ML20245J921
| ML20245J921 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/20/1989 |
| From: | Joseph Furia, Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245J911 | List: |
| References | |
| 70-1100-89-02, 70-1100-89-2, NUDOCS 8905040283 | |
| Download: ML20245J921 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
70-1100/89-02 Docket No.
70-1100 1
License No.
SNM-1067 Priority 1 Category ULFF Licensee: Combustion Engineering, Incorporated 1000 Prospect Hill Road Windsor, Connecticut 06095 Facility Name: Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor,-Connecticut Inspection Conducted: March 13-17, 1989 Inspectors:
J. Roth(JProfec~t Engineer, ERPS, FRS&SB, DRSS
' ' d a te' 0V Y
J.Furia(, Ra'diftfon Sp4pfa' list, ERPS, FRS&SB,
'/ date/
DRSS v
Approved by:
/M Y
Ch9 sw e-W.' J.
ciak, Chief, ERPS, FRS&SB, DRSS
/ datJ/
Inspection Summary:
Inspection on March 13-17, 1989 (Report No. 70-1100/89-02)
Areas Inspected:
Routine, unannounced inspection by two region-based inspectors of the licensed program including reviews of the licensee's operations, effluent I
monitoring program, environmental monitoring prcgram, preventive maintenance
' system, procedures, and shipping container storage.
Results: Two violations and two unresolved items were identified.
Violations:
failure to assign measured uranium-235 content and enrichment values to packages of sludges and solid wastes within five days of sealing (Paragraph 2b); and, failure to follow all of the requirerrents of a Radiation Work Permit (Paragraph 2.c) and failure to have a written procedure to cover the dilution of liquid wastes of all applicable concentrations prior to release to the en-vironment (Paragraph 3a).
Unresolved items:
failure to establish Quality Control procedures for instrumentation or determine voltage plateaus for alpha / beta counters (Paragraph 3c); and, failure to determine if the compressive Icad on three stacked loaded Model 927 shipping containers meets the structural integrity safety factor of 3.0 specified in Section 4.2.7 of the license application
'(Paragraph 7.).
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8905040283 890420 PDR ADOCK 07001100 C
9 r DETAILS 1.
Persons Contacted
- S. T. Brewer, President, Nuclear Power Business Division
- P.-L. McGill, Vice President, Nuclear Fuel
- P. R. Rosenthal, Program Manager, Radiological and Industrial Safety C. Molnar, Licensing Engineer.
- C R. Waterman, Vice President and General Manager, Nuclear Fuel Manufacturing
- P. W. Hubert, Manager, Manufacturing Engineering
- D. G. Stump, Manager, Radiological and Industrial Safety J. Vollaro, Health Physics and Safety Supervisor
- R. E. Vaughan, Manager, Operations
- A. E. Scherer, Director, Nuclear Licensing J. Helems, Radiochemist J. F. Conant, Manager, Nuclear Material Licensing
- denotes those present at the exit interview.
The inspector also interviewed other licensee employees during the inspection.
2.
Review of Operations-The inspector examined selected areas of the plant and the nuclear laboratories to observe operations and activities in progress, to inspect the nuclear safety aspects of the facilities and to examine the general state of cleanliness, housekeeping, and adherence to fire protection rules.
a.
Postings During examination of the Building 17 fuel manufacturing facilities, the-inspector noted that the posting inadequacies identified during Inspection No. 70-1100/89-01 had been corrected.
b.
Labeling During examination of the Building 6 liquid waste handling and storage facilities and the Waste Storage Pad located along the south wall of Building 21, the inspector observed several containers which were not properly labeled with the uranium content or enrichment.
i-Two five gallon containers dated October 28, 1988 were stored in the basement of Building 6.
Those containers held sludge removed from strainers located in liquid waste pipes leading to the liquid waste storage tanks. As of the date of this inspection, the licensee had not initiated actions to determine the uranium-235 content or enrichment of this material. A total of three Model B-25 containers (Numbers 1176, 1182 and 1185) were stored, on the Waste Storage Pad located lL________-______._______.__________
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3 along the south wall of Building 21, between June 23, 1988 and August 18, 1988, and were not properly labelled with the uranium-235 content or enrichment.
Each of the containers were labeled with a "less than" value for enrichment and a less than 350 grams U-235 value for uranium.
Contrary to Operation Sheet No. 1764, the licensee failed to assign measured uranium-235 and enrichment content to each container within five days of sealing. This was identified as an apparent violation 3
(70-1100/89-02-01).
Prior to the end of this inspection the licensee i
properly labeled each of the Model B-25 waste boxes and had initiated I
actions to analyze the sludge in the five gallon containers. Adequate l
corrective actions had been initiated or completed prior to the end of this inspection.
In accordance with the criteria of 10 CFR 2, Appendix C.V.A, no Notice of Violation will be issued for this problem.
c.
Radiation Work Permit While examining Pellet Shop activities, the inspector determined that the licensee had initiated a complete cleanout of the pellet manu-facturing equipment. This type of cleanout is conducted each time a change in uranium isotopic enrichment is required. As the inspector approached the east end (dry powder end) of the blended powder belt drier, an operator was observed striking the outside surface of the belt drier enclosure with a mallet in an attempt to dislodge powder i
adhered to the inside surface.
Following each series of strikes with
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the mallet, the operator used a vacuum cleaner to remove any dislodged powder.
During this entire operation a plastic window on the east end of the drier was open and the operators head was within six to twelve inches of the opening as the mallet was being used. The inspector questioned available management about the adequacy of this operation since there was no apparent method in use to minimize the operators exposure (respirator or use of the window).
The operator was wearing a breathing zone sampler so that an after-the-fact evaluation of exposure could be conducted.
The available manager stopped the operation immediately and the operator's exposure was evaluated.
Results of the evaluation indicated that the operator received an insignificant exposure (0.5 MPC-hr) as a result of the operation.
The inspector subsequently reviewed the applicable Radiation Work Permit (RWP 23-89-3 dated March 8, 1989) to determine what instruc-tions were provided to the operators to cover the observed operation.
This RWP required the operators to "use Plexiglas doors to minimize i
airborne." Section 2.7.2 of the NRC-approved license application states that "it is the responsibility of the Plant Manager to assure that all operations involving radioactive materials have written procedures which include the appropriate safety requirements and are followed". The Radiation Work Permit written pursuant to the above requirement must include all safety requirements, protective clothing and equipment, and health physics monitoring requirements necessary to assure that the proposed operation is conducted in a safe manner as specified in Section 3.3.1.
Failure to follow all of the requirements of the RWP, i.e., use of Plexiglas doors to minimize 1
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airborne activity in.the work area, was identified as an apparent violatiot.(70-1100/89-02-02). During the exit meeting the inspector i
was informed that the licensee did.not feel that this was a violation since the operator did not get.any significant exposure and because the airflow at.the opening to the enclosure was 125 linear feet per minute which was in excess of the airflow required for hoods being used.
Further, during the exit interview the licensee stated.that it was acceptable practice not to follow RWP instructions in a situation like this.
d.
Housekeeping The inspector noted that there was a significant improvement in the
' housekeeping activities in the Pellet Shop Annex and in the Building 21 warehouse.
However,'it was observed that the west aisle of the warehouse was still blocked with boxes of equipment.
Licensee representatives stated that actions to cleanup all of the warehouse aisles will be completed.
3.
Effluent Monitoring The licensee monitors the release of liquid and gaseous effluents which contain uranium. As part of this inspection, the licensee's program and procedures utilized to monitor effluents were examined.
a.
Liquid Effluents During the inspection, the inspector examined the following procedures associated with liquid effluents.
Radiation Protection Instruction (RPI) 218, Rev. O, " Processing Liquid Radioactive Wastes."
Analytical and Radiochemistry (A&R) Procedure 15, Rev. O, "The Determination of Alpha and Beta Radioactivity'in Waste Waters."
A&R Procedure 14, Rev. O, "The Determination of Uranium Losses Which Result From Liquid Waste Releases."
RPI 218 is the licensee's procedure used for controlling the release of liquid ef fluents containing uranium from the licensee's site.
Although this procedure is specific in its instructions and calcula-tional methods, it fails to take into account relatively high activity liquid wastes.
The procedure is designed to accommodate the dilution of waste concentrations up to a 7:1 ratio of alpha emitting nuclides, and the release of those diluted wastes.
Further, this sampling procedure involves agitating the contents of the tank for a duration of only 30 minutes prior to sampling, whereas at least a 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> agitation of the wastes, to ensure a uniform and representative sample, is common. On
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1 or about January 3,1989, the licensee determined the concentration of alpha emitting isotopes contained in waste storage tanks A-1 and A-3, located in Building 6, to contain a concentration such that dilution ratios of 15:1 and 14:1, respectively, would be required for i
release. These are concentrations beyond the scope of RPI 218, and the licensee devised a method for dilution and release of the contents of these two tanks.
This method involved an unwritten, unapproved procedural modification that consisted of partially draining tanks A-l'and A-3 into the waste dilution tanks.
Since all waste storage tanks, including tanks A-1 and A-3 have only three level indications, empty, half full, and full, the licensee was unable to determine the amount of waste actually sent into the waste dilution tanks. The use of that unwritten and unapproved procedural modification is an example-l' of failure of the Plant Manager to assure that all operations involving radioactive materials have written procedures which include the ap-propriate safety requirements in accordance with Section 2.7.2 of the NRC-approved license application. This was identified as an apparent-i violation of license requirements (70-1100/89-02-02).
In addition, the inspector determined that the licensee does not measure the waste concentrations in the dilution tanks.
Instead, the licensee has installed a composite sampling device downstream of the-waste dilution tanks. However, the results of analyses from this sampler are determined after the waste has been released off site.
It was also noted that Building 6 (where the waste tanks are located) is monitored only by a sump monitor and by periodic (weekly) entry to the building.
In the event of a leak or spill from the tanks, a building sump pump would activate. Activation of this sump pump causes an indicator to light on the computer monitor.
However, at the present time, the monitor is checked only once each week by the health physics staff.
Because of this, the sump pump could operate for periods of l
up to about one week before action is taken to correct the problem.
i The licensee stated that they would review this problem.
b.
' Airborne Effluents The licensee measures the release of gaseous effluents containing uranium from two buildings on site, Buildings 5 and 17. During 1988, the licensee hired a consultant to analyze the gaseous release paths from these two buildings to ensure that the systems operated properly and that their effluent sampling method was in accordance with ANSI N13.1-1969.
Results of this study are contained in the report "A Survey and Report on Building Five and Seventeen Exhaust Systems",
dated June 7, 1988.
Results of this report indicate that the three j
systems located in Building 5 do not meet the ANSI N13.1-1969 j
criteria for effluent sampling, and that in Building 17, the ventilation system FA-1 is capable of operating at only 62% of design flow capacity for reasons not yet determined, and ventilation system I
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I FA-2 clogs to below minimum standards (delta P of 4 inches of water) in as little as 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee has yet to take action on the findings of this study. According to licensee representatives, the 1
consultants' report is still being evaluated. As a result'of the
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consultants study it was determined that system FA-2, located in building 17 had a zero flow area at and around the center of the air i
chamber. The licensee is in the process of evaluating the consultant's report.
1 The licensee's semiannual effluent release reports cnly consider releases measured from Building 17.
The licensee stated that this was because the contribution to the total effluent release from Building 5 was negligible when compared to that from Building 17.
In light of the consultant's report concerning the exhaust and measuring systems in Building 5, the licensee was requested to include the Building 5 effluent release data in the semiannual effluent release report.
i Additionally, during the inspectior, a potentially unmonitored release l
path was identified. An operating exhaust system in Building 6, where the liquid waste storage tanks are located, was not monitored. The inspector determined that the inside of the building is a contami-nated restricted area and that, as previously discussed, the licensee could fail to detect a contaminated liquid spill for several days.
As a result, monitoring of releases from the filtered building exhaust system could be required.
Failure to monitor this building exhaust stack is identified as an inspector follow-up item.
10 CFR 20.201(b) requires each licensee to make surveys as may be necessary for the licensee to comply with the regulations in this part in that 10 CFR 20.106(a) states, in part, that a licensee shall not possess, use, or j
transfer licensed material so as to release to an unrestricted area radioactive material in concentrations-which exceed the limits specified in Appendix B Table II of this part except as authorized pursuant to 20.302 or paragraph (b) of this section (70-1100/89-02-03). The licensee stated that it would evaluate the potential for radioactive releases from Building 6, and take appropriate corrective actions if necessary.
c.
Radiochemistry Laboratory Liquid and air particulate effluent samples are sent to the licensee's analytical and radiochemistry leSoratory, located in Building 5, for analysis of gross alpha, gross beta, and uranium content.
Review of procedures and records at this laboratory indicates that the use of control charts, for the Canberra alpha / beta counter used for the I
analysis of gross alpha and beta activity, had only been instituted i
since January 1989; those control charts are not graphed and plotted on a daily basis but are stored on a computer disk and generated at the end of each month; there is no Quality Control procedure for instrumentation; voltage plateaus for the Canberra alpha / beta counter are not taken after each change of counting gas; and procedures were 1
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7 written between 1974 and 1978 and have not been reviewed by management j
since written.
Because the licensee has not established a Quality Control procedure for instrumentation or determined voltage plateaus for the Canberra alpha / beta counter, the measurements made to show that the licensee-does not exceed the concentration requirements.of 10 CFR 20.106(a) and (g) are suspect. As a result, this has been determined to be an unresolved item pending demonstration by the licensee that these programmatic,and analytical deficiencies did not affect the reported values (70-1100/89-02-04).
i 4.
Environmental Monitoring Program Review The licensee's annual environmental monitoring report and environmental I
program is coordinated by the Radiochemist.
The inspector examined the licensee's environmental monitoring program records for 1987 and.1988 and found the same lack of a Quality Control program as identified for th.e measurement of effluents. Although the licensee receives several environmental samples including uranium containing samples.as part of the-Environmental Protection Agency's (EPA) cross check program, the licensee.
has not analyzed the uranium samples provided. The licensee stated that the EPA uranium samples were not appropriate to the needs of the facility, however no attempt has been made to secure a commercially fabricated, traceable.
source which can be used to verify the accuracy of the licensee's uranium analytical data.
In additi-on, the licensee does not analyze spiked or split environmental samples.
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Review of the data to be incorporated into the 1988 Environmental Report showed a spike in the measured uranium activity for on site fallout samples analyzed for June 1988. These fallout samples, which are analyzed quarterly, had typically been at or below the licensee's minimum detectable activity
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level of 18.5 ug/m.
In June, samples as high as 154.3 ug/m 2
2 were detectcd.
The licensee offered no explanation for this event, and failed to conduct any investigation at the time of occurrence. The inspector requested the licensee to conduct an investigation into the source of this higher value, 5.
Preventive Maintenance Program Early in 1988, the licensee initiated work on a preventive maintenance system as a result of equipment problems identified during 1987. An engineer was hired to establish the system.
That individual identified about 150 systems within the facility that require preventive maintenance. A system was established to assure that maintenance is conducted when required. That system included a calibration program.
Actions were also, initiated to obtain operations and maintenance manuals for each piece of equipment and to establish a mechanism to assure that j
the maintenance work has been completed in a satisfactory manner. During this inspection, the inspector reviewed the status and implementation of the preventive maintenance system.
During this review, the inspector was informed by licensee representatives that the system was fully operational for only about one month, since about February 1,1989.
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Therefore, there was not sufficient history to detennine the j
effectiveness of the system.
However, through discussions with licensee representatives,- the inspector determined that the. individual responsible for' implementation of the system was about to leave and that the preventive maintenance system did not. apply to equipment or facilities located in Building 5.
Licensee representatives indicated that an individual will be assigned to this effort and that the equipment'or L
facilities located in Building 5 would not be included in the-established l
Preventive Maintenance System since it was applicable only to the Building 17 facilities and equipment. Maintenance activities in' Building 5 were l
to be handled by the Windsor site maintenance group and not by Building 17 personnel.
i 6.
Radiological Protection Procedure Review Subsequent to Inspection No. 70-1100/89-01 the licensee issued 18 of the 22 procedures for implementation by the facility radiation protection technicians, the status and content of each of the issued procedures was examined by the inspector.
On the basis of the review, the inspector determined that none of the procedures appeared to be applicable to Building 5, Development Laboratory operations.
This was discussed with licensee representatives.
Initially, the licensee considered issuing two sets of procedures, one set for the Nuclear Fuel Manufacturing facility and one set for the Development Laboratories.
However, the decision was finally made to establish one set of procedures applicable to both facilities.
However, the wording in the procedures was not modified to reflect this change in applicability.
The licensee intends to take action to correct this oversight.
Several other specific recommendations for improvement of those procedures were provided to licensee representatives by the i
inspector.
For example, RFI 210 " Protective Clothing" should be modified since the protective clothing requirements specified in the procedure are not the same as used routinely in the pellet shop.
I 7..
Shipping Container Stor qe During examination of the yard area of Building 17, the inspector observed twenty empty Model 927 fuel assembly shipping containers stacked four high. The licensee routinely stacks full shipping containers three high in the same area.
The licensee has evaluated the nuclear criticality safety of the storage of these shipping containers in an infinite array stacked three high. The inspector questioned if the structural integrity of the full packages would meet the minimum safety factor of 3 required by section 4.2.7 of the NRC approved license application especially with regard to deformation of the shipping containers under compressive load. The licensee could not locate the details of structural evaluations conducted on these shipping containers prior to obtaining Certificate of Compliance No. 6078 to see if the factor of 3 test could be met.
Therefore, the licensee intends to reevaluate the structural stability of these containers.
Pending completion of that reevaluation, this was identified as an unresolved item (70-1100/89-02-05).
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9 8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance
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or deviations.
Two unresolved items with regard to the quality of environ-mental measurements made to show compliance with 10 CFR 20.106 requirements (paragraph 3c) and the structural stability of stored Model 927 containers (paragraph 7) were identified during this inspection.
9.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection on March 17, 1989. The inspector summarized the scope and findings of the inspection.
Subsequent to the inspection the licensee was informed that an apparent violation with regard to the establishment of written procedures to cover the proper dilution cf liquid waste and an unresolved item with regard to the quality of environmental measurements made to show compliance with 10 CFR 20.106 requirements were also identified.
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