ML20203A089

Insp Rept 70-1201/97-06 on 971103-07.Violations Noted:Major Areas Inspected:Licensee Operations,Mgt Controls,Training, Environ Protection,Transportation & Waste Mgt Programs

ML20203A089
Person / Time
Site:	07001201
Issue date:	12/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203A076	List: ML20203A072 ML20203A082 ML20203A089
References
70-1201-97-06, 70-1201-97-6, NUDOCS 9712110275
Download: ML20203A089 (28)

Text

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l U. S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.. 70-1201 License No. SNM-1168 Report No. 70-1201/97-06 Licensee: Framatome Cogema Fuels, Inc.

Facility: Lynchburg Manufacturing Facility location: Lynchburg. VA Dates: November 3-7, 1997 Inspectors: D. A. Ayres, Senior Fuel Facility Inspector W. B. Gloersen, Senior Fuel Facility Inspector Approved by: E. J. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 2 Nk21{$$

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EXECUTIVE

SUMMARY

B&W Fuel Company NRC Inspection Report 70-1201/97-06 This unannounced inspection focused on the observation and evaluation of the licensee *s operations, management controls, training, environmental protection transportation, and waste management programs. The report covers a one week period and includes the results of inspection efforts of two regional fuel facility inspectors.

Based upon the results of this inspection. the licensee's operations.

training. transportation, environmental protection and waste management programs were acceptable. Violations of license requirements were found in the area.; of audits and proceuural controls. The inspection identified the following aspects of the program as outlined below:

Plant Ooerations e The overall conduct of operations appeared to be in accordance with written procedures and posted safety rules.

• Despite a significant increase in the number of projects, the licensee's configuration control practices have improved.

Manaaement Oraanization and Controls e With one noted exception, changes to the licensee's operating and safety 3rocedures were being approved as required. This one procedure had not Jeen approved by the Manager. Safety and Licensing and was noted as a Non-Cited Violation.

e The semi annual safety audits performed .1 the first half of 1997 did not meet th license requirements for audit scope. Further improvements are needed Dy the licensee to ensure that independent auditors provide adequate documentation of the auJit reviews and that all license requirements are thoroughly covered. Notice of Violation 70-1201/97-06-02 was issued regarding these deficiencies.

e The performance of the Safety Review Board was adequately meeting the license requirements for reviewing safety issues.

Environmental Protection e The licensee's sampling program was consistent with the requirements in Section 5.2 of the License Application and licensee procedures.

e Gross beta analyses were above licensee action levels in certain soil, water, and vegetation samples collected in 1997.

2 Waste Manaaement e The licensee had implemented an effective program to monitor and control gaseous radioactive effluents and to maintain the radioactivity released l in those effluents to quantities less than the License Application limit l and concentrations which were below the limits specified in 10 CFR 20 for j release of radioactive material to unrestricted areas e The licensee's management controls of liquid waste did not take into consideration the solubility of uranium in the water of the retention '

tanks before the water was transferred to the municipal water treatment facility, e The licensee's controls and procedure 3 for the solid waste management program were acceptable and capable of accomplish; its safety objectives.

Transnortation e The procedures and licensee activities related to the Jackage preparation, loading, operating, and maintenance of the Model B paccages generally implemented the requirements of the Certificate of Compliance, o The licensee's corrective actions to correct past shipping problems seemed reasonable, however, similar problems had been identified after the implementation of the corrective actions.

Trainina e The licensee's General Employee Training included all of the topics required by the License Application and safety training procedure SL-1140.

e The General Radiation Worker training provided to Lynchburg Marufacturing Facility (LMF) employees meets license and procedural requirements.

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REPORT DETAILS

1. .Sjummary of Plant Status During the inspection, the Lynchberg Manufacturing Facility (LMF) of Framatome Cogema Fuels. Ire. was operating its rod loading area under a normal schedule. The service equipment refurbishment facilities (SERFS) were continuing to decontaminate large tanks in SERF-3 and recondition mechanical reactor components in SERF-4. Packaging of low-level contaminated waste from LMF was being performed at SERF-2.

2. Safety 00erations

a. Plant Operations (88020) (03)

(1) Conduct of Operations (03.01)

(a) Insoection Scoce Reviewofokerationsinthepellethandling. rod loading. SE F. and outdoor storage areas was conducted for adherence to regulato"Y requirements.

(b) Observations and Findinos The inspector toured the facility to observe the general condition of potentially contaminated equipment storage and specific adherence to safety requirements. Outdoors, the inspector observed the large number of containers awaiting decontamination and/or refurbishment at one of the SERF facilities.

The inspector also observed a number of large above-ground tanks (-25.000 gallons each) and Sea-Land containers being stored at the back of the controlled area on the west side of the grounds. ihe inspector observed the radioactive material tags present on those items that were considered slightly contaminated. The inspector found no deviations from regulatory requirements with regard to material stored outdoors.

Despite the large number of containers and vessels outdoors, the inspector observed that some of the storage trailers. 3articularly those that stored scrap fuel pellets. had Jeen removed from the site. The inspector found that the licensee was making progress in cleaning out and removing all old storage trailers not designated for decontamination at one of the SERF areas. The inspector also observed that the old 48-inch UF6 cylinders that contained heels, and were stored on a pad at the southwest corner of the site, had been removed.

2 The inspector observed the pellet loading operations, fuel assembly storage areas. and pellet receiving truck bay for compliance with posted safety instructions. The inspector found that postings were

. generally being followed adequately. The inspector found a potential conflict between the NCS posting and the posted local safety rules. The former allowed horizontal storage of loaded rods at a height from 12 inches to 60 inches above the floor. The latter allowed storage from the floor to 60 inenes above the floor. The twelve inch buffer zone from the floo:-

listed in the NCS posting was Intended to negate the potential moderating effect of the concrete in the floor. The inspector notified licensee management of this potential conflict and the local safety rules were corrected.

The inspector observeJ another area where the posted local safety rules for fuel rod scanning stated that e list of qualified operators would be posted nearby.

The inspector found that the posted qualified operator list still included an operator that had retired a few months earlier. and was no longer considered a qualified operator. The inspector notified the licensee management and a revised qualified operator's list was promptly posted.

(c) Conclusions The overall conduct of operations appeared to be in accordance with written procedures and posted safety rules. Some additional attention to details was still warranted. -The licensee had made progress in removing unnecessary stored equipment and debris from the site.

(2) Facility Modifications and Configuration Controls (03.02)

(a) Insoection Scone The analysis and documentation of facility modifications performed or aroposed in 1997 was aviewed for compliance wit 1 procedural requirements.

(b)-- ' Observations and Findinas-The inspector observed that 25 proposed facility changes had been initiated thus far in 1997. Of these, 15 had been completed, one had been canceled, and the other nine were still in various stages of the review cycle. -The inspector reviewed a select sampling of the projects and found that the documentation and management review of each project

3 met the licensee's procedural requirements. The inspector also observed the results of some of the com)leted projects that wero deemed to be the most risc signift ant and associated with licensed material. Tne inspe tor found that the final installed configurations matched the approved designs.

(c) Conclus'ans Despite a significant increase in the number of projects, the licensee's configuration control practices hav< improved since the last inspection of this program area in February 1997. The licensee is adequately meeting license and procedural requirements.

(3) Follow up on Previously Identified Issues (03.08)

(a) Insnection Scone The corrective actions taken by the licensee in the '

response dated May 27, 1997, to VIO 70-1201/97 03-01 were reviewed for completion and adequacy.

(b) Observations and Findinas Violation 70-1201/97-03-01 was cited for failure to comply with posted Nuclear Criticality Safety (NCS) requirements conccrning the storage of moderating-materials in the fuel assembly storage area. The inspector h3a found appr ,ximately 100 nylon straps being temporarily stored on the catwalks between fuel assen.blies despite the NCS posting stating that moderating materials must not be stored there. The response to the NOV indicated that licensee operations personnel did not realize that nylon was a moderating material. The response also indicated that management i failed to adequately provide oversight of the area to ensure strict compliance with the posting. The corrective actions to be taken included implementing a weekly inspection of areas with NCS postings to ensure compliance, and t Nining licensee personnel on identifying moderating materials. The ins)ector

, observed the licensee s records of the weecly NCS audits and found thea to be adequate. The inspector observed a general employee training session and found

. that moderating materials were discussed. The inspector also observed the fuel assembly storage area and found no extraneous moderating materials.

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4 (c) Conclusions The corrective actions to V10 70 1201/97 03-01 were considered adequately implemented. This item is coinidered closed,

b. Management Organization and Controls (88005) (05)

(1) Procedure Controls (05.02)

(a) Insnection Stone

The licensee's system for approving changes to l

procedures was reviewed for consistency with license requirements.

(b) Observations and Findinas The inspector reviewed a sampling of safety and operating procedures to determine compliance with license requirements. The inspector found that all safety procedures were properly approved per the licensee's safety procedure change requirements (SFPRs).

The inspector observed a sampling of manufacturing procedures to determine the adequacy of their review and approvals by management. The inspector found that manufacturing procedures were typically approved by the Process Engineering Manager, the Fuel _

Manufacturing Manager, the Product Quality Manager, and the Safety and Licensing Manager. The inspector found one procedure for reworking fuel rod welds that had not been approved by the Safety and Licensing Manager. Section 2.6 of the License Application requires that.

• Written procedures for the conduct of specific operations. ..shall be reviewed and approved by appropriate production management and Manager.

Safety and Licensing." Thus, manufacturing procedure MA 458 " Fuel Rod Weldment Rework." Revision 19 dated January 7. 1997, did not meet the license requirement for approval of operating procedures, The inspector observed documentation that the licensee had recently undertaken an effort to identify all discrepancies in its procedure approvals. Procedure'MA-458 is an infrequently used repair procedure and was overlooked in the licensee's review efforts. The inspector found the incomplete approval of procedure MA-458 to tv.! an isolated incident. The inspector also found that this violation of license conditions had a low safety significance since the procedure was adequate to

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5 ensure safety of the operation, and only encapsulated SNM was involved with the operation. Therefore. this i NRC-identified violation is not being cited because '

criteria specified in Section VII.B of the jiRC Enforcement Policy were satisfied (NCV 70-1201/

97-06-01).

(c) Conclusions With one noted exception changes to the licensee's operating and sF?ty procedures were being approved consistently witj the L Pense Application.

(2) Internal Reviews and Audits (05.03)

(a) Insoection Scone Monthly and semi-annual safety audits were reviewed to verify consistency with license requirements.

4 (b) Observations and Findinas  ;

1 The inspector reviewed the most recently published l semi annual audits in the arcas of health physics (HP)

and nuclear safety. The inspector observed that the

most recently published health physics audit received

from licensee management was performed January 28 &

29. and February 3. 1997: and the report dated February 10. 1997. was entitled " Quarterly Independent

(. Audit - LMF Emergency Plan." The inspector verified with licensee management that the document was indeed the semi-annual HP audit, even though the title of the document stated that this was a quarterly audit and ,

was concerning the facility Emergency Plan. The -

inspector found that the audit contained a review of '

three Radiation Protection procedures and two emergency procedures.

The introductory summary of the " health physics" audit explained that the scope of the audit centered around respondingtoaccidentsandevaluatingtheEmer

program (as suggested by the document s title),gency and 1

was thus not intended as a HP audit. -The inspector

, also found that the audit did not meet the standard

criteria set forth in the License Application (and repeated in the licensee's auditing procedure) for conducting semi-annual audits. .Section 2.7 of the License Application states that the audit scope shall i include reviews of the effectiveness of procedural controls; an audit of operating records: a review and evaluation of contamination survey data: and ascertaining the overall performance of the plant i i

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6 functions in surveillance,providing adequate and follow controls, up to assure safety and i; license compliance. The inspector observed that the i

portion of the audit report associated with radiation protection procedures only discussed a few procedural inconsistencies (outdated references to procedural attachments, lack of available copies of procedures at emergency muster areas. and lack of nasal swabs on a -

supplies inventory sheet). This failure to meet the audit scope requirements in the License Application was identified as a Violation of License Condition 2.7 j (V10 70 1201/ 97-06-02).

! The inspector observed the most recently published 4

semi-annual NCS audit dated April 30. 1997. The i inspector observed that-the NCS audit consisted of a series of ten checklists. each covering a different area of the LMF. The inspector observed that each checklist contained three to seven items for the auditor to examine, and each had a place at the bottom for auditor's comments. Collectively. the checklists

provided a snapshot of the operation of the LMF on the i

day of the audit and basically checked operator ,

complianca with local NCS postings. The inspector ,

found that. like the HP audit. the NCS audit did not include the reviews required by section 2.7 of the License Application, This failure to meet the audit scope requirements is another example of VIO 70-1201/

97-06-02.

The inspector reviewed documentation of a second set of semi-annual audits conducted the week of June 30.

. 1997. by a different contractor than the earlier audits. The inspector observed that the audit scope for the HP audit was stated as including the items '

listed in the License Application. The inspector observed that the audit itself mentioned the reviews of records in the areas of bioassay, hood air-flow ,

measurements extremity exposure surveys, and differential pressure measurements. There were no findings as a result of these reviews. The' inspector also observed that the audit found several HP procedures that had not been reviewed in the required time frame. Finally the audit noted that reviews.

comments, and recommendations documented in 1996 on HP procedures could not be located for follow up, and the auditor made a recommendation to the licensee to implement a system to track such comments and recommendations. The inspector found that although the audit scope reiterated the license requirements.

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7 an evaluation of the effectiveness of procedural controls and an overall performance assessment of plant functions were not discussed in the audit.

The ins)ector observed that the NCS audit performed the wecc of June 30, 1997, briefly mentioned procedural controls, but only verified that the controls existed, and did not assess their effectiveness. Additionally the auditor's report (which included both the HP and the NCS audits) had not been submitted to the Plant Manager for review as specified in Section 2.7 of the License Application.

Tnese failures to meet the audit scope requirements are further examples of Violation 70-1201/97-06-02.

The inspector found that clarification was needed on certain aspects of conducting safety audits. The second set of semi annual audits performed in 1997 were conducted June 30 through July 3. Clarification was needed as to which half of the year such an audit would be credited: the half in which the audit began, or the half in which it was completed. The inspector also found that clarification was needed at to what constituted completion of the audit. The semi-annual audits conducted beginning June 30, 1997, were not documented in a report until November 1997. The inspector found this length of time to )roduce the six pages of documentation as excessive. Tie issuance of a final report is t'mically considered the completion point of an audit. fhe inspector found that clarification from the licensee is needed to consistently produce the audit reports in a timely manner. These clarifications will be tracked as Inspector Follow up Item (IFI) 70-1201/97-06-03.

The inspector observed the monthly internal safety audit records for the most recent six months. The inspector observed that the monthly audits consisted of checkl1%s of items for a wide variety of safety discipl 4 es including industrial safety, fire safety.

radinion safety. and criticality safety. The inspector found that the inspections were being performed within the appropriate time frame. The inspector observed that within the most recent six months of monthly audit records, over 700 items had been checked with only thcee problems noted. The inspector observed that each audit checklist included a statement that the checklist was not all-inclusive

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l- and that other items were to be reviewed as warranted.

However, the ins v: tor observed that no notations were made on any of t1e monthly audits to indicate items othcr than those on the chedlists were reviewed.

(c) Conclusions The semi-annual safety audits performed early in 1997 did not meet the license requirements for audit scope.

The second set of audits performed in mid-1997 were an improvement, but still fell short of meeting all of the criteria in the License Application. The licensee indicated tuat some of the shortcomings may be attributed to under documentation of the audit.

Further improvements are needed by the licensee to ensure that independent auditors provide adequate documentation of the audit reviews and that all license requirements are thoroughly covered. The failure to conduct audits as recuired by the license was identified as a Violation (h0V 701201/97-06-02).

Clarifications were 'oeded concerning the timeliness of audit reports an. $

audits that have portions conducted in both hi ')f the calendar year. This situation will be tra . as Inspector Follow up Item 70 1201/97-06-03.

(3) Safety Committees (a) Insoection Scone A review of the Safety Review Board (SRB) meeting minutes was performed to verify that activities were in accordance with license requirements.

(b) Observations and Findinos The inspector reviewed the minutes for all SRB meetings held in January through October 1997. The inspector found that the meetings were held more frequently than the quarterly minimum requirement.

The inspector found that the scope of the meetings typically included reviews of proposed facility changes, discussions of procedural inadequacies, and discussions on potential improvements to safety programs. The inspector found that all-other required review topics were discussed when appropriate.

(c) Conclusions The performance of the SRB was adequateb ..aeting the license requirements for reviewing safety issues.

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(4) Follow ur on Previously identified Issues (a) Insnection Scone Corrective actions associated with VIO 70-1201/

97-03-05 completion.

Inspector Follow up Item (IFI)were reviewed to verify /0-1201/

reviewed as part of the overall audit system evaluation.

(b) Observations and Findinas The corrective actions developed by the licensee for VIO 70-1201/97-03-05 included clarifying the definition of the term " semi-annual". The violation was cited for failure to comply with the timeliness requirements of semi annual safety audits. The inspector observed the Program Definitions procedure SL-1040 dated June 26. 1997. The inspector observed that paragraph 4.24 of procedure SL-1040 defined semi-annual as six months +25% and as occurring at least once between January and June, and at least once between July and December. The inspector found this definition to be adequate. Thus. VIO 70-1201/97-03-05 is considered closed. However, the inspector found that review of this item in conjunction with the reviews of the audit system brought forth additional questions concerning definitions associated with performing semi-annual audits (see Section ll.B.2 of this report).

As part of the review of semi-annual audits the inspector reviewed the situation surrounding IFI 70-1201/97-01-01 concerning the lack of scope of audits. The lack of scope centered around the fact that only one program area in the radiation protection program was being reviewed with each semi-annual audit. Thus, it would take several years to audit the entire radiation protection program. The inspector observed that the licensee's procedure for performing safety audits (SL-1150. Rev. O. dated June 30, 1997) now includes a provision to audit three program areas during each semi-annual audit and that the entire program would be reviewed within a two year period.

The inspector found this action to be a positive step toward improving the thoroughness of semi-annual audits in the radiation protection program.

IFI 70-1201/97-01-01 is considered closed.

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i 10 (c) Conclusion The licensee's actions taken in response to VIO 70-1201/97-03-05 was found to be adequate and was considered closed. The response to IFl 70-1201/

97 01-01 was considered inadequate, was closed and replaced with VIO 70-1201/97-06-02 (See Section 11.B.2 of this report).

3. Radioloaical Controls

a. Environmental Protection (88045) (R2)

(1) Monitoring Program Results (R2.02)

(a) Insnection Scone The inspector reviewed selected aspects of the environmental monitoring and sampling program to ensure that the requirements of Section 5.2 of the License Application were met. Section 5.2 of the License Application specified the requirements for the environmental monitoring program. Section 5.2 also specified that environmental monitoring shall be conducted in accordance with approved procedures which requires the environmental data to be evaluated against internal action levels.

(b) Observations and Findinas The inspector reviewed and discussed selected environmental sample results collected and analyzed in 1997, including vegetation fish, surface water, sediment, and soil samples. These sam)1es were required to be collected annually by tie License Application. The water, sediment, and vegetation samples were collected on September 19. 1997, analyzed by a vendor laboratory and completed on October 17, 1997. The results were received and reviewed by the licensee on November 6. 1997. The soil and fish samples were collected in May and April 1997.

respectively and the results were reviewed by the licensee in September and July 1997 respectively.

The inspector noted that for the selected data reviewed, sample matrices were collected and analyzed in accordance with procedural requirements. The samples were collected and analyzed for gross alpha and beta activity by the licensee's contract laboratory.

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11 Soil samples collected in the vicinity of the wet weather stream indicated gross alpha and beta concentrations in excess of the licensee's action level of 20 pC1/ gram. Gross alpha and beta concentrations ranged from approximately 4 to 41 pCi/ gram and 20 to 38 pCi/ gram respectively.

This area was currently under review by NRC/NMSS for unrestricted release.

Excluding the soil samples collected in the vicinity of the wet weather stream, there were no other samples that exceeded the gross alpha action limit. however, the following samples exceeded the gross beta action limit: (1) soil at Plant North location (22 pC1/ gram):

(2) water at the James River downstream location (45 pC1/ gram); and (3) one vegetation sam)le at Mt. Athos Road North (30 pCi/ gram). At tie time of this inspection. the licensee was in the process of determining the next course of action. including the re-sampling of the affected areas. The inspector discussed performing isotopic analyses to better characterize the activity.

(c) Conclusions The inspector concluded that the licensee's sampling program was consistent with the requirements in Section 5.2 of the License Application and licensee procedures. . The licensee had not determined the source of the gross beta activity noted in certain soil, water and vegetation sample results collected in 1997.

(2) Quality Control of Analytical Measurements (R2.04)

(a) Insoection Scoog-The inspector reviewed the licensee's quality control (OC) program for environmental analytical measurements to verify that the licensee had maintained adequate management controls for the environmental program, (b) Observations and Findinas The licensee primarily relies on the use of a contract laboratory to perform analyses of the various environmental samples collected throughout the year. l The only samples analyzed on site are the perimeter '

air samples which are collected weekly and analyzed for gross alpha and beta radioactivity.

12 During the last inspection of this program area, the inspector noted that the licensee had no formal procedure specifying ne quality assurance (0A) and OC programs for environe .'al sample results.

Specifically there t n guidance for the evaluation of quality control 4 ata, inter-laboratory and intra-laboratory comparisons, audits of the primar contractor laboratory, spike sample program,yand cross-check sample program. The inspector noted during this inspection, that the licensee had initiated development of a )rocedure. SL-1160 Review of 0A programs for Vendors )erforming Environmental Analyses to better manage the OA program. The inspector did not review the procedure since it was still in draft, however, the inspector indicated that this po'" an of the program would be reviewed during a subsequent inspection, (c) Conclusions The licensee's quality control program for environmental analytical measurements was under development.

b. Waste Management (84850, 84900 and 88035) (R3)

(1) Airborne Effluent Controls. Procedures, and Instrumentation (R3.03)

(a) Insoection Scone The inspector reviewed the licensee's airborne effluent procedures and controls to verify that systems and programs were in place to assure compliance with applicable license conditions and Federal regulations.

10 CFR 20.1302 requires radioactive releases to be within certain limits and 10 CFR 20,1101(b) requires that doses to members of the public are as low as reasonably achievable (ALARA). Safety ConditiorrS-1 of SNM-1168 required the licensee to use licensed material in accordance with the statements .

representations and conditions of Part I of the License _ Application dated June 22. 1990. and supplements thereto. Sections 3.2.2 and 5.1.1 of the License Application specified the requirements for gaseous effluent controls.

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13 (b) Observations and Findinas The inspector examt M the licensee's program for sampling the gaseous effluent release points at the facility, as specified in RP-004. Airborne Radioactivity. The inspector noted that the licensee discharged gaseous effluents from four release points:

(1) Main Stack (the PLR area and SERF-1 controlled area): (2) SERF-2 radiologically controlled area (RCA); (3) SERF-3 RCA, and (4) SERF-4 RCA. The inspector verified that the controlled area effluents were continuously sampled for gross alpha and beta airborne radioactivity when the facilities were in an operational status and that samples were collected on a daily basis, except weekends and holidays. The inspector did not note any apparent problems with the air sampling equipment or configuration.

(c) Conclusions The licensee had implemented an acceptable program to monitor and control gaseous radioactive effluents.

(2) Liquid and Airborne Effluent Monitori_ng Results (R3.02 and R3.04)

(a) Insoection Scoce '

The inspector reviewed the lirensee's airborne effluent monitoring results to determine if the gross alpha and beta radioactivity-in the effluent were below the License A) plication limit as specified in Section 3.2.2.2. T1e inspector also reviewed the liquid effluent monitoring results with respect to the limits referenced in Section 5.1.2 of the License Application.

(b) Observations and Findinas The inspector reviewed the licensee's quarterly effluent air sample reports for the first and second quarters 1997 and verified that the airborne releases were well within the 10 pCi/ quarter release limit for gross alpha radioactivity as _specified in tha License Application. For the first six months, the total gross alpha result was 1.57 pCi.

For the same time periods. the gross beta concentrations were significantly less than he License Application limit which was 25 percent of the quarterly derived air concentration (DAC) specified in-Table 2 of 10 CFR 20. Appendix B. The source of the i

14 beta activity was primarily from Co 60 due to the other licensed activities in four field SERFS. During the first six months of 1997, the total gross beta result was 29.93 pCi.

The inspector also reviewed the 10 CFR 70.59 effluent monitoring reports from 1994 through the first half of 1997. A summary of the data is in Table 1 below.

Table 1: Summary of Airborne Effluents Released to the Environment Radionuclide 1994 1995 1996 1997 (4)

U-234 4.01 3.73 3.29 1.22 U-235 0.22 0.21 0.18 0.07 U-238 0.93 0.87 0.76 0.28 Total U 5.2 4.8 4.2 1.57 Co-60 49.2 19.3 51.3 29.9 From a review of the total uranium data, a slight decreasing trend was noted.

The inspector also reviewed the licensee's liquid effluent controls and monitoring results. The liquid effluent controls were specified in procedure AS-1104.

Waste Water Effluent Control. Rev.18. September 23, 1996.

Potentially contaminated liquid waste releases via a dedicated drain line to the wet weather stream were ceased on December 1. 1987. After December 1. 1987.

all radiologically contaminated water generated by operations was rerouted to a dedicated evaporation system with the offgas being discharged through the plant high efficiency gaseous filtration system. The licensee had a Retention Tank System that was used for non-contact inon-radioactive) industrial waste water.

Liquid discharges from the Retention Tank System were sus) ended in June 1993. Subsequently, the Retention Tanc System had been removed. thus precluding any licuid effluent discharges via this pathway.

R6ciological releases via the liquid pathway would occur only during spills or other non-routine events.

There were four liquid waste streams identified:

(1) sanitary waste water: (2) industrial waste water; (3) non contact cooling water; and (4) storm water run off. Sanitary waste water was piped underground

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directly to the waste treatment facility at NNFD. The industrial waste water was treated via the ion 4

exchange system and discharged to the Lynchburg Regional Waste Water Treatment Facility. The non-contact cooling water was discharged to the plant fire pond and released to receiving waters (outfall 1).

4 Storm water run off was also discharged to the fire pond via a series of storm drains. The licensee verifies that plant processes do not contaminate these

pathways by collectin

outfall location No. g l one liter liquid This grab samples from effluent sample was required by the licensee's National Pollution i Discharge and Elimination System (NPDES) permit, i Section 5.1.2 of the License Application also i

specified the requirements for the collection of various surface water samples.

During this inspection, the inspector noted that the fuel rod production line included a wash and rinse process. The wash water was sent to two approximately 500 gallon retention tanks on a batch basis, while the rinse water was a continuous feed to the retention tanks. This water was periodically transported via a tanker to the Lynchburg Water Treatment Facility (LWTF). In 1992 the licensee performed a study and determined that uranium and the introduction of other radioactive contaminants in the retention tank water were negligible. The inspector noted that the l licensee was collecting quarterly retention water tank samples and performing an analysis for total uranium.  ;

The inspector considered this sampling frequency- '

adequate and with in the sampling frequency guidance

. specified in Regulatory Guide 4.16 for radioactivity in the effluent which is considered insignificant, l Regulatory Guide 4.16 defined a significant liquid effluent release when the concentration averaged over a calendar quarter is equal to 10 percent or more of the appro)riate concentration listed in Table 2 of Appendix 3 to 10 CFR 20. .For the first three quarters of 1997. the total uranium concentrations in the retention tanks were as follows:

Table 2: 1997 Quarterly Total Uranium Concentrations in the Retention Tanks Location First Quarter Second Quarter Third Quarter Tank #1 7.9+/-0.5 pC1/1 5.1+/-0.6 pC1/1 11.6+/-1.1 pCi/l Tank-#2 0.5+/-0.1 pCi/l 0.8+/-0.2 pCi/l 36.6+/-2.9 pCi/l j

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i 16 The licensee would only be authorized to dispose of this liquid waste by transporting it to LWTF as long as the four disposal conditions specified in 10 CFR 20.2003(a) were satisfied. Upon further review, the inspector noted that the licensee had not determined if the radioactive material (uranium) in the retention tank water was readily soluble in water as recuired by 10 CFR 20.2003(a)(1). The inspector discussec with the licensee the guidance provided in Information Notice 94-07. Solubility Criteria for Liquid Effluent Releases to Sanitary Sewerage Under the Revised 10 CFR Part 20. dated January 28, 1994. During the exit meeting, the inspector indicated that a study of the solubility of the uranium in the retention tank water must be performed to determine if the licensee meets the disposal conditions specified in 10 CFR 20.2003(a). Since additional information was needed to determine if the licensee was authorized to make this type of disposal, the inspector indicated that this issue would be tracked as an unresolved item (URI) pending review of the licensee's analysis of the l solubility issue (URI 70-1201/97-06-04).

l (c) Conclusions The licensee had implemented an effective program to monitor and control gaseous radioactive effluents and to maintain the radioactivity released in those effluents to quantities less than the License A) plication limit and concentrations which were below t1e limits specified in 10 CFR 20 for release of radioactive material to unrestricted areas. The licensee's management controls of liquid waste did not take into consideration the solubility of uranium in the water of the retention tanks before the water was transferred to the municipal water treatment facility.

(3) Radioactive Solid Waste Management (a) Insnection Scoce The inspector reviewed and discussed with licensee representatives activities associated with the packaging of low-level radioactive waste (LLRW) generated-from on-site operations and its transfer to a licensed waste-processor for disposal. Speci fically, the inspector reviewed the licensee's program as it pertained to the requirements of 10 CFR 20.2006 and Appendix F to 10 CFR Part 20.

~ _ _ _ _ _ _ _ _ _ .

17 (b) Observations and Findinas As noted in the LLRW Storage section of this report, all LLRW generated from the SERFS and the LMF-is stored tem >orarily in dedicated SeaVan containers.

-For the LLRW generated from the SERF area, the licensee performed a 100 percent scan of each plastic bag containing the waste to determine the maximum dose rate before placing the solid radwaste into the SeaVan container. The dose rate data were then used in conjunction with the most recent isotopic analysis of a representative waste stream composite sample to determine-the radionuclide content. The inspector reviewed the results of the most recent semi annual isotopic analysis of smear samples collected from the SERF-1. SERF-3. and SERF-4 facilities. The licensee collected one smear sample per month at each SERF from representative locations including )ieces of equipment and the floor surfaces. T1e sample collection and analyses were performed in accordance with the requirements specified in Procedure SL-1600.

Addendum 6. Contaminated Field Services Equipment Shipment. Rev. O. June 30. 1997.

For LLRW originating from the fuel handling areas, the licensee scanned each container (a 55-gallon drum with 2-3 bags of contaminated waste) with a sodium iodide (Nal)-detector and a SAM 2 counting system. The material controls and accountability personnel provided the assay results to the health physicist responsible for shipping radioactive materials so that the total quantities of uranium could be included with the shipping papers.

Once the Seavan containers were filled the licensee shipped the containers to a licensed waste processor (American Ecology Recycle Center, formerly Quadrex) for sorting and compaction before the waste was buried at a licensed disposal facility. The licensee shipped approximately four containers per year to the waste processor.

The inspector did not identify any concerns regarding sorting. Jackaging, scanning or radiological controls of the LLRW storage areas.

18 (c) Conclusions The inspector concluded that the licensee's controls and procedures for the solid waste management program were acceptable and capable of accomplishing its safety objectives.

(4) Low Level Radioactive Waste Storage (a) Insnection Scoce The inspector reviewed and discussed with licensee representatives activities associated with the storage of LLRW generated from on-site operations.

Section 3.3.5 of the License Application recuires that waste in the restricted area is to be storec in a manner that provides adequate protection from deterioration and/or the elements.

-(b) Observations and Findinas I

The inspector toured and examined the licensee's storage areas for LLRW and noted that the licensee maintained three temporary short term storage locations for LLRW, The licensee temporarily stored all LLRW generated from the SERF and fuel handling areas into three dedicated SeaVan containers for each facility: (1) SERF 1 and PLR: (2) SERF-3: and (3) SERF-4. The solid waste consisted primarily of packaging material, floor sweepings. filters.

decontamination materials, contaminated equipment and evaporator sludge. The waste materials were placed in plastic bags, surveyed for radioactive material content and placed in the appropriate SeaVan. Once the SeaVan containers were filled. the licensee shipped the containers to a license <1 waste processor for sorting and compaction before the waste was buried at a licensed disposal facility.

(c) Conclusions The inspector determined that the licensee was temporarily storing low-level radioactive waste safely and in accordance with 3rocedures. The LLRW storage containers were accepta)1e for the term of storage.

c. Transportation Activities (86740) (R4)

The inspector reviewed the licensee's program for routine radioactive materials shipments to determine whether the licensee had. established and was maintaining an effective management-controlled program, to ensure radiological and nuclear safety in

l 19 the receipt. packaging, and delivery to a carrier of licensed radioactive materials, and to determine whether transportation activities were in compliance with the applicable NRC and DOT transport regulations noted below. During the inspection.

transportation activities associated with LLRW and fissile material shipments. including procedural guidance. OC activities, and record completeness conducted in accordance with 10 CFR Part 71, and 49 CFR Parts 171-178 were reviewed.

10 CFR 71.5(a) requires that licensees who trans) ort licensed material outside the confines of its plant or otler place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the DOT in 49 CFR Parts 170 through 189.

(1) Preparation of Packages for Shipment (a) Inspection Stone The inspector examined the licensee's written procedures and observed activities associated with the preparation and delivery of completed packages for shipment of fuel assemblies.

(b) Observations and Findinos The inspector verified that the licensee had procedures for the preparation of shipping packages and delivery of the packages to the carrier for shipment. The following procedures were revicwed:

o MA-533. Maintenance of Model B Fuel Assembly =

Shipping Container. Rev, 1, January 13, 1997 o

MA-292.MK-BWFuelAssemblyPackagin.Shigng, and Container Storage. Rev.10. Apri 3. 1 o SL-1600. Shipment and Receipt of Radioactive Material. Revision 0 June 30, 1997: Addendum 2.

Fuel Assembly Snipments. Rev. O. June 30. 1997 The inspector ncied that step 5.7.6 of MA-533 required a visual inspe. tion of the 0-ring gasket and tank seat to look for indications of deterioration. The gasket was to be replaced annually or immediately if signs of deterioration were evident. The licensee, however.

had no records or provisions in the procedure to document when the gaskets were changed. In MA-292.

step 5.1.4.0 required leak tests (i.e. 3ressurization tests) to be performed on all fuel assem)1y Model B shipping containers. The Maintenance Supervisor was n,, .

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l 20 to decide when to perform the leak test. Similarly, the licensee had no records or provisions in the procedure to document when the leak test was performed. Further discussions with the licensee and the Spent Fuel Project Office determined that the leak test and gasket replacement were self-imposed requirements that did not necessarily affect the safety margin of the package. However, at the conclusion of the on site inspection, the licensee revised the procedures noted above so that gasket replacement and leak test would be docemented for the record.

The inspector observed shipping and packaging Jersonnel preparing inspecting, and loading the iodel B fuel shipping containers. The entire operation involved one operator / loader and one quality control inspector. The inspector verified that the

- e wrator inspected the gasket for deterioration and

,e overall condition of the shipping container.

Other than the lack of documentation for performing certain tasks. the inspector did not identify any problems with this process.

(c) Conclusions Through the observation of packaging operations underway during the inspection, it was concluded that the licensee's performance in this program area was acceptable. The procedures and licensee activities related to the package preparation, loading, operating, and maintenance of the Model B packages generally implemented the requirements of the Certificate of Compliance (CoC).

(2) Certificates of Compliance (a) Insnection Stone The inspector reviewed selected NRC CoCs for packages used by the licensee to ship fissile materials.

10 CFR 71.12(a) requires, in part that a general license is issued to any licensee of the Commission to deliver to a carrier for transport, licensed material in a package fnr which a license. CoC or other approval has been issued by the_NRC.

The general license specified in 10 CFR 71.12 applies to a licensee who (1) has a copy of the certificate of compliance and the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging and to the actions to be

21 taken prior to shipment: and (2) complies with the terms and conditions of the license, cer+1ficate, or other approval, as applicable, and the ap)licable requirements of Subparts A. G and H of tais part.

(b) Observations and Findings The inspector reviewed the following NRC CoC for packages used by the licensee to ship fuel:

NRC CoC 6206. Rev. 22. USA /6206/AF. Model B.

dated March 22. 1996 The inspector verified that the licensee maintained a current copy of the NRC CoC and that the licensee had registered with the NRC as a user of the applicable NRC-certified package. In addition, the inspector verified that the licensee had management approved procedures and controls for the use and maintenance of the Model B fuel shipping package.

(c) Conclusions The inspector co'71uded that the licensee's controls and procedures for implementing the requirements of the CoC were acceptable and capable of accomplishing its safety objectives.

(3) Records (a) Inspection Scone The inspector reviewed licensee shipping activities and documents with respect to fissile material shipments to ensure compliance with the appropriate criteria specified in 49 CFR Parts 171-178.

(b) Observations and Findinas S)ecifically, the inspector reviewed and discussed slipping paper documentation associated with fuel assembly shipments made to selected commercial reactor facilities. Selective records from January to October 1997 for four fuel shipments were reviewed. The inspector did not note any significant problems with the shipping ) apers, certifications, ins)ections, surveys, checclists, and emergency teleplone numbers.

The inspector also reviewed the licensee's system for identifying and correcting problems as it pertained to the transportation program. These problems were captured in the Radiological Deficiency Reporting i

22 (RDR) system. The inspector reviewed the RDRs for the period November 1996 to October 1997. The inspector noted that the licensee had identified numerous problems associated with improper shipping ) aper work, surveys, and container labeling. Most of tie problems occurred in the last quarter of 1996. Part of the corrective action was to limit the administrative shi) ping responsibilities to three individuals (HP tec1nicians) and have all the ship)ing documentation reviewed by a health physicist. T11s corrective action was implemented during the first quarter 1997.

It i inspector noted that since im)lementation of the corrective actions, the licensee lad identified five more examples of shipping aaper inconsistencies and one container labeling pro)lem.

(c) Conclusions The licensee's shi) ping records were well maintained and accessible. T1e licensee's RDR system for l identifying problems in the areas of surveys, labeling l and shipping paper work was effective. The licensee's 1 corrective actions to correct the shipping problems seemed reasonable, however, similar problems had been identified after the implementation of the corrective actions which may be an indicator of inadequate staffing.

4. Itainino(F2)

1. 10 CFR 19,12 Training (F2.01)

a. Inspection Scoce General Employee Training (GET) was reviewed to verify -

compliance with 10 CFR 19.12 and license requirements.

b. Observat,ons and Findinas The inspector observed a GET session on November 4. 1997.

The requirements of Section 2.5 of the License Application, and licensee procedure SL-1140. Rev. 1. dated July 25. 1997.

were compared with the observed training. The inspector found that all topics of discussion required by the License Application and SL-1140 were adequately addressed. The inspector compared the requirements of 10 CFR 19.12 with the observed training. The inspector found that Paragraph 19.12(a)(4) was not being fully discussed in the GET sessions. Paragraph (a)(4) of 10 CFR 19.12 states that employees "shall be instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and

. _ _ _ - _ _ _]

23 licenses or-unnecessary exposure to radiation and/or radioactive material." The GET session discussed reporting hazardous conditions to a supervisor with an example of a tripping hazard given. The ins)ector observed that the GET also included the instruction tlat NRC regulations must be followed. However, the inspector found that the complete message provided in 10 CFR 19.12(a)(4) was not being conveyed. The licensee indicated that this message was largely communicated to the employees through specific cases in the operating procedures, but that there may be situations not covered by the procedures. Although 10 CFR 19.12 does not require the licensee to provide the instructions in Saragraph (a)(4) in its GET nor does it require that suc1 instructions be given through a formal training program, the licensee agreed that the GET would be the best mode of communicating this information and would be covered in future GET sessions. This item will se tracked as IFl 70-1201/97 06-05,

c. Conclusions The licensee's GET included all of the topics required by the License Application and safety training procedure SL-1140. The -instruction to employees required by 10 CFR 19.12(a)(4) was not discussed in the GET. The inclusion of this instruction in the GET will be tracked as IFI 97-06-05.

2. General Radiological Safety Training (F2.03)

a. Insoection Scone The formal courses covering General Radiation Training were reviewed to verify adherence to license requirements,

b. Observations and Findinas The inspector observed the Controlled Area Access Training course on November 4. 1997. This course provided workers and visitors with information that centered around radiological hazards throughout the plant. The completion of the course allowed unescorted access to controlled areas of the site. The inspector found that the topics discussed were consistent with the requirements of Section 2.5 of the License Application and licensee procedure SL-1140.

The inspector reviewed the course materials for plant wide Radiation Worker Training. This course is required for anyone working in a material access area. The inspector found that the course materials basically covered the topics required by procedure SL-1140. However, the inspector found certain portions of the manual had been left blank so that site-specific information could be inserted, but had not yet

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24 been completed. The inspector discussed this with the licensee's safety staff responsible for the manual. The licensee indicated that the manual would be completed to include site-specific information for future training sessions.

c. Conclusions The General Radiation Worker training provided to LHF employees meets license and procedural requirements.

3. Follow up on Previously Identified Issues

a. Insnection Scone The training program was reviewed for resolution of URI 70-1201/97-05-03,

b. Observations and Findinas URI 70-1201/97-05-03 involved the ak of available information to evaluate the adequacy of the licensee's training programs during a previous inspection. The inspector found that the review of training documented in Sections Ill.A.1 and Ill.A.2 of this report resolves the basic issue of adequacy of the licensee's training programs.

Thus, URI 70-1201/97-05-03 was resolved and can b-considered closed. Other areas of the licensee's training program will be reviewed at future inspections,

c. Conclusions The licensee's general training is adequate, URI 70-1201/97-05-03 has been resolved ad is considered closed.

5. Exit Interview (H1)

The inspection scope and results were summarized on_ November 7, 1997, with those persons indicated in the Attachment. The inspector described the areas examined and discussed the inspection results, including any potential violations, follow-up items, unresolved items, and the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although 3roprietary documents and processes were occasionally reviewed during tais inspection, the proarietary nature of these documents or processes has been deleted from tais report. Dissenting comments were not received from the licensee.

_o

ATTACHMENT

1. PERSONS CONTACTED LicenseePersonnel T. Allsep. Health Physicist

• G. Elliott, Manager Safety and Licensing

• D. Gordon, Senior Health Physicist

• A. Jenkins, Manager. SERF 3&4 Facilities

• G. Lindsey, Health Physicist

u. Map). Training Instructor

• J. Matleson, V.P., Operations

• J. Mayberry. Product Quality

• A. McKim, Manager. Quality / Health / Safety

• M. Minor, Manager, Process Engineering

• H. Morrell. Lead Process Engineer

• T. Wilkerson Manager, Nuclear Fuel Manufacturing Other licensee employees contacted included engineers, technicians.

security, and office personnel.

• Denotes those present at the exit meeting on November 7, 1997

2. INSPECTION PROCEDURES USED 4

IP 84850 Radioactive Waste Management IP 84900 t.ow-Level Radioactive Waste Storage IP 86740 Transportation Activities IP 88005 Management Organization and Controls IP 88010 Operator Training / Retraining IP 88020 Regional Nuclear Criticality Safety Inspection Program IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 92701 Follow up IP 92702 Follow up on Co:rective Actions for Violations and Deviations

2

3. LIST OF ITEMS OPENED. CLOSED AND DISCUSSED i

Item Number Status Qgscriotion 70-1201/97-01-01 Closed IFl - Review the scope and details of the independent audit scheduled for January 22, 1997.

70-1201/97 03 01 Closed VIO - Failure to comply with posted NCS requirements concerning storage of moderating materials in the fuel assembly storage area.

70-1201/97-03-05 Closed VIO - Failure to comply with the timeliness requirements of semi-annual safety audits per the approved License Application and the Radiation Protection Program Definitions procedure (RP-000).

70-1201/97-05-03 Closed URI - Content of required training courses could not be adequately confirmed.

70-1201/97-06-01 Closed NCV - Operating procedure MA-458.

Rev. 19 was not approved by Manager.

Safety and Licensing as required by internal procedures.

70-1201/97-06-02 Open VIO - Scope of semi-annual safety audits not in accordance with license and procedural requirements.

70-1201/97-06 03 Open IFI - Clarifications for conducting semi-annual safety audits and producing audit reports are needed.

70-1201/97-06-04 Open URI - Review the licensee's solubility assessment to determine if the disposal of the fuel rod wash water from the retention tanks into the municipal sanitary sewerage system was authorized by 10 CFR 20.2003(a).

70-1201/97-06-05 Open IFl - Instructions to employees required by 10 CFR 19.12(a)(4) are to be included as part of General Employee Training.

l

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3

4. LIST OF ACRONYMS i ALARA -As low as is Reasonably Achievable CFR Code of Federal Regulations CoC Certificate of Compliance DAC Derived Air Concentration EML Environmental Measurements Laboratory FCF Framatome Cogema Fuels IFl Inspector Followup Item LLRW Low Level Radioactive Waste LMF Lynchburg Manufacturing Facility mrem millirem NCS Nuclear Criticality Safety NCV Non-Cited Violation NMSS Nuclear Material Safety and Safeguards NNFD Naval Nuclear Fuel Division (BWX Technologies. Inc.)

NPDES National Pollution Discharge and Elimination System NRC Nuclear Regulatory Commission pC1 picocuries

]pb parts per billion QA Quality Assurance QC Ouality Control RDR Radiological Deficiency Report RP Radiation Protection SERF Service Equipment Refurbishment Facility SFPR Safety Procedure Change Requirement SNM Special Nuclear Material SRB Safety Review Board pCi microcuries URI Un-Resolved item USDOE United States Department of Energy VIO Violation

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