ML20215G250
| ML20215G250 | |
| Person / Time | |
|---|---|
| Site: | 07000984 |
| Issue date: | 06/08/1987 |
| From: | Brock B, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20215G213 | List: |
| References | |
| 70-0984-87-01, 70-984-87-1, NUDOCS 8706230182 | |
| Download: ML20215G250 (13) | |
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- O U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-084/87-01 Docket No.70-984 License No. SNM-942-Safeguards Group: V Licensee: Battelle Pacific Northwest Laboratories P. O. Box 999 Richland, Washington 99352 Facility Name: Pacific Northwest Laboratories .
Inspection at: Richland, Washington i Inspection Conducted: April.27 - May 1, and May 14, 1987 Inspector:
- 8. 'L. Brock, Fuel Facilities Inspector
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Date'Si ned Approved y:
R. 'D. Th'omas, Chief
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Dite' Signed Nuclear Materials Safety Section '
l Sum-nary:
Inspection on April 27 - May 1, and May 14, 1987 (Report No. 70-984/87-01)
Areas Inspected: A routine unannounced safety inspection was conducted of management organization and controls, . training, criticality safety, operations review, radiation protection, transportation / radioactive waste management /10 CFR Part 61, environmental programs, and emergency preparedness.
During this inspection, the procedures covered were 88005, 88010, 88015, 88020, 83822, 86740/88035/84850, 88045 and 88050.
Results: No violations were identified in the ten areas inspected.
8706230182 870615 ,
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- 1. Persons Contacted: I
- J. T. Donovan, Manager, Laboratory Safety Department S. C. Hawley, Senior Engineer
- D. E. Lucas, Manager, Radiological Engineering P. H. Burke, Hazardous Material Transportation
- V. C. Asmund, Senior Development Engineer, Radiological Engineering J. E. Coleman, Electron Microscopist A. R. Bruce, Building Manager J. L. Allen, Supervisor, Radiation Protection P. M. Hickey, Safety Training Coordinator J. E. Lester, Senior Technician R. E. Filipy, Safety Education Leader R. B. Richmon, Senior Development Engineer J. J. De Myer, Emergency Preparedness Specialist R. M. Gough, Sr. Development Engineer - Fire Protection T. S. Allen, Deputy Fire Chief D. C. Hill, Radiation Protection Technologist J. B. Webb, Assistant Building Manager J. B. Harrison, Jr. , Radiation Protection Technologist G. L. Van Arsdale, Senior Engineer P. A. Wright, Technical Leader M. W. McCoy, Waste Management Engineer L. C. Carrick, Senior Specialist
- Denotes those attending the exit interview.
United States Testing Company Contacts:
l V. H. Pettey, Vice President / General Manager N. H. Hembree, Director, Quality Assurance G. R. Rao, Director, External Dosimetry / Hazardous Substance Analysis M. M. Lardy, Director, Radiochemistry A. V. Robinson, Director, Quality Control
- 2. Management Organization and Controls The licensee is authorized to use Special Nuclear Material (SNM) under license SNM-942 in 6ccordance with the statements, representations, and conditions contained in Part 1.0, " Criteria and Administrative Procedures," of the licensee's application dated May 9, 1979.
A. Organization Structure Section 1.3(A) of Part 1 of License SNM-942 requires that the licensee maintain a unique department responsible for the establishment and conduct of all radiation protection and nuclet.r safety programs. This department will be separate from the operating departments.
2 The Laboratory Safety Department remains separate from the operating departments although some reorganization has occurred. The reorganization resulted in the absorption of the. Hazardous Materials Safety Section within an Occupational and Environmental Safety Section that it; comprised of an Industrial Health and Safety Group and a Waste Management and Environmental Compliance group. The criticality safety responsibility, temporarily residing with the Laboratory Safety Department managers staff, is planned to be transferred to the Radiological Engineering Section. See Section 4.B for additional details.
B. Procedure Controls Section 1.3 (page 6) of Part 1 of License SNM-942 requires that the license maintain formal administrative procedures for radiation protection and criticality safety.
The licensee maintains formal administrative procedures for i radiation protection and criticality safety- The licensee recently completed a trend analysis of Off-Normal Events. A significant decrease in the number of events had occurred. The causes of the events had also shifted from principally personnel related to ;
principally procedure related. Appropriate emphasis in training was '
a part of the corrective actions. The licensee ider,tified and
, adequately corrected a procedure problem wherein a revised criticality safety specification was not provided and contributed to a violation of the D-Cell possession limit. See Section 4.A for details. Additionally, the licensee !dentified and adequately corrected a radiological safety problem where minor contamination had been carried offsite on the personal socks of several machinists. See Section 6.A for details. No NRC licensed material was involved in either operation.
C. Safety Committee Section 1.3(E) requires the licensee to maintain a Safety Review Council as established in Management Guide 12.7 to review program designs and safety analyses where the direct or indirect consequences of a credible accident are deemed to be of substantial magnitude.
The manual recommended by the licensee's Triennial Safety Review Board, ' Manager's Guide to Safety', was issued in September of 1986.
This closes iten (85-01-02).
No violations involving NRC licensed materials were identified.
- 3. Operator Training and Retraining Section 2.3 of Part 1 of License SNM-942 requires that the licensee provide training in radiation protection and criticality safety.
The training program has been strengthened with the addition of a Safety Education Leader. Recent efforts resulted in ccimpletion of Hazardous
7 3 Material 'Right To Know' training. Efforts directed toward 'Right To
- n. ,Know' training for researchers are being delayed pending receipt of a new standard being develbped for laboratory operations. The new standard will address the inherently smaller quantities of. hazardous materials used in laboratories relative to the larger quantities used_in direct support of production operations. The 'Right-to-Know' training was given selectively wherein the training modules used were matched to the needs of the craft in attendance. The course " Hazardous Waste Management" was given separately early in the Hazardous Materials Training Program. The status of lesson plan preparation and presentation of each module is documented on a Status of Training Module data sheet.
During the inspection an introductory VCR tape on criticality safety was being viewed by a small group. The tape, Part II of a three part series appeared informative. The Senior Engineer Nuclear Safety indicated the tape was very informative and was prepared by.the Lawrence Livermore .
National Laboratory (LLNL).
No violations'were identified.
- 4. Criticality Safety
'Section 1.3 (page 7) of Part 1 of License SNM-942 requires that for work l involving fissionable material, the licensee allow the Two-Contingency Policy and maintain formal procedures for implementation of the policy.
The principal procedure for control of fissionable material is the Criticality Safety Specification (CSS),.which provides limits that ensure criticality safety in specific operatiens with fissionable materials.
A. Criti.cality Safety Analyses No criticality safety analyses were required for licensed materials since the last inspection.
There were-two Unusual Occurrences (U0) wherein the Criticality Safety Specification prescribed limits were violated. The licensee stopped each operation, evaluated each incident, and planned and executed appropriate corrective actions. No NRC licensed materials were involved in these incidents. The licensee's corrective actions were reviewed because they reflect on the licensee's practices and serve as an indication of what can be expected if such incidents should involve NRC licensed materials.
(1) In the first UO the problem stemmed from cleanup of a glove box in the Critical Mass Laboratory followed by ' cutting it up for disposal. The nondestructive assay (NDA) of the resulting waste boxes by neutron and gamma counting yielded plutonium values that exceeded the quantity measured in the glove box before it was sectioned. Operations were halted and evaluated. ,
Appropriate steps were then planned, approved, and executed. !
f The actions taken included redistributing the packages from three of the waste bnxes into waste boxes and drums.
Remeasurement of the packages, the waste boxes and the drums resulted in all waste boxes and drums containing less plutonium 4
/ 1 4 4 than the limits specified in the Criticality Safety Specification (CSS) and the Burial Compliance Checklist (the latter is provided by the waste burial site).
(2) In the second UO the problem involved transferring fuel rods to D-Cell in the Process Technology Department before the revised CSS was prepared. The Nuclear Criticality Safety (NCS) evaluation was completed and had been posted in the D Cell operating gallery with the CSS for which a revision had been requested. These documents were subsequently misinterpreted as being the approval required to proceed. The planned fuel rod transfer was therefore made and the currently applicable CSS limit was thus exceeded. A program initiated safety review of the facility was conducted and the violation was identified.
The process was shut down. The review clarified that the CSS had not yet been revised and the problem was administrative in nature because of the compliance with the limits in the applicable NCS evaluation (NCS 86-2). During the four months of operation the spacing between the fuel rod canister and other special nuclear material (SNM) was more than the required 24 inches edge-to-edge, and further, only one fuel rod was being removed from the storage container at any time. Other applicable procedures were also being followed. A temporary variance to the current CSS was issued. This permitted the resumption of operations. A revised CSS reflecting the NCS evaluations was subsequently prepared and issued to meet the requirement for continuing operations.
B. Criticality Safety Staff Changes The Senior Engineer Nuclear Safety (SENS) position, previously a part of the Hazardous Materials :ection, is currently vacant. An effort is underway to fill the position. However, under the reorganization, the SENS will report to the Radiological Engineering manager. In the interim, if the need arose, the licensee could use the services of the current manager of the Laboratory Safety Department who previously held the position of Tech'nical Leader, Nuclear Safety. The criticality safety analysis support from the Energy Systems Department remains unchanged. The Senior Specialist Criticality Safety remains available for providing the technical bases for establishing the criticality safety limits. The license specifies in Section 4.1 authorized approval signatories to CSSs.
The licensee therefore must assure the reorganization doesn't dilute the depth of approval and concurrence required by the license.
No violations involving NRC licensed materials were identified.
- 5. Operations Review Section 1.1 (page 2) of Part 1 of License SNM-942 provides the criteria and administrative procedures set up to assure the maintenance of high quality health and safety conditions for all Battelle-Northwest work performed under this special nuclear material license.
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, 5 A. Co:tduct of Operations The NRC inspector-visited the two buildings where NRC licensed materials were stored. The items comprising the inventory in each building were checked against the inventory record. All of the items were properly identified as being present.
None of.the licensed SNM was in process, it was all in storage.
Some of the material is being held as historical samples. Some is expected to be used for preparation of metallographic mounts for future comparisons with samples that will undergo post irradiation examinations (PIE).
Room 164, a powder preparation laboratory in Building 306W where step off pad controls were questioned (Report 70-984/84-02), had been cleaned and controlled to the point where shoe covers are no longer required. The NRC inspector noted that good contamination control was apparent in a current furnace servicing project.
B. Housekeeping.
The areas visited reflected upgrading of the licensee's housekeeping practices. An improvement in contamination control was undertaken in Building 306W, Specialty Shop (see Section 6. A for details).
C. Hazardous Materials '
The Technical Leader, industrial Health and Safety (IH&S) stated that the licensee's program follows Occupational Safety and Health Administration (OSHA) and Department of Energy (00E) guidance. The licensee's private funded programs meet the same controls as the DOE contract programs. Research is currently exempt from the OSHA
'Right-To-Know' (RTK) program; however, OSHA guidance for a
'Right-To-Know' program for chemical laboratory quantities is expected soon. The chemical laboratory user differs significantly from industrial users in that smaller quantities are involved in chemical laboratory research and these chemicals are changed frequently.
The licensee's biohazard protocol addresses the carcinogens both known_and suspected as well as highly toxic meterials. The projects involving use of these materials are subjected to reviews for adequacy of planned controls, and the quantities involved, before the startup of each specific research project. All fires or accidents involving hazardous materials are investigated. Those accidents involving injuries requiring sutures and/or medication are reportable under OSHA guidelines. They are reported to the operating organization from the Safety organization at the Department Manager level. The results of the investigation are published and are discussed as topics in subsequent safety meetings.
Management safety inspection attention is focused on the area and special safety meetings may be held. The Laboratory Monitors are empowered to shut down operations because of safety concerns. They 1
, 6 are alert to.the status of the Radiation Work Specifications and they also keep an eye on housekeeping in the various areas.
A Safety Newsletter published bi-monthly facilitates wide i distribution of safety related events. The information distributed I addresses safety aspects of recent problems. The IH&S information Program emphasizes the kind of problems currently prevalent.
Although researchers are frequently involved in new areas, their attitudes towards safety have improved and their accident rate has decreased.
The staff of the IH&S section includes seven personnel trained in Occupational Safety, Industrial Hygiene Biostatistics and Fire Protection. The IH&S office maintains a current file of Material
' Safety Data Sheets (MSDS). Reviews of this kind of information on the MSDSs have been included in Safety meetings to assure hazardous i material users can recognize this important iniormation.
No violations were identified.
- 6. Radiation Protection Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.
A. Bioassay Program Performance The NRC inspector's review of the licensee's Unusual Occurrence reports found that the licensee had identified a problem wherein a group of workers.had apparently sustained contaminated personal stockings eventhough they had changed into licensee provided regulated shoes for working in the specialty machine ~ shsp. The ,
regulated shoes (a low top design) apparently permitted fine chips from the machining operations to get inside the low top shoes thus contaminating the inside of the shoes and the stockings (no NRC licensed materials were involved). The problem came to light when a personal survey using a hand and foot counter detected low level contamination on the personal shoe of a machinist. Followup surveys found the low level non-smearable contamination inside of shoes belonging to the five other machinists from the same specialty shop.
Also, the contamination was found in four of their five lockers.
The license indicated no other personal effects or skin contamination was detected. Subsequent surveys of four homes found minor contamination which was removed. The licensee's corrective action included providing regulated high-top close fitting boots, controlled plant stockings, shoe racks at the stepoff pad. Also, the licensee increased the locker and inside plant shoe survey frequency. The fines involved in this problem may also be contributing to slightly elevated uranium uptake detected in the bioassay program among these specialty shop machinists. (see inspection report 70-984/86-01 Section 5). Results from the improvements in ventilation and other engineering controls have not resulted in a decrease in the uranium uptake bioassay data. The ventilation system is under further review with emphasis on
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7 evaluating the efficiency of the elephant trunks. The elephant trunks supplement the hoods on the new machines; however, the trunks are the only ventilation on the older machines. Consideration is also being given to designing a collector which will.be serviced by the elephant trunks. Cutting oil is used in the machining operation. Its effect on the efficiency of the filtration system is also being evaluated. The licensee agreed to keep NRC apprised of the success of the effort to lower the slightly elevated bioassay results for this small group of workers.
During the site tour, survey instruments were checked for current calibrations. All survey instruments and automatic hand and foot counter systems had stickers reflecting that their calibrations were current.
The inspector toured the facilities of the contract laboratory that provides bioassay analyses and processing of external exposure measurement devices, and thermoluminescent dosimeters (TLDs). The contractor provides ample controls on the quality of the laboratory's measurements.
B. External Radiation Exposures An external radiation exposure of 4120 mrem that did not exceed the DOE limit of 5000 mrem was identified on an Event Fact Sheet. The exposure was not from operations involving material possessed under-the NRC license. The licensee's response was of NRC interest because it may have fallen short in the adequacy of the corrective action. The licensee identified this event because the exposure exceeded the authorized administrative annual control limit of 3800 mrem and the PNL MA-6' control limit of 4000 mrem. The licensee's investigation identified the cause as a delay in determining the previous offsite exposure and failure to use the required exposure assumption as specified in PNL MA-6. The previous exposure determined belatedly was 790 mrem and when added to the' current exposure of 3330 mrem yielded the exposure of 4190 mrem, which exceeds the various limits. To preclude recurrence the licensee has assigned a staff member on the project to maintain a running exposure total. The operations person will be kept informed and will assure personnel exposure guidelines are not exceeded. This cause of failure to follow the procedure which required determining the offsite exposure does not address the reason the procedure was not followed. The licensee should attempt to learn the reason for the oversight to more effectively preclude its recurrence. The pressure of maintaining a schedule could have interfered with the determination of the offsite exposure. If this was the case, then the corrective action should address the need to preclude schedules from infringing on the need to follow safety related' procedures.
The investigation should endeavor to clarify that the scheduling pressures do not diminish attention to adherence to safety related procedures. The corrective action should include training sessions that not only reemphasize the need to follow procedures, but also directly address management support for compliance with safety procedures. This would help assure that scheduling pressures, real
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or implied, are dealt with openly and that employees fully understand management's level of support for the safety aspects of the laboratory's operations.
No violations involving NRC licensed materials was identified.
- 7. Transportation / Radioactive Waste Management /10 CFR Part 61 Transportation of licensed materials is regulated by 49 CFR 100-177, 10 CFR 71 and 10 CFR 20.311. Additionally, 10 CFR 20.301 to 20.401 regulates waste disposal. 10 CFR Part 61 requires that all radioactive waste prepared for disposal be classified in accordance with Section 61.55 and meet the waste requirements in Section 61.56.
A. The Hazardous Materials Transportation Officer remains responsible for these activities. No shipments of NRC licensed Special Nuclear Materials had been made since the last inspection. Furthermore, the licensee has not made mixed shipments of radioactive and hazardous materials. The licensee's hazardous materials, under private ownership, are shipped to an authorized disposal site in close proximity to the place of use.
The licensee has successfully controlled the vc ume of radioactive waste generated at the Battelle Memorial Institute Research Laboratory at Sequim, Washington. The waste is segregated by surveying and only material exceeding NRC release limits is shipped to a radioactive waste disposal site.
No violations were identified.
- 8. Environmental Programs Section 1.3 (page 22) of Part 1 of License SNM-942 requires that gaseous effluent systems keep effluent releases as far below the limits specified in 10 CFR Part 20 as practicable.
The NRC inspectors reviewed the effluent dats for stacks on buildings in which NRC licensed materials were stored. The licensee's releases were well documented and were less than NRC release limits specified in 10 CFR Part 20.
No violations were identified.
- 9. Emergency Preparedness Section 1.3 (page 20) of Part 1 of License SNM-942 requires that emergency procedures for each separate facility conform to the plan for that plant area regardless of which Hanford contractor may operate the facility.
A. Tests and Drills The inspector visited the Emergency Command Center (ECC) for the 300 Area (each area has an ECC). The Manager Radiological Engineering
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is a participating ECC cadre and provided additional insite to the ECC operation during the inspectors visit. The Emergency 1 Preparedness Specialist explained the recent improvements to the l ECC. The problems associated with preparing status sheets, which i were taped to one of the ECC walls, to provide updated information 3 to the ECC cadre during ECC operation has been eliminated. Computer monitors have been set up at the various stations and current information has thus been made readily available. Additionally, computer and monitors now display criticality alarm status at i fifteen second intervals. The digital display of the dose at 15 second intervals indicates not only where and when an event occurred but the rate of change of dose level in the building involved. This 1 information is thus readily available to Hazard Evaluators at the '
Unified Dese Assessment Center (UDAC). The licensee indicated that the County Emergency Response Center (CERC) serves as the alternate DOE Emergency Response Center (ERC). Telephone communications - up to twenty (20) - are recorded to facilitate clarification and recheck of messages. Additionally, the Public Address system for the site can be operated from the ECC. Further, the ECC has inflatable door seals and a bottled air supply to permit operation even if the wind has airborne contamination. The ECC has the capability for direct radio contact with the UDAC, Kadlec Hospital, the Battelle Pacific Northwest Laboratories and the Hanford Environmental Health Foundation (HEHF). The HEHF operates the Emergency Decontamination Center (EDC) which is behind the Kadlec Hospital complex. The EDC is equipped for treating contaminated and injured patients. The licensee participates in a formal site wide drill involving all contractors once per year. The ECC is used about three to four times per year in addition to the annual exercise. The Manager Radiological Engineering strongly supports the exercises stating they are invaluable in identifying the plans that won't work and are in need of corrective actions. The licensee is of the opinion that team work is fostered by practice.
Additionally, the cooperative effort during critiques, adds to the benefit of the operation of the ECC and thus to the benefit of the site occupants and the surrounding community.
B. Fire Protection (1) The inspector visited the onsite fire station. The heavy equipment has been upgraded by the addition of a second "Telesquirt" capable of seventy-five feet vertical extension.
Control of the nozzle is possible from either the vicinity of the extended nozzle or from the control panel at the back of the fire truck. Their first "Telesquirt", vintage 1979, is capable of fifty foot extension and is the stations oldest piece of heavy equipment. The specifications for the six wheel drive range fire truck were set up through the onsite station.
The 1200 gallon unit has a 500 horsepower diesel pumper to pressurize the system. It also incorporates a cab roof window and elevator seat that permits operating a nozzle from an elevated position within cab (through the roof) rather than from the exposed front bumper position used on older equipment.
The licensee has four inch supply hoses to the pumpers and 2h
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I and 1 inch hoses for output lines. The pumping capacity (1500 gallons per minute) can handle the building's sprinkler system while simultaneously fighting the fire from the truck nozzle (1000 gallons per minute). The water supply lines to the site have been inspected by the licensee for scale deposits during repairs. The supply lines are reportedly experiencing corrosion more than scale buildup. The station is also prepared to handle sodium fires with appropriate materials and training. The station staff of thirty-eight provides twenty-four hour coverage. One group is continually conducting fire safety inspections, and is therefore available to man the extra fire truck at the station if necessary. When an engine from the site 300 Area responds to an alarm the fire station in the 200 Area immediately dispatches an engine from its area to provide backup coverage in the 300 Area. Additional support is available via the Mutual Aid Agreement vith the City of Richland. The fire trucks carry radiation detection equipment for which calibrations are kept current. Fire fighters receive training in the use of their radiation detection equipment.
(2) Pre-Fire Plans are prepared by the Fire Department. Critical elements are updated at three year intervals. Non-critical elements are updated at five year intervals. Changes to buildings are added to the Pre-Fire Plans as they occur. A copy of the Pre-Fire Plans is used for training. A copy is also kept in each building. The fire alarm system has been upgraded from a hard wired system to radio alarms. There are about 320 alarms in the 600 square mile area of the total Hanford Site. Of particular note is the high band frequency precludes the interference some other sites have experienced.
Additionally, the Fire Department uses a computer aided dispatch system. A further improvement is the addition of computers and monitors to the lead fire truck so this first engine can call up the applicable M ilding Pre-Fire Plan enroute to the site of the alarm. Annual appraisals by Industrial Safety assure that Pre-Fi~re Plans are kept current.
Additionally, fire safety is promotec' by the Fire Suppression Group which checks Pre-Fire Plans during building tours at 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> intervals. The Testing and Service Group tests fire alarms and does six month flow testing. The water supply is available from onsite tanks, the Columbia river, or from the City of Richland. The site 300 Area Fire Department is operated currently by Westinghouse for the benefit of the various contractors operating in the area.
(3) The fire station also maintains an ambulance which is manned by a driver and a trained Emergency Medical Technician (EMT). In responding to a call, the ambulance stops enroute and picks up the nurse on duty at the onsite medical offices. The injured contaminated person would be taken to the EDF rather than Kadlec Hospital about 99 percent of the time. This minimizes the risk of possible contamination in the hospital. The 3000 Area site where the PSL is located receives ambulance service l
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.' preferentially from the City of Richland because of closer proximity.
(4) A large propane tank of about 3000 gallons capacity was observed to have four pressure relief valves in a two pair configuration. This arrangement permits only one valve of each pair to be deactivated at a time. Further, the tank area was kept free of combustibles and was protected from traffic by barriers. The tank was painted silver as a means of temperature control.
-(5) The inspecthr observed that housekeeping in all areas visited were free of combustible waste.
No violations were identified.
- 10. Exit Meeting The rrsults of the inspection were discussed with the licensee's staff identified in Section 1.
The. topics included:
The areas inspected; The status of open items; Closure of one open item:
(85-01-02) Licensee response to ad hoc committee report on radiological and industrial safety.
Item remaining open:
(85-01-03) Review of records of Criticality Safety Specification training.
Laboratory Safety Department reorganization; Criticality safety staff changes; Controls of measurements at the contract bioassay laboratory; Improvements in the Emergency Preparedness areas of the Emergency Critrol Center and the onsite Fire Station; St4te of Washington licensing effort and the continuing NRC rejponsibility,insitedecommissioning; NRC's continuing interest in the success of the licensee's effort to reduce the Specialty Shop machinists bioassay results; and
- 12 Recognition of the absence of 3000 Area uranium processing effluent l that could contribute to the trace uranium content of the sludge at the local sewage treatment plant, l
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