ML20136D964

Insp Rept 70-0036/97-01 on 970203-07.Violation Noted.Major Areas Inspected:Mgt Organization & Controls,Operations, Maintenance/Surveillance Testing,Radwaste Mgt,Operator Training,Radiation Protection & Transportation

ML20136D964
Person / Time
Site:	07000036
Issue date:	03/06/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136D914	List: ML20136D908 ML20136D939 ML20136D964
References
70-0036-97-01, 70-36-97-1, NUDOCS 9703130068
Download: ML20136D964 (22)

Text

_ . . _ . . _ _ _ __

i. ,

U.S. NUCLEAR REGULATORY COMMISSION 9

REGION III Docket No: 070-00036 License No: SNM-33 a;

Report No: 070-00036/97001(DNMS)

Licensee: ABB Combustion Engineering Facility: Hematite Nuclear Fuel Manufacturing Facility Location: Combustion

• Engineering, Inc.

Hematite, MO '63047 Dates: February 3-7,-1997 Inspectors: Timothy Reidinger, Senior Fuel Cycle Inspector Chuck Hooker, Senior Fuel Facility Inspector, Region IV Approved by: Gary L. Shear, Chief Fuel Cycle Branch Division of Nuclear Materia h Safety 1

1 l

l 9703130068 970306 PDR ADOCK 07000036 C PDR ,

i ,

4 l

~

[XECUTIVE

SUMMARY

I i  !

I~

ABB Combustion Engineering I Nuclear fuel Manufacturing Facility Hematite, Missouri NRC Inspection Report 070-00036/97001(DNMS) i i The inspection involved the review and observation of selected aspects of

! licensee management organization and controls, operations,.

I maintenance / surveillance testing, radwaste management, operator training, I radiation protection, and transportation, l Manaaement Oraanization and Controls (IP 88005)

The licensee was actively working toward meeting their " Criticality

., Safety Program Update (CSPU) goals, and had added a qualified j criticality analyst to'its staff. (Section 1.0) i~ Operations (IP 88020) i The licensee's plans to. submit a license amendment clarifying exhaust  ;

! stack air sampling and cleaning requirements was identified as an inspection Jollowup item (IFI). (Section 2.1)

{

• A weakness in an oxide conversion plant procedure that contributed to an

airborne release and a personnel contamination was identified as an IFI..

j. (Section 2.2) i

• The failure to conduct an adequate review of operating procedures was i

. identified as a violation. (Section 2.3)

I

• The licensee was adequately implementing its criticality safety j requirements for waste incineration operations. (Section 2.4)

{

• The licensee was adequately implementing the surveillance program for I j the criticality detector alarm system. (Section 2.5) , )

Maintenance / Surveillance Testina (IP 88025)

~* A weakness was identified that involved the lack of performing system i functional tests to determine that the conductivity probes in the UF, 4

vaporization chests condensate system were capable of performing their intended safety function. This was identified as an IFI. (Section 3.1) i'

• A weakness was identified that involved the lack of a formal program to 1 calibrate the incinerator's system safety devices and conduct tests to j assure that the safety interlocks performed their intended safety j function. This was identified as an IFI. (Section 3.2) 3

2

- - . _. -. .. . . - - - - - - . - - . . - - . ~ . . . . _ - .

F

]

i Operator Trainino (IP 88010) j l

The licensee was effectively implementing its training program.  !

Operators appeared knowledgeable and adequately qualified to perform their assigned tasks. (Section 4.0)

Radiation Protection (IP 83822) i l

• The licensee was effectively implementing exposure control programs l including the bioassay program and personnel air lapel monitoring l program. (Section 5.1)

?

I The licensee's corrective actions related to additional operator training and root cause investigations of the High Sample Followup Reports was identified as an IFI. (Section 5.1)

Transoortation (IP 867401' '

• The licensee was effectively implementing its radioactive materials transportation program. (Section 6.0) e

! 3

4 ,

Report Details 1.0 Manaaement Oraanization and Controls

a. Insoection Scope (88020 and 88005)

-The inspectors reviewed and discussed recent changes in staffing with the licensee. The status of new procedures.and other administrative J changes relative to the licensee's new improvement program " Criticality l Safety Program Update (CSPU)" were reviewed and discussed with the  ;

licensee. -l

b. Observations and Findinas The licensee had recently relocated a qualified criticality safety analyst from the licensee's Windsor facility to the Hematite facility. '

Tb - adividual will be formalizing the onsite criticality safety pr%.am, which includes updating criticality safety analyses (CSAs) and ensuring that all formal documentation of CSAs pertaining to the Hematite facility is maintained onsite. Previously, the formal i documentation-for CSAs was being maintained at the Windsor facil:'v. l The licensee also expects to acquire five new draftsmen to augmens %e  !

CSPU.

Relative to the CSPU, there were approximately 17 new draft Regulatory Affairs Administrative Procedures in various stages of review. In-

. addition to these new procedures, the licensee was in the process of enhancing existing operating procedures and developing new procedures in other areas. Considerable other action items were also under

-development. One of these actions included a formal method of ,

communicating abnormal occurrences and criticality safety infractions to 1 the safety group for review. Although the procedure for this process  ;

had not been completed, the process was to include actions taken to correct the problem, cause, and corrective actions to prevent 1 recurrence. At the time of the inspection, corrective actions related to the program had not been considered for inclusion in a tracking system. Related to this observation, the benefits of developing such a tracking system was acknowledged by the licensee.

c. Conclusions The inspectors concluded that the licensee was actively working toward meeting their CSPV goals, and the status of the CSPU appeared consistent with the licensee's first quarterly CSPU report submitted to the NRC by letter dated December 20, 1996.

4

)

l l

i I

l 2.0 Operations Review ,

1 2.1 Plant Activities

! l

a. Inspection Scope (88020 and 88010) l The inspectors conducted a plant walkdown to observe ongoing l activities. The areas toured included the uranium hexafluoride (UF,)

cylinder loading dock area, oxide conversion facility, fuel pellet i manufacturing facility, uranium recycle and recovery area, fuel rod l loading and fuel bundle assembly facility, and other selected plant l areas. j The inspectors also discussed, applicable process criticality safety controls and other safety controls with operators and supervisory j personnel. In addition, the inspectors discussed the planned I installation of the new hydrogen fluoride (HF) detection system.

b. Observations and findings Uranium hexafluoride (UF.) cylinders are transferred, by a stationary I crane located in the loading dock area, to vaporization chambers and ,

then heated in the vaporization chambers to vaporize the UF.. The  !

inspectors noted that any minor UF, leaks occurring within the steam heated vaporization chamber have the potential to be released inside the loading dock area and subsequently exhausted through the loading dock ventilation fan mounted on the roof or released through truck doors on  ;

the loading dock in the event the doors had been opened for cylinder i shipments. The inspectors observed that the licensee did not subject  !

the loading dock roof ventilation fan discharge to air cleaning (filters) and continuous air sampling. The licensee stated that the defined air effluent cleaning and exhaust stack sampling requirements addressed in the license only applied to stack exhaust air from process j areas and process equipment and when the doors are open on the loading dock, there is no practical method to process any air released through the doors. The licensee also stated that the cylinder loading dock area I was not: considered a process area and the ventilation fan was not an exhaust stack as measured against other process stacks that are monitored and sampled for radionuclide emissions. The licensee indicated 'that a license amendment will be submitted to clarify exhaust stack air sampling and cleaning requirements in the near future. The  ;

licensee's actions related to this matter will be reviewed during a subsequent inspection and is identified as an Inspector Followup Item (IFI 070-00036/97001-01).

The inspectors noted that operators appeared adequately knowledgeable of the criticality safety controls and limits associated with their respective work assignment. Control room operators for the conversion process demonstrated sufficient knowledge of the purpose and the intended safety function of alarms and safety interlocks associated with the process.

5

l The inspectors noted that posting of criticality limits and controls i appeared consistent with Section 4.1.5, " Posting of Limits and '

Controls," Chapter I of the license and Section 2.4, " Criticality Safety Limits and Signs," of Huclear Industrial Safety Manual (NIS), NIS No. 201, " Nuclear Safety Parameters." The inspectors did note that due to the design features and layout of the fuel rod loading and inspection areas, current postings seemed marginal and confusing as to defining the controls / limits between different work stations. This matter was acknowledged by the licensee who enhanced the postings. j i

The inspectors were informed that a new HF detection system is planned for the oxide conversion plant to replace the inoperable HF detection system that is currently installed. The system is currently tagged out of service because the HF detectors generally had failed calibration tests. The licensee is currently evaluating several HF detection systems for adequacy. Installation and acceptance testing is expected to be completed during the latter half of the year.

During an initial walkdown of the UF, vaporization area and upper levels of the oxide conversion plant, the inspectors noted that the housekeeping in these areas needed some attention. This was acknowledged by the licensee. During subsequent walkdowns of these areas, the inspectors noted that the licensee had promptly acted on this matter.

The inspectors noted that the operators were observant of issues ongoing in their respective work areas, particularly health and safety issues associated with routine work in their areas of responsibility. In particular, an operator reminded another plant staff that a hard hat was required prior to performing an activity in an area identified as a "hard hat" area.

During facility walkdowns, the inspectors observed that indicators on differential pressure gages on high efficiency particulate air filtering (HEPA) exhaust systems were within the prescribed limits. Hoods with air flows below the prescribed control limit were tagged out for non-use.

c. Conclusions The licensee's actions related to a license amendment submittal to clarify exhaust stack air sampling and cleaning requirements was identified as an IFI. Operators demonstrated sufficient knowledge of the criticality controls and limits for the systems they operated and/or tasks being performed. Housekeeping was generally adequate plant wide.

2.2 Conduct of Operations

a. Inspection Scope (88020)

The inspectors conducted a facility walkdown of selected areas to compare observations of activities in progress with selected written 6

procedures from the applicable procedures manual, in addition, the i inspectors reviewed several High Sample followup Reports (HSFR) to  ;

determine the adequacy of specific procedures used by the operators who )

were involved in recent airborne releases. Specific procedures and '

licensee documents reviewed were: j

• Operating System (05) Procedure No. 1705.01, " General Description of I Grinding Station, Trouble Shooting, Maintenance and Processing Grinder 1 j Sludge," Rev. 4, dated January 14, 1997. l I

• OS No. 801.15, " Gamma Counting," Rev. 6, dated January 14, 1997. l

• Shop Traveler (ST) No. 1119, " Uranium 0xide Pellet Plant-Micronizer,"

Rev. 9, dated March 7, 1996.

• OS No. 603.06, "Sempling Procedure," Rev. 1, dated November 25, 1996.

• HP No. 324, " Airborne Release," Rev. 2, dated December 23, 1996. I

b. Observations and Findinas On February 3,1997, a plant employee received a uranium uptake based I upon his lapel air sample results. (See Section 5.0) The incident l involved a micronizer hood operator who had been tasked to drop pellet i powder from a bag filter vessel into an approved container in a hood on l line 2. The operator did not wear a respirator when performing this particular task because the operation was performed in a hood. When the

, operator opened the dump valve from the bag filter vessel, uranium oxide powder was blown from the versel into the hood and subsequently escaped the micronizer powder hood and contaminated the operator. The air supply to the bag filter vessel apparently was not completely isolated by the operator. As a result, the bag filter vessel was partially pressurized with air prior to the operator opening the manual dump valve in the hood. Other operators questioned stated that they had not seen

' visible airborne material released from the hood when they conducted previous pellet powder recovery operations. They also stated that in 4 their opinions the air supply was not completely turned off by the operator or the air solenoid valves for the air supply failed to

completely shut off when the operator actuated the two hand switches.

The inspectors walked down procedures; ST No.1119 and OS No. 603.06,

, with plant operators. The inspectors _ determined neither of the procedures used by the contaminated operator appeared to be applicable for isolating the air supply to the filter bag vessel. The operators

, indicated that these proce.dures were inadequate in providing instructions to position the appropriate hand switches for isolating the

air supply for the filter bag vessel. -The operators pointed out to the

, inspectors that they had historically relied on verbal training conducted by other senior operators to properly conduct pellet powder recovery operations.

7

1 The inspectors also noted that the manual dump valve used by the line 1 l oxide plant micronizer pellet powder operators to dump pellet powder from the bag filter vessels did not conform to conventional valve handle l orientation configuration; i.e., the valve handle was in line with the '

piping which typically meant an open valve but in this case the valve was closed. The line 2 micronizer hood powder dump valve handle i orientation was correct for either open or closed valve operations. '

Operators who would be conducting pellet powder recovery operations on either of the two lines could mistakenly assume the incorrect dump valve !

orientation for that line and as a result, potentially risk another airborne release and personnel contamination.

Another plant employee received a uranium uptake on January 3,1997, as l measured by LAS results. (See Section 5.0) The incident involved an '

operator who had been tasked to " gamma count" trash bags. The operator was conducting a uranium assay of stored burnable trash bags with a Survey Assay Meter (SAM) prior to incineration or for later segregation based on the amount of uranium content. The operator did not wear a respirator when performing this particular task because the trash bags I are taped closed. When the operator pulled a trash bag out from the "to be counted" storage box for gamma counting (uranium assay), the contents l of the bag spilled out and contaminated the operator. The operator l found that approximately 2.3 kilograms of grinder sludge " muck" was in the bag, and that the bag had not been taped closed when it was placed I into the storage box. OS 1705.01, Section 12.0, " Processing Grinder Sludge" states, in part, that the grinder sludge is to be dried and then placed in a stainless steel container for storage in an approved location. Upon questioning, the operator stated that he had previously i found grinder sludge in trash bags on several other occasions. l The licensee's immediate corrective actions included placing the sludge in an approved storage container for processing and conducting refresher training at the weekly operators meeting that cautioned operators that l powder in any form; sludge or pellets, must not be placed in the trash.

The inspectors discussed these issues with the facility staff. The inspectors determined that following either of the operator uptakes, operations staff did not rigorously document any initial root cause efforts, either in facility logs or procedure revisions. As a result,  !

the methodology and results were not available for review by management. l This approach to the conduct of operations, that is, non-rigorous l documentation of root cause efforts, prevented identifying in one case, that the current pellet powder recovery operations did not have an l adequate or appropriate procedure developed and available for the operator's use. In the other case, operators did not follow the l l

procedure to properly process grinder sludge. In addition, this approach would also appear to limit the staff's opportunity to develop a more questioning attitude as a result of an increased understanding of the basis for ongoing operations activities. The licensee agreed to conduct a review of oxide conversion procedures as warranted and develop i the appropriate procedures as needed for filter bag vessel powder l recovery operations and conduct refresher training as needed for grinder l l

8

operators. The licensee's actions related to review and development of oxide conversion-procedures, will be reviewed during a subsequent inspection and is identified as an Inspection Followup Item (IFI 070-00036/97001-02).

c. Conclusions Corrective actions regarding weaknesses identified in procedures

. conducting powder recovery operations and processing grinder sludge evolutions were identified as an IFI.

2.3 Chanae Control

a. Inspection Scope (88020)

The inspectors reviewed selected documents and discussed a recent change related to the fabrication, handling, and storage of boiling water reactor (BWR) fuel bundles with the cognizant criticality safety specialist and responsible project engineer. The inspectors also conducted a walkdown of the area to confirm the application of criticality safety engineering and administrative controls related to this change. Specific procedures and licensee documents reviewed were:

• Operating System (0S) Procedure No. 210, Review of Process and Equipment / Facility Changes," dated December 18, 1987. .

• Nuclear & Industrial Safety Authorization (NISA), " Fabricate and Ship j BWR Bundles," No. 96048, dated December 20, 1996, and attachment i

" Nuclear Criticality Safety Evaluation (NCSE)."

l

• OS No. 3270.00, " Rod Receipt and Storage Procedures, Rev. O, dated December 17, 1996.

• OS No. 3310, " Crane Instructions for Bundles and Contaisiers," Rev. 3, dated December 17, 1996, and Rev. 4, dated February 6, 1997.

• OS No. 3260, " Helium Leak Detection & Transfer Rods to Storage," Rev.  !

11, dated February 6, 1997.

b. Observations and Findinas

-Related to the current change process, a NISA must be obtained for each facility change involving nuclear safety, radiological safety, or industrial safety. NISAs provide a summary of the conditions and special requirements, derived from the associated NCSE and/or engineering safety evaluation, to be implemented by the operating group.

New or revised operating procedures related to the change are forwarded i to Regulatory Affairs for confirming conformance to the NISA conditions and change specifications and final approval.

9

y. _ _ _ _ _ _ _ _ _ . _ . __

i NCSEs, in part, summarize _ and detail the conclusions, and " suggested" limits and controls from the CSAs for the change. Historically, the licensee's CSAs were performed and maintained at the Windsor facility.

Relative to the ongoing CSPU, the licensee was in the process of i transferring all applicable CSAs to the Hematite site. At the time of inspection, the CSAs related to the subject change were being revised in conformance with the CSPO and were not reviewed by the inspectors.

The inspectors noted that the NISA (No. 96048) for the change adequately

. summarized the conditions and special requirements to be implemented as ,

derived from the respective NCSE. The inspectors noted that the NCSE I provided a summary of bounding assumptions, conclusions of the calculated margin of safety from normal and upset conditions, criticality safety limits and controls, operator training requirements, and requirements for reporting of upset conditions that have an effect on the established criticality safety controls. The limits and controls primarily involved physical barriers associated with the design of the  ;

rod storage matrix c.nd physical restraints and administrative controls )

for the fuel bundle storage rack.

During facility walkdowns, the inspectors confirmed that the controls I and limits identified in the NCSE were in existence and being used.

Inspectors also noted that instructions relative to the limits and '

controls had been incorporated into the applicable operating procedures.

However, the inspectors noted that certain instructions on reporting of an upset condition had not been incorporated into the operating procedures as required by the NISA and NCSE:

• The NISA and Item 5.3.2.3, of the NCSE required, for the rod storage matrix, that the applicable operating procedure state that,

" collisions between heavy equipment and the matrix must be reported to the process engineer and the NCSS."

The inspectors noted that the applicable procedure OS No. 3260.00 did not include this safety instruction.

• The NISA and item 8.3.2.3, of the NCSE required, for the fuel assembly storacje rack, that the applicable operating procedure state that,

" collisions between heavy equipment and the array or impact with an assembly severe enough to cause assembly damage must be reported to the process engineer and the NCSS."

The inspectors noted that the applicable procedure OS No. 3310.00 did not include this safety instruction.

10

The.above observations were discussed with cognizant licensee personnel. I Inmediately following this discussion, the licensee revised procedures i OS No. 3260.00.and OS No. 3310.00 to incorporate criticality safety reporting' requirements. The licensee also initiated operator training i on the revised procedures. At the exit meeting,-the licensee informed '

the inspectors that they had completed operator training on the revised procedures.

Safety Condition S-1 of Special Nuclear Material License SNM-33 requires that licensed material be used in accordance with the statements, representations, and conditions in Chapters 1 through 8 of the application dated October 29, 1993, and stoplements thereto.

Section 4.1.3, Chapter 4 of the license application requires, in part, that criticality evaluations: 1) consider potential scenarios which  !

could lead to criti<:ality, and 2) barriers erected against criticality in establishing limits. and controls, and that these limits and controls 4 be incorporated into applicable procedures and postings. '

The failure to include the specified criticality safety instructions  !

for reporting of potential damage to criticality safety barriers required by Safety Condition S-1 of the license was identified as a violation 70-00036/97001-03. Although,-the inspectors recognized _that i the licensee took immediate corrective actions to correct the problem, the matter was identified by the NRC, and the cause and corrective )

actions to prevent recurrence had not been identified by the licensee. ~

As a result, this issue was treated as a cited violation.

c. Conclusions Criticality safety engineering and procedural administrative controls appeared to be adequately implemented with one exception. A violation was identified, where the licensee failed to conduct an adequate review of several operating system procedures.

2.4 Incinerator Operatinas

a. Inspection Scope h. J20 and 88035)

Selected documents and procedures related to inc'inerator operations were reviewed and discussed with operations and other cognizant licensee personnel. The inspectors also conducted a walk down of the system to confirm the application of criticality safety engineering and administrative controls related to incinerator operations. Specific procedures and documents reviewed were:

• Process and Equipment / Facility Change Proposal, dated February 15, 1994, for installation of a new incinerator.

• Engineering safety evaluation - System 330, " Incinerator," dated November 30, 1993.

11

s'

• I

• NISA Control No. 009, dated July 19, 1994.

4

• OS No. 860.00, Incinerator Operating Procedure," Rev. 2, dated December 12, 1996.

,

• OS No. 861.00, " Incinerator Clean-out," Rev. 2, dated December 12, 1996.

b. Observations and Findinal l l

The incineration process was divided into four systems: (1) feed preparation, (2) incineration, (3) off-gas treatment, and (4) ash removal. Solid waste is manually loaded into a feed chamber where the material is ultimately pushed into the primary chamber with a hydraulic 4

ram. Liquid waste can be metered into a nozzle in the natural gas burner located in the top of the primary chamber. Interlocks prevent i feeding of waste until' the proper burning temperature is reached in the primary chamber.

Criticality safety was based on a mass limit (800 grams U-235) and i moderation control (limited water sources and temperature control for waste burning). The inspectors noted that solid waste was adequately inspected, sorted, and assayed for U-235 content before incineration.

Burning of solid waste is accomplished by manual loading of a single charge (limited to 10 grams U-235). The 800 gram U-235 limit was controlled by a continuous computerized mass balance of the uranium fed into the incinerator and the uranium removed with the ash. Ash removal was required when 200 grams U-235 had been processed. The computer system was interlocked with the incinerator feed door to prevent burning of material when 800 grams of U-235 has been processed. At this time, the inside of the incinerator is inspected and cleaned of any residual ash before another run takes place. Based on the composition of material burned and operation of the incinerator, the licensee has not experienced any buildup of ash or slag on the inside of the incinerator, which could have an impact on the mass limit during operation of the incinerator.

The inspectors noted that the operating procedures adequately incorporated the applicable criticality safety limits and controls, radiological safety requirements, industrial safety requirements, emergency operations, and SNM inventory control. Operators were knowledgeable of the safety requirements and instructions in the operating procedures. Waste handling and sorting operations, and waste assaying were in conformance with established procedures.

c. Conclusions The inspectors concluded that the licensee was adequately implementing its criticality safety requirements for waste incineration operations.

Operators appeared adequately qualified and sufficiently knowledgeable of the respective safety requirements.

12

s* . ,

i 2.5 Criticality Alarm System (IP 88050)

a. Inspection Scope

, The inspectors conducted a walkdown of the criticality alarm system and 4

reviewed the criticality alarm system surveillance records.

b. Observations and Findinas

Criticality alarm instrumentation appeared consistent with license requirements regarding installation and location. The inspectors reviewed the Criticality Alarm System test reports for the period from last quarter of 1996 to February 7,1997. The " Monthly Nuclear Alarm Checklist" that recorded the required quarterly surveillance testing i data appeared consistent with procedural requirements. The licensee

incorporated the criticality alarm calibration and testing procedures into a new procedure to capture all of the license requirements for the -

criticality alarm system. The criticality alarm panel configuration was

reviewed and -no anomalous alarms were present.

2 .

c. Conclusions

The licensee has adequately implemented the surveillance program for the

! criticality alarm system.

3.0 Maintenance / Surveillance Testina a

3.1 0xide Conversion Plant

a. Inspection Scope (88025 and 88020)

The inspectors reviewed and discussed calibration and testing

, procedures, and industrial and criticality safety controls associated with the oxide plant and the waste incinerator. The inspection also included a walk-down of the UF, vaporization process, selected portions of the oxide conversion process, and incinerator systems.

b. Observat' ions and Findinas The inspectors noted that the six-month calibrations and defined j operability tests of the criticality safety controls and alarms were consistent with OS No. 4101.00, "0xide Inspection and Alarm Calibration / Testing," Revision 6, dated August 20, 1996,-and Section 4.2.4, "Special Controls," Chapter 4 of the license application.

The inspectors noted, that with the exception of the UF, vaporizer conductivity probes, procedure OS No. 4101.00 and the respective surveillance sheets defined testing of the interlocks for all of the

, controls to verify that they were capable of performing their intended safety function. According to the process engineer and as specified in 05 No. 4101.00, the conductivity probes are only inspected for damage and the operability of the associated alarm is verified. Due to 13

n' .

1 previous fouling problems, the licensee was inspecting and testing the

, alarm function of the conductivity probes prior to conducting UF.

cylinder operations.

The conductivity probes are used to detect the presence of SNM in the condensate line, their safety function is to automatically close the UF. ,

cylinder valve, start the wet HF scrubber, and shut off the steam supply '

to the UF. cylinder vaporization chamber. The importance of performing i a system functional test is to provide reasonable assurance that the l conductivity probes are capable of performing their intended safety function. This matter was discussed with the licensee during the l inspection and at the exit meeting. The inspectors' observation was 1 acknowledged by the licensee.

The lack of functional testing to determine that the conductivity probes are capable of performing their intended safety function was identified as a weakness in the 1icensee's surveillance testing program. The licensee's actions related to this matter will be reviewed during a subsequent inspection and is identified as an Inspection Followup Item (IFI 070-00036/97001-04).

c. Conclusions Periodic calibrations and defined operability tests of the criticality safety controls and alarms were adequately implemented with one l exception. An IFI was identified related to a weakness in the licensee's surveillance testing program regarding conductivity probes.

3.2 Incinerator

a. Inspection Scope (88025)

Calibration and testing of controls and safety interlocks were discussed with the cognizant process engineer and maintenance personnel. The inspection also included a review of the licensee's engineering safety report of the incinerator systems.

b. Observations and Findinas From discussions with the responsible process engineer and review of the licensee's engineering safety report System 330, " Incinerator," dated November 1993, the inspectors noted that the incinerator system was equipped with several safety interlocks that provide either an automatic shutdown of the incinerator or prevented operation of the feed ram.

Most of these interlocks were primarily defined as safety related equipment for environmental and radiological protection. Some of the defined safety features that caused an automatic shutdown of the incinerator were failure of the scrubbing system's recirculating pumps

, (differential pressure switch), failure of the exhaust fan (differential pressure switch), failure of roto-filter motors (overload circuit), and excessive vibration of the scrubbing systems roto-filter (vibration switch). The primary and secondary chambers were equipped with low 14

. - . _ . - . ~_ - - - ._- -.- - . . - - - . . -

,a w ,

, temperature interlocks that prevent operation of the feed ram below specified temperatures.

According to the process engineer, there was no program established for

- calibrating the safety devices or tests to assure that -the safety 1 interlocks performed their intended safety function. Although such

. tests were conducted.when the new incinerator system was installed in j 1994, there have been no subsequent tests. The process engineer stated i that the accuracy of the incinerators temperature indicators are l monitored and calibrated as necessary. In addition, the inspectors noted that calibration records were not maintained and there was no established calibration frequency. The benefits of testing the safety

iaterlocks were discussed during the inspection and at the exit meeting.  ;

i This matter was acknowledged by the licensee.

c. Coplesions -

i r

' j

. The inspectors concluded that the lack of a formal program to calibrate l r the incinerator's system safety devices and conduct tests to assure that  !

i the safety interlocks performed their intended safety function was a l weakness in the maintenance program. The licensee's actions relative to )

. this matter will be reviewed during a subsequent inspection and is identified as an Inspection Followup Item (IFI 70-00036/97001-05).

i 4.0 Operator Trainina'(IP 88010) i'

a. Inspection Scope i

The inspectors reviewed and discussed the applicable licensee-training

programs with cognizant licensee personnel, reviewed selected records of

{ training, reviewed new lesson plans, observed ongoing activities and i held discussions with selected personnel. On February'5, 1997, the I licensee informed the inspectors that annual refresher training would be i i conducted on the Self Contained Breathing Apparatus (SCBA). The i- inspectors attended the training to evaluate the content and q effectiveness of the SCBA training for plant operators. 1 i

b. Observations and Findinas Within the past year, the licensee had significantly enhanced the depth and scope of their training program for plant employees. Section 2.5 of the license requires the licensee to provide initial training and i biennial retraining as appropriate in nuclear criticality, occupational i safety, radiation safety, contamination control, ALARA practices,

accident prevention,' personnel protective equipment, hazardous chemical i safety, fire protection, and emergency response. The inspectors noted that the revised lesson plans for each of the training topics were well l developed, comprehensive in scope and undergoing final review and approval from plant management. The licensee has also developed 3

separate written tests associated with each of the traiaing topics to

better measure and document the understanding of important concepts prior to the employee's initial work assignment. The licensee indicated 15

)

,i .

, t that the revised training program will be fully implemented by the end of the first quarter of 1997. For the random selection of new and experienced operators chosen by the inspectors, appropriate documentation of required training and completed tests were on file for the initial training and biennial retraining.

The inspectors attended the SCBA training class. The training covered the licensee's respirator program, basic respirator safety requirements, procedures for donning respirators and the methodology of verifying SCBA operability. The instructor had well developed course objectives and reinforced these objectives during the practical demonstration.

Training class attendees demonstrated the proper donning and use of the SCBAs. The instructor adequately responded to all questions posed by class attendees.

c. Conclusions -

The licensee's training program was consistent with the requirements of Part 1 of the license and appeared effective. Operators appeared l knowledgeable and adequately qualified to perform their assigned tasks. '

SCBA training appeared effective.

5.0 Radiation Protection (Ip 83822) l 5.1 Exoosure Control Proaram

a. Inspection Scope The inspectors reviewed the licensee's exposure control programs including, the bioassay program, air sampling data, and HSFR reports.

Specific procedures and documents reviewed were:

• HP Procedure No. 314, " Employee Bioassay Sampling," Rev. 3, dated 4

September 10, 1996.

• HP No. 324, " Airborne Release," Rev. 2, dated December 23, 1996.

i'

• HP No.'.300, " Fixed Workstation Air Sample Collection and Logging,"

Rev. 5, dated September 10, 1996.

b. Findinas and Observations The inspectors reviewed selected air sampling results from approximately 92 air samplers. located throughout the plant from December 1996 through the.date of the inspection. Samples were collected and counted each shift. Sample results for the general area samplers typically yielded concentration levels of airborne uranium of 0.2 DAC or less for Class Y material. The inspectors noted that during the facility walkdown that several fixed location air samplers appeared to be no longer in use.

The licensee explained that nine air sampler loc'ations in the process buildings were moved to provide representative airborne concentrations in new work locations. Air sampler locations were typically changed 16

,s .

based upon the annual air flow direction checks required by the license or when process equipment was moved or design changes were completed; i.e., the new grinder installation. The inspectors observed that new air sampler locations appeared to be adequately positioned for monitoring potential uranium uptakes by the plant employees.

HSFRs were generated when either the daily fixed air samplers had a concentration equal to or greater than the DAC for Class Y uranium or an operator's lapel sampler (LAS) results indicated an intake of greater than 8 DAC-hours during a shift. In addition, bioassay sampling was conducted when an operator's LAS had a suspected intake greater than approximately 40 DAC HOURS or the operator had a potential ingestion of a radionuclide in an insoluble form during one shift.

On February 3, 1997, the LAS results from a micronizer operator indicated an uranium intake of 56.4 DAC-hours. The LAS results from a gamma count operaton indicated an uranium intake of approximately 20 DAC-hours. Both high samples appeared to be the result of an actual high airborne contamination. The micronizer operator submitted fecal samples according to the licensee's policy which included analysis by an outside laboratory. The inspectors noted that the administrative requirements for the submitted sample appeared consistent with HP 314 guidance. The results of the bioassay were pending at the conclusion of the inspection and will be tracked as an Inspection Followup Item (IFI 070-00036/97001-07).

The inspectors reviewed the new HSFR tracking system which provided an analysis of the number of HSFRs generated from specific process areas; i.e., pellet plant, oxide, redroom, etc.. The tracking system also trended the different root cause categories of the HSFRs; i.e.,

engineering controls, operator errors, unknowns, etc.. The inspectors noted that of the 886 HSFRs generated in 1995, approximately 41% of the HSFRs (359) were categorized as " unknowns". Upon further review of the HSFR trends, the inspectors noted that approximately 23% of the HSFRs (204) were as a result of operator errors.

Approximately 764 HSFRs were generated in 1996. The licensee indicated that the. corrective action plan implemented in 1995 initiated a decreasing trend in the number of HSFRs generated in 1996. Some of the corrective actions planned included the scheduling of additional operator training sessions to help eliminate operator errors and the elimination of the " unknowns" category by conducting better root cause investigations of the HSFRs. The licensee's actions related to this matter will be reviewed during a subsequent inspection and is identified as an Inspection followup Item (IFI 070-00036/97001-06).

17

sr . ,

I l

The inspector reviewed selected records of routine surveys performed by the licensee during the period of December 1996 through the date of the inspection. The records indicated that the licensee has been performing surveys of its contaminated and clear areas as specified in its license.

Smear results above the licensee's action level for each type of area ,

L resulted in the decontamination of the area and a re-survey to document  ;

that contamination levels were below the licensee's action limits. I i )

c. Conclusions The inspectors concluded that the licensee's bioassay program, survey records, and air sampling program for radiation exposure control met license conditicas and regulatory requirements. The licensee's l

, corrective actions related to the operator training and root cause investigations were identified as an IFI. An IFI was also identified relative to bioassay results for a micronizer operator.

l 6.0 Transoortation Activities 1

a. Inspection Scope (IP 86740)

The inspectors reviewed the licensee's transportation program relating to UF, cylinder shipments. The inspectors reviewed procedures and i records for receiving and shipping cylinders with overpacks, and observed cylinder and trailer surveys for exposure -rates and removable contamination. Specific procedures and. documents reviewed were:

• HP_ Procedure No. 308, " Performing Trailer Surveys," Rev. 3, dated September 10, 1996.

• OS No.1001.2, " Classification of Materials for Shipment," Rev. 2, dated November 23, 1996.

• OS No.1001.3, " Classification, Description, Packaging, and Marking Instructions," Rev. 3, dated January 10, 1996.

• OS No. 1001.4, " Specific Product Instructions," dated January 3, 1996.

• OS No.1001.5, " General Labeling, Mixed Container Shipments, &

Shipment Bracing Instruction," dated January 6, 1992.

6.1 UF, Cylinder Shioments

b. Observations and Findinas During the inspection, the inspectors observed the loading of five empty Model 308 Cylinders in UX-30 radioactive overpack containers. The inspectors observed that the cylinder packages were loaded in accordance with OS No. 1001.3 and OS No. 1001.4. The inspectors noted that although the majority of the shipping procedures contained references to three fissile -lassifications, the transportation supervisor was aware i

18

._. .-. . - -.- - ~ .- - - . . . .. - ~ _ . - _ - . --

,6- i ,

T that the different fissile classes were deleted from 49 CFR Parts 100-179'in 1996. The supervisor indicated that transportation training was y conducted in April 1996 regarding'the revised Department of-

Transportation.(DOT) Regulations.

[ 'The inspectors also observed that the overpack containers were

appropriately positioned and braced on the trailer.- The inspectors S

further observed that appropriate fasteners were used on the container.

2 The. loaded containers were appropriately' marked and labeled for

, shipment. The individuals performing the loading had qualified on the '

! . loading and packaging procedure.

1 .

I The transportation supervisor informed the inspectors that on  ;

October 30,.1996, a semi-tractor trailer carrying approximately'six

empty Model 30B cylinders-in overpacks had a trailer separation while

making the turn'out of the facility's parking lot. Although, the '

shipping company corrected the situation, the licensee later learned.

that a subsequent trailer separation occurred. The licensee.was 1 tracking this issue for further review. )

6.2 Shipping Papers l

'b. Observations and Findinas i

! The shipping papers of licensee transportation activities regarding UF. j cylinder shipments made-to an authorized license were reviewed.

Selected records: associated with shipment numbers ZWQ-BXA-273.and 274: .i and shipped as " exclusive use" on February 5 and 7,1997 'were. reviewed j in detail. The inspectors reviewed the Bill of Lading, shipping i records, UF. cylinder inspection forms, overpack inspections forms, and exclusive use vehicle instructions to the carrier. The inspectors noted that 10 CFR 172.203 (d) (10) requires " Exclusive use shipment" to be added on the shipping paper if appropriate. The transportation supervisor stated in lieu of putting that statement on the shipping paper, an exclusive use vehicle instruction form accompanies the shipping documentation.

6.3 . Trailer' surveys

b. Observations and Findinas A review of selected survey records for the period including October 1 1996 to February 7,1997, for UF cylinders shipped and received documented that removable contamination on cylinders, overpacks and  !

trailer was below the limits of 49-CFR 173.443. Dose rates for cylinders, overpacks, and vehicles were below the limits in the DOT regulations as well.

19

,ec,

c. Conclusions The inspector concluded that the licensee was effectively implementing its radioactive materials transportation program. Individuals performing these activities had been adequately trained on the procedures and qualified for their assigned tasks.

7.0 M3naaement Meetina The inspectors met with the representatives and other staff throughout the inspection and on February 7, 1997, for the exit meeting. The inspectors summarized the scope and findings of the inspections.

The licensee did not identify any of the information discussed at the meeting as proprietary.

A e

20

PARTIAL LIST OF PERSONS CONTACTED l Licensee Personnel Contacted  !

1

• B. Xaiser, Vice President, Fuel Operations  !

E. Criddle, Training Coordinator '

-M. Eastburn, Nuclear Criticality Specialist R. Freeman, Nuclear Criticality Specialist J H. Eskridge, Senior Consultant Regulatory Affairs -

K. Hayes, Industrial Safety Engineer D. Rhode, Technical Training Project Manager.

G. Page, Director, Ceramic Operations B. Tolan, Director, Assembly Manufacturing B. Sharkey,-Director of Regulatory Affairs E. Saito, Health Physicist K. Funke, Health Physics Supervisor

• Senior licensee official at exit meeting on February 7,1997.

l 4

21

io*,

I j Inspection Procedures Used IP 88005: Management Organization and Controls IP 83822: Radiation Protection IP 88010: Operator Training i IP 88020: Criticality / Operations Review I IP 88025: Maintenance / Surveillance  !

IP 88035: Radioactive Waste Management Items Opened. Closed. And Discussed 4

Ooened 070-00036/97001-01 IFI Clarification of exhaust stack air sampling and l 1

cleaning requirements will be submitted for a license 1 emendment. l 070-00036/97001-02 IFI Review of oxide conversion procedures will be I j conducted by the licensee as needed for powder  !

recovery operations.  !

070-00036/97001-03 VIO The licensee failed to include the specified safety instructions for reporting of potential damage  !

-to criticality safety barriers.

3 070-00036/97001-04 IFI The licensee's lack of functional testing to determine that the conductivity probes are capable of performing their intended safety function.

070-00036/97001-05 IFI The licensee lacked a formal program to calibrate the incinerator's system safety devices and conduct tests to assure that the safety interlocks performed their intended safety' function.

070-00036/97001-06 IFI The licensee planned to conduct additional operator training and root cause investigations of HSFRs.

070-00036/970dl-07 IFI Bioassay results from an exposed plant employee will be reviewed.

List of Acronyms i ALARA As low As Reasonably Achievable CFR Code of Federal Regulations HF hydrogen fluoride

, HP health physics hr hour IFI Inspection Followup Item IP Inspection Procedure NRC Nuclear Regulatory Commission U F, uranium hexafluoride HSFR High Sample Followup Report 22 4

.