ML20148A158

IE Inspec Rept 70-820/78-21 on 780912-15 During Which Items of Noncompliance Were Noted in the Following Areas:Failure to Adopt,Approve & Implement Containment Control Procedure & Failure to Post 3 Locations W/Nuc Safety Signs

ML20148A158
Person / Time
Site:	07000820
Issue date:	10/10/1978
From:	Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20148A121	List: ML20148A117 ML20148A133 ML20148A138 ML20148A144 ML20148A151 ML20148A158
References
70-0820-78-21, 70-820-78-21, NUDOCS 7812280250
Download: ML20148A158 (14)

Text

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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-820/78-21 Docket No.70-820 _

License No. SNM-777 Priority 1 Category UR Licensee: United Nuclear Corporation Wood River Junction, Rhode Island 02894 Facility Name: Fuel Recovery Operation Inspection at: Wood River Junction, Rhode Island Inspection conducted: September 12-15, 1978 l Inspectors: , d2 /0[/r[7 V J. th, Project Inspector 'date sfigned date signed date rigned Approved by -s H. W. CFocker, Ch1 W Fuel Facility

/_8/f>/7[

/ dat6 s'igned Project Section, FF&MS Branch l Inspection Summary:

Inspection on September 12-15,1978 (Report No. 70-820/78-21)

Areas Inspected: Routine, unannounced inspection by a regional based inspector of criticality and engineered systems including: scope of operations; organ-ization; facility changes and modifications; 10 CFR Part 21; internal review and audit; safety committees; training; review of operations; nuclear criticality safety; packaging and shipping of radioactive material; nonroutine events; and, licensee action on previously identified enforcement items. The inspection was initiated during off-shif t on September 12, 1978, and involved 24 inspector-hours onsite by one NRC regional based inspector.

Results: Of the 12 areas inspe.cted, no items of noncompliance were identified in 9 areas; 3 appTrent items of noncompliance were identified in three areas (In-fraction - two instances of inadequate or failure to follow contamination control procedures (78-21-02)(paragraphs 4,6 and 13.c); (Infraction - failure to adopt, approve and implement procedures required by 10 CFR 21.21(a)(78-21-05)(para-graph 14.a); and, (Deficiency - failure to post 3 locations with nuclear safety signs and identify 2 process containers as being empty (78-21-01)(paragraph 4.c)).

Region I Form 12 (Rev. April 77) 781228045d __ __

DETAILS

1. Persons Contacted

• C. E. Bowers, General Manager, Fuel Recovery Operations

• D. F. Cronin, Manager, Nuclear Industrial Safety

• D. M. Schultz, Manager, Compliance

• R. J. Gregg, Manager, Quality Assurance J. Murphy, Shift Supervisor J. Wake #id, Manager, Operations J. F. t ,, Shift Supervisor The .r also interviewed 9 other licensee employees during th .e of the inspection.

. totes those present at the exit interview.

2. Scope of Operations The licensee continues to engage primarily in the recovery of uranium from unirradiated scrap by means of solvent extraction methods. These operations are expected to continue at current levels.

3. Licensee Action on Previously Identified Enforcement Items (0 pen) Infraction (820/78-06-01): Three instances of failure to follow standard operating procedures: (1) Operating reports not accurately completed. The licensee completed a review of all opera-ting reports for need, applicability and redundancy of information by May 15, 1978. The dissolver operating report had been revised

and released for duplication during the first week of September,1978.

The use of the new form will commence upon depletion of supplies of the old report forms. Revision of additional operating report forms is expected to be completed by January 1, 1979; (2) Itnproper storage of 5 shipping containers. The inspector verified that supervision and operating personnel had been reinstructed and that Standard Opera-l ting Procedures (SOP) III-A governing material receipt and storage I had been revised to clarify incoming inspection requirements for SNM.

However, this revised 50P had not been approved and issued for use by operating personnel. Discussions with licensee representatives in-dicated that the revised SOP, which should have been issued by June 15, 1978, will be issued by October 1,1978. The delay in approval and reissue was caused by an increase in high priority workload within the facility; and, (3) Failure to conduct container inspection prior to shipping. The inspector verified that the required corrective actions had been completed during inspection 70-820/78-13.

3 (0 pen) Infraction (820/78-13-01): Four instances of failure to follow Standard Operating Procedures. (1) Open unsafe geometry containers located in the processing area and left unattended.

The inspector verified that all unsafe geometry containers located in the processing area were either covered or attended, as required during the course of this inspection. The inspector also verified that a training session was conducted to retrain all shop super-visors and operators in the procedural requirements concerning un-safe geomtry container. (2) Quality Assurance review of SOPS for currency and availability of SOPS to operators in the shift supervisor's 50P Manual. The inspector verified that a review of all SOPS was con-ducted by Quality Assurance personnel. This review was completed on June 30, 1978. However, the internal memo documenting this review did not indicate the results of the review, (i.e. which SOPS were reviewed and based on this review, which S0Ps required updating).

Discussions held with licensee representatives indicated that this information will be generated by October 15, 1978. The inspector did not examine the shif t supervisor's 50P Manual for availability of SOPS.

This aspect will be examined during a subsequent inspection. (3) Im-proper completion of SWPs. The inspector examined 9 SWPs and 27 generic SWPs issued since the last inspection (70-820/78-13) and determired that these SWPs had been properly authorized and/or completed. The inspector also determined that a training session was held for all maintenance personnel to reinstruct these employees in the proper completion of SWPs. (4) Failure to follow special instructions on an SWP. Review of issued SWPs by the inspector indicated that none contained special control measures to be taken. However, through dis-cussions with licensee representatives, it was determined that a pro-cedure has been established to record the actual control measures fol-lowed when these control measures differ from the restrictions specified in the SWP.

(Closed) Deficiency (820/78-13-03): Failure to properly label empty shipping containers. The inspector verified that all empty shipping containers or groups of shipping containers were properly labeled with empty signs as required by license conditions. Corrective actions on this item have been completed.

(Closed) Infraction (820/78-13-05): Failure to maintain continual training of operating personnel in required subjects. The inspector verified that the licensee has reinstituted the training schedule established during January,1977. This schedule requires that the topics of health physics and criticality safety will be covered during monthly safety meetings at least once each quarter. During the month

4 of August, 1978, specialists in the areas of health physics and nuclear criticality safety conducted training sessions on each of the operating shifts in the required subjects. The licensee has also established a system for providing information to shop super-vision for the monthly training sessions. A brief discussion outline sheet will be issued to the supervisors at least once each quarter in each of the subjects by the NIS group. A written report of the safety meeting must be afven to 'the NIS Manager by the t aginning

• of the week following the meeting and NIS will assure that a meeting was held for each operating group each month and that the required subjects are covered at least once each quarter. Corrective actions have been completed on this item of noncompliance.

4. Off-Shift:00erations Review

a. The inspector initiated this inspection with an unannounced off-shift examination of the facility at 11:45 p.m. on the evening of September 12, 1978. DJring this examination, the inspector observed operations and activities in-progress in the production area.

b. The inspector noted that two muffle boxes, used for SNM, one located on a tranfer cart located just north of the muffle box storage rack and one located on a transfer cart about 9 feet south of the 2-L-2 hood, were not marked as empty, nor was information readily available to allow identification of their contents. fliscussion with the shift supervisor indicated that these muffle boxes were empty and should have been marked as such. The shift supervisor immediately identi-fied these containers as being empty. The 4.nspector indicated that failure to mark or identify these containers as being empty was part of an item of noncompliance (78-21-01).

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c. The inspector observed that signs listing approved nuclear criti-cality safety limits were not posted on the muffle box storage rack, the 1-L-3B hood and the 4-L-2A hood. The inspector identified the lack of nuclear criticality safety signs at these locations as part of an item of noncompliance (78-21-01).

d. The inspector noted that an empty transfer cart was stored in the aisle between the shipping container cage and the product storage vault-type room. The NIS authcrization of this area, stated that storage of carts in this aisle was not authorized. However, since there was no SNM stored on the transfer cart, no question of safety was involved. A licensee representative immediately removed the empty transfer cart and moved it to an authorized parking location.

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e. The inspector observed an operator working in the 4-F-2 filter hood. It was noted that the operator was wearing the protective safety equipment, including gloves, as required by the Standard Operating Procedure for this operation. However, as the operator removed his gloved hands from the hood, he turned around to observe meters, which were positioned behind him. As he turned back toward the hood, particulate matter adhering to the gloves fell off the gloves onto the floor infront of and under the hood. Since no rurvey meters were inmediately available, on the next morning, September 13, 1978, the inspector returned to this location with a licensee representative who surveyed the area in question with a PAC 4-S alpha counter. Direct survey contamination levels as high as 20,000 cpm were found on the floor infront of the 4-F-2 filter hood. The action level for this location identified in SOP-I-H, Revision New, dated August 7,1976, " Contamination Control" was determined to be 10,000 cpm on a direct survey. The inspector examined the following operating procedures to determine if procedures for the handling and use of contaminated gloves had been established by the licensee:

(1) SOP-I-H, Revision New, dated August 7, 1976, " Contamination Control" (2) SOP-V-E, Revision New, issued May 1,1976, "4-J-l Series Tray Dissolvers" (3) SOP-I-F, Revision II, dated August 7,1976, " Health Physics" (4) SOP-I-B, Revision New, dated August 7,1976, " Personnel Protective Equipment" (5) SOP-I-D, Revision IV, dated August 7, 1976, " Safety Precautions" In each procedure examined, proper safety equipment, including gloves, was identified, however, in no case were handling pro-cedures for contaminated gloves established. Failure to establish handling procedures for contaminated gloves to prevent the spread of contamination in the processing area was identified as an item cf noncompliance (78-21-02).

5. Operations Review The inspector examined all areas of the plant to observe operations and activities in-progress; to inspect the nuclear safety aspects of the plant; and, to check the general state of cleanliness, housekeeping and adherence to fire protection rules.

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a. During inspection 70-820/78-13, the inspector observed that an alpha survey meter, located at the Post B entrance to the storage warehouse / shipping-receiving area was positioned in a relatively inaccessible location between two personnel locker cabinets approximately 4 to 6 feet away from the entrance doorway. During this inspection, 70-820/78-21, the inspector noted that the alpha survey meter had been moved from between the two personnel locker cabinets, to an ac-cessible location approximately 6-8 feet away from the entrance doorway. The inspector questioned the value of a contamination survey instrument which was located 6-8 feet away from the location where it should be used to control contamination prior to entry into an uncontaminated area. Licensee representatives indicated that this area was still undergoing evaluation. Ac-cording to licensee representatives, this meter when located at the proper operating position, could be affected by tempera-ture and humidity fluctuations. The licensee is evaluating techniques for protecting the meter when it is properly located (78-21-03).

b. The inspector noted that housekeeping was generally good in the facility, and that, the mercury which was being stored on the floor of the fan-loft-mezzanine, under the main plant ventilation system had been placed into a metal storage cabinet.

c. The inspector examined the storage warehouse and noted that the entire floor surface had been sealed with an epoxy-type paint to preclude potential contamination of the floor surface in the event that drums stored in the area should leak.

d. The inspector noted that the plastic 3-D-17 " Slop Tank" had cracks in the sides at the top. Drops of solution were running down the sides of the tank. These drops of solution appeared to have originated from the observed cracks in the tank wall.

However, there was no solution collected on the floor beneath the tanks at the time this observation was made even though the tank was being used at the time. The inspector nctified the cognizant shift supervisor who immediately ceased aperations in this tank and arrangements were being made to correct this problem as the inspector left the processing area. This item was discussed at the exit interview and corrective actions will be reviewed during a subsequent inspection.

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6. Organization The inspector determined that Mr. W. Pawlyk, Assistant to the General Manager, and Mr. A. Covey, Specialist, Chemical Products Sales, had resigned from the facility staff during July,1978. From discussions held with licensee representatives, it was determined that the position of Assistant to the General Manager, has been eliminated from the facility organization.

7. Nuclear Criticality Safety

a. Inspection of Vessels Equipped with Raschig Rings The inspector examined records of monthly inspections conducted on raschig ring levels in 10 waste tanks (1-D-5,1-D-21 A,1-0-21B, 1-D-24A,1-D-248,1-0-41, 3-D-17, HP Vac Tank, A-5 and 1-X-23) for the months of May,1978 t:' rough August,1978. It was noted that 3 additional tanks (Kenics tank 1, Kenics tank 2 and Kenics tank

3) were added to the inspection report form starting in June, 1978. The records indicated that the raschig ring levels in these tanks were maintained at or above the " control levels" specified on the inspection form. Corrective actions, if required, were adequately documented.

I Licensee records indicated that 5 of these tanks (1-D-21A, 1-D-21B,

' D-24A,1-D-24B and 3-D-17) were calibrated for volume on August 2-3, 1978.

Licensee records also indicated that raschig rings from 10 original rashig ring filled tanks were removed in order to perform chemical analysis for boron content of the used rings. As of the date of this inspection, the licensee had not received the results of these i

chemical analyses. This aspect will be examined further during a subsequent inspection.

b. Criticality Monitors The criticality monitors located throughout the facility were examined by the inspector. All monitors were set to alarm at a inaximum of 20 mr/hr and appeared to be operating properly.

All criticality monitors were recalibrated on a quarterly cycle on May 30-31,1978, and August 31, 1978, as required. A cobalt-60 source was used for the calibration and licensee records indicated that adjustments were made to the criticality monitors as needed.

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8. Facility Changes and Modifications NIS Authorizations are used by the licensee to control changes in equipment, facilities, or operating procedures, which could affect safe operation of the facility with respect to nuclear safety.

NIS Authorizations R0-282 through 287, which cover changes that occurred or are about to occur in the facility or operations within the facility, were examined by the inspector. All six of the authorizations reviewed were approved and the final installation ac-cepted for operation. All approved and accepted authorizations were given a dual review, if required, were accepted by NIS and were ap-proved by the Manager, NIS, Manager, Operations, Manager, Quality Assurance and the C-eneral Manager. In each case, review of supporting documents by the inspector indicated that the licensee appeared to utilize adequate evaluation techniques.

There were no facility changes covered by NIS Authorizations. Equipment changes reviewed, included temporary modifications of nuclear safety limits for the 2-L-5 hood, modification of the new extraction system to include raschig ring filled tanks and modified use of the 3-L-6 hood.

9. Internal R eview and Audit

a. The inspector questioned licensee representatives regarding the conduct of internal reviews and audits during the time period May 30,1978 through September 9, 1978. The inspector reviewed the reports of 17 NIS internal audits and inspections, which were conducted during this time period. These inspections and audits covered the nuclear safety and radiological safety aspects of the facilities and operations, industrial safety and housekeeping practices. Inspections were conducted during regular and off-shif t operation. The inspector verified that corrective actions had been takon or initiated on each item identified by the licensee.

b. The licensee's evaluation and reply to the annual audit of the

nuclear and radiological safety aspects of the facility was ex-I amined by the inspector. This audit was conducted during the months of February and March,1978, by a consultant from out-side the Division. The evaluation and reply letter, dated May 1, 1978, examined each item covered by the annual audit and either stated what corrective actions had been or would be taken or ex-plained why corrective action was not needed. In each case, the inspector verified that corrective action had been initiated or completed prior to this inspection.

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10. Safety Committees The licensee conducts a senior staff audit for safety periodically during the calendar year. The staff involved with these audits comprises the membership of an informal safety committee. The most recent audit of the processing area was conducted on September 14, 1978, during the course of this inspection. The results of this audit will be examined during a subsequent inspection of this facility.

11. Nonroutine Events The inspector determined through discussions with licensee representatives and review of licensee reports and records that no nonroutine reportable events occurred at this facility since the last inspection (70-820/78-13). However, it was determined that a nonrcutine nonreportable event did occur on the afternoon of September 12, 1978, just prior to the start of this inspection. At about 5:00 p.m., on the afternoon cf September 12, 1978, during a thunderstorm, a flash of lightning struck the ground adjacent to the licensee's site. The electrical charge in the area set off all security, non-nuclear and nuclear alarms in the facility. The facility was evacuated, all alarms were silenced and reset, and, it was determined that no damage was done to the facility or equipment, then the facility was re-entered, secured and operations were resumed.

Discussions with licensee representatives indicated that this occurrence was being evaluated to determine what steps can be taken to preclude setting off of all alarms under similar circumstances in the future. The progress of this evaluation will be followed by the inspector (78-21-04).

12. Training

a. The licensee has established a formal personnel orientation and training program. All new employees are required to be indoctrinated in the safety aspects of the facility. This indoctrination shall be conducted by the Manager, NIS, or his designated representative. Topics included are: fundamentals of nuclear criticality safety and controls, fundamentals of health physics and controls, emergency alarms and actions required, and a review of safety controls in facility operation.

The inspector determined through discussions with licensee representatives that the safety training of licensee employees is conducted by the Manager, NIS, or the facility Health Physics Specialist. To date, training of contract guards is conducted by the Manager, NIS, the facility Health Physics Specialist or

10 one of the facility Security Supervisors under the direction of the Manager, NIS, or the Health Physics Specialist. Upon com-pletion of current indoctrination sessions, the designated Security Supervisor will conduct orientation training for contract guards with the Manager, NIS, or the Health Physics Specialist available to field questions which the Security Supervisor has not been trained to answer.

b. Licensee training records for the time period February 15, 1978 through June 19,1978 included:

(1) New hire orientation lectures were given to 8 new employees and four classes cf contract guards (approximately 50 guards).

The results of these lectures were monitorec by quizzes given which covered the topics given.

(2) Female employees (3) were given training in 10 CFR 19.12 and Radiation Effects.

(3) Training sessions were held for the facility operators on June 12 and 15 during which the upcoming evacuation drills were discussed.

(4) Training sessions were conducted for facility operators on August 21 and 28, during which nuclear criticality safety was discussed and the results of this discussion was monitored by means of quizzes given to each attendee.

Satisfactory quiz grades in excess of 80% were obtained by all individuals.

c. Records of safety mea'ings were reviewed by the inspector. Safety meetings are to be conducted on a regularly scheduled monthly basis by line supervision and/or specialists in the subjects dis-cussed. Licensee records for May,1978 through August,1978, indicate that the required number of meetings were held each month except for the month of July,1978, all affected personnel attended and the topics discussed at each meeting were documented.

Topics discussed during this time period included, nuclear criti-cality safety, evacuation procedures, SWPs, acid handling and house-keeping practices. As stated previously in paragraph 3, the training schedule for continuing training established in January, 1977, appears to have been reinstituted. Discussion with licensee representatives indicated that safety meetings were not held during the month of July,1978, since these meetings were normally held during the last week of the month and the facility was shutdown from July 24, 1978 through August 14, 1978.

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d. The inspector determined through discussions with licensee representatives and review of licensee records that retraining of facility personnel was scheduled to start during the month of October,1978. It was also determined that the annual security training for contract guards includes emergency training and contamination control, but does not include nuclear criticality safety, fire control and/or the relationship between these subjects. This item was discussed at the exit interview.

13. Packaging, Shipping and Receiving of Radioactive Materials I

a. Licensee records relating to the shipping and receiving of radioactive materials for the time period January 1,1978 '

through June 29, 1978, were examined by the inspector. These records documented results of radiation surveys, container inspection results, labeling, marking and placarding of ve-hicles and/or containers which were required by license condi-tions, federal regulations or internal procedures.

b. The inspector noted that the container inspection forms for 19 of 45 shipments examined had incorrect information recorded relative to Fissile Class. This information had been trans-scribed incorrectly from the official shipping documents (i.e.

Factory Shipping Order, FS0) to the container inspection forms. Many of the container inspection forms also had the incorrect transport aroup recorded. The inspector determined that the official shipping documents contained the correct Fissile Class and transport group information and that the proper labels had been placed in the shipping containers. A licensee representative immediately corrected the information recorded on the container inspection forms and indicated that the persons respons'ble would be retrained in properly completing the forms. The fact that the information recorded on container inspection forms had been corrected was verified by the inspector.

This item was discussed at the exit interview.

c. The inspector examined the following procedures related to ,

shipping and receiving:

(1) SOP III-A, Revision V, dated October 19, 1976, " Receiving SNM" (2) S0P III-C, Revision I, issued May 1, 1976, " Procedures '

for Packaging Product Containers and Outgoing SNM Shipment"

12 S0P III-A, under " Procedures" in paragraph 3, states that, "the transporting vehicle shall be cleared by NIS before leaving the plant site."

S0P III-C, under "NIS Requirements" in paragraph 3, states that, "all vehicles transporting SNM shall be cleared by NIS before release from the plant site," and under " Procedures" paragraph 8, states, " prior to departure from the plant site, the trans-porting vehicle will be monitored by the NIS Department or their authorized representative for radiation and contamination levels."

Through discussions with licensee representatives, and examination of licensee records, the inspector determined that for SNM ship-ments or receipts between January 1,1978 and June 29,1978, only the SST and Tri-State vehicles were monitored for radiation and contamination levels or cleared by NIS before leaving the plant site. This accounted for only about 7 of 45 SNM shipments and 4 of 41 SNM receipt vehicles. Failure to monitor vehicles in 38 of 45 SNM shipments for radiation and contaminatior. levels prior to departure from the plant site and failure of NIS to

" clear" transporting vehicles in 37 of 41 SNM receipts before leaving the plant site was identified as part of an item of non-l compliance (78-21-02).

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14. 10 CFR 21 Procedures l

l a. Through discussions with licensee representatives, the inspector determined that, as of the last day of this inspection, September 15, 1978, the licensee had written but had not approved, issued, im-plemented or adopted procedures required by 10 CFR 21.21(a). These procedures were to be adopted as of the effective date of this regulation, January 6,1978. Failure to approve, issue, implement or adopt the procedures required by 10 CFR 21.21(a) was identified as a part of an item of noncompliance (78-21-05).

b. 10 CFR 21.31, " Procurement Documents" requires each facility to assure that each procurement document for a facility or a basic I

component issued after January 6, 1978, specified, when applicable, that the provisions of 10 CFR Part 21 apply. The inspector ex-amined procurement documents including the specified " terms and conditions" for air filters purchased by the licensee since January 6,1978. The procurement documents included the following:

(1) Purchase Order NPD 47140, dated March 9,1978 (2) Purchase Order NPD 47198, dated March 22, 1978 (3) Purchase Order FR0 10096, dated May 9,1978

13 (4) Purchase Order FP0 10280, dated July 12, 1978 Prior to about April,1978, all purchase orders for the Fuel Recovery Operation plant were handled and issued by the Naval Products Division purchasing organization.

The inspector noted that none of the indicated procurement documents for air filters issued since January 6,1978, con-tained the statement that the provisions of 10 CFR Part 21 apply. Licensee representatives stated that the required statement would be incorporated into procurement documents upon implementation of the 10 CFR 21.21(a) procedures.

15. Operations Log The inspector examined the operations log located in the shift super-visor's office for the period June 15, 1978 through September 12, 1978.

Entries were made in the log for each operating day except for the plant shutdown period July 28, 1978 through August 14, 1978. The entries consisted of instructions to shifts, logging of shift experi-ences, actions taken regarding shift operating problems and questions concerning procedural, policy or operational problems.

16. Exit I nterview The inspector met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection at 11:00 a.m. on September 15, 1978. The inspector summarized the scope and findings of the inspection. The licensee representatives made the following remarks in response to certain items discussed by the inspector.

-- stated that procedures would be established te assure that all nuclear criticality signs were in place (paragraphs 4.b and 4.c)

-- stated that the operating technique which currently involves removal of contaminated gloves from hoods would be reviewed and revised, as appropriate, to preclude the spread of contamination (para-graph 4.d)

-- stated that the forms used to document contamination surveys of shipping containers had been revised to require and document vehicle contamination surveys (paragraph 13.c)

-- stated that the procedures required by 10 CFR 21.21(a) would be approved, adopted and implemented as soon as possible and that the statement required by 10 CFR 21.31 would be added to procure-ment documents (paragraph 14)

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-- stated that the container inspection forms which contained incorrect information transcribed from other documents had been corrected (paragraph 13,b)

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