IR 05000201/1980006
| ML19345H185 | |
| Person / Time | |
|---|---|
| Site: | West Valley Demonstration Project |
| Issue date: | 01/16/1981 |
| From: | Clemons P, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19345H179 | List: |
| References | |
| 50-201-80-06, 50-201-80-6, NUDOCS 8105010182 | |
| Download: ML19345H185 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 80-06 Docket No. 50-201
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License No. CSF-1 Priority
Category RP Licensee:
Nuclear Fuel Services, Incorporated Suite 600, 6000 Executive Boulevard Rockville, Maryland 20352 Facility Name:
West Valley Reprocessing Plant Inspection at:
West Valley, N.Y.
Inspection conducted:
October 15-17, 1980 Inspectors: [
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em P. Clemons, Radiation Specialist date' signed
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date signed c
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d te igned
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Approved by:
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P. J. Knapp,' Cli'ief, Radiation Support
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Section, FF&MS Branch Inspection Summary: Inspection on October 15-17, 1980 (Report No. 50-201/80-06)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the Radiation Protection Program including: outstanding items, special work permits, organization, facilities and equipment, posting and labelling, dosimetry /
bioassay, audits, radiation surveys, smears, terminations, training, leak-test, air samples, ventilation, procedures, material released for unrestricted use and D0P tests. Shortly after arrival, areas where work may have been performed were examined to review radiation control procedures and practices.
The inspec-tion involved 18 inspector-hours onsite by one regional based inspector.
Resul ts : Of the 18 areas inspected, no items of noncompliance were identified in 16 areas. Two apparent items of noncompliance were identified in two areas (Infraction - special work permit not signed by supervisor - paragraph 3; Deficiency - radiation survey results not documented - paragraph 4).
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Region I Form 12 (Rev. April 77)
810 5010 l41
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DETAILS l
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Persons Contacted
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Mr. J. Duckworth, General Manager l
Mr. G. Metzler, Health and Safety Supervisor l
Mr. E. Riethmiller, Training Coordinator l
Mr. C. Seitter, Quality Assurance Supervisor l
Mr. R. Smokowski, Health and Safety Manager The inspector also interviewed other licensee employees during the course of the inspection.
They included the Operations Manager, the Assistant Operations Manager, and Health and Safety personnel.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (201/80-03-01):
Failed to whole body count three employees.
The inspector reviewed documents that indicated that the three employees j
had been counted as of June 27, 1980.
3.
Special Work Permit As the inspector reviewed completed Special Work Permits (SWP) for the period January through September for completeness he noted that an SWP dated September 2, 1980 had not been signed by an Operations Supervisor or Analytical supervision.
The inspector asked if the supervisor was required
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to sign the SWP thereby indicating his approval of the work assignment.
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was told Operations, Maintenance, or Analytical Supervisors are required to
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sign the SWP.
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The inspector asked if entry had been made into the SWP area, and he was told that apparently two operators had entered the area because they had signed the back of the SWP.
j The inspector noted that the work description was to " Dump media into Tank", in the Water Treatment Area located in the Fuel Receiving and Storage Area, a high radiation area.
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Technical Specification 7.1.4 states, " Detailed written procedures, run
sheets, letters of authorization and extended work procedures shall be provided for operation of the plant.
In addition, procedures for handling
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abnormal operating conditions and for radiation protection shall be provided."
Item 3.4 of Section 3, Special Work Permit (SWP), of the Health and Safety
Manual, developed pursuant to the above states, "All entries into zone 4 j
areas or high radiation areas require a Special Work Permit...
Before entry is made, Health and Safety and Operations supervision or Analytical
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supervision must approve the SWP.
In the case of Maintenance entries Health and Safety, Operations supervision and Maintenance supervision must approve the SWP.
The individual entering under the SWP must also sign the form indicating he understands and intends to comply with the stated require-ments."
The inspector stated that inasmuch as an entry had been made into a high radiation area on September 2, 1980 under SWP No. 9491, and the SWP had not been signed by the app'ropriate supervisor, denoting his approval, this represented noncompliance with a license condition. (80-06-01)
4.
Records 10 CFR 20.101(a), " Radiation dose standards for individuals in restricted areas," requires licensees to maintain total occupational dose to employees within specified limits.
10 CFR 20.201(b), " Surveys" states "Each licensee shall make or cause to be made such surveys as may be necessary... to comply with the regulations in this part.."
10 CFR 20.201(a), " Surveys" states "As used in the regula-tions in this part " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal or presence of radio-active materials, or other sources of radiation under a specific set of conditions..,.
I 10 CFR 20.401(b), " Records of surveys, radiation monitoring and disposal" l
states "Each licensee shall maintain records in the same units used in this part showing the results of surveys required by 20.201(b)..."
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As the inspector toured the facility on October 15, 1980, he observed approximately five fifty-five gallon drums in the Analytical Aisle hallway near Cell No. 5, and he also saw lead shielding material at the window of Cell No. 5.
The inspector asked what operations were going on, and he was told that some zinc bromide (shielding material) had been removed from the Cell No. 5 window and' had been replaced with water.
The inspector asked if radiation surveys had been made as the operations were in progress.
He was told that surveys were made continuously to assure that exposures
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were within the regulatory limits.
He was told that dose rates up to 100 mrem /hr were observed in the area immediately adjacent to the window of
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Cell No. 5.
The inspector asked to iee the survey results, and he was told
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by the Health and Safety Supervisor that the survey data had not l
been documented.
The inspector noted that failure to maintain survey records represents non, compliance with 10 CFR 20.401(b).
(80-06-02)
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5.
Licensee Internal Audits Technical Specification 7.1.6 states, " Audit of Operations Management 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 audited."
The inspector reviewed an audit report of the Health and Safety Program which stated that the required audit was conducted by a corporate staff member who was not directly responsible for the operation audited, on July.
22-23, 1980.
The inspector also reviewed records of audits of the radiation protection program conducted by the Quality Assarance Department as required by Section l
1.2.4 of the Health and Safety Manual, developed pursuant to Section 7.1.4 l
of the Technical Specifications.
The records reviewed were for the period January-July, 1980.
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No items of noncompliance were identified.
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6.
Dosimetry The inspector reviewed dosimetry records for approximately 30 employees for the period January through June 1980 to determine if the licensee was in compliance with the regulatory requirements.
The records indicated the exposures for the period reviewed were well within acceptable limits.
No items of noncompliance were identified.
7.
Termination Report 10 CFR 20.408 states:
"When an individual terminates employment with a l
licensee subject to Section 20.407, or an individual assigned to work in such a licensee's facility, but not employed by the licensee, completes his work assignment in the licensee's facility, the licensee shall furnish to the Director of Inspection and Enforcement, 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 assignment in the licensee's facility, containing information recorded by the licensee purusuant to Sections 20.401(a) and 20.108.
Such report shall be furnished within 30 days after the exposure of the individual has been snar the date of termination of determined by the licensee or 90 d%
employment or work assignment, whichever is earlier."
10 CFR 20.409(b) states:
"When a licensee is required pursuant to Section 20.405 or Section 20.408 to report to the Commission any exposure of an
l individual to radiation or radioactive material, the licensee shall also l
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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 Section 19.13(a) of this chapter."
The inspector reviewed documentation which indicated that the required reports had been submitted to the Director and to the two individuals who terminated employment with the licensee in October 1979 ed July 1980.
No items of noncompliance were identified.
8.
Facilities and Equipment l
The inspector toured the facilities and examined equipment and instrumen-tation to verify that the items were available for use and maintained in an operable state. The inspection included examination of continuous air monitors, survey meters, the stack monitor, and area monitors.
No items of noncompliance were identified.
9.
Posting and Labeling The inspector reviewed the facility posting against the requirements of 10 CFR 19 and 10 CFR 20, and observed that the licensee was in compliance with the regulations.
The inspector also observed that high radiation areas were locked and posted, and radiation areas were posted as required. The l
entire facility was posted in compliance with the regulations.
No items of noncompliance were identified.
10.
00P Test Technical Specification 6.5.1 requires certain filters be tested (if they are changed) 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 noted that absolute filters on two systems had been changed in September 1980.
The records indicated th'at the filters were tested, and the efficiency exceeded 99.95%.
No items of noncompliance were observed.
11.
Plant Safety Committee i
The Plant Safety Committe is required to review and approve all standard
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operating procedures annually as stated in Section 7.1.6 of the Technical Specifications. The inspector reviewed minutes of Plant Safety Committee
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meetings for the period January-July 1980.
The minutes indicated that numerous optrating procedures were reviewed and approved during the period Janua'y-July 1980.
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No items of noncompliance were ir%ntified.
12.
Training During 19J0 the licensee hired one new employee to work in the restricted area.
The inspector asked a licensee representative to demonstrate that the employee had received appropriate training as required by 10 CFR 19.12.
The inspector was given documentation for the individual that indicated that he had received the required training.
In addition the inspector was informed that outside contractor personnel had been onsite working at the burial site.
The inspector was given the names of contractor personnel, and he asked the Training Coordinator to demonstrate that the contractor personnel had also received the appropriate training as required by 10 CFR 19.12.
The inspector was given documentation that indicated that the contractor personnel received the required training.
No items af noncompliance were identified.
13.
Routine Surveys Section 5.1 of the Health and f afety Manual, developed pursuant to Technical Specification 7.1.4, states that the Health and Safety Department routinely monitors for smearable contamination, radiation levels and airborne concen-trations.
The inspector reviewed appropriate records for the period January - August 1980 to determine if the licensee was complying with the license condition and also to determine that no regulatory requirements were being exceeded.
No items of noncompliance were identified.
14.
Bioassay Section 4.2.b of the licensee's Health and Safety Manual, developed pursuant to Technical Specification 7.1.4, requires that annual bioassay samples be taken from radiation workers to determine if any long term buildup of plutonium has occurred.
The inspector reviewed urine data for about twelve radiation workers to assure that they were participating and also to determine if there may be problem areas.
No items of noncompliance were identified.
15.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on October 17, 1980.
The inspector summar-ized the purpose and the scope of the inspection and the findings as presented in this report.
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