ML20198G745
| ML20198G745 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 01/05/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198G729 | List: |
| References | |
| 70-0036-97-04, 70-36-97-4, NUDOCS 9801130108 | |
| Download: ML20198G745 (20) | |
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U.S. NUCLEAR REGULATORY COMMISSION RF.GION lil Docket No: 070-00036 l
License No: SNM 33 Report No: 070-00036/97004(DAMS)
Licensee: ABB Combustion Engineering Facility: Homatito Nuclear Fuel Manufacturing Facility Location: Combustion Engineering, Inc. 1 Hematite, MO 63047 >
Date: December 15,1997 Inspector, Courtney Blanchard, Fuel Cycle Inspector, Rlli Amy Bryce, Environmental Engineer, FCSS Approved by: Patrick L. Hiland, Chief Fuel Cycle Branch Division of Nuclear Materials Safety 9001130108 990105 PDR A00CK 07000036 C pm
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EXECUTIVE
SUMMARY
ABB Combustion Engineering ,
Nuclear Fuel Manufacturing Facility I Hematite, Mitsourt NRC Inspection Report 070 00036/97004(DNMS) 1 The inspectors reviewed and observed select license savities for the operation of processes, management organization, maintenance program, radiation protection program, and radiation waste management program.
Doerations inspection Procedure flP 88020)
- Random placement of full two gallon containers on six carts in the ert)la plant was identified as an inspection follow-up item (IFI). (Section 01.1) e Bulk recycle and storage room, laboratory, and ert>la plant operators were properly tralned on, and knowledgeable of, applicable processes and procedures.
However, the inspectors noted trip hazards on the second floor walkway of the oxide conversion plant, and cylinders blocking the exits in the UF, vaporization area. (Section 01.1)
- The licensee stopped monthly Burial Well No.14 sampling in October of 1990, based on operational conditions. The licensee's timeliness on reporting this issue to the NRC was poor (Section 01.2) e Equipment changes made the recycle and recovery room activities less hazardous, and operators worked according to wntten procedures (Sections 01.3) e The licensee appeared to have taken proactive steps to ensure a safe wet hydrogen fluoride absorber system design. (Section O2.1)
Manaaement Omanization and Controls Inspection Procedure (IP 88021) e Management structure changes appeared adequate to support plant operations.
(Section 06.1) hialntenance and Surveillance Activities Inspection Procedure (IP 88025)
- The licensee was implementing a new maintenance system. The maintenance mechanics were conducting preventive and corrective maintenance in a timely manner (Section M1.1)
- The inspectors identified that the lockout and tagout procedure did not specify the physical actions required to secure piping systems during maintenance activities and was identified as an inspection follow-up item. (Section M3.1) 2 l
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Radiation Protection inspection Procedure flP 83822) e' The licensee continued a program to maintain radiation exposures as low as reasonably l achievable (ALARA). The exposure results through the date of the inspection indicated that the ALARA program had resulted in a reduction of the collective dose for the facility. ;
(Section R1.1) l e The personal protective equipment specified in the special evaluation traveler procedure for the wood planing operstbn was adequate to protect the operator. (Section R2.3) .
Re@ed!ve Weste Manaaement insoection Procedure flP 88035) e Liquid emuent releases were within the license requirements. The operators of the new i
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precipitatiorVfiltration system were knowledgeable of the new process and procedures, (Section R2.1) j e Air effluent releases were monitored according to procedure, and were consistent with the licensee's requirements, (Section R2.2) e The mudbet identified the timeliness in responding to the 20.304 burial area Justde;g W an altomate schedule for decommissioning as an NRC unresolved item.
(Section R2.4) f 1
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Resort Details ;
t L Oserations l 4
01 Conduct of C;:2 ;
O l.1 Fa@hr Walk throunh and Discussions with Ooerators
- a. inspection Scope (68020) f i
The inspectors performed severs! facility walk throughs to observe the conduct of l operations, housekeeping, fuel storage and handling, and operational safety limits l throughout the production facility. l b.- Observation and Findinas :
The inspectors observed that the bulk recycle and storage room activities were performed !
per the requirements of operating system (08) pf ocedure No. 801.13,
- Filling Recycle Hoppers.* In discussions with the inspectors, the operator correcHy explained the criteria for notifying management if a hopper was over or under the 50 grams specified container weight. The operator explained how each code on the ' hopper traveler record
- identified the hopper's poird of odgin (red room or pellet plant), previous storage location: not gross weight, critical element analysis (iron, nickel, fluorides, and moisture content), percent i uranium, and grams of uranium 235 (U 235).
During a walkdown of the uranium hexafluoride (UF.) vaporization area and upper levels of the oxide conversion plant, the inspectors noted that the housekeeping in these areas needed some attention. The second level of the UF. oxide conversion plant had several {
tools in the walkway, in addition, the inspectors noted that UF, cylinders blocked the exit .
door in the UF. vaporization area. During subsequent walkdowns of these areas, the ,
inspectors noted that the licensee had promptly acted to relocate UF, cylinders in front of i the vaporization area exit door and removed the tools from the walkway in the UF. oxide
- conversion plant.
The inspectors observed the activities in the laboratory, which the licensee used for sample analyses and to evaluate product quality. Seven chemical technicians, a chemist, ,
and chemical suoervisor staffed the laboratory. A chemical technician desenbod the analyses conducted in the laboratory, which included moisture content and enrichment i determination.
The inspectors noted that posting of criticalitylimits and controls appeared consistent )
with section 4.1.5, " Posting of Limits and Control
- of the license and section 2.4,
' Criticality Safety Umits and Signs,* of nuclear industrial safety procedure (NIS) No. 201,
' Nuclear Safety Manual." However, the inspectors noted a concem with the placement of (
full two-gallon containers on slx caris in the orbia plant. One full two gallon container was ,
located at each end of the six carts. The inspectors checked the spacing between all the full two-gallon containers on the six carts. The full two-gallon containers met the one . .
spacing requirements as posted in the orbia plant. However, the inspectors noted that end to-end contact of the carts would have caused less than one foot spacing between e
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the full two-gallon containers. In discussions with the inspectors, the criticality manager stated that the licensea would paint targets on carts identifying the correct placement locations for the full two-gallon containers. The licensee would position the painted cart targets so that end to-end or side-to side contact of adjacent carts would not sacrifice the one. foot spacing requirement between full two-gallon containers. The censtraints imposed to ensure that spacing between full two gallon containers on carts will be tracked as an inspector follow up item (IFl 070-00036/97004-01),
- c. Conclusions Operations observed throughout the inspection conformed with plant practices and applicable written procedures. However, the inspectors concluded that the full two-gallon containers located on the erbia room carts could vlotate minimum spacing requirements if not correctly placed on the cart.
01.2 Qoerations of the 20.304 Burial Area Well Sampling
- a. [spection Scope (88020)
The inspectors reviewed the 20.304 burial area well sampling operation,
- b. Observation and Findinas On November 17,1997, the NRC project manager notified the Inspectors, that the licensee had stopped monitoring Burial Well No.14. In a telephone conversation with the inspectors on November 10,1997, the health physics specialist stated that the Missouri Department of Natural Resources (MDNR) collected water samples of the Burial Well No.14 on May 20,1997. The MDNR sampling results indicated elevated levels of organic compounds, and at Burial Well No.14 the levels were in excess of the Resource Conservation Recovery Act hazardous waste limits. As a result, all water pumped from Burial Well No.14, must be treated as a hazardous waste. The health physics specialist stated that using the standing sampling procedures, each sample at Burial Well No.14 would produce approximately 300 gallons of hazardous waste. The health physics specialist decided to stop sampling Burial Well No.14 as of October,1996. The inspectors ended the November 18,1997 telephone conversation, by stating that the inspectors would investigate the Burial Well No.14 sampling issue in greater detail during the December 15,1997, inspection of the licensee's facility.
The inspectors rendomly reviewed Burial Well No.14 sampling records for uranium content. The Burial Well No.14 sampling records indicated no statistically significant change to the uranium sampling results for the past seven years (licensee began consistent sampling in 1990). The inspectors reviewed an independent contractor's (certified by a state of Missouri registered geologist) site plan that indicated the ground water flowed from the plant, past Burial Well No.14, toward Burial Well No.16. In addition, the inspectors identified no increase in the uranium content of Burial Well No.16 over the past seven years. The licensee stated, beginning in January 199f' that the Burial Well No.14 sampling would be reestablished to a semiannual frequency until the new burial wells were used.
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The inspSctors reviewed with the health physics specialist the new burial well loc:.tions.
The health physics specialist explained that all of the existing burial area wells would be replaced with new monitoring wells as specified in the burial area work plan
- Proposed Hydrogeological Investigation and Groundwater / Surface Water Monitoring Work Plan for the Combustion Engineering, Hematite, Missouri Site.'
- c. Conclusions The inspectors concluded that section 5.2 of the license did allow the licensee to stop sampling Burial Well No.14 based on operating conditions. However, the inspectors determined there was a lack of communication with the NRC concoming discontinubg the Burial Well No.14 sampling.
01.3 Observation of Recycle and Recovery Room Activities
- a. Irisoection Scope (88020)
Selected documents and procedures related to the recycle and recovery room were reviewed and discussed with operations and other cognizant licensee personnel. Specific procedures reviewed were:
Operating System (OS) Procedure 830.00, *UO Precipitation," dated November 12, 1997.
Operating System (OS) Procedure 823.00,' Dissolution," dated June 19,1997.
Operating System (OS) Procedure 826.00, ' Filtration, Clarity Check and Blending," dated April 7,1997.
Operating System (OS) Procedure 818.00, *NO, Scrubber," dated December 28,1996.
In addition, the inspectors discussed recent equipment changes with the recycle and recovery room operators and project engineer,
- b. Observation and Findinos The inspectors observed work on the " wet side" of the recycle and recovery room where operators prepared material to feed into the dissolution column; mixed the acid and slurry; filtered the dissolved material; and transferred the recovered solution. When working with acid, prior to starting the dissolution column, the operator was wearing the appropriate gloves and TYVEC sleeves as required by OS 823.00. The operators were knowledgeable about the process, and familiar with the safety requirements of the procedures.
The inspectors noted that the licensee had made several recycle and recovery room piping changes in 1997, in discussions with the inspectors, the project engineer explained that the maintenance mech *nbs and welders had replaced approximately 10 percent of the process threaded p,,,og with welded stainless steel or glued schedule 80 plastic piping. The inspectors noted that the licensee had eliminated or simplified several piping runs to and from the dissolution column. In addition, the inspector 6
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observed that the licensee had eliminated most union pipe fittings and observed no system leaks. Past inspection findings noted system laaks at numerous union pipe fittings. The operators stated that the simplification of the piping runs made the dissolution process much easier to perform.
The inspectors noted that the licensee had removed several pieces of equipment in the recycle and recovery room. In discussions with the inspectors, the project engineer explained that the licensee had removed the leaking ammonia hydroxide and ammonla diuranate precipitation tanks. In adoition, the inspectors noted that the licensee had !
changed the method used to feed nitric acid to the dissolution column from a pressurized food system to a simple plastic pump. The operators explained and demonstrated to the inspectors how easy changing a nitric acid container was using the new plastic pump. In addition, the inspectors noted that the licensee moved the mill to the recycle and recovery 3 room. The inspectors observed that the equipment removed from the recycle and recovery room eliminated many system leaks.
The inspectors loamed of future changes to the recycle and recovery room. In discussion with the inspectors, the project engineer stated that the licensee planned to replace additional piping, eliminating the milling process, and to install a metering and control system on the precipitation trough.~ The process engineer stated that the elimination of the milling process would require additional focus on improving and increasing the capacity of the dissolution process,
- c. Conclusions The inspectors concluded that the licensee's recycle and recovery room changes have reduced the number of system leaks and simplified the process, which promoted a safer work atmosphere.
1 02 Operational Status of Facilities and Equipment 02.1 Review and Walkdown of Wet Hydronen Fluoride Absorber System
- a. Inspection Scope (88020)
The inspectors reviewed and discussed the new wet hydrogen fluoride absorber system (HFAS) with the process engineer, nuclear criticality specialist, and industrial specialist.
- b. Observation and Findinas :
In discussions with the inspectors, the process engineer stated that the operation of the wet hydrogen fluoride (HF) scrubber required little attention during normal operation until either the HF storage tanks became full or a system upset occurred. The process engineer stated that in either of these cases, alarms alerted operating personnel.
The project engineer discussed with the inspectors the wet scrubber process gas flow.
The HF vapors from the manufacturing process flowed toward the first stage of the -
scrubber < Three scrubbers in series remove the HF from the process exhaust gas. The wet scrubber was designed to remove 99.5 percent of the HF out of the exhaust gas before the exhaust gas was released out the top of a 30 foot exhaust stack.
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The inspedors discussed with a nuclear criticality specialist the nuclear enticality .
evaluation (E-316-001 RO 80) performed for the HFAS. The criticality evaluation results l specified that the controls for the HFAS were sufficient to maintain safe operation. In I addition, the evaluation specified that the HFAS was designed to remain subcritical under -
all credible postulated accident condetions. The inspectors noted several engineered >
t design features which incorporated nuclear criticality safety features, including safe '
geometry and spacing for the scrubbers, process tanks, and process pipes. .
In discussions with the inspectors, the industrial safety specialist explained and walked ;
down the HFAS safety systems. The inspectors observed the following physical HFAS !
l safety features: [
e The HFAS was contained in a conorote dyked foundation (large enough volume to contain all of the fluids in the HF tanks, pipes, and scrubhors).
e The vapor piping from the manufacturing building to the HFAS was elevated high enough to ensure that no plant equipment could inadvertently hit the pipe.
- The plastic (cross-linked polyethylene) HF holding tank was compatible with HF.
In addition, the inspectors noted that the licenses had contracted an independent design firm to evaluate the safety features of the HFAS. The licensee incorporated the independent design firm's recommendations into the final HFAS design.
The licensee notified the inspectors that the licensee would begin testing the HFAS in '
December and planned to begin using the HFAS in January 1998. The licensee stated that HF would not be shipped offsite until the NRC approved a license amendment. On December 5, the inspectors notified the NRC program manager of the licensee's plan to ,
start up and use the HFAS. l
- c. Conclusions The inspectors identified no safety issues with the HFAS. The licensee appeared to have taken proactive steps to ensure a safe HFAS system design. l 04 Operations Organlaation and Administration 06.1 Manaoement Ornanization and Controls
- a. Inspection Scope (88005)
- The inspectors reviewed management organizational changes.
- b. Observations and Findinos
- The regulatory affairs director explained the changes in the management structure. The inspectors identified that the management structure had changed from focused factory where directors that were responsible for particular production areas (for example, director of ceramic manufacturing and assembly operations), to functional positions (for example, diretor of projects and uranium operations). The regulatory affairs director 8
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explained that the past management structure required redundant positions between production areas. The regulatory affairs director explained that the current management structure focused on plant wide success and promoted more team work between production areas, in discussions with the inspectors, maintenance mechanics and operators explained that the past management structure, at times, caused conflict between different production area workers, but the current management structure promoted better communication and more team work between workers.
The inspectors determined that the responsibilities of the uranium operations director included the overall safe oper:.tlon of the facility, and the responsibilities of the regulatory afiairs director included criticality safety, radiological protection, and the accountability of all radioactive materials in the facility. The inspectors noted that the operation and regulatory affairs directors were staffed with several managers and specialist. Several of these managnrs explained to the inspectors their involvement in ensuring that the facility was operated in a safe manner,
- c. Conclusiens The inspectors determined that the licensee personnel changes did not negatively affect the safety of licensed activities and were consistent with license requirements, ll, Maintenance M1 Conduct of Maintenance M1.1 Preventive Maintenance Proaram
- a. Inspection Scope f88035)
The inspectors interviewed maintenance technicians, maintenance mechanics, and plant personnel regarding the preventive maintenance (PM) program.
- b. Observations and Findinos The licensee was developing a computerized database to manage maintenance requests. The maintenance technician described how the system will allow plant i operators to enter maintenanc9 requests directly into the computer database, and subsequently allow interested parties to check the work status on-line. The maintenance technician anticipated that the computerized system would automatically link equipment, parts, and procedures to each request. Furthermore, the maintenance technicians l planned to use this database to analyze pcst maintenance requests and to anticipate I future problems. The licensee was using commercially available software (MP2, l produced by Datastream) to develop the database.
The maintenance mechanic responsible for the work requests under the current card
( system indicated that approximately 90% of the requests came from operations. Plant I operators noted that the requests were completed quickly, and expressed sailsfaction with recent improvements to the PM system.
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The licensee was systerra'r"v implementing PM throughout the plant, where routine maintenance was scheduled and proceduralized. One example tha inspectors noted was . l that the maintenance mechanics were now pressing blower bearings once a month rather -
i ihan running until blower failure. The licensee had not had a blower failure in the last six months.
, c. Conclusions ;
The licensee continued to improve the PM tracking system, and the PM system has effectively decreased the number of equipment failures, and has contributed to l maintaining safe working conditions. ;,
M3 ' Maintenance Procedures and Documentation M3.1 Lockout and Tapout of Eaulomont i
- s. Inspection Scope (88025) ;
The inspectors reviewed and discussed the lockout and tagout (LOTO) associated with :'
maintenance activities. The inspectors also verifed that circuit breakers were secured open during the maintenance of electrical equipment, in addition, the inspectors l reviewed and discussed with maintenance technicians, maintenance mechanics, and ;
plant personnel the procedures and actions imposed to ensure that piping systems l charged with hazardous gases and liquids were safe to nervice during maintenance
- activities. Specific procedures reviewed were
- l e operating System Proceduro (OS) No. 4001.00, " Hot Work Operatens," dated January 27,19g7. .
o Health Physics (HP) Procedure No. 330.00, " Radiation Work Permit," dated August 13, igg 7.
t e Nuclear Industrial Safety Procedure (NIS) No. 21g, " Control of Hazardous Energy," ;
current issue as of inspection period.
- b. Observations and Findinas The inspectors noted that NIS No. 21g specified the process that the licensee personnel used to isolate equipment during squipment service. The industrial safety specialist explained that NIS No. 21g specified the requirements to isolate equipment from energy i sources capable of injuring or damaging property or personnel due to an u.wxpected start up or energization. The inspectors determined that NIS No. 21g did not effectively
. describe the actions reqa. A to tagout and secure hazardous piping systems, or clearty specify the fixture or equipment used to physically lockout an isolated hazardous piping - j systemi in addition, NIS No. 21g did not address double valve protection (when .'
available) when servicing a hazardous piping system or removing equipment for service.
The inspectors identified that on occasion some maintenance technicians, maintenance mechanics, and plant personnel, were not aware that NIS No. 21g addressed the required process for LOTO of hazardous piping systems, in discussions with the 10 t
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l inspectors, malMenance technicians, maintenance mechanics, and pleM personnel .
1 stater $ they thought that NIS No. 21g only addressed the LOTO for electrical equipment, j
The maintenance supervisor explained that NIS No. 21g did not always address
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hazardous energy sources but in the past only addressed the LOTO for electrical >
systems. The inspectors determined that the maintenance technicians, maintenance mechanics, and pleM personnel, in general, understood the hazards assoolated with the i pleM and demonstrated a questioning attitude concoming safety issues when performing ,
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maintenance activities.- l i
Through discussions with the inspectors, a maintenance medanic and a wolder demonstrated an adequate knowledge of the necessary permits required to initiate maintenance work. In addition, the welder understood the limitations of the bum permit, :
and the mechanic know the licensee conditions that required a radiological work permit l (RWP).
- c. Conclusions ,
The inspectors identified that NIS No. 21g did not effectively specify the actions required to secure hazardous piping during maintenance activities. The inspectors will track this Issue as an inspection follow-up item (IFl 070-00036/g7004-02) to review the licensee's actions to clarify requirements for securing hazardous piping systems during maintenance l activities.
MS Maintenance issues (92702)
- M8.1 (Closed ) IFl No. 070-00036/92004-01: Confirm storage unit foundation anchoring.
The inspectors visually inspeded the Kardex ut its and verified that both units were i
adequately secured to the concrete floor using anchor bolts.
M8.2 (Closed i IFl No. 070-00036/g3001-01: The licensee's transportation manifest did not .
distinguish exclusive use shipments and was confusing.
The inspectors reviewed the licensees exclusive use vehicle instructions to carriers (Form 53/1316), and a completed bill of lading (No. 0034). The inspectors confirmed that the vehicle instructions were clear and straight forward and noted that a carrier's signature was required to acknowledge exclusive use conditions.
M8.3 (Closed ) IFl No. 070-00036/93001-03: The licensee documentation of training was -
inadequate in distinguishing attendees by job category or by initial qualification or requalificstion training.
The inspectors reviewed documentation of an operator's training. The documentation lists the procedures performed in an operations area, which procedures an operator was qualified to perform, indicates when an operator must be retrained, and identifies the last time an operator performed the procedure. The d :umentation was maintained by a
. computer program, and the inspectors observed that the computer program restricts procedure use to trained operators.
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M8.4 (Closed ) IFl No. 070-00036/93001 04: Lack of an effective checklist to ensure that the high efficiency particulate air (HEPA) filters were adequately tested and visually inspected according to ASME standards.
The ins,pectors determined that procedure HP S00, " Ventilation System Filter Efficiency Measurement' effectively described the methods to test and document the efficiency of the HEPA .
f.i8.5 (Closed ) IFl No. 070-00036/93001-05: The U 235 accountability system in the labor 1 tory did not allow exact amounts of malarial to be qualified at any time.
The inspectors reviewed O.S. No. 509.3, *U 235 inventory Accountability Within the Laboratory," and found that the procedure allows the licensee to track the amount of U 235 in the laboratory at any given time.
14 8.6 (Closed i IFl No. 070-00036/93003-01: Management oversight of cylinder storage yard.
In discussions with the inspectors, the license management stated that plant inspections were conducted quarterly, and the results were documented and relayed to the responsible operators. The inspectors reviewed an April 1996 licensee memo that listed housekeeping issues associated with the cylinder storage yard. The inspectors observed that the storage yard was cleaned and organized.
1 M8.7 iClosed) IFl No. 070-00036/950q}-Et The licensee installed a new connection for the plant air supply line to the blender in the orbia oxide plant. The inspectors determined that plant air to orbia was not monitored for moisture before reaching the orbia room.
The inspectors determined that the air piping to the orbia blender, micronizer, and master blender micronizer was modified according to drawing D-5008 5024, dated December 23, 1995. The inspectors identified that the air supplied to the orbia blender, micronizer, and master blender micronizer was monitored and controlled for moisture, M8.8 (Closed) IFl No. 070-00036/96001-01: The Ilcensee inadvertently transferred a fragruent of a conversion reactor contaminated with uranium to a lab which was not authorized to receive special nuclear material.
i The insper: tors determined that the security guard procedure dated January 1996, required the appropriate manager, production support, or security oMicer to authorize equipment or material prior to removal from the site. In addition, the inspectors reviewed procedure 309, ' Survey of items for Release," and found that the procedure required that i all equipment and property removed from the site be monitored for removable and fixed contamination.
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i ML Mant Sumoort i . R1 Radiologleal Protection ,
R1.1 As low As Reasonably A&ievable flP 83822) l
- a. Inspection Scope i The inspedors reviewed the exposure results for th6 year, and compared them with the i licensee's As Low As Reasonably Achievable (Al. ARA) 90als for the year (1997). 3
- b. Osservations and Findinna The main exposure pathway at the plard was through the inhalation of airt>ome uranium, !
primarily Class Y uranium oxide powder or dust. The licensee monitored worker intakes !
by using lapel air samplers for all plant personnel and contractors who worked in the contamination control area. The licensee assigned doses to such workers by utilizing the ,
air sample results to calculate the Derived Air Concentration Hours (DAC-hours) for each worker on a shift basis. Conversion to a dose in millirem was done by multiplying the DAC-hours result by 2.5. The licensee then added the extemal dose resuhs, obtained from the worker's film badge, to these infomal results to obtain the total effective dose j equivalents for each worker.
Prior to 1996, the licensee had established an ALARA goal of 2.5 roentgen equivalent man (rom) for the maximum exposed worker, and in 1996 the licensee decreased the .
ALARA goal to 2.0 rom for the maximum exposed worker (maximum allowed for the year under NRC requirements is 5 rem). The maximum total effective dose equivalent (TEDE) for 1995 was 2.6 rom, and the average TEDE for the ten workers with the highest TEDEs 4 was 2.4 rom. For 1996, the maximum TEDE was 2.5 rom, and the average TEDE for the ten workers with the highest TEDEs was 2.2 rom. As of the date of the inspection, the maximum exposed worker had received a TEDE of 2.5 rom for 1997, and the average for 1 the ten workers with the highest TEDEs was projected to be 2.1 rem for 1997.
The licensee had reduced the collective TEDE for the facility over the past three years ao follows:
e For 1995 the TEDE was 163 rom.
The licensee projected nine workers would exceed the personal dose goal of 2.0 rom :
(TEDE) at the end of the year.
c, Conclusions Projected doses for 1997 indicated approximately nine workers could exceed the ALARA <
- goal. = The projected facility TEDE for 1997 was below the 1996 collective dose for the p facility. Collective TEDE results for the facility have declined over the peut three years.
The licensee planned to continue setting aggressive ALARA goals for 1996, V
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, R2 Environmental MonRoring R2.1 Liould Effluents
- a. Inspection Scope (88035)
The inspectors reviewed effluent sampling procedures for liquid effluent monitoring, discussed sampling results for 1997, and compared data to the licensee's effluerit monitoring reports. Additionally, the inspectors examined the filtration / precipitation system that the licensee began to operate in November 1997, reviewed the associated operational procedure, and discussed the process with operators. Specific procedures and licensee documents reviewed were:
Health Physics (HP) Procedure No. 319E, " Environmental Sampling Waster, Soll, Vegetation, and Alt,' dated November 8,1996.
Operating System Procedure (OS) No. 851.00,
- Filtrate Processing," dated November 11, 1997.
Effluent Monitoring Reports, dated February 26,1997, and August 19,1997.
- b. Observations and Findinos The inspectors noted that the liquid effluent sampling data was reported weekly, which corresponded to the sample collection frequency required by HP 319.00. The licensee did not take two samples in July of 1997 due to a plant shutdown. The health physicist demonstrated the calculations used to compile data for the semiannual effluent monitoring report, and a health physicist had not yet determined how the missing samples would be incorporated into the calculations for the next effluent monitoring report.
The inspectors noted that the licensee modified the sampling approach at the end of 1996. Historically, the licensee assumed that a sample from the liquid laundry effluents represented the liquid effluents released from the entire plant. At the end of 1996, the licensee began to base facility release data on a sample from the septic outfall. The septic outfall represented a combination of effluents from the w..itary sewer, drains and laundry. As a result, data from the second half of 1996 was not directly comparable to data from the first half of 1997. The inspectors noted that the release data was below the license requirements.
In November 1997 the licensee began to operate a precipitation / filtration system to treat aqueous liquid waste from the recycle operations. Operating System Procedure 851.00 required operators to clean the system after 350 g of U 235 were processed cumulatively rather than on a per batch basis. Operators used a running log to note the U-235 content of each bctch received, and the inspectors noted that operators were aware of the U-235 limits and understood the use of the log sheet. Precipitation required the addition of a reducing agent, precipitating agent, flocculating agent, and coagulant. An operator discussed the pn cess with the inspectors, noted the chemicallimits of the operating system, explained that the operators must determine the flocculating agent and coagulant additions on a batch by batch basis, and worked through an example to determine a flocculating agent addition. After precipitation and settling, the liquid was sampled and 14 l
l then transferred to a tanker truck located next to the building. At the time of the inspection, the licensee had not debmtined the disposition of the liquid waste. The operators transferred the sludge to a drum (-1.5 drums per treated batch), combined with ,
c'ay, and treated as a solid waste. !
- c. Conclusions The licensee's liquid effluents were within the license requirements. The licensee was i operating the new precipitation / filtration system, and operators were knowledgeable about the process and procedure. ;
R2.2 Air Effluents
- a. {cipaction Scope (88035)
The inspectors reviewed selected activities, records, and the procedure for sampling air effluents, in addition, the inspectors reviewed and discussed the monthly stack loss reports. Specific procedures and documents reviewed were:
Health Physics (HP) Procedure No. 301,
- Exhaust Stack Sampling," dated April 4,1997.
Inter-Office Memorandum,
- Summary of monthly stack loss report,* dated September 9, 1997.
Effluent Monitoring Reports, dated February 28,1997, and August 19,1997.
- b. Observations and Findinal During a facility walkdown the inspectors observed the locations of all 20 stacks,18 of which released to the atmosphere, and the associated stack blowers, sample stations, and HEPA filters. Discussion with the HP supervisor indicated which stack vented which area of the building. One h2PA pre filter had reached a differential pressure of approximately 5.9 inches of water, compared to the facility limit of 6 inches of water. The HP supervisor explained that the differential pressure on the HEPA filters was checked daily, and that the staff was aware of the maximum pressure differential of 6 inches of water. The inspectors noted that over a four day period, the differential pressure did not visibly increase.
Under normal operations, the licensee typically changed out the stack air samples weekly.
The inspectors observed a sample change out in the erbia area. The HP technician was knowledgeable and followed HP 301.
The licensee compiled stack sampling data in monthly reports that tracked the pCi released from each stack, the percent contribution of each stack to the total release, total release, and cumulative release for the quarter. The health physles supervisor summarized the calculations for reporting. The summarized data was consistent with the semiannual effluent repons, and below the license limits.
15
- c. Qgnelusions The air effluents were monitored according to procedure, and were consistent with the licensee's requirements.
R2.3 Postponement of 20.304 Disposal Area DecommisA onina l
- a. Inspection ScQne (88035)
The inspectors reviewed the licensee's decommissioning timeliness pertaining to the 20.304 burial area.
- b. Observations and Findinog in response to information Notice 96 97,
- Record Keeping, Decommissioning Notifications for Disposal of Radioactive Waste by Land Burial Authorized Under Former 10 CFR 20.304,20.302 and Current 20.2002,* the licensee issued a letter dated September 13,1996, to notify the NRC of a low-level radioactive waste disposal area at the Hematite facility, which was authorized under former 10 CFR Sections 20.304 and 20.302. The licensee requested in this September 13,1996, letter a delay of decommissionirig of the disposal area pursuant to 10 CFR 70.38(e) until total site decommissioning. Licensee managers st'ated that the licensee intended to make the request under 10 CFR 70.38(f), and the request for postponement under 10 CFR 70.38(e) was a clerical error. Licensee managers explained that a draft rule had been used to prepare the licensee letter, and the subpart reference had changed when the NRC made modifications for the final rule.
On November 25,1996, the NRC issued a letter that denied the licensee request to delay decommissioning because the licensee had not adequately established that the delay was in the public interest per the requirements 10 CFR 70.38(t).
By letter dated January 24,1997, the licensee requested additional time to assess the disposal area. However, the licensee did not specify a completion date for finishing the assessment of the burial area or provide any supporting information consistent with the standards of 10 CFR 70.38(f), other than a brief list of the type of information to be reviewed. In addition, the January 24,1997, letter from the licensee requested a meeting with the NRC staff to discuss the licensee's request for additional time to characterize the disposal area. This meeting was held on April 24,1997. As documented in the meeting summary dated May 16,1997, the NRC staff stated that further information on the disposal area was needed (consistent with 10 CFR 70.38(f)) to justify the licensee's assertion that a delay of decommissioning of the disposal area until total site decommissioning was not detrimental to the public health and safety and in the public interest.
By letter dated September 12,1997 (but postmarked September 17,1997), the licensee stated that based on the geological conditions, the burial area was suitable to leave in place and invited the NRC to participate in a joint meeting with the Missouri Department of Natural Resources in Jefferson City on September 26,1997. The licensee discussed during the September 26,1997, meetit.g the hydrogeologicalinvestigation and ground monitoring work plan, NRC staff attended the September 26,1997, meeting.
On October 21,1997, the licensee submitted the work plan discussed at the September 26,1997, meeting to the NRC addressing the 20.304 burial area. On 16
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-l I
1 L
November 21, igg 7, the NRC issued a letter that granted the licensee's work plan {
4 request pursuant to 10 CFR 70 38(f) and (g)(2).- (
The licensee did not submit an adequate justification to delay decommissioning or a
- decommissioning plan within 12 months (by September 12,19g7) of notifying the NRC of the burtal area decommissioning. The inspectors consider this issue an unresolved item (URI 070 00036/g7004-03) pending further review by the NRC staff. j
- c. Conclusions j The licensee developed an approved burial area work plan pursuant to 10 CFR 70.38(f) i and (g)(2). The buttal area work plan was not submitted within the 12 month timeliness ;
requirements of 10 CFR 70.38. The timelmess of burial area work plan issue was an NRC unresolved item. ,
i R3 Radiological Protection Procedures and Documentation R3.1 Wood Planinn Area. )
- a. Inspection Scope (g3822)
The licensee decontaminated' od planks by planing the surfaces. The inspectors discussed the use of personal protective equipment (PPE) with the operator, reviewed .
the special evaluation traveler (SET) for planing, and addressed the need for prompt !
removal of the shavings.
(
- b. Observations and Findinos During a facility walkdown the inspectors observed operation in the area used for decontaminating wood planks by plar.;ng. The licensee conducted wood planing in a ventnated room in the decontamination area of the plant; planing was not in operation due to a planer malfunction. The planing operator indicated that personal protective equipment during planing included a respirator, gloves, sleeves, apron, and hood. The SET for Planing Wood required a respirator and gloves.
The SET required, for radiological safety, that the area be vacuumed clean at the end of each shift. However, the inspectors observed a pile of wood shavings during walkdowns .
for two days. The wood pile was cleared after the inspectors reported the shavings to the licens>e.
- c. Conclusions The PPE gocified in the SET was adequate to prote et the operator during planing operations.
V. Manaoement Meetina
. The inspectors met with representatives and other staff throughout the inspection and on
. December 5, igg 7, for the exit meeting. The inspectors summarized the observations and findings of the inspection.
17 F
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The licensee did not identify any of the information discussed at the meetings as proprietary. j PARTIAL UST OF PERSONS CONTACTED 8 istasee Personnel Contacted Kaiser, Vice President t Sharkey, Director of Regulatory Affairs M. Eastbum, Nuclear Criticality Specialist R. Freeman, Nuclear Criticality Specialist H. Eskridge, Senior Consultant Regulatory Affairs l G. Page, Director, Ceramic Operations G. Jordan, Production Manager E. Salto, Health Physicist K Funke, Health Physics Supervisor i K Hayes, Industria! Safety Engineer J. Kraus, Maintenance S. Welch, Accountability Specialist D. Underwood, Engineering Manager
- Senior licensee official at exit meeting on December 12,1997.
INSPECTlON PROCEDURES USED ,
IP 88005: Management Organization and Cont. L's IP 88020: Criticality / Operations Review IP 88025: Maintenance / Surveillance IP 88035: Radioactive Waste Management IP 83822: Radiation Protection inspection Effort IP 92702: F ollow-up on Corrective Actions fro Violation and Deviations l
l l
l t
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ITEMS OPENED, CLOSED. AND DISCUSSED Opened 070-00036/97004-01 IFl maintaining spacing between full two gallon container on carts 070-00036/97004-02 IFl clarify requirements for securing a hazardous piping systems during maintenance activities 070-00036/97004-03 URI timeliness of burial work plan G2194 070-00036/92004 01 IFl confirm storage unit foundation bracing and anchoring 070-00036/9300101 IFl modify / distinguish manifest 070-00030/9300103 Ifl clarify designation of training for operators 070-00036/9300104 IFl develop checklist for HEPA filter testing 070-00036/9300105 IFl criticality safety laboratory operations 070-00036/93003 01 IFl management oversite of cylinder storage yard 070-00036/95003-01 IFl air to erbia oxide blender not monitored 070 00036/9600101 IFl transfer of contaminated items to unauthorized recipient Discussed None 19
e i
UST OF ACRONYMS ALARA As Low As Reasonably Achievable DAC hours Derived Air Concentration por Hour HF Hydrogen Fluoride HFAS Hydrogen Flouride Absorber System ,
HP Health Physics !
IFl - Inspection Follow up item l IP Inspection Procedure MDNR Missouri Department of Natural Rosaurces NIS Nuclear Industrial Safety Procedure NRC Nuclear Regulatory Commission OS Operating System Procedure PM Preventive Management .
PPE Personal Protective Equipment rem Roentgen Equivalent Man SET Special Evaluation Traveler TEDE Total Effective Dose Equivalent UF. Uranium hexafluoride VIO Violation LOTO Lockout and Tagout RWP Radiological Work Permit HEPA High Emelency Particulate Air URI Unresolved item 20