ML20058F528

Insp Rept 70-0036/90-03 on 900806-10.Violation Noted.Major Areas Inspected:Licensee Performance in Areas of Mgt Organization & Controls,Radiation Protection,Operations Review,Radwaste Mgt & Criticality Safety

ML20058F528
Person / Time
Site:	07000036
Issue date:	10/26/1990
From:	Bidinger G, Doman J, France G, Grobe J, Roth J, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20058F523	List: ML20058F521 ML20058F526 ML20058F528
References
70-0036-90-03, 70-36-90-3, NUDOCS 9011080331
Download: ML20058F528 (21)

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Results

With'in'the areasiinspected there-'were two violations. One violation d

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for-failure?to post criticality safety instructions; and, one violation for-failure to. affix. appropriate labelling in transporting empty--packa Aslist of: concerns (open items' follow-up items and unresolved-. items) ges, j,

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-' require? additional management 1 attention were identified.

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DETAILS 1.

Persons Contscted B. Pigg, -Quality Control Laboratory Supervisor

• L. Deul, Panufacturing Engineer

• H. Eskridge, Manager, Nuclear Licensing, Safety and Acccuntability

• R. Fromm, Manager, Quality-Assurance

• R. Griscom, Plant Engineering Supervisor

• L..Grossman, Director, Manufacturir.g Technology

• R. -Klotz,_ Criticality Specialist (Corporate)

R. Miller,-Manager, Administration and Production Control A.. Noack, Production Superintendent

• J. Rode, Plant Manager During the inspection, members of the NRC interviewed the above members of the licensee's staff,.along with other staff members, and<several operations and health physics technicians.

• Denotes those in attendance during the exit meeting which was held at '

10:00 a.m. on August 10, 1990.

'2.

-Licensee Actions on Previously Identified Items (Inspection Report No. 70-0036/90002)'

- a '.

(Closed) Open Item-01

'" Document. surveys to show that radioactive material intake for workers who do not receive whole body counts is below the measurement level specified in 10 CFR 20.103 (a)(3)."-

Plant operators have whole body radiation measurements on at least D:

an annual basis and in.some cases more frequently as defined by'the Manager of NLS&A in accordance with Regulatory Guide 8;11. Other individuals ~ were included as group representatives or if' they were-involved in activities where the 10 CFR 20.103 (a)(3) limits could have been exceeded.

Although the analysis of work functions' performed and plant area sample levels show. that the pc3sibility of exceeding these limits are remote, the licensee intends to whole body in-vivo count all

individuals who frequently enter. plant processing areas at least every two. years. This commitment does-not include occasional visitors such as inspectors, auditors or' secretaries.

This item 'is closed. ' Region III inspectors will monitor the licensee's performance in this area during future inspections.

5

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b.-

(Closed) Open Item-02

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'"00cument surveys for jobs not under lapel air sampling surveillance; show that airborne concentrations for workers in these areas are below the level specified in 10 CFR 20.103(a)(3)."

Additional lapel monitoring has been performed to document that airborne exposures in assignments not included in routine lapel monitoring are -below the levels specified in 10 CFR 20.103 (a)(3).

All. samples were below the 2 MPC-hour-per day limit though somewhat higher than the fixed station concentrations.

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.This item is closed.

l c.

(Closed) Open Item-03

" Develop,a procedure to indicate both the routine jobs and specific tasks that require lapel sampling."

Based on the results of the lapel monitoring discussed in Item 02,-

Material: Control Operators will be monitored routinely and the licensee will continue.to monitor other jobs periodically to assure c

the validity, of the sampling program.

This item is cl e d.

The licensee's performance in this area will be monitored during future inspections, d.-

(Closed)'Open Item-04

" Determine the range of airborne concentrations or the maximum airborne concentration for the continuous air monitor alarm set points that are used."

The ALPHA-6. continuous air monitors (CAMS) are very effective for detecting rapid-increases in the concentration of airborne uranium.

The intent of' installing the CAM's, however, was not to substitute efor the fixed sampler programs as a record of exposures, but to more

' rapidly detect changes in air concentrations. L The CAM's have.been an asset.in this respect..The fixed. samplers will be used to determine air-concentration levels.

-This item is closed. During future inspections ~this area will' be examined to assure that fixed sampling programs are adequate to maintain a record of exposure.

a-e.

-(Ciosed) Open Item-05

" Monitor employee.compliaice with exit surveys before' leaving the change room; heighten aws.reness among the workers about change room procedures."

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i Employee compliance with exit surveys before leaving the change rooms will be monitored by conducting unannounced overcheck surveys after the employees leave the change rooms. The overcheck surveys will be conducted by a Health Physics Technician a a nominal monthly basis. Awareness about change room procedures was heightened by emphasis during the annual radiation safety retraining in August, 1990.

-This' item is closed, f.

(Closed) Open Item-06

-~" Sample-liquid effluents from the storm and sanitary sewer systems at the point where they leave the discharge pipes; report the combined data in semiannual Liquid Effluent report."

In addition to the siti dam discharge, both the sanitary and storm L

sewer discharges are now routinely sampled. The site dam and e

sanitary sewer data will be combined for the semiannual effluent i

release report (the storm sewer discharge is upstream of the site dam)

Any necessary changes to the license will be discussed with NRC. Licensing.

This item is closed.

g.

(0 pen)'.0 pen Item-07

" Adopt a recognized procedure for obtaining well water samples."

'It is the licensee's intent to comply with this request.

Efforts are continuing to review industry standards so they can be incorporated in a procedure specific for the Hematite Facility.

..This item will. remain open until further review.

h.

(0 pen) Open Item-08 t

'Getermine-through documented. surveys that material / equipment in 4

storage barns is below-the licensee's release levels for radioactive contamination,-return any equipment contaminated above the release

-level tonthe restr.icted area for storage until final disposition,

. alternatively, petition for license-amendment to treat the storage barn as a-radiation area in accordance with 10 CFR'20 requirements."

Equipment which may reasonably.be suspected to have accessible uranium will be. moved from the barn to Building 253, surveyed and-l, cleaned for release or dispositioned for burial.

The licensee expects to begin this activity about September 10, 1990, and complete work by.the end of 1991.

The inventory of 250-2 shipping containers have been surveyed for H

accessible uranium and will not be dealt with at this time, though eventually-they too will require disassembly.

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This item will remain open for additional review by Region III inspectors.

1-i.

(Closed) Open Item-09

" Review the problems associated with filter oxide loading in the poreformer operations hood; assure that an independent audit is performed to prevent UQ buildup behind the filter."

2 Af ter several assay changes, only a minor accumulation of UO (much 2

less than a kilogram) has been found behind the pre-filters.

The assey change procedures will be modified to identify the quantity (weight) on the filters.

The pre-filters collapse when heavily loaded,.i.e.. when containing 10 kg of UOjand the need for replacement.is obvious long before this happens.

This item is closed. This item was reviewed by NMSS representatives i

for nuclear criticality concerns during this inspection (Inspection

. Report No. 70-0036/90003).

The f.ilters were free of UO2 accumulation and the operator seemed aware of the procedure to-change the prefilters.

Region.III will review the licensee's

. procedure for-handling UQ loaded pre-filters during a future g

inspection.

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IClosed)0penItem-10

" Develop engineering controls to mitigate the generation of limestone dust during the changeout of spent scrubber material."

TheLuse of dumpsters-for unloading the limestone scrubbers has been

'I demonstrated to mitigate the generation of dust. When procedures have been prepared and NLS&A approval accomplished, the method of unloading and-sampling will be changed to-permit use of.the

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-dumpsters. This should be complete by the end of the year..

.This item is closed.. The self-dumping hopper was observed by the inspectors. -The licensee plans.to use five hoppers for changeout of

.the spent limestone..This program will be monitored during future inspections, k.-

(Closed) Open Item-11

" Repair / replace the temperature indicator gauge on_the scrubber exhaust of No.1 incinerator."

The temperature. gauge has been replaced with a thermocouple.

This item is closed. The inspector confirmed by observation that the thermocouple had been installed.

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.1.

(Closed) Open Item-12

" Develop an inspection procedure to identify cracked packing

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glands.

Submit _a report of licensee findings to NRC-NMSS.

Include bioassay / dose assessment data."

After discussion with Martin-Marrietta (Portsmouth), the licensee concluded'that damage of-the type encountered should be detectable by visual inspection. The receiving inspection procedure has been revised to require visual inspection of the packing gland retainer.

When in -doubt, the packing gland retainer will be replaced.

Based on the licensee's report, a bioassay assessment showed the exposure to workers was less than 40 MPC-hours.

This item is closed.

m.

(Closed) Open-Item-13

" Identify ways to -prevent moisture or other foreign material from intruding into an uncovered blender vessel."

When uncovered blenders are open, no~ moderator, other than iporeformer will be permitted on the upper deck (third floor) and the area will-be posted for this interval. After reciosing the.

-blenders,'the assay change procedure will require opening the cone valve on each blender to assure that no liquid has accumulated in the blender. These changes will be completed prior to use of the blenders with SNM. An inner-ceiling and an inner wall prevent rain

'from entering the building.

This item is closed.

During future inspections, the' Region will determine-if other equipment should be protected from rain water.

4 3.

Management Organization and Control (IP 88005)

The-Health. Physics supervi.sor resigned his employment since the last inspection on April 23-27,.1990 (70-0036/90002)~. 'The licensee reassigned a Health Physics Technician to the position of. Supervisor, Health.

. Physics. The. licensee noted that the new Health Physics Supervisor meets the minimum experience requirements for this_ position as outlined-in the license. A new technician was hired to fill the vacant technician slot.

The licensee should consider / provide' additional training for the supervisor ~and other technicians to-impro've their technical skills (0 pen

-Item _No. 70-0036/90003-01).

One concern-wss identified.

4.

Radiation protection (IP 83822)-

0-The. inspectors reviewed the licensee's internal and external exposure control. programs, including the required records and notifications.

The inspector also observed the licensee's program for preventing the spread I

of contamination.

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Internal Exposure Control t

Monthly bioassay samples are analyzed by the licensee's corporate laboratory which is located in Windsor, Connecticut..All samples above 50ug U/ liter require an immediate restriction of the individual to jobs where airborne radioactivity levels are not

-expected to exceed 10% MPC. A review of bioassay records covering the April through July,1990 operating period indicated that sampla results were below the level that requires an employee to be placed on restriction. Hence, the 40 MPC-hour intake limit as discussed in i

10 CFR 20 for uranium had not been exceeded. Whole body counts for 36 plant workers were below the 130 ugm uranium-235 action level, b.

External Exposure Control A review of the licensee's film badge data for the operating period April through July, 1990,-disclosed that individual exposure was less than the limits allowed under 10 CFR 20.101.

c.

Maintaining Occupational Exposures ALARA The men's locker room (restricted area) was surveyed for contamination control, during the course of this inspection.

.Smearable contamination levels were less than 500 dpm. alpha /100cm2, Although fixed levels of. contamination (3,300 dpm alpha /100cm ) were.

2 less contamination than the action limits (5,000 dpm alpha /100cm2),

. the level is significantly higher than good ALARA r.actices indicate.

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The floor area beneath the lockers-which is only cleaned monthly, should be cleaned more often to reduce contamination and improve

<s housekeeping (0 pen Item No. 70-0036/90003-02).

d.

Airborne Releases I

The inspector reviewed: licensee records of air sample analyses.

i LArea air samplers located in the revitalized facility measure the airborne radioactivity-from uranium oxide powder and/or pellet handling. operations conducted in the utility hood, grinder sintering furnaces, pellet presses and the plugging press. The sample data

' ranged from 0.1E-10uCi/mi to 0.34E-10uci/ml.

These levels are lower than 1.0E-10uCi/m1,.the limit for insoluble uranium-235 as listed in 10 CFR 20.

No MPC-hour assignment exceeding the regulatory requirement was noted.

e.

Leak Testing Sealed Sources '

. Leak tests were performed on two sealed sources (cobalt-60, contai'ning 10 and 17. mil 11 curies respectively). The leak tests- (performed at six-month intervals). results were less than 0.005 microcuries of removable contamination, 10

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Contamination Control The inspector observed operators repairing the contaminated J

rotary press.

It was noted that the head of one individual was located inside the contaminated prese enclosure as the individual was handling contaminated equipment inside the press enclosure.

That individual was wearing cotton and not rubber gloves while handling the contaminated equipment and did not use a respirator to control exposure to airborne contamination although a respirator was immediately available around the individual's neck.

The. licensee's program identifies general tasks that-require use of a half-mask respirator.

Removing, cleaning, working on press l

tooling, and changing prest 6:ed pails; and cleaning out shuttle box and hoses (presses) are listed as such -tasks.

The inspector

• l discerned'that these instructions appeared to be too vague. The operating sheets that provide instructions for pellet operation and-services should spell out the need for respirator usage.

q The Plant Superintendent indicated that reassembEy of decontaminated parts of the pellet press'did not require the use of a respirater.

The inspector discerned that the worker seemed unaware that she had positioned her head inside~the press enclosure to complete the reassembly'of the. pellet press. Although a health physics.

7

. technician furnished documentation that supported the licensee's claim that the enclosure was under adequate ventilation, the inspector observed;that chipped pieces / pellets of. uranium oxide were located at.the bottom of the pellet press enclosure.

The. presence of uranium oxide pellets (together with loose pellet chips) could also serve as a source for the emanation.of respirable a

quantities of uranium oxide.

This condition could pose an T

inhalation problem for workers who perform maintenance in the pellet press enclosure without proper respiratory protection. _The-inspector identified this activity:as a weakness in that the facility radiation protection procedures did.not prohibit the activity as observed. During the exit interview the licensee was. requested to

. address this program-weakness. The.results of this action should be i

docuinented for future review by a Region III inspector. -(0 pen' Item No.-70-0036/90003-03).

g;

. Personnel Monitoring Reports.

i The inspector observed that the licensee's format for documenting i

-total exposure in letters of termination to-individual workers was difficult to interpret.

The licensee modified the format during the a

course of this' inspection..Hence, compliance with 10 CFR 20.408

/,

. appeared adequate.

p Two. concerns were identified.

4 11

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l 5 ~. : Operations l Review (IP 88020)_

The. inspector toured the facility and observed operations and activities in progress, examined the general status of facility housekeeping, reviewed the' licensee's adherence to OSHA related safety issues, and examined the licensee's procedures for handling 21-ton cylinders used in s

s the containment of uranium hexafluoride.

a_

Review of UF;0perations A review of UFchandling procedures was made in regard to the guidelines con'tained in 00E document OR0-651 Revision V " Uranium Hexafluoride:

Handling Procedures and Container Criteria."

Operations in the cylinder storage area,- UF feed area, and oxide t

production areas were observed.

The follow'ing comments apply:

During examination of the unused filter sock cleanout hood located on the secor.d level of Building 254, the inspector observed that the front of this hood was open, that the hood r

was: contaminated and that there was no dirflow through the hood opening.

The licensee immediately opened a slider valve on the ventilation system. As a result of this action, adequate airflow was.provided to-the hood.

The. use of a CAM (Continuous Air Monitor) in the upper level of.

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oxide production area is to be commended, as it aided in idiscovery of-the UF release on August 28, 1989.

-j 6

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' Cylinder' inspection sheets, "UF Cylinder Inspection Form" used 6

by Cor.Lustion Engineering'were updated to reflect documentation-

.of. ins'pection of cylinder valve for possible defects.

5

. Operating Sheets- (OS-601) will oe updated to provide

' specific instructions on leak testing.of cylinder valve and 4

pigtail.

4 Cylinder leak testing.cannot be accomplished at 0.5 psia, and

.at or above normal feed' pressure due,to. configuration of manifold piping.-

Recommendation is made that :CE review its -

procedures to assure itself that they are consistent with DOE o

document ORO-651' Revision'V.. A compound gauge'would be required

.to;do bothra-low pressur. and high pressure test of the pigtail I

and-cylinder yalve (0 pen Item No. 70-0036/90003-04).

b, Housekeeping.

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Housekee' ping arrangements were adequate enough to allow evacuation routes to remain open. However, -general housekeeping practices 4

showed' signs of deteriorating.

The licensee's facility is undergoing revitalization and expansion and roofing scrap material was stored in disarray, During a tour of the facility the inspectors-1

-also observed the following:

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0 The UF feed area was well maintained and appeared free of contamination.

The oxide production area was well maintained and free of l

clutter.

The outdoor cylinder storage area could be better organized,

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with attention to proper posting of signs.

The Uf cylinder 6

storage cradles are deteriorating.

The cradles are of wood construction and should be repaired / replaced as needed.

The contaminated areas were not properly defined, specifically,' rope barriers which had been put up to identify such areas (demarcated pathways) had fallen down (0 pen Item 10-0036/90003-05),

c.

Dosimetry Tracking The licensee has recently installed a computer network, primarily i

geared for production needs, but also available for data base dosimetry ' logging, tracking and report' generation.. While the r

sy-tem is not 100%. debugged yet, it appears to be an excellent J

Estep in aiding this licensee in conforming to Part 20 records requirements. Until the system is. fully operational, care should be taken to assure results are transmitted back to individuals who need such information in performing their assignments, or in evaluating health physics trends, d..

.Nunradiological Safety Issues During~this. inspection the following items, relative to OSHA safety issues were noted by the inspector.

Each~ot the items were discussed with the licensee, o

-(1) propane Cylinder Storage

'During the, inspection it.was observed that several propane l

cylinders were improperly stored on the south side of the shipping and receiving area.

The licensee indicated that these

. cylinders would be stored ic a proper manner (protected area i

with cylinder restraining mechanisms).

(2). Anhydrous Ammonia Tank

'The inspector examined the anhydrous ammonia tank to determine if the tank was electrically grounded.

No ground was'found. A 1

. ground would provide an' electrical discharge path in case of a

. lightning strike so that damage to the tank.would be minimized.

Licensee representatives stated that installation-of a ground would be evaluated and' appropriate action would be taken.

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(3) Flammable Liquid Storage -

The inspector examined the flammable liquid storage building located to the west of the Recycle Recovery Area.

It was

. determined that the storage building was not protected by a fire suppression system and that the nearest fire extinguisher was located inside the main building at least 15 feet away.

Licensee ' representatives stated that the storage of flammable liquid will be reevaluated and actions will be taken as appropriate.

(4) High Pressure Gas Cylinder Storage The inspector observed that several high pressure gas cylinders were unsecured.

They were stored in the horizontal position in an open area, rather than being secured in.a vertical position. The licensee indicated that'the cylinders were empty and placed in the horizontal position in order to-facilitate a radiation survey.

While-itis realized that it is_ difficult to survey the bottom

of these cylinders, they have to be maintained in an upright position with valve caps on, in a chained or restrained position, regardless of their full or empty status. The licensee indicated that the cylinders would be properly stored.

i,,

This observation is similar to, but not the same as the OSHA 4

finding of an improperly supported gas cylinder, per 29 CFR-1910.101(b) during the April 23,1990' inspection (Inspection Report.No. 70-0036/90002).

(5) _ Falling Hazard During _ examination of the second floor area of Building 254, the inspector noted that the door between this area and the

. remainder of-Building 254 was not locked. This represented a falling hazard since there was no. floor on the other side of.

the door.

Licensee representatives stated that this door-would be posted and locked.

Two concerns were identified.

6.

Criticality Safety (IP 88015)

TF1 inspector examined areas of the plant to observe the nuclear criticality safety aspectlof uranium oxide pellet production and storr]e-operations.

a.

Moderation Control in the New Powder Blending and Pelletizing Areas The. status of the moderation control practices in the new powder blending and pelletizing areas was reviewed. One potential source 14

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'fu of moderator is through the dry air utility.

CE has a sample line a-and moisture detector on the supply air line.

In response to an inquiry, the CE representative admitted that a valve had been

-installed in the sample line.

However, a CE review group had noted e

that the valve could isolate the moisture detector, and a lock-controlled valve was on order to replace the installed valve.

In the alarm condition, the moisture detector would close valves in the supply lines. -On loss of power, these spring-loaded valves also would close.

The licensee representative stated that the moisture detector was to be. replaced so that valve closure would be effected by'a high or low reading (indicating malfunction) on the detector.

The inspector requested that maintenance and calibration include j

-system checks on the moisture detector and valve operators rather than just individual components. The Engineering Manager indicated this would be considered.

The pressurized air to the powder blending and pelletizing area is supplied by a' compressor via an accumulator tank. The accumulator has an automatic blowdown device which can be isolated by manual valves. When noted by the inspector, the licensee agreed to replace the valves with lock-controlled valves.

The licensee has posted 1iquid moderation controls on the second and.

third levels-of-the powder / pelletizing area.

The total volume of Lhydrogenous material authorized in thir, area is ten gallons.

However, the-' licensee has not implemented a control mechanism to-ensure that the posted limits are not exceeded. This was identified an an Inspector Follow-up.Itam to a nure that the licensee establishes a control mechanism (Inspector Follow-up No. 70-0036/90003-06).

!To improve nuclear criticality safety, the licensee was installing-a water tight canopy over equipment on the third floor. This provides.

a second barrier.against liquids entering the process system by way of.a roof 4 leak-The canopy is pitched on a one degree slope.

However, it is not clear how the drainage of water would be controlled and/or prevented'from damaging other plant equipment.

The licensee is still-reviewing this installation. Directional downspouting may.be installed to control the pathway of water. This was' identified as ar Inspector Follow-up Item to assure that the licensee' established appropriate controls-(Inspector Follow-up Item

'No. 70-0036/90003-07).

'The-opening in-the hoods on the second floor have been reduced in-size so that large containers of 11guld moderator cannot be inadvertently entered into the process by these hoods.

The blenders below these hoods require moderation control-for nuclear criticality safety.

-b.'

Nuclear Safety postings During examination of the outside UF storage area, the inspector observed that the storage area was not posted with nuclear safety 15 l

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postings which identified the required storage criteria and controls.

This was identified as an apparent violation of Operations Sheet 201.

which states that storage (of special nuclear material) was governed by limits'shown on posted criticality safety signs.

No storage is 1

permitted in unposted areas (Violation Item No. 70-0036/90003-08).

During examination of the Poreformer Addition Hoods located on the third level of the pelletizing building, the inspector noted that the posted criticality' safety sign specified a maximum allowable limit of 4.4. kilograms.U-235.

These signs were inconsistent with the remainder.of the signs in the facility in that the remaining signs.specified kilograms of uranium' oxide.

In addition, it was 5

noted that the operators maintained a running log on the poreformer j

hoods which recorded the product inventory in kilograms of uranium oxide.. Licensee representatives stated that these signs would be modified to be consistent with other signs-posted in the facility.

~A criticality safety sign posted on the load-unload bood located in the scrap recovery area had tape covering part of the sign. The tape covered two control limits one of which was less conservative L

thaa currently authorized by the licensee.

The inspector identified thisLas a poor practice which should be discontinued.

Licensee representatives stated that the sign would be replaced-rather than

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altered by tape (0 pen Item No'. 70-0036/90003-09).

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- During examination -of.the source material storage vault located to the west of the main-building, the inspector noted that a criticality safety sign dated 1966 was posted in the building.

It was noted that this sign was not applicable to material currently

' stored-in the building.

Licensee representatives stated that this sign would be removed.

-A nuclear safety sign posted in the chemistry-laboratory-established

a. control limit of:740 grams U-235 for the Antire. laboratory.

.However,Lthe inspector determined that the licensee did not maintain a-running log to assure that the 740 gram limit was not exceeded.

Licensee representatives stated that an analysis-had been conducted

.to:show that this limit could not be exceeded.

However,-the

, inspector determined that the: analysis was inappropriate since it

.showed that a-740 gram limit could easily be exceeded.

This,

analysis indicated that 22,000 grams.of uranium oxide could be introduced into the laboratory.

This quantity of uranium oxide would' exceed the U-235 limit by 144 grams if all of the uranium

. stored in the laboratory was enriched to 5% uranium-235 as authorized by the license. Failure to maintain a running -log of the g

U-235 content in the laboratory was identified as an unresolved item in that the licensee could not show that the posted limit of 740 grams; U-235 would not be exceeded (Unresolved Item No'. 70-0036/90003-10).

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c.

Nuclear Poisons

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The' inspector reviewed,the licensee's use of nuclear poisons in unsafe-by geometry tanks.

It was determined that three unsafe-by geometry tanks were being-used by the licensee in the facility scrap recovery area.

Each tank was filled to the point of

-overflow with boron glass Raschig rings which were being used in-accordance with ANSI STANDARD 8.5-1986 "Use of Borosilicate-Glass

.Raschig Rings as a Neutron Absorber in. Solutions of Fissile Material."

Inspection of each tank to -observe settling, degradation of the rings (cracking, chipping, etc.) and filling of the rings j

n with crud was accomplished annually between September 1987 and January 1990.

Rings from each tank were analyzed and determined to j

.contain'between 11.8 and 13.8 weight percent boron oxide.

No

_1 inadequacies were identified.

l One violation and four concerns were identified.

7, Radioactive Waste Management (IP 88035]

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.The inspector observed the licensee's program for handling liquid and-y

-solid radioactive waste.

Contaminated mop and cleaning water, spent scrubber residue, and other liquid residues are evaporated and depending on the uranium content either recycled or solidified for waste disposal.

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Liquid Waste Disposal i

'The uranium tetra oxide (UO ) precipitate formed during scrap j

4 recovery operations:is dried in an oxidation-reduction oven.

The off gases from.this. drying-operation are passed through a solution 3

of. potassium hydroxide (K0H scrubber solution).

Impurities (solids) i from the scrubber solution are precipitated, filtered and prepared for waste disposal-by boil-down (evaporation) and solidification j

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with cementL The inspector observed an operator' transferring a solidified block-of the waste to a 55 gallon drum. The bottom of j

3, the drum is covered with a layer of cement powder to absorb any j

condensate that may form during storage. The solid'" 'd block

-was partially lowered into the drum on a fork lift Ade.

When

- disengaged,,the solidified block free-falls into toe layer of cement 1

powder; causing the' powder to-resuspend and envelope the operator.

Although there is no apparent resuspension of radioactive particles, the' licensee plans to modify this procedure and instruct'the

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operators to wear _a " dust mask." This procedure will be reviewed

-during a future inspection.

b.,

. Solid' Waste Disposal

~The licensee uses crushed limestone rock in reaction silos to react with' hydrogen fluoride in the offgases from the UF conversion 6

process. The licensee removes the spent limestone from a reaction i

tower'by dropping the. material into two 55 gallon drums and then-making alpha measurements on the top layer of spent limestone in each i

drum. The drums of-spent limestone are then dumped into onsite

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storage piles. The licensee uses about 1.5 tons of rock to process a ton of UE. The licensee has about 4100 tons of spent limestone (calcium fTuoride) onsite.

In early days, the If eensee had only one filter in the off gas line.

The licensea has about 800 tons of this material (vid generation) witn an estimated average specific activity 17 pCi U/ gram. The licensee installed a second filter 1. u ies in the off gas lines and has about 3,300 tons of spent limessone (new generation) with an estimated specific activity of 7-8 pCi U/ gram.

This is about two times background. The specific activity values were measured by the licensee. On split samples, Oak Ridge Associated Universities (0RAU) reports values that are 4-6 times higher.

During 3[

the inspection, the cause of this discrepancy was discussed but not resolved.

The Plant Manager and Region III team leader agreed to a revised i

survey method for the spent limestone.

Previously, the licensee had taken measurements wh about one half of the spent limestone had been released from't raction silo. However, the licensee's 4

experience has been that of the uranium was at the base of the reaction silo. The new st ey method will require additional measurements, including a sasurement of the spent limestone in the l

bottom of the reaction sila.

As mentioned above, the licensee's determination of the contamination i

levels on the spent limestone differs from the ORAU data. The NRC 5

staff agreed to initiate discussions with ORAU to seek resolutior..

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NMSS and Region III will discuss the issue with ORAU and then with the licensee.

The Plant Manager noted that in the past, the licensee has shown comparable results with ORAU when low-enriched uranium in soil was being measured..The licensee also had good agreement with two external laboratories on the source term.

c.

Airborne Effluents The July 1989 to June 1980 summary of airborne radioactivity released as gaseous effluents averaged about 30 microcuries per month.

According to Item 20.a. of Special Nuclear Material License SNM-33 gaseous effluents that exceed 150 microcuries per j

calendar quarter must be reported to the NRC.

The quarterly

. summaries for the period indicated that the airborne activity discharged from the plant's 15 stacks comolied with the license limit.

-The above concerns involving solid waste disposal are under discussion and/or review with the licensee.

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8.

Transportation of Radioactive Materials (Ip 86740)

The inspector reviewed the transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological l

safety in the receipt, packaging, and delivery of licensed radioactive materials.

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a.

Shipgng and_ Receiving Activities (1) Receipt Surveys Through a review of licensee rccords for the operatitig period March 21 through July 21, 1990, the inspector determined that the licensee conducted routine contamination surveys of UF package receipts only.

No other packages were surveyed upon receipt according to the licensee, since all others contained less than the type A quantities of radioactive material as specified in 10 CFR 20.205.

(2) Shipments Packages Used Through discussions with licensee representatives, the inspector determined that the licensee uses the following containers for the indicated types of shipment.

Package 1dentification Radioactive Material Shipped UNC-2901 0 pellets CE-250-2 U powder 17 H drum R ioactive waste

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B-25 boxes Radioactive waste / contaminated soil W-21 PF-1 U cylinder overpack 30 B (21s ton)

U cylinder Licensee records reviewed by the inspector indicated that each type of container was being used in accordance with applicable Certificate of Compliance or U.S. Department of Transportation requirements.

b.

. Shipment of UNC 2901 Containers During this inspection, the inspector observed licensee preparations for the shipment of 42 UNC-2901 containers from the Hematite site to

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the Windsor, Connecticut site. Health physics contamination surveys l

of the containers and the vehicle were conducted as required, the containers were blocked in place in the vehicle to preclude movement during transport and the shipping papers appeared to be complete and appropriate.

In this case it was noted that the trailer was not placarded since this was a Fissile Class II shipment.

During examination of other shipments of UNC-2901 containers performed between April 18 and June 21, 1990, the inspector noted that the shipping records did not contain specifically identified instructions to the carrier to assure the maintenance of exclusive use controls on the vehicle, when required. However, the inspector was able to determine that these instructions were provided to the g

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e, carrier. As a result of this observation, the inspector stated that the licensee shou W consider revising the presentation of these

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instructions se that the information required by 49 CFR 173.425(b)(9) for LSA materials and 49 CFR 173.457(b)(1) for Fissile Class III shipments was immediately available to the carrier.

The inspector also provided licensee representatives with several additional instructions which should be included in this document, e.g., do not shift the load or change equipment (tractor-trailer combination) without first contacting the licensee.

Licensee representatives sted that the instructions to the carrier would be modified.

This e s identified as an Inspector Followup Item (No. 70-0036/90003-11).

<he inspector also determined that the licensee was not conducting L

radiation surveys of each UNC-2901 container prior to shipment.

Only the first shipment of each enrichment of uranium packaged was surveyed.

The licensee performed the radiation survey once for each enrichment and then using tne highest reading from that survey on all packages in subsequent shipments of tnat enrichment.

The inspector stated that these survey readings may be appropriate for each subsequent shipment of a specific batch of uranium but this may e

not be appropriate for subsequent batches of uranium since the mix of uranium isotopes (234, 235, 236 and 238) was known to vary from

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bate to batch.

Licensee iepresentatives stated that this practice j

will be reevaluated and discontinued if the evaluation shows dif ferences 'n radiation levels in the uranium contained in different batches.

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Waste Shipments j

During examination of waste manifest forms associated with shipments of waste materials to approved burial sites between April 4 and June 6, 1990, the inspector noted that all waste manifest forms F

indicated that source materials were being shipped te burial.

Through discussions with licensee representatives the,nspector determined that the material being shipped to burial was actually uranium enriched in uranium-235 to about 3.0 to 4.1% and was not 1

i source material.

Licensee representatives stated that they believed that the waste manifest form was being completed in accordance with burial site personnel and modified as appropriate.

This was identified as an Inspector Followup Item (70-0036/90003-12j.

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d.

UraniumHexafluoride(UFyShipments The inspector reviewed the licensee's actions with regard to the

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shipment of cylinders containing residual quantities of UF and 6

, determined that appropriate actions were being taken.

The licensee follows DOE Procedure OR0-651, Revision 5 in the shipping and handling of UF cylinders. UF cylinders not scheduled for j

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z the five year Tecertification are normally shipped to a DOE l

facility containing an acceptable minimum heel weight of 25 pounds r

of UF for the 30A or 30B cylinder.

No inadequacies were 6

l identified.

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Shipment of__ Empty Contaminated Boxes to_the Windsor, Connecticut-Facility During Inspection No. 70-1100/90-05 conducted at the Combustion Engineering, Windsor, Connecticut facility on June 4-8, 1990, the inspector observed as a transport vehicle (open flatbed trailer) entered the Windsor, Connecticut site carrying three large wooden bores.

None of the boxes were marked or labeled with official radioactive material signs or markings.

However, one side of each box contained a piece of yellow tape marked, " Radioactive, Empty-UN2908."

Upon examination of the shipment Bill of Lading, the inspector determined that the wood boxes were identified as being empty radioactive shipping containers which had contained radioactive materials.

There was also a statement on the Bill of Lading which indicated that "the package (s) conforms to the conditions and limitations specified in 49 CFR 173.427 for excepted Radioactive Material - Empty Packages-UN2098". The inspector also determined through discussions with licensee representatives at the Windsor site that these packages were previously used to trar. sport contaminated equipment to the Combustion Engineering, Inc.,

H1matite, Missouri facility from the Windsor, Connecticut site.

Title 49 CFR 173.427, " Empty radioactive materials packaging,"

states that a package which previously contained radioactive t

materials and has been emptied of contents as far as practical, is excepted from the shipping paper and certification, marking and labeling requirements of this subchapter, and from requirements of this subpart, provided that:

(a) It complies with the requirements of e173.421 (b), (c), and (e); (b) TF oackaging is in unimpaired condition and is securely closed so i 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 173.443; (d) Any labels previously applied in conformance with Subpart E of Part 172 of this subchapter are removed, obliterated or covered and-the " Empty" label prescribed in 172.450 is affixed to the packaging; and (e) The packaging is prepared for shipment as specified in 173.421-1.

Upon receipt at the Windsor site, the three packages were not marked 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 an apparent violation of federal shipping regulations which would be cited against the shipper (the Combestion Engineering Hematite, Missouri facility) (Violation Item No. 70-0036/90003-13).

During this inspection, the inspector determined through discussions with licensee representatives that subsequent to notification of the apparent violation, actions were taken by the licensee to correct this violation.- The licensee stated that the appropriate labels had been attached to the pt.ckages prior to shipment to the Windsor, Connecticut site. However, they must have come off during 21

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o transport. The license 's actions included modification of the L

labeling procedure to require the addition of glue to the labels and to require stapling of the labels to the packages. The inspector determined that these corrective actions were complete and appropriate. The inspector had no further questions regarding this item.

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One violation and two concerns were identified.

9.

Maintenance Surveillance The inspector reviewed the licensee's preventive maintenance records anc; determined that maintenance was being performed in accordance with an approved schedule.

a.

Scheduled Maintenance The inspector noted the frequency of checks on plant systems pertinent to safety.

Daily checklists. Oil levels and pressure readings are checked on the air compressor.

I Weekly checklists. The battery and oil level are checked weekly in the emergency generator.

The criticality alarms and i

the water pump for cooling water are both operable through the emergency generator.

Monthly checklists. The plant maintains five cranes (1/4 to five ton capacity) that are used in the processing of special nuclear material. The monthly crane rhecklists includes an inspection of the directional contNis, upper limit switch, and the hoist brake. With the addition of the revitalized facility nine new cranes will be added to the monthly checklists, b.

Enriched Uranium Hexafluoride Handling and Storage During examination of the uranium hexafluoride vaporizer room, the j

inspector requested records of load testing of the crane used to handle the 2h-ton cylinders.

Licensee representatives stated that the. hoist was inspected annually but they did not believe that the crane was load tested on an established schedule. However, licensee representatives indicated that the crane was load tested following installation in the 1960's.

The inspector stated that the licensee should consider load testing this crane on an established schedule to assure that it would not fail during handling of the 2h-ton uranium hexafluoride cylinders.

Licensee representatives stated l

that periodic-load testing was not required by United States Occupational Health and Safety Adminstration (OSHA) requirements.

However, OSHA requirements as stated in 29 CFR 1910.79 indicate that a crane should withstand a test load up to 125 percent of the rated

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load.

Furthermore, the reports of such tests should be placed on file. Although no frequency of performing a rated test load is

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listed, the licensee should review appropriate OSHA regulations, i

Draf t NRC Regulatory Guide 1.104, " Overhead Crane Handling Systems for Nuclear power Plants," and NUREG-0554, " Single Failure Proof Cranes for Nuclear Power Plants," and establish a maintenance program that-includes a periodic test load of the 5-ton UF6 cylinder crane. The licensee indicated that discussions concerning i

a test load on the crane will be pursued with the vendor / contractor.

Region III inspectors will review the licensee's progress during a future inspection (0 pen Item No. 70-0036/90003-14).

.The inspector. also ques cioned licensee representatives regarding the conduct of an evaluation to examine the effects of hazards related to a drop of a cylinder either inside or outside the facility (in the storage yard). The ins:Act9r was informed that an evaluation had been performed for a cylinder drop outside the facility in the storage yard but that a cylinder drop it, the facility had not been evaluated. The inspector stated that the licensee should consider conducting this evaluation so that appropriate emergency actions could be established.

Licensee representatives stated that the evaluation would be performed.

(0 pen t

Item No.. 70-0036/90003-15).

Two concerns were identified.

10.

Exit Meeting-The inspectors met with licensee representatives (denoted in Section 1) at.the' conclusion of the onsite inspection.

The inspectors summarized 3

.the scope and, findings of the inspection, discussed the observations, potential violations (described in Sections 4 and 5) and open items described in'the report.

Dur.ing the course of the inspection and the exit meeting, the-licensee did not identify 'any documents or inspection' statements or references to specific processes as proprietary information.

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