ML20204B457
| ML20204B457 | |
| Person / Time | |
|---|---|
| Issue date: | 03/17/1987 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cunningham R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8703250064 | |
| Download: ML20204B457 (6) | |
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NUCLEAR REGULATORY COMMISSION D
E REGION V 1450 MARIA LANE, SUITE 210
,o WALNUT CREEK, CALIFORNIA 94696 N
N 171987 s
MEMORANDUM FOR: Richard E. Cunningh'am, Director Division of Fuel Cycle and Material Safety, NMSS FROM:
Ross A. Scarano, Director Division of Radiation Safety and Safeguards
SUBJECT:
SUMMARY
OF TI 2600/1 OPERATIONAL SAFETY ASSESSMENT FINDINGS We have completed our assessments of applicable Region V fuel facilities as prescribed in the subject TI. Enclosed with this memorandum is a summary of
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the general findings and recommendations for Advanced Nuclear Fuels Corporation (Exxon Nuclear Company) and GA Technologies (GAT).
The effort expended by NRC Region V and NRC NMSS and 0IE to complete the TI has been extraordinary and has significantly impacted on our entire fuel facility and materials inspection program.
In addition to NRC resources, we were fortunate to obtain extensive manpower and cooperation from EPA, FEMA, OSHA, state, county, and local governments at both Region V fuel facilities.
Much of the effort eFpended in the Exxon and GAT assessments was in the areai?
of fire protection, electrical engineering, hazardous material, industrial hygiene, and emergency preparedness. Significant findings and recommendations i
evolved from these areas where the NRC has little or no regulatory jurisdiction.
We anticipate discussions of these areas and NRC's future regulatory role during our March 19-20, 1987 meeting.
While this assessment effort was useful to clarify the current status of NRC fuel facilities in virwally all health and safeb Meas, we do not feel it l
is possible to sustain this effort without a co s16 able increase in o
i budgeted resources. Therefore, a return to on co ine inspection program would seem to be logical with continued emp'.:,is esolution of significant findings.
1 W
ss A. Scarano, Director ivision of Radiation Safety and Safeguards
Enclosure:
As Stated
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,. c-MAR 171987 Operational Safety Assessment Findings and Associated Recommendations at GA Technologies, Inc. (GAT) and Exxon Nuclear Company (ENC) during team inspections.
A.
Written Procedures and Operator Training (ENC)
Findings /0bservations:
The updating process procedures were timely; however, the updating of changes,to the safety procedures were less timely.
It was also observed that n6L all radiation protection lessons plans were written.
Recommendation:
Audits in these areas is to be increased in depth.
Written Procedures and Operator Training (GAT)
Findings /0bservations:
Procedures and training pertaining to radiological operations appeared adequate. ' Weaknesses were noted with operations involving the use of hazardous (non-radioactive) materials.
Industrial hygienist involvement in hazardous material work authorizations was lacking.
Some employees had not completed hazardous material training programs.
Recommendations:
Standard operating procedures for use with hazardous material work authorizations should be written and implemented.
All appropriate hazardous materials training programs should be completed by everyone who may be potentially exposed to toxic / hazardous substances.
B.
Nuclear Criticality Safety (ENC)
Findings:
It was observed that empty UFg cylinders were not being removed from the vaporization rooms which inhi5it prompt egress in case of an emergency.
A moderation control sign was improperly posted on a door to a room which contained both a moderation control area and a liquid process.
Recommendations:
The licensee should reevaluate the use o.f moderation control for product containers from uranium recovery operations.
Nuclear Criticality Safety (GAT)
Findings:
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'.0 Allowing adequate time for managers on the CRSC to perform their work was
. considered to be a major finding.
It was felt by the team that R&D f
pressures may be detracting from achieving optimum perfonnance on the -
Committee and that member's status was not emphasized enough by Upper
. Management. Several findings were directed at improved criticality signs, containers, audits, and documenting of work station limits and controls.
Recommendations:
The new Upper Management should be totally committed to the CRSC functions and give members all. the support necessary to insure quality work.
Licensee management and staff should be careful to maintain strict adherence to the proper use of criticality safety items such as signs, containers, procedures, and audit reports.
C.
Fire Protection (ENC) f Findinds:
There were no rated fire barriers. installed for compartmentation, the entire building (U0 and ELO. facilities) is considered to be a single 7
i fire area. Moderate combustibles were present throughout.
It was also observed that no offsite Fire Department Agreement with the licensee was in effect. The submerged isolation valves for the fire main system lacked valve position indication. The onsite Pre-fire Plans were incomplete. Training should be pr.ovided to assure that the capability to fight potential fires is established.
Recommendations:
Process shutdown procedures should be revised to incorporate instructions related process equipment to operators for manually scramming all UF6 prior to evacuation of the U0,3 facility in an emergency such as a fire.
- The licensee should evaluate the need for compartmentalizing with fire rated construction. The onsite and offsite Pre-fire Plans should be upgraded. The licensee should upgrade offsite Fire Department and emergency fire response training to include quarterly training sessions.
Fire Protection (GAT) l There were numerous findings in this area indicating the need for improvement.
Due to research and development activities in many i
projects such as fusion and hazardous waste disposal, the licensee was found to have fire protection / prevention problems due to the close proximity of radioactive and toxic materials to each other.
Recommendation:
The state or county fire marshall's office should conduct further l
inspections and evaluations to determine in greater detail the degree to j
which the team findings represent health and safety hazards.
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Electrical Systems and Engineering Functions (ENC)
Findings:
It was determined that internal audits of the Preventative Maintenance
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(PM) and Instrument Repetitive Maintenance (IRM) programs were not being performed on a regular schedule. Also, the surveillance program does not include cycling manually operated valves which are used to back up critical automatic valves.
Recommendation:
The licensee should manually operate valves that backup critical automatic valves at a frequency to ensure their operability, and conduct periodic internal audits of systems _and engireering functions.
Electrical Systems and Engineering Functions (GAT)
Findings:
A furnace safety feature was inoperable due to improper wiring.
Personnel were unaware of this and assumed the interlock was functioning, however no one ever bothered to test it. This underscores significant-4 overall finding that licensee needs to be more diligent in QA program to insure all safety systems operate as intended.
Recommendation:
Thorough safety equipment testing to insure proper operation is needed for all systems.
It is also essential that tests be periodic and frequent to insure system reliability. To this end the QA program should be' reevaluated.
E.
Industrial Safety and Hygiene (ENC)
Based upon the findings identified by the State OSHA representatives the following recomendations were made:
(1) A method to audit the plant accident prevention program, either internally or externally, should be implemented for verification i
that the program is being followed.
(2) A method of audit for the lock and tag safety practices should be instituted to ensure compliance.
(3) A continuous ammonia monitor should be installed in the precipitation area above the vaporization facility.
(4) Compressed air nozzle pressure be maintained below 30 psi.
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(5) The SCBAs be maintained at least 80% charged.
(6) Additional attention to proper use of hearing protectors.
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(7) The incompatible storage of chemicals should be corrected.
Industrial Safety and Hygiene (GAT)
Finding:
Recommendations identified in the industrial hygiene areas were mainly administrative in nature involving staffing, organization, lines of communication and functions of safety cmmnittees.
Recommendation:
Safety committees should be given more management support including attendance and active participation. Despite reduction in some operations this area must not be deemphasized.
F.
Findings:
It was observed by the FEMA representative that Benton County currently has no specific response plans for the Exxon Facility. Also, the Emergency and Radiological Contingency Plan needed updating as well as the supporting appendices.
Recommendations:
The licensee should institute an audit of their Emergency Preparedness Program.
The licensee should make the scenarios more complex 1.e., involve active participation of offsite agencies and organizations.
4 The licensee should review and update the Emergency and Radiological Contingency Plan and supporting appendices. The update should incorporate the chemical emergency issues.
Emergency Preparedness (GAT)
Findings:
Basically the team findings here involved improving liaison with county emergency service and medical support groups. Also, numerous separate plans have created some interface confusion which may complicate efficient response during an emergency.
Recommendation:
Consolidate plans, include a hazardous materials section and coordinate with offsite government agencies.
G.
Environmental Protection (ENC)
Findings:
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It was observed that used oil was being sprayed'on dirt roads for dust control. The oil contained copper which is toxic to aquatic life;
.however, the general' idea of spraying any used oil on roads for dust
control especially in areas where water is relatively nearby is not an environmentally good one. Also, the licensee is planning the -
incineration of chemical and industrial wastes on site.
It was also noted that there was concern in the workspace regarding exposure to irritants which caused mild respiratory problems.
Recommendations:
er An occupational health professional should be consulted regarding the irritant problem. The licensee should discontinue the practice of oiling dirt roads unless the contents of the waste oil are biodegradable and non-toxic. Also, the licensee should explore the possible production of toxic chemicals during incineration in light of the overall concept of environmental impact of the various site activities. The inhalation, dermal and ocular risks of acid dripping from the fuel rods when they are transferred to the subsequent baths of neutralizing materials should be assessed.
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