IR 05000201/1978009

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IE Insp Rept 50-201/78-09 on 781115-17.Noncompliance Noted: Failure to Follow Survey Procedures & Failure to Record Air Sample Evaluation
ML19269C636
Person / Time
Site: West Valley Demonstration Project
Issue date: 12/15/1978
From: Clemons P, Crocker H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19269C629 List:
References
50-201-78-09, 50-201-78-9, NUDOCS 7902070011
Download: ML19269C636 (9)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-201/78-09 Docket No. 50-201 License No. CSF-l Priority

Category RP Licensee:

Nuclear Fuel Services, Incorporated 6000 Executive Blvd.

Rockville, Maryland 20352 Facility Name:

West Valley Reprocessing Plant Inspection at:

West Valley, New York Inspection conducted: November 15-17, 1978 Inspectors: [M

/M5h P. E. Clemons, Radiation Specialist date signed date signed date signed Approved by:

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/,.2/ f / p

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H. W. Crocker, Acting Chler, Radiation date' signed Support Section, FF & MS Branch Inspection Summary:

Inspection on November 15-17,1978 (Report No. 50-201/78-09)

Areas Inspected:

Routine, unannounced inspection by a regional based inspector of the Radiation Protection Program including: respiratory protection, dosimetry, bioassay, smears, radiation surveys, air samples, organization, audits, instrument calibration, special work permits, leak tests, ventilation, procedures, posting, training, annual reports, and termination reports.

Shortly after arrival, areas where work may have been performed were examined to review radiation control procedures and practices.

The inspection involved 18 inspector-hours on site by one regional based NRC inspector.

Results: Of the 17 areas inspected, no items of noncompliance were identified in 15 areas. Apparent items of noncompliance were identified in two areas to maintain records, paragraph 4) procedures, paragraph 3; Deficiency - failure (Infraction - failure to follow

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Region I Form 12 (Rev. April 77'

DETAILS 1.

Persons Contacted Principal Licensee Employees

  • Mr. W. Oldham, General Manager
  • Dr. A. Pierce, Operations Manager
  • Mr. R. Smokowski, Health and Safety Manager Mr. C. Seitter, Quality Assurance Supervisor
  • Mr. G. Metzler, Health and Safety Specialist
  • Mr. D. Tharnish, Health and Safety Specialist The inspector also interviewed several other licensee employees during the course of the inspection. They included the Assistant Operations Manager and Health and Safety Personnel.
  • denotes those present at the exit interview.

2.

Licensee Internal Audits Technical Specification 7.1.6 states " Audit of Operations.

Manage-ment shall provide for periodic audits of the operations... with regard to radiological and nuclear safety.

These audits shall be performed by competent company or other technical personnel not directly responsible for the operation audits."

The inspector reviewed an audit report of the Health and Safety Program which stated that the required audit was conducted by a company representative, who was not directly responsible for the operation audited, on April 19-21, 1978.

The most recent audit, prior to this one, was performed in April 1977 according to docu-mentation reviewed by the inspector.

The inspector also reviewed recort. of audits of the radiation protection program conducted by the Quality Assurance Department as required by Section 1.2.4 of the Health and Safety Manual, developed pursuant to Section 7.1.4 of the Technical Specifications.

The period reviewed was March-September 1978.

No items of noncompliance were identifie.

procedures Technical Specifications 7.1.4 states, " Detailed written procedures...

shall be provided for operation of the plant.

In addition, procedures for handling abnormal operating conditions, and for radiation protection shall be provided."

Section 8.0 of the Health an Safety Procedures Manual, developed pursuant to Technical Specification 7.1.4, requires rcutine surveys be made on a scheduled frequency.

The inspector observed that Tables 8.15(b) and 8.17 of Section 8.0 of the Health and Safety Manual, developed pursuant to Technical Specification 7.1.4, requires that weekly smear surveys for alpha contamination be made in the Instrument Shop; requires that quarterly smear surveys for alpha contamination be made in the Annex Building; requires weekly beta-gamma radiation surveys be made in the Emission Spec Laboratory and in the Mass Spec Laboratory.

The Introduction to the Health and Safety Manual requires each Department Manager at NFS to be responsible to assure that all personnel within his department comply with the provisions in the Manual.

As the inspector reviewed appropriate survey records he noted that contrary to the requirement, the licensee did not conduct smear surveys for alpha contamination, as required, in the Instrument Shop and the Annex Building during 1978.

The licensee did not perform beta-gamma radia. tion surveys in the Emission Specs Laboratory and the Mass Spec Laboratory, as required during 1978 as determined by the inspector as he reviewed appropriate records.

The inspector was told by a licensee representative that the surveys had not been performed because he was not aware of the requirement.

These findings represent noncompliance with Technical Specification 7.1.4. (201/78-09-01)

4.

Records The inspector observed that a SWP operation was performed on May 10, 1978 in which absolute filters were changed in the Ventilation Exhaust Cell (Electric Side).

The inspector noted that the SWP monitoring requirements required that an air sample be taken.

The inspector asked a licensee repre-sentative if the air sample was taken, and the licensee representa-tive stated that the air sample was collected and evaluated.

The inspector asked to see the documentation of the evaluation.

The licensee representative stated that the result of the survey was not recorded.

10 CFR 20.201(b), " Surveys," require that "Such surveys be :onducted as may be necessary to comply with the regulations contained in each section of Part 20."

10 CFR 20.401(b), " Records of surveys, radiation monitoring and disposal" states "Each licensee shall maintain records in the same units used in this part showing the results of surveys required by 20.201(b)..."

The inspector noted that failure to maintain records constituted noncompliance with the regulatory requirements. (201/78-09-03)

5.

Respiratory Protection The licensee is authorized to use respiratory protective equipment, and the licensee makes allowance for the use of such equipment, therefore, the licensee is required to comply with Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection." The inspector reviewed certain aspects of the licensee's respiratory protection procedures to determine if the licensee was in compliance with the requirements.

No items of noncompliance were identified.

6.

Dosimetry The inspector reviewed dosimetry records for the period January to July 1978 to determine whether the licensee was in compliance with the regulatory requirements.

The records of approximately forty employees were reviewed, and in each instance the exposures were well within the permissible limits.

No items of noncompliance were identifie.

Bioassay Section 4.2 of the licensee's Health and Safety Manual, developed pursuant to Technical Specification 7.1.4 requires annual bioassay samples be taken from employees.

The licensee collects urine samples to satisfy this requirement.

The inspector noted that urine samples were collected from employees during December 1977 and January 1978. The samples were sent to a vendor to be analyzed in February 1978 according to a licensee representative.

The licensee had not received the results of the urine analyses at the time of this inspection.

The inspector noted that an inordinate amount of time had elapsed since the samples were shipped to the vendor.

The licensee representative stated that they have been having difficulty in receiving sample results from this vendor in a reasonable amount of time.

No items of noncompliance were identified.

8.

Smears The inspector reviewed smear survey records to assure compliance with Section 5.1 of the Health and Safety Manual for areas other than those stated in Item 3 of this report.

The period reviewed was January to September 1978.

'No items of noncompliance were identified.

9.

Radiation Surveys The inspector reviewed external beta-gama radiation survey records for the period January to September 1978 to assure compliance with Section 5.1 of the Health and Safety Manual for areas other than those stated in Item 3 of this report.

No items of noncompliance were identified.

10.

Ventilation Technical Specification 6.5.1 requires certain filters be tested, if they are changed and prior to routine service, with particulates of appropriate size to establish that the installed filters provide a collection efficiency of 99.95% for particulates 0.3 microns in diameter or larger._ The inspector reviewed appropriate records and observed that absolute filters (IST-49 and IST-49A) changed on May 10,1978 and May 11, 1978 had been DOP tested as require.

On Thursday, November 16, 1978, the inspector requested that velo-city measurements be made across the faces of hoods located in the QC and Standards Laboratory and the Process Control Laboratory.

A licensee representative performed the measurements using the licensee's velometer on six hoods located in the two laboratories.

The measured linear velocities across the face of five hoods was approx-imately eighty feet per minute, and the linear velocity across the face of the sixth hood was approximately sixty feet per minute.

This fact was mentioned to the General Manager at the exit inter-view, and he stated that this has been a continuing problem for them.

No items of noncompliance were identified.

11.

Annual Report 10 CFR 20.407(b) requires licensee's to submit perronnel exposure and monitoring reports to the Director of Inspection and Enforce-ment, USNRC, within the first gr-rter of each calendar year.

The inspector reviewed the licensee's report submitted to the Director on February 9,1978.

No items of noncompliance were identified.

12.

Termination Report 10 CFR 20.408 states: "When an individual terminates employment with a licensee subject to 5 20.407, or an individual assigned to work in such a licensee's facility, but not employeed by the licen-see, completes his work assignment in the licensee's facility, the licensee shall furnish to the Director of Inspection and Enforce-ment, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, a report of the individual's exposure to radiation and radioactive material, incurred during the period of employment or work as-signment in the licensee's facility, containing information re-corded by the licensee pursuant to 55 20.401(a) and 20.108.

Such report shall be furnished within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier."

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10.CFR 20.409(b) states: "When a licensee is required pursuant to 5 20.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual.

Such notice shall be transmitted at a time no later than the transmittal to the Commission, and shall comply with the provisions of 519.13(a) of this chapter."

The inspector reviewed documentation which indicated that the required report had been sent to the Director, and to the indi-vidual who terminated employment on July 3, 1978.

The report was dated October 2, 1978.

No items of noncompliance were identified.

13.

Instrument Calibration

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Section 5.3 of the Health and Safety Manual, developed pursuant to Section 7.1.4 of the Technical Specifications, describes certain instruments and the requirement that the instruments be calibrated.

The inspector reviewed the schedules established for instrument

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calibration, and selected approximately ten portable survey instru-ments to determine if they had been calibrated at the scheduled frequency during the period January to September 1978.

No items of noncompliance were identified.

14.

Posting The inspector reviewed the facility posting against the require-ments of 10 CFR 19 and 10 CFR 20, and observed that the licensee was in compliance with the regulations.

During a tour of the facilities on November 15, 1978, the inspector noted that an area designated as the "Hard Stand" area was posted as a contaminated area, but some of the signs had faded to the extent that the colors could not be determined, and the words were difficult to read.

A licensee representative replaced the faded signs prior to the conclusion of the inspection.

No items of noncompliance were identifie. Training Section 5.4 of the Health and Safety Manual, developed pursuant to Section 7.1.4 of the Technical Specification states "...Self-monitoring certification tests are given by the Health and Safety Special!sts and are valid for a period of one year.

Certification is renewed at the end of the lapse period through reexamination by Health and Safety Specialists."

The inspector reviewed the annual re-certification test that was administered by a Health and Safety Specialist for thirteen em-ployees during the period January to February 1978.

The inspector also reviewed the records of 27 enployees who had received training in respiratory protection during the period January to May 1978.

No items of noncompliance were identified.

16.

Plant Safety Committee The Plant Safety Committee is required to review and approve all standard operating procedures as stated in Section 7.1.1.6 of Technical Specifications.

The inspector reviewed minutes of Plant Safety Committee meetings that were held on August 4,1978, Sep-tember 28, 1978, and November 9, 1978.

The inspector reviewed Standard Operating Procedure 02-5, Revision 8, Centrifuge and Drumming Station Operations that was approved during the meeting on November 9, 1978.

The Committee had fourteen meetings during the period January -

November 1978.

No items of noncompliance were identified.

17.

IE Bulletin No. 78-07 In response to IE Bulletin No. 78-07, a licensee representative called the Region I inspector on or about June 15, 1978 and in-formed him that the contents of the bulletin were not applicable.

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The inspector reviewed an internal memo during the inspection in which the General Manager was informed that the existing respira-tory protective equipment operated in the continuous flow mode.

18.

Exit Interview The inspector met with licensee respresentatives (denoted in para-graph 1) at the conclusion of the inspection on November 17, 1978.

The inspector summarized the purpose and the scope of the inspection, and the findings as presented in this report.