ML20195F984

Insp Rept 70-1257/88-08 on 880906-09 & 23.Violations Noted. Major Areas Inspected:Mgt Organization,Training & Retraining,Criticality Safety,Operations Review,Maint & Surveillance Testing

ML20195F984
Person / Time
Site:	Framatome ANP Richland
Issue date:	11/18/1988
From:	Brock B, Fish R, Pang J, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20195F979	List: ML20195F975 ML20195F981 ML20195F984
References
70-1257-88-08, 70-1257-88-8, NUDOCS 8811220474
Download: ML20195F984 (16)

Text

l U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/88-08 Docket No. 70-1257 License No. SNM-1227 Priority: O Category: III Safeguards Group: I Licensee: Advanced Nuclear Fuels, Inc.

2101 Horn Rapids Road Richland, Washington 99352 Facility Name: Richland Facility Inspection at: Richland, Washington Inspections Conducted: September 6-9 and September 23, 1988 Inspector: N Cb B. L. Brock, Fuel Facilities Inspector N/7/ff Date Signed s -r ,

Inspector: IItb k -fi // E/M J . F, . Pang, R diation Specialist Date $1gned Inspector: hM, fm,/I,,,,# n/,, y/ G/

K. M. Prendergast,jmergencyPreparedness Date Signed Analyst n m .-, -

Approved by: 7 DN'< //// f'[

R. F. Fish, Chief Oate Signed Emergency Preparedness Section Summary:

Inspection on September 6-9, and September 23, 1988 (Report No. 70-1257/88-08)

Areas Inspected: A routine unannounced inspection was conducted of management organization, training and retraining, criticality safety, operations review, maintenance and surveillance testing, radiation protection, transportation and action on previous inspection findings.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020, 88025, 83822, and 86740 were covered.

Results: Two violations were identified in the area of radiation protection.

One violation involved the failure to perform an adequate survey and the other related to excessive contamination levels on cloth protective clothing allowed to be reused (see Section 2.F.9 of Details). No violations were identified in the other six areas inspected. The inspection also identified the need for some action in the area of respiratory protection with respect to activities involving UF6 cylinders and gas lines (see Section 2.0.(1)(a) of Details).

8811220474 881118 PDR ADOCK 07001257 C PNu

f DETAILS

1. Persons Contacted A. Advanced Nuclear Fuels

• T. W. Patten, Manager, Plant Operations D. C. Lehfeldt, Manager, Operations Planning and Scheduling "R. H. Purcell, Manager, Safety and Security

• D. L. Condotta, Manager, Chemical and Ceramic Development "T. C. Probasco, Supervisor, Radiological and Industital Safety

• C. W. Malody, Manager, Corporate Licensing

• J. E. Pieper, Specialist, Health Physics S. R. Lockhaven, Specialist, Industrial Hygiene

• E. L. Foster, Radiological Safety Specialist J. Kohler, Process Engineer T. Luzzo, Electrical and Instrument Maintenance Engineer C. L. Christiensen, Electrical and Instrument Maintenance Engineer R. Beck, Maintenance Engineer R. Norman, Shift Supervisor, Ceramics S. Lawrence, Acting Shift Supervisor

• Denotes those attending the exit interview.

2. Functional or Program Areas Inspected A. Management Organization and Controls (88005)

The licensee's radiation protection organization was reviewed and the following observations noted:

(a) The Health and Safety Committee (H&SC) has about 31 members, 10 of which are also members of the ALARA Committee. Section 2.3 of Part 1 of the license application dated July 1987 (referenced in Condition 9 of the license) states that the H&SC is responsible for all aspects of safety including radiological safety practices and trends. The ALARA Committee is responsible for review of trends in personnel exposures, effluents and their control. The ALARA Committee is required by license to convene semi-annually. Further, it is required to isue a formal report at least annually to the H&SC. The licensee's ALARA Committee functions in accordance with the license application. It is noted however, that the ALARA Committee's recommendations are subject to H&SC decision regarding implementation.

(b) The Radiation Safety Officer (RS0) is responsible for the radiation safety program. In addition he is also responsible for industrial safety, fire protection and industrial hygiene.

In an organization of this size, the radiation safety program usually is a full time commitment of one person.

2 It appears that the radiation safety 5.rogram control may be weakened by the assignment of additional responsibilities to the responsible manager.

Performance in this prograrr. area warrants closer ettention to ascertain the adequacy of the management of the radiation safety program. No violations were identified.

B. Training (88010)

During this inspection records of initial and annual radiological and respiratory training were reviewed by the inrpector. It appears that the initial radiological safety training and respirator training h9d been provided to radiation workers as required.

However, with regard to the annual ref resher training required for radiation workers, the licensee doesn't appear to have in placc a control system that ensures that every worker will receive training each year. According to the licensee's representatives, they have been in the process of developing a computer program to assure identification of those needing the training and facilitating its scheduling.

This program area warrents further attention during a subsequent inspection. No violations were identified.

C. Criticality Safety (88015)

(1) Facility Changes and Modifications The basement area of the Engineering Laboratory Operations (ELO) building had undergone char.ges that were in the planning stages during the previous inspection. The Gadolinium Scrap Recovery Process (GSE?) storage area and change room were reduced in size to provide space for two additional process tanks. The change was made through the use of the Engineering Change Notice (ECN) process. Additionally, the Ash Leach Pilot Plant (ALPP) for the recovery of uranium from the ash generated .

in the Solid Waste Uranium Recovery (SWUR) facility was now operational, This plant (AlPP) along with the GSRP and the Decontamination Facility, currently across the hall from the GSRP, are scheduled to be n.csed into a separate building designed for them sometime in the future (about 2 years). An ECN covering this change is currently undergoing review.

(2) Nuclear Criticality Safety Analysis The licensee maintains a staff of persons qualified to perform iequired Nuclear Safety Analyses and the associated independent reviews. Facility changes conti me to be made under appropriate ECNs.

3 (3) 0bservations (a) The inspector coserved a sign in the GSRP area that precluded additions to tank No. 2 of the process. The sign applied to previous operations involving solid (powder / pellets) feed. Olscussions with the operators and review of the procedures indicated (. hat additions to tank No. 2 are made when processing Liquid Uranium Recovery (LUR) feed. Thus, the sign does not apply to the LUR feed and had not been removed when such procussing began. The criticality safety specialist stated that he had reviewed the procedure before the revision permitting the processing of LUR feed was opu owed. The licensee stated that the iroprovem'*nt in ope-ator perform ince ir following procerares warranted removal of the sign. 1..a sign was removed prior to completion of the inspection.

(b) The inspector noted that the lic.ensee 'isd two administrat1ve limit signs dispite a in the Powder Characteriz'ition facility (PU) v, addition to the criticality limit sig1. The , w ass engineer responsible for the area indicated orie of the administrative limit signs should have been removed following the recent completion of the ooeration to which 't had app'ied. The surplus sign was p: capt ly retroyed. T'e process engineer indicated that the administra'.lve limit had lower limits than the posted criticality limit thus the error did r*nt compromise criticality saftty. l'he inspector asked the licensee to identify the 6 Lgs of SNM on the :Nntinuovt inventory record (CIR) 'or the work station involved. ' t.e inventory confirmed that *.he SK4 at the work station was about 35% of the administrative limit and only 18% of the criticality limit.

(c) The NRC inspector also noted that the CIR in the PCF lacked a column for enrichment. Me absenc* of recording the enrichtrent precluded using the CIR for determining that the licensee remained in compliance with the criticality limit during eddittor. to the work station.

The licensee is propostnq to revise the CIR to include the enrichment of the spec c SNM being added to the work station. This addition will clarify which limit it. ' 5e criticality limit table applies and will facilitate auditing the licensee's adherence to the criticality limit

&s well as the validity of the administrative 1 41t posted.

(d) The NRC inspector questiened the storage of HEPA filters in the line 2 area at the Utility Hood. The Criticality Safety Specialist explained that the HEPA filtars were in Queue for removal of their cores at that work ttation.

The core removal operation would follow the sma. )

operation of recovering a few UF samples. The 6

4 criticality safety specification 3dequately addressed this use of the Utility Hor.]

The licensee's use of signs appears to warrant farther rJview in the future and is therefore identified as open item 88-08-01.

Performance in this program area appears adequate. No violations were identified.

O. Operations Review (88020)

(1) Conduct of Operations (a) Vaporization Room During the tour of the line 1 vaporization room, conducted ca September 7,1988, the "emergency" self contained brwathing apparatus was observed to be inoperable because the air in the cylinder had been expended. A physical check by the operations persornel in the vaporization room determined the SCBA contained less than 3 lbs. of compressed air. When questioned on tne use of the unit, the Acting Shift Supervisor stated that they routinely use the SCBA connected to supplied air when working with UF 6 cylinders. It was his opinion that the rnutinc use was the reason for the SCBA unit being inoperable, He also stated thrt health physics perconnel are responsible to ,

insure the unit's operability. Discussions with health physics personnel indicated it w36 their impression that since operations personnel routinely use the unit, they (operations) were responsible to insure the unit is fully charged and coerhole. Because of the safety significance, it is recommended that the lo atfor, use, and responsibilities to insure the optrability of the SCBA units be addressed in the RWPs. The failure to maintain the RWP (ANF-P91,013) "UF g Vaporization Operations,"

curra t with the present 6pe*ation of the SCBA unit utilizing supplied air is idet.tified as open item 88-08-02. The fiilure to maintaia pressure in "emergency" SCBAs is considered c safety istue and is included as part of the open item (88-08-02).

Note: According to the licenset. the emp'.y .s e ne,y" SCBA tank was replaceu by operaticns persunre. i :

.diate,y after the problem wa. brought to their attent (b) Conversion $rea The NRC inspector cuestioned the car amance of th5) automatic shutdown feature of the temperatur controllers for the heatei s of the oil bath dryer. The acting Shift Supervisor demot.;trated . hat the overter.rgerature controller did clarn ind inut off the heaters when the

5 preset temperature was reached. The controller then required man' sal reset of the unit for reenergizing the heaters.

The inspectors learned during tha Entrance Meeting that the licensee had experienced a quarantine tank leak on September 5, 1988. The leak had been cleaned up, however, during the tour it was noted that the cleanup involved the removal of perhaps an area of about 2 sq. ft of asphalt.

It appears that, In order to leak to the butside asphalt, tht quarantine tank leak would need to flood two internal rooms (per design) before rising above the sill of the door. The licensee was in the midst of investigating the incident and no conclusions were available prior to the departure of the NRC inspectors. The licensee's report will be reviewed during the next inspection as upen item 88-08-03.

(c) , Gadolinium Scrap Recovery Pla7} (GSRP) lhe GSRP is routinely processing uranium recovered by the liquid Uranium Recovery (LUR) process. The feed to the LUR process is on a safe batch basis and the product, controlled te a safe concentration, is feed for the GSRP system. The GSRP product, after verificaticn that it contains less than a safe concentration, is transferred to a 55 gallon drum and subsequently is reprocessed into product powder and th( into fuel pellets.

(d) Soliu Waste Uranium Recovery _ (SWUR) Facility The SWVR facilitj was now processing waste contaminated with tad)1 quantitie: of uranium. The NRC inspectors observed operation of the sorting hood used to separate burnable waste from nonburnable waste. The form of th-current wa:te was cut up wood panels from boxes that '

previously stored contaminated waste. The U-235 content of the tepackaged burnable waste is measured by aandestructive assay (NOA) before placement in the incinerator. The NDA equipeant is checked before measurements are made on the boxes. It was noted that the equipment was not passing the calibration check; therefore, tha box we were obse. wing was not measured nor fed to the incinerator. The operator indicated the NDA equipment was apparently experiencing a problem that needed attention. This measurenent is t,he baris for control of the input batch to the incinerator. The resolution of the problem will be reviewed during the r ,1 inspection as open item 88-08-04.

(e) Neutron Absorber Facility (NAF) i The NRC inspector reviewed changes in the control of removal of pans used in the exidation of pellets from the I _

6 furnace enclosure. The licensee had put a metal seal on the door that was previously used to remove the pans. The licensee had also added a guard rail inride the enclosure to preclude damaging the plastic enclosure while moving hot pans around.

In the rod loading area several changes are underway. The pellet demoisturizing furnace section is being moved south from its present location to facilitate an increase in throughput.

(f) Lagoons Lagoon No. 4 was currently being carefully inspected to identify all breaches of its liner in order to repair all leaks prior to putting it back into service.

The site effluent flow measurement device the licensee previously identified as not functioning normally had been repaired and was currently undergoing testing that was expected to last about 30 days. The test results will be reviewed as part of the follow-up of open item 88-04-05.

(g) New Construction The construction of the new building for housing the Irradiated Fuels Services operation near the southwest corner of the site, is virtually completed. The licensee stated that a supplemental alarm was provided to this area as NRC requested to assure that workers could hear any evacuation signal prior to completion of the installation of the permanent alarm system for the building.

The construction of the new Deionizing facility for process water was also completed. The licensee indicated that the spilled water, observed during the tour of the facility, was leakage from recently assembled plastic piping undergoing testing.

It was noted during the tour that a new tank, installed to the east of the new Deionizing facility, did not yet have a burm around it. The area will be checked again during a subsequent inspection.

Performance in tt program area appears to be adequate. No violations were ntified.

E. Maintenance and ' ce Testing (88025)

(1) The NRC inspecto* reviewed the licensee's Preventative Maintenante Program (PRM). The system operation was demonstrated by the responsible Maintenance Engineer.

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(a) The fire alarm system was reviewed in detail. The applicable procedure preparation, approval, and acceptance was recorded in the computer system. The purpose, requirements, references, and special test equipment were also included. The step by step check list was also a part of the printout and facilitated properly conducting the tests in full and necessary coordination with not only the plant security but with the local city fire depar unent as well. Drawings showing the detector head locations were clearly identific). Special notes called attention to the different test frequencies for the different parts of the system and also provided a reminder that the detector number and the date tested would be entered in the history file. A working document was also provided by the computer. This document included, for each zone, the head number, the head type, the required test frequency, and a check off space for each unit as its test was completed. Additionally, this working document included supplemental informat on helpful in locating various heads. The document ended with a space for unusual conditions, the name of the tester, the date of the test, the tiae it took to complete the test, and the supervisor's approval. The completed document was then

• required to be forwarded to the PM Administrator. To complete the system outstanding PM jobs are tracked and items requiring special work orders for follow-up are identified.

(b) TM fire extinguishers are on a PM issued to the Supervisor of Radiological and Industrial Safety. The fire extinguishert are then inspected under centract on a monthly frequency. One fire extinguisher of the 39 checked by the NRC inspector had been missed in the month of August. That extinguisher, number 81, was located in the locked warehouse's rcuth section in which HEPA filters were stored. The HEPA filter packaging (cardboard boxes and plastic wrapping) appears to represents a significant fire loading because of the large number of filters stored there. Access to this warehouse fire extinguisher should therefore he facilitated.

(2) The inspector also reviewed the Instrument Repetitive Maintenance (IRM) program. The IRM system, which appears to be well organized, was described by the responsible Electrical Maintenance Engineer. Safety instruments on the IRM pror, ram are labeled in red to assure their calibration schedule will not be slipped. Instruments that are blue labeled can be slipped on the calibration program under Special circumstances with appropriate management approval.

Similar docu.ints, totaling about 2600, existed for other categories of equipment. The licensee finds the computer very helpful in keeping the PM program on schedole and in keeping the documents and procedures current.

Performance in this program area appears adequate. No violations were identified.

F. Radiation Protection (83822)

(1) Instruments and Equipment (a' The radiation survey instruments checked for current calibration were found to be within the calibration period.

(b) The calibration stickers on air sample flow meters I observed during the inspection indicated that the flow meters were within the calibration period.

(c) The licensee's magnehelic gauges observed during the inspection indicated normal plant performance. No readings exceeded the 4 inch of water level at which high efficiency particulate (HEPA) filter changes are required.

(d) Several air sample flow meters observed during the inspection were below the set flow rate of 60 CFM. Some were at 40-50 CFM and one was close to 25 CFM. This was readjusted to the proper flow rate by the Health Physics Specialist (HPS) when it was called to his attention.

According to licensee representatives, air sampler filters are changed on at least a daily frequency. Although the licensee stated tha' the air sampler flow rates are checked by the Health Physics Technicians (HPT's), it appears that this is not adequate to ensure that the air samplers are operating at the proper flow rates. The licensee should review his procedt res and equipme it, and take whatever appropriate steps are ~ Ced to ensure that the air samplers are operated at the established flow

, rates. The licensee's corrective action will be reviewed l in a subsequent inspection as open item 88-08 06.

l (2) Postir.g and Labeling It was noted that the radiation levels in the powder storage areas in the Uranium 0xide building were such that a major portion of the body could receive a dose in excess of 100 mrem in any five consecutive days. A "CAUTION RADIATION AREA" (CRA) s',gn should therefore be posted. However, licensee representatives stated that the CRA signs posted on the door to the UO 2 building meet the posting requirements for the posting of radTation levels in the building. This hterpretation is not consistent with the intent of the regulations. Posting of CRA signs must be made where appropriate as determined by the ambient radiation levels in accordance with 10 CFR 20.203. The radiation level at 18 inches from the source or barrier is the level used to determine the need for a CRA sign. This is based on the rationale that radiation levels which exist at this l

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distance from the source or barrier would result in a valid whale body exposure.

(3) _Decontamination Previous inspection reports identified that the licensee had put a grey coat of paint over yellow paint used to cover residual contamination on a room floor in the ELO basement.

The grey coat was put down as a wear indicator. As the grey coat wears the yellow paint will begin to show through, thus alerting the license to the need for corrective action before the surface paint is worn through to the contamination. The sign indicating the contaminatior, exists under the yellow paint remains in the room window. According to the licensee's representatives, a master record of all such contaminated areas so painted is being compiled and maintained. This open item, No. 88-04-03, will be closed when the master record is completed.

(4) Air Monitoring Records of airborne monitoring conducted since May, 1988 were reviewed. No significant airoorne concentrations were noted.

AirggrneconcentrationswerewellbelowtheNRClimitof1x 10 pCi/ml.

(5) Surveys Records of radiation and contamination surveys conducted since May, 1988 were reviewed. No significant radiation or

) contamination levels were noted. However, on some of the contamination survey report forms, the results are given in CPM rather than OPM. The instrument efficiency should be provided on the form if the results are not recorded in DPM.

(6) Radiological Safety Audits Monthly inspectionc of of fshif t operations are conducted by the Radiation Safety Officer (R50). A review of the records for the period since April, 1988 disclosed that the areas inspected had not been noted on the report nor had there been any deficiencies / violations found. According to the R50, corrective actions are taken on-tne-spot and are not recorded.

Monthly audits of the radiation safety programs are conducted by the Health Physics Specialist (HPS). They are summarized in the form of a short generalized check list which remains the same each month. To improve the audits of the radiation safety program, it is recommended thai the HPS cover specific areas in more depth than is curently being done.

, This could be done by selecting certain areas of the program to be audited rather than to attempt tc audit the entire radiation safety program each month. Also it is suggested that independent audits of l

l the radiation safety program by other persons would provide a different perspective of the status of the prcJram.

(7) Bioassays

a. Urine Samples The licensee's summary report for 1988, through 8-24-88, was reviewed. Of the 1167 urine samples collected and analyzed, only three samples were fo'Jnd to be positive.

All of the three positive samples were below the company's action level of 25.0 pg/1.

b. Lung Counts Of the 142 workers who were lung counted, 15 had a positive lung count. Only one of the 15 was above the action level of 0.27 nCi 1.e. the employee had a termination lung count of 0.28 nCi. The employee subsequently was re-employed by the licensee in July, and a lung count at that time was .093 nCi.

c. 'Vhole Body Count A total of 19 employees working with mixed fission products during the first seven months of 1988 were whole body enunted. Five employees had positive whole boc'y counts. The average whole body count was 3.0 nCi (Co-60).

No exoosures above the regulatory limits were identified.

(8) Personnel Monitoring l According to the licensee's summary report, the highest cumulative exposure for the first two quarters of 1988 was 610 mrem. No exposures above the regulatory limits were identified.

(9) Facility Tour i

A facilities tour was conducted during this inspection. The l following represent the observations of the NRC inspectors made l during the tour.

(a) Radiation survey instruments and air flow measurement devices were checked and noted to be within their calibration period.

l (b) Magneheli: gauges observed at all facilities visited indicated normal system performance. There were no readings observed that were greater than four inches, which is the limit that indicates a filter change is required. However, some magnehelic gauges (e.g. south of i the laundry) and air flowmeters faces were noted to be l

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11 stained which made reading the gaupc: al=o:t impossible.

This area shuuld be examined to de. ermine if some improvements are necessary.

(c) During a tour of the gadolinium scrap recovery area, contaminated clothirg was observed to be hangiuo on a coat rack ready for reuse. A survey of the clothiq using the licensee's survey meter, stationed at the step-Off pad, dis-losed contamination levels of approximatelv 46,000 dpm (alpha) on the leg of the coveralls. A wipe of the contaminated area was tak' i and it showed 9,000 dpm (alpha) which confirmed the contamination was removat.le and not fixed. The contaminated coveralls were brought to the attention of the Health Physics Technician and the coveralls were quickly removed and put in the contam'nated clothing container. Radiation Work Procedure ANF-P91,001, "General Facility Radiation Work Procedure," states in Section 5 that "Protective clothing (coveralls and lab coats) shown to be clean by surveys (not shoe covers or gloves) are allowed in intermediate areas (boundaries identified by yellow and green tape on floor)." It ppears that 10 CFR Part 20.201 and the licensee's stocedures were not followed in that: (1) An adequate survey was not performed to insure the coveralls were freo of contamination and the coveralls were mistakenly placed on a coat rack for reuse by licensee personnel; and (2)

Routine plant practices for exit from contaminated areas allow personnel wearing laboratory coats to routinely cross the step-off pad after a brief survey without removing the laboratory coats. The failure to follow procedures and to perform an adequate contamination st.rvey is considered a violation and will be followed as open item 88-08-07.

(d) As the result of touring the site laundry facility and discussions with personnel at that facility, it was learned +. hat radiation work procedure (RWP) ANF-P91,018 and routine laundry practices set a 11mit of 5000 cpm using en HP-260 as the limit for which laundry would be recycled through the cleaning process or discarded as contaminated waste. Both the routine practicrs and the RWP for the laundry facility appear to contradict the 1000 dpm alpha limits stated in the l' cense. Part 1 of the license application, referenced in condition 9 of lic'nse SNM-1227, states in Section 3 that "Cloth protective clothing will not De reused if the contamination exceeds 1000 dpm alpha". Using approximate efficiencies of 12 to 16 percent for the HP-260 probe for detection of alpha l particles, it appears that clothing with contamination values of up to 30000 dpm alpha may be released for reuse at plant facilities based on current practices and the current RWP. The failure to follow the conditions of the license is considered a violation and will be followed as open item 88-08-08.

12 This program area warrants iarther attention. Two violations were identified.

G. Transportation (86740)

The Regulations, 10 CFR 20.205, require that surveys must be made of shipments received. The licensee's program for packaging and sh% ment of licensed material must be in accordance with 10 CFR 20,311 and 10 CFR 71.

Randomly selected records of shipments and receipts of licensed material were reviewed by the NRC inspector. The records indicated that surveys to show compliance with 10 CFR 20.205 had been conducted as required. Recoro, of several randomly selected fuel shipments and receipt of licensed material made since the last inspection were reviewed for compliance with 00T requirements.

This program area appeared to be adequate. No violations were identified.

3. Action on Previous Inspection Findings (Closed) Open Item 87-05-01: The licensee's redesign of the steam lance and repair of the leak now preclude the addition of moisture to the product powder from the conversion lines and thus warrants closing this item.

(Closed) Open : tem 87-05-04: The licensee had lubricated the fire suppression sytem valves as suggested by the consultant. This item is considered closed.

l (Closed) Open Item 88-02-02: The airlock on the east side of the ELO basement was observed to work properly during the inspection.

This supported the licensee's statement that the system had been repaired and put in service prior to the completion of the previous inspection. This item is considered closed.

(Closed) Open item 88-04-01: The licensee provided the temporary alarm in the southwest corner of the site to assure that the workers constructing a new building would hear any evacuation alarm.

This tempo,ary alarm was used until the permanent alarms were I

installed and operating. This item is considered closed.

(Closed) Open Item 36-08-04: Review the upgrading of training, including the frequency of drills and related evaluations and documentation. This area was examined and improvements w e t noted in the emergency response training program. The improvements included updated lesson plans and an increase in the frequency of training and drills. Documentation examined indicated quarterly training was accomplished on differing l subjects such as SCBAs, mass casualty, first aid and response l to a radiation emergency. Records appeared adequate; however, l it was noted that attendance is at the 40 to 50 percent level.

Management should address methodologies to insure all personnel l

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13 receive init.ial and annual refresher training. Documentation for emergency response drills was also noted to be improved.

Documentation for a criticality drill conducted March 29, 1988 was examined and the items identified in the critique were noted to have been brought to management's attention and wore being corrected. This item is considered closed.

(Closed) Open Item 86-08-12: Review cnordination with offsite agencies to allow ANF Emergency Cadre to respond to an emergency, when road blocks have been set up. This item was examined and the licensee has coordinated emergency plant access with the Department of Energy and the Hanford Patrol. This action will allow the Emergency Cadre to pass through road blocks to respond to an emergency at the plant. This item is considered closed.

(Closed) Open Item 88-02-04: Determine if the revision to the Emergency Plan and implementing procedures includes prompt notification of both the State of Washington and the NRC. The item was examined and the Manager of Safety and Security has committed to revising the Emergency Plan and implementing procedures to include the State of Washington and the NRC in the official notification of any formal dttlaration of an emergency. This will include the emergency classifications from unusual event category to general emergency. This item is considered closed.

(Closed) Open Item 88-02-06: Determine if the revisions to the RCP reflect a clarification of the equipment to be deployed and by whom during an emergency. The equipment types, capabilities and procedures should also be addressed. This item was examined and it was determined that the licensee has coordinated the response to an emergency with offsite support agencies, including the Department of Energy, Pacific Northwest Laboratories, and U.S. Testing. This coordination included a comoarison of the types of environmental sampling that would be performed during an emergency and a review of procedures, instrumentation, and methodologies to insure sampling results and instrumentation are compatible. A description of environmental mer.itoring techniques will be provided in ANF-32.

This item is considered closed.

(0 pen)  ? pen Item 85-02-05: Addressed implementation of the Criticality Safety Task Force recommendations. The licensee had added the recommended annual criticality safety program appraisal to ANF 30, Chapter 3, Nuclear Criticality Safety Standard. The item remains open pending '.mplementation of the annual appraisal.

4. Exit Interview At the conclusion of the inspection, the findings were discussed with the licensee's staff identified in Section 1. The topics included:

14 A. The aress inspected.

(1) The licensee's organization was discussed with regard to the function of a Radiation Safety Committee (RSC) and the effectiveness of the position of Supervisor of Radiological and Industrial Safety.

The licensee expressed the opinion that the ALARA Committee fulfilled the responsibility of the RSC and that the Supervisor of Radiological and Industrial Safety was able to adequately fulfill his radiological safety responsibilities.

(2) The observations made durirg the course of the inspection were discussed. Some posting and labeling problems were identified.

Subsequent in office documentation review, in addition to information provided by the licensee telephonically on September 15 and 23, 1988, resolved the inspector's concern regarding these items. Relocation of recovery operations from the ELO baserrent were briefly mentioned. The licensee confirmed that the move was definitely scheduled.

(3) The need fer better control of refresher training was also montioned.

(4) Maintenance and surveillance testing was mentioned briefly with regard to the demonstration of the ovei-temperature cutoff on the oil heated dryers.

(5) Radiation Protection was discussed with regard to laundry release limits, contaminated protective clothing on the cold side of a step-off pad, underposting of radiation areas instrument calibration frequency interpretation, and ths .eed for 'ndepend'.nt audits with a f resh percpective.

The licensee stated he did not think a change in the instrument calibration program was warranted. He indicated consideration would be given to having independent audits conducted as well as conducting them in greater depth by covering select areas fer each audit. An increased frequency for the base walk-through audit was being considered as well.

(6) The operator's routine use of SCBA tanks during l6 cylinder hookup was identified as an open item.

(7) The laundry procedure and practices were identified as being in violation of Part 1 of the license with regard to the limits for cloth protective c1cthing scheduled for reuse.

(8) The performance of inadequate self surveys as evidenced by the preserce of contaminated coveralls on a coat rack outside the GSRP area.

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8. Unusual incident review.

The li qsee experienced an overflow of the quarantine tanks on Septe o 5, 1988. The incident was still being reviewed by the lice..,.e at the time of the inspection.

C. Status of open items Closed items @

New Open items g t

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