ML20043G534

Insp Rept 70-0036/90-02 on 900423-27.No Violations or Deviations Noted.Areas of Concern & Unresolved Items Identified.Major Areas Inspected:Comprehensive Review of Licensee Activities & Assessment of Mgt Organization

ML20043G534
Person / Time
Site:	07000036
Issue date:	06/13/1990
From:	France G, Mallett B, Scott Moore, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20043G527	List: ML20043G526 ML20043G534
References
70-0036-90-02, 70-36-90-2, NUDOCS 9006200402
Download: ML20043G534 (26)

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i JDocketLNo.I70-361 License No. SNM-33 5

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" Inspection At:'- Hematite!-Missouri n

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Nh0 Inspection' Team Leader: ' D' f J. Sreniawski,' Chief 4

Nuclear Materials' Safety

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b gn Ir)spect' ion Team Members: 'G.M.FrancehlII; d6 # po [ n.' Region III Date 4 +

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< 3 .S Office of Nuclear Materiala e' M .c i D. T* Safety and Safeguardsg ,2 o A_ (on rotation with i' 3egionIII/NMSS) .r. o a s pe p x e t I' Appro d By Bru e Mal e D., Chie [ A +Date. / J t Of Nuclear = Materials Safety _ Branch s o 's v, a .o.. q. ,W . 3.,, fa ' s;, 4 gy 1 m 6.a, y w W Inspection Summary ~ (' i, ye_ d

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i 7 it . 23-27,1990(ReportINo.~7'OOO36/9002[DRSS)) ~ .A y i 6 s Inspection' conducted April , 4, , Areas Inspected:, Special anncunceli team assessment of. facility requinspection .i ~P,"l. irements: p specified:in NRCiregulations,:1_icensE and licensee' conditions.L The $e ' 1 7, involved a comprdhensive revied of glicensee activities and; a safety assessment F; '(MC?2601) of the. licenseetperformance inf the areas'of, management,,organizationt ,)1 y,, y + t iQ: 's i gz 4 't i r 4 f 7 t. = I j

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i .- c a r ,r t gn ..g fy,. 3,( * + M P,_ Vand controis-(IP 88005);; radiation. protection (IP'83822); operations'rev.iew. ph 3 (IP 88020); radioactive waste management (IP 88035);. criticality safety' > l 3 i;p g/f.p - (IP-88015); and maintenance and surveillance testing (IP 88025). An OSHA, ..o i y'l b - inspector performed'an industrial safety assessment of plant operations. :The" " L) OSHA inspection report will be= forwarded from the St. Louis, Missouri, office 5.'. 4 ,;.of OSHAiunder. separate cover, t ya Results: Within the areas inspected there were no violations' or de' iations> v f .[ Lto. NRC iehuirement's. ' However, a list of concerns -(open items)e that1 require i .,. y x, J.y,

additional = management attention were identified.

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v -3 'Q, 4 g-- a;, w,, p o u m1 b ; ' Persons Contacted h; y ~ ~ pp n v a s (* B. Pigg,; Quality Control LaboratoryJSupervisor ,t ,4 ' + v -I

• LN Deul, Manufacturing Engineer F

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• H jE.fEskridge,. Manager, Nuclear Licensing, Safety and Accountabili.ty 6
• R. W.lGriscom,1 Plant Engineering Supervisor v
• L.f Grossman, Director,. Manuf acturing Technology.

~*RO Klotz',' Criticality Specialist-(Corporate). R.1 Miller, Manager, Administration and Production Control' - A. Noack',~ Production Superintendent C. Proctor Health Physics Supervisor

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Rode,'P1 ant-Manager During the team assessment members of the NRC interviewed the above listed members of the licensee's staff, along with other staff members, k Land-several operations and health physics technicians.

• The' asterisk denotes those in attendance during the exit meeting which was' held at 11:00 a.m., on April. 27, 1990.;

c i-2. 'NRC NMSS/ Region'III/0SHA Representatives; ^

• W.'L. Axelson, Region III, Deputy Director, Division-of Radiation Safety i

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• G..Ketcham, OSHA Inspector

' S.: Moore l NMSS Health Physicist

• S; Soong, NMSS Project Manager.

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• present?at exit meeting.

J ^ 3. .ManagdentOrganizationandControl-(IP88005) HTwo European-companies ASEA (Swedish) and Bpown Boveri (Swiss) formed ABB,- a holding company of 800 businesses and 200,000 employees. :0ne of tne . businesses acquired ~in December 1989.was Combustion Engineering,tInc. -now named ABB-Combustio'n, Engineering,'Inc.!(ABB-CE) (Attachment 1 R c p . Organizational Chart). 'ABB-CE has about 25,000 employees in.various 3 ' enterprises :as: shown;in the organizational-chart. One of.these

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enterpr.ises is ABB Combustion Engineering Nuclear Power - Nuclear Fuel 4

• ' ABB-CENP-NF) with 496 employees.

ABB-CFMP-NF includes, as par,t of Lit.'s operation, Windsor Nuclear Fuel-Manufacturing (202 employees) .m 0 a.NRC licensee.in Windsor, Connecticut, and'the Hematite Facilit'y-f,h (104 employees) iri Hematite, Missouri. The'CE/HematiteFacilityis;( rauthorized by, NRC License No. SNM-33 to convert uranium hexafluoride"; ' 1.

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]O f '(UFe) received from varjous vendors to uranium oxide fuel pellets forf t i ,-A ' shipment to,the' Windsor facility. j 4 q g (. l The' Manager,. Nuclear Licensing, Safety and Accountability (NLS&A) hAs. J 77[i ' - direct' line responsibility for' safe -operation of the Hematite' Facility. i R. ' ~i L y e i '. 3

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y yj N wm i ~} - t l He reports-to the Plant Manager who uses severaltindependent audit 1 . functions to assure the NLS&A manager is successful'in performing his function _ The NLS&A Manager has a Health Physics (HP) Supervisor-and I six HP technicians to implement the radiation safety. program and a HP Data Clerk to record and track it's output. The inspector observed that 1l 5 communication among the Plant Manager, NLS&A Manager and HP Supervisor is. good, and for the most part occurred daily. b < ' % ' ], >y 4 gi Program Audits q 'Q.1t. 9QAfandsafetyauditsareperformedofcriticality, industrial,' chem [Nal }'" l M T*' and radiation ~ safety, transportation, maintenance and product qualit9.at i p all management levels. The corporate offices in Windsor, Connecticut # { "such as Radiation and Industrial Safety (Program Manager,- a.., 't J 'cp'g, JP.1 R.1Rosenthal), Quality Assurance (Manager, H. M. _ Glotzer) and Nuclear"

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?,0t'- Materials Licensing (Manager, J. F. Conant) perform the final audits,, b! f( (ABB-CENP-NFc(C.,Watermann).The managers of these offices' report td the Vice q'uarterly. g In addition, R. J. _Klotz, Criticality i i '4 Specialist, is on temporary assignment (one week' e~ach month) from the ycorporate office to audit both criticality safety and function ^as partzof H e ~CE's Corporate. Radiation and Industrial Safety Office. Mr. Klotz does "i ' monthly plant walk-throughs and inspections, reviews the Hematite Facility ) (, operating sheets and procedures, incident-and accident report forms, NRC reports and the quarterly reports of the NLS&A manager (Hematite). 1., In: addition to the corporate audits the Hematite Facility. conducts it's own audits at all levels of management. The plant manager,:J. A. Rode, q performs a daily walkthrough of the plant to review all. operations, including safety. He also chairs the Safety Committee, formerly started .in January 1990. A review of the minutes from these Safety Committee r meetings showed the issues were similar to those. covered informally in the routine staff: meetings. i About one year.ago the Hematite Facility st'arted " Quality Improvement Teams" to look-at maintaining and improving quality in product, procedures and operations. -The plant manager and other staff members, i attended a week of classes at Quality College in Florida where they received training on how to establish the teams. The teams are composed - E of;three to'.four supervisory and operator-personnel. Currently-four teams have been started with.at least one directly involved with radiation 3. safety. That team was looking at ways to improve radiation contamination e control-and to reduce airborne levels. The teams are given high' visibility 4& 'in_.the plant with photo posters of the team members on display. L., The NLS&A Manager attempts a daily walkthrough of the plant and prepares e quarterly written report for the plant manager with copies for all supervisors. A review of the March 31, 1989, June 14, 1989, October 2, O. 1989, December 22, 1989 and March 31, 1990 reports listed areas where. corrective action was required. In many cases (not all) there were V: followup letters from the supervisors stating the corrective action'taken. f H 4 s F p r s

p-- g 4 F 2 k In addition to the audits by ABB/CE personnel there are semianaual audits by two of their insurance carriers, CNA Insurance Company and American L . Nuclear Insurers (ANI).' A review of their reports showed that they R examined accident reports, safety meeting and audit reports, training, respiratory protection program, evacuation drills, noise levels, signs for safety equipment, ventilation flow rates, bioassay results and trends, i: contamination surveys, environmental monitoring and f.re protection. The insurers also did industrial hygiene sampling for ammonia, noise and .1.1,1 trichloroethane. e .The-inspector concluded that the licensee conducts operations in accordance with the license and NRC regulatory requirements and provides o' assurance for health and safety through its independent audit program. . No violations or deviations were identified. 4. Radiation Protection (IP 83822) The Nuclear Licensing, $afety. and Accountability (NLS&A) Manager is responsible for implementation of the radiation protection program at this facility. Routine radiation protection monitoring, analysis, ? response, and documentation activities are the responsibility of the Health Physics Supervisor, who reports to the NLS&A Manager, the ' health physics staff of six technicians, and a Health Physics, Data Clerk; The Health Physics Office is staffed continuously, throughout 11 three, j t k Y+ plant shifts. m ,7 4 [$s Assessment of the radiation protection program covered,the following h,C't majorareas: ^ a. External Exposure 1 j E O All employees are issued whole body film badges that are worn and tIi exchanged on a monthly basis..The licensee uses a major, national - R '; dosimetry service company to provide and analyze the badges. The ; 'g - ( 1 gi film badges are stored, when not in use, at the guard's station at; the plant entrance. Review of random external exposure records gI i x showed that exposures are low for most employees, with many q *' individuals receiving minimal dose, or exposures ict than 40' millirem 6 't per month. Few individuals received doses in excea of(25% of the s L levels specified in 10 CFR Section 20.101(a). The licensee's report to the NRC of annual whole body exposures in CY89'shows no personnel, annual doses in excess of 1.0 rem. The film badge supplier's monthly reports indicate that a fraction of the badges are sometimes contaminated when returned for reading. The-inspectors discussed this with licensee management and addressed - the @ ch 1990 report which showed more than' ten contaminated badges. Inswf f nient information was available to the inspectors to deterei:,e the cause of contamination. The licensee had considered-this situation, t 3 had also not been able to ascertain the cause of 1 5 i A q z

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73 s m W IC f r. a contamination. The number of contaminated badges varied i_n different 1 <v' <"2 months, but even the contaminated badges showed only low e'xposures, Because of the low doses, the inspectors did not consider thisin j ,i Serious safety concern. However, identification and elimination of l.' the cause of badge contamination would enhance credibil.ity in_the exposure records and may show lower individual doses to the workers.; e [ The licensee' has recent1'y instituted a month-long program to study a - and document the level of extremity doses to plant operators in the a new process line, using TLD rings and wrist badges. The licensee >y' had received the first week of data at the time of the team. r assessment, which showed only low levels of extremity exposure. The licensee stated that dose levels in.the new pellet process line were i well below those of the previous area. The licensee's prompt action .to investigate extremity exposures'in the new process area is t commendable, t No areas of concern were identified. E

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Internal Exposure + L Internal uptake of radionuclides by plant operators is monitored 1 I<, . directly by wonthly urinalysis and annual whole body counting. Inspectors reviewed records for whole body counting from 1987 through 1990. All operators had been monitored over the past calendar year, and the whole body counting results showed fairly low levels of internal; exposure to uranium-235. Conversations with plant staff f revealed that only the union-employees at the plant were routinely i monitored with the whole body counting, although the licensee has .t made an effort since mid-1989 to include health physics tectinicians. r The licensee has:no written policy on which persons or particular ' c jobs' indicate the need for annual whole body counting. The inost' W .D e A recent renewal of'the license only requires such monitoring forL 1, f plant operators. It is recommended that the licensee either make a i 4 "U j and document surveys for each type of job.to show that the, extent of radioactive material intake for workers who do not receive who,le A ~ ' body codnts is below the measurement level specified,in,10 CFR

4 Section 20.103(a)(3), or begin conducting whole body counts for all-

.) e ttypes of workers who enter the plant's processing areas 1 (i.e.,7all l-except administrative staff). (0 pen Item 70-0036/90002-01) n i 5 The' licensee monitors airborne radionuclide concentrations through 1 - fixed air samplers and portable " lapel-monitor" samplers. Analysis- ,1 c t. , of the filters for the fixed air samplers, which are located at each; of the licensee's major work stations, is completed for.cach shift. i- .The licensee changes and counts filters from tne fixed air samplers 3 i in' areas of plant activity three times each day. Inspectors-am discussed the fixed air-sampling program with licensee health physics - O staff and management. The licensee's efforts to monitor, count, ' analyze, and document air concentrations at fixed locations appears sufficient. Particularly noteworthy is the licensee's. analysis of L trends in the airborne concentrations at fixed sampling locations.- i 6 F 9

n ,1 i [- 1 g, . Plant workers in certain jobs wear lapel monitors two days each week to measure airborne concentrations in their work areas. Lapel monitors are also worn during all radiation work tasks that require 4 r full-face respirators. With the lapel monitor measurements, the-licensee determines the average exposure to assign as the worker's radionuclide intake, or uses the fixed air-sampling data when it is more accurate. The licensee does not have a written policy on which positions within the plant require routine lapel sampling. It is c recommended that the licensee make and document surveys for each type of job that is not included in the lapel monitoring program to show that the airborne oncentrations for workers who do not receive y routine (twice per wen) lapel sampling are below the measurement level.specified in 10 CFR Section 20.103(a)(3). (0penItem 70-0036/90002-02). The licensee could resolve this concern through-F analysis and documentation of airborne concentrations for each type of job in a general location within the plant, rather than for each individual. It is further recommended that the licensee develop a procedure to indicate both the routine jobs and the specific. tasks that. require lapel sampling. (0 pen Item 70-0036/90002-03). Inspectors' review of airborne sampling records showed that routine personnel intakes were significantly less (nearly 50% less for the November 1989 through March 1990 operating period) than 4E-12 pCi/ml e which is"the regu1~atory limit (10 CFR 20; Appendix B. Table II) for the Maximum Permissible Concentration (MPC) for insoluble uranium-235. When analysis of thetlapel-or fixed air samplers show airborne e concentrations greater.than 0.8 MPC (insoluble uranium-235),.the health physics Ttaff documents the probable cause and calculates the worker's exposure on a "High Sample follow Up" fnrm. Such forms were + ' 4 used to document 112 follow-ups between January 2, 1990, and April 12, 1990. Lic3nsee investigation and documentation of high airborne 4 , concentrations appeared'to be excellent. J ,e The inspec' tors noted that soluble uranium is a concern in three areas of the plant: the release of uranium hexafluoride (ufo) near i the vaporization station, uranyl fluoride'(U0 F ) near the R1 22 reactor and other soluble forms of uranium compounds coprecipitated in the wet recovery area. The licensee's limits (25 pg U/1).for soluble uranium would be used in case of an incident involving any of these areas. [ A worker's exposure to soluble uranium compounds is evalue' , the licensee's monthly urinalysis sampling program (bioassay progra,m). The actual uranium concentration is determined by the fluorometric analysis of individual urine voidings performed by a lice.see contractor. Records examined for the November 1989 through March 1990 operating period indicated that the highest reported value (37 pg U/1) was less than the regulatory intake limit of 40 MPC-hours. A subsequent urine voiding was supplied, when the licensee's action level of 25 pg U/1 was exceeded. This result was 'a near the instrument detention level (less than 5 pg U/1).. Hence, no further action was needed. + 7 1 e J

L i ...g i The inspector determined that a statistical summary of the personnel monitoring information recorded by the licensee. indicated that for the 1988 and 1989 calendar years, the highest annual dose to any . individual was less then I rem. This report is submitted annually to the NRC in accordance with 10 CFR 20.407. The licensee uses respiratory protective measures such as hoods-and respirators for specific. tasks land at work stutions throughout the plant. The NLS&A Manager described elements of the' respiratory protection program to the inspector. including annual checks'of workers by a physician, smoke testing of half-face respirators, and r sign-out of full-face respirators and lapel monitors from health . physics. A health physics technician described and demonstrated the. L licensee's methods of measuring airflow in the hoods each week with a velometer, and the inspector discussed licensee actions when insufficient flow velocities are measured. The inspector reviewed random records of hood airflow measurements and found few instances .where airflow velocities were less than 150 ifm, the licensee's stated action level in plant production areas.~ Wheri hoods were found to have insufficient airflow, the~ records indicated that the: velocities were usually,. brought back above standards wahin one week. 'Three areas of concern were identified. y c. Instruments and Equipment , f r The health physics staff uses and calibrates.a' wide, variety of L' radiation, monitoring equipment. The licensee uses'a cobalt-60 source on site'to calibrate'their survey meters, and inspectors' checks.ofs 7 s 7 " random ~instruinents showed that calibrations are kept up to date. The yg ,fM~ ' licensee.has,two systems for gross alpha and gross beta co'unting of i* filters, and these systems are calibrated weekly! -Inspectors reviewed ^ }. f 'calibrationsw'e'lre7performedadequatelyand'welldocumented. t the most recent calibration data for one of these instruments. The J .o -' Five continuous' air monitors (CAMS) that sample for uranium-235 air s' ' concentrations are' located in the plant's processing buildings, and ,, during;this inspection four were in use. The fifth CAM is located s f. in the'old pe.llet plant, which is in standaby. The CAMS sample.the air continuously by monitoring a filter for gross alpha counts. P", Alarms on th~ CAMS are set in terms of standard deviations from the 'l e past concentration data. A fast alarm' indicates large, rapid increases-in radionuclide concentration, and a slow alarm indicates. J more gradual increases in the concentration. Licensee personnel. noted that the. CAMS. most of which are locate in relatively new locations, indicatedLfalse alarms frequently;.in early 1990.(one or 1 more times per day). The licensee personnel described problems with great fluctuations in radon concentration patterns at the Hematite site, which cauced the false alarms. Health physics staff have C begun adjusting the CAM alarm set points each night and morning to minimize false alarms caused by high radon concentrations. The inspectors asked health physics staff,-the Health Physics Supervisor, 1 and the NLS&A Manager to describe the alarm set points in terms of 8 a

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s j& p E. airborne concentration (microcuries/ milliliter or MPC), but none of 3 ltl' y 4 the licensee personnel could provide routine set points or a range a y G of set points in terms of airborne concentration. It is recommended that the licensee determine'the range of airborne concentrations or q s the maximum airborne concentration for the continuous air monitor h, alarm set points that are used.' (0penitem 70-0036/90002-04). O, +- Dneareaofconcernwasidentified. d. Personnel protection 7 s Licensee workers enter and leave the processing buildings through h change rooms. Employees who work in the process areas change from l"g ' personal clothes into protective overalls and boots prior to entering 9 the process area, and shower at the end of the shift prior to changing clothes and leaving the site. Managers and administrative staff don 4 protective laboratory coats and rubber shoe covers before entering g the process: area. All personnel exiting the process area and change ~f r room are required to monitor hands and feet with an alpha probe Tc before leaving. The NLS&A Manager indicated that' health physicsi staf f had previously conducted occasional, unannounced-surveys of x L,m workers as they left the change room. While-the workers appear to (; bel generally following licensee change procedures,-the inspector's ' 4 interviews with licensee personnel-and observations of the men's + < changetroom at the end of a shift indicate the need for the licenseo ,L to' heighten awareness of and monitor workers! attention to the , 1 procedures for exiting the change area. It is' recommended that the . licensee ass'ure compliance with the change room procedures during [? 3 quarterly audits by the NLS&A Manager and enact mechanisms to heighten awareness,to the change room procedures. (0 pen Item 70-0036/90002-OS). '(<t , The licensee could increase' attention to the procedure by, for instance, re-instituting random health physics surveys of personnel o as they leave the change room. s s' One area of concern was identified. l Lv e. Surveys [e., - E c The licensee conducts routine. smear surveys for gross alpha and gross f beta contamination throughout the plant according to set schedules. ' 'The health physics technicians conduct the surveys and compare the'

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counting results to allowable contamination limits for that area. A F ", review of random smear survey _ records indicated that the surveys were being completed in' clean areas (such as the clean side of the change c'4[ room and the break area)'and in processing; areas. .l All incoming shipments of uranium hexafluoride cylinders are-surveyed for.. removable alpha contamination at each end of the overpack, according to health physics staff and licensee management. 1 Outgoing shipments of waste material and spent cylinders are appropriately surveyed for both removable alpha contamination and exposure rate. A health physics technician described procedures to the inspector,for surveying uranium pellet shipments and previous 4 1 9 x. ~ l lf;, I t' yf m

<3 o?y t ,,e. .et t i ) [; I g i ] studies that had been done to establish exposure rates for fixed w levels of pellet enrichment. The licensee's survey procedures for .k . incoming and outgoing radioactive material shipments appeared, 1 adequate. No areas of concern were identified.' { 3, ? Radiological Safety Aspects of UFc Leak-Cylinder Valve f. rF'3 a 1 3 s On April 17, 1990,' the+11censee had an incident involving a UFc f X-release which potentially exposed certain licensee workers to 1 d N rairborne radionuclides and hazardous chemicals. The incident:is described in Section 6.d., " ufo Leak-Cylinder Valve," Operations i Reviews of this report. Preliminary results show that the fixed .'(

• air sampler on the loading dock, near the vaporizer, measured

=t O.'64 MPC-hours for the incident. The licensee performed bioassay 1 on'the worker who opened the cylinder..His initial urinalysis 7 ^ ? .(sampled within 5 hours af ter intake) indicated 24 MPC-hours, o ^ while'a later urinalysis (represents a 24-hour sample) measured m~.'r 2.3 MPC-hoursLintake. No additional samples were taken..The f l, G ' decreasing' level in MPC-hours was caused by the high solubility of j - UO F "in body fluids and the subsequent dissolution and excretion 22

along.with normal body fluids.

Beginning on April 20, 1990, workers. .s opened the vaporizer, cleaned the contaminated cylinder, and replaced the broken valve. The workers involved in these followup operations wore protective garments and SCBA gear; The ufo /UO F release was 2 localized in the vaporizer area and caused no adverse impact to the environment. The licensee is continuing to investigste the; incident, and a report will be forthcoming. 5.- Radioactive Waste Management (IP 88035)

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Radioactive Liquid Effluents - A' Radioactive liquid effluents are released into the environment through two disposal pathways: the storm sewer system and the sanitary sewer system. The storm sewer system'is discharged at the northeast end'of a pond located on the plant's grounds. 1The pond is spring-fed and flows over a concrete dam at its south end to form a i creek.. The sanitary sewer system.is discharged slightly downstream of the dam, directly into the creek. According to the plant's Manufacturing Engineer, the primary radioactive effluents discharged through the storm system are T' liquids froin the plant laboratory's sinks, storm water runoff, and the plant's cooling water. Storm drains run underneath the plant buildings, and storm drains inside the plant are raised four inches above the floor. The storm sewersline runs underground, past'the-restricted area's fence line to the pond, where it is discharged i through a weir box. t 10-y ai D 4 i a r

F -} i 1 =4 3 y-J. 'Q. o' The primary radioactive ef fluents discharged through the sanitary sewer system are the plant!s treated sanitary wastes, shower water, .and laundry water (which is filtered, held, a_nd sampled prior to 3 [ , release). The inspector toured the site pond _and examined the dam and the = storm sewer system discharge point. The licensee measures w reportable liquid effluent releases at the dam, as'well as: J volumetric flow. rates of water over' the dam, to assure-compliance ^ 4 with 10 CFR Section 20.106. Samples of radionuclide concentrations-j 7 "t N in the liquid effluent stream are also made at several other 1 locations to a'ssure that concentrations are within acceptable

• ~

limits. The'NLS&A Manager explained that-the liquid effluent n, 9 releases reported to NRC [in accordance with 10 CFR 70] were made FW ^; at the dam site. The data for July - December 1989 indicate a total release'of 1,79 E-3 curies in 4.8 E+5 liters, or approximately 1 4 1 N 3.7 E-6 microcuries per. milliliter,,The MPC-water for insoluble uranium releases to unrestricted areas is 3 E-5 microcuries per j milliliter. Nith the licensee now discharging laundry water through the ) ~' sanitary' sewer system, which empties downstream from the dam, the licensee s current sampling point will not record sanitary sewer discharges. Additionally, the sampling point is located at the far end of the pond from the storm sewer discharge point, so the a reported-discharge levels are reduced by dilution in the pond. The i. pond is not located in the restricted a m a. It is recommended'that - the licensee initiate a license change to sample liquid ef fluents at the point where they leave the pipes of both the_ storm sewer system j and sanitary sewer system and report the combined data in their [ . semiannual report to the NRC. (0 pen Item 70-0036/90002-06). The Health Physics Supervisor indicated that the' plant is also conducting environmental sampling for liquid effluents at other locations in the plant's vicinity, such as upstream and downstreamt on Joachim creek, at a local well in Hematite (upstream), and at several wells on the plant's grounds outside the restricted area. Samples are collected on either a monthly or a quarterly. basis. The inspector reviewed sampling data for February 4199_0 that showed as maximum gross alpha level of 151.2 picoeuries per liter, which is well below the MPC-water for uranium-235, and a maximum gross beta. -t e concentration of 104.2 picocuries per liter. Water samples are-sent to a laboratory at the licensee's fuel facility plant in Windsor, CT, + for analysis. The licensee's efforts to sample liquid effluents at - multiple locations are a strength-in the environmental monitoring: o program. 3 L -One area of concern was identified.4 e b. Evaporation Ponds License' Condition No. 19 requires the licensee to decontaminate,two evaporation ponds on-site to average residual contamination limits of 4 11 3 sy u

s 77 60 6' + ) 250 picoeuries per gram of dry soil for insoltble uranium or 100 ~ picoeuries per gram-of dry soil for soluble uranium. License 1 Condition No. 19 also requires the' licensee to determine technetium-99 concentrations in the two ponds. ' Licensee management censiders that -they have met this condition. The NLSf.A> Manager stated that soil and rock lining from the ponds have been removed and shipped.for burial. Surveys have been conducted that found the uranium to be only in the insoluble form. The surveys indicate that the remaining soil is at. or below the 250 picocuries per gram limit, according to,the'NLS&A. manager. The licensee is sampling three wells to the south of the o. 1

1. evaporation ponds.

They detected gross beta contamination of 2000 to 3000 picoeuries per liter before remedial; action was taken on the ponds, but essentially no alpha contamination. The beta source was .f g presumably technetium-99 that once was present in the evaporation t 3, ,V I ponds.. Since the removal of sludge from the evaporation ponds, the 1 NLS&A Manager noted, the beta contamination. levels in the wells have 4 Xs N dropped to'several hundred picoeuries per liter and remain fairly ,., 4pm v T samplingtwells. The inspectors discussed with licensee personnel C N the benefittof.using a standardized laboratory procedure, such.as' ( / "7 W ',+ those' developed by EPA or Oak Ridge National-Laboratory,;forethe w~ sampling. Use of a recognized national procedure rather than one. developedbythelicensee,will'allowintercomparIsonofresultsif1 the ponds are studied by an independent ~ third party (such as an NRC contractor) at some time in the future. It is recommended that the-licensee adopt and'use a recognized national laboratory procedure ~ for sampling well water. (0 pen Item 70-0036/90002-07). One area of concern was identified. I 3 '^ c. Radioactive Airborne Effluents i[ Radioactive airborne effluents are discharged through 14 plant stacks I located on the processing buildings. At the time of the assessment, 13 of the stacks were being monitored. The finalistack will release. effluents from'the second new process line, which is under 4 construction and is not yet operational. .The stacks are monitored r m, daily. Airflow through the stack sampling locations is checked annually using either a velometer or a manometer. The inspector i reviewed random records of radioactiva lirborne effluent releases. 4 through the stacks. Monitoring is accomplished by= drawing air from + the stack though a filter paper at a known rate and then counting the filter. Results are.. corded in terms of concentrations. The / records show highest etfluent concentrations on rainy days. Licensee personnel explained that the data is highly influenced by rain, s(nce ~. . p-12 s t i 4 u o .i,.

c V ) p. l + rainwater mey wash deposited radioactive powder back down the walls of the stack _and cause false high-readings. On the records surveyed 1, of days without rain, the inspector found a maximum release s concentration of 18.6 E-12 microcuries per milliliter on March 12-13, 1990, from one stack. This maximum value indicatet a re10.se of several times the level in 10 CFR Part 20, Appendix B,. Table 11. I According to license condition L.C. 20(a)., the total activity allowed I_ for all stacks in a calendar quarter is 150 microcuries. Hence, no violation occurred from the high level measured (18.6E-12 microcuries/ milliliter) from one stack..Also, all stacks are on the process t buildings, in a restricted area with limited occupation times. The i inspector observed that release concentrations from stacks on the'new " process Line #1 are much lower than the' maximum noted above. The. < g . total airborne effluent release concentrations from the plant are ' generally a small fraction of an MPC for insoluble uranium-235. From fJuly - December 1989, the ' licensee discharged 2.24 E-4 curies of, ..y H gaseous radioactive effluents, with a total volume of F o 5 / 1 - 2.1 E+10 cubic feet, as noted in the semiannual report to NRC..This 4 [ ? data (2.24 E-4 curies or 224 microcuries) is also less than the - - L , quarterly activity (150 microcuries) allowed by L.C. No. 20(a)., In. 4 t U.4 Caddition, the concentration of-radioactivity in the volume of effluent r " released during the period is approximately 3.8 E-13 microcuriei; per F Hb-N milliliter, which is less than 10% of MPC-air (4E-12 microcuries 1 aper: milliliter) for insoluble uranium-235 releases to unrestricted s

; j, *, -

' areas. m u <1 v +

• ^' sL

The licensee also maintains three remote air monitoring stations

/ outside of the restricted erea in the southeast, southwest, and .o northeast. portions of the plant's grounds. These monitors consist . J e: of a vacuum pump that'. draws air through a filter. The filters are L collected weekly and counted. The airflow through the filter is measured using a rotameter, since the high volume flow rate makes i c w ., 4' a, F velomsters or manometers impractical. The inspector toured two of the remote sampling stations and discussed their operation with a 5 health physics technician. The stations were operating properly at the time of assessment. i A short term analysis (February-Maren 1990) as indicated by the' licensee showed an average for the three monitors of 2E-15 microcuries per milliliter or less than 1% of MPC-air for insoluble uranium-235 m 4" released to unrestricted areas. Based on previous (1986-1989) reviews of air monitoring. data for two monitors, the inspector. s + acknowledged that data for the monitor generally ranged from 1 to 4 E-15 microcuries per milliliter. Hence, it appear that the addition of a third monitor did not alter the results from previous data. T No areas of concern were identified, t L F d. Radioactive Solid Waste The licensee disposes of radioactive solid waste from a variety of i sources through shipment for burial at the low level waste site in Barnwell, SC. Certein materials, such as limestone from the plant's-p scrubbers, are surveyed and then held on-site. The sources of solid 13

7 3, 4 i t 't,' ,a f; m. g w + i ,.L 1 waste include cemented ifquors from the wet recovery process, ,o %,'O, Leemented chemical effluents'from the furnace scrubbers, cemented, 4?N !. residues /from,the uranium assay process, limestone, incinerator ash,' ? T l solids from;the\\ recovery process, old machinery, and old insulation.; - Materials such 'as oil from the pellet presses and machinery are being stored on-site while the licensee decides how and when to dispose of

• 1 * 'the material.' Burnable plant trash 'is volume-reduced in an

. N <incineratorn and the ashes are shipped for. burial The licensee uses t 'a commercial' hauling firm to dispose of non-radioactive " clean" solid

1. ' waste'in the; Washington County landfill, according to the i

Manufacturing Engineer, a

1. 5 s

I ' 'g Thel'Nensee,Usestwobarns(woodenstructures)on-site,butoutside- .of the rest'ricted area, to store old machinery and equipment..The inspectors' toured both barns and found equipment such as ductwork. reactor vessel covers, and old shipping containers. Some of the machinery was bagged and taped as if it was potentially contaminated, Markings and labels on some equipment indicate that it was once+used to store, transport, or process radioactive material. The inspectors discussed whether the material was still contaminated with the NLS&A Manager and other licensee personnel, and were told that the insides of some of the material may still be contaminated. It appeared to the inspectors from observations and interviews that the material may still be contaminated. The licensee.could not produce reports i or records to document that the equipment had been surveyed. It is recommended that the licensee assure, through records of surveys, historical. data, or calculations that the equipment in the~ storage barns is below the licensee's release levels, or conduct surveys to assure that the equipment ~isenot contaminated; and move any equipment not meeting the established release criteria back into the plant's restricted area for any further storage prior to' final disposition. (0 pen Item 70-0036/90002-08). One area of concern was identified. 4 ( e. Limestone Mounds LimestoneJfrom the dry scrubbers is: dumped and replenished at the rate of at least one scrubber per shift. Some shifts duuip'two; scrubbers. Each exchange fills approximately two and one-half to q three 55 gallon drums with spent limestone. Health physics L technicians survey used limestone with portable survey instruments for alpha or beta contamination. If the limestone is contaminated at a beta action level of five times above background, it is sent for burial at Barnwell, SC, as solid radioactive wasta. Limestone'that passes the survey as non-contaminated is dumped on-site within the C restricted area in one of several large disposal piles. The , 11,1c.ensee used approximately 200 tons of limestone in 1989. ~The licensee monitors three large spent limestone sites located on 4the plant's grounds. Two sites are outside of the restricted area, .I 3 'and one site is within the restricted area. The licensee's letter dated April 11, 1990, describes the location of these sites. Spent is . Y: j N -* jf. };. y r [. '4 Ml[I s; 9 [, q .4 = , j. ag;; a m ' %x p,dy. ) AFJ f; y y q 3

Q p f .e ' i i I L I limestone has been deposited on the outer sites in the past, but not over the last two years.. The NLS&A Manager described a study the licensee had conducted which found activities in the limestone piles ranging from 0 to 30 picoeuries per gram. The licensee requested NRC to. approve use of limestone from one of the piles as fill material under a building that is being constructed on-site, and is awaiting NRC's reply. The NLS&A Manager noted that activities measured in that pile (Pile B) averaged 15 picocuries per gram during the aforementioned study. Air monitoring using high volume air samplers at the three sites was conducted in the pastr but not over the last two years. The licensee did test the solubility of the uranium in the piles and found it to be insoluble. Since the insoluble uranium could potentially wash off the sites, the health physics staff has been collecting soil samples near the base of the piles on a quarterly schedule and having the laboratory at Windsor, CT, analyze the sampics. The most recent sample was made in February 1990. Further discussions on disposal of limestone and radioactive waste will be reviewed.during future inspections. 6. Operations Review (IP 88020) The Combustiun Engineering (CE) facility of Hematite, Missouri produces uranium dioxide (U0 ) fuel;for the commercial nuclear power industry. 2 -Low enriched uranium (maximum 5% U-235) is received from uranium enrichment facilities as uranium hexafluoride (ufo) in 21/2 ton, 30 inch diameter cylinders. ufo is converted to UO2 powder and/or pellets ' e During the April 23-27, 1990, inspection of licensee activities, the inspector accompanied by selected members of the licensee's staff performed daily tours of facility operations. The inspector observed operator practices and determined that tasks were being performed according to procedures; precautions were taken to control and/or F s ' handle SNM material (i.e., stored in designated arrays for criticality ~~ purposes); log booki were located at the work sites and~an exchange of a ? communications for continued operations was observed between operators ~' i 4 Jduring shift changes. The inspector also reviewed the licensee's- 'r application of corrective actions in recovery from abnormal conditions ^ 7 (an incinerator fire; and a UFe' leak from a cylinder valve). \\ p Certain processes of the facility operations were in a " shutdown" mode. i -y3 The UFe to 00f conversion process was not in operation. However, the t st'orage silos contained enough UO2 powder to maintain the U0' pelletizing 2 operation until more U02 conversion is,needed. U02 pellet production was ongoing in the new facility, while the two pellet lines in the older-r portion of the6 facility were on standby. The-scrap recovery of uranium ' from contaminated residues which require dissolution, filtration, 1 precipitation, and drying of uranium tetraoxide (UO ) was also ongoing, 4 15 q s l =

+g g b ff, N , e te 3, 'l {} 'j The ins'pector conclude'd that f acility operations were being accomplished b in accordance with~the regulations and the license and are adequate'to protect:the health and. safety of the workers and members of.the general l [, public.= 4 y. Four areas of concern (filter loading in the poreformer hood; operator 4 4 4 - partially covered with limestone dust; inoperable temperature gauge, ', No. 1' incinerator scrubber exhaust; and a final report of licensee's investigation on Fo release) were identified and discussed with the s . licensee. 3 J a. Process Description (ufo to UO2) g A cylinder of ufo is heated'within a steam chamber until the vapor !.l ' -the fluidized bed reactor. pressure allows the vaporized ufo to flow to reaction vessel R-1, t .In R-1, the ufo reacts with process steam to form uranyl fluoride; (U0 F ), hydrogen fluoride (HF) and water vapor. The operation is N + 22 g conducted in closed.,gener' ally cylindrical vessels of limited size, y ( designed to enhance nuclear criticality safe.ty. 3 UO F2 2 particles which are formed in reactor.R-1 pass to a second '. reacts with and third reactor R-2 and R-3 in, series,-where U0 F2 ~ 2 , hydrogen (obtained from cracked' ammonia) to form U0. ~ 2 l, ^ Product U0 y' 2 is removed from the R-3 reactor;via pneumatic transfer 'S ~ t i to the storage silos, for subsequent use in the U0 -pelletizing 2 n operation.. p s t-Currently,'the Hematite plant receives UFa enriched up to 5 percent 'in U-235 and converts it.to U02 powder. Dry 002 is agglomerated, granulated, and fed to the pellet press. Pressed pellets are 1 dewaxed,Jsintered,.and processed through a grinder and packaged ? e .for shipment. 1 TbincreasepelletproductionatHematite,CEconstructeda.new pellet building that will eventually contain two pellet production 74 "p. 111nes..The old pellet line will be; maintained for special pellet runsa Below is a description of the' proposed operations. U02 3 granules are received in 1,000 kg hoppers / The filled hoppers ,v' move,on a wheeled transporter through the current pellet Building'255:and into the adjoining new pelletizing Building 254. e," 'In Building 254, the granules flow by gravity from the hopper to s the mill (micro'nizer), and the' resulting powder is pneumatically transferred by negative pressure-into a blender. The blended powder ? *. a is pneumatically transferred by negative pressure into a new dry . powder preparation process that includes the addition of a i f" 1 poreformer and. lubricant, slugging,-and granulating. The + 4 granulated powder is pressed on new rotary presses. The pellets pass through two' furnace step,5 (dewaxing to burn off additives and ~ J ?- i 3

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y i ,n,. 4 >A C sintering). The sintered pellets then go through a wet grinding process, similar to that currently used. The finished pellets are i l, then packaged for shipping. On April 23, 1990, the inspector toured the new faci.lity and noted that the licensee had not fully tested the new blenders (and pneumatic transfer equipment). U02 powder was being batch fed into the poreformer hood in preparation for. pelletizing on the new rotary press. On April 25, 1990, the inspector.again examined the poreformer hood and determined that the filter was coated with U02 powder. The inspector discussed this obserystion with the L licensee. 1 The licensee agreed to quantify the filter load; review and modify if necessary the criticality requirements for handling the fil_ter; t review and modify if necessary the criticality requirements for operations that occur in the.poreformer hood; modify operating procedures and instruct operators to examine the spacing behind the filters for 00 2 buildup in the poreformer. hood.and any other - hoods that may be equipped to filter 002 powder. In addition, the licensee agreed to conduct internal / independent audits to guard against.the undetected buil <up of U0g and to assure that the procedure for quantifyine an.i disposing of contaminated (UO2 loading) filters is adeqm.ie. l It is recommended that the above weaknesses be resolved by developing an audit program to identify total mass present of U0.and prevent l 2 the unobserved buildup of 00. (0 pen Item 70-0036/90002-09) 2 One area of concern was identified. i b. Limestone Scrubber Ded (HF Removal) p a As described under,the process-description, pr.seous HF is formed in the reaction vessel R-1, when ufo reacts with process steam. J Gaseous-HF and H 0(as excess steam) exit the reactor through two Vd 2 sets of porous metal filters. The gaseous materials are routed to the HF removal system. The HF removal system, consists of five cylindrically shaped towers each packed with about 1500'lbs of pebble-sized limestone (calcium carbonate, CACO ). HF is removed 3 by the reaction of. F2 with Ca to form CaF, Excess H in the 2 2 / off gas stream is burned in an in-stack burner located after the i 1imestone fluoride removal system. Progress of the chemical reaction (HF + CACO ) through the limestone 3 scrubber bed is monitored by noting the scrubber bed temperature. In addition, a portion of the spent limestone ; removed from one or two of the towers during each' shift so that alcat 11/3-operating days complete the replacement. Each tower bed is replaced normally in sequence of one to five,by closing the selective off gas # -manifold valve and dumping the contents into two or more 55 gallon drums per tower. The scrubber loading system is used to replace the limestone. l l 17 m

g q' l f,[' !,4 ( 4" i 'M i i u .J ,t !? . y,,i s T siw q / .p.G ii 't .4E s et C The inspector observed two operators while they removed and replaced ~, the limestone bed in one of the cylindrical towers. One operator is

stationed-on a platform near the top of the cylindrical tower, while the other operator is located at ground level near the bottom of the tower.

At this juncture, the limestone is thermally warm (>100*F) and has not been monitored for its radioactive content. An empty 55 gallon drum is placed at ground level just beneath the tou r. There is nearly three feet of air space between the bottom of the tower and the top of the drum. Although the ground level operator wears a half-face mask, the flow of limestone into the 55 gallon drum from the opened tower bottom is forceful to the point of partially covering the operator with limestone dust. s To complete the process of removing limestone from the tower, the ground level operator must use a minimum of two drums. His exposure time to the limestone dust is approximately 15 minutes. The dense cloud also spreads over considerable area of the licensee's property. The impact on the top level operator seemed minimal. It is recommended that the licensee design a transfer system that will enable the operators to complete the removal of limestone rock while ' limiting the spread of limestone dust (0 pen Item 70-0036/90002-10). One area of concern was identified. c. Review of Incinerator Scrubber Fire On. February 16, 1990, the licensee submitted a report to Region III concerning a fire in the rubber lining of No. 2 incinerator scrubber. The incident was reportable under NRC regulations 10 CFR 20.405(a)(1)(sv) which references 10.CFR 20.403 and subsequently requires notification when damage to property exceeds $2,000. Licensee estimates of the damage and cost to repair the incinerator was $5,340. a Incineration is used at CE Hematite to reduce the volume of low-level-contaminated waste. The incinerator equipment cc-ists of two gas 3 - 9 , + g!jfired incinerators, two wet scrubber systems (watt e quenched) and an, s air-cooled heat exchanger..The operator must monitor and maintain t;' the proper liquid level in the scrubbers. s N4 ).Atabout.12:10a.m.,onJanuary 13, 1990, a water sleak dhveloped in 'the scrubber 1 recirculation line of the No. 2. incinerator.. Shortly 1 s ~~ " another water leak was discovered at the flange above thereafter,lating (ejector / venturi) pump.- e.y k. N' the recircu The extent of-the leaks t were'such that the operator switched off the incinerator pumps and G*,y 1 i j L burners and'left the area to find a maintenance operator. Upon O 4 retur,ning to the incinerator area they observed flames. coming .) ,o y .out of,a welded' seam which had split on the sidewall of the e ' \\.. . v'esseli "This was an indication that the rubber lining was on fire. R b . ;The fire kas' extinguished by introducing water through_the scrubber e ,(' . top spray. nozzle and through the split in the sidewall.T lt took 3 approximately:two hours to completely extinguish the~ fire and cool 64 the scrubb'er. $n inspection 1of the damage indicated that most of j . ~ ge I l 18 ,s.

. V id

• i r

the' rubber lining of the scrubber vessel was destroyed, the ceramic packing was reusable, the demister was intact, and the blower and - exhaust stack were undamaged. The licensee also indicated that the No. 1 incinerator / scrubber system was. unaffected. s The licensee's assessment.of the radiological consequences caused by the incident disclosed that neither. personal exposure or airborne activity exceeded normal operating levels. The fixed air sample showed a concentration of.0.09 E-10 uCi/ml (9% MPC), compared to 10 CFR Part 20, Appendix,B, Table 1 value of 1 E-10 uCi/ml. The exhaust stack sample was 0.59 E-12 uti/ml (15% MPC), compared to 10 CFR Part 20, Appendix B, Table II val':e of 4 E-12 uCi/ml. The licensee's investigation ^as to the " root cause" of the incident indicated that the sequence used by the operator to shut down the unit allowed the. scrubber liner to dry quickly., The shut down sequence involved the pumps first (eliminating the availability of - (allowing hot air to contact' the dried rubber liner). N The quench water), the burners second,4and the scrubber blower last ' combustion of a' dry rubber' liner which probably contained smoldering carbon black: particles and the presence of hot air being drawn in by the scrubber blower cadsed the fire.* ( The operator was not aware of the necessity of: maintaining proper

11guid level in the scrubber while there was significant residual heat in the. system.

The licensee initiated the following corrective actions'to prevent recurrence of a scrubber overheating event:, t y p. Installed an emergency cooling water spray at th.e scrubber inlet.c i Added.an emergency ~ shutdown procedure to the operating sheet e-(0.S(801.12). 'Conduc't training of operations at the incinerator location to review emergency. shutdown procedu're., The inspector interviewed the plant engineering supervisor'concerning the root cause.of the incident and the corrective actions and training to prevent recurrence provided for the' operator. No problems were noted. The. inspector observed the operator involved in~the incident simulate the emergency shutdown' procedure as implemented by'the licensee. No problems were identified. However, the inspector observed that the temperature indicator on the scrubber exhaust i system of the No. 1 incinerator,is inoperable and.should be repaired prior to restart (0 pen Item 70-0036/90002-11)., One area of concern was identified, d. UFc Leak-Cylinder Valve On April 17, 1990, an unp1'anned. release of UFe (3.8% uranium-235)- occurred through a cylinder valve. At the time of the. release,-the l 19 s k 5'

G3 ~',& ~ ~ i y w, u : ",, 3 + 1 e y 7 [./ yi 4 , w ty.g cylinder was located in the vaporizer in preparation of introducing. 9 4 s ufo to reaction vessel R-1 to initiate conversion to 00. After the 2 q* leak had subsided and the cylinder had cooled, the' valve was i J replaced with a new one without incident. The affected valve was disassembled, cleaned and found to have two defects (the stem seat- [' t was scoured; and the packing gland retainer nut was cracked over 80%L of its circumference). The width,of the crack was measured to be 1/8 r of an inch. The cylinder was the last one processed in a series of fn .nine cylinders received from a General Electric fuel facility. _No-problems were reported in handling the previous eight cylinders. before attempting to deconte.minate the outside surface of the

' ' d 9

The licensee allowed the affected cylinder to' cool for.two days cylinder, the vaporizer, ano' the cylinder valve. Consequently, the licensee's investigation.and course of action for final disposition-of the affected valve is incomplete. The licensee should submit a n 1 g written report of their findings to include bioassay data-and dose ~4 assessment, concerning this matter (0 pen Item-70-0036/90002-12). A check weight on the cylinder and the cold trap indicated that 7-14 kilograms of ufo was missing and about 4 kgs was accounted for in 7 the cold _ trap. 'v .M-The inspec' tor determined that the incident was not reportablec.~To. e ' -,t. continue operation the licensee could have switched to another cylinder in the adjacent vaporizer. The radiological consequences-showed no adverse im act on persons in the area. This is discussed. under Section 4.f., p' Radiological Safety Aspects of UFe Leak-Cylinder Valve," of this report. One area of concern was identified. s No violations or deviations were.' identified. 7.< ' Criticality Safety (IP 88015) The inspector confirmed that management of the licensee's nuclear criticality safety program is commensurate with administrative and technical requirements-of the license. Two nuclear safety concerns (filter loading in the poreformer hood; and moisture control in unloaded and uncovered blenders) were observed and discussed at the exit meeting. j a. Nuclear Safety.Ar.aiysis [ Operators wer observed performing tasks in accordance with posted criticality limits. Operators stacked the pellet trays in the e l prescribed manner, and stored five gallon containers of SNM meterial within designated, storage arrays. >i A review of nuclear safety' analysis (NSA) records disclosed that'the ~ l most~recent request for a facility change involved the addition of H storage locations for mop buckets, UO2 powder cans, and U02 scrap l pails. The design of'the exclusion areas was~ identified by an 1 4 engineering drawing depicting the storage areas and the spacing of I e b ? + 20 7 m s 7

p{q, ,g , ~, 1 q,. y E the containers either on or' foot or three foot centers. This a s F conforms'to the discussion is, the Special Nuclear Materials. License [, SNM-33. No problems were noted. b. Nuclear Safety-Revitalization Program ~ Criticality safety in the new pellet building depends mostly on moderation control and design of vessels,to safe 1 geometries. SNM material removed from the storage silos into storage hoppers'and ultimately through all pelletizing operation'is limited to 1.0 ' ~ weight petcent moisture. The instruments used for moisture . measurements are scheduled for calibration on a 6 month cycle. \\ \\. During the course of this inspection only a portion of equipment located on the pellet line was operab_le. U02 was being batch fed 1< s through the poreformer hood through to the new rotary press. The 's ~ filter in'the poreformer hood seemed to collect U02 powder at a. + t rate that may cause operational problems. This concern was also e discussed in-this report under Section 6 Operations Review; 1The nuclear saf ety requirements for third floor operations is' under moderation control and limited to 10 gallons of water. Intrusion C, ' from water or other hydrogenous material into a vessel that blends '2,000 kilograms of 002 may violate the moderation control criterion l. s for UO2 by, increasing the K effective value of the vessel, The presence of water could also affect the density of UO2 and restrict / the blenders: vacuum transfer system in the transport of UO2 to the slugging press. The licensee employs two independent moisture detectors to monitor plant air used for blendilig. Hence,-during. oxide' unloading or processing operations, automatic instrument. action,is employed to' assure that moisture is not injected into the blenders. However, the inspector did not observe any precautions to prevent intrusion of moisture when a blender is empty and uncovered. The new oxide blender (and components) are large vessels (23 feet;in 4 height) installed with the base. located on the first floor and the. top protruding a few inches above the third floor.- With the top removed, the blender is nearly flush with the floor. This arrangement may allow the accidental intrusion of water into the vessel, possibly from mop water spillage. One or more of the sock, filters housed in the blender could also be damaged from'a dropped tool or other sharp object. A damaged sock filter could possibly lower the oxide blending efficiency. The inspector made daily, tours ~, (April 23-27, 1990) of this area and'noted that the covers had been removed on two blenders. The licensee should review operations and maintenance requipements in this location and develop administrative and/or engineering i controls to' prevent the inadvertent intrusion of-water into an-l uncovered vessel and also protect the integrity of the sock filters l (0 pen Item 70-0036/90002-13). 'One area of concern was identified. t i 21

7 y w L o ~ ^ g' e-c. Audits Internalaudits(documentedquarterly)areconductedinIlplant locations where SNM material is handled or stored. Minor infractions such as unauthorized storage of mop buckets are usually corrected quickly.: The production superintendent of operations normally supervises the correction of nuclear safety infractions. Other audit functions are discussed in this report under Section 3, Management, Organization and Controls. d No violations or deviations were identified. i N 8. Maintenance and Surveillance Testing (IP 88025) a.- i a A review of the licensee's preventive maintenance. records indicated that maintenance was being performed in'accordance with an approved schedule. The inspector observed a technical representative from Honeywell Corporation conduct surveillance tests on the R-2 conversion reactor. The frequency of checks on plant systems pertinent to safety was reviewed for.the September 1989 through April 10,,;1990 operating period. Daily Checklists. Oil levels and pressure readings'are checked on .the air compressor. a Weekly Checklists. The battery and oi1~ level ~ars. checked on the emergency generator. At least one criticality monitor is checkedi q for operability each Monday morning. TheDinspector observed a-Y, health. physics technician performing set point checks on'three of Y the monitors.3 Noproblemswereobserved.l x.< a ec 'i. Monthly Checkiists. Theplant~maint"ainsiixcranes(quarterton l, b to five ton capacity) that are used in;the processing of special< + i*, nuclear materiar in the old pellet building. Similar checklists i.are being developed for plant systems in,the newtpellet plant'. q o The inspection report's (Checklists) were up to date and'for the review r

4 periodmentioned-abovenoexcessivewear,tocranel components'wasreported..

s

A. technical representative from'Honeywell Co"rporation checked the set b

4 . point alarm for the operating temperature of the R-2 conversion-reactor.. Set points"are aligned to alert the operator by audio, visual display when Y either the' lowest or highest operating temperature is exceeded. No. 4 1 - i. concerns were' identified. 3, No violations or deviations were identifidd.', ^ 9. Exit Meeting l The inspectors met with licensee representatives (denoted in Section-1) R y at the conclusion of the onsite inspection. The inspectors summarized + the scope and findings of the inspection.jdiscussed the observations and open items described in the report and' requested the licensee' to provide', + a written response and a resolution to safety ~ issues. ,q l hA p t e ,f 9 'j .L .?" k n s - w_

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f f;;, c ' i.,. p f; + t 3 o x- >.. g s.. q =" s I h 'f .j gi- ). 9 '4 Stl 1 + f 3 s j.' s ,p y ',1 p, 1, ( 7 W ~ n 3 m. 1 O f" * ' > v iThe'Regi6n III Team Leader delineated the fdllowing requiremenito the.: h licensee concerning correspondence 'on these. inspection findings:- 2 3 ,4 t. s j p,j,

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^ s j . Response to: concerns :which doinot. impact upon radiological safety: aS s must be handled directly'between the licensee and OSHA with copies Y,' a' .of documentatio.n p.rovided to the NRCsRegion'III Office;. 4 58 I.. (4f -j' Np O[ ' e y, 4 Response to concerns which pose' radiological safety / licensee matters ,l ;e A~ should be forwarded directly to the NRC Region III Office. s , ;g c 1 v o Responseto'findingsthat~posebothradiologibaland'non-radiologicsli i ' N N, i < problems.should be. forwarded to OSHA,for an initial review. 4 L t t Q[' Subsequent to-this review a, final _ review will-be performad by ther

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i .~ 7 9 c n g f During the course of the inspection and.the, exit'meeti.ng, thellicensee > did not identify any documents or inspection statements or references tol ,V 'N-specific processes as'.. proprietary. y m o y ,V P 'Attachmenti -CE,0rganization Chart <g q s i,, n '[' l' S y 3 4 4 y; yl .. ' + ? ' *d .g s-1. fr j 1,[- - o i 1)) > s s 3 '?, ~ s , i t_ J-i j3, ,4 i 4 % e,' -y t. g ? } 3 a u g 4 8 k g y ~ l, -- d .y . s ^ m . 6 - p [. ' ipt: '94 s, i 2.,. L i; s4 f_y ' +* .? ,g ? I JT ' ..1 s 'g 5 .,4 v y i?*p_ , -p' j G [/ I' C A r f ' q,# .,s - s a T. 'y sq ; v. h [ -.. i ',5 . ] 4. -,, y gg i ~ ! t .f t 3, ei 4 s s }" 4 "' e h'# t( 4\\ h s g -' _h* 3 c. g '.t. U,- (i, $. 4 p u '. s + y my . 3. "g 9 ) V 4 'l s t w c., z ,L s. i. .v- , g g

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