ML20126F507

Insp Rept 70-1257/85-06 on 850513-17.No Violation Noted. Major Areas Inspected:Mgt Organization & Controls,Operator Training & Retraining,Maint & Surveillance Testing,Radiation Protection & Radwaste Mgt

ML20126F507
Person / Time
Site:	Framatome ANP Richland
Issue date:	06/10/1985
From:	Brock B, Thomas R, Zuradowski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20126F496	List: ML20126F492 ML20126F507
References
70-1257-85-06, 70-1257-85-6, NUDOCS 8506170510
Download: ML20126F507 (9)

Text

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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/85-06 Docket No. 70-1257 License No. SNM-1227 Safeguards Group: I Licensee: Exxon Nuclear Company 2101 Horn Rapids Road Richland, Washington 99352 Facility Name: Richland Facility Inspection at: Richland, Washington Inspection conducted: May 13-17, 1985 Inspectors: ,

A 4d B. L. Brock, Fuel Facilities Inspector Date Signed AA P. R. Zura owski, Radiation Specialist l@ YYY ~

D6te Signed Approved By: d R. D. Thomas, Chief D6te' Signed Nuclear Materials Safety Section Summary:

I_nspection on May 13-17, 1985 (Report No. 70-1257/85-06)

Areas Inspected: A routine unannounced inspection was conducted of management organization and controls, operator training and retraining, criticality safety, operations review, maintenance and surveillance testing, radiation protection, transportation / radioactive waste management, emergency preparedness and deactivation / decontamination activities.

The inspection involved a total of 56 man-hours onsite by two NRC inspectors.

Itesults: No violations were identified in the nine areas inspected.

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DETAILS

1. Persons Contacted

• R. G. Frain, Manager, Operations - Richland

• R. Nilson, Manager, Corporate Licensing

• R. H. Purcell, Manager, Safety and Security Operations

• C. W. Malody, Licensing and Compliance, Operating Facilities

• T. C. Probasco, Supervisor, Radiological and Industrial Safety [;"

• L. D. Gerrald, Licensing and Compliance Engineer L p-

• J. E. Pieper, Specialist, Health Physics l *B. E. Berst, Manager, Speciality Fuels ((

J. Ryden, Manager, Maintenance Engineering !i

=s E. L. Foster, Radiological Safety Assistant R. A. Schneider, Staff Specialist, Safeguards "5 ,

H. Thiss, Manager, Purchasing _

G. Mulligan, Supervisor, Shipping and Warehousing -

• M. K. Valentine, Manager, Plant Operations T. Luzzo, Electrical Engineer, Preventative Maintenance !f W. M. Welden, Quality Control Supervisor R. Hahn, Shift Supervisor, Conversion l- ,

J. Englund, Shift Supervisor, Conversion ;g R. R. Roper, Technician Specialist, Specialty Fuels =

R. A. Nunamaker, Lead Material Control Technician W. F. Bazemore, Maintenance Air Balance Technician En S. M. Mason, Lead Material Control Technician

• S. R. Lockhaven, Specialist, Industrial Hygiene [

D. J. Doremus, Senior Technician y J. Lawson, Technician 2 ma J. W. Green, Senior Chemical Engineer M. J. Hill, General Supervisor, Chemical Operations g B. R. Black, Manager, Quality Control Engineering -

y T. Stafford, Rework Technician b

.*Denotes those attending the exit interview. E F

Management Organization and Controls 7 2.

t Section 9'of. license SNM-1227 incorporated Part I and the Appendices to [

Part I of the licens,ee's application as license conditions.  ;

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A. Organizational Structure

• 1 5 Section 2.4'of the license-application requires certain [

organizational-divisions of responsibility to provide a check and E balance system in the important areas of plant safety. .

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The licensee's organizational structure is unchanged since the February 11, 1985 inspection. However, fourteen changes to improve a the licensee's Criticality Safety Control System were recommended by =_

an internal task force on Criticality Safety. The additional changes are being implemented practicably and their status will be I reviewed;in subsequent inspections (85-02-05).

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- 2 B. Procedure Controls Section 3.1.1 of the license application requires that the licensee establish and maintain radiation protection standards and procedures which shall be maintained by annual reviews and updated as appropriate. These standards and procedures are also based on and in compliance with 10 CFR Part 20.

The inspector reviewed procedure revisions recently made by the licensee to improve criticality safety controls. The procedure revisions had been appropriately reviewed and approved.

C. Internal Reviews and Audits Section 3.13.1 and 3.13.2 of the license applications requires Radiological Safety and Criticality Safety inspections monthly and bimonthly respectively.

(1) Radiological Safety Audits Radiological Safety audits are conducted as required. See Section 7.D for details.

(2) Criticality Safety Audits The bimonthly criticality safety audit by the Criticality Safety Component indicated that the program strengthening actions identified in the licensee's letter to the NRC, dated May 1, 1985, had been completed. The NRC inspector reviewed the procedure revisions, the responsibility reassignments and the letter emphasizing the need to follow the procedures. The revised procedures are being followed. This closes item 85-02-04.

No violations were identified.

3. Training and Retraining Section 3.10 of the license requires that the licensee conduct a training program covering radiation protection, criticality safety, industrial safety, fire protection and' emergency procedures.

During this inspection certain aspects of the radiological and respiratory protection program were examined by the inspector. As was discussed in_the previous inspection report, the required yearly retraining is normally conducted during the latter part of the third quarter and the' records for this training will not be available until the fourth quarter of'1985. However, special training sessions in radi.ological safety, criticality safety and respiratory protection are conducted throughout the year on an as needed basis. Such a training session was held for 15 employees on April 30, 1985, to discuss various aspects of the respiratory protection program needed in planned decontamination work in the M0 Building glove box line. The instructor for this class had recently been retrained in respiratory protection

- 3 techniques at Central Connecticut State University. This one week course has been approved for continuing education credit by the American Board of Health Physics.

No violations were identified.

4. Criticality Safety M

Section 3.2 of the license application requires assurance of criticality safety through both administrative and technical practices. i 4

Criticality Safety Analysis Section 3.2.1.1 of the license application requires criticality safety analysis of all applicable processes in accordance with Section 2.3.20 of jgg the license application and all determinations of Nuclear Criticality Safety be reviewed and approved by a second party reviewer in accordance '

with the requirements.

Six criticality safety analyses were completed since the last inspection.

Five were modifications to existing operations and one was for an operation yet to be implemented. The criticality safety analyses were approved by a second party reviewer as required. The second party reviewer indicated that periodic discussions with the analyst resulted in j

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his being familiar with the criticality safety analysis prior to his -

review of it. The analyst now provides additional detail in the Q

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criticality safety analysis package which facilitates the second party review. Two of the analyses were necessary as corrective actions where ==

an internal audit identified the licensee's failurc to follow procedures. '

) As indicated in Section 2.C.(2) of this report, the subsequent audit i

found the a'ppropriate corrective actions had been implemented. =

a No violations were identified. $N i

5. Operations Review j[

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P Section 2.1 of the license application requires, the licensee to conduct 2:

it's business in a manner so as to assure that licensee facilities are 4E L safe from radiation and other nuclear hazards, and that it's operations will not be detrimental to the environs and to assure that personnel (l radiation exposures, both in plant and offsite, are maintained as low as =

is reasonably achievable (ALARA). In providing this assurance, -

conditions of applicable NRC licenses shall be complied with, and full j regard shall be given to applicable NRC Regulatory Guides. y 2

A. Conduct of Operations a

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(1) The licensee is preparing to increase the throughput of the 5 pilot uranium recovery process. The outdoor process has been f

" shut down since the winter of 1984. Startup has been delayed g pending receipt and installation of the new equipment needed j for increased throughput. g E

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%' Q.i(2)4Themodifications'beingmadeto.thegadoliniumscraprecovery

y. - N - y process vereJobserved/f Filters, .a scrubber, and a slab mixing i

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~ tank lfor extractant. cleanup, are being added. The work is Nx h,ab'outi 75.

s. percent completed.

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t " M ) The. chemistry daboratIry was~ visited. LThe inspectors

, , Q! ' - questioned a laboratory worker regarding criticality safety

' L . - t fprAc;tices." .Theianswers given indicated the employee understood'

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cQ j 1and, adhered to-the Criticality Safety Specifications.

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I N (4)' ThE licenseefis insta11in the equipment for the Miscellaneous

' " #p CUranium Recovery. System (MURS). This system will-reduce the c uranium"cEntent of recovery streams prior to their input to the la' goons , g 7 1  !(5) "The! inspector's followup inspection of . Storage Warehouse No. 4 j

found that the' required storage array boundary has been

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adequately' maintained. The licensee's corrective action was taken during.,th'e previous inspection, immediately after the

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g violation was. identified.

,j , 1(6)'.The licensee's planned use of a_Non Destructive Assay (NDA)

'6 enrichment; measurement was not reviewed since the NDA procedure

' had not yet been written. Preliminary results indicate the w '

-' system is adequate forJthe licensee's needs. This' item remains

~ open (85-02-06)

Y ( .B . Facility Modification Review and Examination 2 e

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~ The~1'icensee operations observed were conducted in accordance with

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procedures. LIn Room 173,: of the Specialty Fuels Building,' a special operation currently underway involved' measurement of residual

% ' plutonium contamination'in glove boxes used in the forme'r UO2-Pu02 ,

' mixed oxide,' pellet production line. The measurements, by a 7

> contract' laboratory, are a necessary -part of determining the level

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,,J - Tof cleanup needed to prepare the' glove boxes for packaging, t

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~, transportation and appropriate disposal. For further details-see >

Section.:10. ,,_

e, , ' Noviolatiobswereidentified.

6. Maintenance and Surveillance Testing-Section 3.12 of-the license' application requires that' periodic tests and H '

inspections are conducted-in accordance with written procedures and are

['" , properly documented.

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• ' A.  : Maintenance

'(1) The licensee's air balance systes for.the.UO2 Building was

- reviewed by the inspectors. The pan'els on'which differential

- pressures'are recorded were also observed. The log sheets -

g ], reflecting the routine" readings taken at eight' hour-intervals y ,

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.we're current. Weekly air lock smoke tests supplement the.

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. evaluation of-the system's performance.

4 =-(2) 1The inspector reviewed the historical file of the monthly generator tests provided from'the computer file. The record

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^ indicated the tests were appropriately conducted.

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'No violations were identified.

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7. - Radiation Protection.

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. Pursuant to-10 CFR Part 20, the licensee.is. required to provide

1. ; protection against radiation hazards associated with licensee activities.

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" A; Bioassay Results

' Urinalysis _results for the~first quarter'of 1985 and those available to date were examined by the inspector. Four results above the

, ~m inimum level of detection were observed in the records for- this time interval. -The two highest results were 19.1 and 20.7 ug/L-

[ which did not exceed-the licensee's action level of 25'ug/L. .

'B' . Lung Count Results Lung count' records'for the first quarter of 1985 and those available to date were, examined by-the inspector. It was found that even though the licensee is having lung counts done with a very sensitive intrinsic germanium (IG) system, the number of' counts above.the.

.26 nCi action level appears to be decreasing. The highest count.

noted in the records wass.21 nCi. -None exceeding the action level

,ereobservedin'.the'reco'rdsfo[thetimeintervalspecified.

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. Whole Body Exposu're C.*

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External, exposure' records for the first.. quarter of 1985 were

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j, examined and6it+was again ci>nfirmed that low enriched fuel

." fabrication' facility operations personnel have a low potential for y p receiving whole body: exposures. Almost all; exposures were at.or 6 7,; 1:near' the 16we'rfl6it of . detection. No reported exposures for t

.1 persons working 'at .the 'Richland Facility exceeded the licensee's f action" levels or'NRC Part'20 requirements.

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/ An' examination'of,the-licensee's.1984 ALARA Committee Report

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1. -disclosed that'the+ downward trend in both internal and external

- exposures is continuing. The downward trend may.be due in part to improvements made in the ventilation ' system, particularly in the pellet. grinding area, and improved surveillance related to visable y" contamination^ and spills in the Lube Blend Room and pellet press area. ,t

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Radiological Safety' Audits

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- Radiological safety audits are being performed monthly by a Senior

• Radiological Engineer as required by Section 3.13.1 of the current k  %

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c license application. The radiological safety practices in the plant are reviewed during these audits and the findings are included in a written report to management.

One finding disclosed contamination of 10,000-30,000 DPM around the Room 180 barrel tumbler. Further investigation indicated the drum lid seal as the most probable cause of the problem. The drum lid is being redesigned. As.a temporary solution to the problem the contamination is being cleaned up as it occurs. The licensee's progress in this area will be reviewed during the next inspection (85-06-01). The problem involving the cause of contaminated pallets originating in the Lube Blend Room has not yet been resolved. The pallets are being washed and decontaminated as needed until the root cause can be determined. Item (84-10-02) will remain open.

No violations were identified.

8. Transportation / Radioactive Waste Management 10 CFR Part 61 requires that all radioactive waste prepared for disposal is classified in accordance with paragraph 61.55 and meets the waste characteristics requirements in paragraph 61.56. The licensee's program for packaging and transportation of radioactive waste must also bc conducted in accordance with 10 CFR Part 20.311 and 10 CFR Part 71.

Since the last inspection six shipments of radioactive waste have been made to the commercial waste disposal site on the Hanford Reservation (U.S.-Ecology). Twelve 4'x4'x6' metal boxes of waste were being prepared for shipment during this inspection and the preparations were observed by the inspector. All paperwork associated with the six shipments were examined by the inspector and it was found that all requirements of the applicable parts of 10 CFR 20, 61 and 71 were met. In addition, it was observed by the inspector that these shipments were made in conformance with'the licensee's internal procedures XN-NF-759 " Shipping Standard

. Including Low-Level Waste" and XN-NF-281 " Shipment of Uranium Waste to

. Disposal Sites". 'These' procedures are consistent with the requirements

, 'of-10 CFR Parts 20, 61 and 71.

The twelve boxes'of waste that were examined by the inspector were found

'to be'well sealed with the containers free of any dents, holes, cracks or significant rust. -The containers were marked and labeled properly. The containers were well constructed of heavy gauge steel and appeared to be able to withstan'd the normal' rigors of transportation as required by DOT regulation's;  ;

" Discussions lwiti hl the Manager, Quality Control Engineering disclosed that in order to further insure compliance with NRC, DOT and internal procedures,'QC audits of packaging and monitoring techniques in the UO2 Building will commence during the third quarter of 1985. This audit will be in addition to the QC audit of waste drums prior to shipment as required by the licensee's internal document XN-NF-P68538 entitled

." Inspection of Waste Drums." The licensee's progress in this area will L be reviewed during the next inspection (85-06-02).

• :. 7 No violations were identified.

9. Emergency Preparedness Section 3.9 of the license application addresses the licensee's Emergency Plan (XN-NF-32) which includes a listing of procedures that have been prepared to implement the plan.

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A. -Fire Protection (1) Fire extinguishers throughout the plant were found current with regard to required monthly inspections.

(2) Housekeeping improvements continue to reduce flammable material accumulations.

(3) The licensee is endeavoring to eliminate the Class "D" designation from the site. Reevaluation and some modifications may be required to make this change. The Class "D" designation restricts the use of water in fire fighting in the posted area.

If removal of this designation is justified, the licensee's plant would thet be consistent with other large plants in the area.

No violations were identified.

. 10. Deactivation /Decontaminatiot , Activities The inspectors toured Room IP3 of the Speciality Fuels (SF) Building, formally called the Plutonium Glove Box Facility of the Mixed Oxide Building. The inspectors observed preparations being made for the removal of contaminated equipment within the glove boxes and eventually the glove boxes. The Radiation Work Procedure (RWP) No. SF-85-3 controlling this work was examined. Discussions were held with the author of the RWP, who is the Senior Technician in charge of the health physics aspects of the project. The RWP was found to be sufficiently detailed to adequately control the hazards associated with the project when used by properly trained personnel. Discussions with the Supervisor, Radiological and Industrial Safety disclosed that they are planning to hire (within a few weeks) two experienced senior health physics technicians.whose' sole assignment will be to oversee the day to day aspects of the project. New respiratory protection equipment and other safety-related items have beba purchased for the work. Weekly planning meetings are being' held by licensee management to discuss details of the project.

It~is anticipated _that decontamination work inside of the glove boxes

.will start in a few weeks and the entire project will be completed and ready for an NRC overcheck by the middle of the fourth quarter of 1985.

A'prelimina'ry copy'of the decontamination plan was given to the inspectors for, informational purposes. A final copy will be forwarded to NRC headquarters for review.

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11. Exit Meeting

~The results of'the inspection were discussed with members of the

' licensee's staff identified in Section 1. The topics. included:

+ i* no violations were identified

.n the areas inspected

the status of open items'(5 of 8 items remain open)

• - criticality safety' practices' relative to procedures and task force recommendations

'*- need for appraising NRC of the schedule for. cleanup of Room 173 in the Speciality Fuels Building training of technical personnel-

-10 CFR Part 61 performance-

> planned licensee QC inspections of waste packaging-28 >the procedure for measurement of enrichment by Nondestructive s; " Analysis should inc1ude a.. difference limit and action to be taken e- fwhen the limit.is exceeded-

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'l.::improvementsneede*d<intheUOzBuildingairbalanceinstrumentation

~h.The$1'icenseeindicatledthecause,ofcontaminationofpalletsinthe

' powder. blending room was known and efforts were direcced toward

controlling thescont'asination while they sought to make modifications to

..significantly reduce, iti' ~7

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