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Insp Rept 70-1257/85-10 on 850729-0802.Violation Noted: Visible Hole Identified on Bottom of Container in Shipment
	ML20135A335
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/21/1985
From:	Brock B, Pang J, Thomas R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	;
Shared Package
ML20135A319	List: ML20135A315; ML20135A323; ML20135A335;
References
	70-1257-85-10, NUDOCS 8509100107
	Download: ML20135A335 (10)
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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No.

70-1257/85-10

Docket No.

70-1257

License No.

SNM-1227

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Safeguards Group:

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Licensee:

Exxon Nuclear Company

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2101 Horn Rapids Road

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Richland, Washington ,99352

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Facility Name:

Richland Facility

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Inspection at:

Richland, Washington

Inspection conducted:

July 29, 1985 to August 2, 1985

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Inspectors:

. L. Brock, Fuel Facilition Inspector

DnfeS%ned

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. F. Pang, Radiation Specialist

Date Signed

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Approved By:

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R. D. Thomas, Chief

IVte igned

Nuclear Materials Safety Section

Summary:

Innpection on July 29-August 2, 1985 (Report No. 70-1257/85-10)

Areas Inspected:

A routine unannounced inspection was conducted of

management organization and controla; cperator training and retraining;

criticality safety; operations review; radiation protection; transportation;

radioactive waste management; emergency preparedness; environmental protection

and deactivation / decontamination activities.

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

During this inspection, innpection Procedures 88005, 88010, 88015, 88020,

83822, 86740, 88035, 88050, and 88045 were covered.

Results

One violation van identified in one area (see Section 7) and no

violations were identified in the remaining eight arena inspected.

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DETAILS

1.

Persons Contacted

R. G. Frain, Manager, Operations-Richland

R. Nilson, Manager, Corporate Licensing

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

T. C. Probasco, Supervisor, Radiological and Industrial Safety

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D. Gerrald, Criticality Safety Specialist

J. E. Pieper, Specialist, Health Physics

B. E. Berst, Manager, Speciality Fuels

C. Volmer, Manager, Corporate Quality Assurance

E. L. Foster, Radiological Safety Assistant

R. A. Schneider, Staff Specialist Safeguards

G. Mulligan, Supervisor, Shipping and Warehousing

M. K. Valentine, Manager, Plant Operations

W. E. Stavig, Senior Operations Analyst

N. Wing, Manager, Analytical Chemistry Laboratory

W. E. Niemuth, Manager Facilities Design and Construction

J. Englund, Shift Supervisor, Conversion

K. O. Johnson, Staff Engineer

E. T. Johnson, Supervisor, Analytical Chemistry Laboratory

R. J. Ehlers, Manager, Purchasing and Logistics

J. H. Fastabend, Manager Equipment Engineering

J. A._Rosscup, Health Physics Technician

S. R. Lockhaven, Specialist, Industrial Hygiene

I. J. Urza, Staff Engineer

J. W. Green, Senior Chemical Engineer

M. J. Hill, General Supervisor, Chemical Operations

S. Mason, Lead Technician

E. Arel Traffic Controller III

Denotes those attending the exit interview.

2.

Management Organization and Controls

Section 9 of license SFM-1227 incorporated Part I and the Appendixes to

Part I of the licensee's application as license conditions.

A.

Organizational Structure

Section 2.4 of the license application requires certain

organizational divisions of responsibility to provide a check and

balance system in the important areas of plant safety.

The licensee's organizational structure is unchanged since the prior

inspection. Responsibilities for the changes recommended by the

internal task force on criticality pafety have been assigned and

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dates for the completion have been established. Various aspects of

all the recommendations are scheduled for completion by the end of

1985 except for the implementation of the annual safety appraisal

which is scheduled for 1986. The progress on implementation of the

task force recommendations will continue to be reviewed in

subsequent inspections (85-02-05).

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B.

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 being conducted as required.

See Section 7.D for details

(2) Criticality Safety Audits

The bimonthly criticality audits are conducted, documented, and

reported as required. The clear results reflected the

increased attention given plant wide to criticality safety.

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, respirator

and transportation training were examined by the inspector. The new

employee training provided for five radiation workers and the

radiological orientation given three non-radiation workers were reviewed.

Radiological safety training, including respirator training, had been

provided to radiation workers as required. Based on the review, a

recommendation was made that the orientation given to new non-radiation

workers include the explanation of the various radiation safety signs and

symbols used by the licensee.

A review of the training given to the transportation workers is discussed

in Section 7.

No violations were identified.

4.

Criticality Safety

Section 3.2 of the license application requires assurance of criticality

safety through both administrative and technical practices.

Criticality Safety Analysis

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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

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the license application and all determ! nations of Nuclear Criticality

Safety be reviewed and approved by a second party reviewer in accordance

with the requirements.

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The licensee continues to provide second party review of required

criticality safety analyses. The Liquid Uranium Scrap Recovery (LURP)

operation expansion incorporated previous reviews of tanks used in the

expansion. The interaction analyses of the new configuration will be

reviewed during the next inspection (85-10-01).

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No violations were identified.

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5.

. Operations Review

Section 2.1 of the license application requires the licensee to conduct

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business in a manner so as to assure that licensee facilities are safe

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from radiation and other nuclear hazards, and the operations will not be

detrimental to the environs and to assure that personnel radiation

exposures, both in-plant and offsite, are raintained as low as is

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reasonably achievable (ALARA).

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A.

Conduct of Operations

(1) The LURP expansion equipment required for increasing the pilot

plant throughput has been acquired. The equipment installation

is nearly completed and startup of the process should be in the

near future. The administrative controle incorporated in the

procedure to control input quantities to within a safe batch

will be reviewed during the next inspection (85-10-02).

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(2) The modifications planned for the Cadolinium Scrap Recovery

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Process (GSRP) have been completed.

(3) The Miscellaneous Uranium kecovery System (MURS) being

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installed during the last inspection is now operational.

(4) The Non Destructive Assay (NDA) system for verification of the

enrichmentofuraniuminUFfcylinderswasdemonstrated. The

system appeared to be capabIe of making the required

measurements.

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P.

-Facility Modification Review and Examination

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The licensee's' decontamination of the Specialty Fuels Building mixed

oxide room (Room 173) is proceeding. The operation is following the

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plan prepared for the safe removal of the equipment. See Section 10

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details.

No violations were identified.

6.

Radiation Protection

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Pursuanttb10CFRPart20,thelicenseeisrequiredtoprovide

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protection against radiation hazards associated with licensee activities.

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Bionssay Results

Urinalysis results for the second quarter were reviewed. The

highest urinalysin noted was 26.45 ug U/1. This individual was

subsequently resampled within a week, and the reported result was at

the minimum detectable level of 10 ug U/1. The inspector determined

'that initial urinalysis had been conducted on five new radiation

workers as required.

No significant exposures were noted.

B.

Lung Count Results

Lung count results obtained since May 18, 1985 were reviewed by the

inspector. Also, it was determined that five new radiation workers

had been lung counted as required.

No significant lung counts were noted.

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C.

Whole Body Radiation Exposure

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Non-radiation workers, and radiation workers who work with

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encapsulated material, and radiation workers who work with

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non-encapsulated materials are monitored on an annual, semi-annual

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and quarterly bases. Records of radiation exposures for the second

quarter of 1985 were reviewed. The highest radiation exposures

noted of 0.54 rem whole body (WB) and 0.54 rem skin were received by

an individual working in the plutonium facility decontamination

during the month of June. The cumulative whole body exposure, to

date, for this individual is 0.820 rem. None of the reported

exposures exceeded the NRC Part 20 requirements.

D.

Radiological Safety Audits

Radiological safety audits are being performed monthly by the Senior

Radiological Engineer (SRE) as required by Section 3.13.1 of the

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current license application. The radiological safety practices in

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the plant are reviewed during these audits, and'the findings are

included in a written report to management.

The SRE stated that he also conducts a walkthrough inspection of the

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facility twice a week.

Records of these audits conducted since the last inspection were

reviewed by the inspector. The audits appeared to be comprehensive

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and included such areas as posting, bionssays, radiation and

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contamination surveys, transportation and operating procedures. No

significant findings were noted in the audit reports.

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Two items previously identified in the licensee's audits concerned

DPM around the Room 180 barrel

10,000-30,000

contamination of

and of contaminated pallets originating in the

tumbler (85-06-01),

Since the licensee has not been able to

Lube Blend Room (84-10-02).

find a satisfactory solution to these problems, these items will

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remain open.

E.

Procedures

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It is noted that the Radiological Safety Operating Procedures Manual

The revision was initiated in May and

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is being completely revised.

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a draf t will be completed by August,

F.

_ Leak Testing

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The licensee's source inventory and leak test records were reviewed

The licensee has a current inventory of sixteen

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by the inspector.I.ea& tests had been conducted in a timely manner as

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sealed sources.

required.

G.

Surface and Air Contamination

Randomly selected records of contamination surveys conducted were

Decontamination and surveys had been

reviewed by the inspector.

conducted when the cction levels had been exceeded.

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Average airborne contamination levels for the ten plant areas for

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the period up to July 1985 were reviewed by the inspector.The air contamination

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significant contamination levels were noted.

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levels averaged about 3.5 E-12 uti/mi which in below the company

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guide of 1.0 E-11 uci/ml. By comparison the NRC limit for

It was noted during the walk

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unrestricted areas is 5.0 E-12 uci/ml.

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through inspection that one of the air sampling instruments appeared

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In length in

to have a piece of tygon tubing approximately 1.5 ft.

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The use of tygon tubing in sample inlet

the sample inlet line.

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lines is not considered good practice because of the effect upon the

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This matter was discussed with the

collection of particulates.

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Information received since the inspection indicaten that

the licensee has currently completed action on two air samplers and

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licensee.

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should complete action on the remaining four samplers by September

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6, 1985. This matter will be reviewed during the next inspection

(85-10-05).

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Instrument Calibration

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Activitien such as instrueent calibration, equipment checks, etc.

that recur on a periodic basis are entered into a computer system

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maintained by the licensee's Preventive Maintenance Group.

computerized recall ifnt is provided to each user the month prior to

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the month in which the activity becomes due.

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Air sampling instrumentation and portable survey meters were

randomly selected during the inspection to determine if any were

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overdue for calibration. All of the instruments observed were

within the calibration period.

No violations were identified.

7.

Transportation

10 CFR 20.205 requires that surveys must be made of shipments received.

The licensee's program for packaging and shipment of licensed material

must be in accordance with 10 CFR 20.311 and 10 CFR 71.

The licensee has a staff of seven individuals in the Shipping and

Warehousing Group who are devoted entirely to the receipt and shipment of

licensed material. Training in the Department of Transportation (DOT)

and NRC requirements consist of on-the-job training, and the attendance

at off site seminars on DOT requirements. Five of the staff members

attend at least one seminar annually. _ The instruction manual used by

this group is the Materials Instruction Manual XN-NF-281.

This manual

will be replaced by the newly completed Logistic Procedures and Training

Manual. The new manual appears to be thorough and comprehensive in the

coverage of the DOT transportation regulations.

The licensee's quality control (QC) procedurns for shipments of ifcensed

material were reviewed by the inspector. Check off lists are used by the

shipping group for UF

pellet, fuel assembly and radioactive waste

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shipments. The licensee also conducts compliance audits of shipments of

licensed material. In addition, the licensee has a quality assurance (QA)

group which conduct audits of the QC program on a one year frequency.

Records of receipts of licensed material were reviewed by the inspector.

Surseys to show compliance with 10 CFR 20.205 had been conducted as

required. Records of three fuel shipments made since the last inspection

were revi2wed for compliance with DOT requirements. All records were

accepta11e.

A shipment of radioactive waste was sent to the U.S. Ecology, Inc. low

level waste burial site in Richland, Washington on June 25. 1985. The

shipment No. H1116, Radioactive Shipment Record (RSR) No. 53313 was

received at the burial site on June 27, 1985. Thn State of Washington

inspector cited the licensee for a container (WD-17276) which had a hole

in the side of the container. This was in viointion of 49 CFR

173.425 (b) (1) . Also, 10 CFR 71.5 requires, in part, that each licensee

who transports licensed material outside the plant, or who delivern

licensed material to a carrier for transport, shall comply with the

applicable DOT regulations. This matter was identified as a violation.

The circumstances associated with the shipment which caused the violation

of DOT regulations were discussed with the licensee. The licenses has

determined that the damage to the container occurred after the final QC

shipment check had been conducted (approximately ten days prior to the

shipment). In order to preclude any further violations associated with

containers being damaged prior to shipment, the licensee has taken action

to (1) place a protective barrier arourd the barrel storage area, and

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(2) the QC shipment check will be conducted immediately prior to the

shipment.

One violation was identified.

8.

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 procedures used to assay the uranium contents of metal boxes and

55 gallon drums of uranium radiot.ctive waste generated were

reviewed. Metal boxes are used :o hold non-compactible radioactive-

waste material such as large pieces of contaminated equipment which

will not fit into a 55 gallon drum. These metal boxes are monitored

with a survey meter and the readings are used to derive the uranium

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content.

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The contents of 55 gallon drums are compacted and counted in a

barrel counter which is mounted with four 1" x 2" sodium iodide

scintillation detectors. The barrel counter has a stated random

error of 10% and a systematic error of 16% for total uranium.

The licensee stores all boxes and barrels containing 150 grams or

more of uranium for future recovery. All boxes and barrels

containing less than 150 grams of uranium are shipped to the U.S.

Ecology waste burial site at Richland, WA, as LSA radioactive vaste.

As noted in the last inspection report, QC auditn of packaging and

monitoring techniques in the UO Building will commence during the

third quarter of 1985 (85-06-02)2 This item remains open.

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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.

A.

Fire Protection

(1) The nineteen fire extinguishers which were examined by the

inspector throughout the plant were all current with regard to

the monthly inspection requirement.

(2) The licenene completed elimination of the class "D" fire

posting from the site. This change permits the professional

fire fighter in-charge during a fire emergency to decide on the

proper fire-fighting technique.

No viointionn were identified.

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10.

Environmental Protection

Section 3.5 of the'licanse application addresses the licensee's

Environmental Surveillance Program wherein gaseous effluents, liquid

effluents and lagoon systems are monitored. Additionally, the licensee

collects vegetation, soil and air samples at strategie locations for

analysis of pertinent chemicals and uranium.

During the review of the licensee's gaseous effluent data the NRC

Headquarters (NMSS) representative indicated that although the licensee's

gaseous effluents were within regulatory limits, the measurement

sensitivity indicated in the Environmental Impact Appraisal of August 13,

1981 appears significantly beyond the capability of the licensee's

measurement system. The licensee agreed to re-evaluate the measurement

systems performance. The results of the ifcensee's effort will be

reviewed during the next inspection (85-10-03). Additionally, it was

noted that the results of the fluorimetric measurement of the uranium

content of soil. and sewage sludge samples may also be showing a

measurement problem. The licensee agreed to review the performance of the

measurement system and recognized the need for an enricLuent seasurement

of the uranium content of the sewage sludge. The licensee's findings

will be reviewed during the next inspection (85-10-04).

Seven soil samples were taken by the inspector in the vicinity of the

licensee's site. Four offsite samples were taken, two were downwind and

two were upwind (the prevailing wind was from the southwest). The upwind

samples were not within the plant boundary but were on the licensee's

property. The three onsite samples were all taken downwind from the SF

Building. The samples have been sent to a Department of Energy

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laboratory for independent analyses.

No violations were identified.

11. Deactivation / Decontamination Activities

The decontamination of Room 173 (the mixed-oxide room) in the Specialty

Fuels (SF) Building, is proceeding according to the licensee's plan.

The need for the licensee to submit a plan of this preparation and

packaging project to NRC-HQ (NMSS) for their review was discussed. There

is no clear requirement for such a submittal. The licensee did provide

an information copy of their plan to the NMSS representative during the

inspection. The licensee also stated a copy of the final plan for

decontaminating the empty room will be provided to NRC for approval when

it is completed. On August 9, 1985 the inspector was advised by an NMSS

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representative that auch a plan had just been requested of the licensee

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and the Ifeensee agreed to provide it.

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No viointions were identified.

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12.

Exit Meeting

The results of the inspection were discussed with members of the

licensee's staff identified in Section 1.

The topics included:

One viointion of transportation regulations

The areas inspected

The status of open items (4 of 5 items remain open)

The NDA system for enrichment measurement of UF cylinder receipts

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The SF Building decontamination and waste

The dry conversion process review packaging project

Solid waste recovery process input control

Liquid uranium recovery process input control

Soil sampling around the SF Building

Fluorimetric analysis of soil samples and sewage treatment plant

sludge samples

Measurement sensitivity of atmospheric release samples

Pallet contamination control (the source of contamination is known)

Contamination control improvement needed in the powder nixing room

Training non-radiation worker new employees in the meaning of

radiation protection signs

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Implementation of the audit of waste drum packaging

The use of tygon tubing in air sampling

The licensee restated that the source of contamination of both the powder

mixing room and the drum pallets was known; however, an effective corrective

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action had not been developed. The licensee also stated that the tygon

tubing would be repinced with metal tubing in the air sampler. Additionally,

the licensee indicated that a check would be made of the gaseous effluent

measurement sensitivity and the fluorimetric measurement accuracy.

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ML20135A335

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