ML20212K819

Insp Rept 70-1257/86-05 on 860721-25.Violation Noted:While Performing Equipment Maint,Electrician Spilled Uncontained Visible UO2 Powder Which Was Not Reported to Hpt

ML20212K819
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/14/1986
From:	Brock B, Skov D, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212K804	List: ML20212K800 ML20212K806 ML20212K819
References
70-1257-86-05, 70-1257-86-5, NUDOCS 8608250073
Download: ML20212K819 (12)

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. U. S.-NUCLEAR REGULATORY COMMISSION s

REGION V Report No. 70-1257/86-05 Docket No.-70-1257' License-No. SNM-1227 Safeguards Group:'I Licensee: Exxon Nuclear Company 2101 Horn Rapids Road Richland, Washington 99352-Facility Name: Richland Facility 1

Inspection at: Richland, Washington Inspection Conducted: July 21-25, 1986 Inspectors: . D.O. IMA[m Date Signed B. L. Brock, Fup Facilities Inspector AaRdL~ Date Signed D.D.Skov,RagationSpecialist Approved by: "A /J. I h // m R.D.' Thomas,Chpf Date Signed Nuclear Materials Safety Section Summary:

Inspection on July'21-25, 1986 (Report No. 70-1257/86-05)

Areas. Inspected: A routine. unannounced inspection was condacted of management organization and controls,, training:and retraining, criticality safety, operations review, maintenance und surveillance testing, radiation protection, transportation / radioactive waste management, and emergency preparedness.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020,

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88025, 83822, 84850, 86740/88035,.and 88050 were covered.

-Results: One violation was idSntified in the nine areas inspected.

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DETAILS ,

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1. -Persons-Contacted. 4 I ,

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S *R. G. Frain, Manager, Operations.-~ Richladd l N j c]' 1. ,

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R.'A. Schneider,'. Staff Specialists, Safeguards' 5.< _f

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• T. C.;Probasco, Supervisor, Radiological and-Industrial' Safety . ' ' E: .

,c *L. D.' Gerrald, Criticality Safety Specialist' , .- - ' i ~N s *J..E. Pieper, Specialist, Health Physics  ; ,

• R.:H. Purcell, Manager, Safety and Security c .

'E. L. Foster,' Radiological Safety Assistant'

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• M. K. Valentine, Manager, Plant Operations' '

s W. E. Stavig, Senior Operations Analyst <

• C. W.' Malody,' Manager,- Corporate Licensing. - ,

• W.-G. Keith, Plant Engineer, Chemical and Conversion 7

• D. C. Lehfeldt,' Manager, Operations Planning and Scheduling '+ ' ,

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• H. L. Caudill, Manager, Process ~and Equipment Engineering _

E. T.; Johnson, Superviscr, Analytical Laboratory ,

L. Bisping, Senior Engineer, Equipment.and. Maintenance Engineering-J. - Phillips ,-- Shif t . Supervisor,- Conversion -

.D. W. Wade; Lead Control Room Operator-L. Klug, Senior Technician- '

M. Foley, Senior Technician B. R. Denning,' Chemical Operator Technician '

G. V. Mulligan, Supervisor, Shipping S. R. Lockhaven,. Specialist, Industrial Hygien'e

. M. J.' Hill', General, Supervisor, Chemical. Operations J. Cudmore, Senior Health Physics Technician J. Payne, Control Room Operator, Line 2 D. Belt, Health' Physics Technician R. A.' Nunamaker, Lead Materials Controller G. York, Health Physics Technician R. D. Norman, Lead Technician B. Peters, Technician

• Denotes those attending the exit interview.

2. . Management Organization and Controls Section 9 of License SNM-1227 incorporated Part I and the Appendixes to Part I of the licensee's application'as license conditions.

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, A. , Organizational Structure Section 2.4 of the license. application requires certain

, , organizational divisions of responsibility to provide a' check and balance system in the important areas of plant safety.

(1) The inspector reviewed the Senior Operation Analyst's monthly production criticality safety audits. Items identified during

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. the audits were expeditiously corrected. This{ closes item '

(86-03-01).

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[^* "(2) The. minutes of the monthly meetings of the licensee's' Safety.

Committee were reviewed by.the inspector. The licensee's

- response to identified problems was expeditiously undertaken.

No incident review' boards were required for licensed

, activities. <

No violations were identifie'd.

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3. Training and Retraining s 'Section 3.10'of the license requires a program for th'e training and-retraining of employees in the subjects of radiation protection, .

criticality safety,-industrial safety, fire protection, and emergency-procedures. ,

The inspector reviewed the completion of training of four operators and one electrical equipment: maintenance worker. A check of the training

-records show that two of the employees who were hired on September 19,

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1985 had received initial instruction within two weeks following ,

o employment as required. Annual. refresher training was last completed by L

all five workers during the months of September thru November, 1985 as

- documented by written tests. Respirator Fit-Test Records were sigr.ed by these employees to acknowledge'that they were instructed in the,, '

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selection, use,-and maintenance of negative-pressure respirators.1, 1

No violations were identified. '[

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a 4 '. -Criticality Safety <

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Section 3.2 of the license application requires assurance,of; criticality *

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safety through both administrative and technical practices.

_ Section 3.2.1.-1 of the license application \ requires criticality safety 1 analysis of all" applicable processes in accordance wit _h Section 2.3.20 of ' ,

the license application and all determinations of Nuclear. Criticality Safety be reviewed and approved by a second party reviewer in a'ecordance with the requirements. 7

,. '(1) The -inspector's review of the criticality safety activities found ' .

that three criticality safety. analyses werefcompleted since the.last

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. inspection. The analyses were reviewed and approved b'y a 'second party reviewer as required. One analysis evaluated operations with p and storage of UF cylinders containing 5.0 weight percent U-235.

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- Another analysis addressed a revision to the UF cylinder washing 6

station. .A third analysis was for changing from mass control to slab control for stations used for cleaning centrifuge bowls. The licensee's effectiveness in assuring compliance with new slab control procedures will be reviewed during the next inspection-(86-05-01).

(2) The inspector reviewed the bimonthly criticality safety audits conducted by the criticality safety analyst. The audits had been conducted as required. They included the UO3 Building, the Specialty Fuels Building, the Engineering Laboratory Operations

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Building, t[he Wareho~ u ses,' and outside areas. No violations were

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- identified;by the-licensee in.the bimonthly audits.

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.(3) The inspector also reviewed the m'nthly o criticality. safety audits In audit number 226'the'

- made by the Criticality' Safety Specialist.

, specialist identified improper . storage of a drum of, uranyl nit. rate -

hexahydrate.(UNH) product from the Liquid Uranium Recovery (LUR)-

1 . system. The drum had been placed on the same pallet as a drum already in' process. The twelve inch-spacing required by the posted

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' criticality limitLeard.had

not been maintained. This violation, l identified byLthe licensee was promptly corrected, steps-taken.to

. - preclude its recurrence. appeared' appropriate, reporting was not.

required, and a'similar incident had notLbeen: cited in the past.two

- years. The licensee's corrective actions, still being formulated, 3- willsbe reviewed'during the next~ inspection (86-05-02).

. (4) ~The inspector reviewed the status of the implementation of the recommendations of the. licensee's criticality safety' task force.

, 'All:but.three of.the recommendations had been implemented. The.

<"" remaining recommendations inclu'de: - (a) improvement in clarity and 11 formatting of criticality safety specifications.(CSS), (b) relegate CSSs to.a secondary reference role and.use criticality limit cards at.each station as the primary control,,and (c),,reinstitute the

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annual criticality safety appraisal and include it in a revision of -

EXN-30. Progress on each of these items will be reviewed during the i . next inspection.- Item'(85-02.05)' therefore remains open.

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No violations'were identified.

. J-5.- -Operations Review - ,

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Section 2.1"o'f the license application requires the licensee to conduct' business' inca manr.er sofas lto assure that'the licensee facilities are-

' safe'fromiradiatien'and'other nuclear hizards, and the operations will not< be detrimental ltc the environs and to assure that personnel radiatica

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b explosures, both in plant and.offsite,' are maintained as low as is .

' reasonably; achievable'(ALARA).

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! A. Conduct of Operations

'(1) The LUR system was in routine operation. A centrifugeLhad been added to:the system. ' The solids retrieved from the centrifuge are, added to the contents of lagoon three and the filtrate from' st he.-process is piped to. lagoon four. The product uranyl

nitrate solution is fed to 55 gallon drums for storage.

(2)_ The Gadolinium' Scrap Recovery Process'(GSRP) was noticeably

. free of organic solvent odors. The licensee stated the laboratory ventilation had been improved. Sampling-by the

i. licensee for organic vapors in the GSRP is also being given closer attention. - Individual sampling units are scheduled to be used as part of an assessment of the laboratory's 1

atmosphere.

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.(3),,The inspectors visited the Neutron Absorber Facility (NAF) in the Specialty Fuels (SF) Building. The process was not running at the time of the visit.

'(4) The status of the incinerator installation in the SF Building was observed. .The floor in Room 173 has been prepared to receive the base of the incinerator.

(5) The licencee had put piping, pumps, and valves inplace to

. transfer the UNH from washing heels from UF g cylinders into a 55 gallon drum located in a new location. The drum was previously filled in the Line 2 airlock. The present location precludes the airlock contamination the licensee was experiencing.

B. Licensee's Procedures and Practices (1) The inspector reviewed the licensee's procedure for neutralization of hydrofluoric acid (XN-NF-22 P66,727 Rev. O,

" Neutralization Tank Operation"). The procedure specified the protective equipment to be worn by the operator. It also clearly indicated the steps to be taken in the event of a chemical burn. Appropriate first aid materials are available in the Health Physics Technician (HPT) office. The inspector also checked the location of the tanks used for neutralization and the locked and shielded pumping station where the sodium hydroxide was stored. The licensee's system reflected careful planning.

(2) The licensee is required by Section 2. of Appendix I of the license amendment to assure containment of stored plutonium contaminated waste by verification at least every six months by visual inspection and smear surveys of the containers. The waste material was generated from fuel processing operations, and from decontanination efforts following the shutdown of the mixed oxide production line. Each of the thirty-four waste drums stored has a log sheet identifying its contents.

Although Appendix I also stipulates repackaging may be necessary to provide continued containment, it appears that these containers will likely be stored until disposal of concentrations greater than 100 nCi transuranics (TRU)/g are permitted. The licensee indicates the dilution factor to reduce the current concentration to less than 100 nCi TRU/g is prohibitive. Additionally, some mixed oxide pellets in the waste complicate the problem because they are not uniformly distributed. Tte licensee has not diligently pursued resolution of this problem through formal channels such as correspondence with NRC licensing officials. This was identified as an open item (85-12-04) in inspection 70-1257/85-12 and~ currently remains open.

(3) The licensee revised procedure XN-NF-695 (P43,079 Rev. 1)

" Procedure for Weighing UF Cylinders" to include steps to be 3 cylinder has been received. The taken when an overfilled ,ur 6

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r fv UFg cylinder.will lie quarantined via~ application of 'a red hold '

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tag-identifying the cylinder number and its_ overweight status.

The Supervisor of Shipping and Warehousing will be notified and

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,, .hefor his delegate will' witness reweighing-of the cylinder; The statement that an overfilled;UFA cylinder may rupture when #

heated during processing was also added. Thisfcloses, item

((85-12-02). , , . .

t (4) ' A poor practice was observed during"the.touE.Of the 'UO' ', ' '

, .Buildingwhereinsomeequipmentservicing1resulted'inlpillage; e

, of a 'small amount of uranium oxide powder. , Appropriate,hetion

'was not taken by the' worker. -See Section 7. fo'r: detail's.

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- No violations were identifie'd. ~. [Theincident.describedin;pa'ragrapN  :

i 5.B(4);is cited as a violation in Section 7," paragraph G]. '

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. 6. Maintenance and Surveillance' Testing i u- ,'" L.J, y -

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• Section 3.12'of the S cense application requires that" periodic >testshand;  ;

.; - , inspections are conducted in~accordance with written procedures ~and'are "

- properly documented. , ,

The inspector reviewed the licensee's program!for the control of gaseous. -

. effluents and the associated' record keeping. The' licensee requires that' ,

all HEPA filters are tested and certified by the manufacturer to be at ^ '

2 least'99.97 percent efficient for the removal ~of 0.'3 micron par _ticles * '

-before..they are' installed in'the plant air cleaning systems. ' Additional ~

in place leak testing..of the installed filter bank is performed by a

. licensee / contractor using a challenge DOP/ DOS aerosol penetrant. -

Differentia 1' pressure readings across each HEPA' filter system are made

- twice per month.by maintenance personnel;and the filters are replaced before reaching the maximum pressure limits. The results of. visual ,

lnspections and performance tests of installed filters, and radiation ,

surveys made'upon filter replacement over the past year were found to be documented _and in compliance with license requirements. The inspector randomly reviewed record entries ~from February -~' July, 1986 of monthly air' flow velocity measurements.

L - No violations'were identified.

7. ~ Eadiation Protection Pursuant to 10 CFR Part 20, the licensee is required to provide

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~ protection against radiation hazards associated with licensee activities.

A. - Urine Bioassay Results -

Urinalysis results for the second quarter ~of 1986 and those

-available to date were examined by the inspector. All reportable results, with the exception of one,' were below the action level of 25 ug U/1. A second urinalysis has been requested for one worker '

following-an assay of 27 ug U/1 on July 14, 1986. A further review by_the inspector of records of several workers disclosed that an

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. initial urinalysis had been completed upon employment and' routinely.

once'per month'as required.

. B. Luna ~ Count Results~

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The results of. lung count > measurements performed since the'last inspection were-reviewed'by the inspector.. All reportable body: - :i burdens were below .the action level of 0.26 nCi. Additional records' Lwere' checked which verified that lung counts are routinely _ conducted

'on new employees who have previously handled radioactive material.

C. zWhole Body Exposure

,  : External. radiation exposure' records were reviewed for the second quarter of 1986 but were incomplete since the exposure reports for

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s most badged individuals'during this period had not yet been.

. forwarded by the contractor to'the licensee. Of the available

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records reviewed, no doses were received in excess of 50 millirems for,the^ calendar quarter.

D. ~ Airborne Contamination ,

Weekly airborne contamination level surveyfreports for the period between May 5, 1986'and July 13, 1986 were reviewed.- The raximum

' quarterly air. concentration level reported for all fourteen air

. monitoring stations which are routinely tracked-for continuous evaluation was 7.7 E-12 uCi/ml, which is below the licensee's guideline of'1.0 E-11 uCi/ml. Certain areas resulting from plant operations where higher measurable air concentration _ levels (up to 6.3 E-11 uCi/ml) were noted to occur on a weekly. basis include:the vaporization chest, blend room north, calciner drop,, grinde'r, and bowl cleanout.

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P E. Surface Contamination i -

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i The inspector reviewed records of routine and repeat follow-up.

radiation level and contanination surveys ~ completed:since: the]last 's (v inspection. The status of three corrective actionsitaken'by the- '

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licensee to improve the program of follow-up surveys:following the

+a detection of surface-contamination were also evaluated:by thes _

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Radiological Safety Assistant of the radiation and contamination'

!;; survey records for May and June, 1986.were documented-as having been .

71 reviewed by the Supervisor of: Radiological and Industrial Safety, i: This internal audit program has been expanded to include the 4

adequacy of air and bioassay sampling, waste effluent monitoring, -

p receipt and shipment package radiation. surveys,,and~certain '

c{; statistical QA testing of radiation counting instrumentation. No-

43 - significant problems were identified by the audits completed. This action closes one part of Item'(86-03-02).

f The licensee is also preparing but has not yet completed a job checklist to be used daily by each shift HPT to track follow-up contamination surveys. The training-of all HPT personnel in the use i-

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of the checklist has been scheduled for July 26, 1986. A' record

. will be prepared naming those personnel in attendance at this training session. Since the actions involving the job checklist and training had not been completed, Item 86-03-02 remains partially open and will be reviewed again during the next inspection.

~F. Instrument Calibration Air sampling and contamination monitoring instruments were checked at various locations throughout the UO2 Building to determine that calibration was within the required semi-annual period. Maintenance tags attached to the instruments were examined and all instruments

. were found to be in current calibration.

G. Radiological Safety Procedures The licensee has recently completed the final draft of;the Radiological Safety Operating Procedures Manual, XN-NF-67, Rev. 4 which is currently being distributed to management for approval.

The inspector discussed with the licensee the recommendation to provide additional information in Section 8 of the manual to address minimum time periods for follow-up radiation surveys.

During a tour of Room 100 of the UO9 Building, the inspectors observed a contamination incident 15volving an electrician who was performing maintenance on a heater in the Process Offgas System at the North end of the Line 2 Calciner. .Upon removal of the heater,

, black powder was spilled and became airborne; however, the worker

. continued maintenance work. The area war neither roped off nor posted as an "On-Mask" or Airborne Radioactivity Area. No respiratory protection was being worn by the worker. The electrician was informed several minutes later of the. presence of UO 2 c ntamination by the health physics technician who had been summoned by the Radiological Safety Specialist who was accompanying the inspectors on the tour. More detailed area surveys were performed by the. licensee resulting in virible and measurable contamination of up to 50,000 dpm from floor smegs. Elevated airborne contamination levels of up to 7.9 x 10 uCi/ml were also measured following'the analysis of filters from fixed air sampling stations located lseveral feet from the spilled powder. Nasal smears obtained from the maintenance--worker contained no radioactivity above background. Smear surveys.of the worker's hair and face reported measurable contamination of 3700 dpm which was reduced to l'ess'than 50 dpm following de_ contamination by showering. Future bioassays which have been. scheduled'by the licensee include 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> urine sampling-andla lung count within seven days. The bioassay results will be reviewed during the next NRC inspection (86-05-03).

Routine maintenance work on equipment within a Contamination Control

' Area is covered under the General Facility Radiation Work Procedure, XN-NF-P91,001 Revision 1 which requires in part that workers contact

'HPT whenever visible contamination is known or suspected to be present outside of a ventilated enclosure. The failure of the worker to cease maintenance operations in the area when visible

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Y1 3[ - contamination appeared; add tihe failure to subsequently notify HPT

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, . . of its presence was' identified as a violation ~of the above Radiation Work Pro'cedure-and of. License Condition 9.

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'H. . . Radiological Safety Audits

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' Records'ldocumentingfseveralviolations_ofradiationworkprocedures

, which were identifi'de by Radiological' Safety since' January, 1986 were: reviewed y by!thea inspector.<'Except for the most.recent' incident'

, which occurred on4 July 11, 1986,'for which.a' response had notiyet beenLreceived, sdeq'ust'e:andctimely corrective. actions appear to have' been taken by the responsible-plant s'upervisor for the reported violatif>* ons. ,

[ 5 The inspector also examined re' cords of audits performed during the 1y . months df May'and' June,(1986 by' Corporate Licensing. The' apparent '

violations identified had been corrected and one outstanding item

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from the-previous internal audit was re-evaluated and closed- '

satisfactorily. However, this; subject previously discussed as item .

(86-03_-06), will remain open until several additional safety audit-reports'have been-rev'iewed during a future NRC inspection to more o fully assess improve'ents m made in the licensee's internal audit

, program. , ,

Installation of new piping'has been completed to reroute liquid uranium and thorium waste resulting from'UF6 cylinder wash

' operations from the Lin'e 2 airlock to'the East wall of the

, Maintenance Area inside the Line 2 Conversion Room. This item (86-03-03) will-remain open pending the review of the completion of L the installation and. operating procedures ~during the next NRC e '

inspection.

- The inspectors' observed UO2 p wder c ntaminati n a the boat rollers ,

, of the NAF press in the SF Building. Corporate Licensing plans to discuss with HPT personnel the need for increased surveillance and radiation s'urveys in this part of the line process. Documentation

- covering this remaining open item, (86-03-04) will be reviewed during the next inspection ~.

- The problem of contamination on the floor underneath the conveyor

.. . belt between press number 3 and its pellet stacker in Room 100 of-b - the UO2 Building has been corrected by.the installation of a h ventilated enclosure around the conveyor belt. This action closes F -open' item (86-03-05).

One violation was identified.

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8. Transportation / Radioactive Waste Management The licensee's program for packaging and shipment of licensed material must be in accordance'with 10 CFR 20.311 and 10 CFR 71. All low-level 4

radioactive waste prepared by the licensee for disposal must also be l classified and' labeled to conform to the requirements of 10 CFR Part 61.

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Transportation activities are covered in detail under.the recently-

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, . revised and managementlapproved Purchasin'g'and Logistics Policy.and.

Procedures: Manual', XN-NF-695'(Rev. 5). The licensee has an extensive QC

. program and check lists are used by the shipping-group to help ensure- j NRC/ DOT. compliance.

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( To;date a total of sixteen shipments of radioactive waste .

have'been made to the'U. S. Ecology operated waste burial. site on the 1Hanford Reservation. Several records were select'ed for examination of these. waste' shipments. The recordsof one of the shipments containing l

, . 26.5 curies of plutonium and americium waste in a_ concrete cask,' which was senti to>the Hanford' Burial Site on January 13,-1986, was determined to.be in: error. The Bill'of Lading had' described the shipment as: , '

/I containing Class A/ Unstable waste'and with Class A waste labels applied although the waste manifest; correctly identified'the shipment as waste

-. form Class C. . A phone , conversation' between the : inspector and the State' ,

( of Washington inspector at the burial site on July-31, 1986g disclosed ~

that'the concrete cask had been received and handled.as Class C waste by ' 't-

. U.'S. Ecology. nNo DOT /NRC violations had been identified upon receipt of "I

o the shipment.. .

C. ,$ li The inspector examined a Tri-State Motor Transit vehicle which had been' '

loaded with 97 drums of LSA radioactive waste ' generated by the li~censee .

for exclusive use' shipment to the Hanford Buri'al/ Site. . DOT and'NRC 7 7 requirements ha'd been satisfied with regardft'oshipping.papersy waste . O^'_

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classification and. packaging, drum.labelin'g, radiation surveys, and pla,cardin~g.'. .

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9. Emergency Preparedness

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Section 3.9 of the license application addresses the licensee's Emergen'cy?

Plan (XN-NF-32) which includes a listing of procedures that have been

• prepared to implement the plan. ,

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-A.  : The inspectors visited-the Eraergency Command Post and observed that the criticality alarm silencer switch had b'een installed and was- '

locked in the on position (i.e. alarm will sound). Further, an, alarm condition occurs'in the Central Alarm Station whenever the l~ silencer is in_the off (no alarm) position. The key cannot be

! removed when the silencer is in the off. position. This closes item. ,

l (85-12-01).

i' B. It was noted that the emergency radiation survey and personnel monitoring instruments were maintained in current calibration. It.

• was also-reported that the Administrati~on Building emergency l equipment storage location had been relocated from the back of the building to the personnel interview room in the front of the same building.

C. The licensee stated that the Richland Fire Department (RFD) responds to onsite problems and has participated in drills.with the licensee.

l. If'needed, additional resources are requested by the RFD under the City of Richland Mutual Aid Agreement. The RFD also participates in

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, the licensee'_s ons~ite fire' extinguishment, training; The RFD smoke _ .,

trailer is'used f.or training the ExxontEmergency-Cadre who us~e SCBA. '

Emergencies extending offsite; result in activation of the Benton and b

Franklin Counties Emergency Response Plan which covers fixed nucleare

-facilities. The licensee has a. copy of the plan.

'D. Thh licensee's drills have included discussions of UF releases by '

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emergency cadre who would respond to such a. release. 6-Drills have-

. also, included treatment of-injured persons wearing simulated wounds.

The nearest local hospital,.Kadlec hospital, has not participated in

'a drill with the licensee. Although slightly contaminated patients would be treated at Northwest ~ Health Services during normal hours, off shift hour similar cases would be treated at Kadlec Hospital with licensee. health physicists in attendance. It would. appear that the hospital.may'need some preparation time to prepare for receipt.

of the patient and to minimize contamination of their facilities. .

The results.of the licensee's effort to enlist the hospitals ^

. participation in drills will be reviewed in the next inspection

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(86-05-04).

NoLviolations were identified.

10. Exit Meeting The results of.the inspection were discussed with the licensee's staff identified in~Section 1. The topics included:

.The areas inspected. )

Two potential _ violations were identified: '

a. Failure of a worker to control a spill by stopping work, and seeking help;

b. Failure to properly categorize and label a waste shipment.

i Closure of open items:

(85-12-01) Installation .of a key operated howler silencer switch; i

(86-02-02) Procedure addressing licensee's action on receipt of.

an overfilled UF cylinder; 6

(86-03-01) Need for more detail in the Senior Analyst's'" audit--

findings; s

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Y- .(86-03-05) Control of floor contami~ nation between the:line 2 ,

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pellet press and its stacked.

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Items remaining open: -..

(84-10-02) Pallet contamination control improvements; s

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E Cill 11 (i .

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1(85102-05)*D. Critical ~ity' Safety' Task Force recommendation p, M QJ, I ' imp ~lementation;

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-(85-06f01) ' Ventilation 4 improvement around.the drum. tumbler;

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L(85-12-04) ,' Dispos $l,of34drumsofTRUw'aste;

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, . . i(86-02-01) . a) -Pressure based UF 6 cylinder heating shutdown; b) fAutomatic inchest TC placement, currently

, . considered not feasible; i

(86-02-03) . Emergency scrubber capacity reevaluation;

'(86-03-02)" b) Retraining of Health Physics" Tech'nicians;

. c) Job checklist' preparation;

.(86-03-03) Relocation of UF6 cylinder rinse storage drum; (86-03-04)-  : Documentation of corrective action needed for

^- resolution of the boat roller contamination at the-1 .NAF press; (86-03-06)l Corporate licensing improvement in records tracking discrepancies through 1 their resolution.

New-open items:

~

-(86-05-01)- Check' licensee's performance where mass control'has been replaced by slab control; (86-05-02) Check compliance with control. limits on UNH barrel spacing; (86-05-03) Review results of additional bioassays which have .

been scheduled by -licensee. of a contaminated

, . maintenance worker;

_ ;(86-05-04). Check licensee's plans with regard to interfacing with the hospital regarding lead time needed for preparation to receive a contaminated patient not requiring the shielded facility.

Semiannual inspection and smear survey of the 34 drums of TRU waste.

- -4

. Measurement of noncombustible waste separated before incineration of

, combustible-fraction.

e.

4 Lessons. Learned Task Force Report KUREG-1198.

l-Enforcement guidance,10 CFR P' art 2 Appendix-C,Section V.A.

E addresses'the, conditions which if met the NRC may not issue a

.. violation'for a licensee identified item.

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