ML19257D171
| ML19257D171 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 10/01/1979 |
| From: | Book H, Cooley W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19257D169 | List: |
| References | |
| 70-0025-79-06, 70-25-79-6, NUDOCS 8002010478 | |
| Download: ML19257D171 (9) | |
Text
U. S. NUCLFAR REGUIATORY COMMISSION OFFICE OF INSPECTION At:D ENFO?. CEMENT REGION V 70-25/79-06 Report No.
I Stim-21 safeguards Group 70-25 License go, Docket No.
Energy Systems Group Licensee:
Rockwell Internat'onal Corporation Canoga Park, California 91304 Headquarters Site and fluclear Development Field Laboratory Facility Nan e:
Headquarters Site Inspect ion at :
August 21-24, 1979 Inspection conducted:
)b,f'9.[h b
//[/77 Inspectors:
'Ddte ' igned d
W. J. Coole[, Fielgf acilities Inspector Date Signed Date Signed
/U[/)')9 A pro"ed By :
O~b 5
' Da't e S igned P
H. E. Book, Chief, Fuel Facility and flaterials Safety Branch Summary:
Inspection on August 21-24,1979 (Report flo. 70-25/79-06)
Areas Inspected:
10 CFR 21 evaluations; facility changes and modifications; internal review and audit; safety committee activities; employee training; maintenance; operations review; criticality safety; radiation protection; and radioactive waste management. The inspection involved 26 inspector-hours onsite by one NRC inspector.
Resul ts_:
fio apparent items of nonco.;pliance or deviations were identified within the subject areas inspected.
RV Forn-719(7) 1855 043 souu olo 97F
DETAILS 1.
Persons Contacted
- M. E. Remley, Manager, Health, Safety and Radiation Services Department
- R. J. Tuttle, Manager, Radiation and fluclear Safety J. D. Moore, Engineer, Radiation and fluclear Safety R. J. McDermott, Director, Quality Assurance W. E. flagle, Manager, Quality Assurance, CRBR D. C. Empey, Manager, Quality Assurance Engineering C. A. Parker, Manager, Training Department R. M. Michlich, Training Specialist E. J. Walsh, fluclear Material Accountant
- Denotes those attending the exit interview.
2.
flotification of Failure to Comply or Existence of a Defect (10 CFR 21)
The licensee's program addressed to the requirements of 10 CFR 21 has been described in Section 8 of ilRC Inspection Report tio. 70-25/78-02 dated April 18, 1978.
Since the inception of the licensee's program a number of discrepanc!es have been observed by the licensee's Quality Assurance Department and evaluated according to existing procedures. Those discrepancies included two cases of materials properties; a required valve redesign; two cases of nameplate discrepancies; and one case of questionable workmanship (variation in finish specification).
In each of the above cases the matter was closed as nonreportable with respect to 10 CFR 21 after eval-uation and correction as required.
On July 20, 1979 a qualification weld sample failed during distructive testing.
Investigation by the Quality Assurance Department revealed that two different types of weld material were present in the qualification sample. Further investigation revealed that 1% of 971 spools of weld wire were plain carbon steel as compared to high chromium-molybdenum weld wire which had been ordered by the licensee.
That matter has been reported to the fiRC, I&E, Region IV for in-formation by the licensee.
3.
Facility Changes and Modifications The licensee has done some preliminary planning on the construction of a low enrichment powder-compact preparation facility and fuel element assembly area. At the time of this inspection, work on that project within the Health, Safety and Radiation Services Department had been suspended.
Ito other facility changes or modi-fications had been made beyond those reported in the last inspection report.
1855 044 4.
Internal Review and Audit The licensee's internal audit program was rev:ewed as a part of the inspection. That review covered the perio from the last to the present inspection. The review indicated that monthly inspections for criticality safety had been made and reported by the Cri ticality Control Advisor. Weekly inspections and reports had been made by the Criticality Coordinator.
Quarterly reviews and reports had been made by the Criticality Control Advisor.
Radiation safety reviews of operations had been made at a quarterly frequency by a representative of Health, Safety and Radiation Services assisted by Certified Health Physicist on loan from another department of Energy Systems Group.
The Criticality Control Advisor's audit for the second quarter, 1979 was addressed to several functions of the Health, Safety and Radiation Services Department.
Those functions included the periodic inspections by the Criticality Control Advisor; periodic inspections by the Criticality Coordinator; control of special nuclear material transfers; a review for completion of recommended action items on previous quarterly reviews; a review of the maximum SNM inventory per area comoared to the established limit of SNM for that area.
The report included a review of previous recommendations including recementing gaskets on drawers in the main vault to maintain mod-eration control; the closing of an unused exhaust duct in the powder preparation area; and anchoring the south wall storage rack in the main vault. The report noted appropriate action has been taken on those previous recommendations.
Additionally, the Health, Safety and Radiation Services Department had made a summary of health physics type measurements for the year 1975.
Similar summaries are planned for subsequent years in an effort to observe trends. The 1975 summary included whole body doses of radiation to employees; radioactive material releases in the form of gaseous and liquid wastes; in-plant airborne activity measurements; environmental radioactivity measurements; employee bioassay results; and employee lung count results.
5.
Safety Committee Activities On May 18, 1979 the Fuels Committee of the Nuclear Safeguards Review Panel met to make a review and recommendations for clarifi-cations in the Nuclear Safety Analysis and Criticality Study which had been prepared for the decladding of Fermi reactor fuel.
The Fuels Committee met again on June 5,1979 for its final review of the Nuclear Safety Analysis for the Fermi decladding checkout and granted its approval of that work.
6.
Employee Training Employee training requests originate with operations supervision and require approval at operations management level.
The approved 1855 045 written request for employee training is then transferred to the Training Department where the Training Specialist arranges the scheduling and administration of training and examinations.
Control documents showing the request for training, its approval, and its accomplishment are maintained by the Security Represent-ative.
Employee personnel records include the individual training courses that each employee has completed.
Those records are also available on computer printout along with a computer tab signaling any required retraining.
Training in the areas of radiological and criticality safety and security are available on videotape. The licensee has just com-pleted an additional training tape covering the Department of Transportation regulations and has given that course to aporox-imately 62 employees.
This inspection included a brief review of the control documents for the training of seven individuals.
The purpose of that review was to determine the length of time between the application for training and its accomplishment.
Three of the control documents were for maintenance personnel and indicated a range of ten to twenty days delay between request and accomplishment of training.
Four of the control documents were for Fuel Fabrication Facility employees and the range of time delay was from one to four days from request to training.
Employee representatives explained that maintenance employees may be placed on non-hazardous work assign-ments whereas Fuel Fabrication Facility employees require early training for placement in radiation control t reas.
7.
Maintenance The Health, Safety and Radiation Services Department requested a compilation (checklist) of various preventive maintenance routines performed on ventilation, filtration, fire detection and suppres-sion, and radiation alarm systems.
The request was made for the Radioactive Materials Disposal Facility at Santa Susanna (DOE); the fluclear Material Development Facility Santa Susanna Building 55 flRC ; the Rockwell International Hot Lab Santa Susanna Building 20 NRC, the Fuel Fabrication Facility DeSoto Avenue Building 1 NRC, Hot Analytical Chemistry Laboratory DeSoto Avenue Building 4 ilRC and State of Calif ornia); Gamma Irradiation Facility DeSoto Avenue (State of California); Santa Susanna SNM vault Santa Susanna Building 64 (DOE); and the DeSoto SNM vault (NRC). A purpose of the request was to establish the basis for periodic audits of preventive maintenance functions by a committee of the Nuclear Safeguards Review panel.
Replys with checkoff lists of varied complexity were received from Industrial Security (fire protective equipment); the Nuclear Material Development Facility; the Rockwell International Hot Laboratory; and the Radioactive Material Disposal Facility.
Correspondence on the subject reviewed during this inspection indicated that preventive 1855 046
-4 maintenance procedures and checks were in effect at several locations.
The correspondence does not indicate any further action by Health, Safety and Radiation Services in develo? ng the audit.
i 8.
Operations Review The inspection included visits to the high enrichment powder-compact preparation line; the DeSoto Avenue St'M vault; the Fuel Fabrication Facility assembly areas and the area proposed for the low enrichment powder-compact preparation line.
It was observed that areas and work stations were properly posted with respect to the presence of radioactive materials and radiation areas.
Work stations were also posted with criticality mass limitations.
The DeSoto Avenue vault, fuel fabrication areas, and high enriched powder preparation room appeared in very good condition showing excellent housekeeping.
9.
Criticality Safety In [1RC Inspection Report 70-25/79-03, Section 5 Criticality Safety, last paragraph, the following correction is made.
In the last paragraph this statement is made "An isolated array of 6L and 6M shipping containers was located centrally between the north and south arrays in the vault." The discription of the shipping con-tainers and their contents in the last paragraph of Section 5.is correct. However the licensee had not regarded the centrally located array as an " isolated" array.
Rather the licensee had evaluated the criticality index for 6L and 6M containers using the density analog method of calculation and had arrived at a permissible number of shipping containers regarded as a portion of the entire vault array. The model DT-14 shipping container was included in the analysis. The criticality index was calculated as the transport index for each container divided by 50.
An analysis was made by the licensee regarding the receipt of quantities of uraniun-235 and their subdivision into production batch sizes after receipt.
Highly enriched uranium is received in lots of approximately 18 kilograms in the model DT-14 shipping container. That quantity of material is contained in a sealed metal can and is in the form of small chunks of metal randomly loaded in e can. That quantity of uranium fills the inner sealed can of the onipping container to approximately two-thirds of its volume.
For that reason double batching in open cans is not possible.
The average fuel density in the inner can is 0.33 fraction of the full metal density.
From fluclear Safety Guide TID-7016, Revision 2, the factor for increasing subcritical mass limits for a.33 fraction of theoretical density is 4.5.
The single-parameter limit for a reflected metal sphere of uranium-235 is 20.1 kilograms as given in the same reference. A sealed primary can with 18 kilograms of uranium-235 may, therefore, be brought into the facility consistent with Stim-21 license criteria of spherical geometry, no moderation, and full reflection.
1855 u47 In routine operations the licensee subdivides the 18 kilogram charge into approximately 6.5 kilogram production batches contained in a 5-inch diameter can of 1.83 liter volume.
That unit is sub-critical when noderated and reflected by virtue of the i9..e l imi ta tion. Three cans of that discription each loaded with approx-imately 6.5 kilograms of uranium-235 spaced at 12 inches are subcritical sealed and subcritical with one of the three cans flooded.
The licensee's procedures for subdivision, therefore, provide for one unsealed can of three spaced at 12 inches and loaded to less than 6.5 kflograms uraniun-235.
The Nuclear Safety Analysis and Criticality Study for the Fermi fuel decladding checkout had been completed by the licensee and was reviewed as part of this inspection.
The Fermi fuel decladding checkout is a study of one Fermi fuel assembly to determine how to remove the zirconium cladding and any zirconium-uranium eutectic which might exist at the surface of the fuel.
Various approaches are being used including hydride enbrittlement of the zirconium cladding and centerless grinding.
The Criticality Study made various assumptions and imposed certain controls.
Centerless grinding sludge must be checked out of the grinder sump for each throughput of approximately 336 grams uranium-235.
Full reflection and spherical geometry was assumed in deter-mining mass limits. Modera.or exclusion must be orovided for mass limits greater than approximately 336 grams uranium-235.
I t was determined that hydriding would cause less than an H/ uranium-235 ratio of 3.
The effort covered by the Nuclear Safety Analysis was for one Fermi assembly. That assembly is composed of 140 pins.
The assembly uranium-235 content is less than 4.7 kilograms and approximately 22 grams plutonium-239. A single pin has a uranium-235 content of about 35 grams and a pluttnium content of approximately 0.16 grams.
The mass limitation on all operations of the storage was limited to 10 pins (336 grams uranium-235 and 1.6 grams plutonium-239).
Storage considerations included one assembly or 140 pins (4.7 kilograms uranium-235 and 22 grams plutonium-239). Storage of 120 pins (4.03 kilograms uranium-235 and 20 grams plutonium-239) was provided in Hot Cell 2 and Hot Cell 3.
No other use of fissile material in the Hot Cell Complex was permitted during the Fermi fuel decladding checkout. All transfers of pins were to be made in geometrically safe diameter cans (4-inch diameter). The fissile enrichment is 25%. The uranium-235 density in the fuel is 4.1 g/cc.
10.
P;adiation Protection On June 27, 1979, Region V received a telephone call from Dr. M.E. Remley of the subject licensee organization.
Dr. Remley reported for information purposes only an incident which had occurred in Building 55 at the licensee's Santa Susanna site.
He stated that a team was 1856 048 replacing a furnace heater at a plutonium glove box in Building 55 on June 26. As the heater coils were pulled out, contaninated material came out with it.
He said that some airborne contamination and surface contamination in the vicinity of the box occurred.
Eberline f'odel Alpha 3 - Air Monitor located approximately three feet from the operation alarmed at a setting of 45 MCP-hours.
One individual making the furnace heater change was in the irrmediate vicinity and was wearing a full face mask.
Two additional men were located approximately eMht-to-ten feet from the operation.
Indications by the constaat air monitor and a recount of the air samples are that the potential exposure was 45 MPC-hours.
Taking the full face mask credit of X50, the operator handling the furnace heater probably received an exposure of 1 MCP-hours according to Dr. Remley.
Dr. Remley stated that the other two individuals located approximately eight-to-ten feet away were estimated to have received three-to-four MCP-hours exposure because they were not wearing respiratory protection.
Urinalysis sarrples were obtained on five individuals who occupied the Building 55 Laboratory at the time of this incident.
One fecal sample had been obtained.
Surveys of the area indicated a range of 18 to 75 dpa/100 square centimeters surface contamination in the vicinity of the incident.
During the presently reported inspection a review of bioassay records was made. That review indicated that six urinalyses and one fecal analysis had been performed on personnel occupying Building 55 during the above described incident.
Records indicated the results of those analyses were less than the detectable deposition of plutonium. The matter is considered closed.
Further review of the licensee's bioassay program results for the period 1979 to August 20, 1979 indicated eight positive results of a total of 93 analyses by the uranium fluorometric method.
The maximum indication was 2.4 ug/1500 cc where the limit of detection is 0.3 ug/1500 cc. That analysis was repeated and the results indicated less than detectable excreted activity. There were no positive results in 80 urinalyses performed by the uranium radio-metric analysis. Or.e positive piutonium analysis in 24 analyses indicated 0.08 dpm/ day where the limit of detection is 0.05 dpm/ day.
Upon repeet analysis the plutonium excretion rate was less than detectable.
In vivo lung counts were performed on 16 individuals during the period of the review. One positive result in that group indicated 55 ug + 39 ug as compared to the maximum permissible lung burden of 200 ug There were no positive results in three fecal samples analyzed for plutonium during the review period.
1855 049 The licensee's D0P testing equipment was not available from approx-imately February,1979 to the end of July,1979 because of equipment failure.
An absolute filter change had been made in exhaust system EF-15 (high-enriched powder preparation system) in February,1979.
Tha licensee corrected the situation by having the defective equip-ment repaired and acquiring a second set of DOP testing equipment.
One set of equipment is located at the DeSoto Laboratory and the other at the Santa Susanna facility providing mutual backup.
Exhaust concentrations between February and through July,1979 were below permissible levels although the filter seating in EF-15 had not been tested.
In August of 1979 when the new DOP testing equipment became available that system was tested and found to be 98.7%
efficient.
The absolute filters were again replaced at that time, retested and indicated an efficiency greater than 99.9%.
The maximum stack exhaust concentration for EF-15 during the period of theguestionable seating of the EF-15 absolute filters was 2.8 X 10-uCi/cc which is a factor of at least 10 beneath the permissible concentrations in unrestricted areas.
The calculated dilution factor from the EF-15 exhaust to the nearest boundary at DeSoto Avenue is approximately 1500.
Beginning in January,1980 the licensee will exchange persoanel dosimeters at a quarterly exchange frequency as compared to the present monthly exchange frequency.
Special provisions will be made for individuals who may have access to possible exposures of 100 to 300 millirem. Those provisions require the wearing of a visitor's personnel dosimeter to be processed each week and worn along with the standard quarterly exchange dosimeter plus a pocket, self-reading dosimeter for daily use.
During this inspection the substance of IE Circular Nos. 79-09 and 79-15 were discussed with licensee representatives.
It was determined that the licensee does not possess the Scott Air Pak or Surviv Air models of self-contained breathing apparatus listed in those two circulars.
During this npection the substance of IE Bulletin 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial, was discussed with licensee representatives. With regard to the action to be taken by licensees listed in that bulletin a plan of action had already been put into effect.
The licensee saw no difficulty in meeting the required actions and reporting within the alloted 45 days.
IE Bulletin flo. 79-19 Items flos. I through 7 have been in effect for a number of years although Items 5 through 7 may require some review. The information required in Item 9 is readily available to Health, Safety and Radiation Services personnel from transportation records currently maintained there.
1856 050 11.
Radioactive Waste Management In compliance with Condition 42 of License SNM-21 the licensee monitored retention pond water at Santa Susanna and sewage outflow at the DeSoto Avenue facility for tritium from approximately flovember, 1977 through January, 1979.
tio discharges above the limit of detection for the tritium analysis (25 dpm/ml) were detected over that period of time.
By letter dated March 22,1979 the licensee informed the i:RC Fuel Processing and Fabrication Branch of those t esults and discontinued tritium sampling as provided in Condition 42.
fio discharges of radioactive rriterial subject to the rules and regulations of flRC are made f' om Building 55 at the Santa Susanna facility of the licensee.
Ik discharges of radioactive materials are made from Building 20 at the Santa Susanna facility in that waste generated at that building is solidified and transferred to licensed land burial sites.
Discharges of microgram quantities per year are made from the Fuel Fabrication Facility located in Building I at DeSoto Avenue.
Those discharges are made to the sanitary sewer after retention and sampling in tanks located at that facility.
Airborne effluents are monitored for alpha and beta gamma activity at all discharge points at both the DeSoto Avenue and Santa Susanna facilities. Those results along with the sanitary sewer discharges from Building i at DeSoto Avenue are reported semiannually to the fiRC and have been found to be in compliance with f;RC rules and regulations.
- 12. Management Interview The scope and results of the inspection were discussed with licensee representatives at the conclusion of the inspection on August 24, 1979.
Those persons were informed that no items of noncompliance or deficiencies were observed within the scope of the inspection.
1855 051