ML20045G660
| ML20045G660 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 07/08/1993 |
| From: | Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20045G657 | List: |
| References | |
| 70-1100-93-01, 70-1100-93-1, NUDOCS 9307150018 | |
| Download: ML20045G660 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
70-1100/93-01 Docket No.
70-1100 License No. SNM-1067 Priority 1 Category ULFF Licensee:
Combustion Engineering. Incomomted 1000 Prospect Hill Road Windsor. Connecticut 06095-05_QQ Facility Name: Nuclear Fuel Manufacturing and Nuclear laboratories Inspection At:
Windsor. Connecticut Inspection Conducted: May 11-13.1993 Inspector:
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eded 78.
7-f'k3 J. Roth, Proje2t Engineer
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date Facilities Radiation Protection Section Approved by:
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WG 7~8'f3 W. Pasciak, Chief date for Facilities Radiation Protection Section Areas Inspected: Unannounced inspection by one region-based inspector of the licensed program in the areas of operations review, decommissioning activities, criticality safety, emergency planning, training and transportation activities.
Results: Within the scope of this inspection, one violation of regulatory requirements was identified. Violation: Failure to establish appropriate radiation safety controls for a rod stacking operation (Paragmph 2.1.3). In addition, an unresolved item conceming the evaluation of criticality safety controls identified on a sign posted in the Pellet Shop was identified (Paragraph 2.1.4).
9307150018 93070s
{DR ADOCK 07001100 PDR
Ihlalb 1.0 Individunis Contncted
- J. Conant, Manager Nuclear Material Licensing C. Coppersmith, Chairman, Facilities Review Group
- S. Junkrans, Vice President, Manufacturing
- G. C. Kersteen, Uranium-Plant Manager J. Limpert, RSO, Outages Services J. Moulton, Manger, Windsor Woods Projects D. Parks, Manager, Nuclear Material
- A. E. Sherer, Vice President, Regulatory Affairs
- W. Sharkey, Manager, Radiological Protection and Industrial Safety
- Denotes those present at the exit interview. Other individuals were also interviewed during this inspection.
2.0 Review of Operatiorn The inspector examined areas of the nuclear fuel manufacturing facility, the nuclear labomtories, and the formerly utilized Building 3 facilities, to observe operations and activities in progress. In addition, the following areas were reviewed: nuclear safety aspects of the facilities; the general state of cleanliness, housekeeping, adherence to fire protection niles; and the status of redeployment and decommissioning activities.
2.1 NurlGr Fuel Mnnufacturing During examination of the Nuclear Fuel Manufacturing facilities located in the Building 17/21 Complex, the inspector reviewed the following items.
2.1.1 Stttps of Fedeployment Activitim i
The inspector observed that cleanup of the Pellet Shop, except for the waste handling and fuel rmi loading operations, was completed. This included removal and/or relocation of all process equipment.
The licensee also completed initial decontamination of walls and floors of portions of the Pellet Shop, where required. However, the inspector noted that the licensee had climinated the contaminated enclosed walkway located between the waste handling and the fuel rod loading areas. Instead, the licensee established a plastic covered walkway through the area that had been partially decontaminated.
2.1.2 Nnrth Yard Ele;1ge Area During examination of the north yard, the inspector determined that the
" Residue Trailer" had been emptied and removed. In addition, a Type A
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3 container used to transport fuel rods was marked with a Radioactive Material LS A label and with an " empty" label. At the request of the inspector, licensec representatives verified that the container was empty and removed the LSA label prior to the end of this inspection.
2,1.3 Pellet Shop Sinck and Load Operation During review of the Pellet Shop, the inspector observed that operators were stacking fuel pellets for fuel rod loading on the fuel rod loading down draft table and not on the stacking table. When questioned about this operation, licensee representatives stated that this work was being done to reload about 4
twelve reject rods and, in order to facilitate the work, they performed it on the fuel rod loading table rather than on the stacking table as they did not want to have to perform an enrichment cleanup at the stacking table. These fuel rods were to be loaded with fuel pellets of a different enrichment than were present on the stacking table. When the inspector requested documents indicating that the plant Radiation Protection Group had evaluated and approved this operation, the inspector was informed that the Radiation Protection Group had not been consulted. The inspector expressed concern that the licensee's procedures did not allow for the stacking of pellets on the loading table (Operations Sheet No. 510, Revision 84, dated January 30, 1992), and that appropriate radiation protection controls had not been established as the loading table was not equipped with the required beta shields for stacking operations.
However, the inspector noted that the work was being conducted under the direction of the plant process engineer and the shift foreman. Failure to establish appropriate radiation protection controls was identified as an apparent violation of license conditions (1100/93-01-01). The Manager, Radiation Protection and Industrial Safety issued a memorandum to all production supervisors which reiterated the requirement for Radiation Protection personnel to conduct radiation protection evaluations on all operations prior to the start of each operation.
2.1.4 Apparent Criticality Safety Posting During examination of the Pellet Shop area, the inspector observed a posted sign that stated "all containers of water must be separated from other containers of water and other containers of SNM ('special nuclear material) by 12 inches or more" Water in containers, such as buckets, could contain unmeasured quantities of SNM. Since this sign implied the establishment of a criticality safety control, the inspector requested the licensee to provide a copy of the required criticality safety evaluation to determine if-all non-coplanar array geometries were evaluated. If they were not, the 12 inch separation required by the sign may not be conservative. License SNM-1067 states that non-coplanar arrays exceeding a vertical height differential of
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4 12 inches requires a horizontal separation of at least four feet. Since the site criticality safety specialist was not available during this inspection, this was identified as an unresolved item (UNR)(1100/93 01-02).
2.2 Rulldine 5 Catuplex Toltr During examination of the Nuclear Laboratories located in the Building 5 Complex, the inspector observed the following:
2.2.1 Llulldingj8 Illeh Bay Area The inspector observed that a test bundle was being prepared for insertion into one of the coolant water test loops. The inspector determined that the test bundle contained depleted uranium. However, none of the signs posted in the area, nor the available Radiation Work Permit (RWP), identified the radioisotope being used so that appropriate precautions could be taken by workers.
Through discussions with workers in the area, the inspector determined that the workers were aware of the radioisotope being handled (depleted uranium) and the precautions required were in place. In any case, licensee representatives stated that the radioisotope being handled would be identified in the future where required. The inspector verified, subsequent to the inspection, that the licensee had modified the RWP to identify the radioisotope being used.
2.2.2 Demistry Lahatalaty_I1 nod Ventilation The inspector noted that the airflow though the Chemistry Laboratory hood was variable, ranging from less than 50 linear feet per minute at the bottom, to in excess of 175 linear feet per minute at the top of the opening. Although the average hood air velocity exceeded the required 100 linear feet per minute, licensee representatives stated that the reason for the fluctuations will be investigated and appropriate corrections will be made, as necessary.
2.3 Buildine 3 The inspector toured Building 3 to observe those areas reported by the licensee to be contaminated with uranium. This building was formerly used for the production of reactor cores for the Navy Nuclear Propulsion Program. The licensee is negotiating with the Department of Energy for the remediation funds needed for cleanup. See paragraph 6.0 for additional details.
5 3.0 Criticality Safe.ly 3.1 fitellity Cluluce Requests The inspector examined licensee records which documented the results of evaluations of facility changes that were approved and issued between January 13,1992 and hlarch 24, 1993. Evaluations with regard to industrial, chemical, radiological and criticality safety were performed, as appropriate. Those evaluations requiring criticality safety reviews were performed by two qualilled individuals as required by license conditions. No inadequacies were identified.
3.2 NRC IMietin 91-01 Repgris Through a review of licensee records and discussions with licensee representatives the inspector determined that there had been no events involving criticality safety, at the Windsor Fuel blanufacturing facility, that would have required issuance of a report to the NRC As a result, the licensee has not sent any Bulletin 91-01, " Reporting Loss of Nuclear Safety Controls," reports to the NRC since the Bulletin was issued.
4.0 Emergency Planing The inspector examined the licensee's procedures for notification of personnel k)cated in Building 6A of an onsite emergency. Evaluation of the licensee's emergency plan by the NRC's Office of Nuclear hiaterial Safety and Safeguards (NhtSS) revealed that personnel located just outside Building 6A could be subjected to an exposure of 1 Rem as a result of a criticality at the Fuel hianufacturing facility. The licensee's response to this evaluation indicated that personnel in Building 6A would be notified to stay inside the building during an emergency. In that case, their exposure would be negligible. However, the method for notification was not indicated.
During this inspection, at the request of NMSS, the inspector verified that the Windsor site guards maintained and followed procedures specifying that, when a criticality event takes place in the Fuel hianufacturing facility, they will immediately notify personnel in Building 6A by telephone to remain indoors until further notice, in a letter to NhtSS dated June 10,1993, the licensee attested to the existence of this procedure. The inspector also verified that personnel in Building 6A were appropriately trained to respond to this notification.
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5.0 Training The inspector reviewed the following tmining programs and lesson plans:
TP-2, General Indoctrination Training, Rev. O TP-3, Radiation Worker Training, Rev. O I
TP-4, Radiation Worker Refresher Tmining, Rev. O l
The training courses appeared to contain appropriate radiological, criticality, industrial and I
chemical safety information. In addition, the courses contained site specific hazardous material handling information. Effective controls were in place to ensure that each worker received the appropriate training or the worker was denied access to restricted areas. No inadequacies were identified.
6.0 Contaminated Arem Through discussions with licensee representatives, the inspector determined that all initial chameterization efforts have been completed of an onsite wooded area that is contaminated with enriched uranium. The results of this characterization have been provided to the Department of Energy. The licensee has formally applied to the Department of Energy for funds and guidance to facilitate cleanup of the site. The guidance was expected to lead to the final disposition of the special nuclear material found, possibly under the Formerly Utilized Sites Remedial Action Program (FUSRAP).
The inspector was also informed by licensee representatives that areas of Building 3, formerly utilized for the fabrication of nuclear cores for the Navy Nuclear Propulsion Progmm, under contract with the AEC, were found to be contaminated with uranium. The licensee looked for, but could not locate, a final survey of Building 3 made following decommissioning during the early-to mid-1960's. Contamination levels in excess of 5,000 dpm!!00 cm have been identified on upper walls and ceilings of the building.
2 Characterization of this building is continuing. The licensee expects to include Building 3 decontamination in the ongoing discussions with the Department of Energy.
7.0 Transoortation Activities The inspector examined licensee records of radioactive waste, residuals and fuel assembly shipments conducted between January 1 and May 12, 1993.
No inadequacies were identified.
8.0 Decommissionine Plan Review During the course of this inspection, the inspector performed a cursory review of the Building 17/21 Complex Decommissioning Plan which was submitted to the NMSS on March 30,1993. The inspector advised that the Hs did not adequately address actions to
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7 be taken with regard to Building 3, the wooded area, the site stream, Building 6, and drain 4
l lines leading to Building 6.
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9.0 Exit Interview The inspector met with the lic0nsee representatives denoted in Paragraph 1.0 at the conclusion of the inspection on May 13, 1993. The inspector summarized the scope and findings of the inspection. The licensee acknowledged the inspection findings.
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