ML19256G447
| ML19256G447 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 10/04/1979 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256G434 | List: |
| References | |
| 70-0820-79-16, 70-820-79-16, NUDOCS 7912310320 | |
| Download: ML19256G447 (13) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-820/79-16 Docket No.70-820 License No.
SNM-777 Priority 1
Category UR Licensee:
United Nuclear Corooration UNC Recovery Systems Wood River Junction, Rhode Island 02894 Facility Name:
Fuel Recovery Operation Inspection at:
Wood River Junction, Rhode Island Inspection conducted: Augus t
-31, 1979 Inspectors:
/
/0
/
f s
W. 'W.Kinne[ Projerd Inspector da'te signed date signed date signed Approved by-jog 7c)
H. W. CrockEChief, Fuel Facility
' tfate signed Project Section, FF&MS Branch Inspection Summary:
Insoection on August 27-31,1979 (Report No. 70-820/79-16 Areas Inspected:
Routine, unannounced inspection by a region-based inspector of licensee action on previous inspection findings; packaging of material for transport; operations; nuclear criticality safety; internal reviews and audits; facility changes and modifications; training; and maintenance.
The inspection involved 29 inspector-hours onsite by one NRC region-based inspector.
Resul ts:
Of the eight areas inspected, no items of noncompliance or deviations were identified in six areas.
Two apparent items of noncompliance were identified in packaging of material for transport and one apparent item was identified in nuclear criticality safety (infraction - Failure to have procedures which specifically address the proper closure of shipping ccqtainers, esper.ially the inner container - Paragraph 3b; deficiency - failure to maintain records which showed that the inner containers of shipping containers were closed properly - Paragraph 3b; deficiency - borosilicate glass raschig rings in tank 1-D-24A did not have boron content between 11.2 and 13.8 w/o B2 03 - Paragraph SC).
1664 183 Region I Form 12 (Rev. April 77) 10 79123 32O
DETAILS 1.
Persons Contacted
- C. E. Bowers, General Manager
- K. A. Helgeson, Nuclear and Industrial Safety 'ianager J. E. Dunning, Operations Manager
- D. M. Schultz, Compliance Manager The inspector also interviewed two quality assurance engineers, a production supervisor, two operators, and a health physics technician during the course of the inspection.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Infraction (70-820/79-01-01):
This item of noncompliance involved two instances of licensee personnel failure to follow posted criticality safety limits.
The inspector verified by reviewing appropriate documents that the licensee took disciplinary action with the individuals involved with the failures to follow posted criticality safety limits.
Records of safety meetings with operating personnel showed that compliance with posted criticality safety limits was a subject covered in a safety meeting held immediately after the occurrence of this item of noncompliance.
(Closed) Infraction (70-820/79-01-02):
This item of noncompliance involved three instances of licensee personnel failure to follow contamination control procedures.
The inspector verified by review of shift meeting minutes that the licensee re-instructed operators on the rules applicable to smoking in the change room.
The change room is still a designated smoking area, since the licensee has found personnel to be following the contamination control rules.
The licensee has also re-instructed members of the contract guard force on the requirements and proper procedures for personal monitoring, when a person exits from a potentially contaminated aren.
(Closed) Deficiency (70-820/79-01-03):
Three sample bottles containing uranium were stored in the foreman's office with no posting of the criti-cality safety limits allowing the presence of SNM in the foreman's office.
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3 The inspector verified that an authorization to store fissile material in a specific location in the foreman's office was given by Nuclear and Industrial Safety.
However, the use of the specific storage location was not initiated by operations.
Therefore, storage of SNM in the foreman's office is presently prohibited.
3.
Packaging of Material for Transport The licensee packages their U 08 product for shipment in DOT-6M, Certifi-2 cate of Compliance No. 5908, and UNC-1484, Certificate of Compliance No.
4949, shipping containers.
The license packages solid waste for shipment to burial in 17-H drums and plywood boxes.
a.
Transportation Program The inspector inspected the transportation program concerning the packaging of radioactive material for transport during this inspection.
The program for the receipt and monitoring of incoming packages of radioactive material was not inspected.
The licensee has an operating procedure entitled, " Procedure for Packaging Product Containers and Outgoing SNM Shipments", Number III-C, Revision I, effective April 6, 1976.
This procedure outlines the packaging of product in a broad manner.
The content of the procedure is addressed more specifically in paragraph 3.b. of this report. The licensee has a standard method entitled, " Packaging and Labeling of Radioactive Material for Shipment", S.M. No. 9.1, Revision I, approved September 29, 1976.
This method outlines the surveying of the packages for radioactive contamination and the labeling of inner containers and the labeling of packages for on-site storage.
This method does not address the labeling of the shipping containers delivered to a carrier for transport.
The licensee prepared and submitted in December 1978 a description of a quality assurance program for shipping packages to the Office of Nuclear Material Safety and Safeguards (NMSS) as required by 10 CFR 71.51(a).
The licensee has prepared a more comprehensive program at the request of NMSS and submitted this program description July 1979.
The licensee has not implemented a formal quality assurance program for shipping packages at this time.
The licensee's overall program for preparing packages of radioactive material for shipment currently is not formally documented.
The licensee indicates that implementation of the quality assurance program, along with changes in the operating procedures, will document the program more formally than has been the case here to fore.
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4 b.
Routine Use of Packages The licensee is registered to use the following shipping containers.
Model No.
Identification Certificate of Compliance UNC-1484 USA /4949/AF 4949 Rev. 1 UNC-1634 USA /5274/AF 5274 Rev. 2 00T-6M Type B USA /5908/B (
)F 5908 Rev. 5 BU-5 USA /6458/AF 6458 Rev. O BU-7 USA /9019/8 ( )F 9019 Rev. 2 As indicated previously, the licensee is currently using the UNC-1484 and 00T-6M shipping containers for packaging of U 0 for transport.
3 8 The inspector reviewed the licensee's procedure for the packaging of radioactive material for compliance with 10 CFR 71.54, Routine determinations.
Procedure III-C, " Procedure for Packaging Product Containers and Outgoing SNM Shipments" did not address the closure of the inner container.
Closure of the inner container of a shipping container in accordance with applicable drawings and/or specifications is of prime importance in achieving assurance that a package would contain the radioactive material under accident conditions.
For the UNC-1484 shipping container inner container to be closed in accordance with United Nuclear Corporation Drawing No. 66008-401, Rev. 1, an asbestos gasket must be used between the flanges of the inner container and lock washers must be used under the nuts fastening the blind flange in place.
For the DOT-6M shipping container, the inner 2R container must be closed in accordance with 49 CFR 178.34, Specification 2R; inside containment vessel.
This specification requires the following for a screw-type cap or plug closure.
The number of threads per inch must not be less than United States standard pipe threads and must have sufficent length of thread to engage at least 5 threads when securely tightened.
Pipe threads must be luted with an appropriate non-hardening compound which must be capable of withstanding up to 149 C.
(300 F) without loss of efficiency.
Tightening torque must be adequate to maintain leak tightness with the specific luting compound.
Failure of the procedures to specifically address the proper closure of shipping container, especially the inner container, is an item of noncompliance with 10 CFR 71.54(i).
(79-16-01)
The procedure for packaging product containers called for a shipping container inspection form to be filled out.
This form has the following items under Container Inspection.
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5 Container Free of Damage Gaskets Free of Damage Closure Free of Damage Container Properly Assembled and Closed Signature of Inspector The records of the packaging of material performed thus far during 1979 showed that the health physics technician was signing this form as the inspector of the container.
Discussion with the health physics technician disclosed that the health physics technician observed the outside of the closed 00T-6M and UNC-1484 containers.
Therefore, the health physics technician could ascertain that the outside of the containers were not significantly damaged and that the bolt rings were in place and properly tightened.
- However, observation of the outsides of the containers would not allow proper observation that the closure of the inner contairers was performed properly using required gaskets or luting.
Failure to maintain records which showed that the inner containers were closed properly in accordance with requirements is an item of noncompliance with 10 CFR 71.62(a)(10).
(79-16-02)
During the inspection, the licensee was not packaging any radioactive material for shipment.
Therefore, actual observation of the performance of pre-use inspection of the packaging; loading of the radioactive material; closure cf the container; and radiological surveys was not possible.
The inspector asked the licensee to open an empty D0T-6M container and an empty UNC 1484 container for inspection.
The 00T-6M container used a screw-type cap closure for the specification 2R inner container.
The luting material which appeared to have been left from the last use of the container was a white tape.
The empty UNC-1484 container opened had a flat black flexible gasket material in the inner container sealing system.
The licensee stated it was a graphite impregnated asbestos gasket material and that it qualified as an asbestos gasket for use in the UNC-1484 shipping container.
The asbestos gaskets the inspector was familiar with were usually gray in appearance and stiff rather than flexible.
The licensee was unable to supply documented information to the inspector concerning the qualities of the material which would verify its qualification as an asbestos gasket.
The suitability of the use of this gasket is questionable.
This situation points up the fact that if the licensee had a quality assurance program in effect for the shipping containers the licensee would have had documented information concerning the qualification of the gasket for the requirements of the UNC-1484 shipping container.
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6 The empty UNC-1484 inner container flange was fastened with nuts without lockwashers.
Discussion with the operators disclosed that the licensee uses lockwashers when closing the flange of a shipping container loaded with radioactive material.
The records for the packaging of material in the UNC-1484 and 00T-6M shipping containers during 1979 showed that the packages were surveyed for radioactive contamination and radiation levels as required.
The records also showed that the packages were labeled properly.
c.
Initial Use of Packages The packages being used by the licensee have been in service for some time.
d.
00T Requirements The inspector reviewed the circumstances concerning a " Radioactive Waste Shipment Discrepancy Report" which was sent to the NRC by the South Carolina Bureau of Radiological Health.
This report stated that a trailer received at the burial site in South Carolina from the UNC Wood River Junction, Rhode Island, site was contaminated.
DiscussionwithaSouthCarolinaofficialdisclosedthatghetrailer afterbeingunloadedattheburialsitehag35dpm/100cm smearable beta gamma contamination and 51 dpm/100 cm smearable alpha contam-ination.
dpm/100cm}healphacontaminationwasabovethereleaselimitof22 imposed on the burial ground operator by his state approved license application.
The federal regulations concerning the contamination control requirements for transportation vehicles is given in 49 CFR 173.397, Contamination Control.
Since the trans-ported material contained high enriched uranium and the involved vehiclewasusedasanexclusiveusevehiclefortransgortingthe waste, the limit given in 49 CFR 173.397 is 220 dpm/cm (22,000 2
dpm/100 cm ).
Therefore, the contamination level of the trailer was much below the federal requirenmnts and there was no noncompliance with federal regulations involved with this reported contaminated trailer.
Also, the licensee smeared the trailer before it left the WogdRiverJunctionsite,andthetrailerwasbelowthe100dpm/100 cm smearable alpha level the licensee uses as a release limit.
The inspector observed the loading of some drums of waste in a trailer for transport to the burial site.
The bottom of the trailer was covered with three layers of brown paper.
A filter cloth was nailed in place for the fork lift truck to run over while transporting the drums and boxes of waste into the trailer.
The drums had been surveyed for radioactive contamination.
It appeared that the licensee was taking appropriate actions to avoid contaminating the trailer.
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7 The drums of waste being loaded on the trailer appeared to be in good condition and all were sealed with tamper-safe seals.
4.
Operational Review An inspection of the facility was initiated after the entrance ir.terview.
Nuclear criticality safety postings were located at the processing and storage locations.
Housekeeping inside the main building was generally satisfactory; however, there were many empty lime bags on the mezzanine above the D-14A & D-14B tanks.
The licensee indicated that the accumulation of empty bags in this area was a continual problem.
The licensee is cleaning up the outside areas.
The inspector noted several severely rusted drums in the bull pen area.
According to the licensee, the material inside the drums is being repackaged and the rusted drums are being collapsed and put into boxes for burial.
The old incinerator building is in a state of disrepair.
The building roof has a hole in it.
The licensee has put in a pump and line for transfer of sludge and liquid from the lagoons into the D-14A tank in the main processing building. The sludge is allowed to settle.
Then it is drained into 55 gallon drums.
Cement is added to the drum to react with all the water in the drum.
The resulting solid waste is packaged and sent to burial.
The licensee initiated this processing of the residues in the existing lagoons by September 1, 1979, thereby meeting the requirements of license condition 26.
5.
Nuclear Criticality Safety Observations during Physical Inspection of Facilitig a.
During the inspection of the facility the inspector noted that the nuclear criticality alarms appeared to be functioning and all were set to alarm at 20 mR/hr.
The inspector also noted that the licensee had an uncovered gallon container in one of the positions in the residue storage rack behind solution waste tank 3-D-17, while the nuclear criticality safety posting called for covered containers only.
The licensee removed the container from the rack.
It was noted that storage racks appeared to be in an acceptable state of repair.
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8 b.
Evaluations The inspector reviewed the Nuclear and Industrial Safety Authorizations listed below:
Authorization No.
Subject RO 289 Drum Counting at Gamma Scan Location R0 290 Uranium Samples in Process Supervisor's Office R0 292 Met Mount Breakout R0 292, Rev. 1 Met Mount Breakout R0 293 Processing 200 Kgs. of 2% Enriched Material in Process Area R0 294 Belt Filter Press Test-Lagoon Recovery Equipment R0 295 Fabrication of Simulated Lagoon Sludge (uranium free)
All of the above authorizations had final NIS approval.
The nuclear safety evaluation included in these documents appeared to be in accord with license requirements.
c.
Raschig Ring Filled Vessels The inspector examined the records of the monthly raschig ring level checks for March through August 1979.
The licensee checked the ring levels in 13 vessels, the wet cut-off saw coolant tank, the milling machine coolant tank, and the pickle-liquor room floor sump.
The raschig rings were all above the control levels, according to the inspection reports.
In November 1978 the licensee sampled the rings in all the vessels in service except for the rings in exhaust gas scrubber 1-X-23, the wet cut-off saw coolant tank, the milling machine cooling tank, and the pickle-liquid room sump.
According to the licensee, the rings in these vessels were changed at the time of sampling and they do not sample the old used rings under this circumstance.
The analyses of the 8,3 0 content of the rings sampled in November 3
1978 showed that the two sample rings from the 1-D-24A filtrate tank had boron contents of 15.08 and 17.62. weight percent B 0 of the license states that, "Raschig rings sball.
Section 305.1.1.2 be Corning Glass 7740 type or equivalent containing nominal four (4) w/o natural boron with a range of 11.2 to 13.8 w/o B 0."
The following explan-ationscouldaccountfortheringsinth$10-24Atankhavinga 3
boron content of 17 weight percent rather than 12.8 weight percent.
The Corning Glass 7740 rings placed in the tank were chemically attacked and the silicates were leached from the rings leaving.
the boron in the rings at higher concentrations.
1664 190
9 The laboratory failed to analyze the boron content properly.
Corning Glass 7052 rings with a nominal B, 0, content of 17.8 weight percent were present in the tank ihst5ad of the Corning Glass 7740 rings with a nominal B 0 content of 12.8 weight 2 3 percent.
For the first explanation to be true the following would also be true:
For a ring to sustain an increase of 8, 0 content from 12.8 3
to 17 weight percent the ring would have to 18se 28 percent of its non-8, 0 constituents.
Such a corrosion situation would be physically 3
apparent.
Also, according to a Corning representative, rings used in a caustic system do not have the non-B 0 constituents leach Theringsdissolve,iftheyarechebic$11yattacked.Ringsin out.
an acid system may have some of the 8 0 leached out, thereby 7 3 reducing the B 0, weight percent. From tne above, it would appear 2
that the first explanation is not a plausible explanation.
The second explanation could be true.
However, the laboratory analyzed the two rings from each of ten other tanks and none of these samples had suspect B 0 contents.
2 3 The third explanation is plausible.
According to the laboratory results of sample taken from the 1-D-24A tank taken on November 22, 1978, the rings in the tank did not meet section 305.1.1.2 of the approved license application.
This is an item of noncompliance (79-16-03).
The licensee sampled the rings in the vessels in service except for the wet cut-off saw coolant tank, the milling machine coolant tank, and the pickle-liquor room sump on July 17, 1979.
The rings in the vessels which were not sampled were changed.
As stated before, the licensee does not sample and analyze the old used rings when they are replaced.
The results of the boron content analyses of the sampled rings were not available at the time of the inspection.
Four of the thirteen vessels were calibrated in June and July 1979.
In all cases the volume of the rings was greater than 22 of the volume of the tanks.
6.
Internal Reviews and Audits The inspector reviewed the records of the license required weekly audits performed by Nuclear and Industrial Safety during the period from January 2, through August 2, 1979.
For the thirteen week period from January 1 1664 191
10 through March 31, 1979, the licensee had 6 reports for weekly inspections.
According to the licensee, during this period the health physics specialist and the NIS manager were prcviding QA/NIS coverage on the third (12-8) shift; and this provided the added management attention to the observation of operations to assess compliance with nuclear criticality safety and radiological safety controls which was usually provided by these weekly audits.
Audits were also not performed during three weeks in June, when the plant was shut down.
Since May 11, 1979, the Manager of NIS has continued to perform the audits, however, most of the weekly audits also include audits performed by the nuclear criticality safety specialist for compliance with nuclear criticality safety controls.
According to the audit reports, increased emphasis on nuclear criticality safety has resulted.
Items requiring action were documented on " Request for Corrective Action" forms.
These forms showed that appropriate actions were taken on items requiring correction.
The inspector reviewed the monthly and quarterly reviews and appraisals of the weekly inspections for the weekly inspections performed during January through May 1979.
According to the licensee, the monthly reviews for the weekly inspections of June and July have been performed; and the reports are awaiting typing.
During June the general manager's staff performed an audit of housekeeping, electrical safety, and industrial safety.
This audit disclosed items requiring corrective actions.
According to the licensee, the corrective actions were taken.
The last licensee required annual audit was performed during December 1978.
Two technical specialists from the UNC Naval Products Division performed the audit in radiological safety and nuclear criticality safety.
The auditions had 30 recommendations on which the licensee took appropriate action.
7.
Facility Changes and Modifications The licensee has decided not to pursue the recovery of uranium from the lagoon residues as authorized by Amendment No. 4 to License No. SNM-777.
The licensee constructed a concrete pad and a concrete pit for the facility before terminating the activity.
The licensee is now considering other methods of processing the residues in the lagoons so they can comply with License Condition 26 which requires that they decontaminate the lagoons to release limits.
Use of filtration and drying of the residues for subsequent burial is being considered as the process to be used.
The licensee intends to submit a license application concerning the process they will be using to process the lagoon residues to the NRC in the near future.
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11 8.
Training The inspector reviewed other licensees records on training of new employees and also briefly attended a training session for new contract guards.
The licensee covers fundameatals of radiation protection and contamination control; fundamentals of nuclear criticality safety and controls; emergency alarms and actions to be taken during emergencies; and industrial safety.
The licensee gives a 50 question quiz at the end of the training to assess the knowledge of the trainees in the areas covered in the training sessions.
The records also showed that training was given to three women employees on prenatal radiation exposure.
The licensee had records which showed that all the employees attended an annual retraining session.
The retraining was given by NIS from the middle of July 1979 through the first week of August 1979.
According to the licensee, each session was about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> long.
Radiological health, criticality safety, and industrial safety were covered in the the session.
The inspector inspected the records of the safety meetings held by super-visors with their employees.
Meetings were held in January, February, April, May, June, and July 1979.
Topics included housekeeping, contamination control, the bioassay program, radiation safety and industrial safety items.
The items requiring attention brought up by employees appeared to be mainly of an industrial safety nature.
9.
Maintenance The Maintenance Supervisor reports to the Operations Manager.
The main-tenance group has an electrician, an electronics specialist, and a mechanic.
The supervisor also performs some of the maintenance work.
The licensee uses a Safety Work Permit system to assure safety during the performance of any nonroutine jobs, which is discussed below.
The requestor describes the work to be performed on the Safety Work Permit form.
The person or group to perform the work is assigned.
The primary hazard expected is listed.
The requestor signs the Safety Work Permit form.
Nuclear and Industrial Safety performs a review of the work to be performed.
Special instructions are issued if required.
If health physics monitoring during the performance of the job, this fact is stated on the permit.
The safety equipment required for performing the work is specified.
The form lists the following equipment that may be checked as being required:
1664 193
12 rubber gloves, welding gloves, supplied air mask, hard hat, goggles, welding goggles, face shield, respirator, apron, and other.
The NIS Manager sir,qs and dates the Safety Work Permit, when he gives his approval to start work.
The Safety Work Permit includes a section for the " user".
This section includes a Precautions Check List which must be completed either as being performed as indicated by a check or as N/A, when the item is not applicable.
The check list includes the following under CHEMICAL:
Equipment Drained; Valves closed and/or tagged; splash shield at point where work is performed.
The checklist includes the following under ELECTRICAL:
Breaker disconnected; fuses pulled; switch tagged out.
The checklist includes the following under WELDING / CUTTING: Area checked for combustibles; area checked for hazards; combustibles removed or covered.
The c;.acklist includes the following under GENERAL:
Familiar with hazards; approved staging; adequate protective equipment (fire extinguisher, safety shower, etc.).
The checklist has a space for other items which were checked by the user.
The Safety Work Permit form has a section showing that the work was completed with a place for signature and date.
According to the licensee, the maintenance group does not have any specific written procedures for performing their maintenance duties.
10.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph
- 1) at the conclusion of the inspection on August 30, 1979.
The inspector presented the scope and findings of the inspection.
During the interview the inspector presented three items as items of noncompliance:
(1)
Failure to have written procedure which specifically address the closure of the inner containers of the shipping containers containing product for transport.
(2) Failure to maintain records which showed that the inner containers of the product shipping containers were closed in accordance with packaging requirements.
And (3) Failure to perform 7 of the weekly audits during the 13 weeks from January 1, 1979, through March 31, 1979.
(Paragraphs 3.b and 6).
During and after the interview, the licensee presented information which showed that NIS management was actually providing NIS coverage on the third.(12-8). shift during that period of time.
This coverage provided the management attention to operating conditions usually achieved by the weekly audits. The third items was not considered to be an item of noncom-pliance under these circumstances. (Paragraph 6).
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13 The inspector called the licensee on Sectember 14, 1979, and informed them of another item of noncompliance.
The glass raschig rings in the I-D-24A filtrate tank had boron contents outside the license specified boron content for the rings.
The rings sampled on November 22, 1978, had boron contents of 15.08 and 17.62 weight percent B 0 the bcrosilicate glass raschig r$ng$.
According to section 205.1.1.2 shall be Corning Glass 7740 type or equivalent containing nominal four (4) weight percent natural boron with a range of 11.2 to 13.8 weight percent B 0.
(Para-2 3 graph SC).
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