ML19347E626
| ML19347E626 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/17/1981 |
| From: | Crocker H, Ketzlach N, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML19347E622 | List: |
| References | |
| 70-1100-81-01, 70-1100-81-1, IEB-79-19, IEC-80-14, IEC-80-20, NUDOCS 8105130148 | |
| Download: ML19347E626 (19) | |
Text
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[k U. S. NUCLEAR REGULATORY COMMISSION"'
0FFICE OF INSPECTION AND ENFORCEMENT fgp REGION I l
(
Report No.
70-1100/81-01 Docket No.
70-1100 License No.
SNM-1067 Priority 1
Category UR Licensee:
Combustion Engineering, Incorporated P. O. Box 500 Windsor, Connecticut 06095 Facility Name:
Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At:
Windsor, Connecticut Inspection Conducted:
February 10-13, 1981 Inspectors:
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J. Gbtl, Project Inspector
'catd Accompanied by:
N. Ketzlach Uranium Fuel Licensing Branch /NMSS date date 9"//~7/d'"/
Approved b H. W. Crocker, Chief, Fuel Facility
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Projects Section, DRPI Inspection Summary:
Inspection on February 10-13, 1981 (Recort No. 70-1100/81-01)
Areas Inspected: Routine, unannounced inspection by a regional based inspector of the licensed program including: organization, facility changes and modifi-cations; internal review and audit; safety committees; training; review of operations; nuclear criticality safety; review of nonroutine events; licensee action on'previously identified enforcement items; follow-up on regional office Iircolars; and, participation in licensing / licensee meeting.
The inspection was initiated on the day shift and involved 35 inspector-hours onsite by one NRC inspector.
Results: Of the 11 areas inspected, no items of noncompliance were identified in,10 areas. One item of noncompliance was identified in one area (Violation - Failure to maintain a co-planar slab array in the unclad fuel handling area and failure to maintain one foot separation between storage and work stations (81-01-01), paragraphs 3a(2) and 3a(4).
Region I Form 12 (Rev. April 1977) 81 osis o MU
DETAILS 1.
Persons Contacted Nuclear Manufacturing
- H. V. Lichtenberger,'Vice President-Nuclear Fuel
- F. J. Pianki, General Manager-Fuel Manufacturing
- G. A. Johnstone, Supervisor, Health Physics and Safety Nuclear Laboratories P. R. Rosenthal, Manager, Health Physics J. Limbert, Radiological Engineer The inspector also interviewed 12 other licensee employees during the course of the inspection. They included, operations foremen, laboratory supery' sors, operators, health physics tec'hnicians, laboratory technicians, and general office gs *onnel.
- denotes those present at the exit interview.
2.
Licensee Action on previously Identified Enforcement Items (0 pen) Inspector Follow Item (1100/78-10-d2): Training program for response orgsnization. The training to be given to the emergency response personnel has been documented by the licensee in the form of schedules and lesson plans. The site emergency procedures have been modified to include a series of checklists to be used by each category of personnel involved (i.e., supervisors, security guards, survey teams, emergency director, etc.). However, the training program, based on the revised program, has not as yet been implemented.
For additional information see item 1100/79-12-03 below.
3 (0 pen) Unresolved Item (1100/79-12-03):
Emergency training, Radiation Worker training. As discussed above, the licensee has revised the site energency procedures. These procedures / checklists were submitted to NRC Region I by letter dated May 23, 1980 for information and review. During review of the checklists a Region I Emergency Planning Inspector determined that the checklists lacked specific detail. For example: Checklist 1.2,
" Survey Team" action item (1) properly referenced the procedure used to conouct contamination surveys of victims, but failed to specify the type ef instrument to be used for surveying skin contamination; action item (4)-
the procedure used to obtain urine samples was not clear, and did not indicate the size urine sample required for analysis; Checklist 1.4,
" Emergency Director Checklist" action item (1) failed to specify the loca-
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tion of the energency assembly area; " Evaluation Questionnaire" needs to require additional information,' for example, the position and location of the individual when the criticality alarm sounded. The above matters are o
' typical and generic for the checklists reviewed. On the basis of the.
above review, it appears that additional work is required to be done in
-- order to improve the information accumulated during an emergency.
- ~~(Closed) Inspector Follow Item (1100/80-02-02): Review licensee action to replace gaskets in low level waste shipping containers prior to shipment (Bulletin 79-19). The inspector verified that the licensee had opened all waste containers observed by the inspector during inspection 70-1100/
80-02 and had installed lid sealing gaskets in the shipping containers, if necessary, prior to shipment. Actions have been completed on this item.
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4 (Closed) Infraction (1100/80-07-01):
Failure to evaluate the use of unsafe geometry containers with 9 eater than 3.5% enriched U0. The 2
inspector verified that the lice #see had evaluated the use of various unsafe geometry containers (including: wash basins, mop buckets, 55 gallon waste drums, vacuum cleaners and filters) with up to 4.1% enriched UO. Corrective actions have been completed on this item of noncompliance.
2 (Closed) Infraction (1100/80-07-02):
Failure to maintain a 20 foot separation between two arrays of shipping crntainers which contained special nuclear material (SNM). The inspector verified that no two arrays of shipping containers were being maintained with less than a 20 foot separation. The licensee had posted Building 21 with a sign that reminded personnel of the 20 foot separa* ion requirement and had retrained all applicable plant personnel in SNM storage requirements. Corrective action has been completed on this item of noncompliance.
(0 pen) Inspector Follow Item (1100/80-07-03):
Installation of shelves and criticality alarm in the new Building 2 SNM vault. T.he inspector observed that there had been no significant progress on the installation of this vault since the last inspection.
Licensee representatives indicated that the criticality alarm instrumentation had been received but had not, as yet been installed.
(Closed) Inspector Follow Item (1100/80-07-04): Organizational structure relating to criticality safety. Because of the recent resignation of the Nuclear Licensing and Safety Manager, the inspector questioned the organization 31th respect to nuclear safety. As a result, the licensee submitted a Itcense amendment application dated Novenber 14, 1980 which specified changes in the organization and responsibilities of key personnel respon-sible for the nuclear criticality and radiation safety programs. The facility license was modified by Amendment 26 dated January 30, 1981 to incorporate these changes. Actions have been completed on this item.
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3.
Review of Operations The inspector examined all areas of ths plant and the nuclear laboratories to observe operations and activities in progress; to inspect the nuclear safety aspects of the facilities; and, to examine the general state of cleanliness, housekeeping and adherence to fire protection rules.
a.
Nuclear Fuel Manufacturing Facilities (1) Nuclear Safety Signs The inspector noted that all observed areas and work stations were properly posted with nuclear safety signs. However, it was observed that the sign posted at the rod examination fluorescence station was not readily readable. This sign was changed prior to the end of this inspec* ion.
(2) Nuclear Safety Slab Geometry The storage of fuel pellets in trays and boats in the Fuel Handifcg area was not in accordance with the co planar slab geometry specified in the approved license application.
It was ebserved that the differential in height between segments of the slab plane varied as much as 10 inches.
For instance, it was noted that a differential in plane height of 10 inches occurred between adjacent and touching slabs located on transfer carts and the sintering furnace boat cooling tables.
In addition there was a slab geometry transfer car adjacent to and touching the pellet surface grinder with a differential in plane of 10 inches.
Failure to maintain a co planar slab geometry in the pellet manufacturing area was identified as an item of noncom-pliance (81-01-01).
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6 (3) Radiation Work Permits The inspector noted that Radiation Work Permits (RWP's) were not posted at or near the area where the work was being done.
According to licensee representatives as verified through review of licensee procedures, the licensee has not specified the requirement to post RWP's at or near the work locations.
This was discussed at the exit interview during which the inspector stated that posting of an. RWP at the work location would serve as a reminder to workers of the requirements specified in the RWP. Licensee representatives stated that this would be reviewed for applicability to their operation (81-01-02).
(4) Separation of Safe Individual Units (SIU)
..e inspector noted that a waste drum was located within two inches of a slab limited storage area (the Window Storage Area) in the rod assembly area. This is contrary to the licensee requirement which states that all SIUs must have a separation of at least one foot, edge to edge. This was identified as part of an item of noncompliance (81-01-01).
(5) Nuclear Safety Log Sheets The inspector examined the micronizer and hammermill log sheets for the time period January 2,1981 through February 9,1981.
The records indicated that the appropriate posted nuclear safety limit was not exceeded during the time period.
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During examination of the QC Inspection Room (P-55) it was noted that the room was posted with a 24 kg U0 limit. The 2
room contained 15 trays of about 100 pellets each and one small boat of pellets. There was no log available to indicate what the UO content of this room vias at the time of this inspection.
2 In addition, personnel available at the time of this inspection could not indicate how much material was in the room at the time. Subsequently it was determined that the room contained about 15.8 kg of material. At the exit interview, the inspector stated that maintenance of a log at this work station would eliminate uncertainty as to the quantity of UO2 present at any time.
No items of noncompliance were identified.
b.
Nuclear Laboratories (1) Fai:111ty Examination The inspector examined all areas of the Nuclear Laboratories including Buildings 2 and 5.
It was noted that the ceramics laboratory had been recombined into one single criticality control area which was limited to a maximum of 740 grams U-235.
The SNM content of each criticality control area in the Nuclear Laboratories was less than the applicable posted limit.
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l (2) Building 2 Fuel Storage Vault The licensee has not initiated installation of the special nuclear material storage vault in a vault type room located in Building 2.
The criticality alarm system monitors have been received but have not been installed.
During examination of the nuclear safety evaluation which had been completed for this installation it was r.oted that nuclear safety was based on slab geometry. The inspector pointed out to the licensee repre-sentatives that slab geometry was authorized in the license only for fuel manufacturing operations and not for nuclear laboratory operations. Since this new vault will be located in a nuclear laboratory building, the licensee will submit a license amendment application to NRC-NMSS to allow the special slab limit in Building 2 prior to initiating the use of this new v'ault.
No items of noncompliance were identified, c.
Examination of Building 6 The inspector examined the Building 6 Liquid Waste Tank Storage Facility and no inadequacies were identified. However, during discussions with licensee representatives, the inspector was informed that the licensee had taken and analyzed sludge samples from nine of the ten retention tanks and both dilution tanks. The tenth retention tank contained no sludge. The uranium in the tanks contained U-235 ranging from about 2.8 to about 60 percent enrichment. The licensee estimates that the tanks contain a total of about 460 grams U-235.
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The retention tanks contained U-235 ranging from about 2.8 percent to about 12 percent enrichment. The dilution tanks contained U-235 ranging from about 5.2 percent to about 60 percent enrichment.
9 According to the licensee, the retention tanks were cleaned out some time during the 1974-1976 time period, however, the dilution tanks were not cleaned out at that time. The itcensee plans to conduct further sampling of all the tanks, determine all of the sources of the liquid filling the tanks and then cleanout all of the tanks.
The inspector determined through review of license data that there did not appear to be any nuclear safety hazards associated with the accumulation of U-235 in the waste liquid tanks. However, the inspector pointed out to licensee representatives that the facility license does not authorize the licensee to have uranium enriched in excess of 20 percent U-235 onsite since the incorporation of Amendment 24 into the facility license on February 25, 1980.
Prior to that date the Itcensee was authorized to use up to 4800 grams of U-235 in uranium enriched in excess of 20 percent U-23' onsite.
Since the licensee h'as identified two instances where wasst daterials have been found to contain small quantities of uranium enriched in excess of 20 percent U-235 during the last 12 months, the inspector stated to licensee representatives that they should consider applying for a license amendment to incorporate a line item into the facility license which would cover any additional instances where small unaccessible quantities of uranium enriched in excess of 20 percent U-235 are found. Di: ring the exit interview licensee representatives indicated th?t th's would be considered.
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Nuclear Criticality Safety a.
Nuclear Fuel Manufacturing (1) Internal Review and Audit (a) Daily Audits Records of daily audits conducted by health physics technicians for the time period August 25 1880 through February 9, 1981, were examined by the inspector. These audits examined signs, logs, radiation alarms, criticality safety compliance, contamination levels and airborne contamination levels.
Items requiring correction were corrected immediately.
(b) Monthly Audits The inspector examined documentation'of monthly audits conducted by the Supervisor, Health Physics and Safety or a Criticality Safety Specialist during the time perioc August 29, 1980 through January 29, 1981. The inspector verified that appropriate corrective actions were taken or had been initiated by the licensee for the items identified in the 11 reports which required correction.
No items of noncompliance were identified.
11 (2) Nuclear Safety Evaluations (a) Facility Changes and Modifications The licensee has relocated the Health Physics Technician's office. This office has been installed in the rear portion of the smoking area located off the men's change room and a window has been installed between this office and the hallway leading into the unciad fuel handling area. This window is used to pass through water samples from the centrifuge systems, breathing zone samplers, etc.
The inspector also noted that the orientation of the men's
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room change line had been modified to include two personnel l
monitoring stations.
The inspector was informed that the licensee had acquired an additional 50 acres of land on ths west side of tile property which extended the property lii:e out about 1200 feet in the westerly direction.
I The inspector observed that the licensee had completed installation of a fence and guard house around the Building 17 and Building 21 complex.
In addition, motion detectors and door alarm systems were installed in appropriate areas of the Nuclear Laboratories. The new site security plan was irglamented fully as of February 6,1981.
No items of noncompliance were identified.
j 12 (b) Review of Nuclear Safety Evaluations The inspector reviewed the records of the review and approval of process equipment or facility changes per-formed by the Nuclear Licensing Consultant for criticality safety or by the Supervisor, Health Physics and Safety for Radiological Safety.
From August 19, 1980 through January 13, 1981 (Request No. 60) 13 requests for review and approval were made by Engineering.
Twelve of the requests were reviewed and approved. Nine of the 12 involved nuclear safety and 3 involved radiological safety only.
Conditions of approval were imposed, as needed, for criti-cality and radiological safety considerations. The requests involving criticality safety' considerations were independently reviewed by a qualified person designated by the Nuclear Safety Commit'ee. These evaluations were then countersigned by this qualified person as required.
b.
Nuclear Laboratories Monthly Audits af the Nuclear Laboratories The inspector examined the records of 9 audits of the Nuclear Laboratories conducted by the Supervisor, Health Physics and Safety for the time period May, 1980 through January, 1981. The inspector determined that no problem areas were identified during the conduct of these monthly audits. The inspector noted that the audit reports were not dated. Several, in fact, only designated the month, i.e., November, December, January, with no day of the month or year indicated. This was discussed at the exit interview.
The inspector stated that the audit records were not complete unless the reports indicated when the audits were actually accomplished. The licensee indicated that these records would be dated in the future.
1 No items of noncompliance were identified.
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Safety Committees The inspector examined records of a meeting of the Nuclear Safety Committee which was held on December 12, 1980. As part of the meeting the committee conducted an audit of the Nuclear Fuel Manufacturing facilities. The inspector verified that corrective action had been taken on items identified by the committee as needing correction. The committee also conducted a radiological review of the facilities and reviewed the following items including: Buildup of sludge in waste tanks, the radiation exposure program, the facility bioassay program, unusual events that occurred in the facility during 1980 and licensee identified items of no;campliance.
No items of noncompliance were identified.
7.
Organization As discussed previously in paragraph 2, the licensee has modified his organizational structure with respect to nuclear safety as described in the letter dated November 14, 1980 and approved by NRC-NMSS in Amendment 26 dated January 30, 1981. The Supervisor, Health Physics and Safety (Mr. G. A. Johnstone) has assumed the administrative responsibilities previously described in the license application for the Nuclear Licensing and Safety Supervisor. He is also responsible for reviewing and approving operating procedures which do not involve any changes in the critic $lity safety controls used for that particular process in the past and for training and periodic retraining of personnnel in criticality, radiological and industrial safety.
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A new position of Nuclear Licensing Consultant has been incorporated into the facility license by Amendment 26. This position has been filled by the former Nuclear Licensing and Safety Supervisor (Mr. G. J. Bakgrvich).
The responsibilities of the Nuclear Licensing Consultant include: ' consulting on all aspects of nuclear criticality safety involved in licensing activities; audit of the manufacturing facility for criticality safety; provide initial review and approval of proposed facility and equipment changes which affect nuclear criticality safety; and, review and approve operating procedures and revisions which involve a change in criticality safety controls.
No items of noncompliance were identified.
8.
" Contaminated Storage Area" The inspector examined the " contaminated storage area" which was located in a wooded area of the licensee's site approximately 900 feet northwest of Building 2.
This area had been initially discovered during an aerial radiation survey and was subsequently reported to Region I on June 13, 1980.
A licensee representative stated that the following actions had been completed or were in process with respect to the cleanup of this " storage" site:
a.
A request to NRC-NMSS to allow " processing" of this materfa! was being prepared.
b.
Preliminary subsurface ground core sampling has been completed.
c.
Analysis of " scoping" samples has been completed.
d.
A lean-to staging shelter has been built and will be installed at the entrance to the area.
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A mechanism for determining air concentrations at the edge of the restricted area is being devised.
f.
The licensee will keep Region I informed on the status of this cleanup operation.
No items of noncompliance were identified.
9.
Training a.
Nuclear Fuel Manufacturing (1) Operators Through discussions with licensee representatives and review of licensee records, the inspector determined that during the calendar year 1980, 28 new employees (operations) received training in health and safety requirements and the emergency plan. This initial training was conducted on the date of hire or within the first week after starting. Training given included:
criticality safety; precautions required for U02 p wder handling; exposure to external radiation; use of protective clothing, use of personnel monitoring devices; fundamental radiation safety rules and policies; and, plant emergency procedures.
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16 Licensee records indicated that annual retraining for operators was also given as required. The licensee has established a mechanism to assure that personnel who miss the annual retraining sessions because of vacations, illness, etc., will be trained at a later date. Records indicate that all operators have been trained and retrained as required.
(2) Other personnel Licensee records indicated that other personnel including, supervisors, engineers, management, and maintenance were trained and/or retrained as required.
In addition, outside contractor personnel who were to work in the unciad fuel handling area were trained in: use of breathing zone samplers; emergency procedures, evacuation routes; use of protective clothing; techniques of monitoring for contamination; and, risks asso-ciated with working with or around UO2 p wder. Training of Health physics personnel w;11 be examined during a subsequent inspection (81-01-03).
The inspector stated during the exit interview that occasional personnel and/or visitors, (i.e., auditors, members of the Nuclear Safety Committee, consultants and vendor personnel) who enter the unciad fuel handling area, should be trained in applicable subjects (i.e., emergency procedures, evacuation routes, use of protective clothing, contamination monito.-ing techniques, etc.) as necessary. Licensee representatives indicated that this aspect of training will be reviewed for applicability.
No items of noncompliance were identified.
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17 b.
Nuclear Laboratories Through discussions with licensee representatives and review of licensee records the inspector determined that the licensee was revising the laboratory training lecture series to include, emergency procedures, waste handling rules and regulations, risks of radiation, TLD's and how they work, and new security requirements. Other aspects of Nuclear Laboratory training and retraining will be reviewed during a subsequent inspection (81-01-03).
No items of noncompliance were identified.
- 10. Nonroutine Events On July 14, 1980 at aboct 12:35 p.m., a small fire was discovered in the sinterability test hood. The fire was caused by the overflow of a metal bucket of contaminated hydraulic oil which was left in the sinterability test oven to evaporate. The overflowed oil came in contact with the heating element of the oven and resulted in a small fire.
Two operators returning to the pellet shop from lunch noticed the fire, cut the electrical power to the oven and extinguished the fire with a dry chemical fire extinguisher. There was no airborne release of contamination out of the hood and no apparent equipment damage occurred. The use of this procedure for boiling down contaminated oil has been discontinued and alternative methods for the disposal of contaminated oil are being devised by the licensee.
No items of noncompliance were identified.
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- 11. Licensee Action on IE Circulars a.
IE Circular No. 80-14 " Radioactive Contamination of Plant Decontamination Water System and Resultant Internal Contamination of Personnel" dated June 24, 1980 The inspector questioned licensee representatives on the results of a review of plant water systems as suggested by the referenced circular.
Licensee representatives indicated that the plant demineralized 1
water system enters the contaminated area into a tank. Water from the tank is gravity fed to the point of use. There is no mechanism available for water to feed back from the point of use to the storage tank. Verbal instructions were given to all personnel during training sessions held on or about August 21, 1980 that domineralized water from the plant system was not to be used for personal consumption.
No items of noncompliance were identified.
b.
IE Circular No. 80-20, " Changes in Safe-Slab Tank Dimensions" dated August 21, 1980 Through a review of plant operations, the licensee determined that one horizontal slab tank about 4 feet by 4 feet by 4.6 inches in height had been instailed on the mop water centrifuge system.
Although no dimensional changes were identified, as a precaution, the licensee installed a one inch vent line into the tank to assure that dimensional changes could not occur because of over pressuri-
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zation.
No items of noncompliance were identified.
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- 12. Licensing / Licensee Meeting l
A member of the NRC-NMSS staff accompanied the inspector during this inspection to review company operations relative to a license renewal application submitted to NMSS dated December 18, 1980. During the course of this inspection, the criteria section of this application was reviewed by the inspector and comments wre made to the NMSS staff member cor.cerning the application. Emphasis was placed on the need to clarify the licensee organizational structure, administrative controls for safety and the establishment of criteria for all process and storage operations. During the licensing / licensee management meeting, the NMSS staff member discussed the above items, and the need to follow the " Standard Format and Content for the Health and Safety Sections of Renewal Application for Uranium Fuel Fabrication Plants."
No items of noncompliance were identified.
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- 13. Exit Interview The inspector met with the licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection at 11:00 a.m. on February 13, 1981. The inspector summarized the scope and findings of the inspection.
Remarks made by licensee representatives have been incorporated int'; the applicable paragraphs of the report details.
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