ML20151S299
| ML20151S299 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 04/21/1988 |
| From: | France G, Greger L, Paul R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151S265 | List: |
| References | |
| 70-0036-88-01, 70-36-88-1, NUDOCS 8804280274 | |
| Download: ML20151S299 (12) | |
Text
7 U.S. NUCLEAR REGULATORY C0FNISSION REGION III Report No. 70-36/88001(DRSS)
License No. SNM-33 Docket No. 70-36 i
4 Licensee:
Combustion Engineering, Inc.
Nuclear Power Systems Windsor, CT 06095 Facility Name:
Hematite Inspection At:
Hematite, Missouri Inspection Conducted:
February 16-19, and April 13-15, 1988
['#/~~ M Inspectors:
G. M.
- rance, Date
$-sL/~ 88 Date f
Approved By:
L. R. Greger, Chiet
'pf-gg Facilities Radiation Date 3
Protection Section
)
Inspection Summary Inspection on February 16-19, and April 13-15, 1988
{ReportNo. 70-36/88001(DRSS))
Areas Inspected:
Routine, unannounced safety inspection including organization and management controls (IP-88005), allegations (IP-92705),
radiation protection (IP 83822), criticality safety (IP-ES015),
maintenance and surveillance (IP-88025), transportation (IP-86740),
and waste generator requirements (IP 84850).
An allegation, reported by an OSHA representative, addressed a worker's (non-licensee) concern of receiving radiation exposure from reworking uranium oxide pellet punches.
Results:
No violations or deviations were identified. However, several concerns related to radioactive sources used for calibration of survey instruments, whole body data MPC values, and HP technician training were identified, l.
4 8804280274 880421
~
i PDR ADOCK 07000036 l
C DCD
DETAILS 1.
Persons Contacted
- L. Deul, Manufacturing Engineer
- H. Eskridge, Nuclear Licensing, Safety and Accountability Supervisor
- R. Fromm, Quality. Assurance Manager
- R. Griscom, Engineering Supervisor
- R. Miller, Manager, Administration and Production Control
- A. Noack, Plant Superintendent
- J. Rode, Plant Manager
- Denotes those present at the exit meeting.
The inspectors conducted interviews / discussions with the Quality Control Laboratory Supervisor, Quality Assurance Engineer, Shift Foreman, Maintenance Supervisor, Health Physics Technician, and the Shipping and Receiving Foreman.
2.
General This ins.oection was conducted to examine licensee actions in complying with regulatory requirements related to fuel facilities.
The inspectors examined the licensee's management and organization controls with particular emphasis on continued training for ilP technicians and documentation of outside audits.
An allegation concerning potential 1
exposure to a non-licensee worker was investigated without substantiation.
The inspector noted several problems in the licensee's radiation 4
protection program.
The licensee's performance in the areas of criticality safety, maintenance surveillance, transportation, and waste generation was viewed as adequate to meet the regulatory requirements.
3.
Managemen'. Orcanization and Controls (IP 88005)
The inspectors reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organizational structure, procedure revising and updating, and utilization of the audit system for reporting deficiencies to management.
a.
Organization 1
Since May of 1987 (See Inspection Report No. 70-036/87001), the licentce has required each of the four Health Physics Technicians to work on a rotating shift schedule.
During the rotating shift each technician performs routine and special HP activities.
Although this arrangement has added to their overall experience, it appears that after a technician is qualified to perform these functions, he/she receives minimum continued training and retraining.
1 2
e The inspector noted that atte'nding a course in health physics would be a good review /or introduction for the licensee HP techr.icians d
in the subject areas (radiation interactions, principles and practices in identifying and controlling exposure situations, radiological calculations, etc.) expected of junior and/or senior health physics technicians.
It was also noted that the licencee's Corporate HQ has proposed expansion it the Hematite facility.
Plant expansion could double the work force, which is presently 75 persons.
Additionally, HQ NRC/NMSS.is reviewing the licensee's application to increase the plant enrichment level from 4.1% to 5% enriched uranium.
A combination of the above activities implies a need for the licensee to upgrade training in the radiation protection' program.
The licensen acknowledged that offsite training for the HP technicians will be investigated.
The inspector will monitor the licensee's activities for further developments in continued training for health physics technicians. (0 pen Item 70-036/88001-01) b.
Internal Reviews and Independent Audits The inspector verified that the licensee maintains records of audits performed by the Corporate Consultant Scientist, American Nuclear Insurers (ANI), CNA insurers, and internal audits conducted by the Nuclear Licensing, Safety and Accountability Supervisor.
Audit findings performed by the Corporate Consultant Scientist are discussed in Section 6 (Criticality Safety) of this report. ' CNA reviewed safety activities in the licensee's programs, including:
safety meetings, safety inspections, accident investigations, job safety analysis and health hazard recognition program, employee training and reeducation, personal protective clothing program; and cmergency evacuation drills.
No recoceendations were submitted by CNA reviewers.
ANI audited the licensee's program for fire emergency response by offsite agencies and noted that the licensee had a mLtual aid agreement with the Festus, Missouri fire department.
Additionally, the Hematite Fire Department made a general tour of the plant.
Records of the various audits were kept in an orderly manner.
Responses to audit findings indicated that the licensee utilizes independent audits conducted by Corporate Personnel and/or insurance reviewers as another meai.e of reporting deficiencies to management.
Routinely, the Nuclear Licensing, Safety, and Accountability Supervisor acts as liaison to management for conducting audits and promptly reporting deficiencies to management and/or to NRC.
Other than discussions about the need to upgrade health physics technicians through educational opportunities, no other problems under management controls and organization were identified.
No violations or deviations were identified.
3
b 4.
Allegation (IP 92705) a.
Background
On January 22, 1988, a representative from the St., Louis, Missouri branch office of OSHA notified Region III that aa'erployee of Ehrhardt Tool and Die Company, also based in St. Louis, who wishes to remain anonymous expressed concern about being exposed to radiation in reworking "nuclear punches" from the Callaway Nuclear Plant.
During a preliminary investigation conducted by telephone with the President of Ehrhardt Tool and Die, Region III learned that the company was not performing any work on equipment from the Callaway plant.
(This information is consistent with information reported by the resident inspector as noted below.) However, the company is engaged in reforming / reworking pellet punches for Combustion Engineering's Hematite and Windsor fuel fabrication facilities.
The President also noted that Ehrhardt has been on strike, and temporary personnel are engaged iri some plant work.
The NRC Region III resident reactor inspector located at the Callaway Nuclear Phnt determined that representatives from Callaway's radiation protection and equipment end supplies departments confirmed that no tools or components of equipment are sent to Ehrhardt Tool and Me Company for refurbishing.
During this inspection, the inspector conducted interviews with the licensee Plant Manager, Nuclear Licensing, safety, and Accountability Supervisor, Health Physics Technicians, Quellity Assurance Specialist, Shif t Foreman, and the Laboratory Supervisor as well as representatives of the Erhardt Tool and Site Company.
In addition, supporting documentation was reviewed from the time pellet punches are removed from service, decontaminated, submitted to Ehrhardt Tool and Die, for rework, and returned to CE Hemstite.
b.
Discussion Steel alloyed pellet punches used in the Hematite uranium pellet presses are identified as upper and/or lower position punches.
Ranging from about 3.5 to 4.5 inches in length, they are similar in size to a ball point pen.
The punches are designed to form a cylindrical shaped pellet out of powdered uranium oxide.
The contact end of the punch is uniquely shaped in order to formulate a pellet that stacks precisely with adjacent pellets.
The shaped end of the punch is the only portion of the punch that is reformed / reworked by the Ehrhardt Tool and Die Company.
In service, a punch will last from several days to a week j
before degradation of the contact end occurs.
The licensee indicated that tolerances for reworking a punch were very small (0.0055 inch range); therefore, the punches could only be reworked approximately twice.
The records disclosed that at least 2 batches /
boxes of punches were shipped from CE Hematite to Ehrhardt for rework since December 1987.
4
Initially, pellet punches removed from service are cleaned with I
trichloroethylene (TCE), a solvent used to degrease metal.
The TCE should do a satisfactory fob of decontaminating the punches; however, occasionally a punch may be rejected by a Health Physics Technician for failure to meet releasable radioactive contamination limits.
On these occasions, the punch is hand cleaned with a laboratory cleanser.
There has been no evidence of failure to decontaminate a punch to the release limits specified in the license.
Health physics records indicated that the licensee's method of decontaminating the punches with TCE consistently removed contamination levels to below 200 dpm.
This meets the license restriction of 1000 dpm/100 cm2 for removable contamination based on smear counts.
Fixed radioactivity levels also meet the license limits for release.
The inspector requested the licensee to test the extent to which radioactive contamination could be removed from a previously decontaminated punch.
A decontaminated punch was agitated in an ultra-sonic bath of distilled water.
The water was then transferred to a glass beaker, evaporated with nitric acid (to dissolve any uranium oxide), and brought to dryness in a 2-inch metal planchet.
The residue was counted and yielded about 67 dpm (alpha), which is well within the license limits for release.
A follow-up survey of the pellet punch indicated that the level of fixed material (radioactivity) remaining on the punch after the ultra-sonic treatment was not significantly different than instrument background.
This determination is made with the PAC-4G counting system.
On April 13, 1988, the inspector, accompanied by the NRC Region III Chief, Radiological Effluents and Chemistry Section, performed a radiological survey at the Ehrhardt Tool and Die Company of the work benches and grinding machine used to rework pellet punches and of some punches from Combustion Engineering which were awaiting rework.
Direct radiation surveys performed with a gamma micro-R meter, a beta gamma survey meter equipped with an HP-210 detector, and an alpha survey meter did not detect any radiation levels above background.
Smears were performed on the grinder machine, on 12 punches awaiting rework, on two work benches, and on the surrounding floor area.
The smear survey also failed to identify any radioactivity levels in excess of the release limits specified in the Combustion Engineering Company NRC license.
c.
Conclusion Based on the inspector's interviews of perscnnel, review of supporting documents, test of a decontaminated punch, and surveys at the Ehrhardt Tool and Die Company, it is apparent that the pellet punches that the licensee is submitting to the Ehrhardt Tool and Die Company meet the NRC regulatory requirement for releasable radioactive contamination limits cecified in the Combustion Engineering Company license.
i 5
-3 c c r.
J' b-
-Theallegationofradiatione$posurefrom"nuclearpunches"wasnot substantiated.
No significant radiation safety concerns or regulatory problems were identified.
5.
Radiation Protection (IP-83822)
The inspector reviewed the licensee's internal and external exposure control programs, including the required records, reports and notifications, and the-licensee's methods for calculating maximum permissible concentration (MPC) limits from air sampling, bioassay, and/or whole body counting data.
i a.
Internal Exposure Control Bioassay records for 1987 operations disclosed that the 40 MPC-hour intake limit for soluble uranium was not exceeded.
Whole body counts for plant workers were also below the 130 ugm U-235 action level.
One worker has been carried on the restricted roster for a number of years (since 1969) because he exceeds the action level of 130 ugm U-235.
His most recent whole body count showed 244 ugm of U-235.
r MPC levels are frequently derived from calculations based on air sample data.
Because of the difference in chemical and/or physical properties of uranium compounds throughout the plant process, the classification of uranium solubility can be i
difficult.
Urinalysis results reflect the soluble form of uranium; whole body counting is relied upon to determine exposure levels in workers exposed to insoluble uranium oxide.
During this inspection, the licensee's method for converting whole 4
body count and urinalysis data to MPC-hours was reviewed.
It was noted that although the licensee could satisfactorily demonstrate how urinalysis data is converted to MPC-hours, no conversion methodology had been developed to convert whole body count data.
Nor were there any written procedures or methodology concerning conversion of either urinalysis or whole body count data to MPC-hours.
Based on this review it appears that a licensee i
procedure addressing the conversion methodology is needed.
This 1
matter was discussed at the exit interview and will be reviewed during a future inspection.
(0 pen Item 70-306/88001-02) b.
External Exposure Control 7
The inspector reviewed the licensee's exposure control program including adequacy of procedures used to evaluate, control, and 1
minimize exposures and required records, repcrts, and notifications.
The annual exposure report for 1987 operations disclosed that 81 persons were badged during the year.
An exposure table follows:
i
}
6 i
\\
I 7
ANNUAL DOSE RANGES NUMBER OF INDIVIOUALS (REM)
IN EACH RANGE nom $asurableExposure 9
Measurable Exposures Less Than 0.100 44 0.100 - 0.250 18 0.250 - 0.500 9'
0.500 - 0.750 1
4 0.750 - 1.000
_0 TOTAL INDIVIDUALS REPORTED 81 In accordance with 10 CFR 20.407, the licensee submitted the above data to the USNRC Office of Nuclear Regulatory Research, with a copy to Region III.
All reported exposure levels were less than the dose limits for individuals, as shown in 10 CFR 20.
c.
Program Review During the course of this inspection, the inspectors identified several a eas of concern that if not addressed could lead tn programmatic weaknesses.
J The uranium source used for calibration of alpha survey j
instruments, which appears to be a metallic disc, shows signs of wear.
Several indentations and scratches are visible.
l Also, records indicate that the source activity has not been NBS certified or verified since 1976.
It appears that the 4
source should be replaced.
(0 pen Item 70-036/88001-03)
"Continuing education" for HP Technicians was discussed in Section No.
3., "Management Organization and Controls." The inspector stated that the licensee should consider expanding their current training program to include periodic retraining for HP Technicians, especially if plant expansion and doubling of the work force occurs.
(0 pen Item 70-036/88001-05)
The four alpha sources (plutonium electrodeposited sources) may j
be inadequate for calibrating survey instruments.
The sources range from 750-57,000 dpm.
According to one HP. Technician a j
linear plot based on counting results of the four sources could 1
not be established.
However, the inability to develop a linear plot from the data may be caused by a combination of source strength, counting geometry, and counting statistics.
Based on these findings the licensee should reevaluate the method of calibration.
(0 pen Item 70-036/88001-06).
l 7
\\
The inspector.will monitor the licensee's progress in the above areas during future routine inspections, d.
Reports and Notifications In accordance with 10 CFR 20.408, the licensee furnished the Director, Office of Nuclear Regulatory Research, USNRC, a report on radiation exposure for individuals who had terminated their work assignment.
These records appeared to be in order.
No problems were noted, i
The inspector requested the licensee to take action on the problems noted in order to mitigate potential weaknesses in the radiation protection program.
No violations or deviations were identified.
6.
Criticality Safety (IP-88015)
The inspector reviewed criticality safety audits and documentation of facility changes that required nuclear criticality safety analyses, a.
Audits An annual audit of the criticality safety program is condcted by a Nuclear Criticality Specialist from the licensee's corporate office.
Subsequent to the audit program, criticality safety inspections are conducted twice per year by either the Nuclear Criticality Specialist or another qualified person.
In addition, the licensee's Nuclear Licensing, Safety, and Accountability Supervisor conducts quarterly criticality inspections.
Quarterly inspections are required by the license.
The records indicated that redundant criticality safety inspections uncovered several minor violations.
The licensee corrected these violations, discussed below, during the course of the inspections.
A container of liquid was placed in storage without a completed identification tag.
No uranium content was listed.
Two mop buckets were improperly stored.
Hop buckets have designated storage locations.
A container of dried residue was stored without a completed identification tag.
The uranium quantity was not listed.
A 5 gallon pail containing vials of uranium oxide was filled to a level that allowed the vials to extend above the top rim of the container.
The sample vials contained small amounts of uranium.
A criticality limit sign located on the UFe receiving dock was partially obstructed by temporary storage of a wooden crate.
8
4 The licensee's actions in correcting these violations to SNM storage criteria meets the criteria specified in 10 CFR 2, Appendix C, for self-identification; therefore, no notice of violation is being issued.
The inspector examined nearly a third of the SNM storage locations and determined that among the random locations examined, the material was properly stored and identified.
The inspector also noted that the sign designating the criticality limit for the pellet Grinder Hood No.1 needed replacing.
b.
Examination of Unsafe Geometry Container The inspector examined the licensee's data for the annual inspection and testing of Raschig rings used in 2 filtrate tanks and a uranyl nitrate blend tank.
The boron content of the Raschig rings and the effects of corrosion were not significantly different than data' collected during previous years.
c.
Facility Modifications and Changes Requiring Criticality Review The inspector reviewed the licensee's documentation of facility changes requiring criticality considerations, including determination of whether the licensee has the appropriate expertise to establish criticality safety limits for facility operations, and determination of whether the licensee has positive management controls to ensure that facility operations are conducted within nuclear criticality safety limits.
Only one change and/or modification to operations was noted by the inspector.
A request was submitted for the replacement of the No. 3 furnace scrubber heat exchanger.
The request was submitted to replace the worn unit with a smaller, more efficient heat exchanger.
The installation will have no affect on other units in the area.
All material dried in the furnace is based on a safe i
concentration.
All SNM material dried or ashed in the furnace is based on a safe concentration of 1 gram U/ liter.
No other criticality consideration is needed.
In-depth discussions with the cognizant engineer and a review of the criticality program with the Nuclear Licensing Safety and i
Accountability Supervisor demonstrated to the inspector that the licensee uses conditions and assumptions in performing NCS analyses that are valid and that facility modifications and changes undergo independent reviews that meet nuclear and health safety practices.
No violations or deviations were identified.
7.
Maintenance and Surveillance Testing (IP 88025)
The inspector reviewed the licensee's maintenance operations to determine whether emergency power equipment is being maintained as required, and records are maintained on other plant systems pertinent to safety.
9 l
--w 9
The licensee maintains emergency power equipment to assure that there is no interruption of ventilation in the event of a loss of power.
The main emergency generator also provides utility services for water, steam, and instrumentation and evacuation alarm systems.
The generator is exercised
- weekly and records are kept in the maintenance log.
The inspector examined the maintenance work sheets and determined that routine services were being performed on emergency systems.
The licensee performs weekly tests on criticality (gamma sensitive) detectors with audible alarms. The licensee noted that spare alarms for gamma sensitive detectors are maintained as replacement units.
One of the standby / replacement units was being repaired during the course of this inspection.
Because it is important to criticality safety to have spare detectors /
alarms and because the maintenance in the spare unit was not completed at the conclusion of this inspection, this item will be reviewed during a future inspection.
(0 pen Item No. 70-036/88001-07)
The inspector noted that monthly crane inspections were conducted in a timely manner.
Records also indicated that an overhead crane survey report had been prepared by an offsite vendor.
The crane survey report of annual independent inspection recommended replacing the trolley and pinion gears.
The replacement gears have been ordered.
On January 6, 1988, the licensee completed the annual inspection of the incinerator / scrubber systems.
Observations were as follows:
A slight accumulation of solids was found on the bottom of the heat exchanger inlet, and a moderate buildup of solids was found in the discharge plenum.
A heavy accumulation of solids was found on the scrubber inlet duct, and a moderate buildup of solids was found on the scrubber ejector system.
According to licensee records, about 10 kgs of solid material was removed from incinerator / scrubber components.
This material was estimated to contain 1% by weight uranium.
The inspector concluded that emergency utility services and surveillance tests, as conducted under general maintenance operations, are being maintained and that satisfactory test results were obtained.
Additionally, an offsite vendor is used to conduct annual maintenance on the UFs cylinder crane.
j No violations or deviations were identified.
9 10
)
r-i
'4 g
b i
8.
Transportation (IP 86740)/ Waste Generator Requirements (10 CFR 20 and 61)
~
(IP 84850)
The' Inspector reviewed the licensee's program for the shipment'of radioactive materials including, determination whether waste shipments are in compliance with NRC and DOT regulations, and determination-if there were any transportation incidents involving licensee shipments.
During the January through December 1987 operating period, the licensee made four shipments cf low-level contaminated waste to a licensed disposal site.
The shipments cantained solidified sludge from waste ponds, waste solidified from UFe cylinder "heel" removals, and contaminated limestone from the hydrogen fluoride scrubber system.
A copy of shipping Form 741 signed by the disposal site licensee confirmed acceptance of each shipment.
Shipping records also disclosed results of radiological surveys.
2 Contamination levels were reported to be no higher than 75 dpm/100cm,
which is significantly less than DOT removable contamination limits.
Contact exposure levels were significantly less than 200 mrem / hour.
The inspectors also noted that waste generated from the cylinder wash program contained traces of technetium-99.,This waste was classified 4
and/or solidified in accordance with 10 CFR 61 in order to meet the minimum requirements to facilitate handling at the disposal site.
The inspector concluded that the shipping manifest disclosed that the transported materials were properly packaged and provided protection of health and safety of personnel at the disposal site.
I The inspector also observed the licensee's performance in handling incoming shipments of UFe, received in 2\\ ton cylinders.
In the observed instance, the licensee determined that the cylinder was equipped with an approved tamper safe device; verified the weight of UFe in the shipping cylinder; and performed the operation according to the instructions of Operating Sheet No. 05-1003, "Uranium Receiving Procedure." The inspector concluded that there was no evidence of a broken seal to indicate tampering with the cylinder valve.
In handling the UFs cylinder, the operator followed safety concerns posted for crane operations at the UFs vaporization station.
No violations or deviations were identified.
9.
Licensee Amendment Application (5% uranium-235)
)
On April 14 and 15, 1988, the inspector attended a meeting at the Combustion Engineering's (CE) Hematite facility concerning the licensee's application to increase the plant's enrichment level from 4.1 to 5%
uranium-235.
The meeting was conducted by NRC/NMSS.
Representatives from CE's Corporate Headquarters, CE Hematite, and Region III NRC were also in attendance.
During the meeting, the CE Hematite Plant Manager indicated that the plant is also considering an expansion of the existing facility to accommodate increased pellet production.
11 1
H The meeting ended with the understanding that the licensee must address l
additional criticality safety controls for 5% enrichment criteria and resubmit the license amendment application.
10.
Exit Meetino (IP 30703)
The inspector ret with licensee representatives (denoted in Section 1) on February 19, 1988, to summarize the scope and findings of the inspection and with Mr. Eskridge on April 15, 1988, concerning inspection findings related to the allegation.
The inspector discussed the following:
a.
The allegation was not substantiated.
No regulatory requirements were violated.
(Section 4) b.
Several potential radiation protection program problems (reeducation of HP technicians, replacement of sources, dose assessment calculations) were identified.
The licensee acknowledged that these problems would be corrected.
(Section 5) c.
Redundant criticality inspections helped to identify problems.
Criticality signs need reviewing and replacement where needed.
(Section 6) d.
Surveillance items were tested according to schedule.
(Section 7) e.
Transportation manifest showed that waste shipments were accepted at the disposal site.
Requirements of 10 CFR 61 for waste classification t
were properly addressed.
(Section 8) f.
No violations or deviations were identified during the course of this inspection.
Nevertheless, the licensee must address the radiation protection problems in order to prevent possible slippage in i
performance.
i The inspector also discussed the likely informational content of the j
inspection report with regard to documents or processes reviewed by the inspectors during the inspection.
The licensee did not identify any such documents / processes as proprietary.
b j
-.