ML20209F142
| ML20209F142 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 09/03/1986 |
| From: | France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20209F101 | List: |
| References | |
| 70-0036-86-02, 70-36-86-2, NUDOCS 8609120060 | |
| Download: ML20209F142 (14) | |
Text
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U.S. NUCLEAR REGULATORY COMISSION REGION III Report No. 70-36/86002(DRSS)
Docket No. 70-36 License No. SNM-33 Licensee:
Combustion Engineering, Incorporated Nuclear Power Systems Windsor, CT 06095 Facility Name:
Hematite Inspection At:
Hematite, M0 Inspection Conducted:
July 28 through August 12, 1986 r
h k%& 5 Inspector:
. M. France', III b
Date Approved By:
L Chief 9
h Facilities Radiation Date Protection Section Inspection Summary Inspection on July 28 through August 12, 1986 (Report No. 70-36/86002(DRSS))
Areas Inspected:
Routine, unannounced safety inspection including organiza-tion, training, operations review, environmental activities, transportation activities, maintenance surveillance, criticality safety, radiation protection program (audits,' surveys) and review of an incident involving personnel hand contamination and subsequent offsite spread of contamination.
Results:
One violation was identified for failure to follow procedures (Section 4e.).
0 8609120060 860903 PDR ADOCK 07000036 C
DETAILS 1.
Persons Contacted
- L. Duel, Manufacturing Engineer
- H. Eskridge, Nuclear Licensing, Safety, and Accountability Supervisor
- R, Fromm, Quality Assurance Manager G. Jordan, Production Operator
- G. McKay, Health Physicist
- R. Miller, Manager, Administration and Production Control R. Moore, Maintenance Supervisor
- A. Noack, Plant Superintendent B. Pigg, Quality Control Laboratory Supervisor
- J. Rode, Plant Manager R. Stokes, Health Physics Technician N. Wilpur, Health Physics Technician
- Denotes those present at the exit meeting.
2.
General This inspection, which began at 12:45 p.m. on July 28, 1986, was conducted to examine licensee actions in complying with regulatory requirements related to fuel facilities.
The inspector examined the licensee's radiation surveillance program and investigated the circumstances that led to the contamination of two workers' hands.
An exit meeting was conducted on August 1, 1986.
3.
Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organizational structure, procedure review, and utilization of audit systems.
a.
Organization There have been no changes in the health physics organization since the previous inspection.
The licensee has notified NMSS that Mr. R. J. Klotz replaced Mr. L. J. Swallow as Criticality Specialist for the Hematite facility.
(See Inspection Report No. 70-36/85003(DRSS)).
The licensee noted that requests for nuclear safety analysis must be independently reviewed by Mr. Klotz prior to implementation, b.
Internal Reviews and Independent Audits The inspector verified that the licensee utilizes independent audits conducted by the Corporate Consultant Scientist, American Nuclear Insurance (ANI) and representatives of CNA - Insurance Company as means of reporting deficiencies to management.
Audit findings are highlighted below:
2
Marsh and McLennon Nuclear Consultants (ANI) approved the arrangement of a fire door and the proper sealing of a fire wall.
CNA - Insurance Company reviewed the licensee's safety program and noted that safety activities were well documented and available for review.
A Corporate Criticality specialist performed a semiannual Nuclear Safety Audit.
The auditor recommended the posting of criticality signs to limit the amount of SNM in uranium oxide agglomeration hoods.
4 c.
Safety Committee Meetings During plant safety meeting's the Health Physicist discussed pathways of ingestion for radioactive material, proper methods of using hand check surveillance monitors, and radiation monitoring in unrestricted areas (includes plant break room).
The inspector determined that attendance rosters were signed to reflect worker attendance from all operating shifts.
d.
Procedure Revising and Updating l
The inspector confirmed that the licensee periodically reviews and updates radiation protection and plant operating procedures.
Procedure approval for implementation was shown by the signature of the Nuclear Licensing, Safety and Accountability Manager, and by department managers in Engineering, Production, and Quality Assurance. The inspector determined that procedures are available for operator use.
No violations or deviations were identified.
4.
Radiation Protection The inspector reviewed the licensee's internal and external exposure 4
control programs, including the required records, reports and notifica-tions, and the licensee's program for maintaining occupational exposures i
a.
Internal Exposure Control Bioassay records for the first half of the year disclosed that the 40 MPC-hour intake limit for soluble uranium was not exceeded.
Whole body counts for plant workers were below the 130 pgm U-235 action level.
As discussed in Inspection Report No. 70-36/85003(DRSS),
one worker has been restricted from uranium production work because he exceeds the action level of 130 pgm U-235.
Results of his most recent whole body count showed 220 i 52 pgm of U-235.
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f b.
External Exposure Control The inspector reviewed the licensee's exposure control program including adequacy of procedures used to evaluate, control, and minimize exposures and required records, reports, and notifications.
The annual exposure report for 1985 operations disclosed that 69 persons were badged during the year.
An exposure table follows:
i ANNUAL DOSE RANGES NUMBER OF INDIVIDUALS (REM)
IN EACH RANGE NO MEASURABLE EXPOSURE 23 MEASURABLE EXPOSURES LESS THAN 0.100 34 O.100 - 0.250 9
i 0.250 - 0.500 2
0.500 - 0.750 1
0.750 - 1.000 O_
TOTAL INDIVIDUALS REPORTED 69 In accordance with 10 CFR 20.407 the licensee submitted the above dat) to the USNRC Office of Nuclear Regulatory Research, with a copy to Region III.
c.
ALARA Activities 1
The inspector examined licensee records on contamination control and identified areas in the plant where improvement is needed.
During a tour of the facility the inspector expressed the following concerns:
Contamination was found on the outside of the ufo cylinder wash precipitation tank, the tank support railing, operators desk, and waste water pails.
There is no demarcation of the contaminated area in the i
vicinity of the precipitation tank to define personnel pathways and step off pads, and to prevent the trafficking i
of contaminated material.
Survey records suggest that plant personnel may have become too lax in observing rules to prevent contamination spread and possible ingestion of radionuclides.
From 46 to 97 dpm was found on the breakroom coffee pot, cream / sugar containers, and the water fountain located near the work area.
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Smear tests on the ventilation register (cold air return) in the workers' break room showed a high result of 460 dpm.
Although air sampling results are less than the plant action level (0.8E - 10 pCi/ml), there is concern that high airborne problems in the plant could affect the airborne recirculation in the break room and the control room.
Ventilation in these locations is controlled by self contained units with 100 percent recirculation.
Since the air changes occur during door openings the incoming air could bring in contaminated air from the plant.
The inspector determined that although contaminated levels as shown on recent surveys meet acceptable surface contamination levels they are significantly higher than good ALARA practices would permit.
This matter will be reviewed further during future inspections, d.
@ borne Releases The inspector selectively reviewed licensee records of air sample analyses.
Air sampling is conducted using fixed room samplers and/or lapel samplers when breathing zone samples are needed.
The highest MPC-hour assignment for the first half of 1986 was 35.1 MPC-hours which occurred when a worker was changing out parts in the No. 2 pellet press.
No MPC-hour assignment exceeding regulatory requirements was noted, e.
Surveys and Contamination Control The inspector reviewed the licensee's program for indiological surveys to verify compliance with the regulations and with licensee requirements including the circumstances surrounding the contamination of two employees' hands.
(1) Background On May 14, 1986, the licensee's Manufacturing Engineer engaged the services of a Production Operator to make an adjustment and/or reassembly of the mixing manifold of a ufo cylinder wash precipitation tank.
The Engineer had determined that the mixing manifold was plugged.
The manifold was designed with four orifices measuring 1/8 to 1/2 inch in diameter.
The manifold is also equipped to operate with an eductor pump for transferring and/or recycling liquids and/or slurries.
Apparently, the manifold had been plugged during a previous operation involving the nitric acid wash of granular alumina, ufo scrubbor material, to remove uranium.
When washed with nitric acid, the granular alumina forms a paste-like substance that obstructs flow through the manifold orifices.
The licensee noted that a "Special Traveler" (written instructions) for the recovery of uranium from the granular alumina, requires the operator to wear a chemical face shield 5
and rubber gloves (SET 737) when performing this task.
The precipitation tank and manifold assembly must be cleaned each waste recovery campaign in order to prevent a reaction between chemicals.
On August 7, 1986, the inspector contacted the Production Operator by telephone.
The operator acknowledged that he was not wearing protective gloves while making final adjustments to the tank manifold.
The engineer noticed that the operator was proceeding with difficulty and decided to provide assistance.
The engineer hand held the manifold in place while the operator made the final adjustment.
Both were working on the outside of the tank and neither wore gloves.
The operator indicated it was possible, that while positioning the manifold for final adjustment he inadvertently grasped a portion of the manifold that was inside the tank.
Both the engineer and the operator indicated that had they known the outside of the tank and protruding end of the manifold were contaminated, they would have worn gloves.
The health physics staff had previously issued an Operating Sheet (OS 202, Health Physics Controls) which addressed contamination control in the plant.
Paragraph 2.2 Surface Contamination, Item d., of l
the 05 202 states that gloves are required when handling contaminated equipment, containers, or uranium pellets.
The inspector determined that both the engineer and the operator were aware that they were performing work on equipment that traditionally shows the highest plant contamination levels.
It appears that the engineer and the operator violated the requirement of 05 202 which requires hand protection for handling contaminated equipment.
(2) Health Physics Survey While monitoring his hands with a survey meter the Production Engineer observed that the meter tripped the setpoint alarm.
Subsequent washings and surveying disclosed that his hands were still contaminated.
He notified the plant Health Physicist and the Production Operator, of his findings.
A followup survey by the HP indicated that the precipitation tank, support railing, operator desk or writing stand, and the clipboards used by the operator were all contaminated.
The alpha activity detected on the engineer's hands as determined by the HP technician was about 700 to 1200 dpm.
Initial surveys performed on the Production Operator's hands showed a high of about 2000 dpm.
No beta contamination was detected, the uranium contamination encountered was enriched to 2.7 percent U-235.
Repeated washing of the hands in EDTA wash solution reduced the contamination levels only slightly.
Hence, both the engineer and the operator were provided with rubber gloves to wear overnight in order to induce exudation.
The HP indicated that the sweating process normally facilitates the removal of contaminated particles l
trapped in the pores of the skin.
1 6
OnJune9,1986,theoperatorwasissuedacontaing/1;however, r to collect a bioassay specimen.
This sample result was 12 pg the sample was collected at the end of the work shift.
Failure by the operator to collect a urine specimen prior to commencing the work shift raised the possibility that the sample may have been contaminated.
Because of concern for potential contamina-tion, the HP technician issued the operator another sample bottle on June 11, 1986.
In order to reinforce the plant requirement of sampling prior to commencing work, the operator was instructed by the guard to provide a sample prior to entering the plant u
locker room.
This sample result was 2 pg /1.
There was no apparent evidence that either skin adsorption of uranium or recuspended contaminated particle inhalation had occurred.
The licensee extended the hand survey probe to other plant personnel and determined that one operator working in the same area of the plant (as discussed above) had contamination levels of 600 to 2000 dpm alpha on his hands.
A survey of this operator's vehicle showed an alpha level of 400 dpm on the armrest.
In performing weekly surveys on employees exiting the plant the HP determined that six other employees had contaminated hands and forearms.
However, the contamination was reduced to background after an EDTA solution hand wash.
On the following day, a survey of the engineer's hands showed a reading of background to 100 dpm.
Subsequent readings were near background.
A check of the operator's hand showed levels up to 1000 dpm.
The operator, without HP approval, used sand-paper to abrasively remove skin from the callused portions of both hands.
There is no evidence that this had any significant affect on subsequent hand survey readings.
Through June 9, 1986, a survey of the worker's hands detected alpha activity at levels to about 700 dpm.
Surveys of the operator's car and his house were also conducted.
A survey of the right arm support located in the operator's automobile, showed about 2000 dpm, while no levels above background were detected in the operator's home.
The armrest was promptly decontaminated.
Badges worn by operating personnel and collected at the guard station were also reading contamination levels significantly above background (about 700 dpm).
The inspector requested that the operator's hands (discussed above) and the badge storage location be checked again during the course of this onsite inspection.
Results were shown to approach background in both the hand survey of the operator and the contamination survey of the badge storage location.
A survey of the operator's locker (restricted area) detected contamination levels of 2000 dpm on three baseball caps, 20,000 dpm and visible material on a scrowdriver, and 2,000 dpm on the worker's blue smock.
The operator responded to the inspector's inquiry by noting that his work habits have changed and that his contaminated clothing had been washed in the plant laundry.
7
(3) Medical Review The inspector reviewed the physician and Radiation Safety Officer's statements / letters concerning their independent measurement and discussion of findings with the Production Operator.
After a review of all the data and inhouse counseling with the Production Operator, the licensee decided to have additional counseling and independent measurements performed by a medical consultant.
On June 18, 1986, the operator was escorted to St. Louis, Missouri, by the plant HP, where similar and additional tests were performed.
The following excerpts were derived from the medical consultant's letter:
The physician explained to the operator the physical characteristics of the various types of ionizing radiation.
Subjected the operator to a complete blood test that involved a 21 test chemical profile.
All were completely normal.
Subjected the operator to a series test blood chemistry, to include uric acid, albumin, and blood platelet count.
No problems were noted.
In addition to the medical examination, the operator was also subjected to a hand survey for alpha detection by the Radiation Safety Officer of the University of Washington, St. Louis, Missouri, The RSO used a Nuclear Chicago M-2670 with a 2641 alpha probe calibrated on February 11, 1986, to survey the Production Operator's hands.
Results of the survey are shown in the attached table.
During the inspector's inquiry the Production Operator noted that discussions of concern were held with his supervisor, the HP, and the NLS&A Supervisor.
He also noted that the discussion he held with the physician was similar in scope to discussions held with the NLS&A Supervisor.
The contamination level was largely alpha.
There was no evidence of a skin break or other mechanism to allow the uranium to enter the worker's body, and the alpha contamination would not result in an external dose to living tissue.
In the absence of significant beta contamination or internal alpha contamination, no significant personal exposures would be incurred by the workers.
Although the licensee had not established preselected skin decontamination levels, decontamination attempts were administered in conjunction 8
i i
with a medical consultant.
Complete records were maintained and periodic surveys indicated that contamination levels became significantly less than the 220 dpm/100cm2 action level for removable surface contamination to the skin (Regulatory Guide 8.23).
The inspector concluded that the licensee programmatically reduced the problem of worker hand contamination and that recent surveys have detected background levels.
The licensee acknowledged that continued surveys a a weekly basis conducted at the exit areas are in order.
The licensee also acknowledged that random surveys should also be extended to include surveying the workers' privately owned automobiles.
One violation was identified.
5.
Operations Review The inspector observed the licensee's performance of plant operations to include handling and storage of SNM material in accordance with applicable regulatory requirements.
In addition, the inspector reviewed l
with the licensee the status of operations at the Hematite facility.
a.
Observation of Operations The plant was processing uranium enriched to 3.7 percent.
In recent months, the process only included the conversion of UF8 to U02 powder.
Currently, there are no plans to make fuel pellets.
However, a study is being conducted to determine if any facility modifications are needed to increase the maximum enrichment limit allowed by the license from 4.1 to five percent U-235.
I In a recent license amendment, authorization was granted for the licensee to receive, perform measurements, and dispose of a 2.5 curie Co-60 sealed source.
This was completed in accordance with Amendment No. 4 to materials license SNM-33, before the May 31, 1986 deadline.
On April 17, 1986, the licensee was granted authorization to increase the possession limit for source material from 20,000 to 50,000 kilograms.
The inspector reviewed the licensee conditions for the increase in source material quantities, examined the storage location, and agreed that the licensee can store 10-ton cylinders on the existing storago pad.
b.
Housekeepina Portions of the scrap recovery plant were not operating.
Hence, the area had been cleared and placed on hold until the next scheduled campaign.
It was noted that scrap campaigns are usually scheduled l
during colder weather.
Although, the overall housekeeping effort at l
the facility was satisfactory, the inspector noted that the licensee had become lax in administering the ALARA concept.
Section 4, Radiation Protection, discusses results of recent radiation surveys.
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No violations or deviations were identified.
6.
Transporta on The inspector reviewed the transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt, packaging, and delivery of licensed radioactive materials.
During the first half of 1986 the licensee has delivered over 1850 cubic feet of radioactive waste to waste disposal sites.
In one instance a variance was grarW d by the State of Washington via U.S. Ecology license.
In order to dispose of contaminated oil (60 cubic feet of cement - oil mixture) at the U.S. Ecology site, the shipper must either solidify or
-abserb the oil and place the mixture in a four mil plastic lined metal container.
The variance was granted to omit the plastic liner because the oil was presolidified in cement.
No violations or deviations were identified.
7.
Maintenance Surveillance
.The inspector examined the licensee's maintenance operations to determine if records are,u In additio N the in)sintained on plant systems pertinent to safety.
spector observed the licensee's performance during a 15-minu(e power' failure.
The inspector reviewed the licensee's preventive maintenance records and determined that maintenance was being performed in accordance with an approved schedule.
The inspector noted the frequency of checks on plant systems pertinent to safety.
Daily checklists. Oil levels and pressure readings are checked on the air compressor.
Weekly checklists.
The battery and oil level are checked weekly in the emergency Generator.
Monthly checklists.
The plant maintains five cranes (1/4 to five ton capacity) that are used in the processing of special nuclear material.
In response to inspector concerns, the licensee acknowledged that inquiries would have to be made to determine whether the level of maintenance performed on the five-ton crane is adequate.
The five-ton crane is pertinent in the handling of 2.5-ton UFs cylinders.
The Maintenance Supervisor indicated that effective communications and feedback from shift to shift requires either verbal (face to face) or telephonic, and/or review of log book entries.
A printed tag " HANDS OFF" is used, as determined by the Maintenance Supervisor, to alert plant personnel about equipment out of service.
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While the inspector was examining the production foreman's log book the plant experienced a 15-minute power outage.
The inspector noted that the Production Foreman, Productiun Operator, and Maintenance Supervisor occupied positions in the control room in order to expedite the return of the plant to normal operations. The two emergency generators self-engaged during the power outage and supplied power to the nuclear alarm monitors, control room panel oxide plant, boiler, and other plant equipment.
The emergency lanterns were also self-activated and provided enough illumination for personnel to proceed to their work stations.
The only mishap noted was failure of the meter in one of the nuclear alarm monitors to return to zero after the power was restored.
This was corrected by the Health Physicist.
The power failure procedure provides instructions to assist personnel in the areas of production, scrap recovery, and laundry operations.
In highlighting maintenance achievements during the first half of 1986, the licensee noted that the cylinder used in the process as a cold trap for UFs solidification was recertified, and the main steam boiler was inspected.
No adverse conditions were noted.
In response to inspector concerns, the Maintenance Supervisor noted that Combustion Engineering employed a fire guard during welding operations. The only fire recalled was promptly located in a Dempsey Dumpster trash container.
No violations or deviations were identified.
8.
Environmental Monitoring The inspector reviewed the licensee's documentation of monitoring results
^
involving periodic sampling of air, soil surface, groundwater, and vegetation.
No problems were noted.
m The licensee's sampling locations are shown in the table presented in the November 1982 report entitled, Environmental Assessment Related to Renewal of Special Nuclear Materials License No. NSM-33.
Decontamination of the evaporation ponds and tha survey and disposal of spent limestone are still proceeding in accordance with the license requirement.
The inspector reviewed results of drinking water analysis.
Levels of radioactivity in onsite drinking water compared favorably with total alpha and beta activity in drinking water samples obtained in the nearby town of Hematite, Missouri.
No violations or deviations were identified.
9.
Criticality Safety The inspector reviewed the licensee's documentation of facility changes requiring criticality considerations, including determination of whether the licensee has positive management controls to ensure that facility operations are conducted within nuclear criticality safety limits.
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5 a.
Nuclear Safety Analysis The inspector reviewed documentation of the following facility M
changes requiring criticality considerations performed since December 1985, Inspection Report No. 70-36/85003(DRSS):
A request was submitted to install a 55 gallon shop vacuum behind the platform of the powder drum loading station.
The vacuum is dedicated for the pick up of non-uranium bearing material, such as vermiculate insulation.
There doesn't appear to be any criticality significance.
A sign will be posted for the vacuum pick up of clean shipping drum insulation only.
Approval was requested to relocate the UFs vaporizers.
By moving the vaporizers six inches forward (west) wall siding may be added to enclose the dock.
A trench for drainage to direct steam condensate from the vaporizers will also be provided.
There was no design or dimension change that will affect the interaction between two cylinders of UFs stationed at the vaporizer. The existing configuration was moved forward by six inches to accommodate the construction of a new wall.
The inspector examined the configuration of the two vaporizers and concluded that the modification did not require a new criticality calculation, b.
Open Item The inspector reviewed the comments concerning an open item mentioned in Inspection Report No. 70-36/86001(DRSS).
There appears to be an ambiguity _between nominal enrichment and actual enrichment when comparing safe batch mass limits.
The posted nuclear safety sign uses nominal enrichment ranges, such as:
Nominal Enrichment U-235 Safe Batch Limit 3.2 - 3.4 35 kg 3.4 - 3.6 32 kg 3.6 - 3.8 28 kg According to the previous inspection (listed above) eight containers exceeded the safe batch limits when actual enrichment was used.
For example, a container showing an enrichment of 3.615 percent U-235 had nearly 32 kgs of material.
This appears to exceed the mass limit.
The nominal value of 3.615 is 3.6 which allows up to 32 kg per container at that enrichment.
The ambiguity is discovered when it appears that 3.615 falls between 3.6 - 3.8 allowing a mass limit l,
of only 28 kg.
In reviewing this matter with the Nuclear Licensing, 12
6 l
Safety, and Accountability Supervisor it was determir.ed that the existing limits as posted are only 43 percent of a critical mass, and two containers stored side by side would approach 36 percent of a critical mass.
However, the licensee has agreed to review this matter and determine if a license amendment application is in order.
The inspector examined the computer run consisting of more than 40 pages showing the mass contained in each storage container.
The maximum mass limit was exceeded by only 25 grams in a given container. The licensee is considering modifying the job traveler to agree with the mass allowed by critice.lity storage requirements.
The excess weight is due to moisture absorbed by the uranium oxide.
The open item will remain (Inspection Report No. 70-36/86001(DRSS)).
No violations or deviations were identified.
10.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the onsite inspection on August 1, 1986, and by telephone with the Health Physicist and the Nuclear Licensing, Safety and Accountability Supervisor on August 12, 1986. The inspector summarized the scope and findings of the inspection.
In response to certain items discussed by the inspector, the licensee:
a.
Acknowledged the ' inspector's comments concerning administrative control of SNM storage arrays.
b.
Acknowledged the inspector's comments about higher echelons of maintenance for trane operations.
c.
Agreed to continue random radiation surveys on personnel exiting the plant; extend the random surveys to include privately owned automobiles.
During the course of the inspection and the exit meeting, the licensee did not idencify any documents or inspector statements and references to specific processes as proprietary.
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Atttchment CE OPERATOR, SKIN SURVEY JUNE 18, 1986 i
Net 4n Net Activity.
Net Activity Surface Count Rate Conversion Per 100 cm2 Averaged over Surveyed Detected (cpm)
(Approximate dpm)
Based on approximate
- Entire Surface 2
Detector Size of Hand dpm/100 cm.
dpm/100 cm2 4
Right Palm
- 15 260
+210
$90 Left Palm
~20 350
- 280 120 Right Forearm 0
0 0
0 Left Forearm
- 10 170'
- 137
~60 I
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- Nominal surface area of hand taken to be 300 cm2 i
.I 2
(Regulatory Guide 8.23, specifies action level for removable skin contamination of 220 dpm/100 cm for commencing decontamination attempts under the direction of Radiation Safety Officer or Medical Consultant).
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