ML20236Q619

Insp Rept 70-1100/87-05 on 871005-09 & 19-23.Violations Noted.Major Areas Inspected:Radiological Controls Including, 870812 Pellet Shop Incident,Reviews of Allegations & Implementation of Radiation Protection Program

ML20236Q619
Person / Time
Site:	07001100
Issue date:	11/10/1987
From:	Gresickcioffi, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236Q611	List: ML20236Q609 ML20236Q619
References
70-1100-87-05, 70-1100-87-5, NUDOCS 8711200176
Download: ML20236Q619 (20)

Text

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U. S. NUCLEAR REGULATORY COMMISSION )

REGION I {

Report No. 70-1100/87-05 Docket No. 70-1100 i Category ULFF l

License No. SNM-1067_ Priority 1 l.

Licensee: Combustion Engineering, Incorporated P. O. Box 500 Windsor, Connecticut 06095 i I

Facility Name: Nuclear Fuel Manufacturing Inspection At: Windsoc, Connecticut l Inspection Conducted: October 5-9 and 19-23, 1987 Inspectors: ud-+ - / t [b- /0 d&te '

7 Jeph A. Gresick-Cioffi V RaMiation Specialist, FRPS ,

Approved by: -fr/ M ///b//pp'7 M. M. Shanbaky, Chie~fr 'date Facilities Radiation Protection Section, EP&RPB, DRSS Inspection Summary: Inspection on October 5-9 and 19-23, 1987 (Inspection Report No. 70-1100/87-05)

Areas Inspected: Routine, unannounced inspection of radiological controls.

Areas inspected included: review of August 12, 1987 Pellet Shop incident; reviews of allegations received; implementation of the Radiation Protection program; management organization and controls; training of personnel; radio-active waste management; transportation; and status of previously identified items.

Results: Ten apparent violations of NRC requirements were identified; as well as apparent breakdowns in your management controls system relative to your radiological safety program. These apparent violations are: failure to maintain Pellet Shop contamination levels below the license limits, as specified in SNM-1067, Section 3.2.8.1, (paragraph 5.2); failure to perform '

bicassay measurements to assess intake by workers, 10 CFR 20.103(a)(3),

8711200176 871117 0 DR ADOCK 0700  ;

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(paragraphs 3.0,4.1,5.4); failure to perform radiological surveys, 10 CFR 20.201(b),(paragraphs 4.1,4.6,5.2); failure to maintain a respiratory protection program,10 CFR 20.103(c), (paragraph 5.5); failure to take suitable measurements of concentrations of radioactive materials in air, 10 CFR 20.103(a)(3), (paragraph 5.4); failure to establish, maintain, and implement radiation protection procedures as required by SNM-1067, Section 2.7.2,3.1.1,4.1,(paragraphs 5.1,5.3,5.4,5.5,8.1); failure to use process or engineering controls to limit concentrations of radioactive materials in air, 10 CFR 20.103(b)(1), (paragraph 5.3), failure to instruct i workers,10CFR19.12,(paragraphs 4.1,5.5,7.1); failure to post notices to l workers, 10 CFR 19.11, (paragraph 7.1); failure to maintain records of surveys, 10 CFR 20.401(b), (paragraph 5.2).

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DETAILS q

=1 1.0 Persons Contacted 5 j

1.1 Licensee Personnel i

• P. McGill, Vice President, Nuclear Fuel, CE' Power Systems

• F. Stern, Vice President, Nuclear Quality Systems, CE .i

• A. Scherer, Director,' Nuclear Licensing, CE ] '

G. Chalder, Plant Manager, NFM - Windsor ,

D. Parks, Nuclear Materials Manager, NFM-CE Windsor .

• R. Sheeran, Manager, Nuclear Safety. Licensing, Accountability- l and Security, NFM-CE, Windsor ' .. 1 J. Vo11aro, Supervisor, Health and Safety, NFM-CE, Windsor- ]

K. Butenas, Accountability Specialist, NFM-CE, Windsor j

• S. Kucavich, Senior HP. Technician, NFM-CE, Windsor. j 1.2 NRC Personnel,

• M. Shanbaky, Chief, Facilities Radiation Protection'Section EP&RPB, DRSS, RI

• W. Pasciak, Chief, Effluents Radiation Protection Section, EP&RPB, DRSS, RI

• J. Roth, Project Engineer, ERPS, EP&RPB, DRSS, RI

• Denotes attendance at the exit interview on October'23, 1987 j Other licensee personnel were contacted or interviewed.

2.0 Purpose ,

The purpose of this routine inspection was to review the radiation protection program with respect to the following elements: j

- The August 12, 1987 Pellet Shop Incident 1 Allegations received during the inspection

- Implementation of the Radiation Protection Program including:

Procedures

- Surveys, Pcsting and Labeling Radiological Work Controls in the Pellet Shop Internal Exposure Controls .

Respiratory Protection Program Management Organization and Controls

- Training of Personnel  !

- Radioactive Waste Management ,

- Transportation

- Status of Previously Identified Items .

2 3.0 Review of August 12, 1987 Incident The licensee informed the NRC on August 17, 1987 of equipment breakdowns which occurred on August 12, 1987, in which a pellet press shuttlebox, which carries uranium oxide (U0 ) powder from the feed hopper to the " die platen" of the pellet press, br$ke. The licensee reported that 11 workers received measurable intakes. The two workers working nearest to the failed equipment, received 98 MPC-hours and 79 MPC-hours, and nine additional workers working in the Pellet Shop on that shift were assigned 21 MPC-hours to 36 MPC-hours, based upon their proximity to the failed equipment. All recorded intakes were based upon the licensee's air sampling equipment, which is a fixed air sampler arrangement, located near ventilated hood openings or process equipment that is most expected to generate airborne radioactive material. The sharp increase in airborne radioactivity resulting in the above intakes was not recognized until the next shift because the air samples were counted one shift later to allow for decay of radon. This practice was inadequate to immediately determine the existence of sharp increases in high airborne radioactivity. The inspector discussed the short-term and long-term corrective actions with licensee representatives. The following short-term corrective actions were noted:

The licensee stated that the failed equipment was shut down and immediately repaired.

The two individuals assigned the greatest intakes were whole body-counted at a nearby nuclear power plant whole body counting facility. The results of this in vivo analysis was that no detectable radioactive material was observed. Additionally, urinalysis was performed on all individuals from the two shifts.

Urinalysis results indicated that there was no excretion of uranium in urine.

However, the inspector determined that the whole body counter used to assess the two worker intakes was insensitive to the potential presence of uranium levels in the workers' lungs as a result of the incident. The whole body counter used was calibrated and set up as a mixed fission product whole body counter. The software library did not include uranium-235. Furthermore, the type of material in the facility is non-transportable or insoluble uranium oxide powder.

In particulate form, a large fraction of non-transportable uranium oxide powder translocated to the gastrointestinal (GI) tract.

Therefore most of the U0 2 will be excreted in feces. The very small fraction retained in the pulmonary region is slowly removed by gradual dissolution into the extracellular fluids with minimal excretion in the urine. Therefore, urinalysis was not the correct bioassay methodology to assess worker intakes; fecal analyses should have been performed. The licensee had no fecal analysis program in place to assess intakes, as specified in WASH-1251 and Regulatory Guide 8.11.

3 Failure to properly assess intakes of radioactive materials of radiation workers is an apparent violation of 10 CFR 20.103(a)(3),

which states in part, "the licensee shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals." (87-05-01)

The health physics staff purchased a constant, alarming alpha air monitor to be installed near the pellet presses to give immediate warning of elevated activity in the air. At the time of the inspection, the air monitor was on-site. However, the monitor had not been calibrated, nor set up. Further, no procedures had been written for its use or calibration. This area will be reviewed in future inspections.

Through discussions with various supervisors and workers, the inspector identified that in previous years, the licensee shut down plant operations in the Pellet Shop for routine plant decontamination and equipment maintenance / repairs for two weeks in the summer months. This year, the plant continued to operate on one shift each day. Therefore, no plant decontamination or equipment maintenance were performed. The Plant Manager told the inspector that no preventive maintenance program existed for the equipment in the Pellet Shop.

The inspector discussed the long-term corrective actions with the Plant Manager to prevent a re-occurrence of this event. The Plant Manager indicated that the only long-term action planned was the acquisition of a newer pellet press. The inspector discussed the ALARA design considerations for the purchased equipment. The Plant Manager stated that the press was being purchased from a manufacturer that supplies the nuclear incustry, so that he assumed engineered safety features were designed into the equipment to minimize personnel exposures.

4.0 Allegations Received During the Inspection During the conduct of the inspection, the inspector was approached by several plant workers who had alleged safety concerns at the fuel facility. Allegations were received on October 8 and October 21, 1987.

4.1. Allegation of Lack of Respiratory Protection Equipment Alleger No. I alleged that on September 26, 1987, a worker was assigned to perform a powder preparation enrichment clean-up on pellet press no. 1. He asked his supervisor if a respirator was needed. The supervisor said no respirator was required for this job, only a breathing zone air sampler (BZA). The supervisor also instructed the worker to keep his head out of the hood while performing the clean-up operation.

4 The worker's BZA results indicated that he received 4.78 MPC-days (approximately 38 MPC-hours) of uranium. He was suspended from further work in the Pellet Shop for 1 week (in accordance with license requirements) and urinalysis was performed on the individual. The urinalysis results indicated that no uranium was present in the urine. The alleger requested additional medical evaluations and his exposure records. He also requested an evaluation of his intake. No additional evaluation other than urinalysis was performed.

Inspector Review The inspector reviewed the Radiation Work Permit (RWP) under which the worker worked, interviewed the production supervisor, and the health physics technicians on shift at the time of the incident, and observed the work area involved. The inspector identified the following:

The RWP did not describe the scope of work nor was an evaluation performed of the work activity relative to the radiological conditions. The Health Physics technicians on E

duty at the time of the incident were unfamiliar with the work to be performed. Neither full HP coverage nor intermittent coverage was specified on this RWP.

The worker used a BZA, given to him by Health Physics when he told them he was breaking the hood containment. The Health Physics technicians stated that the individual never told them that he was breaking the hood containment.

The inspector stated that because an evaluation of the radiation hazards incident to the use and presence of radioactive material was not performed, this is an apparent violation of 10 CFR 10.201(b)(2), which states that "each licensee shall make or cause to be made such surveys as are reasonable under the circumstances, to evaluate the extent of radiation hazards that may be present." (87-05-02)

The RWP specified respirator use "when required by H.P." The worker did not ask the Health Physics staff about the use of the respirator because the shop practice is to ask the produc-tion supervisor who was assumed to be familiar with the re-quirements of the job. Moreover, the worker was not briefed on the hazards associated with the work to be performed prior to commencement of the work, nor was he provided adequate instruction to minimize his exposure to the radioactive material present. The inspector stated this was an apparent violation of 10 CFR 19.12, which states, in part, that "all individuals working in or frequenting any portion of a restricted area shall be instructed in precautions or procedures to minimize exposure..." (87-05-03)

5 The licensee requested three urine samples from the worker to perform bioassay measurements to assess the intake as a result of the BZA filter analysis. The results of the urinalysis showed that no uranium was present in the urine samples.

However, due to the presence of insoluble or non-transportable uranium, the bioassays required to assess the intake are whole body counting, and fecal analysis (see paragraph 3.0 for additional details). These analyses were not performed. The inspector stated that this was another example of the apparent violation of 10 CFR 20.103(a)(3) which requires licensees to "use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for. timely detection and assessment of individual intakes of radioactivity by exposed individuals." (See also paragraphs 3.0 and 5.4). (87-05-01) 4.2 Allegation of Smoking in a Radiologically Controlled forea Alleger No. 1 also alleged that an individual smokes cigarettes at the " knock-down" hood in a radiologically controlled area, in violation of plant procedures.

Inspector Review The inspector toured the FA-4 mezzanine and " knock-down" hood area to observe any signs of cigarette smoking, and interviewed several Pellet Shop workers to ascertain the validity of this allegation.

The inspector could not substantiate the allegation by observation or interviews with workers.

4.3 Allegation of Improper Use of Air Sampling Equipment Alleger No. I also alleged that when workers are assigned the enrichment clean-up job, they usually shut off their BZA, so that a high air sample is not identified and they are not subsequently suspended from Pellet Shop work.

Inspector Review The inspector reviewed data of general air samples and BZA samples, and interviewed workers, Health Physics technicians, and supervisors, to ascertain the validity of this allegation. The inspector could not substantiate this allegation through the review conducted.

4.4 Allegation of Lack of Decontamination Allegers No.2 and 3 alleged there are not enough personnel performing decontamination to keep shop levels of contamination down.

6 Inspector Review High contamination levels and associated radiological control problems were identified by the inspector prior to receipt of this allegation. Paragraph 5.2 identifies an. apparent violation as a result of alpha contamination levels in excess of license conditiong. The license requires areas with (greater than 10,000 dpm/100cmj)tobecleanedimmediately,andareas(greaterthan5000 dpm/100 cm to be cleaned within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4.5 Allegation of Lack of Preventive-Maintenance Program Allegers No. 2 and 3 alleged there is no preventive maintenance program, that the equipment is faulty, and this-adds to the contamination.

Inspector Review This concern was identified by the inspector during the first week of the inspection (October 5-9,1987), prior to receipt of this allegation (Additional details appear in paragraphs 3.0 and 5.2).

4.6 Allegation of Inoperable Friskers Allegers No. 2 and 3 alleged that the friskers in the bathroom alarm, with Health Physics resetting the alarm set-point higher without investigating the cause of the alarm.

Inspector Review The inspector interviewed Health Physics technicians to ascertain the validity of the allegation. The. Health Physics technicians provided no information to substantiate or refute this allegation.

The inspector checked the frisker in the ladies locker room. The count-rate meter attached to the probe was set on slow response. ,

When the inspector set the count-rate meter on fast response, the '

needle of the meter jumped erratically and alarmed at approximately 80 counts per minute. This indicated that the equipment in use to monitor individuals for contamination may have been inoperable. No 1 determination was made by the licensee to verify the operability of  !

the equipment. j On October 23, 1987, at the end of a Pellet Shop tour by NRC personnel, a frisker in the men's locker room was identified by the )

NRC as being faulty. The frisker was erratically responding and ,

indicating false count rates, Further, the frisker had been t(gged i and identified as being inoperable the day before. However,  !

personnel were still using the frisker to check for contamination prior to exiting the radiologically controlled area. 1herefore, workers were leaving the contaminated areas without knowing whether

7 they were clean or contaminated. The inspector stated that this was anotherexampleofanapparentviolationof10CFR20.201(b),which states that "each licensee shall make or cause to be made such surveys as are reasonable under the circumstances to evaluate the extent of the radiation hazards that may be present." (See additional details in paragraphs 4.1 and 5.2) (87-05-02) 4.7 Allecation of Industrial Safety Concerns on Ventilation A11egers No. 2 and 3 alleged that on the non-radiologically controlled side of the fuel manufacturing facility, there are health and safety concerns regarding the presence of zirconium and inconel dust in areas that have no ventilation.

Inspector Review The inspector discussed this concern with the Supervisor, Health and Safety and a production supervisor. The inspector was told that a ventilation system was ordered and on-site. The system would be installed as soon as possible. The inspector was further told that installation of the system was being done on October 22, 1987.

However, on October 23, 1987, the inspector was informed by a union representative that the installation had not been performed or completed. The inspector observed, through a preliminary examination of the ventilation system, that although some ducting was there, major portions of the system were not installed, including the fans and motors.

4.8 Allegation of Industrial Safety Concerns on Vapors Allegers No. 2 and 3 alleged that an individual working on the Millicron machine (non-radiological side of the manufacturing facility), which uses a cutting oil, Power Cut No. 360 (Hexylene glycol) is experiencing headaches and bloody noses.

Inspector Review The inspector discussed this with the Supervisor, Health and Safety.

The Supervisor stated that this was only recently brought to management's attention. The individual was sent to the company's physician for a medical evaluation.

Since the subject of these last two allegations concerns non-radiological aspects of the licensee's operation, the Operational Safety and Health Administration (OSHA) Region I office will be notified of the events and conditions believed to have industrial safety significance.

8 4.9 Allegation of Improper Calculation of Radioactive Material Concentrations in Air Alleger No. 4 alleged that a worker was concerned about his BZA result from the day before. He stated that the worker had the BZA on for only a total of 15 minutes, but his exposure was calculated based on having the BZA on for one hour. The worker was concerned that his exposure was not properly documented.

Inspector Review The inspector reviewed this concern by interviewing the HP staff and reviewing records. The HP technician who recorded the BZA results did not have the correct sampling time. However, the sample result showed no activity or, the filter paper. The HP technician assumed a one hour BZA sample pump time and recorded that result. When the error was identified by another HP technician, the correct time was recorded on the worker's exposure record. Although the calculational error did not result in any degradation in the licensee's radiological control actions, the lack of attention to technical details by the HP technician was discussed with licensee management. The licensee stated that this was a mistake that was immediately corrected, and did not reflect on the technical capability of the HP technician that made the mistake.

5.0 Implementation of the Radiation Protection Program The implementation of the Radiation Protection program was reviewed with respect to criteria and regulatory requirements contained in:

10 CFR 20, " Standards for Protection Against Radiation," and SNM-1067, Part 1, " License Conditions," Section 3.0, and Part II,

" Safety Demonstration", Sections 4.0 and 5.0.

5.1 Radiation Protection Procedures NRC Inspection Report No. 70-1100/87-01, conducted on April 13-16, 1987, identified a violation of the Special Nuclear Materials license which requires that " procedures necessary to implement the radiation protection program" be maintained. In the licensee's letter of response to the notice of violation, dated June 17, 1987, the licensee stated that "all procedures required for the Health Physics operation including those noted by the inspector...will be completed by August 31, 1987. All completed procedures will be approved by tne Manager, NLSA&S, and incorporated into the ' Nuclear Licensing and Safety Manual.' This manual will be released to the Central Document Control Center (CDC)."

Although certain procedures identified in Inspection Report No.

70-1100/87-01 had been written, the inspector noted that certain other essential radiation protection procedures had not been

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identified nor written (See paragraphs 5.3, 5.4, 5.5, and 8.1 for specific examples). Moreover, the Nuclear Licensing and Safety manual was not approved by the Manager, NLSA&S nor submitted to the Central Document Control (CDC) system. This is an apparent repeat violation of SNM license No. 1067, Sections 2.7.2, 3.1.1, and 4.1 .

which requires that radiation protection procedures, necessary to implement the radiation protection program, will be established, I maintained, and followed. (87-05-04) j 5.2 Surveys, Posting and Labeling i The licensee's program for radiological surveys, posting and  ;

labeling was reviewed with respect to criteria contained in Section  !

5.0 of this report by observations made during tours of the Pellet Shop, review of licensee documentation, and discussions with ,

personnel. l l \

Within the scope of this review, the following was identified: )

i During tours of the Pellet Shop, the inspector observed that l uranium oxide powder was present on surfaces in the shop. l Through discussions with the Health Physics staff and review of l

licensee surveys,2 th (e alpha contamination j

10 000 dpm/100 2

cm in one location as high aslevels exceeded 160,000 dpm/100 cm ) and were not being immediately cleaned up, as required by the license. Health Physics technicians stated that they identified substantial contamination in the Pellet Shop for some time, but were unable to effect the decontamination as required by the license. In September, the Health Physics l staff began documenting the results of the contamination in memos (dated September 15, 1987 and September 21, 1987) to the l Manager, Nuclear Licensing, Safety Accountability and Security (NLSA&S) for his action. However, the inspector noted that no action was taken by licensee management to immediately decontaminate the areas as required by the license.

Failuretoimmedigtelyclean-upcontaminationinexcessof 10,000 dpm/100 cm is an apparent violation of Special Nuclear Material License No.1067, Section 3.2.8.1. (87-05-05)

On October 23, 1987, during the exit interview, the inspector was informed by the Manager, NLSA&S that additional decontamination people had been hired to decontaminate the Pellet Shop to within license limits.

The inspector noted that there were two water fountains in the Pellet Shop. The inspector requested smears of both fountains.

Licenseeanalysisofthesesmearsindicatedghatonewater fountainwascontaminatedto1300dpm/100cm,angtheother water fountain was contaminated to 300 dpm/100 cm . No caution

10 signs concerning the presence of radiactive materials on the water fountains were found. The inspector noted that plant personnel were drinking from these water fountains.

The inspector reviewed survey records for the water fountains.

Shop surveys were conducted weekly on these two water fountains and indicated that no contamination was ever detected on the  ;

water fountains. The inspector discussed the survey technique for these fountains and was told that the survey was taken only after the water fountains were decontaminated. The inspector stated that this was another example of the. apparent violation-of 10 CFR 20.201(b) which requires the licensee to "make such surveys as are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present."

(See also paragraphs 4.1 and 4.6) (87-05-02)

Health Physics technicians told the inspector that they had identified that the water fountains were contaminated, by taking smear surveys in addition to the weekly surveys. The technicians requested, as a result of these measurements, that the water fountains be removed from the Pellet Shop because of the contamination found, and because eating, drinking, and smoking are prohibited in radiologically controlled areas. The inspector requested to review the records of these -

measurements, and was told by the technicians that records of these measurements were never maintained. The inspector stated that failure to maintain records of measurements of contamination on the water fountains, to assess the radiological hazards, was an apparent violation of 10 CFR 20.401(b) which requires each licensee to' maintain records showing the results of surveys as required by 10 CFR 20.201(b).

(87-05-10)

The inspector discussed the contamination of the water fountains with licensee management, who stated that they did not recognize the hazards associated with drinking from contaminated water fountains. On October 6, 1987, and after the identification of contamination on the water fountains, the licensee removed both water fountains from the Pellet Shop.

5.3 Radiological Work Controls in the Pellet Shop The inspector reviewed the licensee's radiological work controls and the radiation work permit (RWP) program with respect to the criteria contained in Section 5.0 of this report by observations made during tours of the Pellet Shop, review of selected RWPs, and discussions with personnel.

The inspector found the following:

- The inspector found that RWPs are sometimes written without Health Physics Technicians fully understanding the scope of the 1

11 i work to be performed. Further, unless a respirator is required I

by the RWP, no continual or intermittent HP coverage is provided. This practice appears to have contributed to the incident on September 26, 1987, when a worker received an intake (by BZA result) of approximately 38 MPC-hours during an enrichment clean-up (see paragraph 4.1 for details). Through interviews conducted with HP staff, the inspector noted that the Health Physics technicians who were present on shift at the time of the incident were unfamiliar with the scope of the job.

Consequently, HP technicians did not periodically check the worker to see what job he was performing, and failed to provide respiratory protection when the hood containment was breached.

Paragraph 4.1 describes the apparent violation of 10 CFR 20.201(b), as a result of this deficiency.

RWPs are used to cover non-routine and maintenance tasks in the Pellet Shop. However, there was no adequate procedure in place to describe the preparation of the RWP and to include the appropriate protective equipment and radiological survey information. This is another example of a failure to establish procedures as required by Special Nuclear Materials license 1067, sections 2.7.2, 3.1.1, and 4.1 (see paragraph 5.1)

(87-05-04).

Although Special Nuclear Materials License 1067, Section 2.2.2 states that the Supervisor, Health and Safety has the authority to halt any operation in which the limits of the license are exceeded, the Supervisor, Health and Safety was not cognizant that he had such authority. At the time of the inspection, the Supervisor, Health and Safety was still unaware of his authority under the license.

5.4 Internal Exposure Controls The licensee's program for air sampling, for providing designed engineered safety features to limit concentrations of airborne radioactive materials in air, and for bioassay measurements to assess intakes of radioactive materials by workers, was reviewed with respect to criteria contained in Section 5.0 of this report by observations made during tours of the licensee's facility; review of procedures, surveys, and bioassay analyses; and discussions with personnel.

Within the scope of this review, the following was identified:

During tours of the Pellet Shop, the inspector noted that U0 powder was present on floor and equipment surfaces. Further,2 many equipment hoses which fed uranium oxide powder from feed stations to the pellet presses, and other hoses associated with pellet manufacture were taped in many places to fix cracks in the hoses. The inspector observed loose powder behind the

12 pellet press hoods, where powder was leaking from faulty equipment. The inspector brought this condition to the attention of the Manager, NLSA&S. He stated that there was negative pressure applied to the rear of the pellet press to ensure that the powder would not be blown out into the shop.

However, the inspector later found that the areas behind the pellet presses were not under negative pressure. When this was brought to the attention of the Manager of NLSA&S he stated that needed design changes would be made to confine the powder to the area in back of the pellet presses.

On October 21, 1987, the inspector observed U02 powder spraying out of the back of pellet press no.1 onto the powder feed hose. The inspector asked the operator how long this condition existed. The operator stated that this condition had persisted since Monday (October 19,1987). The press continued to be operated until a Health Physics technician came and requested the press shut down, shortly after the inspector interviewed the operator.

The inspector noted, on October 23, 1987, that the feed hoses for pellet press numbers 1 and 2 had been replaced with new hoses.

On October 23, 1987, 007 powder was observed spraying out of a feed hose on the mezzanine above pellet press number 3. The hose had been taped in several places. The leak occurred in the location of a repair.

The three above cited examples are an apparent violation of 10 CFR 10.10M b)(1) which states that "the licensee shall, as a precautionary measure, use process or other engineering controls to the extent practicable, to limit concentrations of radioactive materials in air." (87-05-06)

The fixed air sampler data was reviewed, in which the licensee performs additional measurements, such as multiple head / multiple height air samples, tethering individuals to the fixed air sample pumps, and high volume air samples to verify representative breathing zone air samples. The inspector found good agreement between the fixed air sample pumps and the other air sample methods. However, the inspector noted that the fixed air sampling system was set up under ideal conditions, which included shop contamination levels at less than 10,000 dpm per 100 square centimeters, and the potential for increased concentrations of airborne radioactivity only at or closest to the location of the fixed air sample head. During this inspection, the inspector noted that the potential for increased concentrations of airborne radioactivity had spread to many unmonitored areas of the Pellet Shop. Furthermore, due to a lack of equipment maintenance, and extensive equipment

13 breakdown, the potential for localized airborne radioactivity had substantially increased. However, the licensee did not augment their routine air sampling system with additional portable air samplers for appropriate detection and evaluation of concentrations of airborne radioactivity in all work areas.

This is an apparent violation of 10 CFR 20.103 (a)(1), which states that, "the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas."

(87-05-07).

During the exit interview on October 23, 1987, the licensee stated that additional breathing zone air sample pumps would be used to ensure that adequate air sampling was perfonned to detect and evaluate airborne radioactivity.

The licensee's procedure for bioassay of individuals was reviewed, as well as the results of bioassays performed on workers who sustained intakes on August 12, 1987, and September 26,1987 (see paragraphs 3.0 and 4.1). The licensee had no procedures in place for handling non-routine incidents, in which an evaluation of intake would be required. Further, the procedures for routine (annual) bioassay, did not include information on how to assess bioassay results to verify that the air sampling program was adequate. The inspector stated that failure to have a bioassay procedure to detect and assess individual intakes was another example of an apparent violation of SNM License No.1067, Sections 2.7.2, 3.1.1, and 4.1 (see also paragraph 5.1) (87-05-04)

The inspector reviewed the licensee's routine bioassay program.

The licensee uses a vendor who brings a whole body lung counter trailer and whole body counter operator to the site annually.

This equipment is specifically set up and calibrated for uranium lung counting. In addition the licensee performs routine urinalysis on all workers who enter the Pellet Shop on an annual basis. However, as stated in paragraph 3.0, this method of in vitro bioassay is inappropriate for the type of radioactive material present at this facility, and will provide limited or no bioassay information to the Health Physics staff for evaluating and assessing intakes of radioactivity by exposed individuals. The inspector stated that failure to establish an appropriate bicassay program was an apparent violation of 10 CFR 20.103 (a)(3), which states, in part that, licensees "shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements, as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals." (see also paragraphs 3.0, 4.1) (87-05-01)

14 5.5 Respiratory Protection Program The licensee's respiratory protection program was reviewed with respect to criteria contained in Section 5.0 of this report, by -.

observations of respirator use in the Pellet Shop, review of licensee's procedures, and discussions with workers and Health Physics technicians.

Within the scope of this review, the following was identified.

The inspector, through a review of licensee procedures of respiratory protection, found that essential program elements were missing, including the following:

(1) There is no policy statement issued from a high level of management in the use of respirators. (Regulatory Guide 8.15, Section C.1).

(2) There was no clearly designated individual responsible for the ..

implementation of the program (Regulatory Guide 8.15, Section .;

C.4.b).

(3) Personnel administering respiratory protection had not received any training on respiratory protection theory, use, selection, fittin C.4.b)g, or maintenance (Regulatory Guide 8.15, Section (4) Workers in the Pellet Shop received no training in the use of respiratory protection (Regulatory Guide 8.15, Section C.4.b).

(5) Individuals were not fit-tested to ensure that there was an adequate seal to take credit for protection factors. The inspector also observed one individual with long sideburns using a respirator. The long sideburns were located in the sealing surface area of the face-to-respirator interface (Regulatory Guide 8.15, Section C.4.c).

(6) The only bioassay procedure used to verify respirator seal integrity was a nasal smear. This bioassay methodology assumes that all respirator users breathe through their noses, and does not consider individuals who breathe through their mouths (Regulatory Guide 8.15, Section C.4.f).

(7) A written statement on relief from respirator use is issued to each respirator user and signed by each user. This document was used by the licensee as a respirator issuance record.

However, no specific training was given in this area (Regulatory Guide 8.15, Section C.3).

(8) There is no written policy on the limitation of time on respirator use (Regulatory Guide 8.15 Section C.1).

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l The licensee, in a letter dated February 18, 1985,' informed the j' NRC Regional Administrator, Region 1, that they would use respiratory protection in accordance with 10 CFR 20 and would apply protection factors when respiratory protective equipment was used.

The inspector stated that based upon the status of the current respiratory protection program, the licensee was in apparent violation of 10 CFR 20.103 (c), which requires that when respiratory protective equipment is used to limit the inhalation of airborne radioactive material the licensee may make allowances for this use  !

of respiratory protective equipment in' estimating exposures of individuals to this material provided that" the essential elements of a respiratory protection program specified in 10 CFR 20.103(c) are maintained and implemented. (87-05-08)

- The inspector, through interviews conducted with Pellet Shop workers, found-that the workers receive no training on '

respiratory protection use, donning, and removal. Further, no training was given on the written statement, which advises a respirator user that relief from a respirator is permitted in the event of physical or psychological stress or equipment malfunction, which they sign upon being issued a respirator.

Failure to instruct workers in the use of respiratory protective equipment is another example of an apparent violation of 10 CFR 19.12, which states, in part, that "all individuals...shall be instructed in the purposes and functions of protective devices employed" (See paragraphs 4.1 and 7.1).

(87-05-03) J 6.0 Management Organization and Controls The licensee's management organization and controls were reviewed with  !

respect to criteria contained in SNM License No.1067, Furt 1. Sections  :

2.0, " General Organizational and Administrative Requirements," 3.0, Radiation Protection," and Part II, Section 3.0, " Organization and Personnel."

The effectiveness of licensee's management organization and controls were  ;

determined by: I

- review of the organization for Nuclear Fuels Manufacturing with respect to radiation protection,

- review of position descriptions for the Plant Manager, the Manager, Nuclear Licensing, Safety, Accountability, and Security, the Super-visor, Health and Safety and the Radiation Specialist,

- review of resumes for personnel in key positions within the organization, and

- discussions with licensee personnel.

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Within the scope of this review, the following was identified:

- A personnel change took place two to three_ months ago at the Vice- .i President level. At the time of the . inspection, an amendment-had .I not been submitted to the NRC as notification of the: change, as ,

i required by the license.- The Manager Nuclear Licensing, Safety, Accountability and Security stated that an amendment was being prepared.

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- The position description for the Supervisor, Health and Safety did s l

not describe all the authorities for this position, as specified in ~ '

l l the license. For example, the license states that the Supervisor Health and Safety has the necessary authority to halt'any operation 1 which falls outside license limits (i.e. health and safety,-as well j ascriticalitystandards). J The staffing in Health Physics.is weak. There is no.. professional Health Physicist to provide needed technical assistance or guidance in radiation protection areas. {

l No corporate, company, or plant policy statements could be found at -l tha facility which address a commitment to maintaining radiation exposures at the facility ALARA.-

i The inspector discussed these programmatic weaknesses with licensee ,

management during the inspection, and at the exit interview on '

October 23, 1987.

7.0 Training of Personnel l

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The licensee's program for training of plant workers and health physics- ,

technicians was reviewed with respect to criteria contained in:  :

1 10 CFR 19.11. " Posting of Notices to Workers," l

- 10 CFR 19.12, " Instructions to Workers," l SNM License No. 1067, Part 1, Section 2.6, " Training." '

The adequacy of the licensee's program related to the above criteria was determined by:  !

-i review of training given to plant workers; review of the Qualification Manual for the Health Physics technicians; and discussions with the Health Physics-staff and plant workers.

7.1 General Employee Training The inspector discussed the unwritten plan for general employee initial training with the individual given this responsibility (a <

newly hired senior health ph of the Radiation Specialist)ysics Thetechnician performing thethe duties

. licensee explained that time '

allotted for training new individuals was only two hours, and i

17 included a written test of the subject matter presented.- A booklet entitled " Employee Training for the Building 17/21 Facilities" was reviewed with the new employeees, but newly hired individuals were not permitted to have a copy .of the booklet. The inspector stated that although the booklet may constitute a good tool to indoctrinate radiation workers into the plant, additional instruction may be needed. The inspector stated that some of the missing elements of the program were:

- There was no training for the use of respiratory protection.

- There was no training on the use of breathing zone air-samplers.

- There was no practical factors training for donning and removing protective clothing and the proper technique to frisk out of the Pellet Shop.

- There was no trainirig on worker's rights and responsibilities, as specified in 10 CFR 19.

The inspector stated that failure to provide the above necessary elements of training to new radiation workers illustrated additional examples of the apparent' violation of 10 CFR 19.12, which stater in part, "all individuals working or frequenting any portion of a l restricted area shall be instructed in the health protection l problems associated with exposure to such radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed; shall be instructed in, and instructed to observe, to the extent within the worker's control, the applicable provisions of Commission regulations and licenses for the protection of personnel from exposures to radiation and radioactive material occurring in such areas, and shall be instructed of their responsibility to report promptly to the licensee any condition which may lead to or cause a l

violation of Commission regulations and licenses." (87-05-03)

The inspector observed bulletin boards around the manufacturing facility and conducted interviews with workers and the plant health physics staff to determine compliance with the requirement for posting of notices of violations to workers. The inspector determined that personnel working at the facility did not know about the violations identified in NRC Inspection Report No. 87-01, regarding posting areas and containers with the " Caution Radioactive Materials" sign. The inspector discussed this finding with the Manager, NLSA&S, who stated that the violations identified in NRC 1

Inspection Report No. 87-01 and the licensee's response were never posted because he did not know that the requirement to post notices of violations pertained to those violations. The inspector stated I that failure to post the notices of violations regarding NRC

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Inspection No. 87-01 was an apparent violation.of 10 CFR 19.11-(a)(4), which states, in part, "each licensee shall. post current l copies of any notice of violation involving radiological working conditions, and any response from the licensee._" (87-05-09).

7.2 Health Physics Technician Training The inspector reviewed the Health Physics technician training  ;

program. The training program consisted of a -topical outline of l various subjects of importance_ at the, facility and sign-off sheets .)

for lessor,s completed. However, there was no lesson plan to detail each topic and what information was given. Moreover, the Supervisor, Health and Safety delegated the training responsibility' to a Senior Health Physics technician. The adequacy of Health -j Physics technician training will.be further reviewed in a' future 1 inspection.

8.0 Radioactive Waste Management The licensee's program for the control of liquid and gaseous -radioactive waste was reviewed with respect to critieria contained. in:

- 10 CFR 20.106, and

- SNM License No.1067, Sections 6.1, " Liquid Effluent Discharges;'?

6.2, " Airborne Radioactivity Discharge;" and 5.2, " Effluent Control Systems Commitments."

The licensee's performance related to the above criteria was determined by:

- discussions with licensee personnel; and review of procedures related to these areas:

8.1 Liquid Effluents The inspector discussed the sampling and analysis of liquid wastes discharged from the site, and reviewed the following' procedures for determining the activity in the discharged waste waters:

- " Standard Operating Procedure for the Determination of Uranium l Losses which result from Liquid Waste Releases," dated l November 13, 1974.

- " Standard Operating Procedure for the Determination of Alpha I and Beta Radioactivity in Waste Waters," dated February 14, 1978.

The procedures appeared to adequately assess radioactivity and amount of uranium from waste waters. However _the inspector noted  ;

that no procedure existed for obtaining a sample from the liquid waste tanks prior to analysis and release. Failure to have a  :

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.l procedure for sampling the waste hold-up tanks 'is' another examp1e' of an apparent violation of SNM License No. 1067, Sections 2.7.2, 3.1.1, and 4.1 which require procedures to be written and maintained for all operations involving radioactive materials. (See also paragraphs 5.1,5.3,5.4,5.5)(87-05-04) 8.2 Gaseous' Effluents i During NRC Inspection No. 70-1100/87-01, the inspector noted j concerns regarding the adequacy of the licensee's ability to obtain l l a representative sample from the ventilation stacks (Follow-up item i I

87-01-08). During this inspection, the licensee provided a copy of a purchase order for a local ventilation consultant to perform'a verification of' isokinetic sampling in the ventilation stacks. _The q licensee specified in the purchase order that the sampling system' i must be in conformance with the ANSI N13.1-1969 standard. This item ,

remains open and will be reviewed in a future inspection when the system isokinetic sampling is verified.  ;

i 9.0 Transportation Activities j The licensee's management controls, and training program were reviewed l.

for transportation activities.

The inspector identified the following: i

- The Manager, Nuclear Materials has the responsibility for 4' transportation of shipments off-site. A position description was available, and it described the responsibilities which included maintaining documentation and recordkeeping. Responsibility for package preparation, QC oversights of packages, and radiation protection activities associated with transportation activities were not clearly defined.

There were no implementing procedures for transportation activities associated with the movement of radioactive materials off-site.

There was no training program for waste handlers, health physics technicians or any other staff on transportation regulations and requirements.

These apparent program weaknesses were brought up to the licensee's attention and will be reviewed in a future inspection.

10.0 Status of Previously Identified Items 10.1 (Closed) 87-01-04 (Violation). Failure to post area " Caution- 1 Radioactive Materials." .

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%g F.0 The inspector . verified the licensee's corrective actions, as stated in a letter to the NRC, dated June 17, 1987. The licensee's correc- i tive actions appeared adequate and sufficient to prevent a re-occurrence of this violation.

Failure to post containers " Caution-

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10.2(Closed) 87-01-05(Violation).

Radioactive Materials."

The inspector verified the licensee's corrective actions,~as stated in a letter to the NRC dated June 17, 1987. The licensee's corrective i actions appeared adequate and sufficient to prevent,a.re-occurrence .

i of this violation.

l 10.3(Closed) 87-01-06 (Violation). Failure to calibrate radiation detection instrumentation.

d The inspector verified the licensee's corrective actions, as stated in a letter to the NRC, dated June 17, 1987. The licensee's correc-tive actions appeared adequate and sufficient to prevent a re-occurrence of this violation.

10.4 (0 pen) 87-01-03 (Violation). Failure to' establish procedures for radiation protection activities.

The licensee's response in a letter dated June 17, 1987 stated that the procedures would be completed, approved, and issued through document control by August 31, 1987. However, additional examples of failure to establish radiation protection procedures were identified during the current inspection. Morover, the licensee did not comply with their response to this violation. (See paragraphs 5.1 for details of this repeat violation).- ,

j 10.5 (0 pen) 87-01-08 (Inspector Follow-up). Review isokinetic sampling i of ventilation stacks - labs and manufacturing.

Details appear in paragraph 8.2.

l 11.0 Corrective Actions Anticipated As a result of the number and significance of violations, and the degraded radiological conditions that existed during the inspection, the i NRC issued a Confirmatory Action Letter on October 27, 1987 documenting .l the licensee's planned corrective actions to immediately return the plant  ;

to operation within the limits of the license.

I 12.0 Exit Interview The inspector met with the licensee's representatives (denoted in paragraph 1)attheconclusionoftheinspectiononOctober 23, 1987. The inspector summarized the purpose and scope of the inspection and findings as I described in this report.

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