ML20236H885
| ML20236H885 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 07/29/1987 |
| From: | Brock B, Thomas R, Zurakowski P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20236H796 | List: |
| References | |
| 70-0025-87-04, 70-25-87-4, NUDOCS 8708050377 | |
| Download: ML20236H885 (13) | |
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U. S. NUCLEAR REGl!!ATORY COMMISSION REGION V Report No. 70-25/87-04 Docket No. 70-25 License No. SNM-21 Safeguards Group: I Licensee: Rockwell International Corporation Rocketdyne Division Atomics International 6633 Canoga Park, California 91304 Facility Name: Headquarters Site and Santa Susana Field Laboratory Inspection at: Headquarters Site and Santa Susana Field Laboratory Inspection Conducted: July 6-10, 1987 Inspectors: / C 7/M /
B. L. Brock, Fuel facilities Inspector Date Signed b0 k kMbh $29l57 ff) P. R. Zurakowsgi, Radiation Specialist Date Signed Approved by 7?(7 hUf5;r,'rt 7/29/8 7 hR.D. Thomas,CtQff
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Ddte Signed
(/ Nuclear Materials Safety Section Summary:
Inspection on July 6-10, 1987 (Report No. 70-25/87-04)
Areas Inspected: A routine unannounced safety inspection was conducted of management organization; operator training and retraining; criticality safety; operations review; maintenance and surveillance; radiation protection; transportation / radioactive waste management /10 CFR Part 61; and emergency preparedness.
During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 88025, 83822, 86740/88035/84850, and 88050 were covered.
Results: No violations or deviations were identified in the areas inspected.
8708050377 870729 PDR ADOCK 07 l5 C
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DETAILS l
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- 1. Persons Contacted A. Licensee Employees:
- J. S. Mcdonald, Director, Atomics International
- M. E. Remley, Director, Nuclear Safety
- R. D. Barto, Director, Security
- C. J. Rozas, Director, Health, Safety and Environment R. P. Warren, Technical Skills and Development Human Resources and Communications
- R. J. Tuttle, Manager, Radiation and Nuclear Safety ,
W. R. McCurnin, Manager, Nuclear Operations l F. H. Badger, Health and Safety Engineer i J. W. Rowles, Health and Safety Specialist .
J. D. Moore, Health and Safety Engineer )
L. E. Rodman, Senior Fire Protection Engineer ;
(Emergency Coordinator)
J. A. Gump, Fire Protection Engineer S. Brown, Administrative Assistant B. Davis, Training Specialist D. Harrison, Staff Chemical Engineer !
E. L. Babcock, Assistant Manager, Rockwell International Hot Laboratory (RIHL)
F. C. Shrag, Member Technical Staff R. S. Frazer, Member Technical Staff D. R. Tatum, III, Lieutenant, Protective Services D. E Oliver, Lieutenant, Protective Services J. A. Curry, Physicians Assistant D. Parker, Shift Leader F. E. Bagley, Health and Safety Specialist Respiratory Protection J. A. Chapman, Health and Environmental Safety Specialist D. C. Campbell, Member, Technical Staff D. J. Elliott, Assistant Manager, Hot Cell Operations C. A. Giesler, AWC Contract Monitor
- Denotes those attending the exit meeting B. Off Site Contacts:
Humana Hospital West Hills C. Hague, Director. Department of Radiology C. Bowers, Chief Nurse, Emergency Room Ventura County Sheriffs Department H. Carrillo, Lieutenant
2 Ventura County Fire Protection District F. W. Baugher, Captain City Of Simi Valley Police Department R. Thomas, Lieutenant M. R. Adams, Emergency Services Coordinator
- 2. Management Organization and Controls Section 9 of NRC License SNM-21 incorporates Part 1 of the licensee's application and supplements dated October 29, and December 17, 1982, March 2, 7, May 29 and June 12, 1984 as license conditions.
A. Organizational Structure Section 11.3 of the licer.se application requires certain organizational divisions of responsibility to provide a check and balance system in the important areas of plant safety.
The licensee's organizational structure for licensed activities remains unchanged. An updated organization chart reflecting personnel changes in management positions was acquired. It is evident that the checks and balances of the organizational structure have been maintained.
B. Procedure Controls Section 11.3.4 of the license application requires that changes in established procedures must be authorized in advance by appropriate management.
The Fermi decladding procedure that had been partially revised was reviewed again by the NRC inspector. The inspector found that one of the previously recommended modifications had been added. The modification was recommended by a team assembled to investigate a small fire extinguished by inerting the hot cell. Incorporation of the recommendation into the procedure closes item (86-01-01).
The licensee is currently preparing procedures that will be needed whenever the decontamination and decommisr.ioning of the hot cells is scheduled.
No violations were identified.
- 3. Operator Training and Retraining Condition 14 of the current license requires that prior to unsupervised work with special nuclear material appropriate formal training shall be given in criticality and/or radiation safety.
A. f review of the licensee's master training records and discussions with Training, Radiation and Nuclear Safety, and Building 020
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Operations personnel disclosed that all persons had received the required training prior to working with licensed material.
A careful check by the inspector of secondary records maintained in Building 20 and Building 100 disclosed no discrepancies between these records and the master training record. It appears that the master training record has become an accurate and viable document that can be used productively by all persons needing this information. Item (85-01-02) is therefore closed.
B. A training document entitled " Respirator Training Manual for D/635 Personnel" was reviewed by the inspector and discussions were held with the Senior Health and Safety Specialist in charge of the program. The manual was found to be clearly written and well suited for the required training function for which it was designed. The inspector was informed that each person given this required training receives a copy of the manual.
C. Training of Ancillary Workers Training of anc.illary workers has begun. A master training plan which includes training of ancillary workers is being developed by the Health and Safety Specialist in charge of the program. The anticipated completion of the master training plan is October 1987.
Item (86-03-06) will remain open for further review.
No violations were identified.
- 4. Criticality Safety Section 2.7 of the license application requires that prior to initiating a project involving potential hazards, authorization must be obtained from the appropriate Department Director and from designated Safety and/or Criticality Safeguards personnel in the Health. Safety and Radiation Services Department.
A. Nuclear Criticality Safety Analysis Section 4.1.3 of the license application requires the completion of a Nuclear Safety Analysis for the Fast Flux Test Facility (FFTF) fuel if it is scheduled to be declad at the RIHL.
The licensee maintains on the staff persons qualified to do the required analysis as well as provide the required independent review. The new Chairman of the Fuels Committee, formally trained as a mechanical engineer, has criticality safety, SNM accountability, and statistics experience in addition to being a licensed attorney. The new Chairman understood fully his role and clarified that the second party independent reviews would continue to be performed by the Fuels Committee's physicist. This closes
- tem (87-01-01).
4 B. Fermi Fuel Declad Project l The Nuclear Safety Analysis for the Fermi decladding project includes in Section 9.f, under General Safety Considerations, the requirement that, "If any condition develops which requires the use of procedures not previously approved, operations will be halted, '
and radiation and nuclear safety will be informed. A safe procedure will be devised to overcome the nonstandard condition. Approval of the interim procedure by Radiation and Nuclear Safety will be accomplished as expeditiously as is possible."
The licensee's performance in this area was reviewed during the previous inspection (70-25/87-01). The review raised a question about the licensee's practices versus the procedures and was identified as open item (87-01-02). The inspector's review of this item curing the current inspection indicated that the license.had provided additional training with emphasis on the necessity to stop operations, to have the conditions appropriately evaluated, to have a recovery procedyre reviewed and approved, and to adhere to the procedure during recovery. Further, since the previous inspection, the licensee had occacion to put the recent training into effect.
The occasion involved a small unmeasured quantity of grinding fines of uraniun-molybdenum alloy (10 percent molybdenum) contained in a slurry of zirconium grinding fines. The slurry was generated during cleanup of the grinder used in both the early development of the grinding process for the Fermi decladding work as well as during the decladding of the irradiated Fermi fuel elenents. The procedure involved grinding off the zirconium cladding and only a small amount of the U-Mo alloy fuel rod. The effort was to eliminate zirconium from the separated declad U-Mo alloy rods sent for chemical recovery of the nominally 0.2 percent contained plutonium. The uranium in the alloy being declad was about 26 percent enriched. The licensee used several methods to measure the uranium content of the sludge which was in four containers. The total quantity of uranium was.
determined to be about 57 grams of U-235, and the largest quantity in a single container was 28 grams. This appeared consistent with the operations upper limit estimate of 80 grams U-235. The I measurements obtained during the licensee's investigation demonstrated that the criticality safety limit was not exceeded.
The licensee's performance was significantly improved. The operations personnel stopped operations, operations management notified nuclear safety, an evaluation was made, a procedure was developed, reviewed, and approved before it was carefully followed in affecting a recovery. The licensee adhered to the General Safety Considerations of Section 9.f of the applicable Nuclear Safety Analysis. This closes item (87-01-02).
No violations were identified.
- 5. Operations Review Section 2.1 of the license application requires the licensee to comply with all the requirements of the regulations, to operate the facilities
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I in a safe and efficient manner and within the requirements of all license conditions under which the activities are authorized.
A. Decontamination / Decommissioning (D/D) I License Condition 25 requires that the licensee follow the general decommissioning plan submitted in the enclosures to the letter dated March 15, 1987. 3
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(1) Building 055 Nuclear Materials Development Facility (NMDF)
(a) The final report of the Oak Ridge Associated University's independent overcheck for the NRC has not been issued.
The draft report did not indicate anything that would
, preclude release of the building to unrestricted use.
B. Operations (1) Building 020 Rockwell International Hot Laboratory (RIHL)
(a) The disassembly of the Fermi fuel has been completed; however, there are two damaged fuel assemblies which cannot be declad for recovery with the current procedures.
The licensee is seeking Department of Energy (DOE) guidance on disposition of these fuel elements. Repacking appears necessary to reduce surface dose rates (see Section 8 for details).
(b) The licensee responded to the need for additional operator training in the wet vacuuming of zirconium fines by discussing the safety significance of this operation in a recent safety meeting. Additionally, the operators again reviewed the revised procedure and by signature attested to their understanding. This closes item (87-01-03).
(c) The cleanup of the alpha glove box used in the Southwest l Experimental Fast 0xide Reactor (SEFOR) decladding project I
has not been completed but no glove box re-entry is planned. (see Section 7 for details).
l No violations were identified.
I 5. Maintenance and Surveillance Testing l
Section 9 of NRC License SNM-21 incorporates Part 1 of the licensee's I
application and supplements dated October 29, and December 17, 1982, and March 2, 7, May 29 and June 12, 1984 as license conditions, i
Ventilation System The ventilation system has been operating normally since the malfunctioning fan was replaced. The licensee had previously considered replacing the other fans put into service about the same time as the l problem fan. However, now that D/D of the RIHL is under consideration, j the licensee is delaying the decision on installation of the new fans and l
. 6 l related equipment until the decision is made on the next RIHL project.
l The current normal performance of the system warrents closing item (86-03-02).
- 7. Radiation Protection l Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20. .
1 A. Tour of Facilities The RIHL (Building 020) and the Respiratory Protection Maintenance l and Training Laboratory were visited by the inspector. No violation of good health physics practices or NRC requirements was noted during the tour.
B. External Exposure The review of 1st and 2nd quarter 1987 radiation exposure records disclosed no exposures in excess of regulatory limits. The nighest quarterly whole body exposure noted was 420 mrem. The highest ring I badge reading noted was 570 mrem. No significant readings were found in the visitor film badge records.
C. Internal Exposures The licensee continues to utilize a bioassay program from U. S.
Testing Company of Richland, Washington. A review cf the available records for the 1st and 2nd quarters of 1987 disclosed no internal exposures exceeding licensee administrative limits or regulatory limits. Results for six persons submitting samples for plutonium analysis during the 2nd quarter of 1987 had not been received prior
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to this inspection. This will be carried forward as an open item to be reviewed during the next inspection (87-04-01).
D. Non-Reportable Incident Review One non-reportable incident which. occurred during the 1st quarter 1987 was reviewed. This involved a radiation worker who, while wearing a full suit-up of protective clothing in cell #4 on a hot.
day, collapsed from heat exhaustion while attempting to exit the cell. First aid was given by Protective Services,;and the worker was transported by ambulance to the Medical Department Office for.
observation. No internal or external contamination was detected on any of the persons involved. However, because heat stress has been a potential problem for many years, particularly. during the hot summer months, the licensee is taking several actions to alleviate the problem. These actions are discussed in Section 7.F.
The nonreportable item reviewed during the last inspection which involved an entry into the large SEFOR glove box in an attempt to decontaminate it more thoroughly was-left as an open item in report ~
70-25/87-01 in the event that another entry was attempted. However,
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7 the licensee has decided not to re-enter the glove box in the foreseeable future. This closes item (86-03-01).
No violations were identified.
E. Facility Exhaust Stack Releases Radioactive effluents released to the atmosphere.from the RIHL (Building 020) exhaust system for the 1st quarter of 1987 were reviewed by the inspector. 1 l
TheMaximumPermissibleConcentration(MPC),,grreleaseofairgrne j radioactivity to unrestricted areas is 6X10 alpha and 3X10 uCi/ml beta. The release values for the quarter were less than 0.5%
of the appropriate MPC for the most restrictive radionuclides ,
expected in the discharged effluent. A gamma spectrometric analysis !
made by the licensee of a composite of all main stack exhaust air sampling filters for the first quarter detected only cesium-137 plus -4 naturally occurring radionuclides which probably entered the system j through the by pass air intake. '
These results indicate that no re' leases in excess of licensee action l levels or regulatory limits are occurring from the stacks.
F. Upgrading of the Breathing Air Supply System !
l The higher-than-ambient temperature breathing air supplied to the ;
airline respirators used for in-cell work is suspected of I contributing to the non-reportable incident discussed in Section i 7.D. The air (atmosphere supplied) was warmed by solar and j compressional heating. The licensee has proposed several actions to j reduce this problem. Briefly summarized they are:
- 1. Shield air lines, tanks, and other associated apparatus from the direct rays of the sun.
- 2. Insulate and cool air lines that pass through the building attic prior to descending into the cell area. !
- 3. Have Radiation Workers wear NASA type cooling jackets under their protective clothing on particularly hot days.
Because of the great potential hazard associated with a Radiation Worker collapsing in a highly contaminated hot cell, the licensee's corrective actions will be followed closely for the next several inspections as open item (87-04-02).
G. Color Coding of Dosimeters The licensee's plans to color code dosimeters in order to more easily identify out of date dosimeters, visitors, type of badge etc.
were reviewed by the inspector. It was found that the color coding system is fully operational. This closes item (86-03-04).
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H. Shortening Exchange Period for Film Badges .
Prior to the last inspection, the licensee agreed to study the possibility of exchanging their film badges on a monthly schedule rather than a quarterly one in order to reduce reading errors due to l
" aging effects". In response to this request, the licensee i contacted their film badge supplier, made a literature search, and compared past readings with backup pocket dosimeters and TLDs that f 4 they have used concurrently. The licensee has concluded that,- ;
considering their backup systems, changing the film badges to a .
monthly system would have little or no effect on the accuracy of the readings. They.therefore have elected to remain with their quarterly exchange frequency. -This closes item (86-03-05).
No violations were identified.
- 8. Transportation / Radioactive Waste Management /10 CFR Part 61 Annex "B" of the current license incorporates guidelines for release of equipment and facilities for unrestricted use. 10 CFR Part 20.301 to Part 20.401 regulates the disposal of waste. 10 CFR Part 61 requires that all radioactive waste prepared for disposal is classified in accordance with Section 61.55 and meets the waste characteristics requirements in Section 61.56. I 10 CFR 20.311(d)(3) requires that licensees who transfer radioactive waste to a land disposal facility or licensed waste collector shall conduct a quality control program to assure compliance with 10 CFR 61.55 ;
and 61.56, 1 10 CFR Part 71 regulates the packaging and transportation of radioactive material.
A. Waste Management j
- 1. Some of the problems associated with the packaging of Fermi Wrapper Tube and End Hardware were discussed in Report 70-25/87-01. Since that inspection, a detailed written procedure has been completed to cover this operation. This procedure (1530P000010) was used to successfully package fourteen 55 gallon drums with Fermi wrapper tubes and end hardware. Briefly, this procedure involved placing the stainless steel wrapper tubes with grid support structure into 12 gallon drums. These drums were then lowered into 55-gallon 00T 17H or 17C drums which were shielded with 1" thick carbon steel cylinders and concrete. The 12 gallon drum packaging and 55 gallon drum loading operations were performed using remote techniques (master-slave manipulators, remote in-cell crane, etc.) inside Cell 4 end Decon Room 4. The drums were packaged without incident or excessive exposure and transported to the Radioactive Material Disposal Facility (RMDF). NRC, DOT and EPA packaging, labeling and " content" requirements were observed in the final package prior to shipment. The well written detailed procedure which adequately addressed both fire
9 and radiation safety issues contributed significantly to the smooth and safely conducted operation. This. closed item l (87-01-05).
- 2. Disposal of Fermi Damaged Elements Two damaged Fermi fuel elements containing approximately 9 kg.
U-235 and 2 grams of plutonium are being securely stored at the RMDF'. The licensee has concluded that it is not possible to salvage any material from the damaged elements and is waiting instructions from DOE on a disposal site. Should.it be necessary to repackage this material in the hot cell area of the RIHL, this aspect of the operation would be under NRC ;
jurisdiction. NRC will therefore follow. developments in this l area closely as open item (87-04-03). 1
- 8. Transportation and Part 61 Because the Manager, Nuclear Safety and Licensing who maintains complete records on the subject items was on travel during this inspection, it was not possible to complete this section. The !
Director, Nuclear Safety and' Licensing stated that, in his opinion, 1 no shipment of radioactive material under NRC jurisdiction had l occurred since the last inspection as is usually the case. However, l since he did not have access to all of the records these subjects will be reviewed during the next inspection. Therefore, item (87-01-06) remains open.
No violations were identified. .;
- 9. Emergency Preparedness License Condition 24 requires the licensee to maintain and execute the response measures in accordance with the Radiological Contingency Plan submitted to the Commission on August 28, 1981, as revised on l March 3, 1982. Additionally, Appendix A to the Radiological Contingency u Plan states that the Master Emergency Plan has been approved as part of {
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A. The fire extinguishers inspected during the tour had all received l their monthly inspections. The housekeeping in all areas visited 3 was good. l B. The licensee had prepared a scenario for a drill scheduled for late i July. An invitation has been extended to Humana Hospital West Hills to send observers or participants (the. hospital did not participate ,
in or observe the last such drill). During the inspector's visit to l the hospital he learned the hospital intended to provide two i observers. The hospital staff acknowledged that their previous i observations had given them additional insight into the kinds of ]
problems a patient originating from the licensee's site may present. ;
C. The Ideensee has instituted a trial use of independent auditors for l emergency drills. The auditors will be used again on the imminent l l
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- s drill. The licensee provided additional guidance to the in-house f auditors.
4 D. .The inspector visited the West; Valley Sheriff Station and confirmed j that the. station had the latest issue of the. licensee!s Contingency q Plan dated' July 24, 1984._ The watch commander: indicated that the-station would be moving to another location before the end of the
_ year. The_new location is only about'a half mile.. west of..their ,
present location. The~ telephone number'will_ remain the:same.-
E. 'The inspector visited the City Of Simi Valley Police Department and f met briefly with the officers responsible.for. emergency service I coordination. The officers. indicated that they would likely be the first offsite agency to establish a road block of Black Canyon road if the need arose. They agreed that_a special badge for the licensee's emergency cadre would facilitate their passing a road a block in responding to'an onsite emergency. ,When apprised of this, the licensee pointed out that his. security force _would.also be an early participant at the road block and would provide immediate i verification of the. identity of' the~ authorized emergency cadre and j other persons who need to be present to control or mitigate the consequences of an emergency.
J F The inspector also visited the Ventura County. Fire Department's-Station 43 which is the first support.to the onsite. Security Department's fire fighters. The previous Captain had recently; retired. The new Captain indicated that he anticipated no' changes in the relationship between the fire department and the licensee. )
The Captain asked about possibly obtaining copies of the licensee's f Fire Pre-Plans. The inspector indicated that the licensee's operations were principally outside of the jurisdiction of the NRC and therefore a significant number.of Fire Pre-Plans existed beyond the few of specific interest to the NRC. The inspector agreed to i raise the question with the licensee but suggested that the nature 'l of some of.the licensee's work'may preclude providing the fire department with copies of all of the F. ire Pre-Plans. The inspector-subsequently discussed the subject with the licensee.and learned I that it would be impractical ~ to provide the -fire department with the large number of Fire Pre-Plans _._ The inspector suggested'that the !
licensee contact the Captain ind explain the impracticality,of the Captain's suggestion. The licensee indicated,the s'ubject would be discussed directly with the Captain'and the call'would facilitate = ~
raising other issues.of mutual interest.
G. The onsite fire. station was' visited by the inspectors to review._the-status of the system set up to assure that required inspection of components.of~the fire supression system would be'made at the, required frequencies. ..The system also identified the training status of the security staff. The 500 gallon per. minute'(gpm) pumpers had been completely overhauled. Additionally,.the new-1600-gpm fire engine was observed. This latter unit is also equipped with a resuscitator and is the unit sent to backup the City of:
Simi's fire statio'n (No. 43) when it is responding to a local fire.
- 11 H. The licensee has a computer generated hazardous material inventory listing in alphabetical order. The listing facilitates the rapid location of the Material Safety Data Sheets-(MSDS) by the material users. The licensee indicated that the Fire Pre-Plans include type-and quantity information on the hazardous materials in the various buildings.
No violations were identified.
- 10. Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1. !
The topics discussed included: l The status of the previous open items: l Closed I (85-01-02) Training records accuracy.
(86-01-01) Review approval of Fermi procedures.
(86-03-01) Review airborne concentration levels during alpha glove box entries.
(86-03-02) Review program of replacement of RIHL ventilation system fans.
(86-03-04) Review the status of plans to color code dosimeters.
(86-03-05) Review licensee's plans regarding use of TLDs or shortening the use period of film badges. 1 (87-01-01) Review background of new Fuels Committee I Chairman when appointed.
(87-01-02) Review the retraining relative to actions to be taken when nonstandard operation conditions are encountered.
(87-01-03) Review the retraining provided relative to the safety significance of vacuuming the zirconium chips'while wet.
I (87-01-05) Review the licensee's new packaging for the l coarse zirconium sawing chips.
1 Open (86-03-06) Review licensee's plans for training ancillary workers.
(87-01-04) Review the status of the upgrading of the Breathing Air Supply System.
(87-01-06) Review records of shipments made under NRC jurisdiction.
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1 (87-04-01) Review the plutonium analytical results for the six persons for which the results had not been reported.
(87-04-02) Review the licensee's actions on upgrading the Breathing Air Supply System.
(87-04-03) Review the developments in the licensee's efforts to prepare and package the damaged Fermi fuel elements for shipment.
Other Topics Discussed The licensee's initial use of independent auditors for observation of the emergency drills.
The uncertainty of the next project for the RIHL.
The licensee's improved performance with regard to taking appropriate action when the loss of a criticality contingency is suspected.
The need to include the upper limit of the uncertainty when evaluating a potential criticality safety problem.
The need to followup on the invitation to the hospital :
to observe the next drill.
The surface material (steel) lining the walls in the RIHL hot cells.
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