ML20059C185
| ML20059C185 | |
| Person / Time | |
|---|---|
| Site: | 07001100, 07001101 |
| Issue date: | 10/21/1993 |
| From: | Bores B, Noggle J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059C183 | List: |
| References | |
| 70-1100-93-03, 70-1100-93-3, NUDOCS 9311010042 | |
| Download: ML20059C185 (8) | |
Text
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4 U.S. NUCLEAR REGULATORY COMMISSION REGION 1 Report No.
70-1100/93-03 Docket No.
70-1100 License No.
SNM-1067 Priority 1 Category ULFF t
Licensee:
Combustion Engineering. Incorocated 1000 Prosnect Hill Road Windsor. Connecticut 06095-0500 Facility Name:
Nuclear Fuel Manufacturine and Nuclear I2bomforie_s Inspection At:
Windsor. Connecticut Inspection Conducted:
September 15 - 17. 1993
/ !2/!D 0
Inspector:
gle, Sr/piation Specialist Date '
J.
t Appmved by:
bLdL*d N 10}2th3 B. Bores, Chief,"Facilites Radiation Date Protection Section Areas Inspected: An unannounced safety inspection was conducted by a region-based inspector to review audits and surveillances, operations review, radiation protection, effluent releases, and transportation of radioactive material.
Results: The inspection occurred during the final week of fuel fabrication at this facility.
No decontamination / decommissioning activities had begun at this time. No adverse safety findings or violations of the license or NRC regulations were identified.
'l 9311010042 931023-PDR ADDCK 07001100 C
- PDR, i
Details l.0 Individuals Contacted j
- J. Conant, Manager Nuclear Materials Licensing i
- R. Freeman, Plant Manager, Uranium Plant
- R. Kula, Supervisor, Radiological Protection and Industrial Safety j
D. Parks, Manager, Nuclear Material
- R. Sharkey, Manager, Radiological Protection and Industrial Safety
- R. Sheeran, Manager, Accounting and Security I
- Denotes those present at the exit interview. Other individuals were also interviewed during this inspection.
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2.0 Previously Identified Items
-i (Closed) NOV 70-1100/93-01-01 l
During a previous inspection', an inspector observed fuel pellet restacking activities occurring on the fuel rod loading table rather than the stacking table. The fuel rod loading table was not provided with a beta shield for protection of the workers and i
the radiation protection group had not been consulted to pmvide the appropriate radiation pmtection controls for this non-routine operation. The licensee took immediate corrective action by issuing a memomndum to the pmduction supervisors reminding them of their responsibility to inform radiation protection prior to commencing non-routine operations.
The licensee issued a reply to the notice of violation, which was dated August 5, 1993. This letter committed the licensee to provide training for the pmduction supervisors to reiterate. the importance of involving radiation protection personnel r
prior to the start of non-routine operations. At the time of this inspection this training had not been performed. Due to the cessation of fuel manufactoring operations, the reduction of production staff and the cormctive actions outlined above the violation is considered closed.
(Closed) Unresolved item (70-1100/93-01-02)
During a previous inspection of the Pellet Shop area, an inspector noted a sign that stated "all containers of water must be separated from other containers of water and other containers of SNM (special nuclear material) by 12 inches or more". This sign -
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implied a criticality safety contml limit. SNM license no.1067 stated that non-coplanar arrays exceeding a vertical height differential of 12 inches requires a horizontal separation of at least four feet.
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' Inspection No. 70-1100/93-01, conducted on May Il-13,1993 1
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3 Due to the cessation of handling large quantities of SNM at this facility, the unresolved item no longer has any application and this item is now closed.
3.0 Audits and Surveillances The inspector reviewed the quality oversight program with respect to the following SNM License No.1067 Safety Evaluation Report (SER) Commitments listed below.
The SER specifies a quarterly nuclear criticality safety audit, a semi-annual e
radiation protection aud.it, a semi-annual industrial safety audit, and an annual environmental audit.
The Facility Review Group (FRG) is required to provide safety oversight of the Nuclear Fuel Manufacturing Facility and Product Development Laboratory, with quarterly meeting reports issued to the Uranium Plant Manager.
The Safety Committee provides quality oversite external to the responsible e
organization and is requimd to provide an annual audit to the President, Nuclear Fuel.
The inspector verified the performance of criticality safety audits during 1993 and reviewed the results. The first quarter 1993 criticality safety audit was conducted between March 29,1993 and March 31,1993. This audit was fairly detailed and provided a few program improvements. The audit carried open action items from past audits through closure. During the first quarter of 1993, the cricality alarm system was removed from building 5 as approved by the NRC through license admendment application. The second quarter 1993 criticality safety audit was conducted between June 28,1993 and June 30,1993. This audit was sparsely documented with no findings or improvements. This audit served to highlight the remaining open items.
The inspector requested the latest radiation protection and environmental audits conducted for 1993 and the licensee stated that the first semi-annual radiation protection audit had been conducted, but the approved report had not been issued at the time of this inspection. The licensee has not performed the required annual envimnmental program audit for 1993 and expects to drop this requirement through a proposed license amendment to be submitted to the NRC in October of 1993.
The licensee utilizes a safety incident resolution program called an Abnormal Event Occurrence (AEO) Report program. Procedure AP-2, Revision 2, provides a mechanism for abnormal events to be immediately corrected and investigated. The appropriate factory manager determines the root cause and then the events are reviewed by the AEO Review Committee for investigation. This committee reviews 1
4 and approves proposed root cause determinations as well as assignment of corrective actions for resolving the event.
The inspector reviewed six AEO Reports generated during 1993.
l-A-2-22-93 described a February 22,1993, licensee identined event when several fully loaded 927 fuel shipping containers were parked within four feet of a trailer containing 2901 shipping containers. The license requires a 20 foot minimum separation between loaded fuel shipments. This was a violation of license Part 1, Section 4.3.19 and a violation of 49 CFR 173.447, which requires spacing of 6 meters for radioactive yellow II shipments. This event was licensee identified and timely corrective actions were taken by moving the shipments to the required separation distance. The material handlers were involved in an incident critique and training session and two lines were painted in the trailer storage yard that were 20 feet apart for future refemnce for trailer storage. This incident appeared to be an isolated event. The cormctive actions were timely and appeared to be effective, which meets the criteria presented in 10 CFR Part 2 for a non-cited violation.
1-A-3-5-93 involved a Mamh f,1993, event when a worker was disassembling e
a laser filter canister and after separating the filter a couple inches, the niter exploded due to zirconium tr.etal reaction with oxygen. The corrective action mcommendation required the applicable pmcedure to be revised. In addition to a one hour 2% oxygen purge (which allows zirconium metal to convert to zimonium oxide in a controlled fashion), a fifteen minute water soak was required. This AEO Report was open pending procedure draft and approval.
The other four 1993 events were oflow safety significance that included false criticality alarm annunciation after a power outage, nitric acid spill occurrence, several minor infractions of criticality safety controls, and a non-contaminated
" Radioactive" sign was found in a dumpster.
The inspector's review of the AEO reports for 1993 indicated that a very good abnormal event program was implemented during 1993, with effective corrections being taken.
The FRG review committee and Safety Committee meeting minutes and audit results were not reviewed during this inspection.
4.0 Operations Review The inspector toured the Nuclear Fuel Manufacturing Facility several times during the inspection period and observed work in progress during the manufactum of fuel I
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5 bundle fabrication. Criticality controls were well posted in all applicable work areas with no violations of these controls observed. Tne criticality alarm system had been tested in accordance'with the license required periodicity (monthly) and the criticality detectors had been calibrated semi-annually. The pellet shop operations, which
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included pellet drying, stacking, QA inspection, and fuel rod loading, were safely executed with appropriate air sampling and radiation monitoring provided. High efficiency particulate air (HEPA) filter units were within the license specified acceptance criteria. The non-contaminated fuel handling areas were provided with explicit criticality control precaution postings and the fabrication process had minimized the exposure to industrial safety hazards. Emergency eye wash and body showers were located close to the nitric acid pickling tank and were operable at the time of this inspection. Where practical, mechanical lifting devices were provided to limit the back strain posed by manipulating fuel rods and fuel bundles between stations. The entire manufacturing process utilized a computerized fuel rod accountability system with computer work stations provided at each step of the fuel bundle assembly process to ensure material control. The inspector did not note any safety discrepancies.
5.0 Radiation Protection The inspector reviewed implementation of the licensee's radiation protection program through observation of on-going work, review of records, and through discussions with personnel. This review was with respect to license requirements and federal regulations contained in 10 CFR Parts 19 and 20.
The inspector observed workers stacking and loading exposed sintered uranium fuel pellets in the pellet shop. Each worker in the pellet shop wore a personal lapel air i
sampler. This was an excellent practice as the license allows the use of a general stationary representative air sampler to be used..The pellet shop area (a contaminated 2
area) was generally maintained below 500 disintegrations per minute (dpm)/100 cm,
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This was one tenth of the license required 5,000 dpm/100 cm 1 mit requiring cleanup within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Radiation dose rates in the. pellet shop averaged 0.1 - 2.5 mR/hr i
with 40 mrad /hr beta dose rates found in close proximity to the exposed fuel pellets.
The licensee has a plastic beta shield to effectively eliminate the beta exposure hazard. The inspector determined that the radiological hazards were low and appropriate monitoring of radiation exposure was performed. Radiological postings and housekeeping controls were good.
The inspector reviewed selected radiation survey records and noted that they were of good quality and the required frequency of surveys was met. From the contaminated area surveys reviewed, general contamination levels in the Pellet Shop averaged 2
2 approximately 350 dpm/100 cm beta / gamma and generally 100 dpm/100 cm alpha 2
2 with a maximum value of 11,000 dprn/100 cm beta / gamma and 4,000 dpm/100 cm
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alpha. The clean area surveys of the Nuclear Fuel Manufacturing Facility demonstrated routinely low levels.
External radiation exposures were also very low. The licensee was tracking collective radiation exposures for approximately 43 badged personnel, which represented 2.6 person-rem for the first quarter of 1993 and 2.0 person-rem for the second quarter of 1993. Current NRC regulations permit any eng individual to receive 3.0 rem per quaner (with radiation history documentation and assuming lifetime exposure constraints are not limiting).
Air sample intake results for 1993 were reviewed. The average air sample derived intakes for pellet shop workers for 1993 was 10.2 Derived Air Concentration-hours (DAC-hrs) per month, which relates to current regulatory values of approximately 6 Maximum Permissible Concentration-hours per quarter per pellet shop worker. The n>gulatory limit was 520 MPC-hours per quarter and the licensee was averaging 1 %
of this internal exposure limit for the exposed worker population. Indirect measurement of the radionuclides deposited in the bodies of the workers was accomplished by monthly urinalysis of radiation workers. The monthly monitoring results of badged personnel indicated < 1 micro-gmm per liter of uranium detected in urine samples for each worker during 1993, which represented the lower limit of detection of the measurement system. Direct measurement of personnel radionuclide deposition was performed on 43 radiation workers on August 23-25,1993, by a uranium sensitive Lung counter using phoswich detectors. The maximum detected uranium deposition was 49 micrograms with a measurement ermr band of.i40 micrograms. The maximum permissible lung burden for uranium-235 is 250 microgmms with a license specified action level for diagnostic urinalysis set at.;> 175 micro grams of uranium-235. These results again substantiate the low exposures received by the facilities' radiation workers.
6.0 Effluent Release The inspector reviewed the licensee's 1993 record of effluent release data with respect to license requirements. The license limits gaseous effluent releases to 18 microcuries per calendar quarter based on gross alpha measurements. Liquid effluent releases to the Windsor site creek are limited to concentrations of _<;_3 picoeuries per milliliter (which represents 10% MPC for insoluble natural uranium).
Licensee supplied data indicated gaseous effluent release of 0.3 microcuries total for all four quarters of 1992 combined. The first quarter of 1993 resulted in 0.37 microcuries of gaseous effluent released and 0.62 micmcuries released during the second quarter of 1993. These release levels represent 2-3.4% of the limit. Liquid effluent releases were batch releases. The license limits the concentration released.
The licensee tracks total activity released rather than the discharge rate. The raw data l
7 reviewed by the inspector indicated a maximum discharge rate of 0.63 picoeuries per milliliter or 21 % of the allowable discharge rate. No discrepancies were noted.
7.0 Transportation The inspector reviewed the licensee's program for the shipment of radioactive material and radioactive waste in accordance with NRC and DOT regulations. In addition, the basis for determining uranium content for non-fuel shipments was reviewed in detail as the future decontamination and decommissioning project is expected to genemte appreciable uranium containing waste material other than the typical fuel bundle products shipped in the past.
Radioactive shipments involved records generated by three separate groups. For fuel shipments, the SNM content was controlled by the Material Accounting and Security group in accordance with the Fundamental Nuclear Material Control Plan, which tracked assayed pellet batches through fuel rod loading and weighing, and fuel bundle assembly operations. The radioactive material content for the new fuel shipments was determined from this material accountability system. For other non-fuel shipments, the Material Accounting and Security group provided uranium assay determination for three waste types. The Radiological Protection and Industrial Safety group provided the radiation surveys of the new fuel bundles and external surveys of the loaded shipping containers. The Nuclear Material Manager provided the shipping paper documentation for each shipment.
7.1 Shioment Records The inspector reviewed the following shipment records.
Shipment #
Contents Type Activity Destin.
2472 fuel rods A
0.06 Ci Hema,Mo 2510 fuel B
9.3 St. Lucie 356 laundry LQ
.0002 INS, MA 2470 dept fuel LSA/RQ l.85 total Hema,Mo
/ pellets 355 laundry LQ
.0002 INS, MA
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All shipping reords were determined to be complete and to meet the applicable requirements of 10 CFR Parts 20, 70, 71 and 49 CFR Parts 171-178. The inspector review the shipping cask Certificates of Compliance and consignee licenses and verified that all were on file as required. No safety concerns or violations were identified.
7.2 Uranium assav determinations for non-fuel sbioments The licensee pmpared indirect counting standards in February and October of 1990 by pulverizing fuel pellets from a previously assayed batch of 4.3% U-235 enrichment and weighing incremental amounts into plastic packets. Fifty-five gallon and thirty-gallon dmm containers were loaded with clean waste, clean HEPA filters or clean laundry materials interspersed with the plastic packet fuel powder standards. These three waste types were counted with varying amounts of U-235 in the two sizes of containers; from 5 grams up to 100 grams of U-235 and a calibration curve was plotted. The calibration information was incorporated into a computer program, CALWAST, which was used to calculate the umnium mass content from the count data. The inspector found no discrepancies with this uranium assay technique.
Currently the system is limited to miscellaneous shop trash, laundry, and HEPA filters. During the decontamination and decommissioning project additional counting geometries may be requimd to accumtely determine mdioactive content of other materials,given density and geometry distribution considerations.
8.0 Exit Meeting The inspector met with licensee representatives at the end of the inspection, on September 17, 1993. The inspector reviewed the purpose and scope of the inspection and discussed the findings. The licensee acknowledged the inspection findings.
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