ML20236B778

Insp Rept 70-0036/87-03 on 870921-25.Violations Noted:Major Areas Inspected:Fuel (U Powder/Pellet) Production & UF6 Cylinder Storage Operations During Normal Shift & off-shift Hours,Including Organization & Training

ML20236B778
Person / Time
Site:	07000036
Issue date:	10/19/1987
From:	France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236B730	List: ML20236B727 ML20236B738 ML20236B778
References
70-0036-87-03, 70-36-87-3, NUDOCS 8710260348
Download: ML20236B778 (11)

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.i "i U..S. NUCLEAR: REGULATORY COMMISSION-REGION III .

l Report No. 7tl-36/87003(DRSS) License No. SNM-33

Docket No. 76-36 1

i Licensee: Combustion Engineering, Inc. .;

Nuclear Power Systems- '

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. Windsor, CT 06095  !

Facility Name: Hematite ..

Inspection At: Hematite,LMissouri

.j Inspection Conducted: Se'ptember 21-25,'1987 '

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Inspector: G. M. #i III France, 16;/ ff7 l

Date Approved By: L. . reger,. Chief /O-/9 87 -

Facilities Radiation Date

, Protection-Section Inspection Summary Inspection on September 21-25', 1987 and September 29, 1987 (Report No. 70-36/87003(DRSS))

Areas Inspected: Routine, unannounced safety inspection of fuel (uranium . '

powder / pellet) production and UFs cylinder storage operations during_ normal shift and off-shift hours, including: organization, training, operations review, criticality safety, radiation protection program (audits, procedures,.

and surveys) and transportation activities. The inspection also' involved a determination of the licensee's progress on corrective action measures to <

previous-inspection findings.

Results: The licensee was found to be in compliance with NRC requirements within the areas examined, except for the following item: failure to follow-  ;

procedures (Section 6, Radiation Protection).  ;

f B710260348 871020 PDR ADOCK 07000036 C- PDR 0

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1. . q l DETAILS-1 1

1. Persons' Contacted G. Boyer, Health Physics Technician

• L. Deul, Manufacturing Engineer

• H. Eskridge, Nuclear Licensing, Safety, and Accountability U Supervisor

• R. Fromm, Quality Control Manager

• R. Griscom, Engineering Supervisor J. Harter, Shipping and Receiving' Foreman

• R. Miller, Manager, Administration and Production Control

• A. Noack, Production Superintendent- i

• J.~ Rode, Plant Manager j R. Stokes, Health Physics. Technician J G. Uding, Quality Assurance Engineer N.'Wilpur, Health-Physics Technician

• Denotes those'present at the exit meeting on. July 17, 1987.

The inspector also contacted the off-shift foreman concerning training of new. employees.

2 .- General This inspection of onsite licensee activities, which began at 1:30 p.m.

on September 21, 1987, was conducted to examine activities involving fuel ~

L fabrication at the' Hematite site under Material License No. SNM-33. .The l

inspector al'so reviewed the licensee's progress in correcting previous' inspection findings, the radiation protection ~ program, and off-shift' activities. An exit meeting was conducted.on September 25, 1987.  ;

3. Licensee Action on Previous Inspection Findings  !

During this onsite-inspection, the i.nspector reviewed the progress'the licensee had made in correcting weaknesses and open items. identified ,

during a previous inspection.

1 l' a. (Closed) 70-36/86004-02: Lack of an alarm on the cold trap pressure l

sensor. A panel alarm was calibrated and installed in June 1987. ,

l Vendor representatives performed the initial tests. Periodic- 1 L service will also be' supplied by the vendor. 1

b. (Closed)'70-36/86004-03i Heating'of-cold trap without pressure. ,

sensor online. .A pressure sensor has been installed and tests'for  ;

operability were completed; ,The licensee indicated that the sensors-

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response to.the tests. vere acceptable,

c. (0 pen) 70-36/86004-04: No periodic verification of. operability.of 1  ;

the cold trap load cell. Periodic checks on the' operability of the cold: trap load cell.are required and-are listed on.thefoperators data sheet. This will be reviewed during a f.uture inspection. I i

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d. (0 pen): No alarm on the cold trap load cell. An alarm for high l level weight appears on the control panel as both a visual alarm light and an audible indicator. Verification of the load cell span  !

will be monitored during a future inspection.

h. (Closed) 70-36/86004-09: No airborne-detectors to warn of ufo releases in the vaporizer area. An improvement in the ventilation system in the vaporizer room has minimized the problem of spurious alarms on the recently~ installed detectors. Only two-have been ~j raported, one from fumas generated by welding and the other from electronic malfunction.

i. (0 pen) 70-36/86004-10: The use of automatic functions to minimize spread of HF and U0 2 F2 within the plant buildings. A system has been designed, and a date to commence installation is being scheduled. This will be reviewed during a future inspection.

J. (Closed) 70-36/86004-11: Need for improved training qualification program formal documentation. This program has been implemented and will be reviewed periodically during future-inspections. More details on program requirements are found in the previous inspection report (Inspection Report No. 70-36/87001(DRSS)).

k. (Closed) 70-36/86004-12: Need to review procedure review and approval program. The licensee has made significant progress in this area. Nearly two-thirds of the operating procedures have been rewritten, reviewed and approved. A periodic review of the licensee's progress in this area will be conducted during future inspections. More details on program requirements are found in the previous inspection report (Inspection Report No. 70-36/87001(DRSS)).

1. (Closed) 70-36/86004-13: Need to evaluate method for ensuring operators are aware of procedure revisions. The licensee's use of the operating sheet acknowledgement form which allows the operator to review and initial procedure revisions continues to function adequately. The program will be monitored periodically during i future inspections. '

m. (Closed) 70-36/86004-14: Need to assure that safety parameters are correct on data sheets. Data sheets (process parameter sheets) have been modified to include only those items important to safety. The licensee indicated that modification of the parameter sheets in this manner should reduce the likelihood of operator' errors. The data sheets will be reviewed periodically during future inspections.

n. (0 pen) 70-36/86004-15: Need to expand QA/QC program to include those process components that may impact on onsite or offsite health and safety. Since the previous inspection (70-36/87001) production  ;

has increased significantly. This production increase required more QA/QC effort'on product parameters. Hence, the QA/QC audit program has not been expanded. Progress on improving QA audits will be monitored during future inspections.

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p. (Closed) 70-36/86004-18: Need to determine hydrostatic-testing requirements applicable.to the' ammonia storage tank. The licensee has examined / replaced / tested the_ valve that controls the flow of .

ammonia vapor., A valve'will also be installed in the liquid fill

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line. In each instance the valves are designed to fail safe in case of sudden pressure drop. As reported previously (Inspection Report No. 70-36/87001) hydrostatic testing is only required for reinstallation of underground ammonia storage tanks. Installation of fail safe valves in open lines to the underground' tank reportedly.

will bring the tank into conformance with OSHA requirements enacted -l since the tank was first installed.  ;

s. (Closed) 70-36/86004-30: Need to review maintenance procedures 1 '

to ensure they are current. The licensee reviewed maintenance procedures on the following items:

Ammonia Cracker l

0xide Emergency Generator  !

l Main Emergency Generator Electrical Transformers (4)

Fork Lift Trucks (2) U l

Stackers Man Lifts The inspector determined that procedures pertaining to most of the  ;

above items have been rewritten and approved for implementation. The  ;

inspector concluded that the new procedures contain checklists / '

requirements that emphasize health and safety.

v. (Closed) 70-36/86004-16: Need to index or clarify documentation of corporate audits and plant staff audits. The inspector examined the licensee's audit file and confirmed that the file now delineates the location of corporate audits and plant audits, and their corresponding responses.

dd. (Closed) 70-36/86004-27: While NFPA Standard 491 indicates that uranium dioxide can spontaneously ignite in finely divided form, the parameters for producing uranium oxides along with engineering controls and the amount of SNM material being processed minimize the potential for spontaneous ignition, kk. (0 pen) 70-36/86004-37: Need to update the quality assurance program l Tor environmental monitoring. This program is still under review.

I 11. (Closed) 70-36/86004-38: Need to expand the corporate audit of L Hematite operations. A summary of the areas inspected (including l ALARA/ environmental concerns) was attached to a recent corporate l'

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audit. The audit was presented in a format that provided greater j detail. It clearly delineates the areas inspected and specifically lists corresponding audit findings. -]g 1

mm. (Closed) 70-36/86004-39: Evaluation of the use of fixed orifices on .I the fixed air sample system. -The licensee is testing different orifice openings and adjustments'in the flowrate. Through vendor-review of critical' orifices, it was noted that while the critical orifice is a device for maintaining a constant flow rate through a sampling instrument, certain limits-such as increased static pressure capacity on the suction pump must also be considered. This program will be reviewed periodically during future-health and safety ,

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4. Management Organization and Controls l j

1 The inspector reviewed the licensee's management organization and controls for radiation protection and operation, including changes in '

the organizational structure. Two employees in production operations terminated employment with CE Hematite (one by retirement). Since the  ;

previous inspection (70-36/87001) four operators were hired bringing the I work total to 67 at CE Hematite. At the Corporate Office, Dr. P. L. McGill 'l replaced Mr. H. V. Lichtenberger, who retired, as Vice President of .t Manufacturing. Mr. J. Rode, CE Hematite Plant Manager, now reports to Dr. McGill. o 1

a. Procedure Revising and Updating i Operating procedures are being revised for staff review; operators are alerted to procedure changes via an operating sheet acknowledgement form. (This was covered in more detail.in Inspection Report No. 70-36/87001(DRSS)). According to the QA Engineer, who also acts as document control custodian, the-procedure review and approval process is nearly two-thirds complete. The l licensee had demonstrated significant improvement in this area. i

b. Review and Audits The licensee utilizes independent audits and inhouse ' audits as a means of identifying deficiencies. q 1

During the corporate semi-annual nuclear safety audit (August 1987) {

CE Hematite was cautioned about the condition of identification tags  ;

on several SNM storage containers because apparently, the numbers designating the quantity of SNM material and the corresponding enrichment level were not easily distinguished on several container j tags. The licensee promptly corrected the audit finding. J l

No violations or deviations were identified. 'j 5 ,

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5.- Order Modifying License Faulty UFc Valves On July 24, 1987, the U.S. Department of Energy, Oak Ridge Operations Of fice-Safety Division (00E), notified 'the Nuclear Regulatory Commission (NRC) of parallel cracks that were observed in and around the threads i of 1-inch valves used in 30-and 48-inch diameter uranium hex'afluoride  !

(UFe) cylinders. The cracks were observed in the valve threads of valves in' lots 17 and 20 manufactured by Superior' Valve Company. NRC licensoes were notified by phone to look for defects in valves in these lots. On i July 29, 1987, after further investigation, 00E again notified and reported to NRC that Superior valves in lots 16 through 22. inclusive should be suspect for thread cracking. 00E is in the process of determining the reasons'for.the cracking and recommends that cylinders j;

fitted with 1-inch valves in lots 16 through 22 not be filled, emptied, j heated, or shipped until a determination of their safety is made. '

Effective August 19, 1987, the NRC Office of Nuclear Material Safety and Safeguards (NMSS) issued an Order to Combustion Engineering, Inc.,

Hematite facility which:

1 (1) Prohibits filling, heating, emptying, or delivering to a carrier for i transport 48-inch or 30-inch diameter uranium hexafluoride cylinders fitted with Superior Valve Company 1-inch alloy valves manufactured in Superior Valve Company lots numbered 16 through 22 inclusive.

(2) Requires that all 1-inch Superior valves for use in UFe cylinders in warehouse stock be carefully inspected. All valves are to be reinspected before fitting into cylinders All defective valves i found in stock regardless of lot number or manufacturer are to be I reported to the appropriate regional NRC office.

On September 25, 1987, the Order was modified to lift all mstrictions on i valves produced in lot 16. Valves produced in lots 17 through 22 remain l under the Order restrictions.

The inspector reviewed this matter onsite and determined that the licensee had identified and quarantined all valves manufactured in I lots 16 through 22. The only valves from these lots found onsite were produced in lot 16. The valves were inspected for defects; none were found. In addition, the inspector confirmed that.seven 30-inch diameter cylinders (one filled with UFe, the others empty or containing UFs heels) ,

were equipped with valves from lot 16. No defects were identified in i these valves either.

6. Radiation Protection l l

The inspector reviewed the licensee's internal and external exposure.

control programs including the required records, reports, and 1 e notifications.

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a. Internal Exposure control Bioassay records for the April through August 1987 operating period j disclosed that the 40 MPC-hour intake limit for uranium was not '

exceeded. Semiannual whole body counts were to be completed during September 1987. ,

i Selective review of licensee records of air sample analyses  !

disclosed two incidents with potential to health'and safety.

. significance as. discussed below. Both incidents were discussed with the licensee during the exit meeting:

(1) A staff engineer, assigned to' demonstrate .the operation of a I pellet press to a newly hired operator failed to activate the ventilation. system (downdraft exhaust) as required in the press start-up procedure (Procedure No. 702.4 Preparation for l Start-Up of Dorst Presses). The procedure states that the downdraft exhaust system is one of the main service functions that must be engaged prior to operating the ' press. As an engineering control for ALARA purposes, the ventilation system enables the operator to press UO2 pellets without respiratory protection.  !

The resultant exposure to the engineer and the operator (1.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> duration) was determined to be about 18 MPC-hours based on fixed air sampler results. This exposure is one to  ;

two orders of magnitude greater than expected with the exhaust l system functioning.)

As an additional precaution the licensee noted that urine voidings (samples) were obtained from the engineer and the operator; however, " refractory" uranium oxide is quite insoluble and therefore voided in very small quantities in urine. Whole body counts, scheduled for plant workers during the week of i September 27, 1987, will provide additional backup to the  !

calculated exposure. l Although the internal expost:re did not exceed regulatory requirements, the engineer apparently violated the requirement of Procedure No. 702.4 to activate the press exhaust' system as part of the press start-up service function. The licensee's Nuclear Safety Supervisor counseled the engineer concerning complying with operating procedures and utilizing engineering controls in order to maintain radiation exposure to workers ALARA. Additionally, the licensee stressed the need to use operating procedures when instructing personnel.

(2) A staff engineer assigned to coordinate the onsite activities of contractor welders required the welders to wear half-face ,

respirators as a precaution because the engineer anticipated )

that the welding and grinding operation.could cause airborne uranium oxide. However, the contractor workers we're not fit

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tested for the : protective ~ masks,: nor were.. licensee staff members' clear whether~or not.the: contractor personnel-had:

. received medical ~ clearance to' wear a respirator as required by' 10 CFR 20.103 and-Regulatory Guide 8.15. ~ Subsequent' evaluation of anLair sampler located in the vicinity would have been

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exposed to!about,6 MPC-hours without respiratory protection.

Inasmuch as the MPC-hr exposure did'not exceed 40 MPC-hrs.,.

respiratory protection equipment was1not required, except for..

ALARA purposes. No. regulatory violation-occurred; however, the- 3 matter.was discussed with licensee personnel at the exit 'j meeting'due.to its potentialisafety. significance.

a The inspector:noted that the licensee has.the responsibility'to

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'j ensure that persons. coming onsite to perform-work in locations with the potential for radioactive airborne ~ contamination

. possess documentation that a physician has cleared that person

.co. wear respiratory protection; the medical status of each respirator user'is to.be' reviewed at least annually; Licensee progress in this area will be monitored during a future inspection,

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.

Out of-67' employees there were.no exposures above.0.4. rem for the April through August'1987 operating period ~

c. Source Leak Tests The inspector examined licensee records for leak testing byproduct material sealed sources. Tests were performed on' September 4, 1987, in accordance with the provisions-'of Materials License SNM-33.

Licensee records disclosed that both cobalt-60 sources passed the leak test criteria.

One violt. tion was identified.

7. Criticality Safety l 1

The inspector reviewed criticality safety audits and documentation of I facility changes that required. nuclear criticality. safety analyses,

a. Special Nuclear Material-(SNM) Storage Arrays i

In reviewing the last inspection report (Inspection Report- 'l No. 70-36/87001(DRSS)), NMSS noted that SNM mass limits appearing in -l the table (demonstrating storage limits of SNM) did not correspond to the' enrichment' levels submitted in the-license-application. .That

. table was in error. The~ inspector determined that the licensee maintains storage arrays in accordance with the following corrected-L values:

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-Nominal Enrichment Maximum Net Weight

. Kg UO 2 Less.than or equal to: Powder Pellets 3.0% U-235 41 38 3.2% U-235 36 36 3.4% U-235 35 33.

According to the above table a container of 3.15% U-235 powder should be stored with a mass limit of 36 Kg which corresponds to a conservative value of 3.2% U-235. j

b. Nuclear Safety Analysis The following nuclear safety analyses have been completed since the previous inspection: (Inspection Report No. 70-36/87001(DRSS)) j i

(1) Relocation of the vacuum filter vessel. The vessel is l' designed to handle excess U02 powder from the pellet press feed operation. The purpose of moving the vessel is to improve accessibility of the vessel in order to make a j filter change. The analysis requires a 1-foot separation '

from other SNM material that may be present on the conveyor, and a 3.5-foot exclusion area to be marked on the floor. )1 (2) Install a vacuum cleaner as an integral part of the milling l hood. This will enable the operator to reduce the amount of l UO 2 residue that accumulates in the milling hood. .Apparently,  ;

a large build up of oxide residue obscures the operator's  !

vision and requires excessive clean up. The material i collection system (filter bag) is located outside of the hood,  !

while actual filter bag changes occur inside the hood. i Neither the NRC inspection findings nor corporate plant criticality I 1

safety audits disclosed any infractions that involved more than one l change in a process condition. The double contingency policy which {

requires at least two unlikely, independent, and concurrent changes in i process conditions that may lead to a criticality accident was not violated. The inspector confirmed that management of the licensee's nuclear criticality safety program is commensurate with the ,

administrative and technical requirements of the license. ]

j No violations or deviations were identified. ,

8. Transportation and Radioactive Waste Management i l

The inspector reviewed the licensee's program for receipt and/or shipment  !

of radioactive. materials. The inspector also toured the area where the i licensee is decommissioning two evaporation ponds.

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^ . j Since the previous ~ inspection (70-36/87001). only one shipment'was made to waste burial. . The. shipment'was accepted without incident.-

. Nearly 1440 l cubic' feet of contaminated' soil' was . removed from the two -

evaporation ponds' since the previous; inspections The contaminated soil l

'is packaged.in metal bins (about 96-cubic, feet capacity per bin).in ')

preparation for' shipment to off-site waste disposal. The inspector l concluded that the licensee. demonstrated a performance-level:.that assured radiological safety in the handling and transport of licens'ed radioactive.

material. .

No violations or deviations were identified.

9 .' Emergency Preparedness-A recent update of the Radiological Contingency Plan is under staff

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review prior to submittal to NRC. .During the' course of this inspection, i the inspector observed that the UFe cylinder station which can house up. I to two cylinders of UFe for processing UFe to U02 is now completely I enclosed.

Under present conditions (room enclosed) any radioactive material (UO2F2 and HF) escaping from a cylinder would be mostly confined to the enclosure. This arrangement should mitigate.significantly the amount of

. hazardous material that would escape' off-site as the result of a; cylinder -l failure.  !

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The licensee noted that the following activities were ongoing in the "

Emergency Preparedness Program:

• Emergency. evacuation alarms.are tested each Monday morning. .

• All fire extinguishers located in the production facility underwent- j hydrostatic testing by an otatside reviewer. Scott air pak limits '

were'also tested by the reviewer. .

• An emergency call list for ambulance,. physician, and hospital-services and firefighting assistance is posted outside the production foreman's office. During off-shift operations the shift ,

foreman is the emergency coordinator. Hence,: the emergency call list is visibly postri The inspector concluded that the licensee has made significant-improvement in emergency planning to mitigate off-site releases of j radioactive material.

No violation or deviations were identified.

10. Training The NRC inspector reviewed the health physics training provided to four employees. The new employees were instructed in basic health physics and general plant safety. For' plant indoctrination and-training operators are assigned work under the supervision of an. experienced operator and/or-

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L j' supervisor during the initial training period in order to become familiar with procedures and equipment. Training documentation indicated that information in Regulatory Guide 8.29, Instruction Concerning Risks From i L Occupational Radiation Exposure, and 8.15, Acceptable Programs for Respiratory Protection, was provided.

1 No violations or deviations were identified.

11. Operations Review The inspector observed'the licensee's performance of plant operations, including handling and storage of SNM material in accordance with Material License No. SNM-33. I

a. Observation of Operations The plant operating mode included around-the-clock (24-hour) 1 production of UO2 pellets from the ufo conversion process. Off-shift I production was monitored by the shift foreman. During an off-shift {

tour the inspector observed a Health Physics Technician performing safety routines. A follow-up of air sampling analyses indicated that contaminated airborne levels were less than plant allowable limits.

b. Housekeeping The inspector observed that material was stored in designated' storage areas, evacuation pathways were clear, and the potential for accumulating fissile materials in unauthorized locations was minimized. No problems were identified.

i The inspector concluded that plant operations were accomplished in accordance with the license application.

No violations or deviations were identified.

12. Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the onsite inspection on September 25, 1987. The inspector summarized the sc. ope and findings of the inspection.

The inspector discussed specific provisions of Regulatory Guide 8.15  ;

concerning physician determinations of persons who were wearing 1 respiratory protection devices. In addition, the inspector discussed the i importance of following procedures for equipment operation in order to j take advantage of engineering controls that assure minimum exposure.

During the course of the inspection and the exit meeting, the licensee- I did not identify any documents or inspector comments and references to specific processes as proprietary.

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