G. M. #i - nrc.gov

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"i U..S. NUCLEAR: REGULATORY COMMISSION-

REGION III .

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Report No. 7tl-36/87003(DRSS) License No. SNM-33''

Docket No. 76-361

i Licensee: Combustion Engineering, Inc. .;Nuclear Power Systems- |

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. Windsor, CT 06095 !,

Facility Name: Hematite..

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Inspection At: Hematite,LMissouri.j

'Inspection Conducted: Se'ptember 21-25,'1987

N 111~G. M. #i 16;/ ff7 |:

Inspector: France, III

Date

Approved By: L. reger,. Chief /O-/9 87-.

Facilities Radiation Date<

Protection-Section,

Inspection Summary..

Inspection on September 21-25', 1987 and September 29, 1987 (ReportNo. 70-36/87003(DRSS))Areas Inspected: Routine, unannounced safety inspection of fuel (uranium . '

powder / pellet) production and UFs cylinder storage operations during_ normalshift and off-shift hours, including: organization, training, operationsreview, criticality safety, radiation protection program (audits, procedures,.and surveys) and transportation activities. The inspection also' involved adetermination of the licensee's progress on corrective action measures to <

previous-inspection findings.Results: The licensee was found to be in compliance with NRC requirementswithin the areas examined, except for the following item: failure to follow- ;

procedures (Section 6, Radiation Protection). ;

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| DETAILS-

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1. Persons' Contacted - ]G. Boyer, Health Physics Technician

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*L. Deul, Manufacturing Engineer*H. Eskridge, Nuclear Licensing, Safety, and Accountability U

Supervisor*R. Fromm, Quality Control Manager*R. Griscom, Engineering SupervisorJ. Harter, Shipping and Receiving' Foreman

*R. Miller, Manager, Administration and Production Control*A. Noack, Production Superintendent- i

*J.~ Rode, Plant Manager jR. Stokes, Health Physics. Technician J

G. Uding, Quality Assurance EngineerN.'Wilpur, Health-Physics Technician

* Denotes those'present at the exit meeting on. July 17, 1987.

The inspector also contacted the off-shift foreman concerning training ofnew. employees.

2 .- General'

This inspection of onsite licensee activities, which began at 1:30 p.m.

L fabrication at the' Hematite site under Material License No. SNM-33. .The ~|on September 21, 1987, was conducted to examine activities involving fuel

| inspector al'so reviewed the licensee's progress in correcting previous''

inspection findings, the radiation protection ~ program, and off-shift'activities. An exit meeting was conducted.on September 25, 1987. ;

3. Licensee Action on Previous Inspection Findings !

During this onsite-inspection, the i.nspector reviewed the progress'thelicensee had made in correcting weaknesses and open items. identified ,

; during a previous inspection.1|!

|' a. (Closed) 70-36/86004-02: Lack of an alarm on the cold trap pressure| sensor. A panel alarm was calibrated and installed in June 1987. ,

| Vendor representatives performed the initial tests. Periodic- 1

L service will also be' supplied by the vendor. 1

b. (Closed)'70-36/86004-03i Heating'of-cold trap without pressure.,

sensor online. .A pressure sensor has been installed and tests'for ;

operability were completed; ,The licensee indicated that the sensors-~

response to.the tests. vere acceptable,

c. (0 pen) 70-36/86004-04: No periodic verification of. operability.of ;1

the cold trap load cell. Periodic checks on the' operability of thecold: trap load cell.are required and-are listed on.thefoperators

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data sheet. This will be reviewed during a f.uture inspection. Ii

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d. (0 pen): No alarm on the cold trap load cell. An alarm for high llevel weight appears on the control panel as both a visual alarmlight and an audible indicator. Verification of the load cell span !

will be monitored during a future inspection.

h. (Closed) 70-36/86004-09: No airborne-detectors to warn of uforeleases in the vaporizer area. An improvement in the ventilationsystem in the vaporizer room has minimized the problem of spuriousalarms on the recently~ installed detectors. Only two-have been ~jraported, one from fumas generated by welding and the other fromelectronic malfunction.

i. (0 pen) 70-36/86004-10: The use of automatic functions to minimizespread of HF and U0 F2 within the plant buildings. A system has2been designed, and a date to commence installation is beingscheduled. This will be reviewed during a future inspection.

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J. (Closed) 70-36/86004-11: Need for improved training qualificationprogram formal documentation. This program has been implemented andwill be reviewed periodically during future-inspections. Moredetails on program requirements are found in the previous inspectionreport (Inspection Report No. 70-36/87001(DRSS)).

k. (Closed) 70-36/86004-12: Need to review procedure review andapproval program. The licensee has made significant progress inthis area. Nearly two-thirds of the operating procedures have beenrewritten, reviewed and approved. A periodic review of thelicensee's progress in this area will be conducted during futureinspections. More details on program requirements are found in theprevious inspection report (Inspection Report No. 70-36/87001(DRSS)).

1. (Closed) 70-36/86004-13: Need to evaluate method for ensuringoperators are aware of procedure revisions. The licensee's use ofthe operating sheet acknowledgement form which allows the operatorto review and initial procedure revisions continues to functionadequately. The program will be monitored periodically during i

future inspections. '

m. (Closed) 70-36/86004-14: Need to assure that safety parameters arecorrect on data sheets. Data sheets (process parameter sheets) havebeen modified to include only those items important to safety. Thelicensee indicated that modification of the parameter sheets in thismanner should reduce the likelihood of operator' errors. The datasheets will be reviewed periodically during future inspections.

n. (0 pen) 70-36/86004-15: Need to expand QA/QC program to includethose process components that may impact on onsite or offsite healthand safety. Since the previous inspection (70-36/87001) production

;has increased significantly. This production increase required moreQA/QC effort'on product parameters. Hence, the QA/QC audit programhas not been expanded. Progress on improving QA audits will bemonitored during future inspections.

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p. (Closed) 70-36/86004-18: Need to determine hydrostatic-testingrequirements applicable.to the' ammonia storage tank. The licenseehas examined / replaced / tested the_ valve that controls the flow of

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ammonia vapor., A valve'will also be installed in the liquid fillline. In each instance the valves are designed to fail safe in caseof sudden pressure drop. As reported previously (Inspection ReportNo. 70-36/87001) hydrostatic testing is only required forreinstallation of underground ammonia storage tanks. Installationof fail safe valves in open lines to the underground' tank reportedly.will bring the tank into conformance with OSHA requirements enacted -|since the tank was first installed.

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s. (Closed) 70-36/86004-30: Need to review maintenance procedures 1to ensure they are current. The licensee reviewed maintenance

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procedures on the following items:

Ammonia Cracker

|0xide Emergency Generator !

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Main Emergency Generator

Electrical Transformers (4)

Fork Lift Trucks (2) U

lStackers

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Man Lifts

The inspector determined that procedures pertaining to most of the ;

above items have been rewritten and approved for implementation. The ;inspector concluded that the new procedures contain checklists / '

requirements that emphasize health and safety.

v. (Closed) 70-36/86004-16: Need to index or clarify documentation ofcorporate audits and plant staff audits. The inspector examined thelicensee's audit file and confirmed that the file now delineates thelocation of corporate audits and plant audits, and theircorresponding responses.

dd. (Closed) 70-36/86004-27: While NFPA Standard 491 indicates thaturanium dioxide can spontaneously ignite in finely divided form, theparameters for producing uranium oxides along with engineeringcontrols and the amount of SNM material being processed minimize thepotential for spontaneous ignition,

kk. (0 pen) 70-36/86004-37: Need to update the quality assurance program| Tor environmental monitoring. This program is still under review.

I 11. (Closed) 70-36/86004-38: Need to expand the corporate audit ofL Hematite operations. A summary of the areas inspected (including| ALARA/ environmental concerns) was attached to a recent corporatel'1

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audit. The audit was presented in a format that provided greater jdetail. It clearly delineates the areas inspected and specifically

-]lists corresponding audit findings. g

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mm. (Closed) 70-36/86004-39: Evaluation of the use of fixed orifices on .Ithe fixed air sample system. -The licensee is testing differentorifice openings and adjustments'in the flowrate. Through vendor-review of critical' orifices, it was noted that while the criticalorifice is a device for maintaining a constant flow rate through asampling instrument, certain limits-such as increased static pressurecapacity on the suction pump must also be considered. This programwill be reviewed periodically during future-health and safety

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inspections. d

!4. Management Organization and Controls |

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The inspector reviewed the licensee's management organization and jcontrols for radiation protection and operation, including changes in '

the organizational structure. Two employees in production operationsterminated employment with CE Hematite (one by retirement). Since the ;

previous inspection (70-36/87001) four operators were hired bringing the I

work total to 67 at CE Hematite. At the Corporate Office, Dr. P. L. McGill 'lreplaced Mr. H. V. Lichtenberger, who retired, as Vice President of .tManufacturing. Mr. J. Rode, CE Hematite Plant Manager, now reports toDr. McGill. o

1a. Procedure Revising and Updating i

Operating procedures are being revised for staff review; operatorsare alerted to procedure changes via an operating sheetacknowledgement form. (This was covered in more detail.inInspection Report No. 70-36/87001(DRSS)). According to the QAEngineer, who also acts as document control custodian, the-procedurereview and approval process is nearly two-thirds complete. The |licensee had demonstrated significant improvement in this area. i

b. Review and Audits

The licensee utilizes independent audits and inhouse ' audits as ameans of identifying deficiencies. q

1During the corporate semi-annual nuclear safety audit (August 1987) {CE Hematite was cautioned about the condition of identification tags ;

on several SNM storage containers because apparently, the numbersdesignating the quantity of SNM material and the correspondingenrichment level were not easily distinguished on several container jtags. The licensee promptly corrected the audit finding. J

lNo violations or deviations were identified. 'j

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5.- Order Modifying License

Faulty UFc Valves

On July 24, 1987, the U.S. Department of Energy, Oak Ridge OperationsOf fice-Safety Division (00E), notified 'the Nuclear Regulatory Commission(NRC) of parallel cracks that were observed in and around the threads i

of 1-inch valves used in 30-and 48-inch diameter uranium hex'afluoride !

(UFe) cylinders. The cracks were observed in the valve threads of valvesin' lots 17 and 20 manufactured by Superior' Valve Company. NRC licensoeswere notified by phone to look for defects in valves in these lots. On i

July 29, 1987, after further investigation, 00E again notified and'

reported to NRC that Superior valves in lots 16 through 22. inclusiveshould be suspect for thread cracking. 00E is in the process of jdetermining the reasons'for.the cracking and recommends that cylinders ;

fitted with 1-inch valves in lots 16 through 22 not be filled, emptied, j'heated, or shipped until a determination of their safety is made.

Effective August 19, 1987, the NRC Office of Nuclear Material Safety andSafeguards (NMSS) issued an Order to Combustion Engineering, Inc.,Hematite facility which:

1(1) Prohibits filling, heating, emptying, or delivering to a carrier for i

transport 48-inch or 30-inch diameter uranium hexafluoride cylindersfitted with Superior Valve Company 1-inch alloy valves manufacturedin Superior Valve Company lots numbered 16 through 22 inclusive.

(2) Requires that all 1-inch Superior valves for use in UFe cylinders inwarehouse stock be carefully inspected. All valves are to bereinspected before fitting into cylinders All defective valves i

found in stock regardless of lot number or manufacturer are to be Ireported to the appropriate regional NRC office.

On September 25, 1987, the Order was modified to lift all mstrictions oni

valves produced in lot 16. Valves produced in lots 17 through 22 remain |under the Order restrictions.

The inspector reviewed this matter onsite and determined that thelicensee had identified and quarantined all valves manufactured in Ilots 16 through 22. The only valves from these lots found onsite wereproduced in lot 16. The valves were inspected for defects; none werefound. In addition, the inspector confirmed that.seven 30-inch diametercylinders (one filled with UFe, the others empty or containing UFs heels)

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were equipped with valves from lot 16. No defects were identified in ithese valves either.

6. Radiation Protection ||'

The inspector reviewed the licensee's internal and external exposure.control programs including the required records, reports, and 1notifications.e

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a. Internal Exposure control

Bioassay records for the April through August 1987 operating period jdisclosed that the 40 MPC-hour intake limit for uranium was not '

exceeded. Semiannual whole body counts were to be completed duringSeptember 1987.

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Selective review of licensee records of air sample analyses !

disclosed two incidents with potential to health'and safety.. significance as. discussed below. Both incidents were discussedwith the licensee during the exit meeting:

I(1) A staff engineer, assigned to' demonstrate .the operation of apellet press to a newly hired operator failed to activate theventilation. system (downdraft exhaust) as required in the press

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start-up procedure (Procedure No. 702.4 Preparation for|Start-Up of Dorst Presses). The procedure states that the

downdraft exhaust system is one of the main service functionsthat must be engaged prior to operating the ' press. As anengineering control for ALARA purposes, the ventilation systemenables the operator to press UO2 pellets without respiratoryprotection. !

The resultant exposure to the engineer and the operator(1.5 hour duration) was determined to be about 18 MPC-hoursbased on fixed air sampler results. This exposure is one to ;

two orders of magnitude greater than expected with the exhaust |system functioning.)

As an additional precaution the licensee noted that urinevoidings (samples) were obtained from the engineer and theoperator; however, " refractory" uranium oxide is quite insolubleand therefore voided in very small quantities in urine. Wholebody counts, scheduled for plant workers during the week of i

September 27, 1987, will provide additional backup to the !calculated exposure. l

Although the internal expost:re did not exceed regulatoryrequirements, the engineer apparently violated the requirementof Procedure No. 702.4 to activate the press exhaust' system aspart of the press start-up service function. The licensee'sNuclear Safety Supervisor counseled the engineer concerningcomplying with operating procedures and utilizing engineeringcontrols in order to maintain radiation exposure to workersALARA. Additionally, the licensee stressed the need to useoperating procedures when instructing personnel.

(2) A staff engineer assigned to coordinate the onsite activitiesof contractor welders required the welders to wear half-face ,

respirators as a precaution because the engineer anticipated )that the welding and grinding operation.could cause airborneuranium oxide. However, the contractor workers we're not fit

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: tested for the : protective ~ masks,: nor were.. licensee staffmembers' clear whether~or not.the: contractor personnel-had:. received medical ~ clearance to' wear a respirator as required by'10 CFR 20.103 and-Regulatory Guide 8.15. ~ Subsequent' evaluationof anLair sampler located in the vicinity would have beenexposed to!about,6 MPC-hours without respiratory protection.

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Inasmuch as the MPC-hr exposure did'not exceed 40 MPC-hrs.,.respiratory protection equipment was1not required, except for..ALARA purposes. No. regulatory violation-occurred; however, the- 3

matter.was discussed with licensee personnel at the exit 'jmeeting'due.to its potentialisafety. significance.

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The inspector:noted that the licensee has.the responsibility'to 'jensure that persons. coming onsite to perform-work in locationswith the potential for radioactive airborne ~ contamination. possess documentation that a physician has cleared that person.co. wear respiratory protection; the medical status of eachrespirator user'is to.be' reviewed at least annually; Licenseeprogress in this area will be monitored during a futureinspection,

b. External-Exposure Control

The inspector reviewed the licensee's exposure control programincluding adequacy of procedures used to evaluate, control, andminimize exposures and required. records, reports, and notifications.Out of-67' employees there were.no exposures above.0.4. rem for theApril through August'1987 operating period ~

c. Source Leak Tests

The inspector examined licensee records for leak testing byproductmaterial sealed sources. Tests were performed on' September 4, 1987,in accordance with the provisions-'of Materials License SNM-33.Licensee records disclosed that both cobalt-60 sources passed theleak test criteria.

One violt. tion was identified.

7. Criticality Safety |

1The inspector reviewed criticality safety audits and documentation of I

facility changes that required. nuclear criticality. safety analyses,

a. Special Nuclear Material-(SNM) Storage Arraysi

In reviewing the last inspection report (Inspection Report- 'lNo. 70-36/87001(DRSS)), NMSS noted that SNM mass limits appearing in -|the table (demonstrating storage limits of SNM) did not correspondto the' enrichment' levels submitted in the-license-application. .That

. table was in error. The~ inspector determined that the licenseemaintains storage arrays in accordance with the following corrected-

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-Nominal Enrichment Maximum Net Weight. Kg UO2

Less.than or equal to: Powder Pellets

3.0% U-235 41 38

3.2% U-235 36 36

3.4% U-235 35 33.

According to the above table a container of 3.15% U-235 powdershould be stored with a mass limit of 36 Kg which corresponds to aconservative value of 3.2% U-235. j

b. Nuclear Safety Analysis

The following nuclear safety analyses have been completed since theprevious inspection: (Inspection Report No. 70-36/87001(DRSS)) j

i(1) Relocation of the vacuum filter vessel. The vessel is |

designed to handle excess U02 powder from the pellet press '

feed operation. The purpose of moving the vessel is toimprove accessibility of the vessel in order to make a j

filter change. The analysis requires a 1-foot separation '

from other SNM material that may be present on the conveyor,and a 3.5-foot exclusion area to be marked on the floor. )

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(2) Install a vacuum cleaner as an integral part of the milling |hood. This will enable the operator to reduce the amount of |UO residue that accumulates in the milling hood. .Apparently, ;2

a large build up of oxide residue obscures the operator's !vision and requires excessive clean up. The material i

collection system (filter bag) is located outside of the hood, !while actual filter bag changes occur inside the hood. i

INeither the NRC inspection findings nor corporate plant criticality 1safety audits disclosed any infractions that involved more than one |change in a process condition. The double contingency policy which {requires at least two unlikely, independent, and concurrent changes in i

process conditions that may lead to a criticality accident was notviolated. The inspector confirmed that management of the licensee'snuclear criticality safety program is commensurate with the

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administrative and technical requirements of the license. ]j

No violations or deviations were identified. *

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8. Transportation and Radioactive Waste Management i

|The inspector reviewed the licensee's program for receipt and/or shipment !

of radioactive. materials. The inspector also toured the area where the ilicensee is decommissioning two evaporation ponds.

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Since the previous ~ inspection (70-36/87001). only one shipment'wasmade to waste burial. . The. shipment'was accepted without incident.-

. Nearly 1440 | cubic' feet of contaminated' soil' was . removed from the two -evaporation ponds' since the previous; inspections The contaminated soil |

'is packaged.in metal bins (about 96-cubic, feet capacity per bin).in ')preparation for' shipment to off-site waste disposal. The inspector |

concluded that the licensee. demonstrated a performance-level:.that assuredradiological safety in the handling and transport of licens'ed radioactive.material. .

No violations or deviations were identified.

9 .' Emergency Preparedness-~

A recent update of the Radiological Contingency Plan is under staffreview prior to submittal to NRC. .During the' course of this inspection,

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the inspector observed that the UFe cylinder station which can house up. Ito two cylinders of UFe for processing UFe to U02 is now completely I

enclosed.

Under present conditions (room enclosed) any radioactive material(UO F2 2 and HF) escaping from a cylinder would be mostly confined to theenclosure. This arrangement should mitigate.significantly the amount of. hazardous material that would escape' off-site as the result of a; cylinder -|failure. !

)"The licensee noted that the following activities were ongoing in the

Emergency Preparedness Program:

Emergency. evacuation alarms.are tested each Monday morning..

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All fire extinguishers located in the production facility underwent- j*

hydrostatic testing by an otatside reviewer. Scott air pak limits '

were'also tested by the reviewer..

An emergency call list for ambulance,. physician, and hospital-*

services and firefighting assistance is posted outside theproduction foreman's office. During off-shift operations the shift

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foreman is the emergency coordinator. Hence,: the emergency calllist is visibly postri

The inspector concluded that the licensee has made significant-improvement in emergency planning to mitigate off-site releases ofradioactive material.

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No violation or deviations were identified.

10. Training

The NRC inspector reviewed the health physics training provided to fouremployees. The new employees were instructed in basic health physics andgeneral plant safety. For' plant indoctrination and-training operatorsare assigned work under the supervision of an. experienced operator and/or-

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j' supervisor during the initial training period in order to become familiarwith procedures and equipment. Training documentation indicated thatinformation in Regulatory Guide 8.29, Instruction Concerning Risks From i

L Occupational Radiation Exposure, and 8.15, Acceptable Programs forRespiratory Protection, was provided.

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No violations or deviations were identified.

11. Operations Review

The inspector observed'the licensee's performance of plant operations,including handling and storage of SNM material in accordance withMaterial License No. SNM-33. I

a. Observation of Operations

The plant operating mode included around-the-clock (24-hour) 1

production of UO2 pellets from the ufo conversion process. Off-shift Iproduction was monitored by the shift foreman. During an off-shift {tour the inspector observed a Health Physics Technician performingsafety routines. A follow-up of air sampling analyses indicated thatcontaminated airborne levels were less than plant allowable limits.

b. Housekeeping

The inspector observed that material was stored in designated'storage areas, evacuation pathways were clear, and the potential foraccumulating fissile materials in unauthorized locations wasminimized. No problems were identified.

The inspector concluded that plant operations were accomplished ini

accordance with the license application.

No violations or deviations were identified.

12. Exit Meeting

The inspector met with licensee representatives (denoted in Section 1)at the conclusion of the onsite inspection on September 25, 1987. Theinspector summarized the sc. ope and findings of the inspection.

The inspector discussed specific provisions of Regulatory Guide 8.15 ;

concerning physician determinations of persons who were wearing 1respiratory protection devices. In addition, the inspector discussed the i

importance of following procedures for equipment operation in order to jtake advantage of engineering controls that assure minimum exposure.

During the course of the inspection and the exit meeting, the licensee- I

did not identify any documents or inspector comments and references tospecific processes as proprietary.

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