IR 05000729/2008015

Insp Rept 40-3392/85-03 on 850729-0815.No Noncompliance Noted.Major Areas Inspected:Organization,Internal Reviews & Audits,Procedure Control,Operations Review & Radiation Protection Program

ML20135A364
Person / Time
Site:	04003392, 05000729
Issue date:	08/23/1985
From:	France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135A351	List: IR 05000729/2008015 ML20135A348
References
40-3392-85-03, 40-3392-85-3, NUDOCS 8509100121
Download: ML20135A364 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 40-3392/85003(DRSS)

Docket No. 40-3392 License No. SUB-526

< Licensee: Allied Chemical Company P.O. Box 430 l Metropolis, IL 62960 l

Facility Name: Metropolis Works Inspection At: Metropolis, IL l Inspection Conducted: July 29 through August 2, August 7 and 15,1985 Inspector:

h f N :lt h / / W G. M. France, III 8/"/M Date h.V.$$$bdlgev Approved By: L. R. Greger, Chief 8"/>>/S[

Facilities Radiation Protection Date Section l

Inspection Summary Inspection on July 29 through August 2, August 7 and 15, 1985 (Report No. 40-3392/85003(DRSS))

Areas Inspected: Organization; internal reviews and audits; procedure control; operations review; radiation protection program including audits, procedures, instruments and equipment, exposure control, notifications, and reports; and transportation of radioactive waste including records and reports of solid wastes shipped to burial sites. The inspection involved 27 inspector-hours onsite by one NRC inspecto Results: The licensee was found in compliance of NRC requirements within the areas examine PDR ADOCK 04003392 C PDR L __ _ _. _ _ -___ _ _ _ _ _ _ _ _ _ - - - _ . . - _

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DETAILS 1. Persons Contacted A. Cipolla, Plant Manager B. Dunlevy, Plant Maintenance Engineer H. Davis, Plant Engineering Supervisor

• J. Honey, Operations Officer D. Lewis, Foreman, Fluorination Distillation C. Rice, Process Engineer

• H. Roberts, Assistant Health Physicist G. Yates, Supervisor-Accounting and Contract Administration

• R. Yates, Health Physicist The inspector also contacted other licensee employees including radiation protection technicians, plant operators, and members of the technical staf * Denotes those present at the exit meeting on August 2, 1985.

2. General This inspection, which began at 2:35 p.m. on July 29, 1985, was conducted to review the radiation protection program in accordance with the new license, including operator training, internal audits and reviews, procedure revisions, internal and external exposure controls, ALARA program, and radioactive waste managemen The inspector, accompanied by the Assistant Health Physicist, observed licensee activities during UFs production operations. During facilities tours, the inspector examined the current state of readiness of the UFs emergency kit . Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection, operations, and radwaste programs including changes in the organizational structure, procedure revising and card updating, and utilization of audit systems, Organization There have been no changes in the health physics organization since the previous inspection (40-3392/85002). Notwithstanding the present organization, the new license requires that personnel with appro-priate health physics training be present at the plant at all times when operations involving source material are being conducte The plant Health Physicist noted that at least one person will be added to the present organization in order to meet this license requiremen During the course of this inspection the inspector noted that compliance with this condition must be met on or before September 30, 1985. This license condition was discussed during the exit meetin L__ _ _

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b. Procedure Revising and Updating The inspector noted that the licensee requires HP approval of major process changes which could impact upon employee radiation exposur The HP approval is documented in the plant engineering files and is reflected on the procedure and or the radiation work permi The inspector reviewed the following procedures:

. Special Urine Sampling Procedure

. Policy and Procedure for Contamination Control

. Release of Articles for Unrestricted Use

. Radiological Safety Training

. Shipping Radioactive Materials

. Radiation Waste Management The licensee's health and safety procedures are performed by the plant Health Physicist and Assistant Health Physicist in accordance with plant management policy, c. Internal Reviews and Independent Audits The inspector verified that the Health Physicist had conducted a quarterly audit of plant operations in compliance with new license condition No. 16. The audit indicated that the UF8 release procedure is available for employee review and that the last drill simulating the release of UFs material was conducted in June 1985. The quarterly audit discussed safety considerations in selected locations of the plant, including the sampling plant, one preparation area, and the UF4 , green salt production area. The inspector noted that findings of the audit were documented for the Plant Manager's review in accordance with the license condition. The inspector verified that the licensee utilizes independent or corporate audits to report-deficiencies to management. The corporate audit disclosed that the radiation protection department had increased its efforts to separate radioactive waste from nonradioactive waste. The audit recommended preparation of an appropriation request for computeriza-tion of data storage and retrieval to meet NRC requirements for dose tracking. In addition, the corporate audit recommended professional staff additions to the health physics departmen The inspector concluded that management review of audit findings identified conditions that were scheduled for corrective actio No violations or deviations were identifie d. Safety Committee Meetings According to plant policy, a portion of the safety committee meetings is conducted by. radiation protection personnel. Subjects discussed since the last NRC inspection (85002/403392) included: Special Urine Procedure for Employees Performing Baghouse Maintenance, ALARA Concepts, NRC License, and Tank Entry HP Survey Data Car i

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. . Quality Assurance Program The inspector interviewed the Fluorination Distillation Supervisor and several Distillation Operators concerning operator experience in transferring.UFs to ten- and fourteen-ton cylinders. Each operator indicated that QA checks on cylinder transfer lines or pigtails, which include line pressurization with nitrogen, is adequate to identify faulty line connections. The Distillation Supervisor indicated that QA schedules were used to reduce exposure levels by replacing tra.nsfer lines quarterly, 'and by. purchasing standardized

. lots of teflon gaskets to seal each transfer line connectio Carbon dioxide (CO 2 ) is the primary combatant used to solidify any L escaping UFs or UO22F -

No violations or deviations were identifie . Radiation Protection The inspector reviewed the licensee's internal and external exposure control programs including the required records, reports and notifications, and the licensee's program for maintaining occupational exposures ALAR Internal Exposure Control The inspector reviewed the results of routine urinalyses performed on plant personnel since the last inspection (40-3392/85002).

About five workers were involved in a release of soluble UFs materia Although the uranium exposure was in excess of the action level of 30 mg u/1, the 40 MPC-hour intake limit for soluble uranium was not exceeded. Subsequent urinalysis of uranium levels were below the action level. The source of the UFs release was a loose flange bolted on the reflux line of the No. 4 low boiler condense External Exposure Control The-inspector reviewed the licensee's exposure control program including: adequacy of procedures used to evaluate, control, and minimize exposures; required records, reports, and notification TLD data for the first and second quarter 1985 operating' periods disclosed that individual doses were less than 500 mrem. The licensee has implemented a QA program to monitor doses at the nearest residence and at the Metropolis Illinois' airport._ Four TLD kits ar placed in service at each of the above locations. Each quarter one TLD kit is removed and submitted to an independent laboratory for readout. The most recent data collected showed no significant difference in exposure readings at the airport compared to exposure levels determined at the nearest residence. Each location showed

.less than 2 mres/ wee Calculated dose summary to the nearest

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resident for the 1984 operating year was about 11.9 mrem to the bone and 6.8 mrem to the lung. These values represent an increase of 45 and 67 percent respectively over the 1983 operating period, but are significantly less than exposure levels allowed by 40 CFR 19 No problems were noted, c. Surveys The inspector reviewed the licensee's program for control of radioactive materials and contamination, including schedules for periodic surveys, and effectiveness of survey methods in controlled area Contamination surveys of floor areas for direct and removable alpha contamination were performed weekly in controlled areas, monthly in uranium recovery locations, and quarterly in the administrative office Removable alpha contamination averaged less than 200 dpm/100 cm2 . The highest level of removable contamination found in the administrative areas was about 80 dpm/100 cm2 . The inspector concluded that surveys of floor areas for alpha contamination were made at the frequency required by procedure. In order to reduce the potential for trafficking of radioactive material to uncontrolled areas, the licensee plans to install four to six friskers in a designated access area. Personnel exiting the plant will be required to frisk at one of the access station d. Sealed Source Leak Tests The inspector reviewed records of leak tests made by the licensee on radioactive sealed sources. In compliance with license condition No. 18 the tests revealed that removable contamination was less than 0.005 pCi and that the tests were performed within the six month interva e. Calibration of Instruments Records of portable instrument calibrations indicated that portable health physics survey instruments were calibrated quarterly as require f. Air Samplina The inspector reviewed the licensee's program for determining exposure to personnel from airborne radioactivity during baghouse maintenanc Three workers were performing maintenance in the wet oxide baghouse enclosure. Their residence time in the baghouse ranged from six minutes to one hour. Based on the concentration of airborne radioactivity collected by a sampling device, the workers required a protection factor (PF) of about 840. The workers were appropriately donned in full face respirators with a PF of 2000; the exposures ranged from 0.04 to 0.42 MPC-hour k

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Another worker equipped with full face respirator, performing maintenance on the HF reductor used in processing UF 4 or green salt, received an exposure of 0.02 MPC-hours based on the airborne sample data. The licensee noted that engineering controls used to improve ventilation had enabled the radiation protection department to remove the drum dumper operation from respirator control. Periodic airborne monitoring is conducted to assure that airborne concentra-tions of radioactivity is maintained below levels that require respiratory contro The HP incident file disclosed that two workers assigned to perform maintenance inside of a baghouse enclosure were cautioned because of improper donning of respirators. In each case the employee began to use improper procedures by attempting to seal a mask over a cloth hood to protect the hair from entanglement in the rubber strap of the mask. The inspector noted that this was an example of proper instruction to workers prior to baghouse entires. No incidents of improper use of respiratory equipment have been identified since the licensee has adopted a new baghouse entry procedure, ALARA Concerns The inspector reviewed the licensee's program for maintaining occupational exposures ALARA, including worker awareness and involvement in the ALARA program, and engineering controls implemented to reduce exposure levels ALAR Modifications to the' drum dumper ventilation operation have succeeded in removing the operation from respirator control. Weekly urine samples were taken for a two-week period and results were low in uranium concentration. Concurrently, airborne radioactivity monitoring averaged about 18 percent of MPC. This value appears to agree with other plant averages. Seal adjustments were made on the calciner at various operating temperatures. The tightening of seals with hydraulic pressure prevents the escape of ore from the calciner and reduces the opportunity for inhalation of airborne radioactive particulate matte The inspector concluded that the licensee's radiation protection activities appear adequate to protect the health and safety of facility workers and members of the general publi No violations or deviations were identifie . Operations Review The inspector and the Assistant Health Physicist conducted several facility tours and observed the licensee's conduct of operations, fuel storage and handling, and safety limits in accordance with applicable regulatory guide k

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The inspector observed that an operator assigned to change-out a fluoride filter was attired in respiratory gear. The second floor of the process area had been placed on precautionary awareness as a potential respiratory condition. The inspector donned a mask, toured the location, and confirmed that all workers assigned in the area were properly attired in respiratory equipmen In response to inspector concerns about combating UFs releases, providing escape routes for involved workers, and mitigating the effects or a-release, the Plant Engineering Supervisor and the Plant Maintenance Engineer described the following:

The licensee is investigating several ways to facilitate the evacuation of a crane operator in the event a cylinder.of UFs ruptures accidentall According to procedure, the movement of ten- or fourteen-ton cylinders filled with UFs occur in the plants'. product loading station. The procedure may require as many as four movements of filled UFs cylinder The crane operator controls movement of UFs cylinders from a control booth located more than 12 feet above floor level. The transfer of a filled UFs cylinder from load station to weigh station may present an opportunity for the cylinder to drop and possibly rupture, thus making any evacuation maneuver by the crane operator very difficult. In order to mitigate this circumstance the licensee is currently investigating two areas for consideration:

. Installation of a catwalk that the crane operator could reach from his control boot . Ground level crane remote control, which would enable the operator to control the transfer of cylinders while remaining at ground leve The licensee noted that minor UFs releases are controlled by dispensing CO 2 to freeze UFs ac the defected locatio Carbon dioxide pressure is checked and recorded in the operator shift log at.least once each shif The inspector's observations concerning the state of readiness of UFs emergency kits are found in Section 2 (General).

During the review and observation of plant operations, the inspector interviewed the Process Environmental Engineer concerning the storage of radioactively contaminated oil. Waste oil is analyzed for uranium content; containers are inspected to meet storage criteria, and inspections are conducted to assure that filled UFs cylinders are not stored in the

vicinity of waste oil storag The inspector toured the waste oil storage location and confirmed that waste oil containers were stored outside of the production area away from UFs cylinders'and away from evacuation pathway No problems were identified during this tou No violations or deviations were identifie W_________________-_____________________-___--_-_______-_-__-______________

. . Emergency Preparedness The licensee does not presently maintain coordination of emergency planning with offsite agencies. However, the present system'of conducting drills and tests specified in the licensee's emergency plan is being reviewed and the current program may be expanded to include the role of offsite agencies such as the local hospital, fire department and other community organizations. The inspector discussed the importance of

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the state of readiness of all emergency equipment and the frequency of inspection. After examining several of the emergency kits, the inspector reminded the licensee to maintain up to date instructions in order to identify the cognizant on site energency coordinator and list the appropriate emergency telephone numbers. The inspector noted that l several cases used to store emergency kits appear to be deterioratin This matter was discussed with the licensee. The inspector confirmed that the UFe release procedure is available for employee review and the last release drill was conducted in June 198 No violations or deviations were identifie . Operator Training The inspector reviewed the radiation protection training provided to plant workers and discussed the program with the Assistant Health Physicis Since the last inspection, all plant workers involved in baghouse maintenance operations have participated in training sessions to review the changes to baghouse or tank entry procedures, 1984 exposure data, and the new NRC licens The inspector observed that new audio-visual health and safety lectures were being screened for use during safety council meetings. The lectures included hazardous material awarenes No violations or deviations were identifie . Waste Generator Requirements 10 CFR 20 and 61 The inspector reviewed waste generation activities to determine whether the licensee has established and is maintaining adequate management controlled procedures which reasonably assure compliance with the requirements of 10 CFR 20 and 10 CFR 61 applicable to low level radwaste form, waste characterization and classification, stabilization and shipment manifests and trackin The inspector confirmed that the licensee has formally incorporated existing waste procedures and memoranda (adapted for 10 CFR 61) into a single operating m ste management procedure and/or operating manua The manual has been established and distributed as management approved instructions to the appropriate line/ staff organizatio The manual consists of an organization chart for radwaste management, waste shipment checklists, driver information packet, and forms and examples from the

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Barnwell and Richland disposal sites. The manual also consists of standards for protection against radiation and licenses of source material and licensing requirements for land disposal of radwast No violations or deviations were identified, i Transportation The inspector reviewed transportation activities to determine whether the licensee is maintaining an adequate program to assure radiological safety in the receipt, packaging, and delivery of licensed radioactive material The inspector examined shipping / receipt data for five shipments of UFe cylinders and verified that the licensee inspected and surveyed each load. In addition, the inspector observed licensee transport operations for one shipment of low level solid radwast No violations or deviations were note . Exit Meeting The inspector met with licensee representatives (denoted in Section 1)

at the conclusion of the onsite inspection on August 2, 1985, and with Mr. A. J. Cipolla, Plant Manager by telephone on August 15, 1985. The inspector summarized the scope and findings of the inspection. In response to certain items discussed by the inspector, the licensee acknowledged the inspectors comment concerning the desirability to update instructional pamphlets for emergency kits, and increase the inspection frequency of emergency equipment and storage cases. The inspector also reminded the licensee of the September 30, 1985 require-ment to provide health physics coverage at the plant at all times when operations involving source material are being conducte During the course of the inspection and the exit meeting, the licensee did not identify any documents or inspection statements and reference to specific processes as proprietar W _ ___ _-___ -_ _ . _ _ _ _ _ _ _ _ - _ _ . _