ML20055H240
| ML20055H240 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 07/19/1990 |
| From: | Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055H238 | List: |
| References | |
| 70-1100-90-05, NUDOCS 9007250361 | |
| Download: ML20055H240 (23) | |
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S.' NUCLEAR REGULATORY COMMISSION REGION I Report No. '70-1100/90. Docket No.
70-1100' License No.
SNM-1067 Priori ty __1_
Category _ULFF pp+
Licensee: ' Combustion Engineering, Inc.
1000 Prospect Hill Road
- Windsor. Connecticut 06095-0500 Facility Name:
Nuclear Fuel Manufacturing and Nuclear Laboratories
- Inspection ~At: Windsor, Connecticut Inspection Conducted: Jdne-4-8,1990-2 fO Inspectors:
/- dat6 J. Roth, Pro ~ ject Enginger, Effluents Radiation Protection-Section, Facilities Radiation Safety and Safeguards Branch (FRSSB), Division-of Radtation Safety and Safeguards (DRSS)
.A. Datta Fire Protection Engineer, Fuel Cycle Safety.
-Branch, Division of Industrial;and Medical
-Nuclear: Safety', Nuclear Material ~ Safety and Safeguards (NMSS)
Approvedby:(.
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'.R'. Borf'f, Chief Effluents Radiation date Protection Section, FRSSB, DRSS Inspection Summary:
Inspection on June 4-8, 1990 (Inspection Report No. 70-1100/90-05)
M Areas Inspected:
Routine, unannounced inspection by a region-based inspector and a headquarters-based fire protection engineer of the licensed program
. including management controls, operations, transportation, emergency planning, fire protection' and licensee actions on previously identified enforcement /open items.
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-2 Results:- Five apparent violations were identified.
Violations:
failure to maintain the Ceramics Laboratory hood air flow at 100 linear feet per minute (Paragraph 3.4);Lfailure to evaluate the addition of foam rubber to the fluoroscope rack prior to use (Paragraph 7.0)'; failure to follow procedures Ewhich required the Abnormal Event Occurrence Committee to investigate the use of foam rubber on the fluoroscope rack (Paragraph 7.0).
Non-Cited Violation:
failure to follow the requirements of a Radiation-Work Permit in the Bu11dirg-18.high bay area (Paragraph 3.5).
In addition, an apparent transportation violation for, failure to properly mark empty contaminated containers was identified.upon receipt of a shipment from the Combustion Engineering Hematite, Missouri facility. -This violation was transmitted to NRC's Region III' office for disposition (Paragraph 6.2).
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DETAILS 1.
Individuals Contacted r
- B. Ayres, Windsor Site Fire Marshal
=.*J. C. Ballard,~0perations Consultant
- R. Bennett, Training Manager
- J. F. Conant, Nuclear Material Licensing Manager
- M. M. Glotzer, Quality Assurance Manager
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- K. R. Hayes, Industrial Safety Specialist
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- K Keating, Windsnr Site Security Manager
.S. Kucavich, Lead Radiation Protection-Technician J. Limbert,. Radiation Safety Officer J. Molton, Woods Project Manager
- D L. Parks,. Nuclear Materials Manager
- P. R.o Rosenthal, Radiological and Industrial Safety Program Manager
- R. Sheeran,- Accountability and Security Manager
- R. E. Vaughan, Plant Manager J. Vollaro, Radiological and Industrial Safety Supervisor
- Denotes those present at the exit interview. ~The inspector also interviewed other licensee personne' during the inspection.
2.
Licensee Action on Previously Identified Enforcement /Open Items (Closed) Inspector Follow-up Item (1100/86-04-01):
Evaluate the impact of a fire involving uranium dioxide. The licensee. evaluated the consequences of a fire. involving uranium dioxide located inside and 3
outside the facility.
The evaluation indicated that the maximum airborne
. concentration at the nearest residence to the Windsor site would be insignificant (about 0.014% of. the 10 CFR 20, Appendix B maximum permissible concentration for unrestricted areas),
i (Closed) Inspector Followup Item (1100/86-04-02):
Evaluation of!a failure
- of the anhydrous ammonia tanks.
The licensee evaluated the consequences
a of a failure of the anhydrous ammonia tanks to the nearest resident and to onsite personnel.
There were no indicated consequences to offsite residents and onsite consequences could be minimized by restricting entry into the affected areas should an incident occur.
Requirements to
- restrict access to affected areas were incorporated into the facility emergency procedures, j
(Closed) Inspector Followup Item (1100/86-04-03):
Establish a program and.
implementing procedures for the control of flammable and combustible materials. The inspector verified that the licensee established an E
industrial safety program (PR-10, Section 6, dated November 2, 1989) and implementing procedures were issued during May 1990.
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(Closed) Inspector Followup Item (1100/86-04-04): Storage of'zircalloy-
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machining wastes; The inspector verified'that the. licensee reduced the M,,
' total quantity of-zircalloy machining wastes stored and provided a 4
protected storage area.inside seatainers located in the north yard of Building 17.,
l (Closed) Inspector Followup Item (1100/86-04-05):
Protection for gas i
cylinders containi'g explosive gases. The inspector verified that the=
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licensee installed covered cages on the north outside-wall of Building 17 L
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to hold these cylinders. These cages protect the cylinders from direct-i sunlight and the weather.
(Closed) Inspector Followup Item (1100/86-04-06): Dispensing of flammable
-liquids.
The inspector verified that all flammable liquids in the A
Building.17_-21 Complex are currently dispensed from properly grounded drums into grounded receptacle containers and that these containers are of-p, a National Fire Protection Association (NFPA) approved type.
-(Closed) Inspector Followup Item (1100/86-04-08): Venting and grounding of-s
. flammable liquid storage. lockers.
The inspector _ verified that the flammable liquid' storage lockers were fire resistant, properly grounded J
and. vented and were-strategically located throughout the~Suilding 17 W
Lfacility.
hi (Closed) Inspector Followup Item (1100/86-04-09):
Establish a' fire protection program for Building 17.
The inspector verified that the'
- l licensee established a fire protection program for Building 17. A review of this program was conducted by a fire protection-engineer during this inspection.
The results of this review are presented in Section 8 of this report.
'(Closed) Inspector Followup Item (1100/86-04-10):
Installation: of I
sprinkler heads in fixed systems in accordance with NFPA-13 standards.
The inspector verified that sprinkler heads in_ the Pellet Shop which were previously installed in a manner which precluded full coverage had been i
moved to provide coverage in accordance with NFPA-13 standards.
.(Closed) Inspector Followup Item (1100/66-04-11):
Placement.of fire extinguishers.in easily accessible and strategic locations.
The licensee re-assessed' fire extinguisher locations. As a result of this assessment, the fire extinguishers were relocated, where necessary, and all locations were marked to make them easily identifiable, n
(Closed) Inspector followup Item (1100/86-04-12):
Installation of 1 additional ionization or photoelectric smoke detectors.
The licensee reevaluated the placement of smoke detectors in the Building 17-21 Complex. As a result of that evaluation, additional rate-of-rise heat detectors were installed in strategic locations throughout the Complex.
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-(Closed), Inspector Followup Item (1100/86-04-13): Assure daily collection andl disposal of combustibir trash, accumulated hydraulic fluids and
- cir nup 'of spills. The inspector verified that housekeeping had been l
improved throughout the Building 17. facilities,-that accumulated hydraulic-p fluidsihad been minimized and that two spill response carts had been installed in ' appropriate areas, (Closed)LInspector Followup Item (1100/86-04-15):
Establish an industrial-l safety program. -The inspector verified that the licensee established an-1 industrial safety program which was described in Program Document PR-10, dated November 2, 1989.
i (Closed) Inspector Followup Item (1100/86-04-17):
Evaluate h'igh ambient
-temperature ~in the Pellet Shop and its effect on worker safety.
The i
licensee _ inspected the Pellet Shop ventilation system. As a result of this inspection. several discrepancies'were identified and corrected which resulted in a decrease in the ambie-t temperature in the Pellet Shop.
.(Closed) Inspector Followup Item (1100/86-04-19):
Establish.a program and.
implemen. ting procedures to assure adequate housekeeping in Building 17.
-The inspector verified that the facility housekeeping program is as described in Program Document PR-10.
Implementing procedures have been
.t incorporated in Ra'diation Protection Instruction RPI-224.
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-(Closed) ~ Inspector Followup Items (1100/86-04-20 & 21):
Establish a-program to assure that. reviews and audits are conducted of NRC-license requirements associated.with the Health Physics, Industrial Safety and Emergency Preparedness programs.
The inspector verified that the.
' licensee established a comprehensive internal review and audit program-asidescribed in two documents, Administrative Procedure AP-7 and Program Document PR-22.
(Closed) Inspector Followup Items (1100/86-04-23 & 24):
Establish a preventive maintenance / inspection / test program for the anyhrous ammonia storage. tanks and equipment, the ammonia disassociators and equipment, the fire sprinkler systems and other process equipment. The inspector
' verified that the licensee established and: implemented a preventive
-maint'enance/ inspection / test program which was. designed to assure proper 4
continuous operation of all identified and other installed process equipment, b
(Closed) Inspector followup Item (1100/86-04-25):
Provide the anhydrous ammonia tanks with electrical grounding protection. The inspector verified that the licensee installed electrical grounding protection on each of the anhydrous ammonia storage tanks.
7 (Closed)' Inspector Followup item (1100/86-04-26):
Establish a fire fighting training program for fuel manufacturing facility personnel. The licensee has arranged with local fire department personnel to provide fire fighting training to all facility hourly operators, radiological i
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' protection.-technicians and'the manufacturing supervisor on an annuali E
-cycle. A series of classes in the use of fire extinguishers was provided,-
- starting,on June 11,'1990.
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(Closed). Inspector Followup Item (1100/86-04-27):
Instruct fuel-1 manufacturing operators on the contents of Operations Sheets (procedures) and their location.
The inspector verified-that the facility general f
employee training (GET) modules and on-the-job-training information
- included instructions to workers concerning the contents and locations of-'
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n Operations Sheets.
(Closed) Inspector Followup Items (1100/86-04-28 &' 29):
Evaluate the'
' Windsor site emergency control center to determine if it is properly sized and provide an alternate emergency control center.
The-licensee conducted anLevaluation of the emergency control center in use at.the time _of'the inspection. On the basis of that evaluation, the emergency.
control center was moved from Building 6 to the Building 8/8A Complex (site east guardhouse).
In addition, the licensee provided for an alternative emergency control center in Building 4 which would'be'used if-the Building 8/8A Complex became' uninhabitable.
1 (Closed)' Inspector Followup Item (1100/86-04-48):
Re-examine the
..W technique used for the storage of out-of-use uranium oxide powder blending-
' hoppers.
The licensee examined the technique used to provide positive essurance that out-o.f-use powder hoppers were locked out-of-service to-A
'present liiadvertent use. As-a result of this examination the licensee
. modified the technique froni-wrapping a chain around each hopper to running C
a chain through an eyelet. welded to each hopper and locking the chain in
-place.
(Closed) Inspector Followup Items (110/86-04-49 & 50): Assure that L
. nuclear criticality safety analyses are documented in sufficient detail to
! permit an independent review and that.the independent reviewer documents the. basis for concurrence.
The inspector verified that the licensee issued.a series of instructions which providea analysts and reviewers with
'the. guidance necessary to ensure appropriate documentation'of each
. analysis and review.
The inspector examined several analyses to assure that the instructions were being followed. No inadequacies were identified-.
(Closed) Violation (1100/86-04-51):
Failure to check operation of the fire door on the virgin powder storage area quarterly under power failure conditions.
The inspector verified that the licensee instituted a procedure to assure that the fire door on the virgin powder storage area wa's checked quarterly to assure that the door closed whenever the fire
-sprinkler system was activated and under power failure conditions.
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I (Closed) Violation (1300/86-04-52):
Failure to evaluate:the storage of.
natural. uranium rods on top of a safe slab'in the Building 2. vault.. Upon notification of this violation, the licensee immediately removed the natural uranium rods from the top of the safe slab.
In lieu of-conducting:an evaluation, the licensee established administrative controls and-procedures to assse that this type of storage would not take place, t,
.The. inspector verifiec periodically between October 1986 and May 1990-thatlthe. licensee properly adhered to these administrative controls.
i (Closed) Violation (1100/87-01-04):
Failure to post areas of the facility with Caution-Radioactive Materials _ signs.
The inspector verified that tne licensee posted the primary access points and appropriate-areas of the Pellet Shop a*. required.
(Closed) Violation'(1100/87-01-05):
Failure to label containers with Caution-Radioactive Materials signs.
The inspector-verified that the licensee' labeled all containers as appropriate.
In addition, the licensee.
' requested a license amendment which would allow posting of signs at all entrances to.the facility which would read "Every container or _.
vessel in this area, unless otherwise identified, may contain radioactive material",.in lieu of labelling all containers.
The amendment approving the use of these signs was issued on January 4,1988.
I (Closed) Violation (1100/87-01-06):
Failure to properly calibrate radiation-detection instrumentation.
The inspector verified that the licensee discontinued use of an in-house instrument calibration facility
. and. selected an appropriate vendor to calibrate radiation detection instrumentation. This vendor continues to calibrate this-1
' instrumentation for the licensee, j
-(Closed) Violation (1100/87-03-01):
Failure to post four of five' furnaces in the-_ pellet Shop with nuclear criticality limit signs.
The inspector verified that.each of the furnaces in the Pellet Shop was posted with nuclear criticality limit signs.
(Closed) Violation (1100/87-03-02):
Failure to maintain a twenty-fcht separation between two arrays of shipping containers.
The inspector verified;that the licensee painted a yellow line on the ground between the two arrays of shipping containers to provide positive assurance that
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the required twenty-foot spacing would not be violated.
(Closed). Violation (1100/87-03-03):
Failure to comply with all nuclear safety controls specified by a nuclear safety evaluation at the fluoroscope work station.
The inspector verified that the licensee installed a positive restraining device on the fluoroscope work station as required by the nuclear safety evaluation to assure that carts containing fuel could not come within twelve inches of the fuel storage rack at the work station.
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L4 (Closed) Violation (1100/88 03-03):
Failure to maintain'pellfets within
- the, required four-inch slab thickness on.the fue' pellet storage shelves.-
The-inspector'. verified that the licensee installe:I a. positive restraining:
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bar and reduced the total quantity of pellets in' trays to e sure that the trays of. pellets'could not-exceed the required four-inch slab thickness.
N' (Closed) Inspector Followup Item (1100/88-03-07): Licensee to establish a' system to assure that controls established on equipment have been e1 installed as required by. written safety evaluations. The licensee has written and implemented two criticality safety. instructions which require v
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a' documented inspection of equipment prior to startup to assure that all required controls have been installed.
96 (Closed) Violation-(1100/88-03-08):
Failure to evaluate the effects of.an o
accumulation of uranium oxide powder under the conveyor' adjacent to the Batch. Makeup Hood on nuclear criticality safety.
The inspector verified that the licensee,.in lieu of conducting this evaluation,. modified the interface between the hood and the conveyor to' preclude the buildup of
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(Closed) Violation (1100/88-03-09):
Failure to control the addition of
'4 uranium oxide powder to the Hammermill Hood te assure that the posted V
mass limit was not exceeded.
The inspector verified that the licensee 1
established.a working mass limit on this hood which was less than the authorized limit to preclude exceeding the authorized limit, In l
- addition, the licensee institu+ai a requirement -to have Pellet Shop' supervisors check each mass lysheet entry for arithmetic mistakes -prior to each transfer, f'
(Closed)JViolation (1100/88-03-11):
Failure to include the uranium-235 contained in sediment removed from liquid waste tanks and pipes in 0
Building 6 on inventory.
Licensee actions were taken to include this a
- quantity.o.f uranium-235 on the facility SNM inventory until shipment to an approved burial site occurred.
This shipment occurred on or about 1
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'May:1, 1988.
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- (Closed) Violation (1100/88-03-12):
Fat (retoadequatelyassessby 4
testing, the results of the nuclear criticality safety training program.
.The-inspector _ verified that the licensee established general employee training and refresher training programs in accordance with Program Document PR-11, "NFM-Training". These programs require testing with a passing grade of 80 percent. Nuclear criticality safety training was included in the testing requirement.
a (Closed) Violation (1100/88-05-01):
Failure to follow a requirement of a Radiation Work permit (RWP).
The failure involved the handling of contaminated ventilation system components by contractor personnel without wearing gloves.
The inspector verified that the contractor personnel involved were immediately removed from the area and reinstructed in the 5
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need to follow instructions specified in RWPs.
In addition, the facility
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Radiological Protection Technicians were also reinstructed to maintain p
surveillance of contractor personnel working under RWPs to ensure appropriate compliance with requirements.
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(Closed) Violation (1100/88-05-02):
Failure to post Building 5 as required L
by 10 CFR 19.
The inspector verified that the licensee posted the documents and/or notices required by 10 CFR 19 at each entrance to the-I building.'-
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'(Closedt Violation (1100/88-05-03):
Failure to properly label waste' p
containers prior to shipment.
The inspector verified that the licensee
- o modified measurement procedures to assure that each package placed into a q
waste container met the 10 CFR 71 special nuclear material exemption bW criteria for shipment so that each waste antainer could t,e properly V+
3abeled.-
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j (N osed) Viviation (1100/t& 05-06):
Failure to properly assay special r
n9 clear material (SNM) in filters. The inspector verified that the 1
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heensee modified assay procedures and trained measurement personnel to l
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-assure that *,he SNb conter,t of each measured filter was bounded by measurement standatds as required by the facility Ft.ndamental Nuclear-Materia 1 ' Control Plan, i
w (Closed) Violation (1100/88-06-03):
Failure to provide indium foils to i
i-P visitors as required by license conditions, The inspector vsrified that the licensee modified each visitor identification badge used at the
' facility to incorporate a piece of indium foil which would be used as an
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~ exposure monitor in case of a nuclear criticality e.scursion at the f,
- facility.
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(Closed) Unresolved item (1100/88-08-01):
Failure to maintain a twenty-L l foot separation between an array of shipoing containers located outside the. facility and shipping containers containing special nuclear material inside the west wall of the Pellet ihop An ex.
The inspector verified-that the array of shipping contai.1ers located outside the west wall of-i
!the facility had been moved and all equipment located inside the west wall
- had been removed as a result of the redeployment of equipment te the CE i
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. Hematite, Missouri facility. As a result of these actions, the identified issue is no longer of concerr.
3.0 Review of Operations m
' 'h The inspector examined selected areas of the plant and the nuclear
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1aboratories.to observe operations and activities in progress, to inspact the nuclear safety aspects of the facilities and to examine the gewral state of cleanliness, housekeeping, adherence to fire protection F
rules, and'the status of redeployment activities.
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3.1 Redeployme_nt' Activities
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During a tour of the Pe11et Shop, the inspector observed that
.redeployment. activities were continuing.
The dewax and sintering
' furnaces.and pellet grinders had been removed and sent to the new pellet manufacturing facility located in Hematite, Missouri. Other
't equipment such as glove boxes, hoods and blenders were removed, cleaned.. cut up.. packaged'and sent to a contractor for
>t decontamination / disposal.
Dfsposal will be subsequently accomplished af ter. decontamint. tion such that the material can.be released for unrestricted use or by burial at an approved burial site.
Equipment which, in the or, inion of licensee personnel, cannot be decontami-nated, will be> packaged and sent directly to an approved burial site.
l The inspector. observed that the licensee removed all fuel powder l
handling equipment from the Pellet Shop and had initiated removal-of the powder blending station metzanine and associated hardware.
Only five operatir,g. workstations remained in the facility at the time of this inspection. These included two general purpose hoods, the 4..
seighing station
...e filter knockdown hood and a hood containing the large wt.ste water ecntrifuge system.
The inspector observed an operator breaking welds'on potentially r
conteminated rigid screening surrounding the former powder hopper elevt. tor station. Although this individual was w2aring a breathing zone sampler, it was noted that the head of the sampler was shielded in the overhead direction by the indivi M 1's coverall collar.
Since the worker was working on areas above his head, this arrangement.would tend to provide questionable information with regard to ' inhalation exposures.
Licensee representatives
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immediately had the individual uncover the sampling heed of.the breathing zone scmpler.
Subsequent evaluation of available general area. air samplers indicated that this individual should not have i
been exposed to significant airborne contamination during the period of time in question.
3.2 Posting of t_he Hydrogen Analyzer Room l
During examination of the Hydrogen Analysis Laboratory located under the FA-3 Mezzanine, the inspector noted that the posted criticality safety control for the laboratory was a four-inch slab.
However, the inspector noted that several trays of pellets located on tables adjacent to'the hydrogen analyzers were marked to identify an eight-kilogram mass as the criticality safety limit for the trays.
The
-inspector. identified the existence of the two limits as an incon-L sistency.
As such, one of the limits should be specifically identified and maintained.
Licensee representatives indicated that L
the use of the two limits in this laboratory would be reevaluated.
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3.3' Building 5 Ceramics Laboratoty Hood __ Ventilation b
During examination of the Building 5 Ceramics Laboratory, the inspector observed that air flow through the face of one hood located along the south wall was between 50 and 80 linear feet per L
minute on a velometer mounted in the opening. At the request of the L
inspector, 41%ensee representative conducted.an air flow' survey of this hood and an adjacent hood using another velometer. At the L
time, uncontained uranium oxide was present in one of the hoods and L
the hood was in use.
This survey verified that the previously 0
obtained air flow was present in both hoods.
Failure to maintain airflow through the face of these hoods at a minimum of 100 linear L'
feet per minute was identified as an apparent violation of Section 3.2.3 of the NRC-approved license application (1100/90-0b-01).-
b 3.4 Building 18 High Bay Area While examining the Guilding 18 high bay area, the fnspector observed L
severai individuals handling a depleted uranium fuel rod bundle without cloth gloves.
ihe use of the clcth gloves was required by Radiation Work Permit (RWP) No.1-90-6, which was scheduled to erpire on June 20, 1990.
Upon identification of this discrepancy by the inspector, actius were taken by the appropriate individuals to locate and use the cloth gloves as required and the individyals were reinstructed in the need to follow all established requirementt of i
RWPs. Since no radiological hazard appeared to be involved and 1
3-actions were taken to immediately correct this inadequacy, this was e
identified as an apparent noncited violation (1100/90-05-02), in that the criteria specified in 10 CFR 2, Appendix C Section V.A. were
-met.
These criteria included; 1) corrective actions were'immediately taken and completed by the licensee, 2) this was a Severity Level V i
violation, and 3).this violation was not willful. Adequate corrective actions were completed by the licensee prior to the end of this inspection.
In accordance with the criteria of 10 CFR 2, t
Appendix C,Section V.A. no Notice'of Violation will be issued for.
this apparent violation, t
4.0 Contaminated Wooded Area l
Through discussions with licensee _ representatives the inspector determined
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that the licensee has assigned a project manager the task of assuring that the wooded area adjacent to and surrounding the former waste storage pad a
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.has been cleaned up. At the exit meeting the inspector once again requested the licensee to provide the NRC with a status report which described the status of the characterization study.
This request was previously made during. inspections 70-1100/89-07 and 70-1100/90-02.
The status report was expected to contain information on the results of the t
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[p characterization study, decontamination plans and procedures,-_and a i
L projected completion date.
Subsequent to this inspection, the licensee i
provided NRC with a letter. report,_dateo June 25, 1990, which included a l
project summary and an overall status to date. A copy of this report is j
attached (Attachment No.1),
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r 5.0 ' Emergency Preparedness l
i-During the course of.this inspection, the inspector observed actions taken by the licensee to respond to emergency drills conducted during the day i
shift at the Building 17 Nuclear Fuel Manufacturing facility and at the Building 5 Nuclear Laboratories. The former drill was held on June 4,1990'and the latter drill was held on June 5,1990.
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, subsequent to the drills, the inspector provided the following comments to i
N licensee representatives for their consideration.
t 5.F lt was noted ty the inspector that the Building.8 emergency equipment tterage area was being vied as the emergency control centir oy assigned emergency directors, but was not equipped with a telephene. As a result, there was no immediate capability available i
for the emergency director te respond to media or outside agency questions in a t;raely manner.
Licensee representatives stated that these italviduals were lecated within 30 feet of a telephone and could leave the control center if necessary.
However, this comment would be reviewed and addressed.
- t 5.2 During one of the drills the inspector observed a guard in the Building 8A East Guard Shack making telephonte notifications to outs'ide_ agencies and persons on the call-in_ list.
However, this 1
individual could not respond to requests for information, and the-emergency director or other licensee management representative was not available to provide the requested information.
These
't individuals were located in Building 8, which was immediately adjacent to the guard shack. This inadequacy was corrected by the licensee during the second observed drill by stationing a management representative, equipped with a hand-held radio, in the guard shack.
This individual was assigned the task of responding to questions received by the guard..
H 5.3 'The inspector questioned the technique of personnel accountability, since emergency response organization staff report directly to the emergency control center without first going through the personnel accountability checkout point located in Building 3.
Licensee representatives stated that procedures will be established to assure i
that all personnel are accounted for during emergencies.
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SA The new emergency control center was located to the south south east of Building 17 and it was noted that the prevailing wind direction was from the south. As a result, survey teams could have to traverse the road immediately adjacent ~to Building 17 in order to find the plume. Because of the.resulting potential for unnecessary exposure of the survey team, the inspector suggested that maps;of the site showing'all available access roads be placed in the emergency control center. This information could be used by the survey teams n
L to reduce radiation exposure to~the team as they conduct onsite i
6 surveys. ' Licensee representatives stated that these maps would be made available at the emergency control center.
. $ hipping and Receiving 6.0 t
6.17 Receipt Surveys The inspector observed as Itcensee pe' sone.cl conducted radiation and contamination wrveys of.a transport vehicle and packages containing r
uranium oxice pellets upon arrival at the site from the Combustion Engineering Hematite, Missouri facility.
No inadequacies were-identified.
6.2 _ Receipt of Empty Boxes l
The inipector observed as a transpurt vehicle (open flatbed trailer)-
entered the Windsor, Connecticut site carrying thiee large wooden i
boxes,1None of the boxes were marked or labeled with official radioactive material signs or markings. Howner, one side of each box contained a piece of yellow tape marked, " Radioactive, Empty-UN29.08 "
Upon examination of the ' hipment Bill of Lading, the inspector s
determined that the wood boxes were identified as being empty-tradioactive shipping containers which had contained radioactive
- na te ri al s.
There was also a' statement on the Bill of Lading which indicated that "the package (s) conforms to the conditions and i
limitations specified in 49 CFR 173.427 for excepted Radioactive Material - Empty Packages-UN2909.
The inspector also determined through discussions with licensee representatives that these packages were previously used to transport contaminated equipment to the Combustion Engineering Inc. Hematite, Missouri facility from the Windsor, Connecticut site. Title 49 CFR 173.427, " Empty radioactive l
materials packaging", states that a packaging which previously b
contained radioactive materials and has been emptied of contents as far as practical, is excepted from the shipping paper and certifi-pu cation, marking and labeling requirements of this subchapter, and i
from requirements of this subpart, provided that:
(a) It complies p
with the requirements of $173.421 (b), (c), and (e); (b) The packaging is in unimpaired condition and is securely closed so that there will be no leakage of radioactive material under conditions normally incident to transportation; (c) Internal contamination does not exceed 100 times the limits in S173.443; (d) Any labels 1
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previously applied in conformance with Subpart E of Part 172 of this i
subchapter are removed, obliterated or covered and the " Empty" label prescribed in 5172.450 is affixed to the packaging; and (e) The:
packaging is prepared for shipment as specified in-$173.421-14 h
Ubon.receiptattheWindsorsite,thethreepackageswerenotmarked with the appropriate " Empty" label prescribed in 49 CFR 172.450 as required by 49 CFR 173.427 (d). As a result, this was identified as i
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'an apparent violation of federal shipping regulations which would be I
cited against the shipper (the Combustion Engineering Hematite, Missouri facility).
Since the Hematite, Missouri. facility is located within the NRC Region III jurisdiction, the above information with regard to this apparent violation will be forwarded to that office for appropriate disposition.
l 7.0' Employee Allegation During the course of this inspection, the inspector held discussions with-
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- a. licensee employee vno stated that the fluoroscope unit rack used to handle uranium-235 containing fuel rods had been modified by the addition of foam rubber or wooden block!. to support the rods, on or about 1
April-6,1990 and no criticality safety evaluation was con &Jeted to show that,this' modification was safe.
In audition, this incident was not
. investigated by the Facility Review Group or the Abnormal Event Occurrence r
Review Committee as required by licensee procedares, af tet being reported to management on or about April 6, 1990.
Licensee representatives 1
indicated that a critictlity' safety evaluation was not conducted because-the wood. blocks and foam rubber were removed immediately after being reported;1and also stated that the event was not invenigated to determine-the root causes of the incident.
Failure to evaluate the effect rf the addition-of the wood blocks and the foam rubber on the criticaH ty safety
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.ofLthe fluoroscope work station was identified as an apparent violation (1100/90-05-03).of Section 4.1.5 of the NRC-approved license application.
In addition, failure of the Abnormal Event Occurrence Review Committee to conduct an investigation of the root causes of this incident was also
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< identified as an apparent violation of Administrative Procedure AP-1,
" Abnormal Event Occurrence Reporting Procedure" (1100/90-05-04).
Upon i
notification of these apparent violations to licensee management i
representatives by the inspector, actions were immediately taken by the.
7 licensee to initiate a nuclear criticality safety evaluation and an l.
- investigation of the root causes for this incident.
These actions were L
not completed by the end of this inspection.
8.0' Fire Protection Program Review During this inspection, the inspector was accompanied to the Windsor site
.by.a fire protection engineer assigned to the NRC Office of Nuclear Material Safety and Safeguards (NMSS).
The Windsor site fire protection
. program was measured against the requirements of the recently published j
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Branch Technical Position on fire protection, as well as prevalent industry styndards, notably the National Fire Protection Association codes.
Ir. performing the assessment, the fire protection engineer l
examined all buildings and adjacent outdoor storage, materials handling,.
_l and equ*pment areas which house or support licensed activities.
l Documents were examined for.the purpose of assessing the licensee's
. commitment-to the fire protection program and performance of procedures.
The assessment methods also included examination of randomly selected j'
E portable extinguishers, installed fire protection equipment, process equipment, and past inspection reports of American Nuclear Insurers (ANI).
Several facility employees and offsite Fire Department personnel were also interviewed.
I 8.1 Building Fire Safety 1
The fuel manufacturing processes of the facility are located in i
Building 17.
This is a high-bay structure of steel frame, concrete i
-floor, a composite. "transite" and fiberglass insulating board outer L
shell and a built-up roof-on pypsum deck.
The entire building,
.i including the adjoining annex, is covered by fixed automatic sprinkitr systems.
This coverage was determined to be adequate and no deficiencies were identified.
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'in addition to the main fuel manufceturing building (Building 17),
the fire safnty engineer also touwea the f 611owing other buildings, in ubich licensed activities were performed or because of their importance to the overall fire safety of the site, 1.
" Buildings.1 and 1A: Storage i
2.
Buildings 2 ano 2A:
Engineering Development & Services
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Buildings 3 and 3A:
Kreisinger Development Laboratory 4.
Building 5:
Engineering Development Laboratory 5.
- Building 6:
Liquid Waste Retention Vault 1
6.
Building 6A:
Maintenance Shop 7.
Building 8A:
Site Security Building 8.
Building 11:
Fire Pump House 9.
Building.16:
Mcdel Shop 4
'10.. Building 18:
Engineering Development Laboratory (high-bay building, adjacent _to Building 5)
- 11.. Building 21:
Nuclear Products Manufacturing Warehouse i
Of these, buildings, fire protection of the Building 16, Model Shop, was determined to be inadequate.
This building contained a moderate 1
to heavy fire load, mainly consisting of ordinary combustibl9 ;, such as wood and plastic.
Hot working with blow-torches was frequently performed in this building, as determined from actual observation and through interviews with employees. One employee was observed "taking l-the sheen off" plastic shipping containers with a blow-torch for the l
purpose of stenciling, without benefit of a formal " hot working l
permit" or a fire watch.
In addition, this building did not have an L
installed automatic fire suppression system.
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However, the high-bay test facility
' portion;of Building 2, used for storage of combustible packages, was
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not covered by'an automatic suppression system. The fire ~ load,
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combined _with the potentially contaminated controlled zonesc hould s
p necessitate the use of ore or more automatic fire suppression systems F
in the area. The fire protection engineer also noted that a written F
e evaluation of the area by American Nuclear Insurers also resulted in L
a similar recommendation, The fire protection' engineer recommended g
that the licensee review and correct fire protection problems" p
identified in Buildings 2 and 16 (1100/90-05-05)..
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The Building 21 Warehouse facility was fully covered by a sprinkler system, which was determined to provide adequate fire protection.for i
the building. However, a yard storage and dispensing area for p
lubricants and other combustible liquids located within 15. feet to 4
the south was determined to be a potential hazard to the building.
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This matter was discussed with the facility management,' Facility i
management indicated that this yard storage would be eliminated in the near future. The fire protection engineer also noted another oil-dispensing area 2nd storage of about six 55 gallon oil containing drums located in the southeast corner of the building.
Facility management also committee to remove these so that no combustible liquid would be dispensed in or near the building, The fire-protection engineer also examined a newly installed portable Factory Mutual-approved 1 9mmable liquids shed constructed for.the purpose of storing these liquidt.
This shed was located in-the. Building 17 north yard at a suffic'ent distance away from the other buildings.
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All other buildings examined were' deter.nined to have adequate firo protection equipment.
8,2 Process Fire Safet/
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The fire protection engineer examined the manufacturing process and related equipment for-fire safety.
Two outdoor anhydrous ammonia storage tanks and an ancillary equipment building for dissociation of the gas were located to the north of Building 17, One of the J
tanks, 6,000-gallon capacity, was found to be in use, and the other 1
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was empty and awaiting removal. The dissociated gas was piped into Building 17 for use in the pellet drying furnace, This furnace was
.m not fitted with a flame supervision device for the natural gas flame used to burn off the hydrogen, These flame supervision devices are r
required by NFPA 86C, " Standard for Industrial Furnaces Using a Special Processing Atmosphere",
The fire protection engineer recommended tnat the-licensee install a supervision and alarm system on this furnace (1100/90-05-06).
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h The nitric acid pickling area in Building 17 and' the basement were also inspected.
No deficiencies were identified.
J Zircalloy' chips produced in the Building 17 machine shop.were stored in marked containers under water until removed from the t,uilding.
K Sealed drums of zircalloy chips were then stored in seatainer L
shipping container:; away from the buildings, until disposal. No deficiencies were identified.
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.The fire protection engineer observed a yard storage and dispensing-area to the west of the. Building 6A, Maintenance Shop.
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dispensing 55 gallon drums of combustible liquids, including one.
1 containing trichloroethane, were stored on racks which were not 4
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electrically grounded.
There was evidence of previous liquid. spills
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which flowed to a " retention basin" nearby. This retention basin, i
which appeared to be an unlined hole in the ground, was a potential pollution source for a nearby pond and was also a fire hazard. Upon f
identification of this hazard to management personnel, removal of the drums was immediately initiated.
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8.3~ Fire Protection Equipment i
The Windsor site is protected by fire water, supplied by the o
Metropolitan District Commission of Hartforo, Connecticut, consisting of a total of 425,000 gallons stored in storage tunks.
The rematnder
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'of the fire water delivery system consists of ore diesel and one
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electric fire pump, a jockey pump, an 8" fire main, and an adequate number of fire hydranti, to service the 5.ite buildings.- The fire f
water and delivery systems were determioed co be adequate.
In-addition to the fixed fire suppression equipment (sprink*iers, stand pipes and hose systems) mention'ed above, portable fire c
extinguishers were depicyed throughout the site.
The fire protection engineer selected at random and inspected several fire extinguishers.
The type and capacity of the extinguishers were appropriate and the monthly. inspection tags, for the most part, were up-to-date.
However, exceptions were found in that a few extinguishers located in Building 5, had not been inspected during the month of May 1990, Rate-of-temperature-rise type fire detectors were located in the o
fuel manufacturing areas of Building 17. These were connected to an -
annunciator panel in the guard house located at the entrance to the building.
The fire protection engineer requested the licensee to conduct a test of the alarm system.
No deficiencies were noted-Pull-boxes were installed at several locations throughout Building 17.
However, the fire protection engineer recommended that the licensee install additional pull-boxes at two additional strategic i
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locations near exit doors in the Cold Shop (south side) and the,
Pellet Shop Annex on the north side of the building.. The' pull-boxes, fire detectors, and sprinkler flow sensors were i
connected to a central annunciator panel at the Site Security
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Building, Building 8A. No deficiencies were found in the alarm system.
Fire protection equipment maintenance records were examined for' timely inspection and maintenance of the equipment. Maintenance L
records of portable extinguishers and the fire pumps were examined..
The records indicated that the fire pumpt were. tested annually.
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However, there were.no records available to confirm that weekly ~ run tests of the pumps and.the diesel engine were_ conducted. Thus the
-licensee could not demonstrate that these tests were conducted. NFPA 20, Centrifugal Fire Pumps, requires that " engines shall be started no less than once a week and run for no less than 30 minutes to attain normal temperature." Also, the automatic operation of the pumps should be tested weekly, and "at least one start shall be accomplished by reducing the water pressure".
Records of maintenance of the diesel engine and the batterles were also unavailable!at the j
time of this review.
In addition, there was no evidence f. hat the fire hoses (located in Building 2) had ever been. tested.
" Standard for the Care, Use, and Maintenance of Fire Hose Including Connections and Nozzles," requires annual testing and inspections.
The' licensee was not able to denonstrate that these tests and inspections hac bsen conducted.
As a result, the fire protection engineer recommtnded that the licensee initiate weekly fire pump and
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diesel starts and annual fire hose and fitting inspections and tests.
if'they-are not currently being perfo med and that appropriate records be maintained of these tests ard inspections (1100/90-05-07).
1 The fire protection engineee also determined that fire protection equipment maintenance and record keeping.needed to be improved-in i
that equipment maintenance records should be in one place and under P
the control of one office, so that appropriate maintenance could be tracked.
The fire protection engineer recommended that a comprehensive fire protection equipment maintenance program be initiated with an improved record keeping and maintenance tracking system (1100/90-05-08).
8.4 Pre-Fire Planning The fire protection engineer examined the Radiological Contingency Plan for the facility and the Emergency Plan Implementing Procedures. Both contained planning information relating to emergency responses including fire emergencies.
However, particular information that would be required by facility employees and offsite
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fire brigade personnel, e.g., a pre-fire plan, was unavailable. A pre-fire plan should provide information on the facility, such as t
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19 location,. quantity, and nature of the combustibles in each area; 1
restriction of fire-fighting methods, such as use of. fire hose streams; and' location of.the pumps, post indicator valves, hydrants, stand pipes, sprinkler valves, fire department compatible couplings.-
etc., preferably with drawings and charts. The fire protection engineer recommended.that the licensee establish a formal pre-fire plan which would complement the facility Radiological Contingency Plan (1100/90-05-09).
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The fire protection engineer was subsequently informed by-the licensee by letter dated June 18, 1990, that the Poquonock Fire Company has a drawing showing the location of the fire mains, hydrants, and-post indicator valves for~ the entire site, and that s
additional drawings on critical systems for Building 17, are available at.the Building 8/8A emergency control center. The fire protection engineer recommended that Emergency Plan. Implementing Procedure EPIP 3.01, " Fire / Explosion", be expanded to constitute the pre-fire plan which should include these drawings.
The~ licensee does not provide fire fighting training to any one group-of employees, e.g. a fire brigade.
However, there is a plan to provide fire extinguisher training to all. employees.
This training, which will not include the use of live fires, was initiated during the second week 'of June,1990.
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During this review the fire protection engineer interviewed the fire chief of the Poquonock, Connecticut, Volunteer Fire Department.
Thi s fire department is the first umt expected to come to the aid uf the Windsor site in the event of fire or non-fire emergencies. However, the fire protection engineer determined from the fire chief that the licensee did not routinely have'the crew of the fire department tour the' facility once a year for the purpose of familiarizing themselves j
with particular onsite hazards and fire protection features.
Since the facility lacks a trained fire brigade, the fire protection engineer considered it especially important for the fire department
'to be well acquainted with the facility.
Therefore, the fire protection engineer recommended that all members of the local fire department be invited to visit the facility at least annually to familiarize themselves with the facility (1100/90-05-10).
The fire protection engineer determined that evacuation drills, including some with fire scenarios,were held once each six months at Building 17.
However, no critiques of these drills were available
.for inspection and no drills have been performed in recent years-with onsite participation of offsite fire departments and rescue organizations.
The fire protection engineer recommended that the licensee include offsite fire department personnel in drills on a s
regular basis (1100/90-05-11).
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8.5-Administrative Controls The fire protection engineer examined the following documents in L
order to: determine the extent of administrative controls exercised over facility modification / change procedures insofar as it affects fire safety, hazardous operations, such as welding and other hot working, housekeeping, and safety audits.
1.
Change / Modification Request Procedure:
Such requests are.
reviewed for fire safety'by the Industrial Safety Specialist, u
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NFM Safety Committee minutes: Meetings of this committee i
have been held quarterly.. Safety issues were discussed' F
and corrective steps were reviewed.
3.
Industrial Safety Instructions (ISI):
The following ISIS were reviewed.
ISI 104: Hazard Communications 151-105:
Nitric Acid Use in the Pickling Process l
151 108: Hot Working Permit. This document detailed the procedure to be followed for the issuance of hot working (welding, torch-cutting, etc.) permits and the. precautions to be taken, including posting of the fire watch and providing fire extinguishers.
However, this ISI has not been implemented since employees had not been trained in fire extinguisher use.
This training was scheduled for the second week of June 1990.
ISI 109:
Portable Fire Extinguishers.
Locations of portable fire extinguisbars and the procedure and forms for recording of test performance of the extinguishers were provided in the-137.
No inadequacies were found'in the documentation reviewed.
However, the fire protection engineer was concerned about the-effectiveness of the administrative controls in the area of' housekeeping in that several. rooms in Building 5 were cluttered with sundry objects, such as empty cardboard boxes, that should.
have been removed; several eye-wash' stations were obstructed by debris,. including a jar of corrosive liquid found in the I
Environmental Laboratory; the Building 21, Warehouse, had
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several of its aisles obstructed with wooden pallets, hand
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carts, cardboard boxes, and shipping containers.
In-aisle storage reduces the effective width of the aisle and invalidates sprinkler calculations.
As a result of these observations, the fire protection engineer recommended that the licensee institute l
more restrictive housekeeping measures (1100/90-05-12).
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9.0/ Exit Interview s3 The 1'nspector. met with the licensee representatives (denoted in Paragraph.
1).'at, the conclusion of. the inspection on June'8.- 1990.: The inspector-t engineer also provided the 11cer.see with the recommendations for fire-
' summarized-the' scope' and findings of the inspection.. The fire protection :
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.., protection, program improvements made during the cource of this onsite
- review. The: licensee indicated that-these recommendations would be i
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reviewed =and appropriate = actions would be taken..
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ASEA DROWN DOVERI June 25, 1990
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i U.S. Nuclear Regulatory Commission i
Region 1 1
631 Park Avenue King of Prussia, Pennsylvania 19406 l
Attention: Mr. Jerome Roth 1
l
Subject:
Soil Contaminated with Radioactive Materials
Reference:
Letter LD-89 128, A. E. Scherer (C-E) to J. Roth (NRC) dated November 22, 1989 e
Dear Mr. Roth:
The referenced letter noted that operations to characterize and cleanup radioactive contamination of an area near a former low level radioactive waste storage pad had been suspended for the winter.
This letter is to provide a project summary and an overall status to date.
In April and May of 1989, based u)on preliminary radiation surveys, preliminaiy 30' x 30' grids were esta)lished and resurveyed. Approximately 1000 gamma survey readings confirm that the contaminated area had been bounded. As previously reported, the contaminated arca had been posted and isolated from normal access. Measured radiation in the isolated area is
(.pproxin.ately 10 microrem/ hour or almost undetectable above natural background in the Windsor area.
Surface gamma meter readings at the highest " Hot Spots" were 10 to 100 times background. While these
- Hot Spots" are therefore readily identifiable via the surface survey, their boundhries are somewhat diffused.
In June of 1989, 14 samples were collected and counted with a germanium gamma spectrometer system.
Leaves and other organic raaterial were removed
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prior to collecting the samples.
Estimated enrichment, based on long counts, is 89%.
Resulting U235 concentrations were greater than 5000 pCi/gm in sampled " Hot Spots'.
Radioactive material seems to be concentrated at or near the surface of the soil.
l In November of 1989 an additional 31 soil samples were collected for counting. Several divided samples were submitted to an outside facility for confirmation by mass spectrographic analysis.
While many of the samples y
produced results of less than 30 pCi/gm, values of two decades higher were noted from certain " Hot Spots
- near the surface.
ABB Combustion Engineering Nuclear Power
___.,._._._.._.__.m Comtostori Engeeemg inc Prostat Pi Road tw e( 3) M81911 Wmde Comecucut 06095'0500 Telen 99297 COMBEN WSOR
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1 Mr. Jerome Roth Page 2 of 2 l
l All sampling and survey work has been done in accordance with radiological control procedures to our existing licenses.
Radiation exposure for workers involved to date in this activity is below detectable limits.
Long term i
sosting of TLD's for Area Monitors have indicated no detectable change in sackground over tha past 2 years.
Procedures and work instructions are being updated in preparation for i
further sampling and collection of material from the " Hot Spots". We have submitted additional sam)1es to outside facilities for crosscheck analysis by alternate separation $+:1niques as we study the preferred method of conducting remedial activities. This information, plus additional sam)1ing, should allow completion of a characterization of the site during tie summer.
Preparation of a project plan and schedule for cleanup, as discussed during your last visit to the Windsor Site, is currently scheduled for August.
I Very truly yours, COMBUSTION ENGINEERING, INC.
/hh J. C. MOULTON PROJECT MANAGER 4
cc: Mr. T.A. Bisnett, DOE, NRO, Schenectady Mr. Kevin T.A. McCarthy, DEP, Connecticut Mr. Sean Soong, NRC, Washington l
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l-DS90-028 i
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