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Insp Rept 70-0025/86-02 on 860314-17.No Violation or Deviation Noted.Major Areas Inspected:Mgt Organization, Operator Training & Retraining,Criticality Safety,Maint & Surveillance
	ML20197C294
Person / Time
Site:	07000025
Issue date:	05/06/1986
From:	Brock B, Thomas R, Zurakowski P; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	;
Shared Package
ML20197C284	List: ML20197C278; ML20197C294;
References
	70-0025-86-02, 70-25-86-2, NUDOCS 8605130301
	Download: ML20197C294 (10)
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U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-25/86-02 Docket No. 70-25 License No. SNM-21 Safeguards Group: I Licensee: Rockwell International Corporation Rocketdyne Division Atomics International 6633 Canoga Avenue Canoga Park, California 91204 Facility Name: Headquarters Site and Santa Susana Field Laboratory Inspection at: Headquarters Site and Santa Susana Field Laboratory Inspection Conducted: March 14-17, 1986 Inspectors: fI B. L. Brock, Fuel Facilities inspector Date Signed

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. R. Zurakowski, Radiation Specialist AE

.Da e igned Approved .

R. D. Thomas, Chief t Signed _

Nuclear Materials Safety Section 4

Summary:

Inspection on March 14 17, 1986 (Report No. 70-25/86-02)

! : Areas Inspected: A routine unannounced safety inspection was conducted of management organization; operator training and retraining; criticality safety; operations review / deactivation-decontamination; maintenance and surveillance; radiation protection; transportation / radioactive waste management /10 CFR Part 61; environmental protection; and emergency preparedness.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, i 83890, 88025, 83822, 86740, 88035, 84850, 88045 and 88050 were covered.

Results: No violations or deviations were identified in the twelve areas inspected.

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DETAILS

1. Persons Contacted

R. D. Barto, Director, Security

M. E. Remley,' Director, Nuclear Safety and Licensing

R. J. Tuttle, Manager, Radiation and Nuclear Safety F. H. Badger, Health and Safety Engineer J. D. Moore, Health and Safety Engineer V. J. Schaubert, Manager, Nuclear Safety and Licensing J. A. Martin, Engineer-in-Charge D. Allen, Staff Assistant D. Harrison, Staff Chemical' Engineer J. W. Rowles, Health and Safety Specialist F. C. Schrag, Member Technical Staff R. M. Michlich, Senior Staf f Engineer for Training D. C. Campbell, Member Technical Staff R. Wilson, Member Technical Staff S. A. Peck, Department Associate E. Martini, Training Specialist

Denotes those attending the exit meeting.

2. Management 'Irganization and Controls Section 9 of KRC License SNM-21 incorporates Part 1 of the licensee's application anc supplements dated October 29 and December 17, 1982, and March 2, 7, May 29 and June 12, 1984 as license conditions.

A. Organization.1 Structure Section 11.3 of the license application requires certain organizational divisions of responsibility to provide a check and balance system in the important areas of plant safety.

The licensee's organizational structure is currently undergoing revision. The independence of safety organizations f rom operations is planned to be retained. The retention of this separation of functions will be reviewed during the next inspection (86-02-01).

B. Procedure Controls Section 11.3.4 of the license application requires that changes in established procedures must be authorized in advance by appropriate management.

The procedures for the Fermi decladding project were still being revised. Two check runs were made to evaluate the safety and adequacy of decladding by the grinding method using the centerless grinding system. The inspector's review of the licensee's use of

, the changed procedure found the licensee had asrured the required review and approval of the procedure before its implementation. The

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. 2 Iow irradiation assemblies used in the two separate check runs permitted low personnel exposures in subsequent in-cell adjustments of equipment identified as necessary by the check runs. The review of the approval of the Fermi operation procedures (86-01-01) will remain open pending the completion of the procedures.

No violations were identified.

3. Operator Training and Retraining Condition 14 of the current liceuse requires that prior to unsupervised work with special nuclear material appropriate formal training shall be given in criticality and/or radiation safety.

A. A review of the licensee's master training records and discussions with Training, Radiation and Nuclear Safety, and Building 020 Operations personnel disclosed that all persons had received the required training prior to working with licensed material. It was found by the inspector that discrepancies discovered during the last inspection in the master training records had been corrected.

However, a new type of discrepancy in the master training record was discovered during this review. This involved the transfer of two persons from another Division to Building 020. It was found that these persons had received appropriate training in the use of respiratory protective devices prior to the transfer. However, the master training records were not properly updated af ter the transfer. Secondary records did verify that appropriate training had been conducted. Item (85-01-02) will remain open for further review.

B. The inspector noted that the licensee is beginning to provide training in criticality safety analysis to additional persons to develop alternates for coverage during the absence of principal l analysts and principal reviewers.

No violations were identified.

4. Criticality Safety Section 2.7 of the license application requires that prior to initiating a project involving potential hazards, authorization must be obtained from the appropriate Department Director and from designated Safety and/or Criticality Safeguards personnel in the Health, Safety and Radiation Services Departuant.

A. Nuclear Criticality Safety Analysis Section 4.1.3 of the license application requires the completion of a Nuclear Safety Analysis for the Fermi f uel decladding operation.

The inspector's review of the status of the Fermi fuel decladding operation indicated that the Criticality Safety Study (CSS) and the Nuclear Safety Analysis (NSA) were essentially complete. They were

3 being circulated for final signature after the recommendations resulting from the independent reviews had been incorporated.

, B. Criticality Calibrations and Monitoring Systems Section 2.1.1.1.3.5 of the radiological contingency plan requires *

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the maintenance and calibration of the Accidental Criticality Alarm System (ACA), a part of the Radiation Alarm System (RAS), at three month intervals.

4 The inspector's review of all the ACAs, including the one on the !

roof of the hot cell, found all four had been calibrated at three month intervals as required.

No violations were identified.

5. Operations Review Section 2.1 of the license application requires the licensee to comply with all the requirements of the regulations, to operate the facilities in a safe and efficient manner and within the requirements of all license t

conditions under which the activities are authorized.

J A. Conduct of Operations l License Condition 25 requires that the licensee follow the general decommissioning plan submitted in the enclosures to the letter dated March 15, 1978.

] (1) Building 055 Nuclear Materials Development Facility (NMDF) ,

I (a) The inspector reviewed the status of the deactivation /

decontamination of Building 055 and noted the condition of the building was essentially unchanged since the last inspection. The licensee indicated that Department of ,

Energy (DOE) funding for further work is being planned essentially on a month to month basis with all hardware

. scheduled for removal by the 4th quarter CY '86. The licensee plans to do the final survey in CY' 87.

(b) The NaK bubbler safing operation is expected to start within two weeks. The safing operation is expected to start May 1, 1986 and run about two months. The essentially automatic process will run full time (24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day and 7 days per week) to complete the processing of the ten units in storage. The preliminary surveys of the NaK bubbler inlet and output ports indicate the presence i of minimal amounts of plutonium.

(2) Building 020 Rockwell International Hot Laboratory iRIHL1 _

i 1 (a) The inspector observed that Cell 1 of the RIHL still L contains the By-Product Utilization Shipping System (BUSS)

. 4 mockup cask. The cask's thermal characteristics evaluation is continuing.

(b) The centerless grinders have been installed in Cell 2.

The check runs identified needed equipment adjustments and process changes to properly handle the U-Zr fines generated by the process. The use of additional shielding (lead) to lower the dose from barrels of waste presented another problem. Specifically the lead is listed as a hazardous material and now affects the planned packaging of the processed waste (see Section 8.A.). No Fermi processing activities were underway during the inspection.

(c) The Cell 3 laser was nearly ready for routine operation.

The holdup now appears to be related to shipments of the Fermi fuel in appropriate containers. The shipments are dependent on approval of the container for which a current Certificate-of-Compliance is needed.

(d) Cell 4 is scheduled to be used for fuel assembly shroud removal using a band saw. The cell contains a water trough used for checking for leaks in welded containers.

The licensee is required to keep the trough covered to preclude the inadvertent addition of the Fermi rods to the trough.

(e) The hot storage room of the RIHL has been cleaned up and is used as a cold storage room. The few hot spots detected by the licensee which were not readily removable were painted over. The location of these hot spots were identified by a sign painted on the wall where each hot spot area was located. Whe0 the whole building is decontaminated for release to unrestricted use the licensee will remove the contamu.ation by a method more successful than that used previourly.

(f) The alpha glove box is still onsite but no use is projected for it. Efforts are still oriented towards finding a potential user.

No violations were identified.

6. Maintenance and Surveillance Testing Section 9 of NRC License SNM-21 incorporates Part 1 of the licensce's application and supplements dated October 29 and December 17, 1982, and March 2, 7, May 29 and June 12, 1984 as license conditions.

A. Air flow Testing License Condition 18 requires that the licensee check the direction of the air flow in the hot cell facility each month. When adverse air flows are detected, corrective action shall be taken and documented.

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The inspector learned that the ventilation system servicing had been '

completed. The performance produced the required airflows. The normal performance of the system closes item 85-06-01. The inspector also Icarned that one ventilation fan had excessive vibration. An order had been written to acquire a replacement fan.

The overall plan is to replace all the fans in turn since they have been in service the same length of time. A backflow damper will also be replaced. The licensee's annual review of the air sampling locations resulted in no changes. !

B. Sewage Treatment Plant The diversion valve on the plant effluent is designed to fail safe by diverting the effluent to an unlined temporary storage pit during control system upsets. The inspector observed that a control system upset resulted in a diversion of ef fluent to the storage pit during .

the'veek before the inspection (see Section 9). The rate of control system upsets will be reviewed during the next inspection (86-02-02). ;

No violations were identified.

7. Radiation Protection l Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20. !

! A. Tour of Facilities l

(1) The NMDF (Building 055), RIlfL (Building 020), Sewage Treatment Plant and the associated diversion basin, and the Respiratory Protection Maintenance and Training Laboratory were visited by

the inspector. No violation of good health physics or other

! NRC requirements were noted during the tour. A sample of soll

from the bottom of the diversion basin was taken for an ,

j -independent NRC gamma spectrometry measurement. The result of l the independent measurement will be included in the next ,

inspection report.

(2) The open item (86-01-02) involving health physics aspects of the NaK bubbler project was reviewed. It was found that the .

! assembly of the apparatus for containing the hazardous chemical reactions had not yet been completed. It is anticipated that j the assembly of the apparatus will be completed within the next month and the decontamination / deactivation project will commence soon af terwards. As was pointed out in the previous report (70-25/86-01) the NaK bubblers contain both sodium and potassium metal with possible plutonium contamination. This i item will remain open and will continue to be reviewed during l the next inspection. ,

f B. External Exposure e

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. 6 The review of the 1st quarter 1986 radiation exposure records disclosed no exposure in excess of regulatory limits. The highest quarterly whole body exposure noted was 340 mrem. The highest finger ring reading was 450 mrem. All visitor film badge readings were at the minimum level of detection.

C. Internal Exposures The licensee utilizes a bioassay program from U. S. Testing Company of Richland, Washington. A review of the available records for the 1st quarter disclosed no internal exposures exceeding licensee administrative limits or regulatory limits. During the 1st quarter of 1986 the licensee submitted 16 samples for plutonium analyses and 53 samples for fission product analyses. Of the samples submitted 45 results have not yet been received. These records will be reviewed during the next inspection (86-02-03).

D. Non-Reportable Incident Review Three non-reportable incidents which occurred during the 1st quarter t of 1986 were reviewed. No trend toward poor health physics practices was indicated. Each incident was handled by the licensee in an appropriate and expeditious manner. Only one of the three required a urine sample be submitted for a bioassay analysis. This incident involved an inadvertant stoppage of breathing air to an

] airhood while a licensee employee was working in Cell #4. The workman immediately exited the cell and a nose wipe was taken. No activity was found on the wipe. The bioassay is one slated for review during the next inspection (see section 7.C above).

No violations were identified.

8. Transportation / Radioactive Waste Management /10,CFR Part 61 i

Annex "B" of the current license incorporates guideliaes for release of equipment and facilities for unrestricted use. 10 CFR Part 20.301 to Part 20.401 regulates the disposal of waste. 10 CFR Part 61 requires that all radioactive waste prepared for disposal is classified in accordance with Section 61.55 and meets the waste characteristics requirements in Section 61.56.

10 CFR 20.311(d)(3) requires that licensees who transfer radioactive waste to a land disposal facility or licensed waste collector shall conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56.

10 CFR Part 71 regulates the packaging and transportation of radioactive

. material.

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A. Waste Management

! The disposal of waste generated by the decladding operations in the RIHL was again discussed with the Staff Chemical Engineer in charge j of writing and executing the detailed written procedures necessary L

7 to carry out the disposal operation in a safe and efficient manner.

The discussion centered around the Fermi fuel decladding operation.

This decladding operation requires that the zirconium cladding be removed by remote in-cell grinding of the fuel pins on a centerless grinder. The resulting grinding fines consist of zirconium, uranium, and fission products. These products are hazardous from both a pyrophoric and a radiological viewpoint. The licensee proposes to disperse the grinding fines in a solid matrix of Earth-Tite within a 12 gallon drum. This unit is then to be centered in a 55 gallon DOT specification drum and surrounded by concrete and steel shielding. The original plans called for a concrete and lead shield around the'12 gallon container, llowever, a recent ruling by EPA has classified metallic lead as a hazardous substance subject to additional controls prior to burial at a commercial of federal disposal site. Extensive testing by the licensee has shown that the pyrophoricity of the zirconium-uranium fines are well controlled at the low concentration of the fines in the Earth-Tite matrix. However, the change from lead to steel shielding has not yet been fully evaluated. Calculations indicate that full compliance with State and Federal guidelines and regulations can be achieved. However, the Staff Chemical Engineer feels that a trial run should be made with actual " hot" Fermi waste to verify the calculations. If the resulting package did not meet the appropriate guidelines and regulations changes would then be made to the shielding and/or waste concentration to reduce the external exposure hazard in subsequent packages. The licensee's progress in this area will be reviewed during the next inspection item (86-01-01) will therefore remain open.

B. Transportation and Part 61 Discussions with the Manager, Nuclear Safety and Licensing disclosed that no shipment of radioactive material under NRC jurisdiction had occurred since the last inspection. Further discussions with this Manager also disclosed that he was well aware of the specific requirements of 10 CFR Parts 20, 61 and 71 that applied to the licensee's operation. This discussion centered particularly around 10 CFR Part 61.

No violations were identified.

9. Environmental Protection Title 10 of the Code of Federal Regulation, Part 20.106 " Radioactivity in Effluents to Unrestricted Areas" requires that licensees control their operations to preclude releasing radioactive material in concentrations exceeding the limits specified in Appendix B, Table II of Part 20.

A. The inspectors observed that the licensee's temporary diversion pit for the sewage treatment plant contained recently diverted plant effluent. The recording chart indicated a system alarm and effluent diversion occurred five days before the inspection. This followed an apparent alarm and 19 hour2.199074e-4 days 0.00528 hours 3.141534e-5 weeks 7.2295e-6 months effluent diversion three days earlier.

These two periods of ef fluent diversion apparently resulted in the

. 8 liquid observed in the pit. A sample of this liquid was analyzed by the licensee and the activity was below NRC release limits. An NRC sample was taken from the mud at the waterline in the pit. It was dried, milled, and sieved. The results of NRC's independent analysis of the sample will be included in the next inspection report.

No violations were identified. -

10. Emergency Preparedness License Condition 24 requires the licensee to maintain and execute the response measures of the Radiclogical Contingency Plan submitted to the Commission on August 28, 1981, as revised on March 3, 1982.

Additionally, Appendix A to the Radiological Contingency Plan states that the Master Emergency Plan has be.en approved as part of the license.

The inspectors review of fire extinguishers found they had been inspected monthly as required. Housekeeping in the buildings visited (Buildings 020 and 055) was good. The floor covering in the corridor in the RIHL (Building 020) was being replaced and the new floor covering was being covered with plastic to facilitate keeping it clean.

No violations were identified.

11. Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1.

The topics discussed included:

No violations were identified.

Status of previous open items Closed 85-06-01 Ventilation system performance Open 85-01-02 Training records accuracy 86-01-04 Sampling unlined diversion pit 86-01-01 Review approval of Fermi procedures 86-01-02 Review NaK bubbler Pu residue measurements 86-01-03 Review Fermi waste container dose control N_ew 86-02-01 Review the independence of the safety organization from operations 86-02-02 Review diversion pit control system alarm rate 86-02-03 Review first quarter bioassay results

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Organization changea , j Building 020 operations Status of Building 055 deactivation / decontamination Status of NaK bubbler safing operation Lock for temporary stortge ' pit drain valve Status of Fermi vaste h ndling .,

The licensee agreed to put a lock on the temporary storage pit drain valve. The licensee acknowledged the need for retaining depth in the area of criticality safety, f i v"

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ML20197C294

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