ML19261C047
| ML19261C047 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 01/26/1979 |
| From: | Book H, Cooley W, Fish R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19261C043 | List: |
| References | |
| 70-0025-78-08, 70-25-78-8, NUDOCS 7903140475 | |
| Download: ML19261C047 (8) | |
Text
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U. S. !!UCLEAR REGULAT0?Y COMMISS10il 0FFICE OF IllSPElTIOil A!;D EilFORCEMEllT REGIO!! 'V Report lio.
70-25/78-08 Docket flo.
70-25
__ License flo..Sr;M-21 Safeguards Group 1
Licensee:
Energy Systems Group Rockwell International Inc.
Canoga Park, Califor:11a 91304 Facility llame: Headquarters Site and fluclear Development Field Laboratory Inspection at: Headquarters Site liovember 21, 1978 and flovember 28-December 1,1978 Inspection Conducted:
Inspectors:
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//,as'//f U. J. ' Cooled Fuel Facilities Inspector
/ Date Signed
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- 0. C. Shackleton, Investigator
' Date Signed M
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Other Accompanying Personnei:
V,im S. Wong, Calif. Division of Occupational Safety and Healt Administration
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irt Approved By:
H. E. ' Book, Chief, Fuel Facility and Materials Date Signed Safety Branch Summary:
Inspection on flovember 21, 1978 and flovember'28-December 1,1978 hoort flo. 70-25/78-08 Areas Inspected:
The inspection was made primarily with regard to a complaint by licensee employees concerning possible exposure to radio-active materials. The complaint was issued to the California Division of Occupational Safety and Health Administration along with drafted notes by the attorney representing the complainants.
The substance of the complaint was that exposure to radiation may have caused illness experienced by one of the employees and that the employees had not been properly traired or furnished proper protective clothing cnd equipment to perform their job assignments.
Because the employees' work assignments placed them in areas of the licensee's facility which are under the IE:V Form 219 (2)
Energy Systems Group -
Docket No. 70-25/78-08 Summary:
(Cont.)
jurisdiction of NRC licensing and in other areas which are under the jurisdiction of State of California licensing, both agencies assigned representatives to review the matter.
The inspection included reviews of the licensee's radiation safety plans, work schedules, work procedures, commitments, and Restricted Area Access Entry Permits as they pertain to the complainants' work assignments.
The inspection also included reviews and discussions with licensee representatives concerning supervisor, senior worker, and health physics technician attendance during those work assignments as well as on-the-job and formal health and safety training provided to the complainants.
The reviews included typical airborn contamination, personnel monitoring, and bioassay data experience with that type of work assignment.
This inspection involved 54 inspector-hours onsite by three NRC repre-sentatives.
Resul ts :
The inspection resulted in the conclusion that the complainants had not been exposed to radioactive material internally or radiation levels externally in excess of the limits of 10 CFR 20. A further conclusion of the inspection was that the complainants had been provided adequate protective clothing including respiratory protective devices to perform the assignments safely.
A further conclusion of the inspection was that the complainants had received sufficient training and monitoring to perform their job assign-ments in a safe manner.
No items of apparent noncompliance or deviations were observed within the scope of the inspection.
DETAILS 1.
Persons Contacted Complainant A Complainant B Attorney for Complainant A and B
- R. G. Jones, Vice President and Controller, Finance and Administration
- M. E. Remley, Manager, Health Safety and Radiation Services Department
- R. J. Tuttle, Manager, Radiation and Nuclear Safety Unit and Criticality Safeguards Advisor J. D. Moore, Radiation and Nuclear Safety Unit R. R. Garcia, Criticality Safeguards Coordinator and Health Physicist F. W. Begley, Health Physics Representative, Building 001 J. L. Bunch, Manager, Plant Engineering F. Aguirre, Manager, Maintenance and Repair W. Flowers, Air Conditioning, Maintenance and Repair C. A. Parker, Manager, Training E. Martini, Training Specialist
- Denotes attendance at exit meeting.
2.
Form of Complaint A complaint of unsafe and/or unhealthful conditions was issued to the Division of Occupational Safety and Health Administration by the attorney for the complainants on November 3,1978.
That com-plaint was accompanied by the attorney's notes on the subject.
State authorities of the Division of Occupational Safety and Health recognized possible U.S. Nuclear Regulatory Commission interest in the substance of the complaint and forwarded that information to U.S.N.R.C. at Region V on November 9,1978.
A fair statement of the complaint is that the employees (A and B) worked with radioactive materials and did not have the proper training, clothing, and protective equipment. One employee (B) began experiencing headaches, backaches and diarrhea after possible radiation exposure. The above summary is generated from the com-plaint form CAL / OSHA 7 dated November 3, 1978, the attorney's notes, and NRC discussions with Complainant A and B and their attorney.
3.
Description of Work with Radioactive Materials by the Complainants Based on statements in the complaint material and discussions with licensee representatives, the complainants were involved with radioactive materials only in connection with filter change oper-ations. The high efficiency particulate air filters which were
-2 changed are housed in large plenum chambers and are used to filter the air exhausted from various laboratories and manufacturing areas to the environment.
The filter changing operation is a team effort usually involving four or five individuals each with a specific assignment.
Custom-arily there is an individual who removes the filters one at a time and brings them to the door of the plenum. That individual is referred to as the "inside man."
The second individual receives the filter at the plenum door in its cardboard box and seals the box with masking tape. That individual is referred to as the "outside man."
Two additional individuals, who are assigned to wrap the sealed cardboard box in a plastic sheet are located some distance from the plenum.
Those individuals are referred to as
" wrappers." An additional individual might be assigned to the team as either an insiae man or outside man.
The filter change personnel described above are drawn from the Plant Engir.eering.
Additionally, each filter change is monitored by a health physics technician from the Health, Safety and Radiaticn Services Department and, according to licensee representatives, a supervisor from Plant Engineering.
Duties of the health physics technician include assurance that the proper protective clothing and respiratory protective devices are worn, assurance that adequate contamination surveys are made to control the spread of contamination and to determine any contamination of personnel, and to provide final personnel and facility contamination surveys at the conclusion of the work.
The responsibility of Plarjt Engineering supervision is to direct the filter change operations for the purpost. of safety and efficiency.
4.
Filter Change Work Schedule This inspection included a review of filter change assignments for the year 1978 through Hovember.
That information was assembled from Plant Engineering records and included the date of assignment, the location (filter plenum) of the change, and the names of the employees assigned to the filter change in each case.
Those work assignments included complainants A and B and agreed substantially with their attorney's notes mentioned in Section 2 above.
5.
Restricted Area Access Entry Permits During this inspection it was observed that the licensee had issued a Restricted Area Access Entry Permit (PAAEP) for each filter change operation which occurred in 1978 through the month of November.
Those RAAEPs were issued in accordance with Condition 14 of the subject license.
Entry permits are written instructions to employees specifying the type of protective equipment and personnel moni-toring equipment required to do a specific job. The entry permits include the job description, location, and date as well as the signature approval of the supervisor of the group performing tha work and the approval signature of the Health, Safety and Radiation Services Department representative in attendance at the work.
The instructions on the entry permits as to protective equipment and personne' monitoring equipment required are directed spriifically to employet.3 identified by name and initial on the permit.
A review of entry permits for filter change operations during 1978 through flovember indicated agreement with the complainants' attornay's notes. That is, on those occasions when the complainants indicated they had worn proper protective clothing, the corresponding entry permit indicated that they were instructed to do so.
On the other hand, on those occasions when the complainants stated they were not wearing protective clothing, no special instructions to do so appeared on the corresponding entry permit.
Discussions with licensee representatives, including the health physics technicians who were in attendance during the filter changes, indicated that the protective clothing requirements on a specific filter change job are at the discretion of the health physics technician.
For example, filter changes in filter plenums 401 and 402 located on the roof of Building 4 are only slightly contamin-ated and in the judgement of the health physics representative, no special protective clothing or devices are required for the
" wrappers" on the filter change team.
Conversely, the filters and filter plenum identified as EF-15 and serving the powder prepara-tion area of the fuel manufacturing facility is known to be highly contaminated.
For changes of filters in that plenum all personnel involved are r.luired to wear special clothing and equipment.
Condition 18 of the subject licensa requires that radiation safety plans, addressing all appropriate aspects of radiation safety, shall be prepared to cover all activites with special nuclear material. The licensee has prepared a radiation safety plan for Advance Test Reactor (ATR) fuel fabrication identified., supporting docu N n:f1065SRR205-003.
Portions of that. plan are addressed to fC ter changing operations including required protective clothing and equipment. Additionally, the licensee has prepared a detailed fili.er change procedure which addresses, among other items, the required protective equipment for personnel working inside the filter plenum and for personnel working outside the filter plenum.
A review of those procedures indicated that the licensee is pro-viding adequate protective clothing and equipment to employees and specifically to the complainants for the type of work to which they were assigned.
6.
Radiation Monitoring The licensee conducts a number of programs to determine exposure to employees. They include a bioassay program utilizing uranium radiometric and fluorometric urinalysis and in vivo lung counts to determine inhaled material; an air sampling program to determine airborne concentration of radioactive naterials 3 and a personnc's monitoring program using film badges to determine exposure to external radiation.
During this inspection, records of bioassay results were reviewed for 13 employees including the complainants. That review covered the year 1978 through September.
The employees selected for that review were those who had participated in filter change operaticns during 1978. A total of 42 analyses were made including two in vivo lung counts. The results of those analyses were invariaXly at/or less than the minimum detection limits for the analysis indicating that no substantial inhalation or ingestion of radio-active materials had occurred among the filter change team members specifically including the complainants.
This inspection included a review of personnel (lapel) air sample data for three members of the filter change teams including one of the complainants. A total of seven analyses were included in the review which extended over data dating from January through August 1978. Themaximumindividualexposure,takingint30
~ account a respiratory protection factor of 50, was 2.1 x 10 uCihr/cc.
Thatexposurecompayswiththemaximumpermissible40hourexposure for U-235 of 4 x 10 uCihr/cc.
This inspection included a review of personnel dosimeter records for 13 employees who had participated in filter changes including one of the complainants.
The review covered the year 1978 through the third quarter.
In all cases the personnel dosimetry results indicated minimal exposure to both beta and gamma radiation.
The maximum year to date whole body exposure through the third quarter was 50 mrem. The results of that review indicate that minimal exposures to beta and gamma radiation are experienced by individuals performing filter changes including the complainants.
7.
Employee Training Program Condition 9 of the subject license references the licensee's application document AI-75-46 and states, in part, that the use of radioactive materials will be in accordance with statements, repre-sentations and conditions contained in Section VII-C of that document.
Section VII-C,6 Instruction of Personnel gives the licensee's plans for employee training for those persons assigned to the use of radioactive materials.
Those plans include indoctrination with regard to radiation and nuclear safety rules prior to beginning work in radiologically posted areas.
Those plans also state in the referenced section that personnel whose regular assignments, for the first time, include work in posted areas must complete a training course covering the general aspects of working with these materials. With respect to the latter of the two requirements, the licensee has developed a respiratory protection training program, a lecture-type training augmented by demonstrations; and a radiation safety, criticality safety and security training lectures presented by vidiotape.
Each of those training elements is followed by a written test with assigned passing grades.
According to licensee representatives, oral instructions to personnel performing filter changes were given on at least three occasions of HEPA filter changes which occurred in 1978 through flovember.
They stated that the instructions were of a general nature including the filter change team assignments, a general statement as to the radiological hazards involved and the specific duties of each individual.
Licensee representatives of the Health, Safety and Radiation Services Department stated that they were continuously present during the filter change operations and were available to answer ques. ions regarding the safety of the operations.
By ref-erence to the filter change assignment sheet, it was determined that the complainants were present as members of the filter change teams on at least three occasions when maintenance supervision instruction was given.
This inspection included a review of respiratory protective training given to 14 employees involved in the filter change operations in-cluding the complainants.
By compar.ison of the filter change assignments dates with the date of respiratory protection training, it was found that both Complainants A and B received respiratory protection training and passed the qualification test prior to the use of respirators in filter change operations.
During this inspection a similar comparison was made for those 14 employees between the date of hire and the date upon which com-pletion of radiation safety, criticality safety and security training had been completed.
That comparison indicated that for the most part the employees received the vidiotape training usually within one to two months of their date of hire.
In the case of both complainants A and B the completion of that portion of the training occurred five months after their hire date.
That training and completion of the qualification examinations occurred for both complainants A and B after their assignments to filter change teams.
A portion of the licensee's employee training program (vidiotaped lectures on radiological and criticality safety) were not presented to the complainants until after they had participated in several filter change operations.
Nonetheless, the NRC inspectors regard the licensee in compliance with SNM-21 License Condition 9 in that sufficient training and supervision had been furnished to the employees to permit them to perform the filter change operations in a safe manner.
8.
Management Interview The purpose, scope, and results of the inspection were discussed with Messrs. R. J. Jones, M. E. Remley, and R. J. Tuttle on November 30, 1978 and in subsequent telephone conversations.
The licensee representatives were informed that no evidence was found that inadequate protective clothing or inadequate equipment had been provided to the complainants or to other licensee personnel performing filter change operations. The licensee representatives were further informed that there was no evidence of significant external or internal exposure to radiation either to the complain-ants or to other personnel who had performed the filter change operations.
Licensee representatives were informed subsequently by telephone confirmation that the inspectors regarded the training and super-vision provided to the complainants had been adequate to permit their filter change operations to be performed safely.
Licensee representatives were informed that no apparent items of noncompliance or deviations were observed.