ML20043B563
| ML20043B563 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 05/24/1990 |
| From: | Hooker C, Qualls P, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20043B562 | List: |
| References | |
| 70-1257-90-02, 70-1257-90-2, NUDOCS 9005300222 | |
| Download: ML20043B563 (15) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION V 1 -
Report No.- 70-1257/90-02 Docket'No. 70-1257
' License No. SNM-1227 Priority:
0 Category: ULFF Safeguards Group: III
-Licensee:
2101 Hcrn Rapids Road Richland, Washington 99352-0130 Facility Name:
Advanced Nuclear fuels, Inc.,
Inspection at: 'Richland, Washington Inspection Conducted: April-16-20 and April 30 through May 4, 1990 Inspectors:
@ [dp b S/~ #/90 C. A. Hooker, Fuel Facilities Inspector Date Signed L
bd.' o b "h S/~ 2 W9b i
P. P. Qualls, Reit: tor Inspector Date Signed c
Approved by: hib r/Mlec l
G. - P.
as, Chief D#te Signed i'
Emer nc. Preparedness and Rad gical Protection Branch L
Summary:
- Areas Inspected: This was a routine unannounced inspection of l'icensee action-g on previous inspection findings, radiation protection, criticality safety,
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operations: review, radioactive waste manager.ent, environmental-protection and
.emergencypreparedness.
The inspection also included extensive tours of the l
-licensee s-facilities.
Inspection procedures 30703,'92702, 92701, 83822, t
88015, 88020, 88035, 88045, and 88050 were addressed.
Resultti In the areas inspected, the licensee's programs ap) eared adequate to q
theaccomplishmentoftheirsafetyobjectives.
However, wea(nesses'were observed in the use of. half-masks Section 4.c), personnel survey requirements (Section 4.d),-control of contaminated equipment (Section 4.d) and fire' safety p
(Section5).
No violations or deviations were identified.
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DETAILS
' ' IL Persons Contacted A..
Advanced Nuclear Fuels (ANF)
- R. G. Frain Vice President P
- W.E.Stavig,, Manager, Safely,lantOperationsSecurity and Licensing
- C. W. Malody, Manager, Regulatory Compliance
- T.- W. Patten, Manager, Plant Operationt
- D. C. Lehfeldt. Manager, Operations Planning and Scheduling i
- T. C. Probasco, Supervisor, Safety' Specialist Safetv L' D.- Gerrald, Crf ticality
- J. E. Pieper, Health Physics Specialist
'*E. L. Foster Radiological Safety Specialist bl. G, Hill, deneral Supervisor, Cnemical Operations L. D. Weaver, Supervisor, Waste Operations
- Denotes those a m nding the exit interview on May 4, 1990, t
In addition to the individuals noted above, the inspectors met and held
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t discussions with other members of the licensee's staff.
2.
' Followup:of Licensee Action on_ Violations (92702)
Item 70-1257/90-09-03-(0 pen).
This item involved the failure to adequately evaluate bioassay measurements.
The -insaector verified that effective immediate interim corrective actions had Jeen implemented to prevent recurrence as stated in~the licenseefs timely-letter dated March 23, 1990.
These corrective. actions were also described in inspection-Report No. 70-1257/90-01. However, the ricensee's long term corrective
-actions,tincluding an amendment-to the license,'had not been finalized.
This matter will remain open until the licensee s long term corrective actions have been implemented.
3.
Followup of Licensee Action on Open Items (92701) x Item 70-1257/90-01-01(Closedj. This item involved the need to r.eview the licensee's evaluation of the intakes of ten individuals-that had urine sample measurements between 10 micrograms uranium per liter (ug U/L) and 25 ug U/L.
Th-a licensee's evaluations concluded that none of the individuals involved had' intakes that exceeded the 40-hour 10 CFR 20, Appendix B, Footnote'4 limit'for low enriched soluble uranium and/or the 10 CFR 20.103(a)(1) limit for nontransportable uranium.
The inspectors m
independently. verified the licensee's conclusions and had no further j
questior.s regarding this matter.
Item 70-1257/90-01-02 (Closed). This item involved the need to review the iicensee's uranium lung counting program.
The review of the licensee's program is described in Section 4.b below.
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14.
Radiation Prctection (83822)
The inspectors examined the licensee's program-for compliance with the requirements of 10 CFR Parts 19 and 20, License Conditions, licensee procedures and recommendations outlined in various industry standards.
e a.
External Exposure Control l
Personnel monitoring was primarily based on thermoluminescent dosimeters (TLDs) processed by a local National Voluntary 9
Accreditation Program certified contract vendor.
TLDs were processed quarterly for operations personnel and individuals that often frequented areas where external radiatlon exposure was likely
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to be received.
TLDs were exchanged annually for personnel with low Y
exposure. potential.
Vendor reports for TLDs processed in 1989 were reviewed. Whole body radiation exposures a)peared to be minimal.
As noted in the licensee's 1989 annual 10 C R 20.407(a)(2) report, r
of 406 personnel-whom personnel monitoring was provided, one-individual received an exposure in.the range of 0.50-0.75 rem; 7 individuals were in the range of 0.25-0.50 rem; 64 individuals were i
in the range of 0.10-0.25 rem 210 individuals were less than 0.10 rem; and 124 individuals had n;o measurable exposure.
About 2795 single chip TLDs for office and visitor personnel were also processed, with no exposure exceedin The individual wi.th the highest exposure (0.54 rem)g 0.060 rem.was primarily involved w
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work activities in the licensee's primary powder storage area.
The i
L licensee was noted to.be evaluating methods to lower t11s individuals exposure.
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.The licensee also performed an annual evaluation of selected workers extremity (hand) exposures that performed tasks where hi exposures were most likely to occur-(e.g. waste handing,gherpellet L
Hf aress, pellet grinder, pellet inspection rod loading and uranium 1exafluoride cylinder washing).
Theevaluationswereperformedby correlating TLD finger rings results to the best estimate of actual E
time they were worn by the worker. The licensee's 1989 evaluations p
indicated that hand exposures ranged from about 0.140-1.224 rem per quarter, with fuel rod loading being the highest.
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The. inspector verified that form NRC-5 or-equivalent for each l'
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individual were maintained in accordance with NRC requirements.
The inspector noted that no individual had exceeded the limits specified D
L in30CFR20.101(a).
Letters documenting exposures pursuant to 10 l: "
CFR 19.13 had been expeditiously prepared and sent to individuals
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that had terminated.
b.
InfernalExpsureControl n y' R-Inspection Report No. 70-1257/90-01 documented the review of the gg "
licensee's urinalysis and air sampling programs.
This inspection (70-1257/90-02) focused on areas not covered in the previous inspection
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(1) Based on a review of urine sample data and licensee action on positive urine sample measurements, since the previous l,-
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3' inspection, it appeared that the licensee was performing adequate evaluations to assess workers intakes of uranium,
.There were no indication that any individual had intakes that exceeded the 40-hour 10 CFR 20, Appendix B, Footnote 4 limit for low enriched soluble uranium or the 10 CFR 20.103(a)(1) limit for nontransportable uranium.
(2) Routine annual and special lung counts are 1erformed by a local contracted laboratory.
New employees that lave previously worked with radioactive materials, and contract workers that may be required to wear respiratory protection are lung counted when hired.
All personnel are lung counted upon-termination of' employmentand/orcontractjobsasappropriate.
Lung counts of-workers were also performed to augment investigation of uranium uptakes when urine sample measurement indicated a need for further evaluation.
The Minimum Detection Level (MDL) for a 50 minute lung count was about 0.11 nanocuries (nCi) for U-235.
Individuals with confirmed positive lun
. months. Weekly urine g counts were recounted within twosamples wer L
were conducted when an individual's lung counts exceeded 0.16-nCi U-235 or had two consecutive positive lung counts.
Work-restrictions were considered when if an-individuals lung count L
exceeded 0.43 nCi U-235.
A review of lung count measurement.
data from January 1,1989, through A)ril 1990, indicated that no individual had exceoded 0.43 nCi J-235.
One individual,
-that worked-in the pellet press area, had several positive lung.
counts that fluctuated from about 0.121 to 0.218 nCi U-235.
It was noted that the licensee had been investigating this case during the last several months, without being able to determine tie cause or make an assessment of the individual's F
L intake.
The investigation, among other things, included more frequent urine sampling, observations of worthabits, and the Fixed air sampling 1
use'of a p(ersonnel la)el sampler (PLS).FASSs) in t1e area had not ind l
stations concentrations that would result-in the observed lung count it was the inspector'gh the licensee was evaluating this case, measurements.
Althou s perception that the licensee-needed to y*
be more aggressive in determining this individuals intake.
t This matter was also discussed at the exit interview on May 4, L
1990.
The licensee's evaluation regarding this individuals L
bioassay measurements will be examined in a subsequent L
inspection and is considered as an open item (70-1257/90-02-01).
L (3) Excluding stack and duct samaling, the licensee maintained about 215 FASSs throuahout t1e facility.
The sampling heads, with attached flow meters, were connected to a central vacuum system which maintained a continuous sample flow rate of about 60 cubic foot per hour.
Routine samples were changed shiftly, daily and weekly, depending on the work activity being evaluated.
Samples changes were conducted more frequently during certain maintenance activities, equipment clean-outs,
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ik,y o)erating perturbations and when samples indicated a higher
.tian the normally expected air activity.
Air concentrations of uranium above the licensee's design guide (1.0 E-11 uCi/ml) were reported to the operations manager and safety supervisor
- weekly, Air concentrations above 1.6 E-10 uCi/mi were reported immediately to the responsible shift supervisor, e
Approximately'6000 samples per month were being counted utilizing four surface barrier detector counting systems.
The detectors were arranged side by side so that four sam)1es could be-manually insertea and counted at.the same time. T1e -
licensee had established a typical minimum sampling time of two hours that allowed for a lower limit of detection (LLD) of about 5.8 E-13 microcuries per milliliter (uti/ml).
The LLD-for an 8.0 hour0 days <br />0 hours <br />0 weeks <br />0 months <br /> sample was approximately 1.5 E-13_uti/ml.
Daily source checks and background counts were performed on each counter, Source check data were plotted on control charts that were generated from quarterly Chi-square tests.
The licensee had acquired a new automated counting system that was M ag tested and evaluated for future use.
y The use of PM s was noted to be very limited.
The licensee was down to three functional PLSs with sixteen units on order.
The primary usee af PLSs were to evaluate the effectivenass of new-FASSs new i m ities, special evaluatinns of selected indiv} duds @;. had repeated positive u oassay measurements and chemical monitoring.
Data from routine and non-routine routine air sampling since the previous inspection were reviewed.
There were no indications of workers being exposed to intakes of radioactive material which would exceed the 40-MPC-hour control measure-
-requiring an evaluation pursuant to 10 CFR20.103(b)(2).
The air sample data indicated that workers exposure from airborne activity from routine operations was being maintained ALARA.
The inspector also noted that the licensee conducted and.
documented annual reviews of air sample locations.
During facility tours the inspector observed that engineering controls to contain loose radioactive material were evident.
c.
Respiratory Protection Although the licensee claimed no credit for respirator use, the respiratory program was reviewed,ing included initial and annualincluding att protection-training class.
Train refresher training on the use and types of respiratory protection equipment for protection against radioactive materials chemical and other non radioactive hazards.
Itapperndthatthellcenseehad available an adequate supply of equipment for routine and unexpected use.
Individuals performing maintenance on respiratory equipment had received specialized training for the tasks being performed.
The inspectors observed that the licensee had installed and was testing a new computerized system designed to perform a full system
-test on self contained breathing apparatuses.
Respirator fit i
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testingIviduals that were medically qualified to wear respiratoryfor full-face and hal for ind protection equipment.
The safety supervisor informed the inspectors
- that equipment was available for quantitative fit testing however,
-there were not adequate facilities for installing the equ pment.
The safety supervisor also informed the inspectors that t ey were considering-having _the fit testing done by a local contract laboratory. The inspectors discussed the advantages of performing quantitative fit tests.
The licensee had completed the installation of a new breathing air system (BAS) in the Uranium 0xide (UO ) Building in August 1989.J
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9 The licensee previously used bottled air in this area.
The new BAS, which received air from the licensee's oil-less. service air compressors, was equipped.with equipment designed to supply Grade D breathing air.
The BAS was observed to be equipped with the appropriate air quality monitoring and alarm devices and a oedicated air receiver tank.
Breathing air outlets were equipped with quick disconnect hose fittings that were'only compatible with the BAS and -
respirators being used.
Spare BAS quick disconnects were maintained and issued by the safety supervisor.
The licensee's facilities for issuance, collection and decontamination of respirators were located in the Health Physics Technician-(HPT) office.
Durin the April 16-20 1990, period of the-inspection,theinspectorobservedthatalistingofindividuals qualified'to wear respirators was maintained at the issuance station.- Respirators were issued by the HPT; however, no issuance records were maintained.
Although the licensee did not take credit for respirator use, the inspector discussed the advantages maintaining an issuance record. During April May 4,1990 the inspectors noted that on April 24, 1990, thelicenseehadinstituted.
the use of a respirator issuance log.
The' inspectors noted that the licensee's facilities for decontamination, sanitizing and drying of respirators appeared to be very' limited.
Respirators were decontaminated and/or washed in the same sink used for
' decontamination of personnel and/or low level contaminated -
equipment.
The HPTs informed the inspector that the sink was surveyed prior to use for respirator cleaning, and each respirator was surveyed prior'to being being bagged for reuse.
Respirator drying was performed with a fan blowing air across a small rack of respirators placed on a chair near the decontamination area.
The inspectors discussed the potential for cross contamination of clean respirators,ility with the safety supervisor.and advantages of having a dedicated cleaning fac These matters were also discussed at the exit interview.
The inspectors observations E
were acknowledged by the licensee.
The inspectors observed that half-masks were wioely used by operators and other workers.
10 CFR Part 20, Appendix A, footnote g requirus, in part, that half-masks be tested for fit with irritant smoke, prior to use, each time it is donned. The inspectors noted that such tests were not conducted by individuals that used half-masks.
The licensee's training and procedures delineated the fU s
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neg.itive pressure check method.
On several occasions, the
' inspectors observed individuals not performing the pressure test when they donned a mask for use.
Several individuals were also observed pulling half masks-from their faces to have conversations with a co-worker while in an area where respirators were required.
Fortuitously, the licensee did not take credit for respirators.
Although the licensee did-not take credit for respirators, the inspectors discussed.these improper practices with cognizant licensee representatives.
The inspectors were informed that half-masks were primarily used for ALARA principles and not for tasks that high air concentrations were expected,.here full-face-
. respirators were required.
The inspectors informed the licensee that if a respirator was used by a-worker, it should be properly used by the worker at all times, and that observed positive bioassay.
measurements could be indicative of im) roper use of the half-mask.
These matters were also discussed'at t1e exit interview.
The inspector observations were acknowledged by the licensee.
d._
ControlofRadioactiveMaterialsadSurveys During facility tours, the-inspector observed that adequate operating. personnel survey instruments were conveniently located at-exits from contaminated areas.
Workers were observed to be dressed in ?rotective clothing as specifled on their radiation work permits, wit 1 the exception in a limited number of examples, where the inspectors observed that individuals were not always timely with donning plastic gloves.
This matter was brought to the licensee's attention during the-inspection and at the exit interview.
The inspectors also observed that, for routine operations, operators were not required to wear head covers (caps or similar protection) for protection against head or hair contamination.from work activities on upper ficor levels, and/or contaminated overhead piping or other structures they could brush against. The inspectors encouraged the licensee to consider the use of-head coverings by all
. workers in these areas.
During facility tours, the inspectors observed that personnel 4
surveys performed by many of the individuals exiting the controlled l-areas primarily consisted of checking their hands and shoes.
4 Although the licensee's radiation safety training provided i
instruction for more detailed personnel surveys (e.g. face, neck, hair, wrists and shoes), the licensee's procedures basically only li
. stated that personnel were required to perform a survey when exiting L
a contaminated area.
The inspectors discussed this matter with the L
safety supervisor during the inspection.
The safety supervisor informed the inspectors that the HPTs randomly surveyed groups of workers at shift changes, and no personnel contaminations have been detected due to an inadequate worker survey, The safety supervisor also informed the inspectors that the company was considering the installation of whole body persor.m' contamination monitors, which 4
would be used in addition to the ir aking stations.
Personnel contamination reports indicated that as of January 1,
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1990, only about 11 personnel contaminations. had been recorded.
The s
a inspectors also noted that urine samples were obtained when facial and or nasal contamination was detccted.
The contaminations were noted-to be primarily related to operating or maintenance incidents.
The inspectors observations of the appearance of minimum personal surveys performed by the workers was also discussed at the exit Linterview.
During facility tours the inspectors made independent radiation measurements-using an Eberline R0-2 S/N 2694 due for calibration onJuly3,1990..Thetoursalsoincludedamajorportionofthe g
licensee s waste storage-yard.
The inspectors noted that radioactive materials and radiation areas vere posted in accordance1 with the requirements Jelineated in 10 CFR Part 20.
During tours of the yard areas the inspectors made the following additional observations:
OnMay1,1990}uoride(pectorsobservedthatapanelontheUF ) cylinder hydro the ins (1) uranium ~hexaf 6
.had been removed and sat aside.
The cabinet and inside plumbing were posted with labels indicating internal system and fixed external contamination.
A dria pan, with a corrosion hole at one end, contained residue t1at appeared to be from leaks in the system.
At the inspectors request,'the licensee performed a survey of the residue.
The licensee s surve indicated about 3.0 E5 disintegrations per minuto (dpm)/y10g b
2 square centimeters (cm ) fixed and about 5.0 E5 dpm/100 cm loose thorium contamination, which was considered as State licensed material.
There was no indication of special nuclear material contamination.
No contamination was detected on the ground area below hole in the drip pan.
The' licensee replaced-the panel-and means to seal the hole were being evaluated.
.The inspectors also observed that the licensee was in.the process of posting off thir, outside area as having potei.tial scrface contamination, for upcoming UFPrevious testing has resulteb cylin lydro-testing testing.
in ground area contamination that had to be removed'by the licensee. The contamination has primarily been due to residual radioactive thorium t"t remains in the cylinders and occasional leakage during tb-testing.
The licensee was aware of the potential radiolog m risks associated with conducting these tests in an open out:.
area.
(2) On May 1, 1990, the inspectors observed four centrifuge bowls in a clean scrap metal collection bin near the Zimmmer Warehouse. The inspectors removed the caps from these units to visually inspect the insides. The inspectors noted a very small yellow stained spot on the inside of one of the caps, and a similar spot on a separator vain from another unit.
Subsequent surveys of these units indicated very low levels of fixed alpha and beta contamination from the spots, with no contamination detected on the remaining inside or outside surfaces.
Apparently these units had been previously released
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from the controlled area several months ago for possible repairs,-and disposed of by the maintenance department when it was determined t1at repairs were not feasible.
Although the contamination levels were determined to be within release limits specified in Part I, Appendix A, of the License;-
cognizant licensee representatives stated that it was desirable to ensure that no. items with detectable radioactive contaminated be released for unrestricted use, and the yellow stains should have been observed and removed during the initial release survey.
(3) On May,3, 1989, the inspectors observed a several small piece of equipment in a clear plastic bag-in a clean scrap metal collection' bin, near the back entrance to the Engineering-Laboratory Operations (ELO) Building.
The scrap metal bin was also located near a labeled radioactive materials collection container.
The inspectors also observed that the bag contained several green plastic gloves,.which are commonly used in the controlled areas, and what ap? eared to be a vacuum hose with a small radioactive label attacled.
The licensee immediately performed a cursory survey of and removed the bag from the scrap bin for further evaluation.
Subsequent surveys of the bag contents indicated the presents of low level beta contamination on ore item in the bag that appeared to be within the licensee's release limits.- The licensee was also investigating the souw e of the bag.
In regard to observations (2) and (3) above, the licensee stated that all clean scrap metal bins were inspected and surveyed prior to being released from the site.
Although the inspectors did not identify any direct violation of NRC requirements, the' licensee's apparent lack of attention to detail was discussed during the
. inspection and at the exit inteiview.
The inspectors observations were acknowledged by the licensee.
Based on review of survey records,.the inspectors noted that the licensee' routine radiation-and contamination survey program of plant areas appeared to be ccasistent with Part I, Section 3.2.6 of the_ License.
The licensee's overall performance in this area seemed adequate. However, weaknesses'were identified in the use of half-masks, personnel survey requirements and the control of contaminated equipment. These matters were discussed in detail with cognizant licensee management during the inspection.
The weaknesses may also be indicative of limited staffing ct HPTs.
Based on cbservations during the inspection, it appeared to the
- insp*:tm that the HPTs were primarily occupied with normal routine activities and had very.little time for evaluating work activities or policing the facilities. The inspectors were informed by licensee management that ANF was in the process of contracting for an independent evaluation of their radiation safety program.
No violations or deviations were identified.
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Criticality Safety (88015)
The insaectors reviewed the licensee's program for compliance with the of 10 CFR- ) art 70, License Conditions, licensee procedures, and recommendations outlined in various industry standards.
The inspectors rev'iewed the following criticality safety analysis (CSA)-
that. had been performed since the last inspection of this' area:
(1) CSA No. PEL-8.0, for a pellet dissolver system in Room 52 of the ELO Building,-dated March 20, 1990.
This new system was designed to, dissolve U0 pellets in nitric acid to form a uranyl nitrate-nitric acid-water $olutionthatwillbetransferredtothe"GadScrap Recovery Process" in Room 53.
Room 52 had been previously used for the pilot operation for the removal-of uranium from the ash of contaminated incinerated combustibles..The new system was observed to be under construction during this inspection and will be revisited-during a future routine inspection.
dated April 16 1990 to change the administrative (2).CSANo.U-4.9,letetheinspeclionoftheuranylnitratehexahydrate controls to de
. UNH) area dissolver screens.
This CSA also involved changing the (permitted amount of material'in the feed screw hopper from a mass limit to a powder depth limit.
.(3) CSA No. PEL-9.0, dated April 6, 1990, for testing of an automatic rod loading system that was observed to be installed and operating in the lower level in the.ELO Building.
Each CSA had been performed by the Criticality Safety Specialist.
The
-CSAs appeared to be conservatively modeled for each condition in accordance with the licensee's procedures an requirements of the License.
The:second party reviews were performed by the Health Physics Specialist in accordance with the requirements delineated in Part I, Section 4.1.1
=of-the License..
the inspectors observed no unsafe criticality During facility tours,ticality control limits appeared to be safety practices.
Cn appropriately posted where special nuclear material was being processed,-
handled and stored.
Each storage container observed was lebeled with the enrichment and quantity of material.
Leakage from wet operations appeared to be minimal.
There had been no changes in the criticality monitoring system from that described in Part I, Clapter 1, Selection 1.6.1 of the License.
Bench top calibration of criticality detectors and overall system tests continued to be conducted annually and quarterly, respectively.
The licensee's performance in this area appeared adequate to the accomplishmentoftheirsafetyobjectives.
No violations or devir.tions were identified.
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6.
Operations Review (88020 This area'was-reviered to determine if operations were being conducted in accordance with the requirements of the license, licensee ?rocedures and recommendations outlined in various industry standards.
T1einspection r
of this area was.primarily based on observations made during facility tours.
There had been no significant changes in operations since the previous inspection.
Both chemical conversion lines were in full operation, and all three' powder ~ lines and pellet presses as demanded.
The Solid Waste Uranium Recovery (SWUR) Facility was in full operation, and the Neutron Absorber Facility was operating.
In the areas toured, the inspectors observed that (1) the exhaust.
ventilation systems appeared to be fully functional, (2) pressure drops across the main filters were within the limits specified in the license, (3) current air flow measurements were posted on exhaust hoods, and (4) housekeeping appeared adequate, except for the observations described below.-
During facility tours on May 2, 1990 the inspectors made the following
. observations regarding fire safety:
(1) A small. storage shed at the Lagoon Uranium Recovery Facility contained a large quantity of combustibles in mixed storage, which appeared to be a-potential-fire hazard.
5)ecifically, the shed contained; (1) about 15 gallons of-paint-tlinner, with some open containers prepared for use, that were not stored in safety-containers; (2) several drums of combustible sulfur based chemical,.
(3) a bottle of nitric acid; (4) a large amount of rags and plastic; t
and (5) an acetylene welding bottle was-stored against the outside wall.
Cognizant ~ licensee. representatives' acknowledged the
' inspectors observations, and took immediate actions to correct the problem.
(2) A large quantity of plastic wrapped HEPA filters were being stored in the U0 Building waste processing area near the line-2 calciner 2
and other associated processing equipment.
An acetylene gas bottle and other assorted combustibles were also stored in:the general area.
During the-inspection and at the exit interview, the inspectors encouraged licensee management to evaluate the need to establish a limit on the amount of combustible material in this area to ensure that an inadvertent fire would not have a signIficanteffectonthenearbyprocessingequipment.
The inspectors observations were acknowledged by the licensee.
The licensee's program appeared adequate to the accomplishment of its safetyobjectives.
However, it appeared that the licensee's staff should be more aware:of potential fire safety hazards.
No violations or deviations were identified.
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7.
Radioactive Waste Management (88035)
The-inspector reviewed the licensee's program for compliance with 10 CFR Part 20, license requirements and recommendations outlined in various industry standards.
There have been essentially no changes in the license's effluent waste program since the last inspection of this area.
The licensee's procedures were noted to be consisted with the r M irements delineated in Part I, Section 5.1 of the License.
a.
Liquid and Gaseous Effluents
~r Records-of liquid effluent sample measurement data and site discharge flows to the city sewage system from January 1, I M O, through March 30, 1990, were reviewed.
All results indicated that liquid effluent releases were well below the limits specified in 10 CFR 20.303.
The review of weekly gaseous effluent sampling data from the licensee's~15 stacks from January 1,ive materials were well 1990, through March p
30 1990 indicated that releases of radioact belowthelimitsspecifiedin10CFRPart20,AppendixB,TableII; and the reporting. level in Part I, Section 5.1.1 of the License.
The inspectors u ted that appropriate corrective actions, to determine the cause and correct the problem, were taken when a stack sample' measurement was closely approaching or had exceeded the action level of 5.0 E-13 uti/ml-alpha as required in Part I, Table 1-5.1 of the License.
The licensee's records for assuring the quality of counting and-uranium fluorometric measuring equipment were examined.
Routine testing for performance and efficiency were performed with standards-traceable-to the National Bureau of Standards.
Quarterly Chi-square tests and daily performance checks were being plotted to evaluate counting equipmc;ii r % snce.
Blanks and spiked samples from known standards ws when fluorometric analysis-were performed.
The inspectors indept.m atly verified that-the licensee's established lower lir'c of detection (LLD) for the counting equipment for gaseous effluent measurements appeared to be well below the concentration limits specified in 10 CFR Part 20, Appendix B, Tables I and II 'and 20.106.
The licensee's semiannual effluent report for the period of July 1, 1990, through December 31, 1990, dated January 15, 1990, was reviewed.
This timely report was submitted in accordance with 10-CFR 70.59 and provided a summary of the radioactive gaseous and liquid effilm ts released from the facility.
In regard to liquid effluent da..
the report contained apparent typographical errors.
.The re) ort
- ated that the concentration value for liquids was less t1an 1.7E-7 Ci/ml with an LLD of 1.7E-7 Ci/ml, when it appeared that the concentration should have been less than 1.7E-7 uCi/ml with an LLD of 1.7E-7 uCi/ml.
The licensee immediately prepared and subraitted a corrected effluent report, when this matter was brought to their attention.
No other errors or anomalies were identified.
The licensee's corrected effluent report dated April 25, 1990, I -f >
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,e o corrected the errors.
The effluent releases.were noted to be less than the limits specified in 10 CFR Part 20, Appendix B, Table II.
Inspection Report No. 70-1257/89-03 documented the same error % the l
' licensee's previous effluent report, and the licensee's. submittal of-a corrected report.
^
In regard to th'e licensee's reporting of effluent data, Inspection Report No.s 70-1257/ 88-10 and 89-03 discuss the licensee's aeporting of releases in terms of "less than" values although positive measurements are routinely observed in some measurements.
This matter was further liscussed during this inspection, in terms of the misapplication or the LLD; since a LLD is an a priori (before the fact) estimate of the measurement systems capabiTity and not as an a posteriori (after the fact)' limit for a particular measurement.
The inspector informed the licensee that it was the NRC's position
.that the results of the actual measurement observed be recorded and reported; The licensee's decision re reviewed in.a subsequent inspection. garding this matter will be 4
This matter is considered as anopenitem(70-1257/90-02-02).
b.
Solid Weste The licensee had made no waste shipments since the last inspection of this crea.
However, they had considerably reduced the number of
'55-gallon recoverable uranium waste drums being-stored in their outside storage yard.
During the last year the licensee has reduced l
the inventory of old drums from about 12,000 to about 6,600, through sorting and incineration of combustible materials at=the Solid Waste Uranium-Recovery (SWUR) Facility.
The' licensee expects that by the i
end of 1991, the backlog of old drums will be depleted.
The licensee had no immediate plans for the disposal-of non-combustible
. aste generated from the SWUR operations and/or other areas on site.
w The licensee informed the inspectors that a facility for decontamination and uranium recovery from contaminated non-combustible materials was being considered.
During this inspection, the inspectors also observed that the Lb licensee had received and were storing about 435 drums of recoverable uranium waste materials from an ANF plant in. Germany.
L ine licensee informed the inspectors, that these drums primarily contained protective clothing and other combustible materials contaminated with uranium.
The licensee ships low enriched uranium l
powder and f0el pellets to their German plant.
According to the licensee, the uranium contained in the waste drums was aart of their original product, and maintained on their inventory. T11s matter 3
wasalsodiscussedwiththelicensee'sNRClicensingproject manager.
l As of this inspection, incineration activities have generated about h
320 thirty gallon drums'of ash that are being saved for uranium-recovery.
The licensee informed the inspectors that the process for rr mring uranium from the ash has been well defined, and planned-to w e-facilities for ash processing during the 1992 and 1993 time L'.
frame.
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The licensee was observed to be in the tinal stages of testing their 4
HEPA. filter ~ cutting and compaction unit.
The licensee informed the inspectors that this new unit should be capable of processing 100 to 140 filters-per week.
The inspectors noted that the licensee was able to compact about 15 filter guts Sto a 55 gallon drum.
The wooden filter, frames were being chopped un for incineration.
Inspection Report No. 70-1257/89-03 descr'ibes the NRC's concerns regarding fire safety due to a vast number of used HEPA filters being-stored in the licensee's Packaged Radioactive Materiais Warehouse.
TheinspectorsverifiedthatthelicenseehadreceivedandreaddE Information Notice No. 90-09, " Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees".
The licensee informed the inspectors that since there was a disposal site in the local area, ANF did not consider the matter-a problem.
The licensee's program appeared adequate to the accomplishment of its safety objectives.
The repeated errors in the licensee's semi annual effluent report appeareo to be indicative of continued inattention to detail.
No violations or deviations were identified.
. 8.
- Environmental Protection (88045)
The inspectors reviewed the licensee's program for compliance with 10 CFR Part 20, license requirements and recommendations outlined in various industry standardt.
There had been essentially no changes in the licensee's program since the 1ast inspection of-this area. The licensee's procedures were consistent with the requirements delineated in Part I, Section 5.2 of the License for the type, number of samples and frequency of samples ~to be collected.
~
Environmental measurement data from January 1, 1990, through March 30, 1990, were reviewed.
Monthly sludge sample data, from the city. sewage processing facility, investigation action level of 25 picocuries per gram indicated that no measurements had exceeded the licensee's-licensed uraniem.
Monthly lagoon interliner sample data indicated nn leakage from the storage-lagoons.
The inspectors noted that the enviroirental monitoring data indicated that releases of radioactive materials to unrestricted areas were well below the regulatory limits.
The licensee's performance in this area appeared fully adequate to the
. accca;plishment of their safety objectives.
No violations or deviations were identified.
9.
Emergency Preparedness (88050)
The inspectors reviewed the liensee's implementation of their NRC approved Emergency Plan (EP) including; offsite support, training, emergency procedures, plant fa-ilities and emergency equipment.
Inspection Report No.- 70-1257/90-01 documented that the licensee had revised their EP to. clarify their Plant Emergency Response Team (PERT) b
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l trainingec! ram.- There had essentially been no other changes in the licenseek E since the last program inspection (70-1257/89-03).
The inspectors verified that the-licensee continued to maintain current agreements with the appropriate offsite emergency support agencies, as-identified in their EP.
The licensee's emergency call list was current, and was updated quarterly.
The inspectors verified that the type and locatfo, of emergency response equipment was maintained as specified in the EP.
The equipment ap
.to be well maintained, and as appropriate, operable and currently peared calibrated.
During facility tours the inspectors observed that emergency exits and pathways were adequately identifiable, and site evacuation appeared b an easy accomplishment due to the location and physical layout of the facility.
The inspectors also observed that fire extinguishers were inspected monthly.
4 The inspectors observed that the licensee continued to conduct PERT as
. delineated in the EP.
In regard to fire fighting, the licensee does not maintain any ma;or fire fighting equipment on site.
Fire fighting by the 1
licensee's staff and training has been limited small incipient fires.
Au per agreement,.the licensee relied on'tnc nearby Richland Fire Department, which can respond to onsite fires within six minutes of notification.
License performance in this area appeared adequate to the accomplishment oftheirsafetyobjectives.
No violations-or deviations 'were identified.
9.-
Exit Interview (30703)
The insaectors met with the licensee representatives, denoted in Section 1 at tie conclusion of the inspection on May 4,-1990.
The scope and fIndingsoftheinspectionweresummarized.
The observations described in the report were acknowledged by the licensee.
The licensee was informed that no violations or deviations were identified.
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