered air exhaust port; and conjestion in the change room.
Certain actions were identified and assigned to reduce the air concentrations in the mens change room.
They included the continued monitoring and emphasis by radiological safety personnel on change room housekeeping; relccation of the filtered exhaust port; evaluation of a number of pro-posed changes in the change room la, a air balancing the exhaust system to improve ventilation; and the elim.i ation of contaminated clothing sort-ing in the change room with the installation of an on-site contaminated clothing laundry.
Those matters were being pursued at the time of this inspection.
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4.
Safety Committee Activities This inspection included a review of the meeting ninutes of the licensee's Health and Safety Council.
That review covered the period from January through May, 1979.
The review indicated that chip guards had been placed on pellet grinder ring gauges to prevent eye injuries from pellet chips (problem nentioned in IE Report 70-1257/79-04, Section 5, dated March 16,1979).
The review indicated the possible relocution of the emergency evacuation staging area due to new construction of office space. The Health and Safety Council minutes also indicated the formation of a subcommittee named ALARA for the purpose of recommending reasonably achievable reductions in potenial evnsures.
5.
Employee Training The licensee conducts employee training programs including periodic retraining sessions.
About April,1979, that training program was augmented by special sessions designed to supply the employees with more quantitative type of information such as warning levels for respirator use, warning levels for bioassay repeat sampling, location of air sampling equi pa.en t, and air concentration permissible limits.
Those special sessions consist of one hour presentations by experts in criticality, radiological and industrial safety.
At the time of this inspection, approximately six sessions of that type had been conducted at a frequency of once per week.
All employees located in Rcom 100 of UO. plant had been reached on two occasions. The licensee intends to con $inue those sessions indefinitely in the future.
Discussions with licensee personnel including an employee at the U0 plant indicated the sessions are well received as indicated by g
good queswions and discussion of problems on the part of employees.
The special sessions were instituted, in part, as a result of an expression for need of nore quantitative, technical, health physics type information by an employee of the subject licensee.
This inspection included a detailed review of the formal, initial training and retraining sessions on the subject of criticality, radiological, and industrial safety presented to a typical empic;ee.
The information was obtained from a review of licensee records of training provided to that employee. Those records indicated an initial indoctrination at the time of hire in the latter part of 1977.
There were subsequently 15 training sessions presented to that employee over the subsequent 18 months. While specific sessions were devoted to more than one safety subject, it was possible to weigh those sessions in the ratio of 8:4:3 with respect to radiological safety, criticality safety, and operational type of training.
Subjects range to industrial safety, air sampling, exposure limits, bio-assay sample enrichment control, use of survey instruments, storage of containers w r fissile material, use of step-off pads, wearing contact lenses and facial hair, criticality safety specifications, and standard operating procedures.
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Operations Review This inspection included a visit to the Special Enrichment Storage trailer located adjacent to the UD, building.
It was observed that the exterior of the trailer was posted with the proper radioactive material warning signs, a prohibition against storing fissile raterial within ten feet of the trailer wall, and the proper fire zone rating D (ne water).
The interior of the trailer was used for storage of 7.1L enriched material. That material was contained in 5-gallon pails mounted in a wooden frame which provided one foot surface to surface horizontal spacing.
The pails were arranged one-high.
Each pail was properly labeled with information as to enrichment, gross, tare, and net weight.
The interior of the trailer was posted with a current copy of the criticality safety specification.
That specification pro-vided for the one-foot minimum spacing of containers, observed.
It provided for a maximum loading of ten kilograms UO per container and restricted movement of the material to ten kilogra$s maximum at any one time.
Durin" this inspection the temporary storage of fissile material in truck trai'ers (mentioned in Section 2, above) was visited.
The seven trailers in use for that storage were spaced at ten foot intervals.
Four sides of each of the trailers exhibited appropriate posting regarding radioactive materials, fire zone classification, and the required separation of ten feet from other fissile material.
A view of the interior of one of the trailers indicated that containers of fissile naterial were spaced in metal grids at a minimum of one foot spacing surface to surface in the horizontal.
The appropriate criticality safety specification was posted in the interior of the trailers according to the licensee representative.
During this inspection a visit was made to the relocated Contaminated Material Storage building.
Containers of fissile material were spaced at one foot surface to surface spacing horizontally in metal grids.
Containers were identified as to gross, tare, and net weight of contents as well as enrichment.
The building was posted with the appropriate criticality safety specification and caution radioactive material signs.
All the above storage facilities were secured with locks at the time of this visit.
Access to the buildings was provided by the Material Account-ability Supervisor.
7.
Criticality Safety One of the planned changes in facilities mentioned in Section 2, above, is the construction of facilities and equipment to reduce the uranium content of low level liquid waste issuing from the conversion areas of the UO2 pl nt.
That process is planned to incorporate a 10,000 gallon
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feed tank, a centrifuge, ion exchange columns and various quarantin tanks in each of three clean-up lines.
Preliminary criticality analytical work has been done on that clean-up system.
The quarantine tanks will be typical of those presently installed in the UO. building and will be subcritical by geometry at SS enrichment.
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10,000 gallon feed tank and 20-inch dian.eter ion exchange columns will be controlled by concentration with consideration to the possibility of pre-cipitation in the large tank and maximum possible loading of the ion exhange columns.
Input into the large feed tank will be at an administratively controlled concentration limit.
Typical input concentrations will be about 0.2 grams per liter uranium as uranyl nitrate.
The large tank will be provided with sparge or stirring system, a conical base, and viewing ports.
a Using the guide lines and data presented in ARH6CO, Volume 1, Page IC-8; Table III.B.2-7; Table III.B.6-3; and Table III.B.6-6, certain tentative parameters have been established.
The safe limiting solution concentra-tion at SS enrichment is taken as 142 grams uranium per liter at a K effective = 0.95.
The total subtritical mass of Si enriched uraniuo at uranyl nitrate is teken as 57 kilograms uranium at a K effective of 0.95.
The total permissible subcritcal mass of 55 enriched uranium as a U02 wat r mixture is taken as 27 kilogram uranium at a K effective of 0.95.
The licensee has conducted and will continue to conduct experiments to determine the maximum loading of the ion exchange column resins.
Data obtained to date indicate the maximun loading is less than 27 kilo-grams uranium. The final analysis is planned for submittal to the NRC for review.
8.
Radiation Protection This inspection included a review of air sample data acquired in the UO2 building and compiled in monthly reports for months of February through May, 1979.
Over that period of time typical sampling included about 3,000 air samples per nonth. Of those, betweea 3 and 55 of the total were in excess of the 10 CFR 20 limit of 1 x 10 '0 uCi/cc.
Abouf060% of the total indicated positive results in the range of 0.1 - 1 x 10 uCi/g.
The uCi/cc.
remaining approxinate 37% of the samples were less than 1 x 10 A similar review over the same period of time was made of the air sample data by referring to individual air samp'e results and by referring to correspc, ding, narrative reports in the health physics technician log book.
Those two sources.lere consistent in identifying occasions when respiratory protective equipment was used. The use of respiratory protective equipment was indicated in bothsources of information when air sample results were in excess of 5 x 10-uCi/cc (the licensee's action level).
The use of that equipment was indicated in the air sanple result records on several c.
m.4 v u u4 m-occasions when the air borne concentraticn was less than 5 x 10~II uCi/cc. A licensee representative explained that the use of respirators was required for certain operations as a precautionary measure and not always as a result of elevated airborne concentrations.
This inspection included a review of uranalysis bioassay data for the period February through May,1979.
The analysis is performed by an independent laboratory.
The limit of detection of the analysis is 10 ug/1.
Approximately 100 bicassay samples of the type are obtained for employees each month.
The review of bioassay results for a four month interval indicated that approximately 25% of the samples showed positive results laying between 10 micrograms per liter and 25 micrograms per liter.
The licensee's action level for resamples is 25 micrograms per liter for insoluble material and 50 micrograms per liter for soluable material.
Of the approxinate 400 samples reviewed during this inspection, two were in excess of 50 micrograms per liter.
One of those samples indicated 135 micrograms per liter on January 24, 1979 and the same individual indicated less than 10 microgra ;s per liter on repeat analysis dated January 30, 1979. A second individual result indicated a 58.9 micrograms per liter on March 22, 1979 and subsequently indicated less that 10 micrograms per liter on April 6,1979.
The bioassay uranalysis review included results for one individual dated from the hire date in late 1977 through April,1979.
The review indicated a total of 13 analyses performed over 16 months.
All results were less than the limit of detection with the exception of one which indicated 27 micrograms per liter.
9.
Waste Uraniuu Recoverv The licensee's plans for the construction of a waste uranium recovery building has been discussed above in this report.
A number of uranium recovery processes will be incorporated.
Solid waste to be handled in-cludes gloves, papers, rags, prefilters, HEPA filters, glass, small metal parts, etc.
It is also anticipated that solid waste from the chemical waste lagoons will be processed for uranium recovery.
The head end of the recovery system will consist of physically sorting the waste naterial into three categories:
nonleachable wastes which are planned for burial, highly uranium contaminated items such as filters which will be campaigned through a shredder; and general refuse which will be processed through a shredder on a continuous basis.
Loose uranium dioxide material will be physically separated during the shredding process, collected in 5-gallon buckets and eventually processed through a uranium scrap recovery facili'.y.
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The shredded waste 'aill be segregated into high and low uranium content waste fractions.
The high uraniur., content shredded waste will be leached, the uranium recovered, and eventually processed in the uranium scrap re-covery facility.
Solids remaining af ter leaching will be transported to burial.
Using a combination leaching, solvent extraction, precipitation and ion exchange, uranium will be recovered from the chemical lagoon waste.
Solid chemical waste from the process will be sent to burial.
Liquid chemical waste depleted in uranium will be discharged to the lagoon system.
- 10. Transportation Progran The licensee's transport pr ; ram and procedures is contained in Document XN281, fla terials Ir.struction fianual. Itanagement approval of the procedures include t ;se of the Managers, Materials and Purchasing, Manufacturing, Quality n,surance, and Quality Control.
The uanual includes a number of procedures which, in general, are addressed to the handling of materals and many of which are addressed to the receipt and shipment of radioactive materials.
Following are a number of observa-tions made during a review of nterials instuction manual.
Procedure t;o. 6 entitled " Receipt of UF6" requires a survey cf the incoming shipment and inspection cf the shipoent for damage.
References are made in the procedure to the criticality safety specification addressed to the handl-ing of gas cylinders.
The procedure requires an inspection of the cylinder and its appurtenances prior to reshipment.
The required forms for recording survey and inspection information are illustrated.
Procedure fio. 9 is entilted " Receipt of Plutonium Dioxide" and illustrates a typical progressive survey as successive containers of plutonium are opened.
Procedure tio.10 is a comprehensive procedure addressed to the shipment of Exxon fuel assenblies.
It addresses contamiriation and radiation levels; inspection of containers prior to loading; details of container preparation, inspection, and refurbishing; loading procedures; off loading and unpack-aging; labeling; and records of package inspection and loading.
The pro-cedure also addresses the instructions to be given to the carrier and to escorts.
It includes tie-down requirements and hand-to-hano transfer records.
Procedure tio.10 entitled " Procedure for Unloading Model tio. 51032-1" is a detailed unloading procedure for the Exxon shipping container.
Similarly, Procedure fios, lla and 11 b are addressed to the unloading of liodels RA-3 Shipping Container and Model M-51032-la, a modification of the Exxon shipping container.
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. Procedure No.12 discussed the hazards and radiation levels associated with the shipment of nixed oxide waste.
Additional procedures are addressed to the shipnent of samples and pellets for analysis to Battelle Northwest Laboratories; the receipt of uranium in forms other than UF6; and the shipment of UF6 cylinders to the Department of Energy.
Procedure No. 22 addresses details of the receipt of empty fuel cont'iners including required surveys, decontamination, opening of containers, inspec-tion for damage, records of inspection results and repair.
Procedure No. 30 addresses the shipment of uranium waste to burial sites indicating the container types, container maximum loading, surveys required, labels required and burial site license limitations.
Records maintained by the licensee with regard to each shipment include an inspection report by personnel of F.aterials and Purchasing.
That report addresses visual inspection of the Model 51032-1 shipping container packag-ing shell, exterior stencils, exterior closure rings, bolts, washers, etc.,
strongback assembly, shock mounts, and fuel assembly clamps and retainer bars. Manufacturing operations personnel assemble and load the shipping container with quality control personnel present. Quality Control personnel perform an inspection at the time of loading which is also recorded.
That QC inspection is also in the form of a check off list and includes inspec-tion of the shipping container and its parts, location of internal and external excellerometers, ard assurance that the containers are properly closed.
The licensee routinely witnesses and inspects the unloading of fuel assembly shipping containers and records the condition of security seals, notes any external damage, observes the interior and exterior excellerometers, notes internal damage, and notes fuel assembly damage, if any.
For each fuel shipment a separate folder containing the records mentioned above and others is maintained by the licensee.
That folder contains a completed shipment receipt; export license, if any; fuel assembly packaging inspection report (preshipment); fuel assembly packaging inspection report (completed shipment); shipping record sheet; address label, radioactive shipment certification; instructions to drivers and escorts; bill of lading; QA signature sheet, and AEC 741 Form.
The licensee's Quality Assurance Program for packaging radioactive materials has been submitted to the NRC for review pursuant to 10 CFR 71.51. The identification of that document is XN-NF-439.
The overall responsibility assignments for the shipping and receiving of radioactive material is given in that document.
Additional procedures in the area of transportation are found in the licensee's radiological safety manual, Document XN-67.
In addition to the Exxon Model No. 51032-1, the licensee uses the RA-3 and CE-250 for the shipment of fuel material.
During this inspection, it was c
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. noted that all reference material in Certificate of Compliance 4986 was available at the UD, plant.
The required backup for Certificate of Compliance 9022 for"the Model CE-250 was available at the R and T Center of the licensee.
Tne licensee possesses 56 Model RA-3 shipping containers for fuel assemblies.
Records maintained by the licensee indicated that they were fabricated by Lanzen, Roseville, Michigan.
That company provided Exxon with a written certification that the RA-3 containers were manufactured according to the GE drawings listed in Certificate of Compliance No. 4986, Rev. 3, dated November 12, 1976.
11.
Management Interview The scope and results of the inspection were discussed with licensee representatives at the conclusion of the inspection on June 15, 1979.
Those persons were informed that no items of noncompliance were observed.
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