ML20126B310

Insp Rept 70-0036/85-01 on 850506-10 & 27.Violation Noted: Inadequate Solidification of Radwaste Shipment

ML20126B310
Person / Time
Site:	07000036
Issue date:	06/10/1985
From:	France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20126B300	List: ML20126B296 ML20126B306 ML20126B310
References
70-0036-85-01, 70-36-85-1, NUDOCS 8506140066
Download: ML20126B310 (12)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 70-36/85001(DRSS)

Docket No. 70-36 License No. SNM-33 Licensee: Combustion Engineering, Inc.

Nuclear Power Systems Windsor, CT 06095 Facility Name: Hematite Inspection At: Hematite, M0 Inspection Conducted: May 6-10 and 27, 1985 A.w J,ti Inspector: . M. France, III lx@/0 /785 Date Approved By: L. R. Greger, Chief 6//0/8f Facilities Radiation Date Protection Section Inspection Summary Inspection on May 6-10 and 27, 1985 (Report No. 70-36/85001(DRSS))

Areas Inspected: Routine, unannounced inspection of the radiation protection program including: organization, facility changes and modifications, environ-mental protection, maintenance, operations review, nuclear criticality safety, radioactive waste, generator requirements, and transportation activities. The inspection involved 28 inspector-hours onsite by one NRC inspector.

Results: One violation was identified in the area of radwaste generator requirements (inadequate solidification of radwaste shipment-Section 6).

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t-DETAILS

1. Persons Contacted

• L. Deul, Engineer

• H. Eskridge, Nuclear Licensing, Safety, and Accountability Supervisor

• R. W. Griscom, Engineering Supervisor

• G. McKay, Nuclear Industrial Safety Coordinator (Radiation Specialist)

• R. Miller, Manager, Production Control and Administration

• A. Noack, Production Superintendent

• J. Rode, Plant Manager J. D. Harter, Shipping and Receiving Foreman B. Pigg, QC Laboratory Supervisor M. Ryan, Chem Nuclear, Inc.

S. Creech, Chem Nuclear, Inc.

The inspector also interviewed other production and laboratory personnel during the inspection.

• Denotes those present at the exit interview.

2. General This inspection, which began at 2:30 p.m. on May 6, 1985, was conducted 4

to examine licensee actions in complying with regulatory requirements related to fuel facilities. In addition, the inspector reviewed ifcensee

, activities in accordance with statements, representations, and conditions contained in Material License SNM-33. During a tour of the licensee's Nuclear Fuel Manufacturing facility located near Hematite, Missouri, the inspector noted that the plant was operating three work shifts, 7 days a week, because of commitments made by their Windsor, CT operations.

During the course of the inspection, the plant was processing 3.4 percent enriched uranium material.

3. Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection, operations, and radwaste generation, including changes in the organizational structure, procedure revising and updating, and utilization of audit systems.

a. Organization There have been no personnel changes in the health physics organiza-tion since the previous inspection (70-36/84005). The inspector noted that the radiation protection organization appears to have onsite management support to insure implementation of an effective control program,

b. Procedure Revising and Updating The inspector confirmed that the licensee reviews and updates proce-dures biennially. Updated procedures are reviewed by the Nuclear 2

i Licensing, Safety, and Accountability Supervisor, designated persons from Production and Engineering Departments and the Quality Control Engineer. In addition, the Quality Control Engineer acts as custodian for document controls.

During a plant tour the inspector observed that plant operators performing steps to remove residual uranium hexafluoride (UFs) from UFs cylinder were following updated procedures and operating sheets.

The inspector concluded that the licensee's system for reviewing and approving procedures complies with license requirements.

c. Internal Reviews and Audits The inspector verified that the licensee utilizes independent audits

- conducted by corporate personnel as another means of reporting deficiencies to management. Routinely, the Nuclear Licensing, Safety, and Accountability Supervisor acts as liaison to management for conducting audits and promptly reporting deficiencies to management and/or to NRC.

The inspector examined licensee records and verified that appropriate corrective measures were taken to correct deficiencies found during the 1984 corporate audit of the Hematite plant. (See Section 8(a)).

No violations or deviations were identified.

4. Radiation Protection The inspector reviewed the licensee's internal and external exposure control programs including the required records, reports and notifica-tions, and the licensee's program for maintaining occupational exposures ALARA.

a. Internal Exposure Control About 20 operators received whole body counts on March 13-14, 1985; three of these workers were recounted due to contamination found on their clothing. Other than the worker mentioned in previous inspection reports who has been restricted from uranium work for several years, no individuals exceeded the licensee's action level of 130 pg of uranium-235. No problems were identified.

The inspector reviewed the results of routine urinalyses performed on plant personnel from January through March 1985. The highest urinalysis result showed about 40 pg U/ liter. This occurred when the operator accidentally struck a blow back valve and caused a release of UO2 powder. Subsequent urinalyses showed a concentration of 13 pg U/ liter which is below the licensee's action level of 25 pg .

U/ liter. The employee was placed on restriction and assigned 24 MPC-hours due to the exposure incident. The MPC-hour assignment was calculated from fixed air sample data and appears to show reasonable agreement with the urinalysis data.

No problems were identified.

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b. External Exposure The licensee's film badge records for 1984 were examined. The maximum whole body dose was about 500_. millirem. During the course of this inspection the licensee was engaged in the removal of dissolver heels-(residual uranium hexafluoride (UFs) that remains in the 2.5 ton cylinders after UFs processing is completed). Exposure levels reached about 100 mR/hr at the surface of two of the cylinders.

The-dissolver heels campaign involves about 50 cylinders, most of which show exposure levels significantly less than 100 mR/hr. Area dosimeters were strategically placed in the work area, surveys were conducted and workers were inspected for-proper clothing, dosimeters, and film badges. The radiation levels were apparently caused by conditions that occur in the gaseous diffusion process. Deposits of technetium-99 are carried as contaminates along with UFs from the enrichment plant to UFs cylinders. The licensee's dissolver heels program should last through June of 1985. The program will be reviewed during a future inspection.

c. Instrument Calibration Records of portable instrument calibrations performed since the last inspection ~ indicated that portable health physics survey instruments were calibrated quarterly as required.

d. Source Leak Tests The inspector examined licensee records for leak testing byproduct material sealed sources. The licensee's leak test records appeared to be complete and tests were performed in accordance with the provisions of Material License No. SNM-33.

e. Air Sampling The inspector reviewed the licensee's program for determining exposure to personnel from airborne radioactivity detected by lapel samplers.

The licensee has set an action level of about 8E-11 pCi/ml for airborne radioactivity concentrations. Lapel sampling data for the eight~ oxide operators was similar to data compiled in previous years. The action level due to airborne concentrations was exceeded on an average of about 21 times per year for the 1983-84 work period, which is approximately the.same as previous recent years. In correlating data for MPC-hour exposure,- the inspector noted that MPC hours decreased about 11 percent.

The licensee noted that the decrease in MPC-hour exposure is attributed to (1) identification of high airborne locations, (2) operator training and experience, and (3) improved use of operating procedures and operating sheets or special evaluation travelers.

No violations or deviations were identified.

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f. -Respiratory Protection The inspector reviewed the licensee's respiratory program including

. examining the licensee's test equipment for performing quantitative respirator fit tests. The' respiratory protection program is conducted in accordance with Regulatory Guide 8.15.

-The_ inspector noted that during an airborne exposure to a pellet plant operator the operator was wearing a lapel sampler and a half-face mask. Although the airborne concentration derived from the lapel sampler exceeded the action level, the operator was wearing a half-face mask (the protection factor allowed an exposure of about

'10-MPC hours) which limited the worker's calculated intake to below regulatory and licensee action limits.

No violations or deviations were identified.

g. Notifications and Reports The inspector reviewed _ licensee reports submitted in accordance with requirements of 10 CFR 20.407 (personnel monitoring reports),

10 CFR 20.408 (reports of personnel monitoring on termination of employment or work), and 10 CFR 19.13 (notifications and reports to individuals). The ifcensee showed documentation of terminated employees' radiation _ exposure history. The licensee provides each employee with a copy of his/her radiation history, upon termination.

The.-licensee's report on whole body exposures for the 1984 operating year showed that out of 69 employees three had exposure levels greater

-than 250 millirem, but equal to or less than 500 millirem.

No violations or deviations were identified.

5. Operations Review The inspector reviewed with the-licensee the status of operations at the

-Hematite facility. In addition, the inspector observed operator practices to determine conformance.with operating procedures.

a .- Observation of Operations The inspector was escorted by the Nuclear Licensing, Safety and Accountability Supervisor and Production Engineer during a tour through the Hematite facility. The plant was processing uranium enriched to 3.4 percent. Plant operations had shifted to a 7-day work week in order to effect completion of the campaign in accordance with corporate commitments. An assay change is planned to prepare the plant to process uranium enriched to 4 percent. In response to NRC concerns discussed in information notice 85-31 about build-up of enriched uranium in ventilation ducts, the Production Engineer and Production Supervisor noted that the plant relies on periodic cleaning of the ventilation ducts to prevent a significant

. accumulation of uranium.

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In the most. credible' area for UO 2 buildup, the U02 cooler, the ventilation system is equipped with prefilter material mounted l

. upstream of the main filter. -'Prefilters are checked frequently for '

002 ' powder buildup, removed if necessary, and processed through to incineration. In addition, an assay change in uranium enrichment requires an extensive cleanout of production systems. Scrubber '

systems are frequently analyzed for uranium concentration in accordance_with criticality. safety practices. CE Hematite conducts an annual plant shutdown, hence, allowing for additional opportunity to reduce the buildup of enriched uranium in ventilation duct work .

-and in process systems.  :!

-During the plant tour the inspector observed operator practices in removing'dissolver heels from UFs cylinders. The operator-performed the task according to procedure, taking adequate precautions for radiation protection and criticality safety. Dissolver heel rinsings were transferred to containers located in designated arrays to prevent

' double batching.

No violations or deviations were identified.

b. Housekeeping During the course of this inspection, the inspector observed that

SNM material was stored in designated storage areas, evacuation pathways were clear, and the potential for. accumulating fissile materials in unauthorized locations was minimized.

The inspector concluded that the licensee's. facility operations appear to be adequate to protect the health and safety of facility workers and members of the general public.

.6. Waste Generator Requirements; 10 CFR 20 and 61 The inspector reviewed waste generation activities to determine whether ,

the licensee has established and is maintaining adequate management ,

. controlled procedures which reasonably assure compliance with the requirements of.10 CFR 20 and 10 CFR 61 applicable to low' level radwaste form, waste characterization and classification, stabilization, f and shipment manifests and tracking. The inspector'also reviewed ifcensee

, actions related to a shipment of solidified radwaste shipped on February 5, 1985, to the burial facility located at Barnwell, South

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Carolina.

The Manager, Production Control and Administration has the responsibility for establishing and maintaining adequate management-controlled procedures

, .in accordance with 10 CFR 20 and 10 CFR 61. The. licensee's Shipping and Receiving Operation procedures (0.S. 1001.1-5) appear to address the

! regulatory concerns for carrying out various radwaste packaging and shipping activities. -By procedure the licensee performs quality control

. inspections for container integrity and surveys the shipment for radiation

-levels. There appeared to be a clear delineation of authority and respon-

- sibility of those individuals assigned to radwaste processing for low level land burial.

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a. .Waste Manifests / Classification Waste Form and Labeling f

Licensee records _ appeared adequate to document a manifest tracking

system.to include waste form and classification, as required under 10 CFR 20 and 10 CFR 61. The-inspector verified that the licensee maintained'a current copy of the disposal site license.

b. : Quality Assurance Review

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QA inspections'are conducted by the Shipping, Receiving Foreman along with preshipment surveys conducted by Health Physics Technicians.

The inspector noted that.the Manager, Production Control and Adminis-tration is the cognizant person required to.effect an investigation in any instance where receipt;of shipment has not been verified within the specified period.

c. Waste Characteristics Incident The inspector reviewed the licensee documentation and recor'ds of-activities to assure that all low-level radwaste conforms to the waste characteristics of 10 CFR 61.56. A letter from the South Carolina Department of Health to CE Hematite dated February 14, 1985, discussed noncompliance with applicable state and federal regulations and an assessed civil penalty of one thousand dollars ($1,000). Chem Nuclear ,

, Systems, Inc. operating the burial facility.in Barnwell, South

). Carolina noted that 2 drums purportedly containing solidified liquid waste, from the CE Hematite radwaste shipment of February 4, 1985, actually contained incompletely solidified material.

, 0.n May'27, 1985, the inspector met with Mr. M. Ryan of Chem Nuclear,' Inc.

and discussed operations at the Barnwell radwaste disposal site.

1 Mr.'Ryan noted that the QC program requires inspection of shipments ,

by employees of both Chem Nuclear and the South Carolina Department

. of Health. In a given shipment, 6 to 8 packages may be thoroughly c . examined. He also noted that every 33rd shipment received a thorough inspection of each package. The Regulatory Affairs specialist of Chem Nuclear, Inc. noted that drums containing solidified waste

!- apparently provide a specific distinctive sound when hit. The drum j inspector.at the Barnwell burial site investigated the contents of l- several drums as part of a shipment from CE Hematite. A hole was F drilled in each of the drums:and a probe was inserted and withdrawn.

4 A gelatinous substance was found on the probe, indicating that the solidification process was incomplete. During the course of this i- inspection when using a stick to probe the contents of one of the drums, the inspector determined that the surface did not appear to be penetrable. When probing the contents of the other drum, the inspector observed that a gelatinous substance adhered to the stick.

The monolith that was formed in each of the 2~ drums was still damp '

i and gave the appearance of a concrete form in the curing stage.

Failure of a generating licensee to conduct a quality control program that demonstrates that liquid waste will be shipped from burial as a P free standing monolith, appears to be in violation of 10 CFR 20.311(d)(3).

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. Findings that contributed to the problems included: (1) the liqui-fled waste was not properly mixing with the cement to consistently 1 ensure a free standing monolith. (2)' inspection of_the mixture by the licensee only included the top portion of the drum contents.

The licensee notified the South Carolina Department of Health about corrective actions taken-in a letter submitted March 5, 1985. The transmittal included revised procedures for solidification of liquid.

residue. The inspector noted that the ifcensee now uses a mortar mixer to provide thorough mixing of concrete and liquid radwaste into a homogen(ous batch. The mixing occurs outside of the shipping container and the batch of concrete / waste formed is considered a waste

-ingot. The newly formed ingot is equipped with a rebar. rod shaped to enhance-lifting and placement into the shipping container. The ingot.

is also easily inspected to ensure that the concrete and liquid residue form a free _ standing monolith.

On March 12, 1985, the South Carolina Department of Health acknowledged

-that CE Hematite had submitted an acceptable procedure for waste solidification, shipments could resume and the payment for civil

' penalty was received. Upon receipt of a subsequent April 25, 1985 waste shilment, the South-Carulina Department of Health indicated that the material met all license requirements and was disposed of in accordance with the burial license.

During a tour of the licensee's waste handling facilities and waste storage locations, the inspector noted that the February 4, 1985 shipment in question had been returned from the Barnwell South Carolina burial _ location to CE Hematite. The licensee plans to rework the shipment through the solidification process.

One violation was identified.

7. Transportation

! The inspector reviewed transportation activities to determine whether i the licensee is maintaining an adequate program to assure radiological safety in the receipt, packaging, and delivery of ifcensed radioactive materials.

The inspector reviewed licensee shipping records and confirmed that

health physics surveys were documented. In reviewing records of the licensee's Manager, Production Control and Administration and the records

. maintained by the Shipping and Receiving Foreman, the inspector noted that a system is in place to maintain a record of each shipment of licensed material in accordance with 10 CFR 71.

i No violations.or deviations were noted.

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8. pluclear Safety The inspector examined records of audits performed by the licensee in order to determine if any breach of procedures had occurred since the previous inspection. The inspector accompanied the NLS&A supervisor on a plant tour and examined the posted areas where SNM is used or stored for posting of SNM enrichment and batch limits, proper storage, and use of unauthorizeo containers.

a. Licensee Nuclear Safety Audits In accordance with Material License SNM-33 on February 7,1985, CE l corporate representatives conducted an annual audit of the Nuclear I Safety Program at the Hematite facility. The audit also covered the radiation protection program, training, facility changes and evacuation drills.

. In response to audit findings the pellet plant micronizer hood was approved for utility use on a safe batch basis.

. In another response to audit findings technicians were instructed to place trash bags in designated storage boxes after gamma counting.

During a tour of the plant, the inspector verified that the ifcensee had adequately responded to corporate audit findings.

The inspector also reviewed the quarterly audit conducted by the Nuclear Licensing, Safety and Accountability Supervisor, and the annual audit conducted by American Nuclear Insurers.

No violations or deviations were identified.

b. Examination of Unsafe Geometry Container The inspector examined the licensee's data for the annual inspection and testing of Raschig rings. The inspector reviewed the published report with the NLS&A Supervisor.

According to the cognizant engineer who inspected the system, there was no significant deterioration in the boron impregnated Raschig rings. No violations or deviations were identified,

c. Facility Modifications and Change Requiring Criticality Review The inspector reviewed the licensee's documentation of facility changes requiring criticality considerations, including determination of whether the licensee has the appropriate expertise to establish criticality safety limits for facility operations, and determination of whether the licensee has positive management controls to ensure that facility operations are conducted within nuclear criticality safety limits.

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Several changes and/or modifications to operations were noted by the inspector, including: i

. 'An ammonia scrubber hold tank was placed in service. The tank was previously used as.a utility tank. This will allow ammonia scrubber solution to be stored separately from potassium hydroxide scrubber solution. -Similar to the K0H hold tank-criticality is based on uranium concentration. Previous operating data shows a uranium assay of less than lg U/1.

The solution Ifmit for uranium is about 25g U/1.

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. A process hood was reclassified as a utility hood to cross blend consolidations of acid insolubles, agglomeration of test batches and other. operations to be specified. Operations are conducted on a safe batch basis. As an operating restriction, the micronizer mounted above the hood will not be used to process UO2 powder.

. An operating procedure was revised to handle the flow of com -

bustible material from its point of origin to incineration.

combustibles are generally burned in the incinerator to effect waste volume reduction. The bulk volume of these materials would preclude the accumulation of uranium equal to or in excess

.of_a safe mass. In addition, the material will be processed in small batches and gamma counted for mass control.

. Cylinder rollers capable of rolling the 2 1/2 ton 30-8, UF 6 cylinder were installed to effect dissolution of dissolver heels (residual UFg remaining in cylinders after vaporizing major contents thr0 ugh plant processes). Spacing is confirmed by the roller block forming an exclusion area ~of more than one foot from other SNM. The inspector reviewed the operating sheet, observed the operators in performance of the procedure, and reviewed each step with the cognizant Plant Engineer and Production Supervisor.

. An additional service tank was placed in service to. accommodate ammonia diurante filtrate from the UF g cylinder dissolution washes of dissolver heels. The filtrate is sampled for grams U/ liter, with a limiting quantity of 10 kilograms of uranium.

The rinsings are analyzed before additions are made to the ADU service tank.

In depth discussions with the cognizant Engineer, observation of operator performance during dissolver heel dissolution program, and review of recent nuclear criticality analyses with the Nuclear Licensing, Safety and Accountability, Supervisor demonstrated to the inspector that the licensee uses conditions and assumptions in performing NCS analyses that are valid and that facility modifications and changes undergo independent reviews that meet nuclear and health safety practices.

No violations or deviations were identified.

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9. Environmental Monitoring The inspectors reviewed the licensee's documentation of monitoring results specifying the quantity of low-enriched uranium released to unrestricted areas in liquid and gaseous effluents during the last six months of 1984.

The radionuclide concentrations found in liquid and gaseous effluents were significantly lower than limits expressed in 10 CFR 20.

In response to NRC concerns about decommissioning of the licensee's waste ponds, the NLS&A Supervisor escorted the inspector on a tour of the evaporation ponds. The inspector observed that the smaller pond is nearly dry and fitted with a plastic liner designed to act as a collection basin during storm water run-off. Water collected on the liner is analyzed for uranium concentration. Based on the analyses, the water is processed through the discharge system for unrestricted release or evaporated, solidified for waste volume reduction, and shipped to burial.

, Soil removal operations have commenced on the larger pond and gravel and sludge was visible on the pond bottom. During the summer of 1985 the licensee plans to remove the remaining sludge and gravel for waste disposal processing.

No violations or deviations to NRC regulations were identified.

10. Maintenance and Surveillance Testing The inspector reviewed the licensee's maintenance operations to determine specifically whether process monitoring instrumentation is being maintained and calibrated as required. s n

The licensee's UO2 powder operations involve no hydrogenous material.

The atmosphere in the blender is continuously monitored for humidity, because an increase in moisture detected at the action level will cause an alarm and subsequent cessation of the blendin'g operation. In response to the inspector's concern for nuclear safety, assuring that surveillance tests have been met, the licensee noted that the moisture or relative humidity gauges were traced and monitored on the instrument control panel and that annual maintenance to include calibration was performed by an independent reviewer or vendor.

The inspector noted that the frequency and extent of calibration of moisture gauges appear adequate.

No violations or deviations were identified.

11. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the onsite inspection on May 10, 1985. The inspector summarized the scope and findings of the inspection.

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The. licensee acknowledged the violation concerning waste form and characterization, described in Section 6, waste generator requirements.

During the course of the inspection and the exit meeting, the licensee

.did not identify any documents or inspector statements and references to specific processes as proprietary.

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