ML20247H639

Insp Rept 70-1257/89-02 on 890417-21.No Violations Noted. Major Areas Inspected:Followup Actions on Open Items,Mgt Organization,Training & Retraining,Criticality Safety, Operations Review & Radiation Protection

ML20247H639
Person / Time
Site:	Framatome ANP Richland
Issue date:	05/22/1989
From:	Brock B, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20247H633	List: ML20247H628 ML20247H639
References
70-1257-89-02, 70-1257-89-2, NUDOCS 8905310283
Download: ML20247H639 (12)

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y U. S. NUCLEAR REGULATORY COMMISSION REGION V

,p 5 RehortNo.7C-1257/89-02 ,

License.No.'SNM-1227 ,>

.. 7 Priority: O Category: III' Safeguards Group: I '

Lic'ensee: Advanced Nuclear. Fuels, Inc.

2101 Horn Rapids' Road Richland, Washington 99352

$ Facility Name: .Richland Facility i

Inspe': tion at: Richland, Washington Inspection Conducted: April 17-21, 1989 Inspector: - 2- f B. L. Brock, Fuel Facilities Inspector, Date Signed Approved by: ,

R. F. Fish, Chief, Emergency Preparedness f/FM D' ate Signed Section Summary:

Areas Inspected: A routine unannounced inspection'was conducted of follow-up actions on open items, management organization, training and retraining, criticality safety, operations review, and radiation protection.

During this inspection, Inspection Procedures 92701, 88095, 88010, 88015, 88020, and 83822 were covered.

Results: The licensee's response to the suggestion in the previous inspection report (70-1257/88-10) that additional attention was needed in the area of radiation protection was sufficiently responsive. The improved performance will continue to receive attention. 1 No violations were identified in the six areas inspected.

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1. Persons Contacted j l

A. Advanced Nut' ear Fuels

• R. G. Frain, n% nager, Richland Operations

• T. W. Patten, Munager, Plant Operations

• R. H. Purcell, Manager, Safety and Security

• H. L. Caudell, Manager, Process and Equipment Engineering l

• T. C. Probasco, Supervisor, Radiological and Industrial Safety

• C. W. Malody, Manager, Corporate Licensing

• J. E. Pieper, Specialist, Health Physics L. D. Gerrald, Criticality Safety Specialist S. R. Lockhaven, Specialist, Industrial Hygiene i J. Edgar, Staff Engineer, Safeguards

• E.-L. Foster, Radiological' Safety Specialist G. V. Mulligan, Supervisor, Shipping L. D. Weaver, Shi"t Supervisor Conversion L. Stephens, Shift Supervisor, Conversion E. A. Johnson, Security Guard K. DeWeber, Security Gnard

• Denotes those attending the exit interview.

2. Follow-up of Licensee Action on Open Items (92701)

A. The following items are considered to be closed.

86-03-02 This inspector identified item involved the need to appropriately follow-up and document the timely cleanup of contamination levels exceeding the limits in the Part 1, f License Conditions. The licensee reinstituted use of the

! Health Physics Technicians logbook for notifying each subsequent shift of items requiring follow-up. The need for diligence in-the use of the HPT logbook was emphasized to the HPTs. The inspectors' examination of the HPT logbook confirmed that it was in routine use. This item is therefore closed, 86-08-01 The ?icensee's Radiological; Safety Specialist is

. modifying the training records to include a completed Radiological Safety Training Record form, a copy of the test given for +he training, a distribution of the test '

results, the notes used in the training sessions, and the list of the persons attending the specific training courses- The inspector's review of the training records noted additionally the inclusion of the viewgraphs prepared from references, the course outline, and the document approving the proposed course subjects (signed by the Specialist, Health Physics, the Supervisor, Radiological and Industrial Safety, and the Specialist,

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Industrial. Safety). . Further, the Fuel Performance Group (including one of the managers) was included in the recently completed Radiation Safety Training course. This closes this item.

88-04-03 The licensee has implemented appropriate documentation listing all areas where contamination has temporarily been covered. The documentation also includes a chronology of such areas (dating back to 1976), backup surveys, and sketches of the areas. The licensee's response adequately ,

addresses this item. This item is considered closed.

88-10-03 The licensee revised the applicable procedure to require use of full face respiratory protection at half the airborne level previously required. Additionally, the user must turn in the respiratnr for cleaning after each shift rather than after a week of use as previously permitted, unless'a survey of the mask by an HPT at the end of the' shift found it free of contamination inside and out. The licensee's response is appropriate. This item is closed.

B. The following items remain open.

88-02-05 The licensee engaged a consultant to do the independent review of the Radiological Contingency Plan. .The consultant was provided reference documents for use in the review. The consultant pointed out some areas for additior.ai licensee attention. The inspector requested and received a copy of the consultants resume. It appeared that the consultant was a competent' individual with significant experience in the nuclear industry, however he did not appear to have directly applicable experience in the field of emergency preparedness. The lack of directly applicable experience is of sufficient importance to warrant leaving this item open for further review by a regional emergency preparedness inspector.

88-10-01 This item which centered around an apparent

• misinterpretation of the development of an exposure history as , required by 10 CFR 20.102, has apparently been appropriately responded to by the licensee. However, the different interpretation the licensee has of the requirement needs to be discussed in depth. For this reason this item remains open pending clarification and resolution of the differing points of view.

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88-10-02 This item centered on the licensee's missing the

- opportunity to reduce the exposure of personnel to levels which were as law as reasonably achievable (ALRA). The

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licensee _was following his procedure when he did not

- investigate uptakes unless the airborne concentrations exceeded 25% of 40 MPC hours. The NRC inspector noted

3 that the licensee did not investigate bioassay results I that were positive but were still less than the licensee's action level.in his applicable procedure. The licensee is taking action at levels less than committed to in his .

license and has indicated improved formalization and ,

documentation will be provided. This item remains open pending review of these changes.

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

(1) Organizational Structure (a) A week before this inspection'the licensee issued an organizational announcement which indicated.that the organizational structure was being changed. One change involved the corporate licensing manager who previously reported to the process and equipment engineering manager and now reports to the' safety, security and licensing i manager. It is noted that'the corporate licensing manager continues to be responsible for the health physics component <, the criticality safety component, and for ,

safeguards. Additionally, the radiological and industrial  !

safety supervisor who previously' reported to the safety

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and secur,ity operations manager now also reports to the safety, security and licensing manager. The radiological and industrial safety supervisor is still responsible for the plant criticality safety engineer and the health physics technicians,.

This organizational' change apparently results in a reduction of the checks and balances in the area of radiological and criticality safety audits which relate to plant safety. The auditors and the auditees in radiological and criticality safety previously reported to separate managers who reported to a'vice president. Under the new organizational ~ structure the auditor and the auditee report to the same manager one step below the vice president level. There is no evidence that the auditing of the operations group has been compromised.

The manager of safety and security operations retired and was replaced by the senior operations analyst whose rer, possibilities iricluded internal audits for the operations group. The manager of process and equipment engineering planned to retire on May 31, 1989.

The former manager of Richland Operations has been appointed vice president of production operations. The manager of employee relations will become the manager of Richland Operations when a replacement for this position has been found.

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(2) Safety Committee (a) The licensee. implemented'the annua 1 Criticality safety.

program appraisal that was added to ANF-30 (as recommended by the licensee's Criticality Safety Task Force). The licensee's in-depth six weeks appraisal of his criticality safety program was beneficial. The:results of.the

-appraisal (October 4 through November 15, 1988) identified twenty-six items needing attention. Responsibility for each item was assigned and the status of the-items was

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tracked by the safeguards staff engineer and reported.

monthly. Twenty-five of the items have been corrected.

They ranged from correcting document inconsistencies, removing ambiguities, providing improved mounting for criticality limit cards, to emphasizing engineered safety 4 features over administrative controls. Only one item y, ,

, remains to be completed. The remaining item involves s y

> assuring that all criticality safety analyses contain. .

'4 ' ' com'plete references. This-last item is scheduled for ..N.

], completion by June 30, 1989. ,

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(b) 'The. minutes of the Safety Committee, which met monthly as s

regbired, were reviewed by the NRC inspector. The minutes. ,;

,i s reflected the results of the internal. audits. The status ,

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=of the corrective action taken on identified items was

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also reported. The results of the radiological safety w s

T', program were also tracked as well as the status of open- ~

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' items identified by NRC inspectors. -

(3) Internal Review and Audit 1, C (a) In the previous inspection report, the licensee's ALARA report was described as appearing to fall short of an

.- in-depth evaluation of the. licensee's radiation safety l

program. The current inspection found that the licensee's reference materials, experiences, and knowledge.. relative-to the radiological and chemical hazards of uranium in the various forms processed was not provided to the NRC l'

inspector throuyh some miscommunication. Additionally, the licensee's progress in completing the, installation of special equipment in a newly constructed building designed to house the Fuel Performance Group (which receives tools l subject to hot particle contamination) was not discussed.

i. The equipment and controls in place in the building designed for this work appear to be appropriate. The communication breakdown precluded reaching a conclusion other than that expressed in this section of the previous report, specifically that the ALARA Committee's effort appeared to fall short of an indepth evaluation of the L radiation safety program. It appears now, however, that the ALARA Committee's report was reasonable.

Performance in this program area warrants continued attention with regard to the adequacy of the maintenance of an adequate program of l

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- checks:and balances-in'the, organizational structure changes.' - No.

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' B. Traininb/kek.raininh(88010) ju t! ,.<

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(1) - The ;11censee's'Radiolbgicalt Safety" Specialist (RSS) subinitted-

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the proposed Ra'diological _Safetypaining course lesson plan to' the. Specialist,5 Health Physics, and the! Supervisor, Radiological and Industrial Safety.for review and approval.

The approved lesson: planswas then used .to train (and retrain)~'

380 personi, in several trainingTsess"ns completed February 21',-

1989. The RSS similarly prepared;a 1esson plan covering-Respiratory Protection Training and after its- approval by the1 same persons plus the Industrial Hygiene Specialist, conducted the' training. The course was completed by 205 persons by February 22, 1989. 'The' records'for the courses included copies-

'of the concurrence of'the course' contents, the course outline,

~the view graphs used, copies from reference documents, the test

results, the dispersion of the test results, and.the list of.

attendees.

(2) The licensee was preparing for a meeting;at which hot particles would be discussed. A notice had been distributed that included as attachments the American Nuclear-Insurers Hot Particle Guidance and a portion of.a course that' addressed

' Automated Contamination Monitoring for Hot Particles. ._The distribution preceded a meeting scheduled for May 3, 1989 at which Hot Particles would be discussed.

The licensee's performance in this area is improved. The-effectiveness.of the changes will be' reviewed in subsequent.

' inspections. It appears.the licensee is capable of meeting its safety objectives. No violations were identified.

C. Criticality Safety (88015)

(1) Facility Changes and Modifications The licensee's relocation of the Gadolinium Scrap Recovery Process (GSRP), the Ash Leach Pilot Plant-(ALPP), and the Decontamination Facility (DF) in a separate building is planned for the year 1992.

(2) Nuclear Criticality Safety Analysis The central region of the Radioactive Materials Warehouse was reconfigure for storage of various process materials containing special. nuclear material-(SNM) based on a criticality safety analysis of the various storage arrays performed by the Criticality Safety Specialist. The criticality safety analysis was conservatively modeled for each storage array. The second party r,eview was provided by the Specialist, Health Phydics and attested to by signature. The Criticality Safety Specifications.were prepared by the

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Industrial Hygiene Specialist based on the limits and controls derived from the Criticality Safety Analysis.

(3) SNM Containers The licensee's modification of the CE-250 did not include the changes made,by Combustion Engineering. The licensee's modifications consisted of adding a thicker inner ring that

,, connected to an inner part to strerigthen the end and preclude the deformation and vermiculite leakage that resulted in test

-failure of the CE-250. The container with the licensee's modification, now designated the ANF-250, passed the tests.

The licensee provided answers to some additional questions 1

raised by NRC Headquarters after the test. The licensee plans

, to modify about'600 containers of this type, which he uses only

. 'for. overseas shipments, after the Certificate-of-Compliance is

. awarded. '

(4) Observations No poor' criticality safety practices were observed during the site tour.

,(5) Audits zThe licensee's criticality safety audits were conducted as required and were of sufficient scope and depth. The recent six week appraisal of the criticality safety management systems by a team of six persons, discussed in Section 3.A.(2)(a),

apparently contributed to the improved findings in the subsequent routine criticality monthly and bimonthly audits.

This appraisal had been added to ANF-30, Chapter 3 as an annual requirement.

Problems previously encountered in this area appeared to result

'from a failure to follow procedures. Thus this area will continue to receive close attention even though the recent internal appraisal resulted in program improvements.

Performance in this program area warrants further review. No violations were identified by the NRC inspector.

D. Operations Review (88020)

(1) Conduct of Operations The licensee's performance was observed in several operational l

areas around the site. The areas toured, not all of which were in operation, included:

a) UO2 Building (Vaporization Room, Conversion Area, Powder Preparation, Powder Storage, Pellet Pressing, Ceramic Area,. Pellet grinding, Pellet Storage, Powder Characterization Room, Rod Loading, and Bundle Assembly),

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b) Engineering Laboratory Operations Building (Gadolinium Scrap Recovery. Plant (GSRP), Ash Recovery Plant (ARP),

Decontamination Facility, and Process Development Laboratory),

c) Solid Waste Uranium Recovery (SWUR) Facility.

(Incinerator),

d) Neutron Absorber Facility (NAF),

e) Lagoons, f) Radioactive Materials Warehouse (RMW), (pellet box

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loading, moderated storage, and storage of used HEPA filters),

g) Zimmer Warehouse, (storage of zimmer rods to.be declad and storage of LUR and GSRP products),

h) Barrel Storage Yard (recoverable uranium contaminated waste),

1) Laundry Facility (temporarily moved to the Irradiated Tool and Equipment Building)

1) Ammonia Recovery Facility (ARF) k) Fuel Performance Building The operations observed appeare'd:to follow procedures. The licensee indicated that the liner of Lagoon 4 is scheduled to be replaced in June of 1989. The licensee stated that the planned installation of additional ion exchange columns had not yet occurred. The related laboratory work has achieved about a factor of ten reduction (1 PPM to 0.1 PPM) of the uranium in the plant effluent to the sewer. The licensee is continuing the effort to-further redu'ce the uranium concentration of the

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waste strea'm because of, reconcentration of the uranium at the local sewage treatment plant. 'The' uranium releases to the.

sewer are less than the'NRC limits in 10 CFR Part 20.

The leach pit' leak l(reported as required) has not been repaired

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as the pit is still full of' sand. Further cleanup of the sand is necessary before it can be released to unrestricted use.

l The licensee is also evaluating disposal of the sand to a licensed radioactive waste disposal site, Removal of t.he sand is essential for instituting repair of the leach pit. A new liner for the leach pit has already been. acquired and is stored onsite.

(2) Facility Modification Revicw and Examination l

(a) The licensee completed the building housing the Fuel Performance Group. The associated Irradiated Tool and

8 Equipment Room appeared to be in full operation. The room included a long cleaning glovebox that is used for cleaning the long tools (up to 19 feet long). The glovebox contained a lazy susan and several hose sprays fed from a contained water tank where the cleaning solution is mixed. Adjacent to the long glovebox is an ultrasonic cleaner-for small parts. North of the glovebox is an intermediate size parts cleaning tub that uses a rotating basket and counter directed sprays. A deep pit for parts assembly and testing was also at the north end of the room. Adjacent to the testing' pit was a 42 position shielded storage bin for parts up to 20 feet long. A 1000 gallon tank and evaporator is in the room for evaporating the accumulated cleaning liquids and retaininn the solids for packaging and shipment to a licensea radioactive waste dosposal site. The personnel change room and airlock is at the northwest end of the room and contains a Personnel Contamination Monitor (PCM) that includes 15 proportional counters for a total body survey. The southeast corner of the room will eventually house the machineshop. The southwest portion of the room contains the airlock (and step-off area) where the equipment is received or shipped. Survey instruments are available in each of the airlocks. Additionally, a shielded cave is available in which to check wipes in the high background (1000 CPM) in this: facility. A window on the west wall of the room facilitates observation of activities and equipment calibrations using electrical 4^ connectors that lead to the electronics shop on the cold -

, side of the window. Instructions at the personnel egress ..

A}; p. E, t i point require notification of a Health Physics Technician . 1 QT , in the event contamination is detected. The licensee has

.yy issued a new Personnel Contamination Report form, as part <

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fof the radiological safety record, which facilitates [

recording the necessary information about an event in t

[ whis.1 a hot particle is detected (see Section 3.E.(1)).

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(b) The licensee's laundry facility had been temporarily ,

relocated to the Irradiated Tools and Equipment building ,

that formerly housed the Fuel Performance Group.

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_ permanent laundry quarters are being expanded to

"( f accommodate two industrial size washing machines.

- Additionally, the laundry will change from an organic medium to an aqueous medium for laundering the protective clothing. The modifications to the building were well underway and the laundry will likely be back in its former location and in full operation by the next inspection.

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I (3) Housekeeping i (a) The yard south of the solvent storage building showed evidence of spilled oil, had an uncovered bucket of oil, and an uncovered bucket of what was identified as likely ethylene glycol. The solvent storage building contained a three quarters full drip tray under one of the oil barrels stored on the. horizontal racks. Oily rags were noted in the area. .

(b) The containers of sand used in testing the CE-250 shipping i containers were .in the Radioactive Materials Warehouse (RMW) without any indications.as to their contents.

Unlabe' led 55 gallon steel; drums and rectangular boxes f(apparently, standards for the'non-destructive assay system-used with the incinerator) stored in the south end of the RMW alsofraisedq 'uestions regarding their contents because

, =of the . lack of labeling.

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, t-(c) JThe ash leach room in the ELO basement also had an unlabeled container on the floorfthat apparently had been removed from/the feed hopper or was about to be added to

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it. If.the' container had recently been removed from the hopper then it would have been' prudent to put the labeled e lid back on the containeri correcting the label as necessary. If the container was~to be added to the hopper then.it would have been prudent not to leave the container open and unattended during a period when the system was not in operation.'

(d) The line 2 conversion area had an overhead leak in the scrubber exhaust duct that dripped a solution that-left a salt deposit on the duct and on the lid of the vaporization chest.

The licensee's housekeeping appeared to be in need of additional attention.

(4) Fuel Handling and Storage The fuel rod operations observed during the tour involved only Non-Destructive Assay (NDA) of loaded. fuel rods. The NDA system uses neutron interrogation and is set to detect the inclusion of pellets of the wrong enrichment.

l Performance in this program area in general appears to be adequate; however, housekeeping needs improvement. No violations of criticality controls were observed in the facilities visited.

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F. Radiation Protection (83822) l (1) Radiation Protection Procedures The licensee instituted the use of a new form to generate a record of pertinent information for use in rvaluating the dose-that an area of the skin received from a hot particle. The new form, Personnel Contamination Report form, was issued as part of.the radiological safety record and. facilitates recording the contamination level, location on the body (pictorially as well as by written description), the size of the area, instrumentation used, countrate before ar,d after decontamination, the circumstances involved, whether or not a hot particle was found, whether or not a bioassay is required,

< and the skin dose estimate.

The licensee" acknowledged that in addition to painting over contamination with a yellow coat of paint followed by a grey

, coat, another approach to identifying contamination was needed.

The different' approach involved the shredder in the portable trailer. A piece of contaminated plywood flooring in the trailer didn't decontaminate well, therefor the situation was identified by a permanent wall sign that read " CAUTION, The

, subfloor of this unit is contaminated and must be surveyed and unconditionally released before the unit is removed from plant site".

(2)' Instruments and Equipment The inspector examined portable radiation detection instrumentation and air sampling equipment during facility tours. All instruments were found to be in current calibration. The 31 fire extinguishers checked during the site tour all bore tags indicating the fire extinguishers were being inspected monthly as required.

(3) Exposure Controls To preclude unrecorded exposures of ANF employees who travel to reactor sites and fi.id they've forgotten their dosimeters, consideration is being given to. issuing extra thermoluminescent dosimeters (TLDs) to their team leaders for issuance as needed.

This will facilitate controlling exposures within nationally recognized limits as well as ALARA.

(4) ALARA The adequacy of the performance of the HP staff was called into question during the previous inspection. Improvements have ,

been noted in training and record keeping, however, this area 1 will continue to receive additional attention until it is clear that the workload allows for routine job site control of operations and maintenance activities.

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.. , i F SJ IT The 11censee's performance inlthis area still needs; improvement but seemed capable of meeting its safety objectives. No violations or-O deviations were identified however, additional attention rill be provided to this area. , -

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5. Exit Interview I At the conch:sion of the inspection the findings were discussed with the licensee's staff identified in Section~1. The topics discussed included:

The areas inspected. '

Open item status: .

i Closed items 4_

Open items (old) 3_

Open items-(new) 0 j Possible weakening of the checks and balances through the planned structural reorganization. l Increased attention being given to finding cause of positive  !

bioassay and in-vivo measurements.

The additional attention needed in housekeeping.

Expeditious correction of the items identified in the annual Criticality Safety program appraisal.

The need to identify root causes for problems encountered and identification of management's contribution to the problem, if any. ,

i Response to Notice of Violation  ;

(a) Noted protective clothing reuse practices.  ;

(b) Noted license amendhient regarding protective clothing laundry release limits.

Apparent progress in recovering the uranium from the waste drums.

Progress made in preparing to recover uranium from the HEPA filters.

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