ML20054D813
| ML20054D813 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 04/05/1982 |
| From: | Book H, Brock B, Cooley W, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20054D810 | List: |
| References | |
| 70-1257-82-03, 70-1257-82-3, NUDOCS 8204230407 | |
| Download: ML20054D813 (11) | |
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U. S. flVCLEAR REGULATORY COMMISSI0fl REGI0fl V Report flo. 70-1257/82-03 (RS)
Docket flo. 70-1257 License flo. SflM-1227 Safeguards Group 1
Licensee: Exxon fluclear Company 2101 Horn Rapids Road Richland, WA 99352 Facility flame: Richland Facility Inspection at: Richland, Washington Inspection conducted: March 1-4,1982 h [b Inspectors:
v'W. J. Cooley, Fuel Facilities Inspector Date Signed 4d M w.scist B. L. Brock, Fuel Facilities Inspector I
Date Sf"gned M
Approved by:
R. D. Thomas, Chief, Materials Radiation
'Date Signed Protection Section Approved by:
H. E. Book, Chief, Radiological Safety Branch Date Signed Summary:
Inspection on March 1-4,1982 (Report flo. 70-1257/82-03)
Areas Inspected: drganization, facility changes and modifications; internal audit and review; safety cocmittee activities; employee training; maintenance and calibration of safety devices; operations review; criticality safety; radiation protection; license conditions; and UF6 gas release.
The inspection involved 50 inspector-hours onsite by two flRC inspectors.
Results: fio itens of noncompliance or deviations were identified within the i
scope of this inspection.
gg0423 0 907
4 DETAILS 1.
persons Contacted D. L. Cornell, Manager, Manufacturing
- T. L. Davis, Manager, Auxiliary Operations.
T. C. Probasco, Engineer, Nuclear and Industrial Safety
- R. L. Miles, Supervisor, Radiological Safety E. L. Foster, Radiation Safety Assistant, Radiological Safety
- C. W. Malody, Manager, Licensing and Compliance, Operating Facilities
- J. E. Pieper, Engineer, III-Licensing
- D. E. Clark, Senior Engineering Assistant
- C. 0. Brown, Senior Licensing Engineer
- M. G. Hill, Supervisor, Chemical Operations J. W. Green, Engineer M. K. Valentine, Manager, Maintenance Engineering
- Denotes those attending the exit interview.
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2.
Organization Mr. Leo Hansen, formerly with the Exxon Nuclear Company Licensing organization has transferred to the Exxon Nucleonics Engineering group at Richland.
3.
Facility Changes and Modifications The licensee's facility modifications include plans for constructing a new building in which to move the U 0 operation.
The lube and blending 3g operation will move into the area vacated by the U 0 operation.
Additionally, the laundry is scheduled to move fro $ kts present location to the vicinity of the maintenance building where larger quarters with an improved ventilation system are available.
Changes proposed include the use of 55 gallon drums for U0 dry power p
storage. A new powder preparation line is also under consTderation.
Such a line would facilitate achieving the higher production rate consistent with the higher possession limits recently requested.
The level liquid waste treatment is being evaluated to determine whether the low contamination levels can be met-to permit releasing most of this waste to the city sewer system.
Smaller streams are being evaluated first.
If SNM bearing low level liquid waste can meet the required low contamination levels after chemical treatment for the high ammonia and nitrate levels, then a significant reduction of the liquid input to the lagoons would occur. The lagoons will continue to be used for retention of process. liquid wastes from various parts of the production operation.
4 4.
Internal Audit and Review c.
Nuclear and Industrial Safety Inspection Five inspections for nuclear and industrial safety were conducted by the licensee since the NRC October 1981 inspection. The areas buildina, Specialty Fuels Building, inspected included the U0p Engineering Laboratory, Laundry, Lagoons, Outside Facilities, Contaminated Storace Warehouse, and the Irradiated Tool and Eauipment Building.
Items needing correction were identified and a written report was distributed.to approoriate management.
The status of identified items was reviewed in subsequent reports and corrective actions were evaluated for adequacy and reported.
The inspections were adequate as to scope and denth.
Followup was appropriate for the items identified and was not inhibited by the inspection freauency.
In some instances lthe' inspector corrected identified' items.
b.
Radiation Work Procedures (RWP)
The licensing engineer is currently reviewing and revising Radiation Work Procedures (RWP's) to simplify them by placing common items in a general RWP. This will facilitate referencing the general RWP in RWPs generated for small specific operations.
The general RWP is currently in draft undergoing review.
5.
Safety Committee Activities 5
The Fuels Manufacturing Health and Safety Council (FMHSC) meets monthly following an inspection by one of the comittees. The inspection results are not reported at that meeting but at the subsequent meeting. This one month delay facilitates obtaining the responses of the involved management before the review by the FMHSC.
Although an As Low As Reasonable Achievable (ALARA) subcommittee of the FMHSC meets semiannually, a report which summarizes the facility's radiological releases and bioassay results for the month are presented 4
by the Radiological Safety Supervisor. The minutes and monthly inspection results since the NRC October 1981 inspection were reviewed. Of special note was a critique on a criticality alarm evacuation drill. Also noted were management's interest in the lack of an emergency scrubber on conversion line 2, and in the ouestion regarding whether or not scrubbers should be designed for the capacity of a full' cylinder of UF6 (about 4600 KG).
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. 6.
Employee Training The licensee's training courses remain unchanged.
However the training records, test results, lung count, and bioassay data currently kept in a single file will be adapted for computer storage, The licensee indicated lung count.and bioassy data can be acquired on tape for input'to Exxon's computer thus reducing data handling errors.
The stored information could then be acquired in'whole or in part and in a variety of useful formats.
Files and signed training course attendance ~ sheets are planned to be microfilmed for efficient storage. By June 1982, the Document Control Center will store the course training packages as well as' information on the sources of training materials used.
An annual radiological training course is given by-the Radiation Safety Assistant.
Course participants are those who will, routinely work with radioactive materials and those who frequent areas where radioactive materials are used. A written examination.is given at.
the conclusion of the course. The examination is graded and a review of the questions missed is held including a discussion of the correct answers before class is dismissed. This is to increase the course participant's understanding of areas the test identified as needing improvement.
The operations group regularly gives a safety training course and periodically includes a section on Radiation Work Procedures (given by the Radiological Safety Assistant).
A sample of nine production workers was obtained and checked against the training records. Appropriate training in Criticality Safety and Radiological Safety had been provided to all nine workers in the sample. All passed the associated tests.
7.
Maintenance and Calibration of Safety Deviceji, The monthly review of the autoclave B C (absorber) control rods is 3
being changed to a quarterly review bHsed on the monthly review results. The x-ray examinations (a part of the monthly review) have shown the void space in the B C control rod increasing at a rate g
consistent with a consumption of about a quarter of an inch of B C per g
month. The autoclave baskets which constrain the rods to a 9 inch diameter safe configuration were inspected monthly but now will also be inspected quarterly.
A. monthly check list is used to record the monthly inspection of the safety interlocks in the UF primary headers. The check list provides g
l for recording the test resuTts in the testing of the trip points for the low pressure and the high pressure valves. The low pressure
. trip is set to close the valve to keep water from being drawn into the UF cylinder if the gas pressure drops below the water pressure.
g The high pressure trip is set to close the valve to keep water from flowing into the UF cylinder if the water pressure rises above g
1.he gas pressure. An interlock is on a thermocouple to close a valve on the header between the UF cylinder and the eductor in the 6
event (after startup and equilibration) that water backed into the header system cooling it. The device thereby indicates the presence of water in the header lines. Closi..y tne header valve would prevent flooding of the UF cylinder. The header on conversion Line 1, which 6
is normally heated during removal of UF from a cylinder in process, 6
had apparently overheated in the vicinity of.a valve to the point where the teflon gasket deformed and permitted a UF6 gas leak. The alarm was activated and an operator responded, evaluatea the situation, and turned off the gas at the cylinder using a remotely operated valve.
This leak of about 10 Kg of UFg gas (containing normal uranium) is described in Section 12 of this renort. The licensee is conducting an internal investigation to establish the cause of the leak.
8.
Operations Review a.
Emergency Scrubbers A visit was made to the Line 1 UF Conversion Room housing the 6
vaporization chests and scrubber as well as to the Line 2 UF Conversion Room which was not operating currently and doesn'k have an emergency scrubber. The valves on the header brought into play during the recent UF release were observed.
It was noted g
that the Line 1 conversion area appeared clean, the plastic box covering the header and valves also appeared clean. The scrubber and its piping system were also observed.
Discussions with the engineer who designed the scrubber system were beneficial in understanding how the system worked.
In the event'of a.UF leak 0
near the cylinder or header during conversion, an alarm is given by a smoke detector, the operator presses a button that activates the remotely operated emeroency cutoff valve mounted on the cylinders valve. Other valves isolate the conversion room ventilation system. Startup of the scrubber and recirculation ~of the conversion room air through the scrubber system gradually removes the U0 F from the air. The U0 F isdissolvedindeionizedwaterthatik p2 sprayed on filters throagh which~the room air is circulated. The filters drain into the bottom of the scrubber from which the water leaves via two 6 inch pipes and one 2 inch pipe that drain into a 6 inch diameter horizontal circulating system. The water flows-through the system and enters a 6 inch diameter vertical hold tank.
The hold tank contents are pumped back to be sprayed on the scrubbers filters except for a small stream which is drawn off and pumped from_the hold tank _to the hydrolysis tank.
A small 5 gallon ner
4 gallon per minute pumo is used on the bleed line, and a 10 gallon per minute pump handles the recirculation.
The water drawn off by'the 5 gallon per minute pump is replaced from a 5,000 gallon tank of deionized water that is supplied by two deionizers used alternately. The 5,000 gallon tank is not dedicated to the scrubber system but is used in several operations in the plant.
If no make up deionized water were added to the system, then grams U and grams U-235 could be determined by calculating the volume of the system and measuring the U concentration and enrichment.
The absence of an emergency scrubber on Line 2 is going to remain unchanged for a while. Although a scrubber was purchased for Line 2 almost 2 years ago and although Line 2 has been down for awhile, the licensee indicated no target date has been set for installation of the scrubber on hand. A question has been raised as to whether a scrubber or an alternate piece of equipment should be cylinder's supplied to handle the total release of a full UFg contents. A reason given for the further delay for the installa-tion of a scrubber on Line 2 is that the licensee's plans for ungrading of the plant capacity has the highest priority. The licensee plans some changes which they feel will take a while to implement. The capacity of Lines 2 and 3 will be fully utilized for several projects thus leading to the decision to keep the plant running rather than shut down Line 2 which would decrease the capacity for the duration of the installation effort.
The licensee has formally reouested that the licensed possession limit be doubled. An increase is needed to permit meeting the higher planned capacity.
9.
Criticality Safety This inspection included a review of three nuclear criticality safety analyses involving the dissolution and storage of low enriched uranium solutions. That analytical work had been performed between 1975 and late 1979 and had been updated as'new equipment was added to the scrap reprocessing areas. Those updates involved primarily interaction calculations.
a.
The Scrap Dissolver The scrap dissolver located in the scrap recovery area of the UO bui.lding consists of three inter-connected cylinders roughly 2
in the form of the letter "T".
The cylinders forming the arms of the "T" are used for preparing charges of scrap, low enriched uranium, for dissolution in the central dissolver tank. The central tank is subcritical by geometry at 5 weight percent u ranium-235. The two side tanks are subcritical by geometry, also, although the shortened length of those tanks (end leakage) must i
l be taken into account. Criticality limits on the dissolver, l
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. therefore, include the limitation of enrichment (5 weight percent uranium-235); geometric form of the vessels (infinite cylinder and. fore shortened cylinders); limitation of total dissolver charge to 45% of the minimum critical mass; and spacing limits between the dis' solver and other fissile material containers in the scrap recovery area. The analysis optimizes the uranium concentration and the system reflection. The calculation of the system was performed using KEN 0 II with cross sections generated by GAMTEC II. The maximum calculated keff was ineachofthe$ide2a)kksandthe (N0 = ' in the central 0.888 +0.011 for the condition of optimum U0 tank aiid 18 kilograms of U0p entire system fully reflected by water. The associated interaction calculation takes into account 13 additional fissile material containers in the vicinity of.the dissolver.
b.
UNH Storage Tanks in the Scran Recovery Area Two UNH storage tanks of the ' safe slab type are used in the scrap recovery area. Criticality limitations on the tanks include a limit of 5 weight percent contained U-235; and a subcritical thickness of 5.6 inches (maximum). The analysis optimizes the uranium concentration and water reflection of individual vessels.
The associated interaction calculations take into account 14 additional vessels containing fissile material and located in the scrap recovery area.
c.
Batch Dissolvers in the UNH Reprocessino Facility Two batch dissolvers used to dissolve scrap material which has been oxidized to U 0 are located in UNH reprocessing facilities. in q8 the expanded porti6n of the U0 Building. The analysis of the 2
dissolvers includes optimum moaeration and full water reflection; safe geometric dimensions on the dissolvers; and a limitation of 45% of the minimum critical mass as a charge in any one dissolver at any one time. An additional ten kilograms of low enriched material is permitted in the hopper feed to the dissolver to provide a seal preventing the backup of N0 gases during the dissolution of the main charge.
Interactingbalculationsare made with respect to an additional nine vessels containing fissile materials in the vicinity.
10.
Radiation Protection A review of the outstanding item (81-07-01) which was identified during the prior inspection resulted in closing the item (see paragraph 10.c. below).
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- a.
Bioassay The bioassay prugram data review reflected appropriate followup (repeat urinalysis) of analytical results above the action level.
In all cases reanalysis on a rush basis indicated results> near the detection limit and consistent with the uptake of uranium in a soluble form. Subsequent in-vivo analyses were acceptable, b.
In-Vivo Lung Counts The annual in-vivo lung counts included 156 measurements on 154 of the licensee's employees. The measurements were made between October 26 and November 3, 1981. The lung counts supported the bioassay urinalyses which indicated that ingested uranium was in a soluble form and was being excreted.
In one case, a 231+44 microgram of uranium measurement result was found to be external contamination. Cleanup and remeasurement yielded a'value of 38+38 micrograms of uranium (essentially background).
c.
TLD Reading in Excess of 1.25 Rem / quarter In an NRC Report 70-1257/81-07, Section 7.C. it was reported that an individual visiting the Exxon, Richland, Washington facilities had received a TLD exposure reading of 1.51' rem during a single quarter of 1981. The individual who may have received that exposure was normally an employee in visitor. status from Germany. No Form NRC-4 had been executed for the individual because his permanent assignment was in Germany.
The matter was investigated by the licensee. The investigation included contacting the Exxon German Facility to determine the employee's previous exposure record and a reconstruction of that-employee's working experience at Richland to determine'all possible sources of exposure.
No source of possible exposure was found at Richland facility, and the German affiliate of' Exxon reported that
-the employee's exposure record indicated no previous occupational exposure to radiation. A reconstruction of a number of trips which the employee had made between the United States and Germany in the course of his duties indicated that the TLD had been sent through various airport X-Ray checking devices which could account for the indicated exposure.
No real evidence of an exposure to the employee was discovered. The licensee concluded that the indicated exposure was not real to the person of the employee.
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. 4 11.
License Conditions This inspection included a discussion with licensee representatives regarding SNM-1227 licensee conditions numbers 15 through 20.
a.
License Condition No. 15 A scoping of the licensee's environmental monthly program indicated that it was as specified in Table 3.7, Table 3.1r, Figure 3.6 and Figure 3.8 of the Environmental Impact Appraisai issued by the Commission on August 13, 1981.
A detailed review the program results was not made as part of this inspection.
b.
License Condition No. 16 This condition requires the licensee to obtain monthly samples of any leaks which might occur in the liquid waste lagoon system.
Pumping on existing leak detection systems associated with the lagoons have indicated that.no leaks in the lagoon liners have occurred. Approximately 2 gallons of liquid was pumped from between the liners on Lagoon No. 2 during a recent test.
Analysis of the liouid found was consistent with the uranium and floride I
concentration of the lagoon prior to its refurbishment about two years ago but inconsistant with the present lagoon contents. The licensee believes that the liquid is from old leaks that have occurred at that location.
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c.
License Condition No. 17 l
The licensee is continuing test of liquids in monitoring wells at the waste liquid lagoon system and analyzing those samples for radioactivity, ionic content and'pH. The wells.being-tested in that manner are wells Number 1 through 15 as listed in Table 3.7
.c of the Environmental Impact Apparisal document.
d.
License Condition No.18 i
This condition requires the licensee to make some special 3
analyses of the liquid in each test well. The special samples had been collected and had been delivered to an independent laboratory for gross beta and technetium-99 analysis. The results of those tests are expected shortly and will be reported to the Director. Division of Fuels Cycle and Material Safety when they are received. Any plans to expand that special sampling program will be made at the time the samples are received and evaluated.
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4 L e.
License Condition No. 19 The licensee is in the process of reviewing existing-ground water data and additional ground water data being collected to determine the definition of the ground water plume beneath the Exxon site. That evaluation will include the determination if additional monitoring data is required.
Licensee representatives indicated that the results of that evaluation would be submitted to the Director, Division of Fuels cycle and Material Safety for review and approval by October 15, 1982.
f.
License Condition No. 20 I
This conditicn requires the licensee to evaluate his sampling systems for measuring total floride release; to make appropriate modifications if necessary; and to obtain the State of Washington approval for the monitoring techniques by December 15, 1981. The licensee has concluded the studies of analytical methods for determining floride, and have discussed the matter with the authorities of the Department of Ecology, State of Washington.
j The. licensee has remained in communication with the State of Washington on the subject and has submitted a new method of stack sampling for floride to the State for approval.
The licensee wishes to continue the study upon receiving the approval in order to correlate the results obtained by the new sampling and analytical j
methods with those in use prior to the sampling modification.
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- 12. Ug Gas Release 1
A gas release of natural enriched UFg occurred on February 25, 1982 at the licensee's conversion Line Number 1 and was reported as an unusual occurrence by way of Preliminary Notification V-82-11. That matter was examined during the current inspection. The information included in the Preliminary Notification overestimated the has release as 25 kilograms rather than the true 10 kilograms of UF. Almost all 4
of the gas was hydroloized during the release by an emehgency water scrubber located at conversion Line No.1.
That scrubber was installed specifically to handle a gas release of this type and ensure the hydrolized gas was collected in associated subcritical geometry vessels.
The maintenance and calibration of the emergency equipment associated -
with UF6 gas releases has been discussed in this report in Section 8.
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It was confirmed during this inspection that no measurable release of uranium occurred as a result of the gas release as determined by effluent stack monitoring and in an environmental survey conducted after the gas release in areas adjacent to the U0, thnufacturing Building. Uranalysis samples had been obtained but results of the samples had not been received by the licensee at the time of this inspection.
The emergency water scrubber system had been installed several years ago for just such a gas release event.
It is significant to note that the device performed precisely as intended.
It is also significant that the licensee intended to install a similar system in conversion Line 2, approximately two years ago, having obtained the required equipment. That installation had not been accomplished as yet, and no target data for its installation had been established at the time of this inspection.
The fact that the gas release involved only uranium of natural enrichment placed the matter under the jurisdiction of the State of Washington.
- 13. Management Interview The scope and results of the inspection were discussed with repre'sentatives of the licensee management at the conclusion of the inspection on March 4,1982. Those persons were informed that no items of noncompliance with NRC requirements were observed within the scope of the inspection.
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