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Docket No . 70-25

UNITED STATES

NUCLEAR REGULATORY COMMISSIONREGION V

1450 MARIA LANE , SUITE 210

WALNUT CREEK , CALIFORNIA 94596

APR 131887

Rockwell International CorporationRocketdyne Divisio nAtomics International6633 Canoga AvenueCanoga Park, California 91304

Attention : Mr. D . J. Sanchini~Vice Presiden t

Gentlemen :

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Subject : Inspection at Atomics Internationa l

This refers to a routine safety inspection conducted by Messrs . B . L . Brock

and P . R . Zurakowski of this office March 9-12, and 26, 1987, of activitiesauthorized by NRC License No . SNM-21 and to the discussion of our findingsheld with members of the staff at the conclusion of the inspection .

Areas examined during this inspection are described in the enclosed inspection

report . Within these areas, the inspection consisted of selectiveexaminations of procedures and representative records, interviews withpersonnel, and observations by the inspector .

No violations of NRC requirements were identified within the scope of this

inspection .

In accordance with 10 CFR 2 .790(a), a copy of this letter and the enclosure

will be placed in the NRC Public Document Room .

Should you have any questions concerning this inspection, we will be glad todiscuss them with you .

Sincerely ,

d 'James L . Montgomer'', Chief

Nuclear Materials Safety and SafeguardsBranch

Enclosure :Inspection Report No . 70-25/87-01

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U . S . NUCLEAR REGULATORY COMMISSION

REGION V

Report No . 70-25/87-01

Docket No . 70-25

License No . SNM-21

Safeguards Group : I

Licensee : Rockwell International Corporation

Rocketdyne Divisio nAtomics International6633 Canoga AvenueCanoga Park , California 91304

Facility Name : Headquarters Site and Santa Susana Field Laboratory

Inspection at : Headquarters Site and Santa Susana Field Laboratory

Inspection Conducted : March 9-12, and 26, 198 7

Inspectors :L . Brock, Fuel Facilities Inspecto r

Approved by :

akowski, Radiation Specialis t

R. 0 . Thomas, Chie fNuclear Materials Safety Section

Date Signe d

Summar :

Inspection on March 9-12, and 26, 1987 (Report No . 70-25/87-01)

Areas Inspected : A routine unannounced safety inspection was conducted ofmanagement organization ; operator training and retraining ; criticality safety ;

operations review ; maintenance and surveillance ; radiation protection ;transportation/radioactive waste management/10 CFR Part 61 ; environmentalprotection ; and emergency preparedness .

During this inspection , Inspection Procedures 88005 , 88010, 88015, 88020,88025 , 83822 , 86740/88035/84850, 88045 and 88050 were covered .

Results : No violations or deviations were identified in the areas inspected .

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DETAIL S

1 . Persons Contacte d

*J . S . McDonald, Director, Atomics Internationa lM . E . Remley, Director, Nuclear Safety and LicensingC . J . Rozas, Director, Health, Safety and Environmen tR . P . Warren, Technical Skills and Development Human Resources and

CommunicationsR . J . Tuttle, Manager, Radiation and Nuclear SafetyW . R . McCurnin, Manager, Nuclear Operation sF. H. Badger, Health and Safety EngineerJ . W. Rowles, Health and Safety SpecialistJ . D . Moore, Health and Safety Enginee rL. E . Rodman, Senior Fire Protection Engineer (Emergency Coordinator)E . Martini, Senior Instructo rB . Dales, Training Specialis tD . Harrison, Staff Chemical Enginee rE . L . Babcock, Assistant Manager , Rockwell International Hot LaboratoryC. Nealy, Member Technical Staf fD. Parker, Shift LeaderF . E . Begley, Health and Safety Specialist Respiratory ProtectionJ . A. Chapman, Health and Environmental Safety SpecialistD . C . Campbell, Member, Technical StaffD . J . Elliott, Assistant Manager , Hot Cell Operations

*Denotes those attending the exit meeting .

2 . Management Organization and Control s

Section 9 of NRC License SNM-21 incorporates Part 1 of the licensee'sapplication and supplements dated October 29 and December 17, 1982,March 2, 7, May 29 and June 12, 1984 as license conditions .

A . Organizational Structure

Section 11 .3 of the license application requires certainorganizational divisions of responsibility to provide a check andbalance system in the important areas of plant safety .

The licensee's organizational structure remains unchanged since therevisions implemented just prior to the previous inspection . Theinstrument calibration group has been added to the Health Safety andEnvironment Department .

B . Procedure Control s

Section 11 .3.4 of the license application requires that changes inestablished procedures must be authorized in advance by appropriatemanagement .

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The Fermi decladding procedure was revised as the result of theinvestigation of the ignition of chips from sawing through zirconiumfuel assemblies in Cell 4 of the Rockwell International HotLaboratory (RIHL) . The revisions were reviewed by the NRC inspectorand were found incomplete (see Section 5B(1)(b)) .

The review of the procedure for packaging solidified grinder coolantand fines in a package using steel shielding instead of lead was

completed . The reduction in the scope of work eliminated decladdingthe fuel therefore no grinding fines will be generated . The project

now involves only disassembly of the fuel assemblies . The waste

packaging problem is now somewhat different ( see details in Section

8 .A) .

No violations were identified .

3 . Operator Training and Retrainin g

Condition 14 of the current license requires that prior to unsupervisedwork with special nuclear material appropriate formal training shall begiven in criticality and/or radiation safety .

A . A review of the licensee' s master training records and discussionswith Training, Radiation and Nuclear Safety, and Building 020

Operations personnel disclosed that all persons had received the

required training prior to working with licensed material . It was

found by the inspector that discrepancies discovered during the last

several inspections in the master training records had been

corrected .

It was also found that the computer print out of the records hasincreased in volume by at least a factor of three due to theaddition of many hundreds of new entries caused by the merger ofseveral divisions in the new Rockwell International organizational

structure . This substantial increase in record volume, the death ofthe former Training Director and the retirement of a key TrainingSpecialist has been detrimental in making the Master Training Record

a completely accurate and viable document . During this current

inspection at least ten discrepancies related to respiratoryprotection training were found . This record disclosed that these

persons had not received the required training . Whereas , a careful

check of secondary records maintained by the Health and SafetySpecialist in charge of respiratory protection training disclosedthat the persons had indeed received the required training . Several

good ideas on how to further improve the master training recordemerged from a discussion with the two training specialists chargedwith the responsibility of maintaining this important record . Item

(85-01 -02) wi_11- remain open for further review .

B . The program for consolidation of the responsibility for therespiratory protection program under one person in the Radiation andNuclear Safety Group was reviewed . It was found that theconsolidation has been completed and is working smoothly . However,because of anticipated annual leave and possible sick leave, a

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second person with expertise in Industrial Hygiene is being trainedas backup to the Senior Health and Safety Specialist now in chargeof the program . This closes item (86-03-03) .

C . The NRC inspectors identified a need for additional training of theoperators . The safety significance of the need to vacuum thezirconium chips generated during the cutting operation while theywere still wet was discussed (see Section 5 .B .(1)(b)) .


4 . Criticality Safety

Section 2 .7 of the license application requires that prior to initiatinga project involving potential hazards, authorization must be obtainedfrom the appropriate Department Director and from designated Safetyand/or Criticality Safeguards personnel in the Health, Safety andRadiation Services Department .

A . Nuclear Criticality Safety Analysi s

Section 4.1 .3 of the license application requires the completion ofa Nuclear Safety Analysis for the Fermi fuel decladding operation .

The required Criticality Safety Study (CSS) and Nuclear SafetyAnalysis (NSA) were completed, reviewed, and approved before startupof the Fermi decladding operation . The scope of the project hasbeen reduced significantly since the previous inspection . The scopecurrently involves only removal of the fuel pins from the fuelassembly and packaging them in groups of 35 as previously planned .Decladding the fuel pins is not included in the reduced scope ofwork .

The Fuels Committee Chairman recently retired . He was a signatoryapproving both the Criticality Safety Study and the Nuclear SafetyAnalysis . The background of the new chairman will be reviewed in aninspection following the appointment (87-01-01) .

B . Fermi Fuel Declad Project

The licensee is limited to "5 kilograms U-235 or enriched uraniumand plutonium in combination not to exceed 5 .0 effective kgcalculated by kg U-235 + (2 .5)(kg Pu) . "

(1) The licensee identified that on February 10, 1987 a transfer oftwo fuel assemblies to the RIHL exceeded the NRC license limit .Security and the Criticality Safeguards Advisor were notifiedafter the two fuel assemblies joined end to end were separated .Operations were stopped at the request of the CritfcalitySafeguards Advisor . Security at the RIHL was reinforced . TheCriticality Safeguards Advisor's review reconfirmed that thecontained U-235 (9 .5 kg) constituted less than half of thecriticality control limit of 22.1 kg U-235 (moderatorcontrolled) ; therefore, this occurrence constituted a violation

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of the license limit of 5 kg U-235 . On obtaining theconcurrence of the Chairman Nuclear Safeguards Review Panelcorrective action was completed . The extra fuel assembly was

returned to the RMDF . The occurrence was reported to the NRCRegion V Safeguards Section Chief by telephone on February 10,1987, the afternoon of the incident, with a follow up letter tothe Region V Administrator on February 11, 1987 . The licenseeundertook an investigation as to the cause of the occurrenceand prepared a procedure to preclude recurrence . It appearedthat the cause was of a nature (one assembly possibly droppedonto another in a storage pit) that corrective action taken fora previous license limit violation (in-cell packaging -inspection report 70-25184-05) would not have been expected topreclude this occurrence .

(2) The Cell 4 posted Work Station Criticality Control Limit of4800 gm U-235, 25 .7% enriched, as 1 assembly or 4 batches . . . had

been exceeded in the occurrence described in the precedingparagraph (4 .B .(1)) . The Nuclear Safety Analysis distinguishesbetween the NRC license limit of 5 kg U-235 and the CriticalitySafety Study derived Criticality Control Limit of 22 .1 kg U-235

(45 percent of a minimum critical mass) .

The Nuclear Safety Analysis includes in section 9 .f, under General SafetyConsiderations, the requirement that, "If any condition develops whichrequires the use of procedures not previously approved, operations willbe halted, and radiation and nuclear safety will be informed . A safeprocedure will be devised to overcome the nonstandard condition .Approval of the interim procedure by Radiation and Nuclear Safety will beaccomplished as expeditiously as is possible . "

The incident documentation indicated that the operators ( a) did not stopoperations when the problem was identified, (b) did not notify Radiationand Nuclear Safety before separating the fuel assemblies , and (c) did not

use a separations procedure that had been reviewed and approved b y

Radiation and Nuclear Safety. The problem did not have the potential to

jeopardize the public health and safety because it involved only 20

percent of a minimum critical mass . However , the licensee 's performance

raises the question of adequacy regarding the retraining in the General

Safety Considerations quoted above . The licensee 's followup of this item

will be - reviewed during the next inspection (87-01-02) .

One violation was identified by the licensee and was expeditiously

corrected. Due to the action taken by the licensee , a citation was not

considered in this case .

5 . Operations Review

Section 2 .1 of the license application requires the licensee`to complywith all the requirements of the regulations, to operate the facilitiesin a safe and efficient manner and within the requirements of all licenseconditions under which the activities are authorized .

A . Decontamination/Decommissioning (D/D)

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License Condition 25 requires that the licensee follow the generaldecommissioning plan submitted in the enclosures to the letter datedMarch 15, 1978 .

(1) Building 055 Nuclear Materials Development Facility (NMDF )

(a) The inspectors included Building 055 during the facilitiestour . The Oak Ridge Associated University (ORAU) team hadcompleted its independent overcheck of the building andgrounds for the NRC . Some additional soil samples weretaken from the drain line trench during the overcheck .The ORAU report is being prepared .

(b) The HEPA filter bank in the Building 055 high volumeventilation system ( breathing air) was removed anddisposed of as radioactive waste .

B . Operation s

(1) Building 020 Rockwell International Hot Laboratory (RIHL )

(a) The Fermi decladding project has undergone a significantreduction in scope . The decladding of the fuel pins bygrinding was eliminated . The operation, now much simpler,also generates much less waste . The dose from wastepackages is expected to be more easily controlled (seeSection 8 .A .) . The licensee disassembled the higher doserate assemblies first . This facilitated shipping thishigher level waste in the NLI 1/2 cask while it was stillavailable . At the time of the inspection approximately 54percent of the 214 fuel assemblies had undergonedisassembly . Disassembly is expected to be completed inMay 1987 . If no additional work develops the DID of theRIHL may start as early as October 1987 .

(b) The licensee experienced burning of some zirconium chipsgenerated in Cell 4 during the sawing phase of thedisassembly operation on October 28, 1987 . Operationswere stopped and the cell was purged with nitrogen toextinguish the chips . The Incident Review Committee thatconvened the next day concluded that the saw blade crepttoward the uranium metal and by friction ignited theuranium chips which were being generated and these in turnignited the zirconium chips that had accumulated in thestainless steel wrapper tube . Process changes to precluderecurrence were initiated by the committee . The inspectornoted that the change involving vacuuming the chips (nowgenerated during wet cutting) before they drietl was notappropriately incorporated in the applicable procedure .The safety significance of the wet vacuuming appeared notto be understood by the operators . The licensee reviewedthe process changes initiated by the committee and agreedthe procedure ( 1530P000005 ) needed further revision toassure that the zirconium chips would be vacuumed whil e

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they were still wet . The procedure revision will bereviewed during the next inspection (open item 86-01-01will therefore remain open ) . Additionally, the licenseewill include the safety significance of the procedurerevisions in an operator training session . The licensee'saction on this item will be reviewed during the nextinspection (87-01-03) .

(c) The inspectors observed the licensee ' s weight basisverification that the 140 fuel pins were being subdividedinto four 35 pin groups . The weighing operation observedgave a measured 35 pin batch weight (clad present) versusa 35 pin batch weight projected from a measured single pinweight . The measured weight was within 0 .3 percent of theprojected weight and would readily indicate a pin countdiscrepancy .


6 . Maintenance and Surveillance Testing

Section 9 of NRC License SN 1-21 incorporates Part 1 of the licensee'sapplication and supplements dated October 29 and December 17, 1982, andMarch 2, 7, May 29 and June 12, 1984 as license conditions .

A . Breathing Air Supply System

The licensee has upgraded the Breathing Air Supply System in theRIHL by adding a backup air pump . Additionally, all regulators areto be replaced with new regulators that will be locked afteradjustment . A metrology number for calibration will be assigned acontrol calibration frequency . The licensee plans to complete theplanned upgrading in recognition of the fact that the system wouldbe needed for cell entries for new contracts or for DID of the RIHL .The status of this project will be reviewed during the nextinspection (87-01-04) .

B . Sewage Treatment Plant

The tour of the onsite sewage treatment plant disclosed nodiscrepancies . The valve controlling release of effluent divertedto the temporary diversion pit was still locked in the closedposition and the key is controlled by the RIHL health physicist .


7 . Radiation Protectio n

Protection against radiation hazards associated with licensed activitiesis required by 10 CFR Part 20 .

A . Tour of Facilities

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(1) The NMDF ( Building 055 ), RIHL (Building 020), Sewage TreatmentPlant and the associated diversion basin , and the RespiratoryProtection Maintenance and Training Laboratory were visited bythe inspector . No violation of good health physics or otherNRC requirements were noted during the tour .

B . External Exposur e

The review of 2nd quarter 1986 through 4th quarter 1986 radiationexposure records disclosed no exposures in excess of regulatorylimits . The highest quarterly whole body exposure noted was 1180mrem . No significant readings were noted on finger ring or visitorfilm badges .

C . Internal Exposure s

The licensee utilizes a bioassay program from U .S . Testing Companyof Richland, Washington . A review of the available records for the2nd through 4th quarters 1986 disclosed no internal exposuresexceeding licensee administrative limits or regulatory limits .During the 1st quarter of 1986 the licensee submitted sixteensamples for plutonium analyses and fifty-three samples for fissionproduct analyses . Of the samples submitted forty-five results hadnot yet been received prior to the last inspection . These recordsand all 2nd, 3rd and 4th quarter records were reviewed during thisinspection. No exposure exceeded licensee administrative orregulatory limits . This closes open item (86-03-08) .

D . Non-Reportable Incident Review

One non-reportable incident which occurred during the 3rd quarter1986 was reviewed . This involved an entry into the large SEFORglove box by a Health and Safety Specialist for the purpose ofdecontaminating the glove box sufficiently so that it could be sen tto another organization . Initial measurements , prior to entry,indicated that if one wore a supplied air hood with associatedsuitable protective garments, the operation could be performedsafely . A lapel air sampler was worn by the person making theentry . The Health and Safety Specialist remained in the glove boxfor approximately twenty-five minutes . Analysi§8of the fir samplerfilter disclosed an air concentration of 7 .8X10 uCi/cm . Thisvalue was much higher than had been expected from the initialmeasurements . The radioactive materials in the glove box wereprimarily mixed fission products, uranium and plutonium . Theincident was handled by the licensee in an appropriate andexpeditious manner . Two bioassays were taken . Both were found tobe at the minimum level of detection . Proper health physicspractices were followed throughout the procedure . No significantinternal or external exposure had been received during he entry .Because of high potential for internal exposure if the air hoodstops functioning properly , this procedure will continue to befollowed as an open item (86-03-01 ) for the next severalinspections . If the licensee decides not to re-enter the glove box,this open item will be closed .

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8 . Transportation/Radioactive Waste Management/10 CFR Part 6 1

Annex "B" of the current license incorporates guidelines for release ofequipment and facilities for unrestricted use . 10 CFR Part 20 .301 toPart 20 .401 regulates the disposal of waste . 10 CFR Part 61 requiresthat all radioactive waste prepared for disposal is classified inaccordance with Section 61 .55 and meets the waste characteristicsrequirements in Section 61 .56 .

10 CFR 20 .311(d)(3) requires that licensees who transfer radioactivewaste to a land disposal facility or licensed waste collector shallconduct a quality control program to assure compliance with 10 CFR 61 .55and 61 .56 .

10 CFR Part 71 regulates the packaging and transportation of radioactivematerial .

A . Waste Managemen t

The disposal of waste generated by the decladding operations in theRIHL was again discussed with the Staff Chemical Engineer in chargeof writing and executing the detailed written procedures necessaryto carry out the disposal operation in a safe and efficient manner .Details of the operation are discussed in Reports 70-25 /86-02 and70-25/86-03 . The original plans called for a concrete and leadshield around a twelve gallon inner container which held thegrinding fines from the Fermi fuel decladding operation . Because ofa recent ruling by the Environmental Protection Agency (EPA), whichin effect prohibits the use of lead as shielding in such cases, thelicensee has experimented with steel as shielding material . TheStaff Chemical Engineer stated that this did not work very wellbecause so much steel was needed to give adequate shielding . Theresulting package was too heavy to meet normal transportationrequirements . It then became necessary to fractionate the grindingfines so that the amount of steel in the shielding could be reduced .The limited quantity of grinding fines on hand were disposed of in asafe manner by fractionating the quantity placed in the twelvegallon containers when necessary . This closes item 86-01-03 .

The centerless grinding operation has since been replaced by sawingthe fuel assemblies into sections and removing the enclosed fuelpins . This operation is performed remotely inside the hot cell .Although the cutting chips and other scrap from this operationcontains far less activity than the centerless grinding operationproduced , a safe and efficient packaging method must still bedesigned and put into practice . The Staff Chemical Engineer statedthe packaging will be similar to that designed for the centerlessgrinding fines . However , the packaging will be significantlydifferent ; therefore , the package will have to be provenexperimentally and a detailed procedure written . The experimentalpackages are expected to be tested in the next few weeks . The StaffChemical Engineer stated that no packages will be disposed of unti l

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the written procedure has been completed and approved . Thelicensee ' s progress in this area will be reviewed during the nextinspection (87-01-05) .

B . Transportation and Part 6 1

Because both the Manager, Nuclear Safety and Licensing and theTransportation Manager were on travel, it was not possible tocomplete this section . The Manager, Radiation and Nuclear Safetystated that in his opinion no shipment of radioactive material underNRC jursidiction had occurred since the last inspection . However,he could not be sure because he did not have access to the records .Therefore these items will be reviewed during the next inspection(87-01-06) .


9 . Environmental Protectio n

Title 10 of the Code of Federal Regulations , Part 20 .106 "Radioactivityin Effluents to Unrestricted Areas" requires that licensees control theiroperations to preclude releasing radioactive material in concentrationsexceeding the limits specified in Appendix B, Table II of Part 20 .

The licensee ' s semi-annual effluent reports for January 1, 1986 throughJune 30, 1986 and July 1, 1986 through December 31, 1986 continue toreflect effluent streams contamination levels less than NRC releaselimits (10 CFR Part 20, Appendix B) .

The results from the analyses of the two samples taken from the temporarydiversion pit, and reported in Table I of the previous report,(70-25/86-03) were below NRC release limits . Item (86-01-04) istherefore closed .


10 . Emergency Preparednes s

License Condition 24 requires the licensee to maintain and execute theresponse measures in accordance with the Radiological Contingency Plansubmitted to the Commission on August 28, 1981, as revised on March 3,

1982 . Additionally , Appendix A to the Radiological Contingency Plan

states that the Master Emergency Plan has been approved as part of thelicense .

A . The fire extinguishers checked on a tour of the facilities had allreceived their monthly inspections . The housekeeping in all of theareas visited was good .

B . The licensee conducted the annual evacuation and training exercisefor Building 020 on June 26, 1986 . The drill was observed byrepresentatives of Ventura County Emergency Planning and theCalifornia State Department of Public Health . The licensee'scritique held immediately after the drill was attended by ten of the

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licensee's employees and the California State, Department of Healthand Safety representative . Nine items needing attention wereidentified and responsibility for each was assigned . Eight of theitems were followed up by October 30, 1987 . The final item,installation of a RADIAX cable in Building 020, was completed andtested since the onsite inspection . The anticipated improvement in

communications with emergency team members was achieved . This

closes item 86-03-07 .


11 . Exit Meeting

The results of the inspection were discussed with the licensee 's staff

identified in Section 1 .

The topics discussed included :

° The violation identified , reported (though not required), andexpeditiously corrected by the licensee ;

° The status of the previous open items :

Closed

(86-01-03) Review Fermi container dose control ;(86-01-04) Sampling unlined diversion pit ;(86-03-03) Review planned consolidation of the respiratory

protection program ;(86-03-07) Review status of corrective actions for problems

identified during the June 26, 1986 drill at Building 020 ; and

(86-03 - 08) Review second quarter (1986 ) bioassay results .

Open

(85-01-02) Training records accuracy ;(86-01-01) Review approval of Fermi procedures ;(86-03 -01) Review airborne concentration levels during alpha glove

box entries ;(86-03-02) Review program of replacement of RIHL ventilation system

fans ;(86-03-04) Review status of the plans to color code dosimeters(86-03-05 ) Review licensee ' s plans regarding use of TLDs or

shortening the use period of film badges(86-03-06 ) Review licensee ' s plans for training ancillary workers ;

New

(87-01-01) Review background of new Fuels Committee Chairman when

appointed ;(87-01-02) Review the retraining relative to actions to be taken

when nonstandard operation conditions are encountered ;

(87-01- 03) Review the retraining provided relative to the safety

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significance of vacuuming the zirconium chips while wet ;

(87-01-04) Review the status of the upgrading of the Breathing AirSupply System ;

(87-01-05 ) Review the licensee ' s new packaging for the coarsezirconium sawing chips ;

(87-01-06) Review records of shipments made under NRC jurisdiction .

° The changing status of the training records and the staffresponsible for them ;

° Assuring that procedures in use are current ; and

° Independent audits of the Master Emergency Plan and the RadiologicalContingency Plan by persons not having emergency responsibilities .

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