ML20151E702

Insp Repts 70-1100/88-05 & 70-1100/88-06 on 880525-27. Violations Noted:Failure to Follow Radiation Work Permit & Failure to Measure U & U-235 on Waste Discards.Major Areas Inspected:Transporation of Radioactive Matls

ML20151E702
Person / Time
Site:	07001100
Issue date:	07/09/1988
From:	Bellamy R, Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151E684	List: ML20151E683 ML20151E702 ML20151E705
References
70-1100-88-05, 70-1100-88-06, 70-1100-88-5, 70-1100-88-6, NUDOCS 8807260176
Download: ML20151E702 (6)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report Nos. 70-1100/88-05 Docket No. 70-1100 License No. SNM-1067 Priority 1 Cateac ry ULFF l

Licensee: Combustion Engineering, Incorporated l 1000 Prospect Hill Road i Windsor, Connecticut 06095 Facility Name: Ny lear Fuel Manufacturing and Nuclear Laboratories i Inspection At: Windsor, Conc.ecticut l l

Inspection Conducted: May 25-27, 1988 Inspectors: M J. Roth, Project EngineeV, Effluents Radiation \\ CDat6'

[b ,ku M .1(d b Protection Section, DRSS l

Accompanied by:

_R.

[ ktf_Ch R. Bellamy, Chief, FacilXties Radiological gy ate M

Safe and Safeguards Branch, DRSS Approved by: -

W. J. Vasciak, Chief, Effluents Radiation La hklgate'

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@M Protection Section, DRSS Inspection Summary: Inspection on May 25-27, 1988 Inspection Report No.

70-1100/88-05 Areas Inspected: Routine, unannounced inspection by a region-based inspector of the licensed program relative to the transportation of radioactive materials.

Results: Six apparent violations of NRC requirements were identified. The apparent violations include: failure to follow the requirements of a Radiation Work Permit (paragraph 2b); failure to post all of the documents required by 10 CFR 19.11 at sufficient locations in Building 5 (paragraph 2c); failure to label waste containers in accordance with 49 CFR 172.403; failure to provide the appropriate information specified by 10 CFR 20.311(b) on the waste manifest form (paragraph 3c(2); failure to measure uranium and U-235 on all waste discards as required by the Fundamental Nuclear Material Control Plan (FNMCP)

Section 4.2.1 (paragraph 4); U-235 measurements were not within the calibrated range for absolute filters as required by the FNMCP Annex Section 4.1.3 (paragraph 4).

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Details 1

Persons ~ Contact _ed

• P. L. McGill, Vice President, Nuclear Fuel

• A. E. Scherer, Director, Nuclear Licensing

• F. Stern, Vice President, Nuclear Fuel Manufacturing

• G. H. Chalder, Plant' Manager, Nuclear Fuel Manufacturing-Windsor

• M. M. Glotzer, Manager, Quality Control

• R. Sheeran, Manager, Nuclear Licensing, Safety, Accountability and Security

• P. R. Rosenthal, Manager, Raaiological Protection Services

• L. Philpot, Nuclear Licensing Engineer R. J. Klotz, Principal Consulting' Scientist D. Parks, Manager, Nuclear Materials

• Denotes those present at the exit interview. The inspector also interviewed other licensee employees during the inspection.

2. Review of Operations The inspector examined selected areas of the plant and the nuclear laboratories to observe operations and activities in progress, to inspect the nuclear safety aspects of the facilities and to examine the general state of cleanliness, housekeeping, and adherence to fire protection rules,

a. Container Labeling

" During examination of the uranium-235 nondestructive assay device located in the pellet' shop annex, the inspector found one calibration drum containing filter' media, that was laoeled with empty, Radioactive Waste and Caution-Radioactive Materials signs. During discussions with licensee representatives, the inspector pointed out that if the drum did not contain radioactive materials, it should be marked empty. However, if the drum contained radioactive materials, the empty sign was not appropriate. The licensee representatives stated that the drum contained contaminated material and was being used as a "zero" uranium-235 standard. As a result of these discussions, the licensee removed the empty sign, retained the other

- signs and marked the drum as containing "zero" grams of uranium-235.

b. Radiation Work Permits During a tour of the Pellet Shop, the inspector. observed two individuals handling potentially contaminated parts that had been removed from the contaminated ventilation duct connected to Press No.

4. Handling of those potentially contaminated parts was being accomplished without protective gloves which was in violation

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cf the Radiation Work Permit issued for the work. This was identified as an apparent violation of Section 3.1.1 of the

-NRC-approved license application. (1100/88-05-01)

c. 10 CFR 19.11 Posting Requirements During examination of the Nuclear Laboratory facilities in Building 5, the inspector noted that the documents specified in 10 CFR 19.11(a) or the notice specifild in 10 CFR 19.11(b) were not conspicuously posted in a sufficient number of places to permit individuais engaged in licensed activities to observe them on the way to or from the licensed activity location as required by 10 CFR 19.11(d). The notice specified in-10 CFR 19.11(b) was posted at the main (east) entrance to the building but was not posted at the north or south entrances.

The documents required by 10 CFR 19.11a(4) were not posted anywhere in Builling 5. This was identified as an apparent violation of 10 CFR 19.11(d). (1100/88-05-02)

3. Transportation Activities

a. Packages Used The licensee routinely ships radioactive materials in Model 17H, B-25, UNC-2901, CE250-2, 927Al and 927A2 containers. The Model UNC-2901, CE250-2. 327Al and 927A2 containers are certificate of s compliance packages. The inspector determined that the licensee was a registered user of these packages and maintained copies of the documents and the Quality Assurance Program required by 10 CFR 71.12.

The use of 00T Specification containers is discussed further in para-graph 3.c(2) of this inspecticn report.

b. SN'M Receipts l The inspector examined record; of radiation and contamination surveys l conducted on incoming packages of radioactive materials between January 21, 1988 and May 18, 1988. These surveys are required by 10

, CFR 20.205(b)(1). It was determined that all incoming UNC-2901 packages were properly surveyed, however, only the tops and about 50%

of the sides of each CE 250-2 containers were surveyed upon receipt.

l Through discussions with licensee representatives, the inspector l determined that the remaining 50% and the bottom of each container, l were not surveyed until after the container was emptied, c. filled, if necessary, and was being replaced on the transportin vehicle for j return to the shipper.

During a review of the contamination survsy results for recent receipts, the inspector observed that there appeared to be a trend toward increased contamination on the surface of the containers received from the Combustion Engineering, Hematite, Missouri l

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4 facility. This may account for the increasing levels of

l. contamination observed in the CE 250-2 container storage area located adjacent to the north wall of the Pellet Shop. Licensee records indicated.

that contamination on the surface of the containers was as high as 2

about 550 dpm alpha-per 100 cm upon receipt and that the storage area was periodically contaminated up to 1000 dpm alpha per:100 cm.

The licensee is required to, and does maintain this container storage area as a clean area (less than 100 dpm alpha per 100 cm ). However, according

, to licensee representatives because of the increased contamination found on the incoming shipping containers, it is becoming more difficult for the licensee to maintain this storage area as a "clean" area. As a result of the foregoing observations, the inspector suggested that the licensee re-examine the established incoming shipping container contamination survey procedures. Licensee representatives stated that the contamination survey procedures would be re-examined and modified, if necessary.

During examination of the receipt records, the inspector could not determine if the receipt surveys were conducted within three hours or 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> of receipt as required by 10 CFR 20,205. However, it was noted that the records indicated that the surveys were conducted on the day of receipt. The inspector suggested that the licensee consider maintaining receipt records that will include the time the transport vehicle arrived at the site and the time that the receipt survey was initiated.

c. Shipments

1. Fuel Shipments 2 The inspector examined shipping records for the shipment of fuel assemblies and scrap pellets to various facilities for the time period January 4, 1988 through February 3, 1988. The examination included a review of container radiation and ton-tamination survey reports, bills of lading, exclusive use driver instructions, state DOT permits and packaging procedures. All of the documentation and records required by 10 CFR 71 and the U.S. DOT regulations were available. However, the inspector suggested that the licensee include the otal U-235 weight for the shipment in addition to the total nt :ber of curies and the total Transport Index for the shipment, in order to provide adequate information to the carrier concerring the shipment. In addition, the inspector suggested that th< d iver's exclusive use instructions be modified to include iistructions not to shift the load without first contacting Combustion Engineering Incorporated for permission and to include a statement that the vehicle has been properly placarded. The driver should then be required to sign the instructions to verify receipt. This was discussed at the exit interview. Licensee representatives stated that the suggested modifications would be evaluated and adopted if found to be appropriate.

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2. Waste Shipments The inspector examined shipping records for the shipment of radioattive waste contaminated with uranium to approved burial i

sites between June 4, 1987 and May 3, 1988. The examination

! included a review of container radiation and contamination j survey reports, bills of lading, exclusive use driver i instructions, r. tate DOT permits, packaging procedures, shipping procedures and waste manifest forms.

The following discrepancies were identified during this review:

Any waste package containing special nuclear material in excess of 15 grams or a package in which the concentration exceeds 5 grams SNM for any 10 liter volume does not meet the fissile exempt criteria specified in 10 CFR 71.53. In the latter case, the packaging must also assure these concentration limits are maintained during transport. The inspector determined that in order to meet the 5 grams per 10 liter criterion, each 12 inr 5 by 24 inch by 24 inch absolute filter box cannot contain more than 56.5 grams of U-235. The in2pector determined that for the June 4,1987 shipment, absolute filters in B-25 Box No. 1103 contained 68 grams of U-235, for the November 2, 1987 shipment, absolute filters in B-25 boxes 1107, 1109 and 1110 contained U-235 ranging from 56.9 to 130.5 grams of U-235. Each of the boxes indicated above was labeled with Low Specific Activity (LSA) signs which were not appropriate. The proper shipping name and hazard class on the waste manifest form was not properly identified. (The boxes identified above were marked Radioactive Materials LSA Nos. UN2912 instead of Radioactive Material Fissile Nos. UN2918.) As a result, the boxes were not properly labeled with Yellow III labels. The B-25 boxes used were strong tight containers and were not approved for fissile shipments by the NRC in accordance with 10 CFR 71.3. Since the licensee failed to demonstrate compliance with the low level radioactive material exemption criteria specified in 10 CFR 71.10 the following violations were identified. Failure to properly label waste containers in accordance with 49 CFR 172.403 was identified as an apparent violation (1100/88-05-03). Failure to provide the appropriate information concerning the proper shipping name and hazard class on the waste manifest form wa2 identified as an apparent violation of 10 CFR 20.311(b). (1100/08-05-04)

4. Non-Destructive Assay Measurements During examination of Radioactive Waste Drum Release Data sheets, the inspector noted that several entries covering the grams U, pounds V, grams U-235 and millicuries radioactive, were designated NDA. The type of material involved with this designation included but was not limited to L. . _ _ _ _ - . - - - - -

6 shop trash, wood, gloves', plastic pipe, cardboard, brick, tile. -

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rubberhose, ventilation tubing, wire, plastic, chairs, sheetmetal, (

zirconium tubing, stainless steel springs and graphite crucibles. The radiation level on the containers ranged from 0.01 to 0.4 millirem / hour thereby in many cases, indicating the presence of radioactive material in the containers. Through discussions with licensee representatives, the t inspector detennined that the term "NDA" stood for "no setectable amount" b which implied that some type of measurement was made to determine the quantity of U-235 present. Upon questioning of licensee representatives, the inspector determined that no measurement of the U-235 content was made on any of those materials with the exception of "shop trash." The 4 facility Fundamental Nuclear Material Control Plan (FNMCP) in Section 4.2.1 states that a measurement system has been established and will be maintained for all SNM receipts, removals and inventory item, and all quantities of SNM in the material accounting records will ee based on measured values. It further states that a system of 'easurement has been established at Combustion Engineering for use in thr control of and accounting for SNM. Measurements of U and U-235 a e taken at appropriate points on proper categories of all nuclear material receipts, shipments, waste discards and material inventories, and all external transfers of SNM shall be based on measurements. The FNMCP dcfines low-level contaminated waste in Table 1.4.1 as shop trash and filters. According to licensee personnel (interviewed by the inspector) "Shop Trash" is defined as compactible trash which does not include non-compactible materius such as Failure to

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springs, tubing, bricks, ventilation system ductwork, etc.

measure uranium and U-235 on all waste discards was identified as an apparent violation of Section 4.2.1 of the NRC-approved FEMCP. *

(1100/88-05-05)

During examir.ation of Table 1.4.1 of the NRC-apprevd FNMCP, the inspector noted that the standards used for the calibration of the Nondestructive Assay device for the determination of U-235 content of ab- te filters ranged from 0 to 90 grams of U-235. Data on several of :adioactive 35 content of Waste Drum Release Data Sheets indicated that the uran' several filters was 101.6 grams (B-25 box No.1107, dated August 3,1987),

115.5 grams (B-25 box No.1110, dated August 26,1987) and 130.5 grams (B-25 box No. 1109 dated August 21,1987). Those values were outside the range of the standards specified in the FNMCP. Section 4.1.3 of the NRC-approved FNMCP Annex states that should results indicate the process material to be outside the calibrated range, the results will not be used.

Contrary to that statement, the results above indicated that measured amounts were outside the calibrated ranges of standards that were used to designate the U-235 content of the filter 3 shipped to burial on November 2, 1987.

This was identified as an apparent violation of the FNMCP Annex Paragraph 4.1.3.(1100/88-05-06) , ,,

5. Exit Interview The inspector met with the licensee representatives (denoted in Paragraph

1) at the conclusion of the inspection on May 26, 1988. The inspector sunnarized t e scope and findings of the inspection.