ML20196C416

Insp Rept 70-0036/98-05 on 981102-06.Violations Noted.Major Areas Inspected:Review of Aspects of Licensed Operations, Training,Transportation Safety & Mgt Organization & Control

ML20196C416
Person / Time
Site:	07000036
Issue date:	11/24/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20196C364	List: ML20196C360 ML20196C388 ML20196C416
References
70-0036-98-05, 70-36-98-5, NUDOCS 9812020048
Download: ML20196C416 (12)

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I U.S. NUCLEAR REGULATORY COMMISSION ,

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. REGION 111  !

1 Docket No: 070-00036 License No: SNM-33 Report No: 070-00036/98005(DNMS)

Licensee: ABB Combustion Engineering, Inc.

Facility: Hematite Nuclear Fuel Manufacturing Facility Location: Hematite, MO 63047 Dates: November 2 - 6,1998 Inspector: John M. Jacobson, Resident inspector Paducah Gaseous Diffusion Plant Approved By: Kenneth G. O'Brien, Acting Chief Fuel Cycle Branch Division of Nuclear Materials Safety 9812O20048 981124 PDR ADOCK 07000036 C PDR

EXECUTIVE

SUMMARY

ABB Combustion Engineering, Inc.

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Nuclear Fuel Manufacturing Facility l NRC Inspection Report 070-00036/98005(DNMS)

This routine, announced inspection included a review of aspects of licensed operations, training, transportation safety, and management organization and control.

Operations e . Operations observed during the inspection were generally conducted in accordance with the goveming procedures. However, the inspector identified three examples of operations not complying with the posted nuclear criticality safety controls for the area.

All three occurrences appeared to be due to inattention to detail on the part of operators during routine operations. (Section 01.1)

• The licensee took appropriate prompt corrective actions and planned long-term scrubber system modifications to prevent recurrence of a contamination event in which uranium contamination was exhausted out of a stack on Building 240-2 and into the clear area of the plant. Surveys performed after the discovery of the contamination indicated there was no contamination tracked outside the restricted area of the site. The licensee promptly initiated decontamination activities to restore the affected area to normal conditions. (Section 01.2)

Trainina e The biennial refresher training for the radiation safety and nuclear criticality safety programs appeared to be thorough and included both theoretical and practical aspects of the programs. The examinations given after the training sessions to check the general proficiency of workers allowed unescorted access to the restricted area were challenging. However, the inspector noted that recent violations of the program  ;

l requirements identified by the NRC during observation of routine plant operations may i l indicate more frequent training in these areas is necessary. (Section 11.1) l l l Transoortation )

• Activities for loading fuel assembly shipping containers and truck trailers and preparing shipping papers for assembly transport to a reactor were conducted in accordance with applicable NRC and Department of Transportation (DOT) requirements. (Section T1.1) f e The inspector concluded that the licensee's program for ensuring that shipments conformed to the removable contamination and direct radiation requirements of 10 CFR 20,10 CFR 71, and the DOT regulations was adequate. (Section T2.1)

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' Manaaement Oraanization and Control

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• ; The timeliness of corrective actions for items identified during license-required quarterly 1

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. Inspections of the facility improved because of a new prioritization scheme and the initiation of weekly walk-arounds by senior management.LAs a result, the number of .

open items carried from one quarterly inspection to another was significantly reduced.

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I Report Details

1. Operations 01 Conduct of Operations i

01.1 Facility Tours and General Operations

' a. Insoection Scooe (880201

! The inspector toured various plant areas and observed ongoing facility operations and l

implementation of nuclear criticality safety (NCS) requirements in procedures and postings. In particular, the inspector reviewed aspects of the implementation of the following procedures:

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Operations Sheet 601.04, "Pyrohydrolysis and Process Cycle Operations"; '

Operations Sheet 1710.00, " Pellet integrity Examination"; and Operations Sheet 806.00," Recycle / Recovery Area Wet Scrubber."

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b. Observations and Findinas l i i Operations observed were conducted safely and generally in accordance with the i

goveming procedures. Procedure manuals were observed at numerous locations L throughout the plant and minor updates (Temporary Shop Instructions) were posted  :

l near the applicable work locations. Check sheets and inventory logs used with specific procedures were completed and available in the immediate area of the operation.  !

l The inspector noted three occasions, however, in which operators did not adhere to the NCS requirements listed on approved postings goveming the operation. On November 3 the inspector noted that the chain placed around the secondary filter fumace on the fourth floor of the Oxide Building (reflection control) was in contact with l- the surface of the fumace. Posting No.120, posted directly above the chain on the i fumace, required that the chains be maintained at least 6 inches from the surface of the ,

! fumace. The chain was apparently moved the previous night without the knowledge of l l the NCS staff during a filter changeout for another filter nearby. On November 4 the inspector observed that a cover for a micronizer hood on Line 2 of the Pellet Plant was not fully installed (only partially covered the opening on the top of the hood). Later that i same day, the inspector observed that no cover at all was placed over the opening on  !

top of a micronizer hood for Line 1 of the Pellet Plant when the hood was not in  ;

operation and a powder hopper was not in place, Posting No.104, Revision 3, posted

near the micronizer hoods, required that operators place white covers over the holes in a hood when hoppers were not in place to prevent ingress of water (moderation control) into the hood.

Upon identification by the inspector, the deficiencies were promptly corrected by the licensee. However, the three posting noncompliances identified by the inspector indicated a lack of attention to detail on the part of operators during routine operations.

l To preclude recurrence, the licensee performed additional training on the postirig requirements for the responsible operators. In addition, the licensee stated that l

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! permanent supports for the posts holding the chains for the fourth floor filter barriers l would be installed. The Director of Operations stated that an investigation team i comprised of management and workers was being assembled to address ongoing issues with compliance with procedures and postings to raise the level of performance after the negative observations made by the NRC in recent inspections as well as the plant's quality assurance group.

Safety Condition S-1 of Special Nuclear Materials (SNM) License No. SNM-33 authorizes the use of licensed materials in accordance with the statements, representations, and conditions in Chapters 1 through 8 of the application dated October 29,1993, and supplements and revisions thereto. Chapter 4, Section 4.1.5,

" Posting of Limits and Controls," of the supplement dated August 8,1997, requires, in part, that work and storage areas where SNM is handled, processed, or stored shall be posted with the nuclear safety limits and controls applicable to each area. The failure to ensure that the boundary chain for the secondary filter fumace was positioned in accordance with Posting No.120 and the failures to properly install micronizer hood j covers in accordance with Posting No.104, Revision 3, constitute examples of a Violation of License Condition S-1 (VIO 070-00036/98005-01).

c. Conclusions Operations observed during the inspection were generally conducted in accordance with the goveming procedures. However, the inspector identified three examples of operations not complying with the posted NCS controls for the area. All i

three occurrences appeared to be due to inattention to detail on the part of l operators during routine operations.

01.2 Followuo to Contamination Event Reoort

a. Inspection Scope (88020)

The inspector reviewed the circumstances surrounding a notification to the NRC l' pursuant to 10 CFR 70.50(b) of a discovery of uranium oxyfluoride particulate and uranyl l nitrate contamination in a non-contaminated area of the plant which caused access to l the area to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (Event Number 34835).

b. Observations and Findinos l

l. On September 24,1998, the licensee discovered a yellow residue on the asphalt driveway located between Buildings 230 and 240 (within the security fence for the site but in a normally clear area). The residue was discovered promptly after a rain storm.

Surveys of the area indicated that uranium contamination substantially above the licensee's action levels for clear areas of the plant was present. As a result of the discovery, the licensee restricted access to the area and began a series of surveys to j determine the extent of the contamination and then decontaminate the area. The i decontamination effort, which involved cleaning the stacks, roof, and driveway, and

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disposing of surrounding vegetation and dirt as contaminated waste, was continued until the areas met the applicable limits for contaminated or clear areas, at which time normal 3

access to the areas was permitted.

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The inspector reviewed the surveys (removable contamination smears and direct or l fixed radiation readings) taken after the discovery. The surveys indicated the extent of i i

the contamination outside of the contaminated area was confined to the stacks and roof of Building 240-2, tank and trailer next to Building 240-2, and the driveway and vegetation in between Buildings 240 and 230. Surveys of the guard house and parking lot near the restricted area all yielded results of removable alpha contamination of L 14 disintegrations per minute per 100 square centimeters or less, well below the clear

! area limit of 200 disintegrations per minute per 100 square centimeters. The surveys i indicated that none of the contamination had been tracked offsite.

The licensee's written report was submitted to the NRC on October 23,1998. The report identified that the cause of the event was the overflow of liquid from a nitrogen oxide scrubber used in the wet recovery process. The overflow occurred when an i

operator started the fill equipment to replenish the water in the scrubber and allowed the i equipment to continue operating while performing other duties. The contaminated liquid overflow entered the exhaust stack piping and eventually was exhausted as entrained droplets and particulates. The licensee's immediate corrective actions included installing a " dead man" switch for the scrubber fill system to ensure the system would l only operate when the start switch was engaged by an operator and providing training to l . the responsible operators to ensure the scrubber sight glass was constantly monitored i when filling. Long-term corrective actions planned included installing a scrubber level j alarm and actuator to cut off the fill system automatically and installing a larger liquid

separator upstream of the scrubber to prevent scrubber overfill from other potential l process upsets. The inspector concluded that the corrective actions taken and planned i i to prevent recurrence of a similar event were reasonable. l t

c. - Conclusions

! j The licensee took appropriate prompt corrective actions and planned long-term scrubber system modifications to prevent recurrence of a contamination event in which uranium

contamination was exhausted out of a stack on Building 240-2 and into the clear area of ,

the plant. Surveys performed after the discovery of the contamination indicated there i

! was no contamination tracked outside the restricted area of the site. The licensee l promptly initiated decontamination activities to restore the affected area to normal l conditions. ,

O1.3 increased Airborne Uranium Concentrations Near the end of the inspection, the licensee completed an analysis of recent trends in the sampling results for both personal lapel air sarnplers and fixed, general-area l samplers throughout the plant. The analysis indicated that for the previous 5-6 weeks, a

! significant upward trend in the concentrations of airbome uranium had occurred,

! although none 6f the monitored personnel were close to exceeding the licensee's administrative internal dose limit of 80 percent of the annual limit of intake for the monitoring year. The licensee planned to continue to analyze the data and investigate whether the increase was due to poor practices in handling the uranium onsite or due to equipment or ventilation problems. The inspector will track the licensee's response to the increase airborne uranium trend as an Inspector Followup Item (lFI 070-l 00036/98005-02).

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l 08 Miscellaneous Operations issues O8.1 (Closed) Event Report 34835: Release of contamination from stack on Building 240-2 l due to overfill of a nitrogen oxide scrubber. See discussion in Section 01.2. This event

! is considered closed.

j- 08.2 (Clos'ed) VIO 070-00038/98003-01a.b: Examples of procedure violation for failure to ,

appropriately store a hazardous material after it was identified by the licensee in a '

quarterly inspection and failure to perform weekly and monthly surveillances for selected equipment in the Oxide Plant. The licensee moved the hazardous material to a proper storage location and initiated changes to the plant's method of tracking and closing l items identified during license-required quarterly inspections (see Section C1.1). The

licensee also placed the weekly and monthly surveillances for the Oxide Plant l equipment (carbon dioxide system, ventilation systems, scrubber systems, etc.) into a i c maintenance work database. The inspector reviewed the recent surveillances and noted that the checks and preventive maintenance tasks had been performed at the required weekly or monthly frequency. As a result the corrective actions, the item is considered closed.

l 11 Conduct of Training l

l 11.1 Biennial Refresher Training

a. Inspection Scope (88010) l The inspector reviewed the recent biennial refresher training provided to plant staff l through observation of classroom training, review of exams and exam results, and

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discussions with plant personnel.

b. Observations and Findinas The biennial refresher training, required by Section 2.5 of Chapter 2 of the license l application, included classroom training sessions for both radiation safety and NCS training. Each employee allowed unescorted access to the restricted area was required to pass an examination after the applicable training session. The examinations were challenging and focused on requirements pertinent to routine operations in the plant. A score of at least 80 percent was required to pass the examinations. Remedial training was provided for those workers who did not pass the examination. A review of the l curricula and examinations indicated that the training covered both theoretical and

! practical aspects of radiation safety and NCS. Selected training records reviewed

' indicated the licensee was appropriately tracking the status of training for each worker in the plant.

l The inspector noted that while the biennial training for operators and other individuals was thorough, the number of criticality safety and radiation safety deficiencies identified by the NRC and documented in Inspection Report 070-00036/98004(DNMS) and this report raised concerns about maintaining the general proficiency and awareness of these program requirements on the part of the plant population between the 2 year 4 review sessions. The NCS specialist indicated that he had a similar concern and

planned to develop smaller training sessions to be conducted with specific work groups e

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out in the plant to reinforce the classroom training with in-field training on a more L . frequent basis.

c. - Conclusions The biennial refresher training for the radiation safety and NCS programs appeared to

! be thorough and included both theoretical and practical aspects of the programs. The E

examinations given after the training sessions to check the general proficiency of l ' workers allowed unescorted access to the restricted area were challenging. However,-

the inspector noted that recent violations of the program requirements identified by the  !

NRC during observation of routine plant operations may indicate more frequent training l in these areas is necessary.

' T1- - Transportation Safety T1.1 Preoaration of Fuel Assemblies for Shioment

a. :Insoection Scope (86740) l The inspector. observed the preparation of selected fuel assembly containers designated i for shipment near the end of November 1998. In particular, the inspector reviewed the l l loading requirements in NRC Certificate of Compliance (CoC) No. 6078 and the i licensee's implementing procedure, Operation Sheet No. 3400.00, " Package Pressurized Water Reactor (PWR) Fuel Assemblies."

' b. Observations and Findinas While the inspector was onsite, the licensee was preparing fuel assemblies for shipment to a PWR using the approved 927C1 shipping containers. The containers had recently been refurbished in accordance with a general review and NRC-approved update to the l CoC initiated after the licensee identified problems with container modifications and

' previous versions of the CoC. The inspector reviewed the loading procedure and -

l observed selected activities in Building 230 where the fuel assemblies are loaded.' The container checks, assembly support, and installation of container hardware for shipping all appeared to be in conformance with the CoC and procedural requirements. In

addition, the inspector noted that loaded containers stored in the back of Building 230 conformed to the NCS spacing and height restrictions.

The inspectbr observed two trailers that had been loaded with fuel assembly shipping containers in preparation for transport. The containers were appropriately labeled and braced as required by 10 CFR 71 and the Department of Transportation (DOT)

- regulations. Shipping papers prepared for the shipments contained the bill of lading with correct identification of container contents, shipper's certification, exclusive use requirements, and emergency response information, as required by DOT regulations. In p addition, the inspector noted that the trailers were appropriately placarded for the L' ' shipment.

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c. Conclusions '  !

i l Activities for loading fuel assembly shipping containers and truck trailers and preparing ,

shipping papers for assembly transport to a reactor were conducted in accordance with applicable NRC and DOT requirements.

.T1.2 " Transoortation Surve.y.g i l a. Inspection Scope (86740)

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The inspector reviewed surveys performed during September and October 1998 of various types of radioactive packages received at the facility and various radioactive packages approved for shipment.

' ' b. , Observations and Findinos

The inspector reviewed the results of surveys' performed for incoming and outgoing j shipments of radioactive materials.~' Results for removable contamination were all well i below 200 disintegrations per minute per 100 square centimeters. - Results for direct )

radiation readings were well below 200 millirem per hour on contact with t_he package i and 10 millirem per hour at 1 meter from the package surface or 2 meters from the truck i depending on the type of shipment.

- c. Conclusions j The inspector concluded that the licensee's program for ensuring that' shipments conformed to the removable contamination and direct radiation requirements of l 10 CFR 20,10 CFR 71i and the DOT regulations was adequate.

l Management Organization and Controls I

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L . C1.1 Manaaement Audits and Inspections

a. Insoection Scope (88005)

L The inspector reviewed the results and corrective actions for the quarterly radiation and criticality safety inspections performed by plant management during the first three quarters of 1998. The inspections were required by Section 2.8 of the license application. In addition, the inspector reviewed recent weekly inspections or walk-arounds performed by the Directors of Operations and Regulatory Affairs.

' b. I Qhservations and Findinas L in inspection Report 070-00036/98003(DNMS), the NRC identified (VIO 070-L 00036/98003-01b) that timely corrective action was not taken by plant staff for a

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violation of the' plant hazardous materials procedure identified during the quarterly inspection for the. fourth quarter of 1997. The inspector's review of the quarterly inspection results indicated that a significant number of items (46) were carried over from the fourth quarterly inspection of 1997 to the first quarterly inspection of 1998. In

[. addition, the inspector noted that there was no prioritization of corrective actions for the items identified. The significance of the items ranged from safety issues and violations 9

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of procedures to minor housekeeping issues and recommendations for improvements in various areas of the plant. As a result, the corrective actions for the items identified during the quarterly inspections were not focused to ensure items requiring immediate attention were promptly fixed while those whose safety or regulatory significance were minimal were tracked to completion or corrected on a long-term schedule. j The licensee developed a revised methodology for documenting and tracking corrective actions for open items as a result of the issues raised by the NRC and in response to the violation. In particular, the licensee initiated a new scheme for prioritizing open items from quarterly inspections. The new scheme used a color code to identity the I I

significance of items and time-frame required for corrective actions. Red items required immediate attention; yellow items required corrective actions to be completed within 4 weeks of the inspection; and green items could be completed anytime before the next

quarterly inspection or based on a schedule provided to the Director of Regulatory ,

l Affairs. The inspector noted that the color code scheme provided a focus for corrective I l actions based on the significance of the items and appeared to be effective based upon

! the decrease in the number of open items carried over from quarter to quarter. 46 for l the first quarter of 1998, 21 for the second quarter, and 5 for the third quarter.

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The plant management also initiated a new policy requinng the Directors of Operations i and Regulatory Affairs to perform weekly inspections or walk-arounds of the facility. i l During these weekly inspections, the senior managers followed up on the corrective j

! actions for items from the previous quarterly inspections as well as identifying and l tracking closecut for items noted during the Directors' walk-arounds. The  !

l implementation of these weekly inspections appeared to have improved the visibility of )

management in the plant as well as the timeliness of corrective actions for deficiencies identified by the formal quarterly inspections. j

c. Conclusions The timeliness of corrective actions for items identified during license-required quarterly inspections of the facility improved because of a new prioritization scheme and the

! initiation of weekly walk-arounds by senior management. As a result, the number of open items carried from one quarterly inspection to another was significantly reduced.

1 V. Manaaement Meetinas X1 Exit Meeting Summay The inspector met with plant management and other sta4 throughout the inspection and on November 6,1998, for the exit meeting. The inspector summarized the observations and findings of the inspection. The licensee management acknowledged the findings and indicated an investigation team was being formed to address the generic aspects of continued procedure and posting noncompliances in the plant.

The licensee did not identify any of the information discussed at the meetings as proprietary.

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PARTIAL LIST OF PERSONS CONTACTED Licensee M. Eastburn, Nuclear Criticality Specialist -

K. Funke, Supervisor Health Physics l K. Hayes, Safety Engineer l G. Page' Director of Operations E. Saito, Health Physicist B. Sharkey, Director of Regulatory Affairs INSPECTION PROCEDURES USED IP 86740: Inspect!on of Transportation Activities IP 88005: Management Organization and Controls IP 88010: Operator Training / Retraining IP 88020: Operations Review / Regional Criticality Safety ITEMS OPENED, CLOSED, AND DISCUSSED Opened 070-00036/98005-02 IFl Response to a significant upward trend in airbome uranium concentrations identified during the inspection.

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'070-00036/98003-01a,b VIO Failure to store hazardous materials properly after i identification by the licensee and failure to perform weekly and monthly oxide equipment surveillances.

070-00036/98005-01 VIO Failure to comply with posted nuclear criticality safety controls for micronizer hoods and an oxide filter barrier.

34835 LER Event report for contamination incident requiring access to clear area of the plant to be restricted more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Discussed None.

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LIST OF ACRONYMS USED ;

E CFR- . Code of Federal Regulations CoC Certificate of Compliance j DOT . ~ Department of Transportation '

DNMS. Division of Nuclear Materials Safety "

LER- Licensee Event Report-NCS'- Nuclear Criticality Safety NRC Nuclear Regulatory Commission PDR . Public Document Room PWR- Pressurized Water Reactor

'SNM Special Nuclear Material VIO Violation t'

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