ML20012B813
| ML20012B813 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/02/1990 |
| From: | Hooker C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20012B810 | List: |
| References | |
| 70-1257-90-01, 70-1257-90-1, NUDOCS 9003160346 | |
| Download: ML20012B813 (19) | |
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S. NUCLEAR REGULATORY COMMISSION T
REGION V:
' Report No. 70-1257/90-01 1
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' Docket No;,70-1257 1
H
')j License No."SNM-1227
- Priority:
0
. Cat'egory: ULFF Safeguards Group: III j
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-Licensee: Advanced-Nuclear Fuels, Inc.
2101 Horn Rapids Road Richland, Washington 99352-0130 Facility Name:: Richland Facility 4
Inspection at: -Richland, Washington
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E Inspection Conductedt January 8-12 and February 5-9,-1990
_. Inspector:
C4'/4.,M A h #pe:
1 C. A.. Hooker, Fuel Fa:ilities Inspector Date Signed.
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, Approved'by: ; C.h A L 6/AlQd L
G. P.
las, Chief
- Date ' Signed
- Emerg
-Preparedness and
' Rad gical Protection Branch L
~ Summary:~
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' Areas-Inspected:--This was a routine unannounced inspection of licensee action J.,
on previous inspection. findings, management and organization, operator
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- training / retraining,Lcriticality' safety, operations. review, The inspection' also included tours of the-licensee's facilities.
Inspection procedures i30703,-~92702, 92701, 88005, 88010,'88015.and 88020 were addressed.
~ Results:; The-licensee's performance-in most areas. inspected appeared B
adequate. 'However,.a significant weakness was. exhibited in the management of
' measurements (Section 3) program regarding evaluation of positive urine sample L-
-the licensee's bioassay
- 0ne violation was identified concerning the failure' l-to conduct adequate-surveys:(Section 3); One non-cited violation (NCV) was y
,also identifiea involving. failure to-adhere to protective clothing
-requirements'(Section 5).
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DETAILS 1.
Persons Contacted A.
Advanced Nuclear Fuels (ANF)
+R. G. Frain Vice President, Richland Operations
- B.N.Femrelte. Manager Richland Operations
- +W.E.Stavig, Manager,$afety,SecurityandLicensing(SS&L)
C. J. Volmer, Manager, Quality Assurance (QA)
+#C. W. Malody, Manager, Regulatory Compliance
- T. W. Patten, Manager, Plant Operations
- J. B. Edgar Acting Manager, Regulatory Compliance 1
- D.C.Leifeldt, Manager Operations Planning and Scheduling d
- T. C. Probasco, Supervis,or, Safety
- L. D. Gerrald, Criticality Safety Specialist (CSP) l
- J, E. Pieper, Health Physics Specialist (HPS)
- E. L. Foster Radiological S&fety Specialist (RSS) l l~
H. G. fM11, denerd Supervint, Chemical Operations L. 9. W n ver, Supervisne, Naste Operations B.
NRC
- W. S. Per.nington, L?consing Project Manager, Fuel Cyck Safety Primch j
C.
ContractVr.ndor(U.S.Tett_i,ng),
i C M. Lardy, Director Rad
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C. Soderquist, Supervisor, ochemistry 1
dioassay
- Denotes those attending the meeting on January 12, 1990.
+ Denotes telephone conversation on January 18, 1990.
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- Denotes those attending-the exit interview on February 9, 1990.
In addition to the individuals noted above, the inspector met and held discussions with other members of the licensee's staff.
2.
Followup of Licenste Action on Violations (92702)
Item 70-1257/89-03-05 (Closed):
This item involved the failure to conduct fire extinguisher training in accordance with the training program delineated in the license s Emergency Plan (EP).
The inspector verified that effective corrective actions had been implemented to prevent recurrence as stated in the license's timely letter dated December 18, 1989.
The inspector noted that the licensee had revised their EP to clarify their Plant Emergency Response Team (PERT) training program, and had provided-hands-on fire extinguisher training that included 26 of 41 members of the PERT on October 31, 1989.
The inspector also noted that 431 individuals out of about 700 ANF employes attended
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General Employee fire protection training on October 25, 1989.
The inspector had no further questions regarding this matter.
3.
Followup of Licensee Action on Open Items (92701)
Item 70-1257/89-03-01 (0 pen).
This item involved the the buildup of excessive combustible materials (used HEPA filters) in the south end of the Packsoed Radioactive Materials Warehouse (PRW).
By letter dated December 18,1989 to the NRC, the licensee described actions taken and established a goal to significantly reduce the inventory of combustible materials in the PRW by July 31, 1990.
During this inspection, the inspector observed that (1) the temporary plastic partition at the north end of the center section of the PRW had been replaced with dry wall and (2) newly installed equipment in the VO building for disposal of the filterswasbeingtestedasstatedint$elicensee'sletter. Although the licensee appears to be on schedule with this task the inspector considers this matter open until the licensee accompilshes their goal.
Item 70-1257/83-03 02 (Closed).
This item dealt with the installation of an automatrc gas shuto1T valve for the licennee's laundry dryers.
During
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I ediscLssionwiththeresoonsibleprojectengineer,whow&sunavailabie l
. during the previctc inspecticn (70-12d/M-03), the inspector was l
Mfe'ad that in addition to the eunufacturer's installed automatic gas 4hu mff u b e, the licensee had instal'ied a backup outomatic gas shutoff According to the projer.t engineer, prior to their startup in Augwt 1969.
vy he un each cf their two dryers there are several parametera that actated backup shutoff valves including loss of power, fsn, nilot light, building ventitation, and high temperature cutoff.
This item is considered closed.
1*,em 70-1257/89-03-04 (Closedl.
Inis item involved the need to review the licensee's investigation of a personal injury of a worker that resulted in the loss of a finger tip, while checking the alignment of a drum in the licensee's incinerator ash dum) hood.
Based on review of the
-licensee's investigation report dated Octo)er 11, 1989, and observations made during facility tours, it appeared that the licensee had adequately investigated the matter and made several system modifications to prevent recurrence. The inspector also noted that the worker's special bioassay measurements (wound counts and urine samples) taken as a result of the injury, indicated that there was no uptake of radioactive materials by theworkerfromtheinjury.
The inspector had no further questions regarding this incident and considered the matter closed.
Item 70-1257/89-03-06 (Closed).
This item involved incomplete uranium hexafluoride (UF ) cylinder shipment inspection forms.
Based on review ofUFgcylinderIbipmentssincethepreviousinspection(70-1257/89-03),
the inspector determined that the licensee had taken appropriate corrective actions to ensure that the required inspection forms were properly completed prior to each shipment.
The inspector considered this matter closed.
Item 70-1257/88-10-02 (Closed).
Inspection 70-1257/88-10, dated January 19, 1989, described concerns involving the licensee's evaluation of positive bioassay measurements.
Inspection Report No. 70-1257/89-02, l
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i dated May 23, 1989, described that the licensee was taking action at
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levels lower than their urine sample action level, and that the license was formalizing their documentation regarding this matter.
During this inspection (70-1257/90-01), the inspector reviewed the licensee's actions i
regarding this matter, and revisited the positive bioassay measurements I
associated with the 70-1257/88-10 inspection.
The inspection of this item was primarily focused on urine sampling, i
i The prima activities at ANF involve the conversion of UF to uranium 6
oxide (UO the processing of U0, and the fabrication of nuclear reactorf$Iassemblies.
Theman$facturingprocessesutilizesboth soluble and insoluble low enriched uranium (less than 5.0 percent U-235) compounds, with an average enrichment of 3.0 percent U-235.
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section 20.103 of 10 CFR Part 20 became effective December 29, 1976, as published in the Federal Register November 29, 1976.
10 CFR 20.103(a)(1) requires, in part, that no licensee shall possess,
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use or transfer licensed material in such a manner as to permit any indIvidualinarestrictedareatoinhaleacuantityofradioactive material in any period of one calendar quarter greiter than tne quantity which would result from ir.htlation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per weet for 13 weeb at uniform concentratior.s cf radioactivo material in air specified in Appendix B, Table 1, Column I.
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10 CFR 20.103(a)(3) requires, in part, that in addition to menurements of radioactivity in air, the use of measurements of radioactivity in the body measurements of radioactivity twcreted from the body or any L
comblnationsofsuchmeasurementstodeterminecompliancew,iththe 4
requirements of 10 CFR 20.103.
30 CFR 20.105(a)2 requires, in part, tut no licensee shall possess, use, or transfer mixtures of U-234 U-235 and i
U-238insolubleforminsuchamannerastopermitanyindivIdualina l
restricted area to inhale a quantity of such material in excess of the intake limits specified in Appendix B, Table I, Column 1 and footnote 4 mixturesofU-238,U-234andU-23$ states,inpart,thatforsolublein air chemical toxii thereto. Footnote 4 to Appendix B limiting factor.
If the percent by weight of U-235 is less than 5 the concentrationvaluefora40-hourworkweekis0.2milligramsuranIumper 3
cubic meter (mg U/m ) of air.
Ugingastandardbreathingrateof20 liters (L) per minute, 0.2mg U/m corresponds to an inta(e limit of 9.6 mg per 40-hour work week.
10 CFR 20. 201(b) requires that each licensee make such surveys as necessary to comply with the regulations in 10 CFR Part 20.
As defined in 10 CFR 20.201(a), " survey" means an evaluation of the radiation hazards incident to the production, use, release -disposal, or presence ofradioactivematerialsorothersourcesofradlationunderaspecific set of conditions and are reasonable under the circumstances to evaluate the extent of the of the radiation hazards that may be present.
10 CFR 20.405(a)(1)(ii) requires, in part, that each licensee shall m>ike a report in writing of each exposure of an individual to radioactive I
material in excess of the applicable limits in 20.103(a)(1) and (a)(2),
or in the license.
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4 In 1982 the NRC issued IE Information Notice No. 82-18, " Assessment of Intakes of Radioactive Materials by Workers", to clarify the NRC's position on the use of ICRP-30 methodology for use in assessing intakes of radioactive materials by workers.
The Notice clearly stated that the NRC would continue to use the ICRP-2 methodology in determining com)11ance with 10 CFR Part 20 until the new proposed revision of 10 CFR 20 1as been published as a final rule.
The Notice also referenced several NRC Regulatory Guides (RGs) that provided guidance for the application of bioassay pro;G 8.11. " Applications of Bioassay forrams for sp operations, which included 1 Uranium", " Applications of Bioassay for Uranium".
The inspector noted that licensing mana er maintained a copy of this Notice and encouraged l
the licensee to rev ew it.
RG 8.11 (June 1974) noted that the technical bases for the criteria appearing in the guide were from WASH-1251, " Applications of Bioassay for Uranium".
RG8.11 and WASH-1251 (June 1974) which describe elements for establishing and implementing bioassay programs for uranium including:
(1) solubility / transportability classifications of various chemical forms of uranium and their associated biological half lives, (2) urine sampling i
frequencies based on w asurement sensitivity for the controlling factors l
I, chemical toxicity and/cr radiation dose), '3) sction guides based on
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bioatsay Neesurensent results for chemica; toxicity and/w radiation dose, and (4) models for determining in individual's dcse f.om either, l
radiation or chemical toxicity.
As stated ir. RG 1.11 and WA551-1251, l
chemical toxicity limits art baue on cuatrolling the uptake of uranium in the b'sood to liinit kidney damage, and note that tbn quantity of uranium permitted ia the blood at anll One tise isi 17 rzg ur6nium (nephrotoxiccentroi',ing limit).
During en inWfice revleu of llecnte documents, tie inmectur noted that by letter dated Sep' amber 12, I?SS, the lit.entto sthmitted an applicstion l
for a 5 year renewal of their licerse.
By letter dated May 18, 1987, the l'
licensee responded to questions :nd comments from the the NRC's review of I
the license renewal application.
Two of the NRC coments concerned the licensee's bioassay program:
NRC Comment-12 stated:
Page 3.9, Section 3.2.7 The bioassay program described in this section is not complete and should be expanded to to include the following:
1.
Criteria for determining who is requested to j
participate in the specified program.
l 2.
Specify the frequencies for bioassay, action levels, and actions to be taken for each measurement technique (bioassay frequency should vary according to elevation of airborne concentration of radioactivity in the work area and dust classification).
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3.
Criteria for determining that a diagnostic bioassay measurement shall be initiated.
i licensee Response-12 stated:
Section 3.2.7 has been expanded to include additional facets of our bioassay program which address the comments above.
l NRC Comment-13 read, in part:
In order to meet the above requirements, we suggest that the bioassay program in Part II of the application (Section 12.12) be moved to Part I.
In addition, the following additional specifications should be included in the program:
t 1.
If the workers' urinalysis results are confirmed (25 micrograms / liter), the licensee shall conduct an investigation to determine the probable cause, and consider work restrictions for affected workers, l
2.
If the workers have received an uptake of L30 mg L
or grsater of uranium in the blood strerary the licensee shall consider imposing work resti'ictio'is for af fected wnrkers.
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. Licensee Response-13 reed, in part:
l 1&2. It is our plan to use 25 ug U/L as an action level.
One option based on the results of the investigatien will be to consider work restriction for affected workers.
Based on the above observations it would appear that NRC Comment-13 No. 2 L
was directly related to controlling employees intake of low-enriched soluble uranium based on chemical toxicity, since the control value was expressed as mg in blood rather than a microcurie or other similar term commonly used for radiation dose control.
RG 8.11, Figure 9, indicates that if single intakes are controlled to less than 1.37 mg for soluble (Class D) uranium in the blood, that no investigative action would be required.
By letter dated August 7 1987, the licensee submitted a new license renewal application, revised in its entirety to reflect the change in l
company name, and changes to the application in response to comments by the NRC staff.
Part I, Section 3.2.7, Bioassay Program, of the License read, in part:
Bioassay measurements shall be conducted so as to assure compliance 10 CFR 20.103 and the ALARA policy.
I The bioassay program will normally be used as a verification of contamination control, but may in an i
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accident or abnormal situations be used to estimate the uptake by, an individual or estimate the exposure that an individual has or will receive.
The normal bioassay i
program shall consist of a monthly urinalysis an a i
yearly lung count.
Section 3.2.7, item 4. read, in part:
i The following action guides shall apply to soluble, biologically transportable uranium compounds:
a.
A dose evaluation shall be performed for an i
individual whose urine specimen exhibits a i
concentration in excess of 25 micrograms l
uranium / liter.
The employee shall be required to submit another urine specimen immediately and at least weekly thereafter until the concentration of less than 25 micrograms uranium / liter is reached.
Based upon the results of the evaluation, worker restrictions may be considered.
Part II, Section 12.12, Bioassay Program, of the Safety Demonstration, read, in part:
1 The frequency snv type of measurement is estabidshed on the' oasis of the exposure potential of the individual's work assignment and the physical and i
biological properties of the radioactive material with which he works.
s By letter dated Septerher 10,198i. ti,e NRC approved and 16swd 4 new 5 year license sith r.n expiration date of Septembar 30, 1992.
s During inspection 70-1257/88-10, tha licensae's procedure for implementing thrir bioassay program ANF-30, Chapter 2, Rev.10, dated July 7, 1988, Section 5.3.2 Urinalysiss, item 5 essentially repeated the statement in Section 3.2.7, item 4. a. of the License, and included a requirement to have lung count performed within 30 days, and that a discussion would be held with the involved employee as part of the investigative effort to determine the cause.
In response to the NRC's concerns described in Inspection Report No. 70-1257/88-10, the licensee revised ANF-30 to upgrade their investigative effort and proceduralized a format for investigation.
Chapter 2, Revision, 11, August 1989, Table 5.3, " Uranium ANF -30,is Action Plan", item 1 required, in part, that for urine sample Urinalys measurements greater than 10 ug U/L, (1) the vendor would be requested to perform a second analysis of the same sample to verify the results, and (2) if'the analysis was confirmed positive, a discussion would be held with the individual involved in an attempt to determine the cause.
Item 2 of Table 5.3 required, in part, that in addition to the requirements in item 1, when urine samples were greater than 25 ug U/L; (1) another urine sample would be collected the first day following the licensee's receipt of the results, and weekly thereafter until the samples indicated
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less than 25 ug U/L-of receipt of the fir (2) a lung count would be performed within 30 days st sample; (3) an investigation would be conducted including a dose evaluation and a review of the employee's work history; and (4) the investigation would be documented.
There was no change to the sampling frequency.
Urinalysis measurements for uranium are performed by a local contract laboratory using the fluorometric method.
By contract, the licensee had requested a MDL of 10 ug U/L.
The insaector noted from the contractor's urinalysis reports, that it appeared t1ey were capable of measuring sampies lower than the contractual MDL.
Sample turnaround time was not ex>edient (20-30 days).
During the last two years the licensee had su)mitted an average of about 150 urine samples per month for analysis.
Special and routine (annual) lung counts were also performed by a nearby laboratory, witt, a lower limit of detection (LLD) of 0.11 nanocuries (nC1) for U-235. The licensee's action level was 0.16 nCi.
In comparing ANF-30, Revision 11, with the biological models used in RG 8.11 and WASH -1251 for transportable / soluble (class D) uranium, the inspector made the following observations:
(1) The ANF-30 action levels of 10 ug U/L and 25 ug/L could correspond to an initial uptake of sbout 13.8 mg U and 35 mg U respectively, 30 days earlier.
Assuming 42 % is the fraction of material exhaled (WASH 1251), these uptakes could correspond to acute inta'as of about 33 mg U and 83 m3 U, respectively.
Assuming 43 3ercent (WASH-1251) of an acute intake of class D uranium is aysorbed in the L
blood, the nephrotoxic control leal of level of 2.7 g U vould he s
l-greatly exceeded, trd the NRC 40-hour intake limit of 9.6 mg U would also be exceed.
l (2)
The MDL (?3 ug U/L)Ime do not provice for (J) prcmpt cnclysis for 30-day sampling f requency and a 20 to 30 day semple turnaround t uranium compounds with Aort biologcal bralfiiver and especially those that excrete very rapidly (U-and related comscunos) fro.a the body, (2) the espability to evaluate intakes of solu)1e or highly l.
transportable material that could go undetected due to the long time between samples, and (3) the capability of having sufficient data points for adequate evaluation of urine excretion rates in order to properly assess individual's intake for soluble uranium.
~During January 8-12, 1990, the inspector reviewed urine sample measurement data from January 1, 1988 - November 1989.
From January 4, 1988 - January 3, 1989, 11 individuals had urine sample measurements that ranged from 10.3 to 17.9 ug U/L, and 4 individuals with measurements that ranged from 26.4 to 53.2 ug U/L, of which one of these individual's had exceeded the 25 ug U/L action level on two consecutive samples.
The inspector noted that one individual had submitted a routine sample on September 6, 1988, that measured 7.58 ug U/L, submitted another sample on September 9, 1888, that was reported to the licensee on September 27, 1988, as having a measurement of 33.3 ug U/L.
The inspector questioned l
the HPS as to why this sample was provided within a few days of the routine sample.
The HPS stated that it appeared the individual had
8 provided the sample on her own accord.
The HPS could not provide the inspector a specific reason for the second samplet except that something in the plant may have occurred that he was not aware of, since the sample had not been sent as a rush sample as normally done when potential uptakes are considered.
The inspector noted that each of the individuals with urine samples exceeding 25 ug U/L were (1) re-sampled when the licensee became aware of the measurement, (2) given followup lung counts within 30 days of their urine sample date, which appeared to indicate no detectable U-235, and (3) informed of their urine sample and lung count measurements.
The inspector that noted the licensee maintained letters documenting that these individuals had been informed that their urine sample had exceeded 25 ug U/L.
Each letter also contained the following statement:
" Persons having a confirmed urine sample analysis greater 25 micrograms Uranium per liter, a lung count greater than 0.16 nanocuries U-235 or two consecutive positive lung counts shall be advised as to the significance of the sampling data and their assistance solicited in preventing future occurrences.
The purpose of this discussion is to provide positive feedback to employees allowing them to modify their werk methods to prevent any additional disposition of material in their lungs and to be alert to identify
>ossible sources of radioactive material uptake in the future.
Artsent during the during this circussion were:..."
Based on the calculation models described in RG 8.11 and WA3H-1251, and review of the licensee's bioassay data (urine samples measurements and l
lungcounts),theinsptetornotedthattheindividualswithurinesample L
measurements greater than 25 og U/L may have received intakes of soluble l
uranium that exceed the NRC intake limit of 9.6 q.
The inspector also r
dotermined that individuals with positive urine sample measurecents greater then 10 ug U/L and less I1an the 25 cg U/L action level, were L
r,1so candidatos for intakas of soluole uranium in exwr of the NRC 9.6 mg limit. These matters were discussed with the meabers of the SS&L staff and at the meeting on January 12, 1990.
The licensee informed the inspector that they believed that if they met the requirements of their license, they were in compliance with NRC requirements.
The inspector informed the licensee that the action levels in the license are licensee commitments to take specific actions and did not exempt them from the requirements specified in CFR Part 20.
1 Based on the above observations-and review of ANF-30, Revision 11 and previous versions, it appeared to the inspector that the licensee had not l
adequately evaluated their bioassay program to ensure compliance with 10 CFR Part 20.
Specifically:
(1) With a 30- day sampling frequency positive urine sample measurements could be indicative of intakes of soluble and/or nonsoluble radioactive material, that could exceed the limits for the 40-hour control measure specified 10 CFR 20.103(a)(1) and the 40-hour limit specified in 10 CFR 20.103(a)(2).
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9 (2) Although the licensee's procedures required dose evaluations and worker restrictions, the procedures did not require i
evaluations of positive urine sample measurements or positive lung counts to ensure that an individual's intakes of radioactive material had not exceed the the reporting i
e m irements specified 10 CFR 20.405(a)(ii) for either i
L.103(a)(1) or 20.103(a)(2).
j Based on discussions with cognizant licensee representatives and from the records reviewed, it a)peared that no evaluation was performed to determine as to what c1emical form may have resulted in the positive
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urine sample measurement, and what the potential intakes could have been.
These matters were discussed with the licensee during the inspection and at the exit meeting on January 12, 1990, with licensee representatives, denoted in Section 1.
The licensee did not present any evidence that would alter the inspector's observations. The inspector informed the j
licensee's staff that the first order of concern was the Sotential exposures of the individuals that had exceeded the 25 ug J/1 action level.
However, all individuals with positive urine samples greater than i
10 ug U/1 were also a concern.
The licensee representatives acknowledged j
the inspectors observations, and stated that they would perform the necessary evaluations.
The licensee also informed the inspector that 1
they would also evaluate their urine sampling program and make the necessary changes to ensure that their program was in compliance with 10
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CFR Part 20.
During a telephone call between the licensee representatives, denoted in l.
Section 1, and the Region V office on January 18, 1990, the licensee
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stated that they were in the process of evaluating the potential uranium u
intakes of the individuals that had exceeded their 25 ug U/! action i
L level, and were takirg action to (1) immediately implement a biweekl urine sampling program, (2) shorten the sample turnaround time, (3) y l
evaluate th2. accuracy of the vendors sample results, (4) work with the l
Vendor tc lower the NDL, and rev'iew plant operations to detemir.e thc 1
need for more frequent sampling.
The licensee also stated that they l
expected to have their evaluations for the individuals that exceeded the j
25 og U/1 action ' level completed within two weeks.
During February 5-9, 1990, the inspector reviewed the status of the licensee's evaluations, and the changes in their urine sampling program.
As of January 16, 1990, the licensee had implemented a biweekly sampling program with a proposed contractual agreement for a MDL of 0.5 ug U/L and j
re-analyze all samples greater than 1.0 ug U/L, and a 2 week sample-a turnaround time.
Reconfirmed positive urine sample measurements greater than 1.0 ug U/L would be subject to further investigation to determine the cause.
Recent vendor sample measurement reports, indicated that the new contractual MDL could be met.
The inspector also visited the contract laboratory and discussed their measurement capabilities with representatives of their staff.
No concerns were identified. Comparing
'i the licensee's new urine sampling program with the biological models used in RG 8.11 and WASH -1251 for Class D uranium, the MDL of 0.5 ug U/1 and j
-investigative level of 1.0 ug/l could correspond to an initial uptake of about 0.22 mg U and 0.44 mg U respectively,14 days earlier. Assuming 42 percent is the fraction of material exhaled (WASH-1251), these uptakes l
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could correspond to acute intakes of about 0.5 mg U and 1.05 mg U, i
respectively.
Assuming 43 percent (WASH-1251) of an acute intake of class D uranium is absorbed in the blood, the nephrotoxic control level of level of 2.7 mg U would not be exceeded, and the NRC 40-hour intake limit of 9.6 mg U would also not be exceed.
4 Regarding the status of the licensee's evaluations, cognizant licensee representatives informed the inspector that, although the evaluations were not formalized,ive uptakes of uranium related to specific incidents, j
their investigations had determined that two of the individuals had rece and that the calculated intakes for these individual's 1ad not exceeded i
any NRC reportable limits.
The licensee had also conclude that two of the individual's high urine sample measurements were not due to intakes i
of radioactive material because (1) their projected lung deposition based j
on urine sample measurements would have been detectable for nonsoluble material, (2) the individuals ~had not worked in areas where soluble uranium was processed, and (3) there was no other radiological evidence that would have resulted in intakes of soluble uranium as potentially indicated by the bioassay measurements.
The inspector noted that the licensee had acquired the services of a local firm (Battelle Northwest Laboratories) to assist them in evaluating i
the potential intakes of the four individuals indicated above.
The HPS j
provided the Bate 11e report, dated February 1,1990, to the inspector for review.
The HPS pointed out several errors in the report as a result of a misunderstanding of some information and/or insufficient data supplied
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to Bate 11e, involving urine bioassay data and the chemical form of 1
uranium exposure to one individual.
However, the errors were not detrimental.to the licensee's evaluation of the individual's intakes.
The inspector noted that the Battelle evaluations and assumptions were based on ICRP-30 methodology.
The inspector interviewed selected members of the Operations Department and reviewed operations logs, HP fechnician logs, records of air sampling seasurements. personnel foldars, cod ether selecter1 records to verify the SS&L Department's conclesions.
Lasad on the discussions and review of time caro activity charges, the inspector noted that one of the individuals the licensee had concluded no intake occurred, had potentially worked in an area where soluble uranium was used (chemical conversion line).
This individual was out of town during the inspection and was not available for an interview.
Based on the SS&L De)artment's conclusion it appeared that the licensee needed to research t11s matter further.
The inspector discussed this matter with the SS&L Department during the inspection and at the exit interview on February 9, 1990.
The inspector's observation was acknowledged by the licensee.
The licensee agreed to interview this person as to what tasks he had been involved with during the time period of concern before completing the evaluation.
With respect to the other individual the licensee had discounted an intake.
The inspector determined that the licensee's evaluation and conclusion for this particular case appeared reasonable based on the licensee's supportive evidence.
During the inspection and at the exit interviewed on February 9,1990, the inspector reemphasized and encouraged the licensee to evaluate the
1 11 the information provided in IE Notice 82-18, since they had been basing their evaluations on the ICRP-30 methodology.
The inspector also j
informed the licensee that both of the requirements, 10 CFR 20.103(a)(1) and 20.103(a)(2), applied to their facility since soluble / transportable and nonsoluble/nontransportable radioactive, materials were used at their i
facility.
The licensee informed the inspector that the evaluations,ld be forwarded
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L for the four individuals that exceeded the 25 ug U/L action level wou i
to the regional office for the inspector's review.
ihelicenseealso informed the inspector that they expected to have the evaluations for the individuals with urine sample measurements that exceeded 10 ug U/1, for the time period of concern, completed by the end of February 1990.
The l
licensee's evaluations for the individuals that had urine samples exceeding 10 ug U/1 will be examined in a subsequent inspection.
This is an open item (70-1257/90-01-01).
j The inspector received the licensee's evaluations of the four individuals
)
on February 20, 1990.
As noted during the on-site inspection, the licensee's evaluation determined that two of the individuals did receive intakes of low-enriched uranium related to specific irscidents, and that the intakes had not exceeded any NRC limits.
The inspector noted that 1
the. licensee continued to use the ICRP-30 methodology for determining the individual's intakes.
For one individual the licensee assigned intake l
values of 0.817 mg U for Class D material and 5.45 mg U for Class W material.
This individual's intake resulted from a leak around a UF i
cylinder wash equipment fitting. Anareaairsamplethatwasonlin$for roximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> indicated that the air concentration was 3.9E-10 app /ml.
The other individual was assigned intake values of 0.33 mg U for uC1 Clasc 0 material and 2.1 mg U for Class W material.
This individual's l-intake was attributed to a malfunction on the Line 2 powder prep 1
hammemill hood containing calcined UO.
The air sample in this area i
E ir.dicated an air concentration of 1.6E 9 uCi/ml. The licensee's evaluation report stated that each of these individual's intake vidues L
vere belon the @ hour 10 CFR 20 limit of 9.6 mg cranium.
The inspector b dependently verified the licensee's conclusica using the guidance in RG l
8.11 and diagnostic guidet, and biological r,odalt, in WASH-1251 that the L
10 CFR 20, Appendix B, Footnote 4 limit as required by 10 CFR 20.103(a) had not been exceeded by either individual, and it appeared that the licensee conservatively applied the all of.the intake to this l~
requirement; however, the Footnote 4 limit only applies to soluble material.
Class W material is considered as being nonsoluble/nontransportable and the requirements specified in 10 CFR 20.103(a)(1) apply in this case.
It appeared that the licensee had not thoroughly evaluated the intake for Class W material in accordance with therequirementsin10CFR20.103(a)(1)toensuretheymetthereporting thattheothertwoindividual{a)(11).Thelicenseehadalsodetermined requirements of 10 CFR 20.405 s urine sample measurements were not related to intakes of radioactive materials.
The licensee attributed the urine sample results to sample contamination and/or measurement error.
The licensee had also included in their evaluation a statement regarding their interview of the individual in question.
l-1
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12 During the onsite inspection, the licensee informed the inspector that they relied heavily on their confidence of their air sampling program to identify in-plant problems in conjunction with worker's intakes of airborne activity. The inspector noted that the licensee's goal was to keep airborne levels to 1.0 E-11 uCi/ml (one-tenth of the NRC limit for insoluble uranium).
The licensee counts on the average about 650 air samples per month.
The average air concentration in 1988 was about 5.0E-12 uCi/ml.
The inspector noted that air activity-was tracked by work station as a function of dose (person-rem) based on ICRP 2, continuous intake of insoluble material, which did not include worker occupancy.
However, the licensee did not have a system to track each individual's maximum permissible-concentration-hours.
The inspector noted from the licensee's 1988 ALARA report that urinalysis data was also evaluated as a function of dose (rem per positive sample), with the assumption that the results were from instantaneous intakes of 50 percent Class D and 50 percent Class W material end a two week lapse time between inhalation, and urine sample (0.0082 rem /ug U/L), with a dose limit of 15 rem; and assuming that at 3.0 weight percent U-235, the radiation exposure hazard is approximately(a)quivalent to the chemical hazard of e
uranium. -The NRC 10 CFR 20.103 (2), RG 8.11, WASH-1251 and many industry technical references state that for soluble uranium with less than 5.0 weight percent U-235, chemical toxicity is the controlling factor.
The inspector also noted the the licensee took very few portable grab air samples, and was informed that for maintenance work, the nearest sample (s) in the work area were normally used to assess the air activity.
The inspector noted that the SS&L Department performed and documented annual reviews to determine a)propriate placement of air samples.
While touring the process areas wit 1 the HPS, the inspector pointed out several locations where additional air samples and/or relocation would improve i
the assecsment of workers intskes.
The HPS acknowledged the inspector's L
obserystions.
The inspetter & cussed with the licensee the limitation on air s,mpling as a definitive basis for avaluating a worker's exposure.
L Since it is impractable to place an air samp10 at each exact location I
that a worker will be at all thes, positive bioassay results indicate an L
cptake and must be evaluated.
Since this inspection vas primarily focused on the urine sampling
. program, the licensee's lung counting program will be given a detailed review in a subsequent inspection.
This is an open item (70-1257/90-01-02).
The licensee's failure to conduct adequate surveys to evaluate workers positive bioassay) sample measurements to demonstrate compliance with 10 l-CFR 20.103 and (a (2) to ensure that the applicable reporting L
l requirements in 10 CFR 20.405 were met was identified as an apparent violation of 10 CFR 20.202(b) " survey" (70-1257/90-01-03).
L 4.
Management and Organization (88005)
This area was reviewed to determine the licensee's compliance with the requirements of the License Conditions, licensee procedures and in agreement with the statements contained the Safety Demonstration.
i o
13 Responsibilities, authority and qualification requirements are defined in Part I, Chapter 2 of the License.
Education and experience of named key personnel are presented in Part I, Chapter 11 of the Safety Demonttration.
Based on discussions with cognizant licensee representatives and review of licensee organizational charts the inspectorobservedthatthelicensee'sorganizationwasconsIstentwith License Amendment No. 7, dated January 4,1990, involving recent organizational and administrative changes at ANF.
With respect to organization and staffing in Safety (, Security and Licensing (SS&L). Department, the Safety Supervisor SS) that reports to the SS&L manager was responsible for directing the activities of the CSP, HPS, RSS, 8 HP Technicians and a records clerk.
In addition to tnese supervisory responsibilities, the SS was responsible for the industrial safety program, Plant Emergency Response Team Training training requirements, and certain fire protection activities.
The problem regarding inadequate evaluation of high uranium urinalysis data, discussed in Section 3 above, may be indicative of inadequate resources and management attention devoted to the licensee's bioassay program.
The inspector reviewed the functions and responsibilities of the Health and Safety Council (HSC) with the Manager, SS&L and reviewed minutes of the HSC meetings conducted during.1989.
The HSC included about 31 members.and was chaired by the Vice President, Operations Division.
Personnel from various levels of management and specialist from various areas of interest comprised the remaining members 11p.
The inspector noted that meetings were conducted monthly and included
- a review of variousaspectsofANF'scriticalityIncluded,inadditiontootherdata,radiolog programs.
The meeting minutes also attachments reporting the results of (1) monthly housekeeping and safety inspections conducted by designated members of the HSC, (2) monthly HP audits, (3) personnel injuries that had occurred (4) monthly criticality safety audits, and (5) a summar.v of bicassay analytical data.
Identified deficiencies were were tracked as open items until they were resolved.
Criticality audits are discusted in paragraph 6 below. Monthly HP aadits are discussed in paragraph 3 above.
Selected old, new and ravised licensee operating procedures, standards and guides were reviewed.
The inspector noted from these samples, that the licensee's procedure control system included the appropriate reviews and approvals were conducted in conformance with the requirements specified in Part I, Section 2.5 of the License.
The inspector reviewed the licensee's NRC approved QA Program, " Advanced Nuclear Fuels Corp.-Quality Assurance Program Topical Report (ANF-1A, Rev. 23)", dated November 9, 1989, and discussed the QA audit program with the QA manager.
Based on the review and discussions, the inspector noted that the QA program and QA audit function, with the exception of the program related to transportation activities, primarily applies to the nuclear safety-related aspects of engineering services and product.
The audit program for vendors are of those that provide servicing and components that go into the product.
The QA program does not encom ANF's HP program or the contract vendor that analyzes the licensee' pass s
J 14 c,
urine samples.
The inspector discussed the advantages of expanding their QA audit program to include independent audits of the on-site HP program and the urinalysis contract vendor.
The value for such independent audits was also discussed at the exit interview on February 9,1990.
The licensee appeared to be maintaining their previous level of performance in this area, and their program seemed capable of meeting its l
safety ob ectives.
However, the problem described in Section 3 above i appears t indicate a weakness in management controls of the licensee s i
bioassay program.
Improvements to strengthen their audits and evaluation of onsite programs should be considered.
The problems discussed in Section 3 above, regarding the bioassay program, may have been prevented by a good performance based audit.
No violations or deviations were identified.
l-5.
Operator Training /Retrainina (88010)
This area was reviewed to determine the licensee's compliance with the requirements of the License Conditions licensee procedures and 10 CFR Part 19.
Theinspectordiscussedthelicensee'strainingprogramswith cognizant licensee representatives; and reviewed selected licensee procedures, training lesson plans, and employee training records.
Part I, Section 2.4 of the License describes the requirements for the initial and continuing employee training programs.
Licensee procedures, ANF-30, Chapter 2, " Radiation Protection Standards", Section 6, "Trainin "; and ANF-30 Chapter 3, " Criticality Safety Standards" Section 8,"Traiin",werewrIttentoimplementthetrainingrequirementsfor radiologica and criticality safety, respectively.
The inspector-noted that new employees received new employee indoctrination training which included the basics of radiation safety, criticality safety, industrial safety, emergencies, security, and safeguards.
Personnel assigned to work with radioactive and fissile l
i materiah, received specific additional formal training prior to working l
without an esecrt.
Workersreceivedannealrefreshertrainingaccording L
to their assigr.ed work areas.
Formal classroom training consisted of l
classroom lectures, slides and videos.
Upon completion of the formal I
classroom training, each individual was tested as to their knowledge of the material presented.
Criticality Safety Specifications (CSS's) and posting were reviewed on a quarterly schedule with operating personnel by their respective supervisor as a refresher.
The quarter 1 sc1edule was l
designed so that all of the CSS's and posting in an indiv duals assigned work area were reviewed annually.
New or revised CSS's and/or postings were reviewed when they were generated.
As part of the training program.
deficiencies an/or infractions identified in the various program monthly audits were reviewed with the appropriate staff during monthly safety meetings.
Operator training and qualification was discussed with cognizant supervisory staff members.
Qualification of operators was accomplished I
byon-the-job (0JT)fortheirassignedworkstation.
Subsequent to the j
initial new employee radiation safet and criticality safet training, each new operator typically spent th ir first two days in t e office L
1 i -~ -
J. 8 * '
15 f
areas to become familiar with ANF's administrative procedures and Plant staff before being assigned to a qualified operator.
New operators are i
under constant watch by a qualified person during the initial phases of i
their OJT.
Qualification was based on a workers ability to perform the i
task assigned them without errors, judgement of the qualified person they were assigned to and supervisors observations.
Levels of qualification ranged from Technician levels 1 (trainee) -4 and Specialist.
Normally two hours per 3 weeks are devoted to some type of formal training that i
may consist of reading assignmentsabove,commercialvideosandtrainIngmanuall criticalit and home made videos.
During facility tours, the inspector observed work in progress and held discussions with several workers.
The inspector did not identify any
}
cause to suspect individuals were not qualified to perform the task they were performing.
The licensee's program appeared adequate to accomplish their safety objectives.
No violations or deviations were identified.
6.
Criticality Safety (88015) i The licensee's pro' gram was reviewed for compliance with 10 CFR Part 70, i
License conditions, licensee procedures arid recommendations outlined in various industry standards.
The inspection included a review of selected t
records and procedures, interviews with personnel and facility tours.
t a.
Modifications and Changes There had been no engineering modifications that would require a criticality safety analysis (CSA) since the last inspection in this area (70-1257/89-03).
However, by letter dated November 20, 1989, the licensee requested an amendment to the license to authorize storage of uranium oxide fuel pellets enriched up to 5.0 w/o U-235 in temporary storage facilities (trailers or freight containers).
The licensee also submitted their CSA in support of the application.
j '.
The application and supporting CSA were reviewed by the NRC HQ Fuel l
Cycle Safety Branch and approved by License Amendment No. 6, dated December 12,1989, and supporting NRC safety evaluation.
The inspector noted that the licensee had not initiated the use of the l'
approved storage facilities as of this inspection.
L L
b.
Audits and Reviews-Monthly audits conducted by the CSP since the last inspection of this area (70-1257/8903) were reviewed.
The September audit, dated l
October 3, 1989, identified three deficiencies involving (1)
L improper labeling by the foreign shipper on BU-D packages for shipments to the USA, (2) failure to post a storage area with limit cards for BU-D packages, and (3) improper spacing of the BU-D packages and transient pails from a rod storage rack.
The inspector noted that the licensee attributed the cause of items 2 and 3 to operations being performed by persons (warehouse staff) not assigned
[:
i to the operations department in order to meet a safeguards dead line,withoutsufficientrevlewandoverviewbytheoperationsand
4.'
16 safety departments.
Corrective actions involved the traffic and
]
warehousing staff receiving additional training on October 17, 1989, i
by the CSP.
Regarding item 1, the licensee stenciled the proper t
shipping label on the packages and were making notification to the the foreign shippir on this matter.
j The inspector noted that, as pt.rt of the required annual review of
)
the Criticality Safety Standards, the licensee had nearly completed 1
a major project of revising their Criticality Specifications.
This l
major revision was to make postings of criticality control limits more generic and user friendly throughout the Plant.
The licensee expects the new posting will reduce the potential for operator i
errors.
c.
In-Plant Criticality Controls l
During a tour of S)eciality Fuels Building the with the HPS on l
January 9 1990, t1e inspector observed a 5.0 gallon uranium vacuum canister bein; stored in a safe batch storage area on the mezzanine in room 17 t1at was not labeled in accordance with the criticality safetylimItpostingforthatarea. The criticality limit card for this area, P90, 210, Rev. O, under " INVENTORY REQUIREMENT", stated, "EACH SAFE BATCH CONTAINER SHALL BE LABELED WITH THE NET WEIGHT AND ENRICHMENT".
Although the canister was considered as a safe batch I
percent) for this type of container,ypical generic enrichment (5.0it was not:
container and was labeled with the t by the posting.
Vacuum canisters are operated from a central vacuum i
system and normally maintained at specific work stations.
The l
inspector discussed this matter with the area supervisor, and the canister was immediately removed form the area, and the contents t
were weighed and transferred to another safe batch container.
The net weight of the canister's contents was about 9.9 kilograms uranium, which is well below a safe batch limit for 5.0 percent enrichment.
The area supervisor initiated a Criticality Safety Corrective Action Request (CSCAR) report to document this matter and forwarded it, with the immediatt. corrective actions taken, to the.
Manager, Plant Operations for iurther corrective actions.
The licensee determined that the orarator failed to follow procedures.
Corrective actions taken to prevent recurrence included (1) the workers in the area were reminded of the recuirements for handling vacuum canisters, (2) the incident was scheculed for review with workers in-similar areas at the next monthly safety meeting to be r
. held by the end of January 1990, and (3) the extra vacuum canister was removed from the immediate vicinity of the vacuum work stations.
These actions were documented on the CSCAR report on January 10, 1990.
ProcedureANF-30, Chapter 3,"NuclearCriticalitySafetyStandards",
Section 4.2.2.2, " Control by Criticality Safety Posting' reads, in part, that criticality safety posting is required at individual work station or storage locations, and the posting shall describe how the applicable Criticality Safety" Specifications (CSS) are to be implemented.
Section 7.3.4, Criticality Safety Limit Cards", read,
^
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c ;4.'
g in part, that criticality safety limit cards specify how a CSS applies to a particular operation.
Although the vacuum canister was considered a safe batch container
)
for uranium enriched to 5.0 percent, failure to label the container i
in accordance with the requirements specified on the criticality safety limit card was identified as an apparent violation of Part I, Section 2.5, " Operating Procedures Standards and Guides" of the License.
However,basedonthesafetysignificanceofthIsincident it would appear to be a Severity Level IV or V matter since (1) it j
did not appear to be reportable, (2) the licensee took immediate corrective actions to correct the problem and prevent recurrence, and (3) the inspector did not observe any other apparent violations associated with criticality control requirements; this apparent violation is not being cited because the criteria specified in Section V.G. of the Enforcement Policy were satisfied (NCV 70-1257/90-01-04, Closed).
The licensee's performance in this area appeared adequate and their program seemed capable of meeting its safety objectives.
However, the findings identified in the licensee's September 1989, monthly criticality safety audit, and the NCV noted in this paragraph may be indicative of a weakness in personnel following established procedures.
One NCV was identified.
6.
Operations Review (88020)
This area was reviewed to determine if operations were being conducted in i
accordance with the License Conditions, licensee procedures, and recommendations outlined in various industry standards.
The inspection i
of this area was primarily based on observations made during facility tours, and discussions with co0nizant licensee representatives regarding current plant o)erations.
In addition to observations described in other paragrapis of t1is report, the inspector made the following additional observations:
a.
Lagoons The licensee had installed a new enclosed pumping and valve station, which included new equipment, designed to facilitate the ease of liquid waste transfers. The old pumping and valve station was not enclosedandwassubjecttooutsideweatherabuse.
The inspector noted that lagoon No. 2 remained pumped down and liner repairs had been completed on lagoon No.l.
All lagoons with the exception on were noted to be in service.
RegardIngthedisposalof No. 2,inated sand retrieved from the lagoons, described in contam Inspection Report No. 70-1257/89-03, the licensee had not resolved this matter as of this inspection.
b.
Other Operations In the VO Building, chemical conversion lines 1 and 2 were in full 2
operation, and all three powder lines and pellet lines were being operated as called for.
These operations were being operated 24
A.*
3g i
~4 i-hours a day, with 3 manned shifts, during the normal 5 day work week.
The inspector noted that the licensee had replaced the fire door on the incinerator in the Solid Waste Uranium Recovery Facility, and were restarting operations in this area.
During facility tours, the inspector noted that housekeeping was generally good.
A few items involving minor industrial safety questions were brought to the attention of appropriate licensee representatives and were immediately corrected and/or were being actedonaccordIngly.
During facility tours, the inspector also noted that fuel handling, storage, and UF cylinder operations observed were being conducted inaccordancewkthlicenseeproceduresandindustrystandards.
The licensee's performance in this area appeared adequate, and their program appeared capable of meeting its safety objectives.
No violations or deviations were identified.
7.
Exit Interview The inspectors met with the licensee representatives, denoted in Section i
1, on January 12, 1990, and at the conclusion of the inspection on l
February 9, 1990.
the scope and findings of the inspection were summarized.
The licensee was informed of the two apparent violations identified in
~
this report, one being classified as a NCV.
The cbservations described in the report, with the exception of those made of the in-office review of their evaluation of urine sample measurements were presented to the licensee represente,tives, e
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