ML20203J249

Safety Insp Rept 70-0025/86-03 on 860707-10.Violations Noted:Refresher Training in Radiation Safety Not Given at 2-yr Intervals & Records of Weekly Contamination Surveys Not Maintained

ML20203J249
Person / Time
Site:	07000025
Issue date:	07/31/1986
From:	Brock B, Pang J, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20203J235	List: ML20203J230 ML20203J244 ML20203J249
References
70-0025-86-03, 70-25-86-3, NUDOCS 8608050216
Download: ML20203J249 (12)

Text

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i U. S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-25/86-03 Docket No. 70-25 License No. SNM-21 Safeguards Group: I Licensee: Rockwell International Corporation Rocketdyne Division Atomics International 6633 Canoga Avenue Canoga Park, California 91304 Facility Name: Headquarters Site and Santa Susana Field Laboratory Inspection at: Headquarters Site and Santa Susana Field Laboratory Inspection Conducted: July 7-10, 1986 Inspectors: , , 7 8/ d B. L. Brock, Fuel Facilities Inspector D6te S'igned W

. F. Pang, Radiation Specialist 4/x I)dte digned Approved b . '7 8/

R. D. Thomas, Chief D/te signed Nuclear Materials Safety Section Summary:

Inspection on July 7-10, 1986 (Report No. 70-25/86-03)

Areas Inspected: A routine unannounced safety inspection was conducted of management organization; operator training and retraining; criticality safety; operations review / deactivation-decontamination; maintenance and surveillance; radiation protection; transportation / radioactive waste management /10 CFR Part 61; environmental protection; and emergency preparedness.

During this inspection, Inspection Procedures 88005, 88010, 88015, 88020/83890, 88025, 83822, 86740/88035/84850, 88045 and 88050 were covered.

Results: Three violations were identified in two of the twelve areas inspected (one in training and two in radiological safety).

8608050216 860731 PDR ADOCK 07000025 C PDR

DETAILS

1. Persons Contacted

• M. E. Remley, Director, Nuclear Safety and Licensing

• C. J. Rozas, Director, Health, Safety and Environment R. D. Barto, Director, Security

• R. J. Tuttle, Manager, Radiation and Nuclear Safety J. W. Carroll, Member Technical Staff D. S. Bost, Member Technical Staff I. N. Stein, M.D., Medical Director V. J. Schaubert, Manager, Nuclear Safety and. Licensing W. R. McCurnin, Manager, Nuclear Operations F. H. Badger, Health and Safety Engineer J. W. Rowles, Health and Safety Specialist Q. W. Koon, Lead Engineer, Calibration Quality Assurance L. E. Rodman, Senior Fire Protection Engineer (Emergency Coordinator)

J. A. Gump, Fire Protection Engineer R. M. Michlich, Senior Staff Engineer for Training D. Harrison, Staff Chemical Engineer E. L. Babcock, Assistant Manager, Rockwell International Hot Laboratory C. Nealy, Senior Scientist D. Parker, Shift Leader J. A. Martin, Engineer-in-Charge R. F. Hanabrey, Electronics Technician C. Hague, Director, Department of Radiology,_ Humana Hospital West Hills C. Bowers, Chief Nurse, Emergency Room, Humana Hospital West Hills

• Denotes those attending the exit meeting.

2. Management Organization and Controls Section 9 of NRC License SNM-21 incorporates Part 1 of the licensee's application and supplements dated October 29, and December. 17, 1982, March 2, 7, May 29 and June 12, 1984 as license conditions.

A. Organizational Structure Section 11.3 of the license application requires certain organizational divisions of responsibility to provide a check and balance system in the important areas of plant safety.

The inspectors' review of the licensee's new organizational structure found that the independence of safety organizations from operations was maintained. The licensee's retention of this separation of functions closes item (86-02-01).

B. Procedure Controls Section 11.3.4 of the license application requires that changes in established procedures must be authorized in advance by appropriate

~

management.

. 2 The Fermi decladding procedures were used on a high exposure fuel assembly to assess the extent of increased fuel rod distortion or other changes that might affect the grinding process. Additionally, processing this high exposure fuel facilitated assessing the adequacy of the change from lead shielding of the solidified grinder coolant to stainless steel shielding. Item (86-01-01) will remain opea pending completion of the evaluation of the adequacy of the high exposure waste package incorporating the stainless steel shielding.

No violations were identified.

3. Operator Training and Retraining License Condition 9 states, in part,.that licensed material is authorized for use in accordance with the statements, representations, and conditions contained in Part I of the licensee's application dated August 20, 1982. Section 11.6.4 of ESG-82-33, " Health and Safety Sections For Renewal Application of the Special Nuclear Materials license SNM-21, Docket 70-25, issued to Energy Systems Group of Rockwell International" submitted with the license states, in part, that refresher training in radiation safety be given at two year intervals.

A. A review of the licensee's training records and discussions held with Training, Radiation and Nuclear Safety, and Building 020 operations personnel established that a person who is a radiation worker in Building 020 had not received the refresher course in radiation safety at the stated two year intervals. The employee completed the basic radiation safety training on May 23, 1980 and the refresher training in radiation safety on March 7, 1984.

However the employee worked as a radiation worker during the periods from; June through July 1982, December 1982 through March 1983, October through December 1983, and June 21, 1986 to date. The above periods of employment are periods when radiation safety training had been completed more than two years earlier by the employee. This was identified as a v';1ation.

It was noted by the inspector that the employee who was not current in his radiation safety training had been issued a film badge without licensee verification that the person was currently qualified in radiation safety and that all of the requirements for a radiation worker had been fulfilled. It appears that since all radiation workers are required to be monitored, the verification that all of the basic requirements have been met should be made a part of the procedure for the issuance of a film badge.

B. Previous inspections had identified deficiencies in the licensee's training records; however, it appears that the corrective actions taken had been limited only to specific deficiencies. Based on the review of the training records and the discussions held with licensee representatives it appears that the licensee's system of training records requires considerable improvement and management attention. Item (85-01-02) will remain open for further review.

3-One violation was identified.

.4. Criticality Safety Section 2.7 of the license application requires that prior to initiating a project involving potential hazards, authorization must be obtained frou the appropriate Department Director and from designated Safety.

and/or Criticality Safeguards personnel in the Health, Safety and Radiation Services Department.

A. Nuclear Criticality Safety Analysis Section 4.1.3 of the license application requires the completion of a Nuclear Safety Analysis for the Fermi fuel decladding operation'.

The check ~ runs for the first two fuel assemblies worth of rods werc described in internal letters to the Criticality Safeguards Advisor and the Fuels Committee. .The Criticality Safeguards. Advisor's review of the letters prepared by the Manager, Rockwell International Hot Laboratory (RIHL) resulted in an additional requirement. The RIHL management was required to' review and confirm the ' documentation that less than 200 grams of U-235 had accumulated in the coolant before the. coolant would be transferred to the waste solidification area (Cell 2 decontamination room). The inspector's review found that the licensee met this requirement.

No violations were identified.

5. Operations Review Section 2.1 of the liden'se application requires the licensee to comply with all the requirements of the regulations,"to operate the facilities in a safe and efficient manner and within the requirements of all license conditions under which the activities are authorized.

A. Conduct of Operations License Condition 25 requires that the. licensee follow the general decommissioning plan submitted in the enclosures to the letter dated March 15, 1978.

(1) Building 055 Nuclear Materials Development Facility (NMDF)

(a) The inspectors noted during their visit to Building 055 that the equipment used in the NaK safing operation was being removed. The management decision to cut off the NaK bubbler connection piping in the inert atmosphere of Cell 1 resulted in increased control of this higher risk phase of the cafing operation. The small explosion that occurred in-cell during the removal of the fourth bubbler's inlet pipe on May 29, 1986 was fully contained.

In response to the explosion, the operations galley was evacuated. Reentry was made with SCBA and monitoring.

Swipe surveys and measurement of the two air filter from

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4-the continuous air monitors that were running in the area Eu during the explosion confirmed there was no release from the cell. The resultant pressure peak was a factor 'of one hundred below the. pressure the cell could readily handle.

The subsequent management review found-that operations-were. properly following procedures and should continue.

Other bubblers experienced some. burning even though the oxygen level was'kept at less than 3' percent. The low oxidation rate of burning was without incident. The final-phase 'of the NaK' bubbler processing was completed in '

' Building 055 as planned and witLout incident. The plutonium content of the empty dry NaK bubblers has been determined.

'The licensee plans-to fill the NaK bubblers with concrete even though the preliminary results indicate the.TRU limit (100nCi/g) has not been exceeded.

(b) The licensee inquired as to the need for removal of the KEPA filter-bank that filtered air in the building's high volume ventilation system (breathing air). This system involved an overhead inlet air distribution system with lateral floor level ~ return ducts fitted with prefilters followed by HEPA filters. These prefilters and first stage HEPA filters were surveyed by the licensee and found

-to be clean. The licensee's survey results for this HEPA -

filter bank will be reviewed when submitted to the NRC along with the results of the survey of the building and site. -The need te remove the filters will be based on the results of the independent survey of the HEPA filter bank scheduled'to'be made by the Oakridge Associated University

~(ORAU) for the NRC.

(2) Building 020 Rockwell International Hot Laboratory (RIHL)

(a) The By-Product. Utilization Shipping System (BUSS) evaluation in Cell 1 has been completed. The BUSS has been placed in the Cell 1 Decontamination Room. This change facilitated the use of Cell 1 for the first phase of the NaK bubbler safing procedure.

(b) The centerless grinders in Cell 2 have worked well and final pin diameters have been readily controlled. The waste sludge from the processing of high burnup Fermi rods is in process and the dose from packaging the waste (using stainless steel; shielding instead of lead shielding) is currently being: determined.' This item will remain open

, (86-01-03). -

(3) The laser in ' Cell'3 is ready for routine operation. The Fermi decladding operation is behind schedule because a revision of the Certificate of Compliance (C-0-C) for the cask to be used

'for these shipments is needed.

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.(4) The inspector verified that the leak detection water trough in-Cell 4 was covered as required by the Criticality Safety

-Specification. -The Fermi related activities for this cell are at a low level currently but are expected to pick up once the C-0-C is approved.

(5). The shielded alpha box in the' decontamination room of. Cell 4 is being cleaned. .The cleanup operation is being used to evaluate the performance of two stripping agents. Box entries are expected to be possible after sources of Pu02 dust are cleaned up. The airborne' contamination levels'in.the glove box during the entries will be reviewed during a subsequent; inspection (86-03-01).

No violations were identified.

6. Maintenance and Surveillance Testing Section 9 of NRC License SNM-21 incorporates Part 1 of the ' licensee's application and supplements dated October 29 and December 17, 1982, and March 2, 7, May 29 and June 12, 1984 as license conditions.

A. Air Flow Testing License Condition 18 requires that the licensee' check the direction of the air flow in the hot cell facility each month. When adverse air flows are detected, corrective action shall be taken and '

documented.

The inspector's review of.the~ records since the last inspection indicated that the checks had been conducted as required.

.The replacement of-the ventil'ation. system malfunctioning fan (excess vibration) and inoperable damper has bee'n completed. The plan to replace all of the = fans will be reviewed during the next inspection (86-03-02)., ,

B. Sewage Treatment Plant l

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The inspector reviewed the strip charts reflecting the performance of the repaired diversion valve control system on the sewage treatment plant effluent line. The review found the repairs were.

' successful because there were no inexplicable alarms. The electronics technician who calibrates the system also indicated that requests for service of the system now get a quick response. Item (86-02-02) is therefore closed. The temporary diversion pit had been subjected to a fire prevention controlled burn since the last inspection.~ It was sampled again during this inspection (see Section 9).

No violations were identified.

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7. Radiation Protection Protection against radiation hazards associated with licensed activities is required by 10 CFR Part 20.

A. Tour of Facilities

1. The NMDF (Building 055), RIHL (Building 020), Sewage Treatment Plant, the associated diversion basin, and the Respiratory Protection Maintenance and Training Laboratory (Radiation Safety) were visited by the inspector. It was noted that the licensee maintains two Respiratory Protection and Training Laboratories. One is operated by the Radiation and Nuclear Safety Group and the other is operated independently by the security group. It was brought to the attention of the licensee that from the standpoint of control and efficiency, the two laborttories should be combined under the Radiation and Nuclear Safety Group.

2. Item 86-01-02 which addressed the NaK bubbler safing operation was reviewed. The required apparatus had been assembled and the NaK bubbler safing operation had been completed. This item is closed.

B. External Exposure

1. The review of the cumulative exposure records for 1986, to July 7, 1986. disclosed no exposure in excess of regulatory limits.

Of the total of seventy-eight staff persons issued film badges during this period, forty-two persons received zero mrem. The highest cumulative exposure for 1986, to July 7, 1986, is 380 mrem. Of the thirty-six persons receiving expcsures during this period, twenty-five persons received less than 100 mrem.

2. The radiation exposures of persons who have lost or misplaced their film badges were investigated by the licensee and an estimated dose was assigned as required. However it was noted by the inspector that the licensee did not document the results of the investigation as required by 10 CFR 20.401(b). This was identified as a violation.

3. The inspector noted that the licensee exchanges film badges on a quarterly basis. The inspector recommended consideration be given to the use of thermoluminescent dosimeters for personnel monitoring on a quarterly basis because of the significant effects of humidity on film (75-95% relative humidity at 23-32 C will cause the recorded dose to decrease by 60% in a months time).

C. Internal Exposure The licensee utilizes a bioassay program from U. S. Testing Company of Richland, Washington. During the last inspection the bioassay

. 7 results for the first quarter were not complete and were left as an open item pending review (86-02-03). The inspector's review of the 1st quarter bioassay results completed during this inspection indicated no significant internal exposures. The highest result observed was 13% of the Maximum Permissible Body Burden (MPBB) equivalent for strontium-90. This closes item (86-02-03). The second quarter bioassay results were incomplete at the time of the inspection and will be left as open item (86-03-08).

D. Audits The first quarter radiation safety audit was completed by the licensee on. June 10, 1986. The results of the licensee's audit appeared to be acceptable.

E. Surveys The licensee's procedure, ESG 82-33, requires a weekly contamination survey of the RIHL (Building 020). It was noted that the results of the weekly surveys of the facility between May 19 and June 5, 1986 had not been documented as required by 10 CFR 20.401(b). This was identified as a violation.

Two violations were identified.

8. Transportation / Radioactive Waste Management /10 CFR Part 61 Annex "B" of the current license incorporates guidelines for release of equipment and~ facilities for unrestricted use. 10 CFR Part 20.301 to Part 20.401 regulates the disposal of waste. 10 CFR Part 61 requires that all radioactive waste prepared for disposal is classified in accordance with Section 61.55 and meets the waste characteristics requirements in Section 61.56.

10 CFR 20.311(d)(3) requires that licensees who transfer radioactive waste to a land disposal facility or licensed waste collector shall conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56.

10 CFR Part 71 regulates the packaging and transportation of radioactive material.

A. Waste Management

1. The licensee has recently developed an analytical technique for the determination of p1tionium in the NaK bubblers which will be disposed of as radioactive waste. Current waste criteria for disposal of plutonium at the DOE waste burial site is 100 nCi Pu/gm maximum. Although the NaK bubblers have 1/8 inch thick steel walls, the method can determine less than 100 nCi per gram using a germanium semiconductor to detect the 60 key from the americium-241 associated with the plutonium-239. The inspector diccussed the method with the Health and Safety Specialist who developed it. Based on the discussion, the

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. inspector concluded it appears that the licensee's method is reasonable and conservative ~.

2. The, licensee's progress for the packaging of the'Zr-U-FP grinding fines, item (86-01-01), was reviewed. The-licensee has completed and issued a' procedure titled " Fermi Fuel-Declading, Operating Procedure For GO NO 95594 No.

1530P000003." The licensee is now in the process of evaluating and selecting one of the Type B overpacks that can be used for packaging the grinding fines. =This evaluation was necessitated by the recent EPA ruling that: metallic lead is considered a hazardous material subject to additional controls prior to burial, and the licensee's change from lead to steel shielding.

Item (86-01-01) remains open.

B. Transportation and Part 61 Discussions with the Manager, Nuclear Safety and Licensing disclosed that no receipt or shipment of radioactive material under NRC jurisdiction had occurred'since the last inspection.

l No violations were identified.

9. Environmental Protection Title 10 of the -Code of Federal Regulations, Part 20.106 " Radioactivity in Effluents to Unrestricted Areas" requires that licensees control their operations to preclude releasing radioactive material in concentrations exceeding the limits specified :in= Appendix B, Table II of Part 20.

The inspectors sampled the mud at the waterline in the' sewage trestment plant's temporary' diversion pit during the previous inspection (70-25/86-02). The measurement of that' sample in the Region V van was delayed by equipment malfunctions. The temporary diversion pit was dry during this inspection therefore an, additional sample was taken in a low-area near the pit outlet! pipe. The dry pit had been subjected to a fire prevention controlled burn that denuded foilage that had been growing in the pit. The results from measurement of these samples are reported in-Table I.

The licensee's environmental monitoring report for 1985 received April 8, 1986, was reviewed by the inspector. Effluent streams contamination levels were less than NRC release limits (10 CFR Part 20 Appendix B).

No violations were identified.

10. Emergency Preparedness License Condition 24 requires the licensee to maintain and execute the response measures of the Radiological Contingency Plan submitted to the Commission on August 28, 1981, as revised on March 3, 1982.

Additionally, Appendix A to the Radiological Contingency Plan states that the Master Emergency Plan has been approved as part of the license.

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A. The fire extinguishers checked on a tour of the facilities had all received their monthly inspections. The housekeeping in all of the areas visited was good. The materials gathered in Building 055 were stored in an orderly manner reflecting appropriate concern for fire prevention.

B. The inspectors visited the Humana Hospital West Hills (HHWH) and interviewed the Director of the Department of Radiology and the Registered Nurse (RN) responsible for the Central Emergency Room.

The inspectors also toured the facility where contaminated injured persons would be treated. The RN and a staff Doctor had attended the REACT /S course given by the Oak Ridge Associated Universities (ORAU). The nurse indicated the course was very informative and provided materials with which she could train other staff nurses

.during 'In-Service' training. The last hospital drill with the licensee found they were able to achieve an appropriate readiness level when the licensee provided notification with a realistic lead time.

C. The licensee conducted the annual evacuation and training exercise for Building 020 on June 26, 1986. The drill was initiated with a radiation alarm which was received at the Protective Services Control Center. The drill included evacuation of Building 020, use of road blocks, response of the ambulance and a reentry vehicle, high radiation levels, use of reentry teams, and transport of an injured employee to the decontamination trailer. Representatives of the Ventura County Emergency Planning and the California State Department of Public Health observed the drill. A critique was held immediately after the drill. Problems were discussed and the responsibility for the correction of each was assigned. The status of the corrective actions will be reviewed during the next inspection (86-03-07).

No violations were identified.

11. Exit Meeting The results of the inspection were discussed with the licensee's staff identified in Section 1.

The topics discussed included:

The potential violations:

Failure to document some weekly surveys; Failure to document lost film badge investigations; Failure to maintain a training record of one individual; The status of previous open items:

Closed (86-01-02) Review of.NaK bubbler Pu residue measurements;

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e 10 (86-02-02) Review diversion pit control system alarm rate; (86-02-03) Review of 1906 1st quarter bioassay results;

l. (86-02-01) Review the independence of_ safety organizations from operations; Open (85-01-01) Review approval of Fermi procedures; (86-01-02) Training records accuracy; (86-01-03) Review Fermi vaste container dose control; (86-01-04) Sampling unlined diversion pit; New (86-03-01) Review airborne contamination levels during alpha glove box entries; (86-03-02) Review program of replacement of RIHL ventilation system fans; (86-03-03) Review status of planned consolidation of .the responsibility for the respiratory protection program; (86-03-04) Review status of the plans to color code dosimeters; (86-03-05) Review licensee's plans regarding use of TLD's or shortening the use period of film badges from quarterly to monthly; (86-03-06) Review licensee's plans for training ancillary workers; (86-03-07) Review status of corrective actions for problems identified during the June 26, 1986 drill at Building 020; (86-03-08) Review second, quarter (1986) bioassay results; TemporaryLdiversion pit drain valve lock; Status of Fermi shipments; Completion"of NaK bubbler safing operation; NaK bubbler measurements and the TRU waste limit.

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7 1g t TABLE'I' i

NRC Analysis of Temporary Diversion Pit Samples Taken at the Santa-Susana Field Laboratory (pCi/g (dry) i 2 sigma)

Sample No. U. Th Cs-137 NRC-1* 1.0 0.2 1.6 1 0.3 0.48 i 0.04 NRC-2** 1.0 1 0.2 1.6 1 0.3 2.3 i 0.1

• . Mud taken at water line of pit Soil taken from pit bottom near outlet pipe _

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