ML19263B505

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IE Insp Rept 70-33/78-15 on 781024-26.Noncompliance Noted: Failure to Post Max Safety Quantity Signs & Failure to Define Posted Signs as Required
ML19263B505
Person / Time
Site: 07000033
Issue date: 12/01/1978
From: Crocker H, Roth J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19263B494 List:
References
70-0033-78-15, 70-33-78-15, NUDOCS 7901180326
Download: ML19263B505 (9)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.

70-33/78-15 Docket No.

70-33 License No.

SNM-23 Priority 1

Category UR Licensee-Texas Instruments. Incoroorated 34 Forest Street Attleboro, Massachusetts 02703 Facility Name:

HFIR Project Inspection at:

Attleboro, Massachusetts Inspection conducted:

October 24-26, 1978 Inspectors:

j. g,/, Jpg J.Roth,ProjectInspfctor dats sigfied

~

H. W. Crocker, Chief, Fuel Facility Projects Section, FF&fiS Branch date signed date signed Approved b M

/,2/j / yge H. W. Crocker, Chief, Fuel Facility date'sicined Projects Section, FF&MS Branch Inspection Summary:

Inspection on October 24-26, 1978 (Report No. 70-33/78-15)

Areas Inspected:

Routine, unannounced inspection by regional based inspectors of the licensed program including:

scope of operation; organization; facility changes and modifications; internal review and audits; safety committees; training; review of operations; nuclear criticality safety; packaging and shipmer t of radioactive material; followup nonroutine events; and, licensee actions on pre-viously identified enforcement items.

This inspection was initiated on the day shift and involved 35 inspector-hours on site by two NRC regional based inspectors.

Results:

Of the eleven areas inspected, no items of noncompliance were identified in 10 areas; one apparent item of noncompliance was identified in one area (In-fraction - failure to post MSO signs and failure to define posted MSQ signs as required by Table 1 of Appendix 1 (78-15-01, Paragraph 5.a)).

'79011803 %)

Region I Form 12 (Rev. April 77)

DETAILS 1.

Persons Contacted

  • J. W. Ross, Project Manager, Metallurgical Materials Division
  • F. Sherman, Manager, HFIR Project
  • D. Talon, Health Physics Officer
  • C M. Hopper, Manager, Nuclear Materials R. Gonzales, HFIR Security Administrator
  • F. Campbell, Manufacturing Foreman The inspector also interviewed four other licensee employees during the course of this inspection.

denotes those present at the exit interview 2.

Scope of Operations The licensee continuas to manufacture fuel elements, for the High Flux Isotope Reactor (HFIR) and for the Oak Ridge Reactor (ORR), for the Oak Ridge National Laboratory.

In addition, the licensee is also manu-facturing fuel elements for the High Flux Beam Reactor (HFBR) for Brookhaven National Laboratory.

3.

Licensee Action on Previously Identified Enforcement Items (Closed) Infraction (33/77-13-02):

Nodification of equipment spacing without specific authorization of NRC-NMSS.

During inspection 70-33/

78-09, the inspector verified that the licensee had submitted applica-tions for license amendment to NRC-NMSS to obtain authorization to move and/or install pieces of equipment for use in the fabrication of box type fuel elements.

During this inspection the inspector verified that the licensee had copies of the authorizing amendment to the facility license (Amendment #8, dated July 28,1978) which authorized the fcbrication of ORR and other box type test reactor fuel elements. Cor-rective actions on this item of noncompliance have been completed.

(Closed) Infraction (33/77-13-03):

Improperly designed trans#3r carts and storage carts.

During inspection 70-33/78-09, the inspector noted that transfer carts which had no built in isolation zone had been redesigned and fabricated based on a separation distance of 6 inches.

This separation distance, also authorized by Amendment #8, dated July 28, 1978, established the distance between SNM units located in work stations or storage racks and transfer or storage, carts.

Corrective actions have been completed on this item of noncompliance.

3 (Closed) Infraction (33/78-09-02):

Failure to adequately train new employees and other persons in Building 10.

The inspector verified that the licensee has retrained all persons not on sick leave working on the HFIR Project in all of the areas stipulated in Section 10.1 "New Employees Orientation" of the approved Health and Safety Manual, dated March,1973.

In addition, the section of the "HFIR Emergency Procedures Manual" relating to training of other persons working in Building 10 has been modified to reflect the actual method of emergency evacuation instructions given.

Cor-rective actions have been completed on this item of noncompliance.

4.

Organization The project organization has not changed significantly si.ce in-spection 70-33/77-13.

Miss Cheryl Karol, Mr. Robert Nnnson and Mr. John M. Heffner have joined the staff.

Miss Karol as project secretary, Mr. Johnson as a process engineer and Mr. Heffner as a quality assurance engineer.

Mr. F. Sherman is acting Project Manager ir addition to being Manager, HFIR Project, while Dr. J.

Ross is on leave.

Dr. Ross is expected to be on leave until Dec-ember, 1978.

5.

Review of Operations The inspector examined all areas of the plant to observe operations and activities in progress; to inspect the nuclear safety aspects of operations within the facility; and, to check the general state of cleanliness, housekeeping and adherence to fire protection rules.

a.

During the course of this examination, the inspcctor observed that several of the maximum safety quantity (MS0) signs did not coincide with the MSO statements listed in Table 1 of Appendix 1 as required by Amendment #8, dated July 28, 1978.

1)

MSO signs in locations, 35, 3C, 37, 38 and 39 read "l-HFIR or similar element" and should read "l-HFBR or similar element." This inadequacy was immediately corrected.

2)

The MSQ sign in location 8 included "l-SS container" in the posted sign.

This sign should read "10 storage posi-tions.

1 69 gms U-235/ position or 24 components.

4

4 3)

The MSO sign in location 5 did not include the mass limit of "< 2.37 Kg U-235 as required by Table 1."

4)

Two HFBR fuel element storage carts which contained SNM bearing fuel elements were not posted with MSQ signs. One cart was located in the chemical etch room and the other was located at the element deburr work station.

MSQ signs were posted in these storage carts prior to the end of this inspection.

The above was identified to the licensee as an item of noncomnliance (78-15-01).

h.

It was also observed that the MSQ signs in locations 32 and 33 were as required by Table 1.

However, the inspector noted that these signs should be clarified since the MSQ was stated as "1 element cart" and each of these locations were also authorized as work stations, in addition to the allowed element cart.

Licensee representatives stated that the posted signs would be modified to reflect actual operating conditions (78-15-02).

c.

The inspector noted that a Ra 226 source was stored in a lead pig located in the HFIR storage area.

Upon request by the inspector, a licensee representative surveyed this container for radiation and datermined that on contact the radiation level was 15 mr/ hour at one location on the perimeter of the container. At 12 inches from the surface, the radiation level was 1-1/2 mr/hr.

The inspector discussed this item with licensee representatives and was informed that in order to reduce the radiation levels even farther the pig was placed into a 10 gallon can and surrounded by steel shot. This action will be confirmed during a subsequent inspection (78-15-03).

d.

The inspector examined the following standard operations during the conduct of this inspection.

1)

" Health Physics Procedure Manual," dated October 10, 1978, EN-78-61 2)

S0-6, Revision J EN 78-17, dated February 22, 1978,

" Blending"

5 3)

S0-7, Revision T, EN-78-17, dated February 22, 1978,

" Press Compacts" 4)

S0-13,' Revision V, EN-78-18, dated March 17, 1978,

" Anneal Fuel Plate Compacts" 5)

S0-29, Revision S, EN-78-4, dated October 5,1977,

" Hot Roll Bonding Plates" 6)

S0-60, Revision 0, EN-69-32, dated November 20, 1969,

" Anneal Hot Roll Fuel Plates" It was noted by the inspector that the procedures contained adequate information for properly trained operators to safely conduct the described operations.

6.

Nuclear Criticality Safety a.

Internal Review and Audit The inspector questioned licensee representatives regarding the conduct of internal reviews and audits dur:.1g the time period June 30, 1978 through October 18, 1978.

The inspector reviewed the reports of five internal monthly nuclear criticality safety inspections which were conducted by the Health Physics Officer.

The reports indicated that corrective actions had been taken and completed on problem areas identified.

However, in many instances the specific corrective actions taken were not docu-mented.

This was discussed at the exit interview.

b.

Quarterly Criticality Safety Audits Audits of the nuclear safety aspects of the HFIR project acti-vities by a qualified person from ORNL were conducted on June 27, 1978 and July 21, 1978, for the second and third quarters of 1978.

As of the date of this inspection (70-33/78-15) these reports had not been received by the licensee.

Reports of these audits will be reviewed during a subsequent inspection (78-15-04).

c.

Testing of the Criticality Monitors 1)

Records of the weekly criticality monitor tests for the period July 10, 1978 through October 17, 1978 were examined by the inspector.

Silent tests were run weekly during the time period examined except for the week of July 17, 1978 through July 24, 1978 when the facility was on vacation shutdown.

The sirene were tested (sounded) quarterly on

6 August 10, 1978, by setting off the radiation monitor located nea: the facility emergency exit to the outside of the building.

This monitor was set off with a radiation source.

2)

All criticality monitors in the facility were calibrated on a,aarterly schedule on June 30, 1978 and September 29, 1978.

During this inspe: tion, the inspector observed each criticality monitor and determined that each ap-peared to be operating properly.

Each monitor was observed set to alarm at about 15 mr/hr.

d.

Nuclear Safety Evaluations The inspector questioned licensee representatives about the preparation o'f nuclear safety evaluations since the last in-spection (70-33/78-09).

The licensee has established a formal nuclear safety evaluation procedure which includes a ~ Request-for Criticality Safety Analysis (RCSA) prepared by the pro-cess engineer or production foreman and a Criticality Safety Analysis and Approval (CSA&A) prepared by the Manager Nuclear Materials. All RCSAs and CSA&As are sequentially numbered in a similar manner so that identity of the request cannot be lost.

The evaluations examined by the inspector included.

1)

Request No.1, " Operation - Mill Edge of Type 3/4 Fuel Plates - Location 35," dated September 6, 1978, approved September 6, 1978 2)

Request No. 2, " Mill and Deburr Edge of Type 3/4 Fuel Plates, Locations 37, 38 and 39," dated September 1,1978, approved September 6,1978 3)

Request No. 3, "HFBR Assay Sample - Locations 65, 66, 69 and 70," dated September 21, 1978, approved September 25, 1978 4)

Request No. 4, " Clean and Deburr Fuel Elements - Location 20," undated, approved October 4, 1978 5)

Request No. 5, " Low Temperature Bake - Location 53," dated October 17, 1978, approved October 17, 1978 The inspector noted that ii. each case, the licensee used con-servative evaluation techniques which were within the purview of current license conditions.

7 e.

PVC Spacers During August,1978, the licensee determined that the spacers used in fuel plates storage boxes were fabricated from poly-styrene based plastics instead of polyvinyl chloride based plastics.

Because of the additional hydrogen present in the polystyrene based plastics, this mixup in plastics could have nuclear safety ramifications which were immediately reported by the licensee to NRC-NMSS personnel.

The licensee also im-mediately conducted an analysis of the problem and it was con-firmed that the use of polystyrene in place of PVC had a negligible effect on the nuclear safety of the systems involved.

In spite of this conclusion, the licensee is attempting to ob-tain new PVC spacers to replace all the existing polystyrene spacers.

This will be followed closely by the inspector during subsequent inspections (78-15-05).

7.

Facility Changes and Modifications The inspector noted that the fuel component storage rack, in location 78, which was approved for use by Amendment 8 was currently in use.

The inspector also observed that the change line into the fuel manu-facturing area (FMA) had been modified (extended) to provide additional space for operators to change shoes and clothing.

In addition, it was noted that permanently assigned operators were currently removing potentially contaminated clothes at the change line and leaving these clothes on the contaminated side of the change line.

8.

Safety Committees The licensee has delegated to the Manager, Nuclear Materials, the responsibility of overview of the Health Physics and Nuclear Safety aspects of the facility.

The internal inspection function is conducted by the Health Physics Officer as audited quarterly by two members of the ORNL Staff (one for nuclear safety and one for industrial and radiation safety).

Industrial safety is the responsibility of the manufacturing foreman as audited by the ORNL staff member.

General safety problems (radiation, nuclear and industrial) are discussed as required during weekly project staff meetings.

Further reviews are conducted as neded by members of the project staff when directed by the project manager.

8 9.

Nonroutine Events The inspector determined through discussions with licensee repre-sentatives that there were no nonroutine, reportable or nonreportable events that occurred at this facility since the last inspection.

10.

Packaging and Shiocing of Radioactive Material Licensee records relating to the shipping and receiving of radio-active materials for the time period February 24, 1978 through October 5, 1978 were examined by the inspector.

These reccrds documented results of radiation surveys, container inspection results, labeling, marking and placarding of vehicles and/or con-tainers which were required by license conditions, federal regula-tions or internal procedures.

No inadequacies were identified.

11.

Training The inspector reviewed the licensee's training records to determine the status of the corrective actions for item 78-09-02 from inspection 70-33/78-09.

On August 25, 1978, and September 8, 1978, the licensee conducted training sessions for all available employees of the HFIR project.

These sessions included retraining in all areas discussed in license conditions as being required during the initial training of employees.

All project employees with the exception of three who were on long term sick leave were retrained.

Licensee representatives stated that these three employees will be retrained upon return to work.

Included in the retraining were fuel handling procedures and storage procedures; discussion of topics and pyrophoric materials used in operations; radiation types and limits; posting; working with radioactive materials; radiological surveys; the use of MSO signs; and NRC rules and regulations.

12.

Licensee Progress Reports The licensee uses weekly progress reports to record the status of the manufacture of fuel elements for each project and to log the status of items concerning safety or sa feguards.

Reports of the HFIR and ORR projects for the period June 20, 1978 through August 1, 1978 were examined by the inspector. These reports document the status of health and safety, safeguards, and security items.

No unreviewed health and safety problem areas were identified by the licensee during the time period examined.

9

13. Exit Interview The inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection at 1:00 p.m., October 26, 1978.

The inspector summarized the scope and findings of the in-spection.

The licensee representatives made the following remarks in response to the items discussed by the inspector.

Stated that MSQ signs would be reviewed to assure that they coincide with the statements listed in Table 1 of Appendix 1 as required by Amendment 8 (Paragraph 5.a).

Stated that the MSQ signs for locations 32 and 33 would be clarified (Paragraph 5.b).

Stated that the Ra 226 source had been repackaged to reduce the package external radiation levels to as low as possible (Paragraph 5.c).

Stated that corrective actions for internally identified de-ficiencies would be more thoroughly documented (Paragraph 6.a).