ML20138A767

Insp Rept 70-1257/85-12 on 851105-25.No Violations Noted. Major Areas Inspected:Mgt Organization & Controls,Training & Retraining,Criticality Safety,Operations Review & Maint & Surveillance Testing

ML20138A767
Person / Time
Site:	Framatome ANP Richland
Issue date:	12/06/1985
From:	Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20138A746	List: ML20138A742 ML20138A767
References
70-1257-85-12, NUDOCS 8512120104
Download: ML20138A767 (9)

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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/85-12 Docket No. 70-1257 License No. SNM-1227 Safeguards Group: I Licensee: Exxon Nuclear Company 2101 Horn Rapids Road Richland, Washington 99352

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Facility Name: Richland Facility Inspection at: Richland, Washington Inspection conducted: November 5-25, 1985 Inspector: M4 B. L. Brock, Fuel Facilities Inspector Date Signed Approved By: TS. P%h.c tw6-g(

R.D.Thomad(Chief NuclearMater}ialsSafetySection Date Signed Summary:

Inspection on November 5-25, 1985 (Report No. 70-1257/85-12)

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

The inspection involved a total of 25 man-hours onsite by one NRC inspector.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 88025, 83822, 86740, 88045 and 83890 were covered.

Results: No violations were identified in the nine areas inspected. i l

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DETAILS

1. Persons Contacted

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

• C. W. Malody, Manager, Corporate Licensing

• T. C. Probasco, Supervisor, Radiological' and Industrial Safety

• L. D. Gerrald, Criticality Safety _ Specialist

• J. E. Pieper, Specialist, Health Physics B. E. Berst, Manager, Specialist Fuels

• R. H. Purcell, Manager, Safety and Security E. L. Foster, Radiological Safety Assistant S. G. Harbison, Manager, Facilities and Equipment, Engineering V. A. Collins, Manager, Security

• M. K. Valentine, Manager, Plant Operations W. E. Stavig, Senior Operations Analyst M. O'Neil, Project Engineer, Equipment Engineering J. Lusty, Traffic Controller E. T. Johnson, Supervisor, Analytical Chemistry Laboratory E. R. Marx, Supervisor, Inspection Engineering H. Thiss, Manager, Purchasing and Logistics S. R. Lockhaven, Specialist, Industrial Hygiene M. Kirkman, Process Engineer, Conversion M. T. O'Rourke, Engineering Assistant 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 SNM-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.

(1) The inspector reviewed the Senior Operation Analyst's monthly production criticality safety audits. Items identified during the audits were expeditiously corrected. The operator's shift reports (Shift Fissile and Criticality Violation reports) have proven helpful in identifying potential safety problems and operation improvements.

(2) The inspector reviewed the minutes of the monthly meetings of the licensee's Safety Committee. An incident review board's investigation of an unannounced criticality alarm was also reviewed by the inspector. No criticality incident had occurred. The alarm sounded (on Saturday, September 7, 1985) because of a preventative maintenance sequence and a wiring

, 2 error made recently in a compactor panel of the criticality alarm system. Two employees of the 43 onsite were injured during the evacuation and one employee did not evacuate in a timely manner. The cause of the incident was identified along with areas of the licensee's response that could be improved.

Nine corrective actions have been completed. Three corrective actions in process are: 1) the receipt of additional survey equipment purchased to upgrade that assigned to the Emergency Command Post, 2) the planned additional emergency response training that will include the employee whose response to the alarm was not acceptable, and 3) the installation of a key operated criticality howler silencer switch for use af ter all employees have evacuated from the plant. The status of these incomplete corrective actions will be reviewed during the next inspection (85-12-01). The inspector also reviewed the report of an incident in which a remotely operated valve failed to close. The employee who actuated the valve was subsequently splashed with five to ten gallons of uranium recovery solution when he began to change a, filter downstream from the valve. A survey of the employee with an alpha meter found no significant contamination. The employee washed his face and hands changed 3

into clean radiation protection clothing and returned to work.

A few days later a survey of his clothing at the onsite laundry identified residual beta gamma contamination. A survey of the employee's house revealed no significant contamination.

Appropriate corrective action was+taken to preclude recurrence.

A copy of the licensee's inv'estigation report was obtained.

This item will be reviewed during the next' inspection (85-12-02).

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.

The previous inspection (70-1257/85-10) resulted in the recommendation that the licensee include an explanation of the various radiation safety signs and symbols during the orientation given to new non-radiation workers. The inspector found that the licensee is preparing slides, view graphs and fliers to use with descriptions of stickers, signs and labels in the next class.

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

'3 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 the license application and all determinations of Nuclear Criticality Safety be reviewed and approved by a second party reviewer in accordance with the requirements.

The licensee completed two criticality safety analyses since the last inspection. The analyses had been reviewed and approved by an independent second party reviewer as required. The inspector verified that the licensee had also completed an additional analysis of the tanks added to increase the capacity of the liquid uranium recovery process (LURP). This closes item 85-10-01.

No violations were identified.

5. Operations Review Section 2.1 of the license application requires the licensee to conduct business in a manner so as to assure that licensee facilities are safe 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 maintained as low as is reasonably achievable (ALARA).

A. Conduct of Operations (1) The expanded Liquid Uranium Recovery Process (LURP) has been shut down for the winter.

(2) The modified Gadolinium Scrap Recovery Process (GSRP) was not being operated during this inspection. Its use depends on the need for uranium of the enrichments available in the scrap pellets.

(3) The pit next to lagoon two is scheduled for use in leaching uranium from the sand stored in the trench adjacent to lagoon three. The license permits sand with less than 30 pCi of uranium per gram to be disposed of to a landfill. The licensee was informed that NRC may want to verify the uranium content of the sand before it is sent to a landfill.

(4) The licensee's dry conversion equipment was in place. The license reviewer identified the need for a lock on a bypass valve at the point where the uranium in the HF stream is measured. The bypass valve facilitates calibration of the inline measurement equipment. The licensee agreed to install the lock to preclude inadvertent rerouting of the HF liquid effluent around the uranium measurement point. The valve lock and its control will be checked during the next inspection (85-12-03).

(5) The cleanup of the former mixed oxide processing room (Room 173) in the Speciality Fuels Building (SFB) is nearly complete. Eight 1crge monolithic concrete blocks containing

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glove boxes and processing equipment are temporarily stored ,

onsite pending receipt of approval to ship them to an approved 3-radioactive waste burial site. About 33 drums of TRU l j (transuranic) waste are also stored onsite. The measurement of the TRU content of the drums was made recently by a contract

laboratory but the results were not.yet available. .The

, , licensee indicated'the waste drums will require onsite storage j _ because they are'not expected to be acceptable for disposal at

a low level radioactive waste disposal site. The measurement 4

results and their affect on the disposal of the TRU waste drums

will be reviewed during the next inspection (85-12-04).

No violations were identified.

6. Maintenance and Surveillance Testing i

Section 3.12 of the license application requires that periodic tests and inspections are conducted in accordance with written procedures and are 2

properly documented.

l A. Maintenance

', (1) . Because of the employee injuries experienced during the recent criticality false alarm, the licensee undertook a review of the high volume and air-conditioning system (HVAC) response, and

, the resultant change in negative pressures in the UO 2 building.

The employee injuries during the evacuation resulted from their attempted passage through airlock doors within the building.

The licensee found there was no. difficulty exiting but more than normal pressure was required to open the airlock doors

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under the conditions that existed at the time of the false alarm. Engineering is evaluating a method of precluding the pressure change but must also consider the . associated reduction

{' in ventilation flow, furnace heat removal and smoke ejection that would be available during an emergency.

(2) The licensee prepared a revision to his PM test procedure for the criticality alarm system. The revision details the use of the new locked howler silencer switch.

No violations were identified. '

7. Radiation Protection- -

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. . - m c Pursuant to 10 CFR Part 20, the license'e isi required to provide

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protection against radiation hazards as,sociated.with licensee activities.

1 - A. ' Bioassay Results' ,

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Urinalysisresultsforthethiidquaftehof1985:wereexamidedby

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the~ inspector. No results exceededithe. licensee's action level of

, 25;ug U/L. Two individuals samples mea'sured 24.00.ug'U/L and l- remeasurement a month later yielded 10.00 ug U/L- for both' individuals with no further action' required. +

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B. Lung Count Results Measurement results for lung counts made during the third quarter 4

were examined by the inspector. One measurement of 0.41 nCi required monthly remeasurement and a rush urinalysis. The remeasurement yielded a report of "non detectable" with a minimum detection level of 0.10 nCi and the urinalysis was 7.46 ug U/L. No further action was taken because the second lung count confirmed the initial spectral indication of external contamination.

3 C. Whole Body Exposure The inspector's examination of the exposure records found that the highest radiation exposure for onsite work during the third quarter was 0.22 rem whole body and 0.22, rem skin. This was received by an individual working in the UF e aversion area. This individual's 6

cumulative whole body exposure to date was 0.41 rem. .None of the reported exposures for work at the Richland Facility exceeded NRC Part 20 requirements.

D. Surface and Air Contamination .

(1) The licensee's airborne contamination levels'.in all restricted areas remains less thaa 10 perc'ent 'of the NRC limit of 1.0 E-10 uCi/ml. The areas with the highest airborne contamination levels are identified-in weekly reports to appropriate managers and/or supervisors. The recentlyfcompleted enclosure of press number one is expected to: lower the airborne contamination in the press area. The enclosure of the barrel tumbler (see Section 7.E.) and planned modifications,to the lube blend hoods should further reduce airborne contamination levels.

(2) .The license replaced the tygon tubing in the duct sampling lines with metal tubing. This action closes item 85-10-05.

! E. Radiological Safety Audits i

Radiological safety audits are being performed monthly by the Senior Radiological Engineer (SRE) as required by Section 3.13.1 of the current license application. The radiological safety practices in the plant are reviewed during these audits, and the findings are included in a written report to managemect.

The licensee's internal audits previously identified contamination around the barrel tumbler in Room 180 and on pallets that were used

, there. The. licensee has brought appropriate resources together to solve this problem. It appears that the pallet contamination will be reduced and the pallets may no longer be needed to transport the barrels to the head end of the pellet pressing lines. Additionally, the planned enclosure of the barrel tumbler will improve control of airborne contamination. ~These open items, 85-06-01 and 84-10-02, will. remain'open until the affect of the changes has been

. determined.

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l No violations were identified. '

8. 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.

During the previous inspection (70-1257/85-10) the licensee was cited by the NRC for failure to comply with 49 CFR 173.425(b)(1). A container with a hole in it (WD-17276) was included in the licensee's shipment H1116 to the U.S. Ecology low level waste burial site in Richland, Washington. The container was inspected at the burial site by a State of Washington inspector. The licensee was cited by the State inspector and the licensee's Site Use Permit was temporarily suspended. .The licensee's Site Use Permit was reinstated on August 25, 1985, after'the Radiation Control Section of the State of Washington reviewed the licensee's corrective action. The NRC inspector reviewed the licensee's revised Quality Control Standard which now emphasized an added requirement that the QC inspection would be made at the time of loadirg the shipping truck and not a few days earlier as previously permitted. The inspection would include the sides, top and bottom to be sure they are free of holes and dents would also be carefully checked. The NRC inspector reviewed tha shipping records and noted the reduced shipment size the licensee previously indicated would facilitate training in the use of the revised procedure. The shipments made since the licensee implementated his corrective actions have been without incident. It appears that the licensee is currently in compliance with 49 CFR 173.425(b)(1). The QC shipment inspection improvements satisfactorily address a portion of open item 85-06-02, but it will remain open until the review of the QC audits of packaging and monitoring techniques in the UO 2 building have been reviewed.

No violations were identified.

9. Environmental Protection Section 3.5 of the license 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 strategic locations for analysis of pertinent chemicals and uranium.

A. The licensee arranged for the uranium content of sludge samples to be measured by an independent contract laboratory as well as his own laboratory to clear up a question about the accuracy of his fluorimetric measurements. The licensee indicated that preliminary results reflected reasonable agreement between the laboratories but an understatement was identified and traced to the difference in the procedures used. The licensee's procedure doesn't separate elements that quench the fluorescence thus leading to an understatement of the measured uranium. The licensee's action will be reviewed during the next inspection (85-10-04).

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B. The licensee reviewed the gaseous effluent measurement system l sensitivity as a result of a question raised about the accuracy of the sensitivity implied in the semiannual effluent reports. The review indicated the uncertainty in the measurements was understated as a result of failure to include the uncertainty in the background measurement when determining the net count measurement uncertainty.

The licensee's data will be reviewed during the next inspection (85-10-03).

C. The measurements'from the seven NRC samples taken at the licensee's site were received. All measurements were less than NRC release limits. The data will be included in the report of the NRC survey results of Room 173 of the Speciality Fuels Building following the NRC overcheck.

No violations were identified.

10. 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 licensee had removed all equipment and gloveboxes from Room 173. The licensee's surveys indicated that the room was clean. The status of the room was discussed and needed additional information was identified. The licensee agreed to remove a door bumper plate, and modify the drawings to clarify the floor drain locations and the subfloor drain pipe routes.

The licensee's final report, including the room survey results, is expected to be sent to NRC Headquarters within two weeks with a copy to Region V.

No violations were identified.

11. Exit Meeting The results of the inspection were discussed with members of the licensee's staff identified in Section 1. The topics included:

the areas inspected. ,

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no violations were identified.' '

3 the status of open items. _,. , s_ ,

the review of internal investigations:; " J . 7  ?#

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the criticality alarm system false' alarm) the failure of an automaticsshutoff valve '

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the need for additional detail in th'e drawings of Room 173 of the SpecialtyFuelsBuilding(SFB).[ ,

the followup lung count measurement results not.available during the inspection.

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Dry Conversion Process licensing; ,

Trend analysis of airborne' contamination.

Centrifuge Test Facility overcheck by }mC should be' considered.

Consideration should be given to consolidation of several parts of the license including incorporation of the license conditions into the license application.

The number of license amendments submitted for quick processing must be reduced.

The licensee agreed to consider an NRC overcheck of the Centrifuge Test Facility. The licensee also indicated an effort would be made to reduce the number of license amendment quick processing requests. The next license renewal request will be prepared with consideration to consolidation. The licensee indicated that the final report of his survey of Room 173 of the SFB will also include appropriate drawing detail.

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