ML19276G161

IE Insp Rept 70-1257/79-01 on 790212-16.No Noncompliance Noted.Major Areas Inspected:Safety Committee Activities, Training,Calibr,Criticality Safety,Emergency Planning & Fire & Radiation Protection

ML19276G161
Person / Time
Site:	Framatome ANP Richland
Issue date:	03/16/1979
From:	Book H, Cooley W, Zurakawski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML19276G154	List: ML19276G153 ML19276G161
References
70-1257-79-01, 70-1257-79-1, NUDOCS 7905150701
Download: ML19276G161 (11)

Text

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U. S. i'UCLEAR REGULATORY CO:f:ilSSION OFFICE OF INSPECTIOil AND ENFORCE'EtlT REGIO!! V Report fio. 70-1257/79-01 1

Docket No. 70-1257 License No. StN-1227 Safeguards Group Licensee:

Exxon Nuclear Ccapany 2101 Horn Rapids Road Richland, Washington 99352 Facility Name: Richland Facility Inspection at: Richland, Washington Inspection Conducted:

Feb'ruary 12-16, 1979 Inspectors:

f[6J 9. 0.-[r fft//7 W. J. Cooley / Fuel Facilities Inspector Date Signed N-l Nbi b' 3////77 P. R. Zurakowsdi{ Radiation Specialist Date Signed Approved By:

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[Jf g H. E. Book, Chief, Fuel Facility and Materials

.$ ate' Signed Safety Branch Summary:

Inspection on February 12-16,1979 (Report No. 70-12E7/79-01)

Areas Inspected: Organization; modifications and changes to facilities and s3 stems; internal review and audit; safety ccmittee activities; employee training programs; preventive maintenance / calibrations; operations review; criticality safety; emergency planning / fire protection; radiation protection; and confimatory measurements.

The inspection involved 58 inspector-hours onsite by two inspectors.

Resul ts:

No items of noncompliance or deviations were identified.

7905150701, IE:',' Form 219 (2)

DETAILS _

l.

Persons Centacted

• R. B. Stevenson, Manager, UO2 Shop Operations

• R. H. Purcell, Manager, Auxiliary Operations

• T. C. Probasco, Engineer, Nuclear and Industrial Safety

• R. L. Miles, Supervisor, Radiological Safety E. L. Foster, Technical Specialist, Radiological Safety

• M. L. Smith, Senior Enqineer, Radiological Safety

• H. P. Estey, Manager, Licensing and Compliance, Richland Facility C. O. Brown, Criticality Safety Analyst M. K. Valentine, Manager, Maintenance Engineering K. L. Myler, Supervisor, Maintenance Engineering J. L. Armstrong, Manager, Air Balance and Ventilation, Maintenance Engineering L. J. Sevigney, Supervisor, Air Balance and Ventilation, Maintenance Engineering R. Feaster, Supervisor, Instrument Shop, Maintenance Engineering N. Vaught, Technician, Instrument Shop, Maintenance Engineering J. B. Edger, Engineer, Materials and Purchasing R. Hahn, Chemical Supervisor D. Marlin, Health Physics Technician C. E. Thoran, Lead Technical, Line 2

• Denotes those attending the exit interview.

2.

Orcanization Mr. H. P. Estey has accepted the postion of Manager, Licensing and Compliance, Richland Facilities.

His present assignment includes preparation of the SNM-1227 renewal application.

3.

Mcdification and Chances to Facilities and Systems The licensee has relocated a developmental waste recovery system from the Engineering Laboratory Operation to the UO2 Building. That system is presently located in an area adjacent to the UF6 Conversion Line No. 2.

The waste recovery system is operated at 1/3 the minimum critical mass limit.

The licensee has experienced an increase in the average airborne contamination levels in Room 100 of the UO2 Building. The licensee believes the increase can be attributed to impaired room ventilation due to the installation of many new pieces of equipment and to the

. use of portable vacuum cleaners.

Preliminary work is being done on improved Room 100 ventilation and consideration is being given to special venting of vacuum cleaner exhaust to the building exhaust system.

Longer range plans of the licensee include the installation of a third UF6 conversion / powder preparation line. More or less con-current with that installation would be the relocation of a cold machine shop; relocation of contaminated scrap storage facilities and the construction of new contaminated scrap storage facilities.

The waste rccovery system was observed in operation recovering material from mop bucket water. Should this prototype system prove successful, it may be possible to recover much of the low level uranium waste that is now diverted to the waste storage lagocns.

4.

Internal Review and Audit This inspection included a review of radiation safety audits performed by the Senior Engineer, Radiological Safety.

The records were reviewed back to the time of the last inspection.

It was noted that the audits were performed in a timely mannar and that all recommendations on the cleanup of visible contamination were given prompt attention by opera-tions and supervisory personnel. The records indicated that contamina-tion and airborne problems continue to show up frequently, particularly around line 2 of the conversion area. This matter was discussed with licensee representatives at the conclusion of the inspection. The li-censee plans the installation of parallel calciner off-gass scrubbers to reduce calciner pressurization events as was done in line 1.

The frequency and severity of contamination problems appear to be increas-ing in the UO2 Building. This may be due, in part, to increased overall activity and design problems on line 2.

5.

Safety Conmittee Activities This inspection included a review of minutes of meetings held by the Nuclear Fuels Health and Safety Ccuncil. The council was found to be functioning as described in previous inspection reports (e.g.,

IE Report No. 70-1257/78-08, Section 4).

The review included industrti safety statistics compiled by the licensee and indicated that a number of uranium pellet chips had struck the eyes of operators during the year 1978. That circumstance was presented to the licensee as a matter of MRC concern at the conclusion of the inspection. Licensee representatives replied that they were aware of the incidents and that they had identified the source of the chips as grinding operations and the use of

. quality control measuring tools.

They indicated they promoted the use of safety glasses at those operations, but that, apparently, chips were penetrating at the sides and below the glasses. They indicated they were actively considering alternative goggles or face shields for the identified operations.

6.

Emoloyee Training This inspection included a review of records maintained by the licensee of the training received by individual employees using radioactive materials.

Those records are maintained in personnel dosimetry files in the custody of the Radiological Safety Supervisor.

Employee training in the area of radiation safety and industrial safety is presented both by manufacturing ocerations personnel and by radiation safety personnel.

The record review indicated that subjects covered by operations personnel include job orientation; emergency procedures; en-ich-ment control; safeguards and accountability; general operating infomation; and industrial safety. Those records indicate the date of the presentation, subject, attendance record, and instruc-tor's name.

Instructors are assigned by operations management and include members of management, was well as operations personnel.

The assignment is for approximately three months during which the assignee is responsible for the conduct and presentation of monthly instructional safety meetings.

The records also indicated an extensive training program given by the radiation safety group.

The general topics covered are rela-tive hazards of the various uranium and/or plutonium compounds, emergency procedures and respiratory protection.

Specific subjects covered included: workplace boundaries for radioactive materials; radiation work procedures; protective clothing procedures; change room step-off-pad procedures; personnel eurvey instruments; instal'.ed radiation and radioactive material monito-ing instruments and alarms; air sampling and monitoring program; radioactive material containment and contamination control; requirements and procedures for removal of equipment or materials from controlled areas; decontamination proce-dures; radioactive materials packaging procedures; tre tment of injuries in radiation areas; personnel external radiation exposure controls; personnel internal and external dosimetry; and waste dis-posal procedures. Topics discussed under emergency procedures are anbgasrelease;airborneU02;fireinvolvingradioactivematerial UF criticality. Alarms associated with the above situations are emphasized. Topics discussed under resairatory protection include:

requirements for the use of respiratory crotection equicment and devices; availability of respiratory equipment; proper selection;

_4_

mask fitting and testing, mask maintenance, repair, decontamination, cleaning and repair; personnel and mask surveys requirements follow-ing use of respiratory protection devices; bicassay and in-vivo measure-ment requirements; special air sampling requirements; and the meaning of protection factors. A spot check of the records showed that not all workers receive all of the above me itioned training, but that appro-priate training is given based on the job classification.

7.

Maintenance / Calibrations This inspection included discussions with management and personnel in the Maintenance Engineering group concerning the repair, main-tenance, and calibration of various detection devices; calibration procedures followed; and the Instrument Repetitive Maintenance com-puter system which is used to insure the assigned frequencies of those activities.

The Instrument Repetitive Maintenance program includes a listing of all detection devices used by the licensee at the Richland Plant along with the assigned calibration and maintenance frequencies and references to the appropriate procedures, The listing is subdivided into three categories; those instruments used at the Richland facility which are regarded as secondary standards; those instruments and devices identified as " red label" and defined as instruments necessary to con-trol the quality of product; those instruments and devices identified as " blue label" and defined as those not directly necessary to the quality of product, but requiring preventive maintenance.

The use of labels on instruments of the radiation detection type indicating the calibration date, the subsequent calibration due date, and the name of the calibrator has been in effect for some time.

That system has been modified by distinguishing between blue labels and red labels as described above and containing the same type of information.

The Instrument Repetitive Maintenance list is printed out monthly and the printout is adjusted to distribute the maintenance / repair /

calibration workload over the calendar year.

Calibration of the secondary standards mentioned above is against primary standards located at the licensee's Research and Technology Center, Richland, Washington. Those primary standards are traceable to the National Bureau Standards.

The Instrument Repetitive Maintenance system presently monitors approximately 60 secondary standards; 120 instruments necessary to the quality of the product; and approximately 500 instruments monitored for routine preventive maintenance.

Calibration frequencies are at six month intervals.

Internal procedures require the shutdown of a monitored system if the established calibration date is not met or if the calibration indicates the detection system operating out of specification.

When an instrument is due for calibration, the IRM Engineer sends a detailed calibration instruction to the Calibration and Maintenance Section for that particular instrument. This document serves as a reminder, an instruction and a work sheet for the work to be performed.

The calibration specialist needs only to do the work, fill out the first page of the instruction and return it to the IRM Engineer. The results are fed into the computer by the IRM Engineer.

HEPA filters are changed when the pressure drop accross them increases to three inches of water. Prior to installation, each filter is DOP tested for efficiency by the manufacturer and by a licensee contractor Environmental Health Services. After an entire filter bank has been replaced, it is tested in place for flow rate and for efficiency with 00P by Environmental Health Services. An efficiency of 99.95% is con-sidered acceptable.

The K-3 filter bank was singled out for a detailed examination of the records.

It was found that it was last DOP tested in place in September 1978. The flow rate was measured to be 46,000 CFM and the efficiency was greater than 99.991%. A formal letter from Environmental Health Services is received after each such test.

By letter dated January 3,1979, from L. B. Higginbotham to FFMS Regional Branch Chiefs, subject: Defective UF6 Cylinder Valves, the regions were requested to contact all licensees who use UF6 cylinders to determine if licensees had received defective valves and whether corrective action has been taken. On January 10, 1979, Region V contacted Messrs. W. S. Nechodom and J. B. Edger to convey the inform-ation in the January 3 letter and its attachmencs.

During the pre-sently reported inspection, Mr. J. B. Edger was contacted on the subject and informed the inspectors that Exxon had received 22 valves as listed in the attachment to the January 3 letter, but that they had been informed by the valve vendor representative (a Mr. R. Ouinn) that none of those valves had a packing nut defect. The inspectors were also informed by the licensee that no purchase orders for valves or cylinders had been executed since 1977 (prior to the May 8,1978, date listed in the January 3,1979, letter to regional branch chiefs).

This completes the Region V response on Action Item Tract No. H30205F5, dated January 3, 1979.

8.

Ocerations Review A tour of line 2, waste recovery area and Roca 100 of the U02 Building was made.

Required notices to employees and appropriate warning signs were observed in the areas visited. Current Radiation Work Procedures and Criticality Safety Specifications were observed where such documents were required.

?!o inappropriate or outdated procedures were observed during the tour.

Current protective clothing and respiratory protection recuirements were posted at the entrance to the controlled area in the UO2 Building.

The inspector was required to wear respiratory protection gear during the tour of line 2 and the waste recovery area.

A half hour was spent observing workers entering and leaving the controlled area. No infractions of the clothing requirements, proper use of the " step-off-pad" or respiratory protection requirements were noted during this observation period. No infractions of good health physics practices were noted during the entire tour of the facilities.

A log used in conjunction with a large blender on conversion line 2 to show the moisture content of the UO2 being placed inside was checked for current entry.

New material cannot be placed into the blender until the moisture content has been cnecked by the laboratory and found to be less than one wt.5.

The log was found to be maintained in a current and proper manner. No new material had been added to the blender until the moisture content had been properly assayed and the log entry checked by supervision.

Discussions with several workers about the need for such controls indicate that they understood the intent of the requirement and were quite willing to conform to it.

9.

Criticality Safety As stated above in this report, the licensee is contemplating the relocation of contaminated scrap storage. The presently procosed storage design for the new facilities is more ccmpact for unmoder-ated materal than that presently used. Contemplated storage is at 45% of a minimum critical mass in five gallon cans.

Those cans are to be stacked two high and in contact with each other in plan view. Aisle spacings will be provided. Moderated, contaminated scrap is olanned for storage in five gallen cans at the same mass limit, one can M]h and with one foot separation in the horizontal directions. Access aisles will be provided. The storage is p'ienned in trailers. The criticality analysis for the new storage location is being worked on.

10.

Emergency Planning - Fire Protection The licensee's industrial safety engineer makes daily safety surveillance checks throughcut the plant which include attention to potential fire hazards.

The same engineer makes weekly plant inspections directed specifically to fire prevention. 9.cnthly inspections are made by the Health and Safety Council (discussed above in this report) which include attention to fire prevention.

At least once each year the licensee's liability insurer conducts an inspection of the plant which may include fire protection features.

The last such inspection was conducted on June 27, 1978 and a review of the insurer's report indicated no adverse remarks regarding fire prevention.

It is noted, however, that the insurer's inspection plan did not specifically call for a fire protection inspection. The next insurer's inspection has been announced and specifically includes a review of fire protection.

The licensee contracts a service for monthly, semi-annual, and five-year fire extinguisher inspections.

The monthly inspection is visual to determine if the extinguisher is properly located; that the discharge seal has not been broken; and to determine that the extinguisher is filled within the acceptable range.

The semi-annual inspection includes the monthly type checks.

In addition, the semi-annual inspection includes weighing C02 cylinders; agit-ating powders, and checking the guage on cylinders.

Nitrogen cylinders are partially discharged to observe the guage response.

Hydro tests are made every five years by discharging the distin-guisher water, pressurizing, and refilling.

The licensee does not conduct fire drills as such. Occasional false alarms have occurred. The alarms are so oriented that only the alarmed building is evacuated at a given time.

All plant personnel received instructicns by the Richland Fire Department in the use of extinguishers as applied to gasoline fires. Special instruction is given to emergency crews during the 350 pound dry powder extinguisher and instruction in how to set up fire walls. The instruction in use of extinguishers is semi-annual.

The licensee's emergency plan has been reviewed by NRC Headquarters and its latest revision was incorporated by amendment into the subject license, February,1979.

11.

Radiation Protection Programs The licensee conducts numerous surveys for contamination in the UO2 and M0 Buildings.

Those surveys are recorded in three cate-gories. Repetitive surveys are those r.easurements made on objects leaving controlled areas or transferring from one controlled area to another. Routine surveys are those conducted of surfaces within specified areas such as change rocms, process areas, laboratories, lunch rooms, and control rooms. Radiation surveys are less fre-quent measurements, but basically similar to the categories mentioned above. They involve special cases of suspected or known contamina-tion and frequently are followed by reconnendation to management for decontamination.

A review of gurvey records indicatgd that the internal limits of 2,000 dpm/dm fixed and 200 dpm/dm removable contamination for objects transferred from controlled areas were not exceeded. Approx-imately 5,000 surveys of that type are conducted each month as deter-mined by a review of records covering the months of December,1978 and January,1979.

Areviewofrecordsofroutinesurveysind{catedcontamination levels on the order of 500 to 1,000 dpm/dm of removeable contamina-contamination. Subsequent surveys in several instances indicated decontamination efforts had been made.

Some higher readings disclosed by routine surveys were 10,000 dpm in the womans change room, 100,000 dpa on the line 1 walkway (and being tracked around), 100,000 dpn on the floor around rotary presses and grinders. Records indicated that all contamination was prcmptly cleaned up upon discovery.

The licensee conducts a bicassay program.

Included in the program are monthly urinalysis samples for all employees who work with or might be exposed to unencapsulated radioactive materials. A repeat analysis is required at an indication of 50 ugU/1 for soluble material and 25 ugU/1 for insoluble material. The licensee is not presently using plutonium.

All radiation workers are provided with an annual lung count by the licensee. Contrary to information supplied in IE Report No. 70-1257/

78-08, Section 7, Radiation Protection, the licensee will not discon-tinue lung count measurements on newly hired employees.

For the last three months, bicassay results were found to be at or near the lower limit of detectability for most people.

Some higher readings disclosed by the records search were 135 ug/1, 25 ug/1, 58.8 ug/1, 45.4 ug/l and 37.4 ug/1.

In each case, when these people were reassayed for uranium, they were found to be at the limit of detection. The records search did not disclose any reportable exposures to personnel.

This inspection included a review of airborne activity as measured at the M0 Building of the licensee.

The review covered the third quarter,1978.

Approximately seven routine air samples are taken in the Plutoniun Fabrication Laboratory. Those samples are exchanged weekly and a review indicated that the maximum sample concentration was less thaiS8 x 10- uCi/cc and that most samples were on the order of 10-uCi/cc.

Similarly, M0 Building exhaust samples are obtained after each of five, first stage HEPA filters located at glove boxes in the fabri-tration of less tj*an 8 x 10 'ge records indicated a ma:cfmum co cation room. A review of thc uCi/cc with most measurements indicating less than 2 x 10-uCi/cc. An additional five exhaust samples are obtained after two stages of HEPA filtration of air exhausted from the fabrication laborgory.

Records indicated all concentrations at or less than 2 x 10-uCi/cc. Additional samples are obtained by the livensee of exhaust stack concentrations after three stages of HEPA indicated concentrations of 10 g of thosa exhaust stack measurements fil tration.

A review of recor to 10-'

uCi/cc.

Both laboratory air samples and laboratory exhaust air samples are of approximately 10,000 cubic feet in volume.

The exhaust samples are ccunted for 20 minutes.

Within the M0 Building work continues in the so called " poison room" in which both natural and low enriched urantun is used. A review of measured gjncentrations in that laboratory indicated a maximum of 9.9g 10-tol0fi/ccwithmostmeasuredconcentrationsrangingfrom 10-uCi/cc.

The records search disclosed that for p#out a month discharges frcm the K-32 stack averaged around 1 x 10-uCi/cc. Apparently, the problem was caused by filters being damaged by failure of the de-noted to be as high as 1 x 10 gadings for short period of time were misters to operate properly.

uCi/cc.

For several days running dQcharges frem the " scrap stack" were noted to be as high as 2.0 x 10 uCi/cc.

No readings were found to exceed MRC limits when averaged over a week or longer pericd.

12. Confirmatory Measurements Smears were taken on the floor in the change rocm green zone and on the line 2 step-off-pad. The smears were returned to the Region V office and read out on a fNC Gas Proportional counter. For the change room \\b,Y counts averaged 46 c/m when the background averaged 44 c/m.

The smears averaged 3 c/m when the background averaged zero. For the line 2 step-off-pad, the 9,Y results averaged 58 c/m and them counts averaged 4 c/m for the samg background as above. Surface areas smeared were approximately 100 cm in each case. The slight positive results disclosed cannot be considered significant.

13.

Exit Interview The results of the inspection were discussed with licensee represent-atives at the conclusion of the inspection on February 16, 1979.

Those persons were informed that no items of noncompliance were observed within the scope of the inspection.