ML20235X390

Insp Rept 70-1100/87-03 on 870601-05.No Violations Noted. Major Areas Inspected:License Program,Including Mgt Organization & Control,Criticality Safety,Operations Review, Radiation & Environ Protection & Nonroutine Event Repts

ML20235X390
Person / Time
Site:	07001100
Issue date:	10/07/1987
From:	Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235X350	List: ML20235X347 ML20235X370 ML20235X390
References
70-1100-87-03, 70-1100-87-3, NUDOCS 8710190337
Download: ML20235X390 (8)

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U. S. NUCLEAR REGULATORY COMMISSION REGION I I

Report No. 70-1100/87-03

' Docket No. 70-1100 ,

License No. SNM-1067 Priority 1 Category ULFF Licensee: Combustion Engineering, Incorporated l P. O. Box 500 1 Windsor, Connecticut 06095 Facility Name: Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor, Connecticut Inspection Conducted: June 1-5, 1987 .

Inspector: W/T /6/9/27

'ifit6 J. Rog, Pfoje'ct Engineer Accompanied by: George France Fuel Facilities Inspector, RIII Approved by: g by /0 >/fr7 W.(d. P'asciak, Chi ef, Effluents dat6 Rddiation Protection Section, DRSS Inspection Summary: Inspection on June 1-5, 1987 (Inspection Report No. '

70-1100/87-03 Areas Inspected Routine, unannounced inspection by a region-based inspector of the licensed program including: management organization and controls; criticality safety; operations review; radiation protection; environmental protection; and non-routine event reports.

Results: Three apparent violations were identified: failure to post four of five furnaces (work stations) with nuclear safety limit signs (paragraph 2.a.(2)); failure to maintain at least a 20 foot separation between two arrays of shipping containers (paragraph 2.d.); failure to comply with all nuclear safety controls specified by a nuclear safety evaluation (paragraph 3.b.(2)).

Failure to provide permanent corrective actions to cover the clean-up and storage of uranium containing contaminated waste solutions following an inadvertent spill was identified as a safety concern (paragraph 6).

8710190337 g73oo9 PDR ADOCK 07001100 C PDR

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l Details I

l Persons Contacted l 1.

• H. V. Lichtenberger, Vice President, Nuclear Fuel Manufacturing

• R. E. Sheeran, Manager Nuclear Licensing, Safety, Accountability and Security R. N. Duncan, Director, Product Development

• G. H. Chalder, Plant Manager, Nuclear Fuel Manufacturing I '

• present at the exit interview The inspector aisc interviewed other licensee employees during the inspection.

2. Review of Operations The inspector examined all areas of the plant and the nuclear laboratories to observe operations and activities in progress, to inspect the nuclear safety aspects of the facilities and to examine the general state cf cleanliness, housekeeping, and adherence to fire protection i rules.

a. Postings During the examination of the f;acilities, the inspector observed the following posting inadequacies:

(1.) Pellet Shop Annex The inspector observed that the empty incoming powder container storage area located near the powder container weighing station was inadequately posted. Posted signs indicating that the stored containers were empty, were either covered by the containers or were hidden behind the storage rack support structure. For criticality safety purposes, those containers should be identified as empty. The licensee representative stated that the area would be reposted so that the empty signs were visible from all directions.

(2.) Pellet Shop During examination of the pellet shop, the inspector noted that none of the Dewax furnaces and only one of the three sintering furnaces were properly posted as required by paragraph 4.1.4 of the NRC-approved license application. Paragraph 4.1.4 requires, in part, that all work stations and storage areas shall be posted with a nuclear safety limit. Operations Sheet No. 526 "Dewaxing Pellets", in Step 3.3, states that the maximum uranium enrichment shall be posted on each Hevi Duty (dewax) furnace. There was no such posting on either of the L __-_.

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l two dewax furnaces. Operation. sheet No.527 " Sintering Pellets" in step 3.4, requires the o station (sintering furnace)perator is postedtowith verify that safety nuclear each work-

_ 1' ifmits. . Only one of three sintering furnaces was posted with nuclear safety limits. The licensee stated that only one of the three sintering furnaces was posted with nuclear safety j limits ~1n order to cut down on the number of signs posted in 1 the facility. _ Failure to post four of the five furnaces -(work j stations) with nuclear. safety limit signs was identified as an i apparent violation (1100/87-03-01). )

'(3.) Building 5 Vault l l

During' examination of the Building 5. vault, the inspector observed an array of five DOT Specification 6M containers which was within 12 feet of three special nuclear material storage areas.. A licensee representative stated that the q containers in the array were empty. .This was verified by the '

inspector. In any case, the inspector-stated that all  ;

1 containers in an2.a.(1)

(see paragraph array a))

(areorassumed to be in each container full.unless the array the wasarray i labeled empty. The licensee immediately labeled each container

-in the array with an empty sign.

b. Flammable Material Storage The inspector observed that the licensee had placed flammable liquids into properly grounded and vented storage cabinets located throughout the pellet shop. However, each of the storage cabinets was found to be filled to capacity. The inspector questioned the advisability of filling each cabinet to capacity considering the l potential impact of a fire on the operation of the pellet shop.

Licensee representatives stated that the storage of excessive flammable liquids would be re-examined and unneeded liqui k would be removed from the pellet shop. l

c. Emergency Egress During examination of the rod end cap welding area of the pellet shop, the inspector noted that emergency egress from that area to the closest emergency exit had been impeded following installation of walls around the pellet stacking area downdraft tables. Since the door to the cold side of Building 17 from the pellet shop was padlocked, an individual working in the welding area would be required to exit by means of several torturous routes, through the north wall of the building. Licensee representatives stated that emergency egress routes from this area of the pellet shop will be evaluated and corrective action will be taken, as necessary.

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d. 'S' hipping Container Storage During examination of the Powder Trailer Storage Area located J> outsidelthe northwest corner of Building:17, the. inspector.

observed.than an array of 26 Model CE-250 shipping' packages

,' containing uranium bearing scrap materials was located _within

, 12 feet of. the Building 17 wall.- Just inside the: building, within three feet of the wall; there was another array of-shipping packages containing uranium bearing scrap materials.

A sign posted on the. building'in this area required a minimum.

of 20 feet between arrays of shipping packages. Paragraph

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4.3.20 of the NRC approved license application requires, in part, that arrays of shipping' packages shall be separated from one another by at least 20 feet. Failure to maintain at least a 20 foot separation between two arrays of shipping packages was identified as an apparent violation (1100/87-03-02).

'3. - Nuclear Criticality Safety

a. Internal Review and Audit (1) Daily Audits Records'of daily audits conducted by health physics technicians for the tima period April 1,1987, through June 2,1987, were examined by'the inspector. The licensee has developed a detailed checklist covering all aspects of the operations as an aid to the health physics technicians when they conduct this facility review. Areas examined included signs, logs, radiation alarms, criticality safety compliance, contamination

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levels, and airborne contamination levels. Items requiring correction were corrected immediately.

(2) Weekly Audits Records of weekly audits, conducted by the Supervisor, Health Physics.for the period April 1, 1987 through June 1, 1987, were examined by the inspector. Areas examined included the same topics as described above. In addition, the Supervisor measured and recorded air flow from areas of lower to areas of higher potential contamination. The inspector determined that air flow direction was being recorded weekly as a.part of the weekly audit report.

(3) Monthly Audits The inspector examined documentation of monthly audits i conducted by the Manager, Nuclear Licensing, Safety I

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Accountability and Security (NLSA&S) and/or Criticality i Specialist during the time period January 31, 1986, through j June 1, 1987. A total of 11 audit reports were reviewed. The- l inspector verified that appropriate corrective actions were i taken or had been initiated by the licensee for the items 1 identified in these reports.

l (4) Quarterly Nuclear Safety Committee Audits The inspector examined documentation of quarterly audits conducted by the Criticality Safety Specialist for the Nuclear Safety Committee between March 27, 1986, and December 16, 1986.

The inspector verified that appropriate corrective actions were taken or had been initiated by the licensee for the items identified in the audit reports.

(5) Audits of the Nuclear Laboratories The inspector examined the records of four quarterly audits of the nuclear laboratories conducted by the Manager, NLSA&S between March 10, 1986 and March 16, 1987. The May 31, 1986 quarterly audit served as the annual audit specified by Amendment No. 2 to the facility license, dated May 23, 1984.

Monthly audits required by Amendment No. 9 to the facility license, dated April 8, 1987 were initiated on May 4, 1987. No inadequacies were identified.

b. Nuclear Safety Evaluations (1) Fecility Changes and Modifications During examination of the facility, the inspector observed that there had been no significant facility changes or modifications in either the manufacturing facility (Building 17) or the Nuclear Laboratories '

(Building 5). It was noted that one of the two multi-head pellet presses had been removed from the pellet shop in Building 17 and that the licensee had initiated preparation of a new vault room in Building 5 so that the archive pellets currently stored in Building 2 could be moved to Building 5. The status of the new vault room (installation of criticality alarms, etc) will be reviewed during a subsequent inspection.

4 (2) Review of Nuclear Safety Evaluations The inspector reviewed the records of the review and approval of process equipment or facility changes performed by the Criticality Safety Specialist for criticality safety or by the Manager, NLSA&S for radiological safety. From October 14, 1986 ,

through April 16, 1987 (Request No. 248A), twenty four requests

for review and' approval were made by Engineering. .All but two of the requests were reviewed and approved. Fourteen of the requests involved both nuclear criticality and radiological safety considerations and ten involved radiological or. .

industrial-safety considerations. :The, requests that involved criticality. safety considerations were independent 1y' reviewed -

by a qualified person-designated by the Nuclear l Safety.

Committee and by the Criticality Safety Specialist, if the original review was conducted by. the Manager, NLSA&S. The-requests involving radiological and industrial safety considerations were reviewed by the. Manager, NLSA&S. The evaluations were countersigned by qualified persons, as required. However, documentation of the independent reviews l was not adequate, in that, in most cases only the signature of the independent reviewer was available in the licensee's records. Licensee representatives stated that a record of each independent review will be maintained to document the Nuclear Safety considerations evaluated during the review process.

During examination of Request No. 211 concerning modification of the fuel rod storage rack at the fluoroscope work station, the inspector noted that.one of the conditions for approval involved the installation of a positive restraint to assure that carts containing fuel could not come within 12 inches of 4 the fuel rod storage rack. Although this request was approved on May 20, 1986, the licensee had not installed the positive  !

restraint by the date'of this inspection, June 4,1987. I Failure to install the positive restraint, a condition for I approval of the fuel rod storage rack modification was identified as an apparent violation of Section 2.2.2 of the NRC  ;

approved license application (1100/87-03-03). 1

c. Nuclear Safety Log Sheets 0 1

The inspector examined the nuclear safety log sheets for the I time period January 1, 1987 through June 2,.1987 available at I the hammermill, the screening hood, the micronizer, and the j blended powder drier belt to assure that mass limits or slab depths were not exceeded. No inadequacies were identified.

4. Nuclear Safety Committee The inspector examined records of meetings of the annual Nuclear Safety Committee meetings and tours of the Nuclear Fuel Manufacturing facilities conducted on December 18, 1985 and December 11, 1986. Areas of the facilities examined during the tours and discussions held during the meetings included: housekeeping, locations where license violations occurred, implementation of previous observations; review of facility changes and review of the radiological protection and ALARA programs. No inadequacies were identified.

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5. Hood Velocity Checks l The inspector examined licensee records of weekly hood velocity checks, conducted in Building 17 from January 6, 1987 through June 1, 1987.

Corrective actions were immediately taken when hood air flow velocity was reduced to less than 100 fpm. l

6. Nonroutine events During examination of licensee records with regard to licensee identified violations for the time period January 1, 1987 through June 2, 1987, the inspector noted that a notification of violation was issued on January 16, 1987. That notification identified the unsafe' practice of storing unanalyzed uranium contaminated waste water in three not-safe-by-geometry 30-gallon containers. The waste water was placed into the 30 gallon containers following leakage from a waste water centrifuge onto the contaminated floor of the pellet shop. Since there was no analysis of the uranium content of the water to show if geometry e controls were required, storage of that water in unsafe geometry containers was not allowed. Subsequent to the identification of this violation by licensee representatives, actions were taken by the licensee to retrain all supervisors in the proper handling of unanalyzed uranium solutions. However, procedures to cover the handling of this type of incident in the future have not been written, approved and issued by the licensee. Failure to complete corrective actions to assure that i violations of this type do not occur in the future was identified as a '

safety concern (1100/87-03-04). l 1

7. Organization Amendment No. 9 to the facility license dated April 8, 1987, authorized the transfer of certain responsibilities from the Nuclear Laboratories to the Nuclear Fuel Manufacturing organization. Those functions within the Nuclear Laboratories concerned with the development of nuclear fuels or components for nuclear steam supply systems were transferred. As a result of the transfer, one group, Nuclear Fuel Manufacturing is now responsible for all activities with Special Nuclear Materials at the {

Windsor, Connecticut site, k The Director of Product Development now reports directly to the Vice President, Nuclear Fuel Manufacturing. The conduct of activities involving Health Physics is currently controlled by the Manager, Nuclear Licensing, Safety, Accountability and Security through a Health Physics Technician who reports to the Director, Product Development for administrative purposes. That technician obtains direct technical support from the Nuclear Fuels Manufacturing facility Health Physics Supervisor. Training of the Health Physics technician is also being conducted by the Health Physics Supervisor.

During examination of Nuclear Laboratory records, the inspector determined that no written procedures had been prepared for use by the Health Physics technician in the conduct of Health Physics l

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duties inithe Nuclear Laboratories. This apparent inadequacy will H

.be examined in detail during subsequent inspections.- .

8. Contaminated Wooded Area-The inspector discussed.the status of the licensee's actions taken to assure that the wooded area was cleaned up. The licensee has completed-cleanup of the area and is currently analyzing soil samples to assure "

that the soil contains less than.30 picocuries uranium per gram of; soil.

The inspector stated that the 30 picocuries of uranium' must include; as a ~

. minimum, uranium-234, uranium-235 and uranium-238.

~9. Exit Interview The. inspector met with the licensee representatives (indicated in Paragraph 1) at the conclusion of the inspection on June 5, 1987. The-inspector summarized the scope and findings of the inspection.

No written material was provided to the licensee during this inspection. '

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