ML20236R284

Insp Rept 70-1257/98-03 on 980615-19.Violations Noted.Major Areas Inspected:Selected Aspects of Operational Safety, Radiation Protection,Radioactive Waste Handling & Storage

ML20236R284
Person / Time
Site:	Framatome ANP Richland
Issue date:	07/17/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20236R267	List: ML20236R266 ML20236R274 ML20236R284
References
70-1257-98-03, 70-1257-98-3, NUDOCS 9807210340
Download: ML20236R284 (17)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-1257 )

License No.: SNM-1227 Report No.: 70-1257/98-03 Licensee: Siemens Power Corporation Facility: Siemens Power Corporation Location: Richland, Washington Dates: June 15-19,1998 Inspectors: Robert G. Krsek, Fuel Facility inspector, Region lil Wayne L. Britz, Fuel Facility inspector Accompanied by: D. Blair Spitzberg, Chief, Nuclear Materials Safety Branch 2 Approved By: D. Blair Spitzberg, Chief, Nuclear Materials Safety Branch 2 Division of Nuclear Materials Safety

Attachment:

Supplemental inspection information 9907210340 990717 PDR ADOCK 07001257 C PDR

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2-EXECUTIVE

SUMMARY

Siemens Power Corporation NRC Inspection Report 70-1257/98-03 This routine, announced inspection included a review of selected aspects of operational safety, radiation protection, radioactive waste handling and storage, follow-up of open items from previous inspections, and follow-up of a recent event.

Ooerations

. The inspectors noted no concerns during the inspection and tours of the operating facilities, in general, plant operations, housekeeping and maintenance appeared adequate (Section 1.1).

. The inspectors reviewed the events surrounding the inadvertent shipment of empty fuel rod cladding to an offsite decontamination facility, with at least two fuel pellets intact in the cladding. The inspectors noted that fuel rod downloading operations prior to February 1998 were not cc, ducted in accordance with licensee procedures, and that

!~ g term corrective actions and recommendations were being reviewed by licensee management. Current downloading operations were conducted in accordance with procedures, and the initial corrective actions taken for the first occurrence appeared adequate. One example of a procedural violation was identified (Section 1.2).

. The inspectors reviewed the laboratory analysis conducted on samples taken from the waste basket involved in the April 15,1998, onsite fire. The analysis indicated the presence of nitric acid, a hazardous waste. The inspectors concluded that one example of a procedural violation occurred, for the failure to properly segregate hazardous waste onsite (Section 1.3).

Radiation Protection

. The licensee continued to effectively implement the occupational exposure program, and worker exposures remained below the limits of 10 CFR Part 20 (Section 2.1).

. The inspectors concluded through field observations of ongoing activities, and interviews with facility staff that the respiratory protection program was effectively implemented onsite consistent with 10 CFR Part 20.1703 requirements (Section 2.2).

. Management's commitment to the as low as reasonably achievable (ALARA) program was exemplified through the successful completion of several engineering projects, which subsequently decreased the average airbome concentrations of radioactive material in certain areas of the plant. In addition, the inspectors noted continued success in the implementation of maintaining lower limits for removable alpha contamination in the dry conversion facility (Section 2.3).

- Routine radiological contamination surveys were conducted at the required frequencies and in accordance with the licensee's health physics policies and procedures. The inspectors noted that survey instruments in use were operable and within the required calibration period, and instrument calibration sources were verified as traceable to the NationalInstitute of Standards and Technology (Section 2.4).

Radioactive Waste Manaaement and Storaae

. The licensee's waste processing and storage activities were consistent with the applicable regulatory requirements and licensee procedures (Section 3.1).

. The licensee had initiated a program to enhance the waste handling practices onsite, to further reduce the possibility of radiologically contaminated waste being sent from the site to the City of Richland landfill (Section 3.2).

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l Reoort Details l

l Summarv of Plant Status The plant was operating Lines 1 and 2 of the dry conversion facility. Scrap recovery was in operation. Fuel pellet production, fuel rod loading, and fuel bundle assembly operations were also in progress.

1.0 Operational Safety Review 1.1 Elant Ooerations

a. Insoection Scoce (Tl2600/003)

The inspectors toured the fuel fabrication plant areas with cognizant licensee personnel and observed the general status of equipment removal and installation, and facility operations.

b. Observations and Findings The inspectors toured and reviewed the operations of the dry conversion facility, and noted that Lines 1 and 2 were operating, and that Line 3 was under construction. The wet conversion facility was toured and reviewed. Line 1 of the facility was undergoing equipment removal , while Line 2 was operated for scrap recovery. The wet conversion facility was reviewed with licensee staff to determine which equipment was scheduled to be retained for scrap recovery and which equipment was scheduled for removal. The pellet production area was also toured and operations were reviewed. During facility inspections and tours the inspectors noted no concerns with the general conduct of operations, facility housekeeping, and ongoing maintenance activities.

c. Conclusion Plant operations, housekeeping and maintenance appeared adequate, except as noted 1 in Sections 1.2 and 1.3 below. I 1.2 Fuel Rod Downloading

a. Insoection Scoce (92701 and Tl2600/003)

The events surrounding NRC Preliminary Notification PNO-IV-98-022, issued on June 5,1998, were reviewed to determine the cause for the inadvertent shipment of empty fuel rod cladding with fuel pellets still intact. The inspectors reviewed the work process for fuel rod downloading and fuel rod rework with the supervisors and operators responsible for fuel rod download operations.

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b. QMcIyations and Findlags In August 1997, Siemens Power Corporation (SPC) shipped approximately 28,000 pounds of empty contaminated fuel rod cladding to Manufacturing Sciences Corporation (MSC) in Oak Ridge, Tennessee. In the process of decontaminating the cladding on January 28,1998, MSC staff discovered a fuel pellet in a section of fuel rod cladding and notified the licensee. A shift supervisor's Abnormal Event Log entry was made on February 10,1998. The log entry attributed the cause of the event to the use of bolt cutters to cut cladding into smaller sections, because the bolt cutters l crimped the end of the cladding making the venfication of empty fuel rod cladding very difficult. The corrective action was to discontinue the use of the bolt cutters which would make inspection easier in verifying that all the pellets had been removed from the fuel rod cladding. In addition, the licensee retrieved all fuel rod cladding onsite which had previously been downloaded, decrimped the ends of the rods, anc reinspected the rods to ensure no fuel pellets were present. No fuel pellets were discovered in any of the downloaded fuel rods which were reinspected.

After further processing of the SPC fuel cladding by MSC, another pellet was discovered on May 28,1998. After the second pellet was found, MSC decided to return the entire shipment of fuel rod cladding to the licensee. MSC was licensed for the possession of 350 grams of uranium 235 (U-235) by the State of Tennessee.

Although there was no violation of the MSC possession limits for U-235, MSC notified the State of Tennessee of the occurrence. The licensee notified the NRC RIV Office on June 5,1998, and a Preliminary Notification of Event (PNO-IV-98-022) was issued that day.

The inspectors observed the fuel rod downloading operations and interviewed the supervisor of Rod Fabrication Operations, the supervisors of fuel rod downloading operators, and the fuel rod downloading operators. The inspectors noted that all cutting of the fuel rod cladding was currently performed with a lathe, and that bolt cutters were no longer used. The inspectors also reviewed Procedures P66,427,

" Fuel Rod and Cladding Rework," and P66,421, " Fuel Rod Downloading," which were used to remove the fuel pellets from fuel cladding. During observations of current fuel rod downloading operations, the inspectors noted that operators performed the following actions: the ends of the rod were cut with a lathe; the pellets were then removed from the individual fuel rod segments by a shaking and pounding process; the fuel rods were then cut into shorter pieces with a lathe to fit in a barrel for shipment; and, a visual inspection through the rod cladding was made by looking in one end through the other end of the fuel rod, prior to placing the fuel rod into a 55-gallon barrel. As stated previously in the discussion regarding the Abnormal Event Log from February 1998, prior to February 1998, bolt cutters were used to cut the fuel rods into shorter pieces. The bolt cutters crimped the end of the fuel rods and made verification that the pellets had been removed difficult.

In discussions with the supervisor of Rod Fabrication Operations and operations staff, the inspectors noted that prior to February 1998, visual inspections were performed prior to the fuel rods being cut, not after, due to the fact that the ends of

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the rods were crimped. Although current fuel rod downloading activities were performed in accordance with procedures, the inspectors noted that failure to inspect fuel rods after being cut to verify they were empty was a violation of Procedure P66,427. Procedure P66,427, Section 5.6.1, required in part, that the cladding was first cut to fit into the 55-gallon barrel, then the fuel rod cladding was to be verified empty, and finally the empty fuel rod cladding was to be placed in the 55-gallon barrel. The supervisor of Rod Fabrication Operations also highlighted that the licensee's analyses of the fuel pellet discovered at MSC in January 1998 concluded that the fuel pellet was lodged in the fuel rod by the crimp at one end of the fuel rod.

In addition, the supervisor of Red Fabrication Operation also stated that the process of fuel rod downloading, and the procedures governing the process were still being reviewed for enhancement and changes, concurrent with the licensee's investigation into the May 1998 discovery of a second fuel pellet in empty fuel rods shipped to MSC.

At the time of the inspection, less than one-third of the shipment was believed to have been processed at MSC. The entire shipment of fuel cladding to MSC from August 1997 was being returned and was en route to the licensee's facility during the inspection. Once the shipment was received, the Fcensee planned to inspect the entire shipment to determine if other pellets remained in the fuel rod cladding. The shipments of fuel rod cladding to and from MSC were made as exclusive use, ,

radioactive material excepted packages for limited quantity per 49 CFR Part 173.421.

No transportation issues were identified.

Procedure P66,427 " Fuel Rod and Cladding Rework," Revision 13, Section 5.6.1 required, in part, that operators cut (fuel] cladding to fit into a 55-gallon barrel, verify (fuel) cladding is empty, and finally piace the [ fuel} cladding into the barrel. Prior to February 1998, the fuel cladding was not verified to be empty by operations staff prior I to L eing placed into a barrel, as evidenced by the shipment of empty fuel cladding to MSC for decontamination in August 1997, which contained at least two fuel pellets in j the cladding. The failure to verify the fuel rod cladding was empty to ensure the fuel j rod cladding was free of fuel pellets prior to shipment to MSC was identified as an example of a violation of the standard operating procedures (70-1257/9803-01). ] i 1

c. Conclusion

An example of a violation involving the failure to follow a standard operating procedure was identified for the failure to verify that fuel rod cladding was empty prior to shipment offsite for decontamination and recycling. Although current operations for fuel rod downloading were conducted in accordance with the procedures, fuel rod downloading operstions prior to February 1998 were not, resulting in the shipment of empty fuel rod cladc'ing with at least two fuel pellets present. Short term corrective actions for the violation addressed an immediate operational issue; however, a management review of operations for program enhancements and potential procedural changes was ongoing.

1.3 Follow-uo of Licensee Actions in Response to the Aoril 15.1998. Fire in the Uranium Oxide (UO2) Building

a. Insoection Scooe (92701 and Tl2600/003)

The management evaluation and laboratory analysis conducted as a result of the fire in the UO, building were reviewed to determine if a cause for the fire was known, previously identified as unresolved item (URI) 70-1257/9802-01. The inspectors reviewed the following documents:

. UO, Building Waste Handling Area Fire llB, May 1998

. UO, Building Waste Handling Area Fire llB Supplement, June 1998

- Memo dated June 11,1998, "Self-assessment on Waste Segregation"

. Memo dated June 12,199f, "After Action Meeting for UQ Waste Handling Area Fire"

b. Observations and Findings NRC Inspection Report 70-1257/98-02, Section 1, described the events surrounding the fire which occurred in the UQ Building Solid Radioactive Waste Processing Area on April 15,1998. URI 70-1257/9802-01 was opened pending the licensee's completion of the chemical analysis of the fire debris. Inspection follow-up item (IFI) 70-1257/9802-02, was opened since the licensee had not: 1) finalized the radiological consequences report; 2) received the fire inspector's report; 3) completed the laboratory analyses of the fire debris; and,4) completed the evaluations of the emergency response actions taken during the event. These items were reviewed during the inspection.

Two documents were reviewed during the inspection: 1) UQ Building Waste Handling Area Fire llB, May 1998; and,2) UQ Building Waste Handling Area Fire llB Supplement, June 1998. These two documents contained the following information: incident investigation reports; event logs and incident repotts; fire department reports, photos, and surveys; and, pertinent procedures to the event.

The radiological consequences were addressed in the June 15,1998, memo

" Radiological Aspects of April 15,1998, Waste Handling Fire." Estimates of radiological exposure to workers and a hypothetical person at the site boundary, as a result of the event, were documented as less than one millirem.

l The report from the Richland Fire and Emergency Services, City of Richland, dated May 12,1998, concluded that the fire was most probably due to one of two possible l causes. The report documented the first possible cause as a malfunction or overheat condition of a ballast in a fluorescent light fixture directly above the wire combustible waste storage basket. The second possible cause was the disposal of hazardous waste material from other areas of the facility that may have been incompatible with the trash in the waste basket, which could have resulted in the generation of significant heat to ignite the combustible trash in the waste basket.

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The memo,"After Action Meeting for UO2 Waste Handling Area Fire," June 12,1998, provided several recommendations and lessons leamed from the fire that would improve emergency preparedness response. The memo stated that any open items remaining from the critiques or after-action reports would be completed prior to or during a mandatory training session to be held the week of October 12,1998.

The licensee performed a self assessment which was documented in a memo dated June 11,1998, "Self-assessment on Waste Segregation." This memo updated the May 28,1998, memo of the same subject which tvas contained in the "UQ Building Waste Handling Area Fire llB Supplement," June 1998. The June 11,1998, memo discussed enhancements to make regardiag employee awareness, standard operating procedures, operator training, waste collection points, and provided a list of several recommendations and action items. The inspectors also discussed further procedural enhancements that were to be added to the list including Procedure P66,803, " Class A Waste Generator Requirements." The fire occurred during a plant inventory when facilities for the disposal of hazardous wastes were not available to plant staff, and provisions regarding this issue need to be addressed.

The action items developed by the licensee were scheduled to be completed in August 1998. 'lFI 70-1257/9802-02 will remain open until the inspectors review the completion of the licensee's recommendations and corrective actions contained in the self-assessments.

The test results provided in the memo, " Laboratory Sample Results," dated May 26, 1998, were reviewed. The laboratory tests indicated that the samples were acidic (pH of less than 1), and that nitrate ions (indicating the presence of nitric acid) were found in the waste collection basket. The waste collection basket was not designated for the disposal of items containing nitric acid, a hazardous waste. Only combustible and non-combustible wastes were designated for the waste collection basket involved in the fire. Section 6.1 of Procedure P66,803," Class A Waste Generator Requirements," of the Standard Operating Procedures states, that "Only the waste that is designated for each respective waste container shall be discardeo into that container." The disposal of hazardous wastes in a container approved only for combustible and non-combustible wastes was identified as a second example of a violation of the licensee's standard operating procedures (70-1257/9803-01). This finding closes URI 70-1257/9802-01.

c. Conclusions A second example of a violation involving the failure to follow a standard operating I procedure was identified for the failure to properly segregate hazardous waste. The licensee's laboratory analysis conducted on samples obtained from the waste basket fire on April 15,1998, indicated the presence of hazardous waste in a container designated only for the disposal of combustible and non-combustible wastes.

IFl 70-1257/9802-02 will remain open until the corrective actions are completed and reviewed by the inspectors.

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2 Conduct of Radiation Protection Activities 2.1 Occupational Radiation Exoosures for 1997

a. Insoection Scope (83822)

The inspectors reviewed select licensee radiation exposure records and health physics procedures, and interviewed licensee health physics staff. The inspectors reviewed the following licensee procedures:

. EMF-1508, 2.7, " Personnel External Dosimetry Program"

• EMF-1507, 5.2, " Personnel Dosimeter Control Program"

b. Observations and Findinas The inspectors noted that all staff likely to exceed 10 percent of the 10 CFR 20.1201 dose limits were monitored for exposure and no radiological workers were subject to the requirements of 10 CFR Part 20.1207, " Occupational Dose Limits for Minors."

Two members of the licensee's staff were declared pregnant workers subject to the requirements of 10 CFR Part 20.1208, " Dose to an Embryo / Fetus." A review of the exposure records indicated that the health physics organization closely monitored the workers' activities and the total effective dose equivalent (TEDE) for the workers were below the 10 CFR Part 20.1208 regulatory limit of 500 millirem. During building walk-downs and tours, the inspectors observed that licensee staff wore the appropriate dosimetry while conducting work-related activities.

Deep dose equivalent (DDE) exposures onsite were determined by the use of thermoluminescent dosimeters (TLD) processed by a vendor holding accreditation from the National Voluntary Laboratory Accreditation Program. In addition, the licensee utilized an extensive array of fixed, portable and lapel air sampler results, in combination with worker bioassays, stay times and respiratory protection factors, to determine a radiation worker's committed effective dose equivalent (CEDE). The licensee also utilized particle size distribution effects, as authorized in the license, for calculating internal doses for insoluble uranium compounds in certain areas of the plant.

The maximum CEDE and TEDE for 1997 was 1.769 rem and 1.849 rem, respective!y. for a worker assigned to the operations support area. The average of the five highest CEDES and TEDEs for 1997 was 1.256 rem and 1.459 rem, respectively, representing workers assigned to the chemical operations and operations support areas. The maximum extremity exposure for 1997 was 1.129 rem for a worker in the ceramics and fuel pellet production area. j The maximum TEDE for 1996 was 1.851 rem (0.941 rem CEDE and 0.910 rem DDE) in the chemical operations area with the average of the five highest TEDEs at 1.529 rem, indicating a slight decrease in the occupational exposure at Siemens from 1996 to 1997. The exposure data reviewed for 1997 documented that the L

occupational dose limits remained below the 10 CFR Par 120 requirements for occupational exposures.

c. Conclusions The licensee continued to effectively implernent the occupational exposure program.

Radiation exposures to workers were below the requirements specified in 10 CFR Part 20.

2.2 Resoiratorv Protection Program

a. Insoection Scooe (83822)

The inspectors reviewed licensee policies and procedures for the use of respiratory protection equipment. The inspectors also observed the issuance and use of respiratory protection by licensee staff and reviewed respiratory protection training and issuance records.

b. Observations and Findings The health and safety technicians (HST) were responsible for the issuance of respiratory protection equipment to staff onsite. The inspectors observed the issuance of respiratory protection equipment and noted that the HSTs utilized the respirator fit approval list, as required. The respirator fit approval list was an administrative aid utilized by the HSTs to ensure that respiratory protection equipment was not issued to staff who were not qualified. If an employee was not on the fit approvallist or if the list showed the employee as overdue for either testing or training, the HSTs verified the worker was properly trained and fit-tested for respirator use, via an approval card issued to the worker. The approval cards were issued to the workers upon successful completion of the annual physical, fit-test and training.

The inspectors noted during observations that equipment was not issued to staff who were not qualified to wear respiratory protection equipment.

The inspectors also observed licensee staff utilizing respiratory protection equipment i during the performance of normal work activities. Licensee staff tested respirators for operability prior to each use through the performance of both a positive and negative fit-check, in addition, the inspectors noted that staff also checked for physical damage to respiratory protection equipment prior to use.

A review of the respirator issuance logs for the dry conversion and uranium oxide facilities for the month of June 1998 revealed that only qualified staff were issued the I proper respiratory equipment for that time period. Licensee policies and procedures l adequately addressed the requirements of 10 CFR Part 20.1703 for the use of respiratory protection equipment.

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c. Conclusions The licensee continued to implement the respiratory protection program consistent with 10 CFR Part 20.1703 for the use of individual respiratory protection equipment.

In addition the inspectors concluded, through observation of ongoing activities, that the licensee's program for respiratory protection was effectively implemented by workers onsite.

2.3 ALARA Proaram

a. Insoection Scoce (83822)

The inspectors evaluated and discussed the licensee's ALARA program, as described and documented in the 1997 ALARA Report and licensee policies and procedures.

b. Observations and Findinas The inspectors reviewed and discussed the 1997 ALARA Report, EMF-98-22 (P),

which documented the licensee's ALARA efforts for calendar year 1997. Analyzed over a 2 year period, several positive improvements were noted in maintaining radiological exposures to plant personnel and members of the public ALARA.

Decreasing statistical trends were noted in the areas of: (1) average airborne concentrations in the waste recovery area, (2) average TEDEs of chemical operations staff, (3) gaseous effluents for fission and activation products, (4) average uranium concentrations in liquid effluents, and (5) solid waste inventories. However, the average in-vivo bioassay results for operations support staff and the dose from gaseous effluents were noted as having an increased statistical trend from previous years. Overall, the inspectors noted that the licensee's occupational and environmental results remained below regulatory limits.

The inspectors also evaluated and discussed with health physics staff 15 engineering projects completed in 1997 as a part of the ALARA program. The engineering projects were expected to decrease the airborne activity within specific areas of the plant. Six projects were expected to have a major impacts in decreasing airborne activity, and the remaining projects were expected to have minor impacts on airborne activity in certain areas of the plant. Data presented in the report documented airbome activity decreases of up to 67 percent in certain areas. The most significant decrease in airborne activity was noted in the area of uranium hexafluoride conversion, with the completion and start-up of the new dry conversion facility. Other engineering projects ranged from improving the overall design of various process lines in the plant to the establishment of laminar flow for certain grinding operations.

An increase in airborne activity was noted for the "Line 2 Press," following the completion of engineering projects; however, health physics staff pointed out that the time logged per day at the press after the project was completed was twice tSe amount of time logged prior to the project. Overall, the engineering projects had a noticeable impact in decreasing airborne concentrations for the 1997 calendar year.

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Finally, the inspectors noted that the license conditions allowed for contaminated radioactive material areas onsite to have up to 10,000 disintegrations per minute per 100 square centimeters (dpm/100cnf) of removable alpha contamination. However, the health physics organization initiated a more stringent contamination requirement, when operations began for the new dry conversion facility of 2,000 dpm/100cnf. A review of current contamination surveys documented that the licensee was successful in the implementation of this goal, and contamination levels in the dry conversion facility continued to remain below the 2,000 dpm/100erriadministrative limit. Health physics management stated that this goal will be reviewed for applicability for all new facilities and operations onsite in the future.

c. Conclusions The inspectors concluded the licensee was effectively implementing the ALARA program. Management's commitment to the ALARA program was noted through the successful completion of several engineering projects, which subsequently decreased the average airbome concentrations within specific areas of the plant.

The inspectors also noted the successful implementation of maintaining lower limits for removable alpha contamination in the new dry conversion facility.

2.4 Radiation Survevs and Survev Instrumentation

a. Insoection Scooe (83822)

The inspectors reviewed sele: t records and observed HST activities related to routine contamination surveys and airborne radioactivity measurements. In addition, the inspectors verified the operability of various radiologicalinstruments and traceability of radioactive sources used for instrument calibration. Licensee procedures and policies were also reviewed and compared to the observation of licensee activities.

b. Observations and Findings The inspectors observed routine facility contamination surveys in the dry conversion facility and uranium oxide building, and noted the surveys were conducted in accordance with the current health physics procedures. The HSTs highlighted to the inspectors that there had been a significant change recently in the documentation of contamination surveys in that most routine contamination surveys were now entered into a computer-based survey database. Previously, the licensee documented radiological surveys on contamination survey forms, and the forms were then kept as the permanent record. The inspectors noted that all the HSTs observed during the inspection were well trained, knowledgeable and comfortable with the use of the new computer-based system.

Health physics staff also highlighted several advantages to the new system including added assurances that calibrated instrumentation was used for the surveys, the ability to immediately determine if any routine contamination surveys onsite needed

to be performed, and added assurance that required follow-up contamination surveys would be completed within the required time limits. In addition, the computer-based system provided the HST manager the ability to closely monitor the status of routine contamination surveys onsite.

Section 1.6.2.2 of Part I of the license application allowed the licensee to possess waste contaminated with plutonium in the Specialty Fuels Building, provided the licensee implemented several controls. The inspectors reviewed the storage of the plutonium contaminated material and verified that all the applicable license requirements, including routine surveys and continuous air monitoring, were implemented.

The inspectors noted no changes in the licensee's survey instrument calibration and maintenance program. The frequencies of calibration and routine instrument maintenance activities continued to be incorporated in the licensee's computerized maintenance program. The inspectors observed during facility tours that survey instruments in use by the HSTs were operational and within the required calibration period. Portable alarming air monitoring instruments and air sample counters in HST offices were also noted as operational and within the required calibration period. The inspectors also randomly selected and verified that calibration sources used for onsite instrument calibration were traceable to the National Institute of Standards and Technology, as required by Section 3.2.4.1, Part I of the license conditions.

Inoperable instruments in storage and in the HST offices were appropriately tagged and physically separated from operable instrumentation. In addition, the inspectors noted that the new computerized survey program, in conjunction with the computerized instrument program, did not allow the entry of data into a survey form if the survey instrument was out of calibration. The inspectors noted this computerized feature as an extra administrative assurance that radiological surveys onsite were performed with operable instrumentation.

During facility tours, the inspectors also noted that radioactive material, radiation, and airborne radioactivity areas were posted in accordance with the requirements of 10 CFR Part 20, and the exemptions allowed by Section I, Part I of the license.

c. Conclusions Routine radiological contamination surveys were conducted at the required frequencies and in accordance with the licensee's health physics policies and procedures. The inspectors also concluded that the initial implementation of a new computer-based contamination survey program appeared successful. Survey instruments in use were noted to be operable and within the required calibration period, and a select number of instrument calibration sources were verified as traceable to the NationalInstitute of Standards and Technology.

3 Solid Radioactive Waste Management and Storage 3.1 Low _ Level waste Storace

a. Insoection Scoce (88850 and 34900)

The inspectors reviewed the areas of waste management and low level wasta storage with cognizant personnel and reviewed pertinent procedures in these areas.

The inspection included tours of the licensee's waste processing and storage facilities.

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b. Observations and Findiras ,

I Waste processing and collection areas were toured with plant personnel. Satellite waste collection areas, the assay counter, waste compactor, incinerator, waste storage pad, waste labeling for collection and storage areas, and waste storage areas were reviewed. Records of the weekly and annual audits of the waste storage area were also reviewed.

The Modular Extraction / Recovery Facility for processing low level radioactive and mixed waste, and for uranium recovery was toured. The facility was nearing completion and wcs scheduled to be operational in the near future.

The Lagoon Uranium Recovery (LUR) and Solids Processing Facility (SPF) for processing lagoon wastes and recovering uranium were reviewed and toured. The LUR facility was operational and the SPF was scheduled to be operational in the near future. The inspectors noted that project engineers had worked closely with health physics staff to ensure that any health physics issues resulting from new operations were adequately addressed prior to facility start-up.

Based on the review of the facilities and discussions with licensee personnel, no concerns were identified. The waste processing facilities presently in operation or near operation should result in a considerable reduction of the stored wastes onsite.

c. faDplusions The licensee's waste packaging and storage activities were consistent with the applicable regulatory raqu>ements and licensee procedures. The licensee was making good efforts in waste control and the elimination of stored waste onsite.

4 Followup 92701 4.1 (Closed) IFl 70-1257/9801-01: Contam!nated Shoe Covers from Landfill. NRC Inspection Report 70-1257/98-01, Section 4.0b, described the events surrounding contaminated shoe covers that were found in the Richland city landfill. An IFl was opened since the licensee was in the process of reviewing the facts associated with the incident to determine if the exact source of the shoe covers could be determined.

Correspondence from the licensee and the Department of Energy to the City of Pichland and the results of the licensee's laboratory analysis of the shoe covers were reviewed by the inspectors. The inspectors also discussed the incident with an official at the City of Richland and determined that the city had no outstanding issues with the licensee. Based on the results of the analysis and the correspondence reviewed, the inspectors concluded that the source of the shoe covers remains indeterminate. However, in response to the incident, the licensee initiated a self-assessment of the event and the current waste handling practices onsite. As a result of the self-assessment, several program enhancements were identified and implemented to further reduce the possibility of radiologically contaminated waste being sent from the site to the City of Richland landfill. The enhancements included additional training for all employees, increased oversight of waste generation areas by the HSTs, improved container identification, use of clear plastic bags for all bagged waste (prior bags were opaque), and HST written approval for the release of garbage dumpsters and construction waste leaving the plant site. The inspectors verified the implementation of the program enhancements taken as a result of the self-assessment and had no further questions related to this issue.

4.2 (Closed) URI 70-1257/9302-01: Completion of the chemical analysis of the debris from the April 15,1998, fire. This item was opened pending completion of the chemical analysis of the debris from the April 15 fire in the UQ Building Solid Radioactive Waste Processing Area. The chemical analysis was performed to evaluate potential chemical ignition sources. During the inspection, the inspectors reviewed the chemical analysis results and noted that nitrate ions were present, indicating the presence of nitric acid. Since nitric acid is a hazardous waste not authorized for disposal in the waste collection basket involved in the fire, a violation of licensee procedures was identified.

5 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusbn of the inspection on June 19,1998. The facility staff acknowledged the findings presented. The licensee did not identify any of the information discussed at the meeting as proprietary.

ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. W. Bell, Plant Support Operations B. F. Bentley, Manager, Plant Operations R. K. Burklin, Health Physicist M. A. Conway, Traffic and Warehousing Operations J. B. Edgar, Senior Engineer, Licensing B. N. Cemreite, Vice President, Manufacturing E. L. Foster, Supervisor, Radiological Safety M. A. Hendrickson, Supervisor, Rod Fabrication Operations R. T. Kimura, Waste Management Engineering l T. L. Knox, Plant Support Omrations I

L. J. Maas, Manager, Regulatory Compliance J. H. Phillips, General Supervisor, Chemical Operations J. B. Perryman, Environmental T. C. Probasce, Manager, Safety i

L. G. Stephens, Supervisor, Plant Support Operations l R. E. Vaughan, Maniger, Safety, Security and Licensing INSPECTION PROCEDURES USED

! IP 83822 Radiation Protection IP 84850 Waste Generator Requirements IP 84900 Low-Level Waste Storage Tl 2600/003 Operational Safety Review IP 92701 Follow-up ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 70-1257/9803-01 VIO Failure to follow procedures for segregation of hazardous waste and fuel rod downloading C1011d 70-1257/9801-01 IFl Contaminated shoe covers from landfill 70-1267/9802-01 URI Failure to foow procedures for segregating hazardous waste Discussed 70-1257/9802-02 IFl Review of licensee's final assessment, recommendations and corrective actions of the April 15,1998, fire event

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l l l LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable CEDE committed effective dose equivalent CFR Code of Federal Regulations DDE deep dose equivalent dpm/100cm2 disintegrations per minute per 100 square centimeters HST Health and Safety Technician IFl inspection Follow-up item LUR Lagoon Uranium Recovery MSC Manufacturing Sciences Corporation NRC Nuclear Regulatory Commission PDR Public Document Room SNM special nuclear material SPC Siemens Power Corporation SPF Solids Processing Facility TEDE total effective dose equivalent TLD Thermoluminescent Detector U-235 uranium-235 UO, uranium oxide URI Unresolved item VIO Violation I

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