ML20002A965

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IE Insp Rept 70-0820/80-05 on 800514-16.Noncompliance Noted:Dec 1979 Audit Did Not Include Analysis of Radiation Exposure for Each Work Station.Mower Moved from Contaminated Area Not Surveyed
ML20002A965
Person / Time
Site: Wood River Junction
Issue date: 08/29/1980
From: Clemons P, Knapp P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20002A958 List:
References
70-0820-80-05, 70-820-80-5, NUDOCS 8012090258
Download: ML20002A965 (7)


Text

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U. S. NUCLEAR REGULATORY COMMISSION OFEICE OF INSPECTION AND ENE0RCEMENT O

REGION I Report No.

70-820/80-05 Docket No.70-820 License No.

SNM-777 Priority 1

Category JR Licensee:

United Nuclear Corporation Euel Recovery Operation

__ood River Junction, Rhode Island W

Facility Name:

UNC Euel Recovery Operation Inspection At:

Wood River Junction, Rhode Island Inspection Conducted:

May 14-16, 1980 Inspectors: ((bd 6/h FD P. Clemons, Radiation 5pecialist date date date Approved by-h 47.

S/2 y/So V. J. Knapp, Chiet, Radiation dupport Section

/ date' FE&MS Branch Inspection Summary:

(InspectiononMay 14-16, 1980 (Report No. 30-05)

Areas Inspected:

Routine unannounced inspection by a regional based inspector of the Radiation Protection Program including previous inspection findings, annual report, annual audit, monthly well water samples, dosimetry, bioassay, special work permits, stack samples, air samples, instrument calibration, smear surveys, radiation surveys, receipt of radioactive material, posting, training, termina-tion reports, and whole body counts.

Upon arrival, areas where work was bein performed were examined to review radiation control procedures and practices.g I,he inspection involved 19 inspector-hours on site by one NRC regional based inspector.

Results:

Of the 17 areas inspected, no items of noncompliance were identified in 13 areas.

Three apparent items of noncompliance were identified in 3 areas (infrac-tion - failed to complete audit, paragraph 3; deficiency - failed to analyzed well samples paragraph 4; deficiency - failed to survey lawn mower paragraph 5)

Region I Form 167 (August 1979) 8012000 2 67

DETAILS 1.

Persons Contacted Principal Licensee Employees Mr. R. Gregg, Manager, Quality Assurance Mr. K. Helgeson, Manager, Nuclear and Industrial Safety Mr. D. Schultz, Manager, Compliance The inspector also interviewed other employees during the course of the inspection.

They included a Health Physics Technician and a Quality Assur-ance Representative.

2.

Licensee Action on Previous Inspection Findings (Closed) Noncompliance (820/78-18-01):

Failure to maintain hood face velo-cities.

The hood face velocities are being maintained at the required velo-ci,tiis' as observed by the inspector.

/ g(Closed) Noncompliance (820/79-18-02):

Failure to perform semi-weekly beta-amma radiation surveys.

Beta gamma surveys are being performed at the required frequency as noted by the inspector.

3.

Annual Audit The licensee is committed to performing an annual audit of the radiologi-cal safety program.

Condition No. 9 of Special Nuclear Material License No. SNM-777 incorporates Section 200 of the licensee's application.

Subsection 207.2 of Section 200 states "An annual audit shall be conducted by a technically competent per-son (s) not directly a part of the plant organization and the f.cnager, Opera-tions.

The results of this audit shall be reported to the General Mana;;er and the Manager NIS and shall include reviews of both the radiological and criticality safety programs.

This a dit shall include an analysis of the radiation exposure for each work station and mummendations for action necessary to maintain personnel exposure at hvels as low as reasonably achievable."

On Ma:' 14.1980, the inspector asked if the annual audit had been conducted during 1979 as required.

The inspector was informed that the audit was per-formed in December 1979, and he was given a copy of the audit report which verified that fact.

}

3 The inspector noted that the audit report specifically addressed an analy-sis made by the auditor for one work station.

The inspector asked a licens-ee representative why analyses of the radiation exposure for other work stations were not included.

T:1e representative stated that he did not know.

The inspector then contacted the individual who performed the audit.

The inspector told the individual that he was reviewing the audit report and the license requirement to analyze the radiation exposure for each work station.

The inspector told the auditor that he had reviewed the one ana-lysis that was reported, and he also said that the audit report did not include the radiation exposure analyses for numerous other stations.

The inspector asked the auditor if the required analysis of the radiation exposure for each work station had been done.

The auditor stated that he had reviewed air sample data during his audit in December 1979.

The inspector noted that the air sample data was not sufficient to evaluate the radiation exposure at each work station because the air samplers were not always located at each work station therefere they could not be con-sidered as being repres1ntative of a workers exposure.

The inspector noted that the audit report d d not address external radiation surveys that are routinely performed by the licensee.

External radiation survey data of necessity, would be included in any analysis of the radiation exposure for each work station.

The inspector stated that failure to perform an analysis of the radiation exposure for each work station represents noncompliance with a license condition.

(80-05-01) 4.

Well Water Samoles On May 14, 1980 the in pector asked if well water samples had been collected and analyzed at the required frequency.

He was told that well water sam-ples had been collected and analyzed for gross-alpha and beta radioactivity and the samples were also analyzed for nitrates, flouride and ph.

Condition No. 22 of Special Nuclear Material License No. SNM-777 states, "The licensee shall collect water samples on a monthly basis at locations and monitoring wells as identified in Figure 407.2-III and Table 407.2-I1 (except for well No. W-8 which is dry) of the submittal dated May 10, 1978.

The collected water samples shall be analyzed for:

(a) Gross-alpha and beta radioactivity.

If the gross-alpha and beta concentrations exceed 16 pC/1 and 50 pC/1 respectively, identifica-tion of major nuclides and determination c? their concencrations shall be conducted by the licensee.

(b) pH, nitrate, and flouride.

If the concentration of nitrate (measured as N) exceeds 10 ppm, analysis of trace element concentrations, i.e.,

Cd, Hg, Pb, Mo, Zn, and Ni in the water sample shall be performed."

4 The inspector noted for the period July-November 1979, approximately fifty samples exceeded the gross alpha and beta concentrations (s10 alpha and 440 beta) cited above thereby requiring additional analyses.

The inspector also noted that approximately fifty samples exceeded the nitrate concentration cited above, thereby requiring additional analyses.

The activity of the ten alpha samples ranged from 16 pCi/l to 49 pCi/1.

The activity of the beta samples ranged from 53 pCi/l to 842 pCi/1.

The inspector asked if the samples had been analyzed for the major nuclides, and the chemical elemerts as stated above.

The inspector was told that the samples had been sent to a commercial vendor for analyses.

The inspec-i tor asked to see the analytical results.

The inspector was given the results for the samples submitted to tne commerical vendor for analyses.

As the inspector reviewed the results for the period July-November 1979 he noted that the results were incomplete inasmuch as certain samples ubmitted had not been analyzed.

I Specifically, chemical analyses had not been performed on:

a.

One sample in August 1979 b.

Six samples in October 1979 c.

Three samples in November 1979

^

Additional radioactivity analyses had not been performed on:

t' a.

One sample in August 1979 b.

Five samples in September 1979 c.

Seven sam;,les in November 1979 4

Approximately fifty percent of the well water samples submitted for the l

period July-November 1979 had not been analyzed as required at the time of this inspection.

The inspector noted that failure to analyze the well water samples repre-sents noncompliance with license condition No. 22.

(80-05-02) 5.

Survey As the inspector toured the contaminated area on May 14, 1980, he observed a licensee employee on a riding lawn mower.

Approximately fif teen minutes later, the inspector observed this individual mowing the lawn in the unrestricted area near the entry into the South Yard.

The inspector asked the employee who monitored the mower, and approved its removal from the-contaminated area to the unrestricted area.

The employee did not respond.

5 The inspector noted that the Health Physics Technician was with him at all times, therefore, he did not survey the mower.

The inspector also noted that the Manager, Nuclear and Industrial Safety was in the Process Area during this same time, therefore, he did not survey the mower.

Condition No. 9 of Special Nuclear Material License No. SNM-777 incorpo-rates Section 400 of the licensee's application.

Subsection 4.4.1 states,

" Contamination surveys shall be performed and documented on incoming and outgoing shipments of radioactive material and material leaving the con-tamination areas to unrestricted areas to assure compliance with applicable regulations."

The inspector noted that failure to survey the mower leaving the contaminated areas represents noncompliance with license condition No. 9.

(80-05-04) 6.

Annual Report 10 CFR 20.407 requires that a personnel monitoring report covering the preceding calendar year be submitted within the first quarter of the fol-lowing year.

The inspector reviewed the licensee's personnel monitoring report that had been submitted on February 14, 1980 to the Director of fianagement and Program Analysis.

The report indicated that 184 individuals were monitored during 1979, and the maximum exposure recorded was 107 milli-rem for the year.

No items of noncompliance were identified.

7.

Bioassay Subsection 402.2 of Section 400 of the licensee's application states that the minimum bioassay frequency for individuals working with soluble uranium is monthly.

The inspector selected the names of seven operators who may work with the soluble form to determine if the individuals were being sampled and analyzed at the stated frequency.

The inspector reviewed data for the period August-December 1979, and the data indicated there were no problems with exposure controls, and the individuals were sampled at the required frequency.

No items of noncompliance were identified.

8.

Dosimetry The inspector reviewed dosimetry data for the period Jcaaary-April 1980 to determine if the licensee was in compliance.

The inspector noted that 15-20 operators are monitored, the individuals most closely associated with ope-rations involving licensed material.

No items of noncompliance were identified.

t

A 6

9.

Air Samples The inspector reviewed air sample data for samples collected in the Process Area for the period January-April 1980 to determine if the licensee was in compliance with regulatory requirements.

No items of noncompliance were identified.

10.

Training The licensee is committed to retraining of employees as stated in Subsec-tion 208.3 of Section 200 of the licentee's application.

Subsection 208.3 states, "The training and Jersonnel safety program is continued with on-the-job-training supplemented ay regularly scheduled meetings...

Standard Operating Procedure I-Z, Revision 1 dated November 11, 1979 4

developedpursuanttoSubsection401ofthelicensee'sapplication,Sec-i tion 2.3 states, " Annual retraining sessions will be conducted by NIS."

The inspector selected the names of all operators routinely assigned to the restricted areas to determine if they had received annual retraining in health physics.

The inspector reviewed documentation which indicated that all of the operators received annual retraining during July 1979.

No items of noncompliance were identified.

11.

Ventilation Subsection 404.2 of Section 400 of the licensee's application states, " Air flow shall be from areas of lower to areas of higher contam'-

ion." The licensee has a recuirement to perform velometer measuremer

.. kly.

The inspector reviewec data for the period December 1979-Mr x85 t. ' indi-cated velometer measurements are being done daily.

The data also indicated that face velocities on the vario

ys e were in excess of the stated requirements.

No items of noncompliance were identified.

12.

Stack Samples The inspector reviewed stack sample data for effluents from the Process Area for the period December 1979-May 1980 to determine if the licensee was in compliance with regulatory requirements.

No items of noncompliance were identified.

1

7 13.

Receipt of Radioactive Material 10 CFR 20.205(b)(1) requires that each licensee upon receipt of a package of radioactive material must monitor the external surfaces of the package for contamination.

The inspector reviewed the incoming shipment records 1980. proximately ten shipments received during the period January-April for ap The records indicated that all packages had been uonitored as required.

No items of noncompliance were identified.

14.

Termination Reports 10 CFR 20.408 requires a licensee to submit a report of an individual's exposure to radiation and radioactive material incurred during the period of employment to the Director of Management and Program Analysis when the individual terminates employment with the licensee.

10 CFR 20.409 requires the licensee to also notify the individual if the licensee is complying with 10 CFR 408.

The inspector selected the names of five individuals who terminated in 1979 to determine that the required reports were submitted.

The documentation reviewed by the irg ector indicated that the reports were submitted as required.

No items of noncompliance were identified.

15.

Whole Body Count Subsection 402.3 of the licensee's application requires that whole body counts be performed bi-annually (twice a year) on certain employees.

The inspector reviewed whole body count data for 1979 to determine that the requirement was satisfied.

The documentation indicated that whole body counts were performed in April 1979 and November 1979.

No items of noncompliance were identified.

16.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 16, 1980.

The inspector summarized the :urpose and the scope of the inspection, and the findings as presented in t11s report.