ML20042D728
| ML20042D728 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 03/26/1990 |
| From: | Bores R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042D726 | List: |
| References | |
| 70-1100-90-02, 70-1100-90-2, NUDOCS 9004050189 | |
| Download: ML20042D728 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-1100/90_02 h
Docket No.
70-1100 License No.
SNM-1067 Priority _1_
Category ULFF Licensee: Combustion Engineering, Incorporated 1000 Prospect Hill road Windsor, Connecticut 06095 Facility Name:
Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor. Connecticut Inspection Conducted:
February 12-16, 1990
_3!26 d_
Inspector:
s J. Rojh, Project Engineer, Effluents
' da'td Radiation Protection Section, Facilities Radiological Safety and Safeguards Branch, FRS&SB Division of Radiation Safety and Safeguards (DRSS) 1 Approved by:
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R. J. Bords, Chief, Effluents Radiation date Protection Section, FRS&SB, DRSS Inspection Summary:
Inspection on February 12-16, 1990 (Inspection Report Ro~ 70-1100/90-02)
Areas Inspected:
Routine unannounced inspection by a region-based inspector of the licensed program including reviews of the licensee's operations, management controls, training, criticality safety, maintenance and trans-portation activities.
Results: One apparent violation was identified.
Violation: failure to maintain a record of a criticality safety evaluation.,nducted to show that an array of fuel rod turret carts arranged perpendicular to each other would be safe.
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sOO4050189 900326 ADOCK 0700 O
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DETAILS 1.0 Individuals Contacted
- C, R. Waterman, Acting Vice President, Nuclear Fuel
- R. Vaughn, Acting Plant Manager
- P. R. Rosenthal, Program Manager, Radiological and Industrial Safety
- W. Mawhinney, Vice President, Quality Assurance
- C, Coppersmith, Director, Measurements and Performance Analysis
- J. F. Conant, Manager, Nuclear Materials Licensing 9.. Bennett, Manager, Training
- J. Ballard, Operations Consultant
- D. Parks, Manager, Nuclear Materials R. E. Sheeran, Manager, Accountability and Security J. Vollaro, Supervisor, Radiation Protection and Industefal Safety K. Hayes, Industrial Safety Specialist R. Klotz, Criticality Safety Specialist
- Denotes those present at the exit interview.
The inspector also interviewed other licensee employees during the inspection.
2.0 Review of Operations The inspector examined selected areas of the 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, adherence to fire protection rules, and the status of deployment activities.
2.1 Deployment Activities Through discussions with licensee representatives, the inspector determined that all pellet fabrication processes involving the use j
of uranium oxide powder in the Pellet Shop were discontinued on December 23, 1989.
Since that time, the licensee initiated the removal of equipment used for these processes.
It is the licensee's intent to redeploy equipment such as dewax and sintering furnaces and pellet grinders to the new pellet manufacturing facility located in Hematite, Missouri. Other equipment such as glove boxes, hoods and blenders were being removed, cleaned, cut up, packaged and sent to a contractor for decontamination and disposal.
Disposal will be subsequently accomplished through decontamination such that the material can be released for unrestricted use or by burial at an approved burial site.
Equipment which, in the opinion of licensee personnel, cannot be decontaminated, will be packaged and sent directly to an approved burial site.
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During examination of the deployment activities, the inspector observed an individual cutting angle iron support structures with an electric reciprocating saw.
The individual was wearing a breathing zone air (BZA) sampler but not a t espirator at the time. Through discussions with licensee representatives and a review of procedures, the inspector determined that a similar saw was being used to cut sheet metal from contaminated glove boxes and hoods.
However, the written procedure only required these surfaces to be cleaned to "less than 10,000 dpm/100 cm2."
The inspector questioned the licensee's practice of cutting contaminated surfaces in this manner without the use of t
respiratory protection. The licensee stated that they had not identified any instances of elevated contamination levels in breathing zone air results during this operation and therefore, did not require the use of respirators. The inspector requested the licensee to re-evaluate t W use of respiratory protection during cutting operations r
since the BZA results only provide after-the-fact in nrmation. This was identified as an Inspector Followup Item (1100/90-02-01).
During a review of the contaminated metal packaging operation, the inspector observed measurements beti.g taken to determine the uranium-235 content. An alpha survey instrument was placed at 30 selected locations randomly on the table upon which the scrap metal was laid out The average contamination level in counts per minute of the material placed on the table was determined from these measurements. This average value was converted to disintegrations per minute and then to grams of uranium-235 on the table. However, it was noted that the inside surfaces of small diameter pipes were not measured and therefore, a portion of the potentially contaminated surfaces was not measured.
This was discussed with licensee representatives who indicated that l
these measurements were not " key" measurements as defined by the facility l
" Fundamental Nuclear Material Control Plan" and therefore, the errors l
associated with these measurements would not significantly effect the nuclear material accounting measurement errors.
This was also discussed l
with NRC-NMSS Safeguards licensing personnel who agreed with the licensee.
l In addition, NRC licensing personnel indicated that there was no regulatory l
basis to require the licensee to conduct more extensive measurements.
2.2 Building 21 Housekeeping During examination of the Building 21 Warehouse facility, the inspector noted that egress from the west end of the building was hampered for emergency purposes.
The licensee had stored material handling equipment and located work tsches such that they partially blocked most of the east-west aisles in the building.
Licensee representatives stated that the equipment would be moved to allow free egress from all areas of the building.
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2.3 Building 5 - Nuclear Laboratories During examination of the Nuclear Laboratories, the inspector observed that siv of the laboratories were posted with signs indicating that they w ' " temporary controlled access areas". Those laboratories were P wiously not posted. The signs also indicated that these laboratories were being maintained as part of previously established
" criticality control areas".
Through discussions with licensee representatives the inspector determined that the " temporary controlled access areas" were defined in the facility security plan and they were established to provide control of, access to, and storage of, small quantities of U-235 in these laboratories.
Similarly, the extension of the previously established criticality control areas to these laboratories was accomplished to authorize the use of these areas for work on U-235 bearing materials without imposing the requirements for the preparation of transfer documents for the movement of U-235 from area to area.
The inspector verified that none of the criticality controls established in the license had been violated by the addition of these new areas.
2.4 Contaminated Wooded Area During examination of the contaminated wooded area located to the west of Building 2, the inspector observed that part of the barrier fence aloag the roadway had partially collapsed. This fence prevented personnel on the roadway from entering the contaminated area. This was discussed with licensee personnel and the fencing was immediately strengthened to preclude collapse.
Licensee representatives stated that they were still awaiting soil sample analytical results prior to completion of the area characterization study. An attempt had been made by the licensee to correlate survey meter readings with uranium content of the soil.
This attempt was unsuccessful and therefore, the licensee continued to analyze soil samples to determine the uranium content. At the exit meeting the inspector once again requested the licensee to provide the NRC wito a status repurt subsequent to the project time that the project was discontinued for the winter.
This request was previously made during inspection 70-1100/89-07 and had not been completed by the licensee since the characterization study had not yet been discontinued for the winter.
This status report was expected to contain information on the results of the characterization study, decontamination plans and procedures, and a projected co,npletion date.
This was previously identified as an Inspector Followup Item.
(1100/89-07-05).
3.0 Criticality Safety The inspector reviewed the licensee's criticality safety program document, PR-3, Revision 1, dated August 1,1989 and associated implementing procedures and instractions.
It was noted that the licensee issued the implementing instructions on September 25, 1989, subsequent to the Mid-SALP Review documented in Inspection Report No. 70-1100/89-80. The change / modification
5 program described in the criticality safety instruction CSI-1, Revision 0, dated August 25, 1989 requires the Senior Criticality Safety Specialist to independently review and approve the Change / Modification Request (CMR) after the Criticality Safety Specialist completed the evaluation and established the required limits.
However, it was noted tnat none of the documents indicated that each individual employee was responsible to follow procedures and/or halt an operation if it was not covered by precedure or if safety was in doubt.
An unresolved item with regard to the conduct of criticality safety analyses on the interactions between fuel rod transfer turret carts placed in an array perpendicular to each other was previously ident5fied during inspection 70-1100/89-07.
This was discussed with the criticality safety specialist during this inspection.
That individual indicated that those interactions had been evaluated, however, that evaluation was not recorded.
Subsequent tu this inspection, the inspector determined that the licensee's failure t
to record this evaluation was an apparent violation of Section 2.9 of the NRC-approved license application which states that records pertaining to health and safety, facility modifications, abnormal occurren:e, criticality analyses,... are retained to demonstrate compliance with the conditions of this application and the applicable Federal, State and Local regulations.
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In addition, Section 4.1.5 states that all process / equipment / facility changes
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shall be reviewed and approved in writing. (1100/90-02-02) 4.0,P,;yyentive Maintenance Program I
The inspector examined the licensee's document PR-17, " Preventive Maintenance Program", Revision 0, dated June 26, 1989, which described the licensee's program to 6ssure manufacturing equipment operability. This program, administered by the licensee's Manufacturing Engineering group, is a computerized tracking mechanism which includes the schedules for the maintenance activities for each piece of equipment, and is used to maintain records of maintenance condacted in order to develop a maintenance history on each major piece of equipment.
Through a review of records and discussions with licensee representatives, the inspector determined that the licensee had established a process and system to assure that equipment and machinery within the fuel manufacturing j
facility were properly maintained on an established schedule. The equipment covered by this program included instrumentation and controls, electrical, l
hydraulic, mechanical and pneumatic systems.
The inspector noted that the Building 6 liquid waste discharge control systems and the Building 5 Development Laboratory machine shop equipment had also been added to the i
preventive maintenance program.
However, the inspector observed that the licensee should also consider the addition of the Building 5 Ceramics Laboratory equipment to this program.
Licensee representatives stated 1
that this equipment would be added to the preventive maintenance program, i
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As a result of this review the inspector determined that the licensee had established a viable preventive mairitenance program which, if followed, should provide reasonable assurance that the manufacturing equipment and I
safety related equipment (e.g., ventilation systems) would continue to be operated in a satisfactory manner.
5.0 Industrial Safety Program The licensee's industrial, hazardous materials and fire safety programs were covered in PR-10, " Industrial Safety", Revision 0, dated November 2,1989.
5.1 Industrial and Hazardous Material Safety Through a review of licensee records the inspector determined that the licensee had written a series of Industrial Safety Instructions (ISIS) which implemented the industrial and hazardous material safety program described in the PR-10 document.
These instructions cover such topics as eye protection, safety shoes, protective clothing, hazardous materials, equipment lock and tag procedures, confined space entry and hot work permits.
The instructions reviewed by the inspector appeared to be comprehensive and covered all major areas of the industrial safety program.
5.2 Fire Protection Although the PR-10 document provided a basis for an adequate fire protection program, the inspector determined through a review of records and discussions with licensee representatives, that no implementing instructions had been written with regard-to the licensee's fire protection program.
However, the inspector was informed by licensee l
representatives that fire safety program implementing instructions were scheduled to be written, reviewed, approved and issued by about May 1, 1990.
This was identified as an Inspector Followup Item (1100/90-02-03).
Through discussions with maintenance personnel and a review of licensee records the inspector determined that weekly, monthly,-
quarterly, semi-annual, and annual tests and/or inspections were scheduled and conducted on fire suppression system preaction valves, pressure regulators, heat detectors, sprinkler system alarms, post indicator valves, gate valves and wet and dry sprinkler systems.
In addition fire extinguishers are inspected reutinely as recommended by b
National Fire Protection Associated (NFPA) documents.
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6.0 Transportation Program The inspector examined the licensee's procedure manual which described the established program for the transportation of special nuclear material.
t This Manual Procedure Number MFG-16-51, dated July 13, 1989, covered LSA, limited quantity and fissile materials shipments, empty shipping containers, hazardous materials, and receipt of radioactive materials.
It also covered shipping paper requirements, waste manifests, and marking, labeling and placarding of containers and vehicles.
Through this review, the inspector determined that the licensee only included the U.S. Department of Transporta-tion requirements in this document. As a result, it was determined that the document did not contain all of the requirements specified in 10 CFR Parts 20, 61 and 71 with regard to Packaging Quality Assurance, Part 61 i
waste requirements, Part 20 waste manifest requirements, and Part 71 routine determinations, initial use of packages, or authori7.ed user and package i
licensing requirements.
Licensee representatives responsible for the facility transportation requirements stated that the procadure manual would be modified accordingly. This was identified as an Inspector Followup Item (1100/90-02-04),
7.0 Emergency Planning Program Audits Through discussions with licensee representatives, the inspector determined i
that the licensee had not conducted any internal or external audits of the site emergency planning program.
However, a special review of this program was currently being conducted as a part of an internal self-assessment which was requested by NRC Region I management. This self-assessment will be used as input to the NRC Systematic Assessment of Licensee Performance (SALP) process which will be conducted by the NRC during the Spring of 1990.
The inspector also determined through discussions with licensee representatives that licensee personnel ;onducted a review and inventory of emergency planning equipment on February 6, 1990.
No inadequacies were identified.
8.0 Facility Review Group Through discussions with licensee representatives, the inspector determired that the licensee had initiated actions to establish the new Facility Review Group (FRG) authorized by Amendment No. 15 dated October 4, 1989.
The FRG was scheduled to meet quarterly to review safety related operations and to provide recommendations to the Plant Manager.
The review was to include safety-related practices and trends, adequacy of emergency planning, effectiveness of the AL/.RA program, inspection and audit reports, abnormal occurrences and accidents and related corrective actions, and any proposed facility or operational changes involving riuclear criticality or radiation i,a f e ty.
8 During this inspection, the licensee announced the members of the FRG.
It was noted by the inspector that the chairman of the group, although qualified to fill the position in accordance with the licensee's specified criteria, did not have any " hands-on" fuel fabrication experience.
In addition, neither of the individuals assigned to cover nuclear criticality nor radiation protection were qualified to conduct reviews or evaluations in those areas. As a result, during the exit interview the inspector commented that licensee management consider the addition of personnel to the FRG who had demonstrated expertise in radiation protection and out-of-reactor nuclear criticality safety matters.
Licensee representatives stated that this comment would be considered ar.d personnel on this committee will be modified if appropriate.
9.0 Training The inspector examined the licensee's training program as described in the e
program document PR-11 "NFM Training", Revision 0, dated December 14, 1989.
In particular, training requirements with respect to unescorted visitors (NRC inspectors, power plant personnel, vendors) were reviewed. The training program contained adequate information with respect to industry-wide j
radiation protection and emerCency planning requirements. The inspector determined that the Nuclear Fuel Manufacturing (NFM) training program document did not include requirements to assure that visitors who had been trained at other nuclear facilities were provided with site specific training such as site limits on radiation levels, contamination levels, response to fire and criticality alarms, sounding of emergency alarms, and location of emergency response assembly points etc.
However, the inspector noted during a recent training session that, in practice, the licensee was providing this information to these individuals.
Licensee representatives stated that site specific training requirement for previously trained individuals would be incorporated into the training program document.
10.0 Management Controls During this inspection the inspector examined the licensee's implementation of program documents which were written to cover the following management policies, procedures, and controls.
10.1 policy Statements In the initial SALP Report No. 70-1100/86-99 it was noted that the licensee had not issued a written policy statement to indicate a management commitment to safety.
Subsequent to the SALP a policy statement was written and issued by the incumbent President of the Combustion Engineering Nuclear Power Businesses and reiterated by the Vice President-Nuclear Fuel on November 20 and 23, 1987, respectively.
These statements were subsequently incorporated into the CE Nuclear i
Fuel Integrated Improvement Program document, Revision 0, dated October 19, 1988.
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9 During this inspection, the inspector requested documentation that these policy statements and implementing documents had been issued to the workers in the nuclear fuel fabrication facility for their use and information.
No such docueentation was supplied to the inspector.
This was discussed at the exit interview, Licensee representatives stated that the requested statements had been incorporated into an employee handbook which was soon to be released.
The inspector was also informed that the handbook release date had not yet been determined.
Therefore, the inspector determined that these management safety policy statements were not routinely available at the time of this inspection to all nuclear fuel facility personnel.
10.2 Audits and Inspections In the SALP Report No. 70-1100/86-99 it was noted that the licensee had an ineffective internal audit program and conducted no it. dependent audits of the radiation safety, criticality safety, fire safety, or emergency planning programs. As a result, recommendations were made for the licensee to establish an independent audit program, conduct self-assessments and develop an internal audit program.
During this inspection the inspector reviewed the program document PR-22 " Audits, Inspections and Surveys", Revision 0, dated June 21, 1989.
That document provided the licensee's staff with guidann for the conduct of appropriate internal inspections and audits except with regard to the emergency planning and fire protection programs which were not addressed.
In addition, the audit program did not provide for ongoing self-assessments other than the two mandated by the NRC, and no plans were made to assure the conduct of independent audits on an ongoing basis by independent persons outside the CE Nuclear Power Businesses group, 1
10.3 Document Control As part of the Nuclear Fuel Integrated Improvement Program, the licensee committed to review and upgrade, as necessary, all written instructions i
to workers.
These instructions were contained in " Operations Sheets" l
and included appropriate radiological protection, criticality; safety and industrial safety requirements.
The inspector examined the licensee's program documents: PR-18, Revision 0, dated June 20, 1989, " Procedure Consolidation / Improvement"; PR-19 Revision 0, dated August 23,1989, " Document Configuration Management";
and AP-12, Revision 0, dated November 13, 1989, " Safety Related Documents".
As a result of this review, the inspector determined that the licensee i
had established a viable procedure / document control system for safety related documents which contained all of the appropriate control i
processes, inspection and audit requirements.
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However, none of these controls appeared to be applicable to any of the operating instructions (Operations Sheets) supplied to workers except for those instructions concerned with waste management.
Document AP-12 defined only the waste management operations sheets as safety-related documents which required review and approval by safety professionals such as the Manager, Radiation and Industrial Safety, the Nuclear Criticality Safety Specialist, or the Industrial Safety Specialist. This was discussed at the exit interview. Management personnel indicated the discrepancy identified would be evaluated and corrected as appropriate.
10.4 Commitment Tracking System In SALP Report No. 70-1100/86-99 it was noted that the licensee had not established a formal mechanism to assure correction of noncompliance items or completion of other commitments. As a result, recommendations were made to establish a commitment tracking system.
During this inspection the inspector reviewed the program documents PR-21, Revision 0, dated May 22, 1989, " Commitment Tracking", and AP-9, Revision 0, dated July 31, 1989 " Commitment Tracking".
PR-21 was written as the program document which describes the commitment tracking system and AP-9 was written as the implementing document which describes the methods used to track the commitments made.
Through a review of these documents, the inspector determined that two types of commitments are tracked, those made to the NRC and others made internally to licensee management.
The licensee's Nuclear Materials Licensing group was charged with tracking commitments made to the NRC and fuel manufacturing facility management tracked the other commitments.
The inspector noted throughout the review that the program documents had not addressed or established a single point of responsibility to assure that actions on all commitments were completed and each commitment was closed; no mechanism was established (e.g., review or audit requirements) to assure that each commitment was closed and verified; and no mechanism was established to assure that due dates were provided for each tracked issue. This was discussed at the exit interview.
Licensee representatives stated that each of the inspector's concerns would be reviewed and actions taken as appropriate, t
10.5 Abnormal Event Occurrence Reporting As part of the Nuclear Fuel Integrated Improvement Program, the licensee committed to establish a system to review, investigate, and correct abnormal occurrences.
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Il The inspector examined the 'icensee's program document AP-1, Revision 0, dated April 17, 1989, " Abnormal Event Occurrence Reporting Procedure".
This procedure provided guidance to licensee employees with regard to the conduct of an investigation, the determination of root causes, and the establishment of corrective action programs to eliminate the root causes.
The inspector determined that this procedure appeared to be appropriate for the review of abnormal occurrences.
11.0 Exit Interview The inspector met with the licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection on February 16, 1990.
The inspector summarized the scope and findings of the inspection.
The apparent violation concerning maintenance of records of a criticality evaluation was identified telephonically by the inspector to the Program Manager, Radiological and Industrial Safety subsequent to the inspection on March 22, 1990.
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