ML20236C021

Insp Rept 70-1100/89-01 on 890130-0203.Violations Noted. Major Areas Inspected:Licensee Operations,Criticality Safety Procedures,Organization,Training Program,Safety Committees & Status of Task Force Rept & Nuclear Fuel Integrated Plan

ML20236C021
Person / Time
Site:	07001100
Issue date:	03/10/1989
From:	Austin M, Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236C008	List: ML20236C006 ML20236C017 ML20236C021
References
70-1100-89-01, 70-1100-89-1, NUDOCS 8903210432
Download: ML20236C021 (12)

Text

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u V. S. NUCLEAR REGULATORY COMMISSION U REGION'I  !

-Report No. 70-1100/89-01

-Docket No. 70-1!00 l q

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: January,3fl : February 3,1989  !

Inspectors: '

f(h '

J. Rot ~, P'roject Engineer, ERPS, FRS&SB, datd I DRSS

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M. A. stin,.Radiat n ecialist, 'datd '

ERP FRa&S DRS l I

Approved by:

W.;J. Pascia , Chief, ERPS, FRS&SB, DRSS

/. b /'r at /

/dat( / t Inspection Summary: Inspec ion on January 30 - February 3, 1989 (Report No.

70-1100/89-01)

-Areas Inspected: Routine, unannounced inspection by two region-based inspectors of the licensed program including reviews of the licensee's operations, criticality safety, procedures, organization, training program, safety committees, and status of the Task Force Report and Nuclear Fuel Integrated Improvement Plan.

Results: Seven violations were identified. Violations: failure to adhere to a posted nuclear criticality safety limit (Paragraph 2a); failure to seal 5 Model'B-25 boxes and send 3 55 gallon drums to burial within 12 months of sealing (Paragraph 2b); failure to ensure that interspersed moderation could not enter the fuel rod box storage area (Paragraph 2c); failure to maintain the face velocity on two chemistry laboratory hoods in excess of 100 linear l

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feet per minute (Paragraph 2e); failure to maintain a 60 inch exclusion zone

-around a new set of pellet storage shelves (Paragraph 2f); failure to adequately measure releases from the FA-3 ventilation system stack in accordance with 10 CFR 20.201(b) (Paragraph 2g); and, failure of the Nuclear Safety Committee to review and approve SNM license amendments affecting =

nuclear criticality safety prior to submission to the NRC (Paragraph 4). In addition, it was noted that the licensee had reviewed and approved but had not implemented Radiation Protection Instructions required to complete corrective actions on previously identified enforcement items. This was the subject of a management meeting held subsequent to the inspection on February 16, 1989.

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j DETAILS i

1. Persons Contacted

• S. T. Brewer, President, Nuclear Power Businesses 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 Feel Manufacturing R. Klotz, Nuclear Criticality Safety Specialist D. G. Stump, Manager, Radiological and Industrial Safety J. Vollaro, Health Physics and Safety Supervisor R. E. Vaughan, Manager, Operations R. Duncan, Director, Product Development

• 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 observed the following posting deficiencies:

there was a handwritten sign posted at the fluoroscope work ,

station which stated "No Fuel Rods to be Loaded Beyond Red Line 1

- 1 Foot from End. HP Department".

The inspector stated that the use of handwritten signs was a poor practice that should be discouraged in the facility.

Licensee representatives stated that the sign in question was .

no longer needed since a nuclear safety evaluation was )

conducted which indicated that the posted restriction was not needed at this work station.

The inspector noted that a sign forbidding the storage of SNM within 20 feet of the south wall of Building 21 had been removed from inside the building. This restriction was needed because of the storage of SNM bearing waste along the outside I south wall of the building. Licensee representatives stated I that the sign would be replaced.

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The inspector observed that signs on several radioa:tive material storage areas located inside the Building !1 Warehouse were no longer visible in that they were ; overed or had fallen to the floor. The licensee immediately corrected these inadequacies.

The inspector determined upon questioning of licensee ]

representatives that two partial fuel assemblies located in the pit area of Building 18 were fabricated with dummy (stainless steel) fuel rods for use during demonstration of the CE fuel assembly consolidation process. These assemblies were not identified as dummy assemblies and no controls were established to treat them as fuel bearing assemblies. The licensee ,

verified that they were non-fuel containing assemblies and l indicated that they would be properly identified.

The inspector noted that the nuclear criticality safety posting l on the pellet press workbenches had been modified to allow up I to a five gallon container of uranium enriched to five percent U-235. Previously, the posting authorized up to a one gallon container. This modification was not authorized by current license conditicns. It was noted by the inspector that the previously authorized container size of one gallon was not exceeded during this inspection.

In the Fuel Assembly Storage Room, the inspector observed a sign on storage rows A and B which stated a limit of "one bundle every station - uncovered" At the time of this inspection Row A contained four bundles, two of which were covered with plastic. Failure to adhere to the posted limit which required the bundles to be uncovered constituted an apparent violation of license requirements (70-1100/89-01-01).

The licensee immediately moved the covered bundles to an authorized location which corrected this apparent violation,

b. Outside Storage of Waste During examination of the storage of waste on the waste storage pad located adjacent to the south wall of Building 21, the inspector observed the following:

A total of five Model B-25 boxes were being stored and were not sealed as required by Section 5.1.3 of the NRC-approved license application in that the required lid clips had not been installed.

Licensee representative stated that these containers were being stored in this manner so that the contents could be rearranged prior to shipment without damaging the container by removing the sealing clips.

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5 According to labels attached to waste drums, three of the 55 gallon drums (Nos. 5149, 5150 and 5152) were placed on the storage pad on December 28, 1987. .Therefore, these containers had been stored on the waste pad in excess of the 12 months authorized by Section 5.1.3 of the NRC-approved license application.

Failure to seal the five Model B-25 boxes and send the three identified 55 gallon drums to burial within 12 months of sealing was identified as an apparent violation ,f of Section 5.1.3 of the NRC-approved licensee application (7 '00/89-01-02).

The inspector noted that the lice had established a radioactive material storage area 'nt to and northwest of the powder and pellet storage trail This new storage area held five Model 17H packages contain, olidified oil, springs, zirconium rods, etc., that were contam. ted with U-235. That storage area was not separated from the railers by at least twenty feet to assure adequate separation of arrays of different shipping containers. This inadequacy was identified to the licensee for correction, even though, at the time of this inspection, the actual separation of packages containing uranium was in excess of twenty feet. Licensee representatives stated that the spacing criteria for this and other outside shipping package storage arrays would be re-evaluated.  !

c. Fuel Rod Storage Area During examination of the Fuel Rod Storage Area, the inspector  !

observed that three doors had been damaged and torn away from the framing. This allowed openings in the structure which could allow water from the fire sprinklers to enter the structure if the sprinklers were activated. Section 11-8.5.4 of the NRC-approved licensee application states that the nuclear criticality safety of the structure is ensured, in part, because interspersed moderation was not considered '

credible since moderation control is assured by the cover, walls and doors on the storage area. Failure to ensure that the accumulation of interspersed moderation in the fuel rod box storage area could not occur was identified as an apparent violation of Section II-8.5.4 of the facility license (70-1100/89-01-03). This apparent violation was corrected prior to the end of this inspection.

d. Emergency Egress During examination of the nuclear fuel manufacturing facilities, the inspector identified two cases of inadequate maintenance of evacuation routes as follows:

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'As a result of construction activities at the west end of the cold shop in Building 17, desks, containers, and equipment were relocated.into aisles. As a result, the emergency egress route to the west end of.the building was restricted. Licensee

-representatives stated that the' emergency route in question would be maintained accessible and that the situation would improve upon completion of the construction activities. ,

During examination of the Building 21 warehouse facility, the inspector noted that the aisle at the west end of the building was fully blocked and most of the east-west aisles were partially blocked because of the storage of equipment. As a .

result of this blockage, personnel working at the west end of j

the building would have difficulty in exiting the building if '

an emergency alarm were to sound. Licensee representatives indicated that actions were being taken to clean out'the warehouse and to develop a revised equipment storage plan for the warehouse which should alleviate the identified conditions.

e. Hood Face Velocity During examination 'of the Development Department Chemistry Laboratory, the inspector had a licensee representative conduct a velocity test of the face of chemical hood Nos.14 and 15, each of which was in use for the preparation of uranium bearing chemistry samples. The velocity measurements indicated airflow of between 50 and 80 linear feet per minute on each hood instead of 100 linear feet per minute-required by Section 3.2.3 of the NRC-approved lie nse application.

Failure to maintain the hood velocity on Chemistry Laboratory hoods 14 and'15 at a minimum of 100 linear feet per minute was identified as an apparent violation (70-1100/89-01-04). Actions were immedi-ately taken by the licensee to increase the airflow.to in excess of 100 linear feet per minute and: restrict use of the hoods until corrective actions could be taken.

f. Installation of New Pellet Storage Shelves l q

The inspector observed that the licensee installed a new glove box and a'new set of pellet storage shelves in the pellet shop across the i aisle north of the centrifuge hood. The new glove box was not in use at the time of.this inspection'. However, the pellet storage shelves (

were being used for the storage of sixteen trays of pellets enriched l in Uranium-235 to 4.3 percent from Lot No. W533VB. The exclusion zone surrounding these storage shelves was one foot instead of the  !

five feet required by Section II-8 of'the NRC-approved licensee l application in Figure 8.6. This was identified as an apparent i violation of the criticality safety criteria established in the l facility license (70-1100/89-01-05). Licensee representatives stated 1

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that the one foot exclusion zone was established on the basis of an internally reviewed and approved nuclear safety evaluation. That

. nuclear safety evaluation was conducted when it was. determined that ,

the five f;ot exclusion zone could not be established on all sides of' the. storage shelves because of interference by.other fuel containing work stations. The inspector stated.that since Section II-8 of the license application was incorporated into the facility license by Amendment No. 14, the licensee was not authorized to make equipment-  ;

changes without requesting approval for such changes from the NRC.

The licensee immediately discontinued use of the storage shelves'and moved the pellets to an authorized location.

g. FA-3 Ventilation System Stack Samplinj During examination of the FA-3 ventilation system which services the pellet grinding and rod loading area of the Pellet Shop,.the inspector L observed that the stack sampling point had been moved since the last-inspection. The new sampling location was hard piped with a sharp 90 degree bend. Incorporation of this sharp 90 degree bend into the sampling line raised questions with regard to the adequacy of the samples. The licensee had not evaluated the new sampler location to assure that the samples obtained were representative 10 CFR 20.106(a) states that a licensee shall not possess, use or 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 except as authorized pursuant to 20.302.or Paragraph (b). Failure to adequately measure releases from the FA-3 ventilation system stack was identified as an apparent violation of 10 CFR 20.201(b) (70-1100/89-01-06). Prior to the end of'this inspection, .

the licensee moved the FA-3 ventilation system sampling point to a position which should provide appropriate information on stack  ;

releases. '

3. Nuclear Criticality Safety

a. Facility Changes and Modifications I During examination of the Building 5 facilities, the inspector  ;

observed that there had been no significant facility changes or j modifications which affect criticality safety. It was noted that the licensee had initiated installation of a new micronizer, hammermill and treatment furnace into the ceramics laboratory.

However, none of the criticality safety controls applicable to i the ceramics laboratory had to be modified as a result of these i new installations. l The unauthorized installation of new pellet storage shelves in the pellet shop was previously discussed in Paragraph 2.f.

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b. Nuclear Safety Log Sheets The inspector examined the nuclear safety log sheets available in the Pellet Shop at the hammermill, the screening hood, the micronizer, and the blended powder drier belt to assure that mass limits or slab depths were not exceeded. The time period examined was from January 25, 1989 through February 3, 1989. No inadequacies were identified.

c. Nuclear Criticality Safety Alarm System Durir.g the first part of 1988, the licensee modified the locations of some of the criticality safety gamma monitors in Buildings 5 and

17. In addition, the central annunciator panel for Building 17 was moved from the former Health Physics office into the north end of the office complex hallway to improve accessibility in case of an

. incident. The inspector reviewed the evaluation prepared by the Nuclear Criticality Safety Specialist and concurred that the modified installation appeared to meet the criteria specified in 10 CFR 70.24(a)(1). No inadequacies were identified.

4. Nuclear Safety Committee The inspector discussed recent activities of the Nuclear Safety Committee with the Vice Chairman of the committee. The annual meeting of the committee was held on January 24-25 1989. However, the licensee had not completed and issued minutes of that meeting at the time of this inspection. Those meeting minutes will be reviewed during a subsequent ,

inspection.

f During the meeting, the committee conducted the annual audit of the fuel manufacturing facility and reviewed applicable sections of the Task Force  :

Report (Radiation Protection and Criticality Safety). As a result of that review, the Nuclear Safety Committee is expected to endorse the task j force findings. The committee determined that most of the December 1987 i annual audit findings were still applicable and that while there was progress with regard to applicable corrective actions on those findings, most of the findings had still not been completely corrected. .

The licensee had rehired, on a part time bases, a qualified employee, who l had retired, to act as an independent nuclear criticality safety consultant for the Committee. In addition, the Committee was considering i the formation of a subcommittee to audit the progress of improvements at the fuel manufacturing facility during implementation of the Nuclear Fuel Integrated Improvement Program. l Through discussions with licensee representatives, the inspector determined g that the Nuclear Safety Committee did not hold meetings throughout the .

I year to review and approve license amendment applications. Section 2.3 of

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p j the NRC-approved license application states that the Nuclear Safety Committee reviews and approves applications for SNM license renewals'and amendments affecting nuclear criticality safety prior to submittal to the NRC. According to members of the Committee,- the chairman of the committee may be reviewing and signing these documents for the committee. However, they had no way of knowing which or how many license amendment applications had been reviewed and submitted to the NRC.

The' inspector requested licensee representatives to supply documentation that such reviews and approvals were conducted. No appropriate documentation was provided to the inspector prior to the end of or subsequent to the inspection. Apparent failure of the Nuclear Safety Committee to review and approve SNM license amendments affecting nuclear criticality safety prior to submittal to the NRC was identified as an apparent violation of Section 2.3 of the facility license (70-1100/89-01-07).

5. Residual High Enriched Uranium

a. Contaminated Wooded Area The inspector discussed the status of the licensee's actions taken to assure that the wooded area was cleaned up. The licensee has completed cleanup of the area, has analyzed soil samples to assure that the soil contains less than 30 picocuries total uranium per gram of soil and has prepared the final survey report. That report was finalized and issued to the NRC on November 29, 1988. The NRC contractor, Oak Ridge Associated Universities, is expected to be at the CE Windsor Connecticut site to conduct a verification survey on March 28, 1989.

., b. Radioactive Material in Uncontrolled Area (Former Waste Pad)

On November 13, 1987, the inspector was notified that the licensee .

had discovered additional radioactively contaminated material I outside the restricted area. The material was found on the licensee's property south of the former Waste Pad located to the west of Building 2. NRC Region I was notified of this finding by l letter dated December 16, 1987. Samples of the contaminated material were analyzed by the licensee and were found to contain uranium in enrichments ranging from 3% to 88% of uranium-235. In accordance with License Condition 23, the licensee initiated actions to remove the contaminated material from the area. Accessible contaminated debris consisting of wall insulation, metal gratings, poly bottles, and pipes were removed, the area was posted as a controlled area and a snow fence personnel barrier was erected. The inspector requested 1 a date from the licensee during the exit meeting which would identify the date when cleanup actions will be completed. Licensee repre-sentatives stated that the requested date will be supplied to the NRC on or about March 31, 1989.

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6. Review of the Independent Task Force Report By letter dated January 31, 1989, the licensee provided the NRC with copies of the Executive Summary of the Final Report on the Independent T.zk Force. Review of the Nuclear Fuel Manufacturing Facility. This >

executive summary was provided in compliance with Commitment No. 4 of Confirmatory Action Letter No. 88-23 dated September 9, 1988. That Task Force Report is considered by the licensee to contain proprietary information and will be withheld from public disclosure in accordance with the provisions of 10 CFR 2.790. During this inspection, the inspector reviewed the content of the Task Force Report and was informed by licensee representatives that the recommendations of the Task Force would be incorporated into the Nuclear Fuel Integrated Improvement Program by ,

March 31, 1989 instead of of March 1, 1989, which would have been in accordance with their December 8, 1988 letter. '

7. Organization During meetings held in the Region I offices on January 17, 1989 and at the NRC headquarters offices on January 25, 1989, the licensee described the organizational changes which occurred as a result of the reassignment of the former Vice President, Nuclear Fuel Manufacturing.- Subsequent to the January 17, 1989 meeting and prior to the January 25, 1989 meeting, the licensee prepared and submitted a letter dated January 18, 1989 providing information to the NRC with regard to a revision to the Windsor Fuel Manufacturing facility organization in the form of a license amendment request,

8. Training

a. Review of Lesson Plans During Inspection No. 70-1100/88-08, the inspector reviewed the contents of three of the Interim General Employee Training Program lesson plans for Building 17/21-personnel. As a result of that review, detailed comments were provided on each lesson plan available.

During this inspection, the inspector verified that the comments previously made had been incorporated into the finalized .

lesson plans. i The inspector reviewed the new " Radiation Worker" lesson plan which was undergoing final review and approval. It appeared that all appropriate topics were adequately covered with the exception of company responsibilities, criticality safety and emergency planning.

Licensee representatives stated that the latter two topics, criticality safety and emergency planning were not covered in this lesson plan because they were covered in detail in the GET training. The topic of company responsibilities will be incorporated into the lesson plan.

11 The inspector also reviewed a draft copy of the new Radiation Worker Retraining lesson plan. All appropriate topics appeared to be adequately covered.

b. Training Program During discussions with licensee representatives, the inspector l determined that the licensea is developing a training program document which will describe the company's training policy and goals. l

c. Applicability of the Training Program The inspector determined through discussions with licensee representat ses that the training program as currently developed is applicable only to Building 17/21 based personnel. This program is not applicable to Building 5 personnel whose activities are covered by License No.

St!M-1067. Training for those personnel is provided through the training program developed for the site By-Product License No.

06-00217-06. The facility specific radiological and criticality safety criteria applicable to the Building 5 fuel handling operations are provided in this training program. However, the inspector determined through a review of training records that all Building 5 personnel who have access to Building 17 may not have received all of the applicable Building 17 training. This will be reexamined during a subsequent inspection (70-1100/89-01-08).

9. Procedure Development The inspector reviewed the status of the licensee's development of Radiation Protection Instructions (RPIs). This activity is described in the licensee's Nuclear Fuel Integrated Improvement Plan (NFIIP) that states, in part, "As the procedures are prepared, they will be approved and issued to the production and Health Physics Staffs. All of the procedures are scheduled for completion by December 31, 1988." At the time of this inspection, the following RPIs had been prepared, reviewed, approved, and authorized for use:

RPI 201 Whole Body Exposure RPI 202 Monitoring for Skin Exposure RPI 203 Extremity Monitoring RPI 204 Radiation Work Permits RPI 205 Dosimetry Program RPI 206 Radiological Control Areas RPI 207 Internal Exposure Control Bioassay Program RPI 208 Bioassay Program RPI 209 Monitoring for Radiation and Contamination RPI 210 Protective Clothing RPI 211 Ventilation System Monitoring RPI 212 Monitoring Visitor Exposure RPI 213 Transportation of Radioactive Material

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RPI 214- -Monitoring for Airborne Contamination RPI 215- Stop Work Order.

RPI 216 _ Respiratory Protection Program RPI 217 Criticality. Safety Program RPI 218 Processing Liquid Radioactive Waste RPI 219 Environmental Monitoring Program-RPI 220 Personnel Training Program RPI 221- Onsite Transfer of Radioactive Materials RIP 222 Instrument Calibration During this inspect' ion, the inspector determined that the RPIs had not l been issued to the production or health physics staffs. 'They had been t

prepared by licensee procedure writers, reviewed by the Health Physics Supervisor, approved by the Manager of Radiological & Industrial Safety, and authorized for use by the Plant Manager by December 22, 1988. However, .

all of.the RPIs were withheld from issuance to the health physics staff.  !

Upon questioning, licensee management stated that the RPI's were not implemented because they contained information, such as programmatic discussions, .not required by.the health physics technicians, which made them-unnecessarily comp 1icated and awkward to use. Licensee supervision plans to extract the specific operational instructions from the RPIs and issue these simplified procedures to the technicians for implementation.

The inspector expressed the concern that it appeared the health' physics staff was operating without any written procedures, and therefore, that-management control of,the overall program was questionable. Licensee  ;

management explained that the health physics staff we effectively i operating in accordance with written procedures contained in the Nuclear

' Licensing & Safety Manual (NLSM) issued in October 1987. Notwithstanding  !

the sta'tement by the licensee', the inspector reiterated the concern that i the existing program was being implemented without updated procedures; it was noted that the new RPIs, which more accurately reflected program ,

upgrades, could be initially issued to the health physics staff for 1 implementation and feedback, on an interim basis, to assure that the  !

actual' program functions were accurately described. .The licensee acknowledged the inspector's comments and stated that this approach to procedure implementation would be seriously considered. -i The inspector's concerns were brought to the attention of Region I f management during the inspection since implementation of these RPIs were required to complete corrective actions on previously identified enforcement items. As a result, a management meeting was scheduled and held subsequent to this inspection on February 16, 1989 for the purpose of resolving those concerns.

10. Exit Interview The inspector met with the licensee representatives (denoted in Paragraph _

1) at the conclusion of the inspection on February 3, 1989. The  !

inspector summarized the scope and findings of the inspection.