ML20151X523

Insp Rept 70-1100/88-03 on 880229-0304.Apparent Violations Noted.Major Areas Inspected:Mgt,Organization & Controls, Criticality Safety,Operations Review,Maint,Radwaste Mgt, Environ Protection,Confirmatory Surveys & Nonroutine Events

ML20151X523
Person / Time
Site:	07001100
Issue date:	04/20/1988
From:	Gresick J, Pasciak W, Roth J, Shankaby M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151X453	List: ML20151X448 ML20151X523
References
70-1100-88-03, 70-1100-88-3, NUDOCS 8805040170
Download: ML20151X523 (22)

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.i U.S. NUCLEAR REGULATORY COMMISSION  :

REGION I  !

Report No. 70-1100/88-03 Docket No. 70-1100 License No. SNM-1067 Priority 1 Category ULFF-Licensee: Combustion Engineering, Incorporated ,

P. O. Box 500

Windsor Connecticut 06095  !

Facility Name: Nuclear Fuel Manufacturing and Nuclear Laboratories l i.

Inspection At: Windsor, Connecticut j Inspection Conducted: February 29 - March 4, 1988 Inspectors: _ // 7# 7 J. R th,' Project Engineer, DRSS // datgf i G Ju k y/u/er i J. @ esick Radiation Specialist, DRSS ~ date I Approved by: . rn 20 M W. Pasclak, Chief, Effluents Radiation i dale P ction Section, DRSS

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.,-Pff C s A S M. M. Shanbaky, Chief, Fjellities Radiation V/u//Y

~ dafe h

l Protection Section, DRSS  ;

Inspection Summary: Inspection on February 29 - March 4,1988 Inspection ,

Report No. (70-1100/88-03) i Areas Inspected: Routine, unannounced inspection by region-based inspectors  ;

. of the licensed program including: management, organization and controls;  ;

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criticality safety; operations review; maintenance, radioactive waste management; environmental protection; confirmatory surveys, non-routine ,

events; and, followup on previously identified enforcement items and review of l radiological safety allegations. [

l Results: Eight apparent violations of NRC requirements as well as apparent t breakdowns in your management control systems were identified relative to  !

your licensed program. The apparent violations include: failure to properly l mark each mass limited container with the actual uranium content and enrichment (paragraph 3a); failure of the Manager, Nuclear Licensing, Safety,  !

Accountability and Security to approve operations sheets and failure to l

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include appropriate safety precautions in operations sheets (paragraph 3b);

failure to maintain pellets within the required four inch slab thickness on the fuel pellet storage shelves (paragraph 3c); failure to conduct daily audits each working day (paragraph 4.a.(1)); failure to evaluate the effects of an  ;

accumulation of uranium oxide powder under the conveyor adjacent to the Batch Makeup Hood on nuclear criticality safety (paragraph 4.b.(2)); failure to

• control the addition of uranium oxide to the Hammermill Hood to assure that the mass limit is not exceeded (paragraph 4.c); failure to include the uranium-235 contained in sediment removed from waste tanks and pipes in Building 6 on in-  ;

ventory (paragraph 9 b); and failure to adequately assess the results of the  !

criticality safety training program (paragraph 10.a.(2)). '

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Details

1. Persons Contacted

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

• A. E. Scherer, Director, Nuclear Licensing

• R. N. Duncan, Director, Nuclear Fuel Development

• 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, Radiological Protection Services

• C Molnar, 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. Licensee Actions on Previously Identified Enforcement Items (Closed) Violation (1100/85-03-02) Failure to maintain a ten inch separation along the length of fuel assemblies in vertical storage. The licensee determined that there was no assurance that the ten inch spacing between fuel assemblies, at the upper end could be maintained because of the inherent design of the fuel assembly restraining device. Therefore, the license has limited storage of fuel assemblies to every other location. The inspector verified that fuel assemblies were being stored in every other location. There are no further queations regarding this violation.

(Closed) Violation (1100/85-03-06) Failure to calibrate level gauges in the liquid waste tanks located in Building 6 annually. Subsequent to Inspection No. 70-1100/85-03 the licensee modified the electronic sensing devices located in the waste tanks and removed the level gauges. In place of the level gauges, the licensee installed level indicators to show whether the tanks were empty, half full or full. If full, the sensors automatically close the tank fill valve and diverts the waste water to the next tank in the series. Through discussions with licensee representatives, and examination of fabrication drawings and installed equipment, the inspector verified that the new liquid waste treatment control system for the tanks appeared to be working as required. Correct-ive actions have been completed on this item.

(Closed) Unresolved Item (1100/85-03-08) Licensee self evaluation to authorize storage of fuel rods in a siv inch slab (5.5 inch slab authorized by the NRC license). On December 16, 1935, the licensee submitted an application to amend the facility license to authorize six inch slabs of fuei rods in the facility. Amendment No. 7 to license No.

SNM-1067 was issued by the NRC on August 4, 1986 authori:ing this license change. Corrective actions have been completed by the licensee.

. 3 (Closed) Violation (1100/86-01-01) Failure to post the fuel assembly shipping container loading area with Nuclear Safety Signs. The inspector verified that the nuclear safety signs posted in the shipping container loading area had been modified to authorize loading of the shipping containers.

(Closed) Deviation (1100/86-01-03) Poor practice of stacking contaminated laboratory coats on top of each other and use without surveying. The inspector verified that the licensee was no longer placing more than one laboratory coat on each hook af ter use. Each location where used clothing is stored for reuse has been labeled with a sign that states "Only one c e to a hook". The licensee has completed corrective action on this item.

3. Review of Operations The inspector examined all 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. Mass Limited Containers During examination of the Waste Storage Pad located along the south external wall of Building 21, the inspector observed three drums that were not properly marked to indicate uranium-235 content and enrichment. The three drums included Drum No. 5121 containing "fuel rods", Drum No. 4565 containing springs and an unmarked drum containing contaminated oil from the pellet presses. Similarly, the inspector observed four drums (Nos. 4564, 4570, 4586, and 4611) stored in the storage trailer that contained contaminated asbestos removed from one of the fuel pellet sintering furnaces. The drums had been sealed between December 20, 1987 and February 2,1988 and the actual uranium-235 content cf each drum had not been assigned within five days of sealing as required by approved operating procedures (Operation Sheet No.1764). Failure to properly mark each drum with the actual uranium-235 content and enrichment was identified as an apparent violation (1100/88-03-01).

b. Review, Approval and Content of Operations Sheets (Procedures)

During examination of the fuel rod helium leak detector work station, the inspector reviewed Operation Sheet No. 945, Revision 39, dated December 10, 1987 associated with the work station and used by quality control personnel. It was noted that the operation sheet (procedure) was not signed-off or approved by the Manager Nuclear Licensing, Safety, Accountability and Security (NLSA&S) as required by license conditions. In addition, the operation sheet did not contain appropriate safety precautions as required. For instance, the nuclear criticality safety posting at the work station was not referenced and the workers were not cautioned to remove their fingers from inside the helium leak test tube (which holds up to four fuel

, 4 rods) prior to pushing the door closure control switch. Failure to have this operation sheet approved by the Manager, NLSA&S and te include appropriate safety precautions in the operation sheet was identified as an apparent violation (1100/88-03-02). Through discussions with licensee representatives, the inspector was informed that several other operations sheets written by the same individual were not approved by the Manager, NLSALS and that none of the operations sheets used by quality control personnel contained the required safety precautions because they were provided in separate operations sheets,

c. Fuel Pellet Storage The inspector examined the storage shelves containing two inch trays of pellets located at the east end of the Pellet Shop. The nuclear criticality safety sign posted at the storage shelves indicated a slab limit (pellets) of 4 inches which was controlled by limiting the number of trays of pellets in a stack to two fgh. There was also a restraining bar welded across from the edge of the storage shelves.

The space underneath the restraining bar was 4 3/16 inches. That space would allow two 2 inch high trays of pellets equipped with 1/16 inch thick covers and bottoms to be placed on the shelves. However, the inspector measured several stack heights and found that they ranged from 4 3/8 to 5 inches in height. These stacks exceeded the allowable stack height by from 1/8 to 3/4 inches. Failure to maintain a 4 inch slab limit of pellets was identified as an apparent violation of Section 4.3.9 of the NRC-approved license polication (1100/88-03-03). Sub-sequent to the identification of this violation, the inspector was informed that a shipment of new trays had been received from the vendor and placed into use. The new trays were fabricated to a tolerance of 2 inches, plus 1/8 inch, minus 0 inches instead of 2 inches, plus 0 inches, minus 1/8 inch and were apparently not inspected by the quality assurance group upon receipt,

d. Empty Container Storage The inspector noted that the licensee posted the empty incoming powder container storage area located near the powder container weighing station in the Pellet Shop Annex with empty signs that were visible from all directions,

e. Flammable Material Storage The inspector observed that the flammable material storage cabinets located throughout the pellet shop were still filled to capacity.

The licensee had not re-examined the storage of excessive flammable liquids as committed to during the last inspection.

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f. Housekeeping

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The inspector noted that housekeeping on the cold shop mezzanine had I deteriorated since the last inspection in that the combustible fire j load had increased. There were quality assurance records stored in '

cardboard boxes. Two to three boxes of paper towels, 25-30 bags of used, contaminated gloves and seven large bags of laundry were stored in the area. License representatives stated that the storage of combustible materials in this area will be re-examined again.  ;

g. Ventilation Systems During this inspection the inspector initiated an examination of sampling points and monitoring systems installed on ventilation systems located in Building 5 and Building 17. It was observed that '

the sampling system associated with the Building 5 Ceramics Laboratory could not be expected to reliably measure particulate releases because of the number of bends in the sampling line.

During this examination, the inspector was informed that the licensee had initiated a study of the ventilation systems in both buildings. Through discussions with the licensee's consultant, the inspector determined that the ventilation systems associated with the ceramics, the hot chemistry and the emission spectroscopy laboratories in Building 5 and all four ventilation systems in  ;

Building 17 were being re-evaluated. As a minimum, the capacity, the sampling, and the monitoring capabilities of the systems were being evaluated. This study was expected to be completed within two l months of the date of this inspection.

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4. Nuclear Criticality Safety a, Internal Review and Audit (1) Daily Audits Records of daily audits conducted by health physics technicians for the time period January 4, 1988, through March 2, 1988, were examined by the inspector. The licensee has developed a detailed checklist covering all aspects of the operations as an aid to the health physics technicians when they conduct this facility review. Areas examined included signs, logs, radiation alarms, criticality safety compliance, contamination levels, and airborne contamination levels. According to licensee representatives, items requiring correction were corrected immediately, if possible. However, the licensee has not established a management control system capable of tracking corrective actions taken from identification of the item to completion of the required actions. Establishment of such a management control system was identified as an inspector followup item (1100/88-03-04). ,

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During examination of the daily audits, the inspector determined that audits were not conducted during the weekends of February 13-14, 1988 February 20-21, 1983 and February 3 27-28, 1988 even though the facility was operating during those weekends. Failure to conduct daily audits during each working day was identified as an apparent violation of Section 2.8.2 of  ;

the NRC-approved license application (1100/88-03-05). i t

(2) Weekly Audits Records of weekly audits, conducted by the Supervisor, Health Physics for the period January 4,1988 through February 25,  !

1988, were examined by the inspector. Areas examined included the same topics as described above. In addition, the Supervisor measured and recorded air flow from areas of lower to areas of higher potential contamination. The inspector determined that air flow direction was being recorded weekly as l a part of the weekly audit report. '

(3) Monthly Audits The inspector examined documentation of monthly audits conducted by the Manag?r, Nuclear Licensing, Safety l Accountability and Security (NLSA&S) during the time period January 30, 1987, through January 8, 1988. A total of 12 audit  ;

reports were reviewed. The inspector noted that the Manager  !

NLSAls did not identify any violations during these audits  !

even though numerous violations were identified internally during the daily, weekly, quarterly and annual audits by other i i licensee personnel and by NRC inspectors during compliance

inspections. This was questioned at the exit interview by the

, inspector. Licensee represer,tatives did not respond at that l time. This is an inspector followup item to be discussed with 1 licensee management during subsequent inspections ,

(1100/88-03-06).

1 (4) Quarterly Nuclear Safety Committee Audits The inspector examined documentation of four quarterly audits conducted by the Criticality Safety Specialist for the Nuclear Safety Committee between April 7, 1987, and January 4, 1938.

The inspector verified that appropriate corrective actions were ,

a taken or had been initiated by the licensee for the items identified in the audit reports.

(5) Audits of the Nuclear Laboratories The inspector examined the records of nine monthly audits of ,

. the nuclear laboratories conducted by the Manager, NLSA&S  !

between May 4, 1987 and January 11, 1988. No inadequacies were identified, i I

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b. Nuclear Safety Evaluations (1) Facility Changes and Modifications During examination of the faciltty, the inspector observed that there had been several significant changes or modifications in the manufacturing facility (Building 17) and the nuclear laboratories (Building 5). It was noted that in Building 17, i the licensee was (1) revising the duct work associated with the Pellet Shop ventilation systems, (2) installing hoods and ventilation systems over and around all work stations where i fuel powder was handled, and (3) removing from service all l unnecessary nuclear criticality monitors and alarms in accordance  !

with Amendment No.11, dated January 4,1988. In addition, the licensee has covered all floors in the Pellet Shop with asphalt l' tile and all conveyor belts and tables with Stainless steel sheeting to reduce contamination control problems. In Building l 5, the licensee installed a new metallographic mount preparation l facility in a room adjacent to the ceramic laboratory and j initiated installatic.. of criticality monitors in the new vault room.

(2) Review of Nuclear Safety Evaluations l The inspector reviewed the records of the review and approval of process equipment or facility changes performed by the Criticality Safety Specialist for criticality safety or by the l Manager, NLSA&S for radiological safety, From April 16, 1987 through November 15, 1987 (Request No. 272), twenty four requests for review and approval were made by Engineering.

Eight of the requests involved both nuclear criticality and t radiological safety considerations and ten involved radiological or industrial safety considerations. The requests '

that involved criticality safety considerations were independently reviewed by a qualified person designated by the Nuclear Safety Committee and by the Criticality Safety Specialist, if the original review was conducted by the Manager, NLSA&S. The requests involving radiological and industrial safety considerations were reviewed by the Manager, NLSA&S. The evaluations were countersigned by qualified persons, as required. The inspector determined that the licensee has improved documentation of the independent reviews by adding additional sign off sheets to the approval package.

Those sign off sheets provide space for the independent reviews to be documented.

During the examination of the evaluations, the inspector also determined that two were voided, two were not approved and two were apparently not approved but were implemented. One of the latter two, Request No. 261, concerned a request to reduce the

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-- January 4, 1988. The other request (No. 268) involved the installation of aluminum sheeting'on the outside of the-fuel rod turret carts to reduce the potential for contamination.

The inspector stated to licensee representatives that, from a management control standpoint, release of any requests for equipment change, without approval, to the NRC or for implementation appeared to be poor practice. In addition, the licensee's records were not complete in that there was no indication of a final review by the Health and Safety group to-assure that all established controls have been installed as required. Licensee representatives indicated that a close-out review sheet will be added to the evaluation package to document final review actions on each evaluation. This was identified as an Inspector Followup Item (1100/88-03-07).

During a tour of.the Pellet Shop the inspector observed that the conveyor between the Batch Makeup Hood and the Batch Makeup Cone Hood had been covered with metal sheeting.

However, there was about a two to three inch space between the Batch Makeup Hood and the covered conveyer. The inspector questioned licensee representatives concerning evaluations conducted to assure that the potential accumulation of uranium oxide powder under the conveyor would not cause a nuclear criticality safety hazard. The inspector was informed that such an evaluation had not been performed as required by Section 4.1.3 of the NRC-approved license application. Failure to conduct the required nuclear criticality safety evaluation was identified as an apparent violation (1100/88-03-08).

c. Nuclear Safety Log Sheets The inspector examined the nuclear safety log sheets available at the hammermill, the screening hood, the micronizer, and the blended powder drier belt to assure that mass limits o. slab depths were not exceeded. It was noted that on February 26, 1988 the hammermill was cleaned out and all uranium oxide powder was removed. On February 27, 1988 the hammermill was cleaned out, once again, and approximately 1.1 kilograms of powder in excess of the indicated balance was removed. Just prior to cleanout approximately 23.4 kilograms of powder was placed into the hammermill hood for processing. The inspector noted that if the cleanout value of 1.1 kilograms was correct, there could have been 24.5 kilograms of powder in the hood. That 24.5 kilograms exceeded the 24.0 kilogram nuclear safety limit established for the hammermill hood. The potential for

, exceeding a nuclear safety limit was identified as a violation of the Section 4.1.2 of the NRC-approved license application (1100/88-03-09).

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d. Virgin Powder Storage Area Fire Door

-Section_4.3.2 of the NRC-approved license application requires the

. licensee to conduct tests to assure that the fire door on the virgin powder storage area will automatically close upon activation of the fire alarm and upon electrical power failure. These tests are to be conducted - quarte rly. The inspector examined records of the required tests for the time period October 7, 1986 through January 20, 1988.

No inadequacies were identified.

e. Nuclear Criticality Safety Monitor Calibration and Alarm Test Through _ examination of licenses records the inspector verified that the licensee conducts daily operational checks, biweekly source response checks and semi-annual calibration of the nuclear criticality safety monitors and alarms. The licensee is currently converting the criticality alarm systems installed in Buildings 5 and 17 from that specified in 10 CFR 70.24(a)(2) to that specified in 10 CFR 70.24(a)(1). No inadequacies were. identified.

5. Preventive Maintenance Program As a result of equipment problems identified during NRC Inspection Nos. 70-1100/86-04 and 70-1100/87-05 and equipment malfunctions chat occurred during the summer of 1987, the licensee has initiated a corrective and preventive maintenance program. An engineer has been hired to establish.the programs. Thus far, that individual has identified about 150 systems within the facility that require preventive maintenance. A system is being established to assure that maintenance is conducted when required. That system will include a calibration program. Actions have also been initiated to obtain operat-ions and maintanance manuals for each piece of equipment and to establish a mechanism to assure that the maintenance work has been completed in a j satisfactory manner.

6. Nuclear Safety Committee The inspector examined records of the annual Nuclear Safety Committee c

meeting and tour of the Nuclear Fuel Manufacturing facilities conducted on January 6, 1988. Areas of the facilities examined during the tours and discussions held during the meetings included: housekeeping, locations where license violations occurred, implementation of orevious i

observations; review of facility changes and review of the radiological protection and ALARA programs. During the facility tour, the Nuclear Safety Committee also identified several violations of license requirements. Actions were immediately taken to correct tk ose violations.

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7. Nonroutine Events Through examination of licensee records, discussions with licenseo representatives and observation of licensee activities, the inspector determined.that several nonreportable nonroutinc events have taken place since the last inspection.

a. Hydrogen Analyzer Fire-On December 17, 1987 at about 10:30 a.m., a hydrogen analyzer experienced an internal short circuit resulting in a fire. The equipment operator secured the hydrogen supply to the analyzer and had the facility fire alarm saunded. Although the fire appeared to be out, the area was evacuated because of dense smoke. Personnel evacuated the Pellet Shop and reported to the Building 6 parking lot assembly area for accountability. Because of cold weather, the workers were sent to Building 5. Subsequently, the workers returned to Building 17, were surveyed for contamination and were allowed to return to work. The evacuation route, Building 6 assembly area, Building 5 assembly area and potentially affected uncontaminated areas of Building 17 were surveyed for contamination. No significant contamination was identified and there were no releases of radio-active materials to unrestricted areas as a result of the fire,

b. Uranium e Powder Spill At about 4.45 p.m. on March 1, 1988 while lifting a five gallon bucket of powder from the batch makeup work station conveyor to the powder blending hood, the bucket lift lost hydraulic pressure and the bucket, in the lift mechanism, fell to the floor. Upon impact '

with the floor, the top of the bucket including the cone, dislodged ,

and powder was spilled on the floor. The lift operator was contaminated on the left arm and the left side of his face.

Personnel decontamination was performed following unich the individual was-found to be clean. The individual's breathing zone sampler indicated a dose of 0.06 MPC-days and nasal smears were negative. Even so, the individual was immediately placed on a bioassay program including urine and fecal analysis. The licensee is continuing to evaluate possible uptakes by this individual. No releases to unrestricted areas occurred as a result of this incident and the area was immediately decontaminated.

c. Dropping of Pellet Trays At abcut 7:55 a.m. on March 3, 1988 while doing a security alarm check on the rollup door at the west end of the Pellet Shop Annex, the lip of the rollup door caught the bottom of a safe slab cart holding five full covered trays of uranium oxide pellets. As a result, the pellets were spilled onto the floor.

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The area was immediately cleaned up. Subsequent floor smears ranged 2

from 300 to 1500 dpm alpha per 100 cm . One individual involved in the cleanup operation was immediately placed on a bioassay orogram including urine and fecal analysis as a result of an elevated nasal smear. There were no releases of radioactive material to unrestricted areas.

The inspector was informed of this incident at about 11:30 a.m. on March 3, 1988 and immediately went to licensee management (the Manager, Nuclear Licensing and the Plant Manager) to discuss the incident. Neither of these individuals were aware of the incident at that time. During the exit interview the inspector questioned the licensee's management controls which allowed incidents in the Pellet Shop to go unreported to licensee managreent for up to 3h to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The_ licensee had no response but indicated that the question would be evaluated. This was identified as an inspector followup item (1100/88-03-10).

8. Organization The inspector discussed the makeup of the Nuclear Licensing and' Safety

• organization with licensee representatives. It was determined that the health physics organization reporting to the Manager, Nuclear Licensing, Safety, Accountability and Security consisted of two supervisors and one clerical worker. Reporting to the Health Physics Supervisor are seven "house" technicians, two "rent-a-techs" and a technical assistant.

• Reporting to the Radwaste Supervisor are two lead decontamination technicians and four decontamination technicians. The Radwaste Supervisor and his six technicians are all temporary "rent-a-tech" employees. .

Tnrough discussions with licensee representatives, the inspector determined that health physics technician turnover had increased to six within the last nine months from about one per year for the prior five to six years. Reasons for this increase will be examined during subsequent inspections. In addition, the inspector was informed that the de-contamination personnel were working two shifts of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> each, seven days per week. The inspector questioned the advisability of working ,

personnel continuously. Licensee management did not believe that this '

could lead to safety problems within the facility.

9. Residual High Enriched Uranium

a. Contaminated Wooded Area The inspector discussed the status of the licensee's actions taken to assure that the wooded area was cleaned up. The licensee has completed cleanup of the area. has analyzed soil samples to assure that the soil contains less then 30 picocuries uranium per gram of soil and is currently preparing the final survey report.

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b. Residual Uranium Stored in Building 6 During examination of the Building 6 liquid waste storage tank facility, the inspector observed eleven five gallon buckets of contaminated sediment that had been removed from the liquid waste storage tanks and a pipeline between Builaing 6 and the Building 3 laboratories during 1985. Building 3 was formerly used as a navy fuel fabrication facility prior to 1962. The sediment contained an estimated 70-300 grams of uranium-235 enriched up to 77 percent.

The sediment has been located in Building 6 since 1985 awaiting transfer to a burial site for disposal. The inspector questioned licensee representative to determine if this uranium had been placed on inventory. Licensee representatives determined that it had not been placed on inventory. Failure to include the uranium-235 contained in the sediment on inventory was identified as an apparent violation of 10 CFR 70.51(b)(1) (1100/88-03-11).

c. Radioactive Material in Uncontrolled Area (Former Waste Pad)

On November 13, 1987 the inspector was notified that the licensee had discovered additional radioactively contaminated material outside the restricted area. That material was found on the licensee's property south of the former Waste Pad located to the west of Building 2. NRC Region I was notified of this finding by c letter dated December 16, 1987. Samples of the contaminated material were analyzed and found to contain uranium in enrichments ranging from 3% to 88% of uranium-235.

In accordance with License Condition 23, the iicensee initiated actions to remove the contaminated material from the area. Accessible con-taminated debris consisting of wall insulation, metal grating, poly bottles, and pipes were removed, the area was later posted as a controlled area and a snow fence personnel barrie was erected.

Additional actions will be taken to clean the area after the ground has thawed. Following cleanup of the area, NRC Region I will conduct a verification survey prior to release of the area for unrestricted use.

10. Allegation Follow-up An allegation was received in the Region I office by telephone on March

, 14, 1988. During this inspection, the inspector interviewed the alleger l and other plant workers to ascertain the validity of the allegations.

1 i a. Allegation Concernin:; Weak or Non-existent Training for Criticality Safety

1) Statement of Allegation l The alleger told the NRC, in a telephone conversation on l March 14, 1988 that there was no criticality safety training l provided for the new Health Physics technicians, which was in violation of the license. The alleger further stated that no l

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44 13 training was given to radiation workers for. contamination controls or the hazards of uranium oxide powder. There was also no training on the requirements of the license.

2) Inspector Review The inspector interviewed the alleger, other radiation workers, the Health Physics . supervisory staff, and a Production Supervisor. The inspector also reviewed records of training (initial radiation worker training) for plant workers in contamination control, Radiation Work Pormits (RWPs), use of protective clothing, and proper person- frisking techniques.

Within the scope of this review the following was identified:

- The initial Radiation Worker Training course consists of a booklet, which was written by the Health Physics staff in 1985. The content of the booklet includes basic radiation

. protection, criticality safety, industrial safety, emergency evacuations, and security. A member of the Health Physics staff (i.e., the Health and Safety Supervisor or the Radiation Specialist) conducts the training, and after a brief written test, issues the booklet to each new employee for future reference. -Testing for criticality safety, however, is marginal and consists only of listening to evacuation alarms.

All new employees receive this training.

- Some additional training is provided to Pellet Shop workers on criticality signs. This training consists of taking a small' group of workers (presumed new workers by the trainer) around the Pellet Shop and reading the criticality signs on each work station or work area. No written test is provided to the workers to determine their comprehension of this training.

- As of February 16, 1988, the training for criticality signs was conducted by the Radiation Specialist. Prior to this date, the criticality sign training was conducted by a production supervisor. Neither the production supervisor nor the Radiation Specialist have received any formal training on Nuclear Criticality Safety. These individuals' knowledge in the area was based upon their on-the-job experience.

- As of March 28, 1988, no additional criticality safety training nor any criticality sign training was given to the alleger.

Special Nuclear Material License No.1067, Part I License Condition, Section 2.6.1, "Initial Training" describes the requirements for initial training of all new employees. This section of the license requires all personnel who will be working with radioactive materials to complete a test to ascertain the effectiveness of training. Further, records of

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test to assess the effectiveness of criticality safety and criticality sign training is an apparent violation of this

. . license requirement (70-1100/88-03-12).-

'3) Conclusions The inspector determined that the allegation concerning weak criticality safety training was substantiated.

The allegation concerning a lack of training for contamination controls and the hazards of uranium oxide powder was not substantiated. As of November 27, 1987, the licensee, in response to a Ccnfirmatory Action Letter from the.NRC (CAL 87-14) cleaned up Pellet Shop contamination levels and provided extensive training to the workers on methods of contamination control in the the Pellet Shop. Further, training on RWPs, personnel frisking and protective clothing was given to all workers in March and April, 1988.

The inspector discussed these findings with the licensee at the exit interview on March 31, 1988. The licensee stated that an upgraded Criticality Safety Training program will be incorporated into the Radiation Theory section of the new General Employee Training.

b. Allegation Concerning Dismissal of Health Physics Technicians for Raising Safety Issues

1) Statement of Allegation The alleger stated that two contractor Health Physics technicians were fired after they raised questions concerning work around asbestos covered piping in the Pellet Shop.

2) Inspector Review The inspector interviewed the alleger. The alleger indicated that he did not personally observe this problem but had heard it from other plant personnel.

The two contractor Health Physics (HP) technicians were unavail-L able for interview. The inspector reviewed this concern by L interviewing other Health Physics technicians and the Health and l Safety Supervisor, and by reviewing documentation written by the two contractor HP technicians.

Within the scope of this review, the following was determined:

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- The.two contractor HP technicians had given the Health and Safety (H&S) Supervisor r.etice of their intent to leave due to other-opportunities for wor.'. This occurred prior to their 1 dismissal.

- The licensee stated that the two HP technicians were asked to leave prior to their scheduled departure date due to failure on their parts to follow ccmpany protocol and to discuss concerns with their supervisor before circulating them throughout the company personnel.

3) Conclusion The inspector concluded that the allegation was not substan-tiated.

1: . . Allegation Concerning Willful Violation of Security Procedures Relating to Key Control

1) Statement of Allegation The alleger stated that licensee personnel were violating security procedures regarding radiation area key controls.

2) Inspector Review During this inspection, the inspector interviewed the alleger.

The alleger admitted that no security procedures were violated regarding key control. The alleger was concerned because he felt that only HP's should have keys to exits to the Radiologically Controlled Area. At this site, that responsibility has been given to the "Deconners" because of radwaste minimization considerations.

3) Conclusion The inspector concluded that this allegation was not substantiated.

d. ' Allegation Concerning a General Lack of Understanding of Safety issues  !

1) Statement of Allegation The alleger stated that the workers in the Pellet Shop were not concerned when their seven day MPC-hours total 16 to 18 MPC-hours. He felt that they were not concerned because they did not understand what this meant from a health and safety standpoint. The alleger further stated that one HP technician on the licensee's staff had not passed his initial General Employee Training (GET).

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'2)- ; Inspector Review The. inspector reviewed this allegation by conducting interviews with the HP technician who allegedly failed the GET test, the H&S Supervisor, the Radiation Specialist, and Pellet Shop workers.

This concern was previously addresse'd in NRC inspection No.

70-1100/87-05, in which the licensee was cited for an inadequate training program, in response to th's violation, the licensee committed to sig'nificant upgrades of the General Employee Training program. The inspector verified that the needed upgrades were underway.

The inspector determined that the HP technician who allegedly failed GET was a newly hired HP technician who was conducting radiation protection tasks under the direct supervision of a (Senior HP technician.)

3) Conclusion The'ir.spector concluded that there was some substance to these i two aliegations, but the licensee was aware of these inadequacies and was implementing appropriate corrective action.

e. Allegation'Concerning the Higher Priority of Production over ,

i. Radiological Safety *

1) Statement of Allegation The alleger stated, during the telephone call to the NRC on March-14, 1988, that the Plant Manager had stopped radiation protection training in RWP's, protective clothing, and personnel frisking techniques oecause the training was '

interfering with production. He further stated that the major problem with the licensee's organization was that the Manager, e Nuclear Licensing, Safety, Accountability & Security (NLSA&S) reported to the Plant Manager, whose primary concern was production. The alleger stated that the Manager, NLSA&S "was i.

not committed to safety and safety issues".

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2) Inspector Review The inspector conducted interviews with numerous licensee personnel, including plant workers, HP technicians, supervisors, and the Plant Manager.

Within the scope of this review, the following was found:

- As a result of NRC Inspection No. 70-1100/87-05, the licensee '

began to upgrade the Radiation Protection (RP) program and establish the required Radiation Protection procedures. One .

17 segment of these RP program upgrades was to establish a good RWP-program, with the required procedure and emp'loyee training. ,

Another segment of the RP program upgrades was to correct personnel frisking deficiencies and improve the protective clothing (PC) use in the Pellet Shop. These two elements of the RP program upgrades had been developed by the beginning of March, 1988.

Licensee contractors had developed draft RWP and PC procedures.

The contractors also developed and began training plant workers and supervisory personnel on the draft procedures. However, these procedures had not been reviewed or approved by the Plant Manager. .The Plant Manager stated to the inspector that he stopped the training on these two parts of the RP upgrade because he was not informed of the new procedures and new methods being planned in the RP program. The Plant Manager _ stated that management is in the process of reviewing these procedures and appropriate changes will be made prior to full implementation by September 1, 1988. The inspector stated that progress in this area will continue to be monitored during future inspections.

3) Conclusion Although weaknesses were noted in this area (delays in procedure approval by management and initial use of unapproved procedures),

specific important safety improvements in the radiation protection program and pellet shop equipment repairs are being undertaken by management. This allegation concerning management's lack of regard for safety was, therefore, not substantiated,

f. Allegation Concerning a Lack of Radiological Controls over Work  !

1) Statement of Allegation The inspector interviewed the alleger. The alleger stated that equipment was faulty and frequently spread contamination, that the HP stop work orders were ineffective, and that work involving non-routine radiation protection activities was poorly planned.

2) Inspector Review

, The inspector discussed each of these concerrs with the alleger.

- The alleger's concern about the faulty equipment and ineffective stop work orders-involved two pieces of equipment, the bulk dry furnace, and the powder preparation lif t No.1.

, (a) The bulk dry furnace creates a large accumulation of l

uranium oxide powder on the exit door to the furnace. The L alleger's concern was that the licensee was not responsive i L to the contamination concerns.

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7, 18 The bulk dry furnace had been identified to the inspector during NRC Inspection No. 70-1100/88-01, as an area which the licensee planned to use additional ventilation'and enclose a portion of the furnace to' reduce this contamination problem.

The' licensee had committed to periodically shut-down'this ,

operation and decontaminate the equipment until the planned modifications were completed. At-the time of the inspection,

. -the ventilation system had just been received on-site and was scheduled to be installed as soon as possible. Therefore, the inspector concluded that this allegation was not substantiated.

(b) During the first week of this inspection, the powder preparation (prep) lift No. I failed,.and a bucket of uranium oxide powder dropped and spilled. The HP technician on duty issued a stop work order and had the spill cleaned up. The alleger stated that the stop work order was cancelled the next day, but the powder prep lift was'not fixed.

When the spill occurred and the stop work order was issued, maintenance was called in to repair the lift. The maintenance personnel' determined that the failure of the lift was due to low oil (the lift uses a hydraulic system). Maintenance personnel added oil to the equipment, ensured that the pressure was appropriate, and informed HP that the equipment could be put back into service.

Further investigation of the lift failure by some plant personnel revealed that the lift was behaving erratically and falling down in a "jerking" motion. The HP technicians reissued a stop work order, and called maintenance in again.

During this inspection of the equipment, the maintenance personnel found that the inertial lock mechanism had not been installed properly. This deficiency was corrected im- .

mediately. When the lift was repaired, the stop work order I was removed, and the equipment was returned to service.

(3) Conclusion The inspector concluded that the stop work orders were effective.

This allegation was not substantiated. In addition, the alleger's concern over poor work planning could not be substantiated.

g. Allegation Concerning the use of a Broken Criticality Safe Cart

1) Statement of Allegation f

The alleger stated that a cart designed for criticality safety was broken and still being used.  ;

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2) Inspector Review The inspector interviewed the alleger. The alleger brought this condition to the attention of licensee management, and the cart.

.was immediately repaired. The alleger's concern.was that the cart may have been broken for some time and had not been

' identified as requiring repair.

3) Conclusion

. Th b allegation was not substantiated.

h. Allegation Concerning the Presence of Asbestos in the Hydrogen Analysis Room

1) Statement of-Allegation The alleger stated that there was asbestos in the hydrogen 4

analysis room.

- Since the subject of this allegation concerns non-radiological 4 aspects of the licensee's operation, the Operational Safety and l Health Administration (OSHA) Region 1 Office was notified of 4

this allegation on April 15, 1988.

i. Summary of Allegations - Management Review

[ The inspector discussed the allegations with licensee management. All i the previously discussed allegations were made by the same individual who informed the licensee's management that he notified the NRC of i .his concerns. The licensee stated that the alleger was provided an opportunity to discuss his concerns with licensee management, or the Nuclear Safety Committee Chairman. At the time of the inspection, the alleger had not communicated all of his concerns to licensee i management. The inspector confirmed this in discussions with the alleger.

- 11. Status of the Radiation Protection program Upgrades The inspector reviewed the licensee's response to the NRC's. enforcement action in a letter dated February 23, 1988. The inspector noted that action was initiated to address the violations. However, the inspector was unable to close any violations due to the slow rate of progress in completing the implementation of the proposed corrective actions.

Further, although the licensee's corrective acticos were specific in addressing each of the violations, it failed to provide plans for performing a comprehensive assessment to identify root cause problems in the program and implement corrective actions as appropriate.

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. 20 The inspector reviewed the'following radiation protection program upgrades:

-- Radiation Protection Procedures

- Training Program

- AirLSampling Program

- Bioassay Program

a. Radiation Protection Procedures Since the establishment of the Respiratory Protection program and procedures, and the Pellet Shop Contamination Control program (including the installation of some engineering controls and equipment repairs), as discussed in NRC's Confirmatory Action Letter (CAL 87-14), dated October 27, 1987, no additional progress has been made in the Radiation Protection program procedures. There still remains a high degree of uncertainty in establishing specific areas of the program. The licensee's rate of progress in this area will continue to be reviewed in future inspections.

b. Training Program Progress in the Training Program upgrades has been hampered by delays in the other Radiation Protection upgrades. The licensee's consultant has proposed a General Employee Training (GET) program which addresses ,

violations identified in NRC Inspection Report No. 70-1100/87-05.

• The licensee stated that annual retraining was due no later than mid-April in accordance with their license requirements. However, licensee representatives were uncertain as to whether the new GET training would be given by April 1988, in light of the observed delays in program procedure reviews and approvals. The inspector stated that training necessary to comply with 10 CFR 19, 10 CFR 20, and license conditions will be reviewed in conjunction with the program upgrades in this area during future inspections.

c. Air Sampling Program '

The. licensee plans to convert their air sampling program to 100% breathing zone air samplers in addition to the station fixed air sampling system.

Preliminary licensee data indicated that breathing zone air samples are an average of three to five times higher than station fixed air samplers. However, no statistical analysis was made at this time.

During the inspection, only certain work stations were covered with breathing zone air samplers. Licensee representatives stated that additional breathing zone air samplers were on order. The licensee plans to have the 100% breathing zone air sampler program in place by July, 1988.

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, 21 d, Bioassay Program Preliminary analysis of the bioassay dath (urinalysis, fecal analysis, and lung counting) was performed by the licensee's consultant and submitted to the licensee in February,1988. However, no further.

progress has been made in-this area.

The licensee's consultant recommended that three individuals be removed from the Pellet Shop due to high bioassay results. At the l

time of the inspection,'only two of the three individuals had been l removed from the radiologically controlled area. When the inspector f brought the third individual to the licensee's attention, he was removed from the Pellet Shop. This occurred on March 31, 1988.

All bioassay program results were expressed in micrograms of uranium-235.

The inspector requested records which demonstrate compliance with 10 CFR 20.103 requirements (i.e., MPC-hour calculations / evaluations).

This data was not available at the time of the inspection. The inspector stated that this matter will remain unrosolved pending review of the required records. (1100/88-03-13)

12. Exit Interview The inspectors met with the licensee representatives (indicated in Para-graph 1) at the conclusion of the inspection on March 4, 1988 and March 31, 1988. The inspectors summarized the scope and findings of the inspection.

No written material was provided to the licensee during this inspection.

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