ML20028G851

Insp Rept 70-1113/90-07 on 900618-22 & 0801-03.Violations Noted.Major Areas Inspected:Review of Licensee Radiation Protection Program Activities,Radioactive Contamination Control,Violations & Info Notices

ML20028G851
Person / Time
Site:	07001113
Issue date:	08/20/1990
From:	Bassett C, Elliott M, Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20028G849	List: ML20028G848 ML20028G851
References
70-1113-90-07, 70-1113-90-7, IEIN-89-013, IEIN-89-024, IEIN-89-035, IEIN-89-13, IEIN-89-24, IEIN-89-35, IEIN-90-009, IEIN-90-014, IEIN-90-020, IEIN-90-027, IEIN-90-030, IEIN-90-035, IEIN-90-14, IEIN-90-20, IEIN-90-27, IEIN-90-30, IEIN-90-35, IEIN-90-9, NUDOCS 9009050149
Download: ML20028G851 (34)

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Report No'. :: 70-1113/90-07

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e Licensee:' General Electric Company' y

Wilmington,-NC 28401 Docket No.:- 70-1113 License No.:

SNM-1097 Facility Name:

General Electric Company Inspection Conducted: June 18-22, and August 1-3, 1990-Inspectors:

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Approved by:

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J. P. Potter, Chief Date Signed.

Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety-and Safeguards

SUMMARY

Scope:

This. routine, unannounced inspection -involved review of licensee radiation protection (RP) program activities. including program staffing ar.d organization, training, radioactive contamination _. control, audits, internei. and external exposure controls and evaluations; transportation of radioactive materials; and review - of previously identified inspector followup ' items violations, cnd.

Information Notices.

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.Results:-

ia Continued ' maintenance of fadi1ity cleanliness and upgraded housekeeping were noted.

Organizational and staffing changes to the Nuclear Safety Engineering (NSE) groupi met License ' Application requirements. - Training and medical L

qualifications for personnel were conducted in accordance with established RP p

program schedules 1 ~ : Air sampling and bioassay monitoring programs were

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' conducted in accordance with established procedures and results were' below applicable license and 10 CFR -limits.

Routine-reports required by 10 CFR Parts 19 and 20, and audits required by :the licensee were completed as-required.

In general, transportation activities were managed effectively and associated procedures were technically adequate.

i Significant concerns were identified relative to evaluation and subsequent-assignment of extremity doses -for selected workers.

Additional program weaknesses included the continued. failure to follow radiological controls

-l specified in procedures for personal radiation protection,- process / recovery operations, and Special Nuclear Material (SNM) sealed-source requirements. An inadequate survey for an-. operator exiting a radiologically controlled area (RCA) was identified.

Within the areas inspected, the following apparent violations were identified.

Failure to have written procedures for conducting the extremity monitoring program for personnel routinely handling unclad uranium material (Paragraph 2.a).

Violation of license condition No. 9.

Failure to monitor and record exposure to the extremities in accordance

-withinstructionsprovidedinNRCForm5(Paragraph 2.a).

Violation of 10CFR20.401(a) requirements.

Failure to supply and to require the use of appropriate extremity exposure monitoring equipment by individuals potentially exceeding 25 percent of 10 CFR 20.101(a) limits (Paragraph 2.b).

Violation of 10'CFR 20.202(a)(1) requirements.

Failure to maintain occupational doses to the skin of the_ hands below 18,75 rem per quarter for individuals handling unciad uranium material (Paragraph 2.c).

Violation of 10 CFR 20.101(a) requirements.

Failure to conduct adequate surveys / evaluations of the hazards present to detect radioactive contamination on the skin of the foot by a Uranium Recovery Unit (URU) worker exiting a radiologically controlled area (RCA)

(Paragraph 4.c).

Violation or 20.201(b) requirements.

Failure to follow procedures for the following radiation protection program areas / activities. Violation of License Condition No. 9.

a.

Personal radiation protection guiuance for:

(1) respirator storage (Paragraph 7); (2) thermoluminescent oosimeter (TLD) use (Paragraph _8.b); and (3) posting a radiation area within a storage pad (Paragraph 8.c).

b.

Process / recovery operations for (1) storing combustible materials near empty UF6 cylinders (Paragraph 8.e); (2) bagging process equipment filters (Paragraph 8.f); and (3) maintaining lids and lock rings for storage cans (Paragraph 8 9).

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c.

Performing inventory and leak tests-of SNM sealed sources (Paragraph 9).

Failure to provide exclusivt use-vehicle instructions to drivers in accordance with 49 CFR 173.425(b)(9) requirenents (Paragraph 10).

Violation of 10 CFR 71.5 requirements.

4:

s 4 Y REPORT DETAILS 1.-

Persons Contacted Licensee Employees D. Barbour, Shift Supervisor, Radiation Protection (RP)

1. • B. Bentley, Manager, Fuel Manufacturing

• G. Bowman, Senior Program Manager, Compliance Improvement

• D Brown, Senior Program Manager, Fuel Manufacturing Operations (FMO)

1. • R. Foleck, Senior Specialist, Licensing Engineering

• R. Keenan, Senior Engineer, Nuclear Safety Engineering (NSE)

R. Lewis, Shift Supervisor, RP

• W. McMahon, Acting Manager, Nuclear Fuel and Component Manufacturing (NF&CM)

1. S. Murray, Manager, NSE

1. • R. Pace, Program Manager, FM0

1. • H. Shaver, Nuclear Safety Engineer

1. • H. Strickler, Manager, Industrial Safety and Environmental Protection

1. • R. Torres, Program Manager, Radiation Protection

• C. Vaughan, Manager, Regulatory Compliance

• H. Walker, Manager, Shipping and Traffic

1. • T. Winslow, Manager, Licensing and Nuclear Material Management

• R. Yopp, Team Advisor, Shipping and Traffic Other licensee employees contacted included engineers, analysts, technicians, operators, and office personnel.

• Attended exit interview conducted June 22, 1990

1. Attended exit interview conducted August 3, 1990 2.

External Exposure (83822) 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regula-tions in'10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

10 CFR 20.101(a) requires that no licensee possess, use or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; and 18.75 rem to the hands and forearms, feet and ankles.

10 CFR 20.202(a) requires each licensee to supply appropriate personnel monitoring equipment and require the use of such equipment by each individual entering a restricted area under such circumstances that he receives or is likely to receive, a dose in any calendar quarter in excess j

of 25 percent of the applicable value specified in 10 CFR 20.101(a).

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10CFR20.202(b) defines personnel monitor.ing equipment as devices designed to _ be worn _.or carried by an _ individual for the purpose of measuring the. dose received.

10 CFR 20.401(a) requires each licensee to maintain records in accordance j

with the instructions contained in NRC Form 5. Current Occupational External Radiation Exposures, dated October 1981, showing the radiation exposures of all individuals for whom personnel monitoring is required under10'CFR20.202(a).

License Condition No. 9 of SNM-1097 requires that licensed material be used in accordance with statements, representati0ns, and conditions of_

Part I of the License Application.

The licensee's extremity (hand) dose monitoring program for individuals involved with handling unciad uranium material was reviewed in detail, a.

Implementation Part I, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.

During the onsite inspection licensee representatives informed the inspector that extremity dose assessment was calculated from algorithms and specific assumptions (parameters) detailed in a study documented in March 1983. The study correlated workers' " touch time" with handling of known masses of _ unclad uranium material.

In addition, the uranium material dose rates and the equivalent absorber i

thickness shielding provided by the workers' protective gloves were empirically determined.

Based on the mass of material handled by each individual conducting various operations for known times, the licensee assigned a calculated extremity dose.

No updates of the i

assessment algorithms or assumptions were conducted since 1983.

4 The inspector requested to review guidance utilized to conduct the 1983 study.

Licensee representatives stated that the 1983 study was not conducted in accordance with written procedures nor were any procedures subsequently developed.

The inspector and licensee representatives discussed operational changes since the referenced study including increased enrichment of processed material, elimination of and automation of operations requiring extremity monitoring, and changes in ' personnel.

The-inspector noted these changes were expected to affect the calculated extremity dose and guidance was required to evaluate the radiation hazards present, to i

establish the criteria and the frequency for reviewing program adequacy, and to determine methods for verifying the extremity doses assigned to individuals. The inspector informed licensee represent-atives that the failure to have written procedures for conducting the extremity monitoring program for personnel handling unciad uranium 1

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material was considered a violation of License Condition No. 9-(70-1113/90-07-01).

t A concern with an assumption made in the 1983 study and subsequently utilized for extremity dose assessments was reviewed and discussed.

The study assessed the extremity - skin dose through a tissue equivalent absorber thickness (sxNce density) of approximately 57.6 milligrams per square centiip- (mg/cm ).

This value was r

selected from data provided in ICRF byort No. 23, Report of the Task Group on Reference Man, which refermed a female finger epidermal thickness of 384 micrometers (um).

Using this value, the licensee calculated a tissue equivalent thickness of 57.6 mg/cm2 The inspector informed licensee representatives that assessment of the skin dose at this tissue equivalent absorber thickness was contrary to the 7.0 mg/cm2 requirement outlined in,. Instructions for-Preparation of NRC Form 5, dated October 1981.

Further guidance referencing the requirement for assessing skin dose through an absorber thickness of 7.0 mg/cm ~ was provided in selected NRC.

r Information Notices (ins) including IN 81-26, Part 3 Placement of Personnel Monitoring Devices for External Radiation Exposure.

IN 83-59, Dose Assignment for Workers in Non-uniform Radiation Fields, and IN 86-23, Excessive Skin Exposures Due to Contamination With Hot Particles.

The inspector verified that the licensee had received the subject ins.

The failure to assess extremity skin dose at 7.0 mg/ cme was identified as an apparent violation of 10CFR20.401(a) requirements (70-1113/90-07-02).

The inspector noted that NRC regulations establish that the limits in 10 CFR 20.101(a) for doses to the skin or skin of the extremities must be applied at an absorber thickness of 7.0 mg/cm.

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evaluated through this absorber thickness must be included on each individual's permanent record.

However, the inspector noted that supplemental evaluation of skin dose through different absorber thickness which may be more representative of the actual risk to an individual worker can be conducted based on various assumptions.

Such assumptions could include the depth of sensitive tissue for l

portions of the hands or feet. The assumptions for the supplemental evaluation and the resultant skin doses may be annotated on the permanent dose records maintained for each individual.

An apparent violation for failure to have written procedures for evaluating extremity doses and an apparent violation for failure to assess skin doses in accordance with NRC Form 5 were identified for personnel handling unclad uranium material.

l b.

Extremity Dose Monitoring Requirements l

l The inspector reviewed and discussed with cognizant licensee representatives, the January 1,1987 through March 30, 1990 annual and quarterly extremity doses assigned to personnel handling unclad uranium materials in selected facility process areas.

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c doses routinely were assigned on an: annual basis for approximately 85 2

to 110 individuals.- The maximum. annual: extremity dose assigned to a worker handling unclad uranium; materials was approximately 48 rem.

l From selected review of the data, the inspector noted approximately -

100 occurrences of workers assigned quarterly doses - exceeding 25 percent of the 10 CFR 20.101(a) 18 '75 rem extremity limit, that is-4.7 rems, requiring the use of extremity monitoring equipment.

Cognizant licensee representatives stated that all extremity doses associated with unclad uranium handling operations were assigned based on the documented 1983 study and no exposure monitoring equipment was utilized.

The inspector informed licensee represent-atives that the failure to provide extremity monitoring equipment for, personnel-potentially exceeding 25 percent of the 10 CFR 20.101(a) limits was an apparent violation of 10 CFR 20.202(a) requirements (70-1113/90-07-03).

Part I, Chapter 3, Section 3.2.4.9 of the License Application states, in part, that extremity exposures may be_ determined and assigned on the basis of engineering evaluations when TLD measurements are not practical.

During the onsite inspection, licensee representatives requested that Section 3.2.4.9 of the License Application be considered an exemption:

from 10 CFR 20.202(a) requirements.

The inspector noted that-the referenced details were not included in Part 1, Chapter 1, Section 1.8 of the Application which specifically lists exemptions and special authorizations.

Furthermore, NRC, Nuclear Material and Safety Safeguards (NMSS) licensing representatives confirmed that the referenced details did not exempt the licensee from meeting the applicable requirements, i

An apparent violation for failing to provide and use personnel monitoring equipment in accordance with 10 CFR 20.202(a) requirements l

was identified, c.

Dose Assessments The inspector noted that the licensee's assessment of extremity skin dose through a tissue equivalent absorber thickness of 57.6 mg/cmr resulted in a nonconservative bias for the-assigned dose relative to the dose calculated through 7.0 mg/ cme which is required for evaluating regulatory compliance.

From the licensee's original attenuation data provided in the 1983 study, the inspector calculated a nonconservative bias of approximately 28 percent for the extremity doses assigned at 57.6 mg/cm2 relative to doses calculated for a 7.0 mg/ cme tissue equivalent absorber thickness.

The inspector informed licensee representatives that, when adjusted for the 28 percent bias, their calculated quarterly extremi':y doses in excess of 14.6 rem would exceed the 10 CFR 20.101(a) limit of 18.75 rem allowed to the skin of the hand.

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The.' inspector selectively reviewed January 1,1987'through June 30, 1990 quarterly extremity exposures records for individuals and adjusted the licensee assigned values for the determined nonconservative bias.

Based on the adjustment, three individual exposures, as evaluated at a tissue equivalent absorber thickness of of 7.0 mg/cm. exceeded 18.75 rem.

The inspector informed licensee r

representatives that the failure to limit calculated extremity exposures to the skin of the hand below 18.75 rem per quarter for the workers was an apparent violation of 10.101(a) requirements (70-1113/90-07-04).

During--the onsite audit, cognizant licensee representatives stated that several assumptions in the 1983 documented " touch time" study were believed to be conservative and requested that the potential exposures be considered an unresolved item.

Furthermore, a-1983 verification study using TLD monitoring to verify calculated extremity values was believed to have been conducted but was not available for review.-

Licensee representatives could not assure that the study was conducted, or if completed, whether the data were available.

During ; an August 6, 1990 teleconference, licensee representatives stated that the 1983 verification results were found; however, determination of the actual experimental setup and evaluation of any resultant biases would require additional review and-possibly additional _ TLD studies. The licensee provided no assurances that the 1983 results were applicable to conditions existing from 1984 ' through 1990.

Based on this information, the inspector informed licensee representatives that the issue regarding individuals being assigned exposures exceeding 10CFR20.101(a) limits would not be considered an unresolved item.

One apparent violation for three individuals assigned quarterly extremity doses to the skin of the hand in excess of 18,75 rem was identified.

d.

Whole Body Exposure The inspector reviewed cumulative whole body' external exposures for Fuel Manufacturing Operations (FM0) hourly employees listed on January 1 through-June 1,1990 termination reports.

The inspector verified that whole body monitoring was provided by a NVLAP approved vendor.

From review of the data, all external whole body exposures were within 10 CFR Part 20 limits and no violations or deviations were identified.

3.

Internal Exposure (83822) 10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed material in such a manner as to permit any individual in a restricted area to inhale a quantity of radioactive material in any

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g period of one calendar quarter greater than the quantity which-would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B.

Table 1 Column 1; 10 CFR 20.103(a)(3) requires for purposes.of determining complier.:.e with the requirements of this section, the licensee shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual. intakes of radioactivity by exposed individuals, i

10 CFR 20.103(b)(2) states that whenever the intake of radioactive material within any period of seven consecutive days by any individual' exceeds' that which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentrations specified _in Appendix B, Table 1, Column 1, the licensee shall make evaluations and take such acticns as are necessary to assure against recurrence.

The licensee shall maintain records of such i

occurrences, evaluations, and actions taken in a clear and readily identifiable form suitable for summary review and evaluation.

a.

Air Sampling The inspector reviewed selected January 1988 through Jun 1990 airborne concentration data for specific job functional areas (JFAs).

l The inspector noted and discussed with cognizant licensee personnel the JFAs with the highest average airborne concentrations from January 1,1988 to June 21, 1990.. These areas and their average maximum permissible airborne concentration (MPCa) levels were as follows:-'Radwaste - 50 percent MPCa, Slab Blender. _30 percent MPCa, and Sluggers - 25 percent MPCa.

The inspector reviewed the procedures pertaining to the implementation of the urinalysis and q

lung counting measurement programs for personnel frequenting these I

areas. The inspector verified these areas were being reviewed by the i

Radiation Safety Committee for possible airborne concentration j

reduction actions.

No violations or deviations were identified.

b.

Lung Burden Analysis Practices and Procedures (P/P) 40-19, Bioassay Program Rev. 8, dated September 20, 1989, requires the licensee to implement a bioassay program in order to ccJ, ply with the conditions of NRC license SNM-1097.

Section 4.2 of the procedure requires the licensee to perform individual lung counts based on each worker's assigned airborne exposure and/or previous lung burden results.

The procedure establishes the limits for restriction of individuals from controlled areas or the frequencies requiring reanalyses.

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The inspector reviewed January 1, 1988 to June 21, 1990 lung burden' data = for individuals working in selected JFAs.

Based on.a review of.

generaliair sample results the Slab Blender, Radwaste, Slugger, Incinerator, anti New Decon areas presented the greatest potential for a!rborne exposure in the facility.

The inspector noted that several worke s were assigned airborne exposure levels greater than 520E-11 microc.irie-hours per cubic centimeter (uCi-hrs /cc) per quarter, that is levels exceeding 10 percent of the 10 CFR Part 20.103(a) limit.-

These data required lung counting frequencies for those individuals to be. increased from an annual to a quarterly schedule. -One observed 4

lung burden result, 165 micrograms (ug) uranium-235 (U-235), was greater than the 150 ug U-235 limit and required subsequent lung burden analyzes to be increased from an annual to quarterly frequency.

Records reviewed indicated that the licensee performed the lung counts for workers exceeding the 150 ug limit as required.

No violations or deviations were identified, c.

Urinalysis Nuclear Safety Instruction (NSI) 0-2,0, Bioassay - Urinalysis Program, Rev. IP, dated March 7,1990, requires the licensee to perform drinalysis measurements on individuals assigned to work in areas where soluble uranium compounds (e.g. uranium hexafluoride, uranyl nitrate, uranyl fluoride, and related compounds) are processed.

Appendix A of NSI 0-2.0 recuires worker urine samples to be submitted for testing weekly or at tie end of each shift depending on the work area.

The inspector reviewed January 1, 1990 to June 21, 1990. urinalysis results for individuals working in the Vaporization and Uranium Recovery Unit.(URU) areas.

Several individual's urinalysis results exceeded 15 micrograms per liter (ug/1) for workers in UNH area or

'35 ug/l for workers in UF6 area-which requires the licensee to calculate an uptake for the respective individuals.

The records reviewed indicateo that no individual exceeded the single uptake limit of 2.7 milligrams total uranium (mg U) or the seven day cumulative limit of 1.4 mg U which would restrict the individual from all airborne controlled areas.

No violations or deviations were identified.

4.

Radiation Controls (83822) 10 CFR 20,201(b) rr: quires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

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a.

. Contamination Surveys >

Chapter 3, Section-3.2.4.6 details removable surface contamination action _ levels requiring. decontamination for controlled and uncontrolled areas.-

The inspector reviewed contamination surveys conducted within selected process RCAs.

All values were less than values requiring decontamination.-

No violations or deviations were identified.

b..

Personnel Survey Instrumentation The RP technician daily audit checklist provides the frequency for conductirg calibrations and/or performance checks of personnel survey equipment at selected RCA access points.

The inspector reviewed March 1 through June 21, 1990 logs of daily _

performance checks for survey instruments maintained at RCA access points associated with. incinerator, URU, and FM0 facilities.

All performance checks were conducted in accordance with the established schedule.

No violations or deviations were identified.

c.

June 8, 1990 Personnel Contamination Incident

. Process Requirements and Operator Document (PROD) No. 85.08, Change

. Room PROD, Personal Survey Leaving Controlled Area, dated December.8, 1986, requires a personal survey for possible contamination on clothing and body, includir.5 the feet and ankles, to be conducted by all personnel when leavir.g the Controlled Area.

During a teleconference on June 11, 1990, the licensee' notified NRC RII representatives of a June 8, 1990 incident involving a employee I

with contamination of his clothing and feet who exited the site as a result of an improper personal survey (frisk). Additional review of licensee RP activities associated with the event were reviewed during the current audit.

r The licensee's Radiological Incident Report indicated that a RP technician noticed yellow foot prints-on-the clean side floor of the URU area access step-off pad (SOP) at approximately 7:10 hours (hr) b on June 8,

1990.

Direct surveys indicated contamination, approximately 20,000 disintegrations per-minute (dpm) alpha per probe area. The contaminated foot prints led from the process area change room to a specific operator's locker.

All URV area access control l

point and locker room activities were stopped and additional l

radiological surveys wera conducted.

Survey results ranged from l

below detection limits to approximately 22,000 dpm/ probe area.

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' and the identified worker's locker.

Subsequent surveys of the identified operator's permanent controlled area shoes indicated contamination inside of the shoes.

The shoes were utilized only within the process area and were maintained on the hot side of the change: room S0P.

Concurrently, RP personnel were dispatched to the identified operator's residence to evaluate contamination of the individual and potential; contamination of his residence and personal belongings.

Contamination of the operator's socks and skin of the feet was verified.

A maximum value of skin contamination, 90,000 dpm per probe area (approximately 59 cm ), on the bottom of the right' foot, i

e was reported.

Excluding the socks and shoes worn to work, no contamination was found within the residence. The operator returned to the site for decontamination activity and also submitted bioassay _

samples for subsequent urinalysis evaluations.

Decontamination-activities were conducted from June 8 through June 11, 1990, by site i

medical personnel and included washing and subsequent abrasion of the contaminated callused skin on the foot bottom.

Contamination levels were reduced to approximately 200 dpm/ probe area for the bottom of the right foot.

The licensee's exposure evaluations for the event were reviewed. All urinalysis results were less than the licensee's detection limit of 5.0 ug U/1.

The calculated skin dose, approximately 10 millirem (mrem), through a density thickness of 7 mg/ cme and for an exposure time of seven hours was below regulatory limits.

The inspector reviewed and verified the licensee's investigation findings, probable causes, and corrective actions regarding the contamination event.

Radiation survey instrumentation operability within the URV change room was verified at the time of the incident.

The affected operator recently completed training regarding personal survey requirements when exiting licensee controlled areas.

Furthermore, the licensee's investigation indicated that process liquids which had accumulated on the floor seeped through a hole in the heel of the operator's controlled area shoes and resulted in the initial contamination of the shoes, socks, and skin of the foot. The licensee's investigation concluded, based on the above details, that the operator did not perform an adequate personal survey (frisk) when exiting the change room area.

The inspector discussed the incident with the operator.

The individual agreed with the licensee's report based on the evidence presented.

The licensee requested that the incident be categorized as a licensee-identified violation (LIV) in accordance with 10 CFR Part 2, Appendix C.

The inspector noted that a similar violation with multiple examples for failure to perform a proper frisk was identified during an inspection conducted from May 22, through June 23,1989, and documented in Inspection Report (IR) 70-1113/

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89-05; _ Based on the previous frisking issue with multiple examples,

= the event was cited as an apparent violation of 10 CFR 20.201(b) requirements (70-1113/90-07-05),

t One apparent violation 'for failure to perform an adequate survey to evaluate the hazards present resulting in a contaminated worker exiting the site was identified.-

d.

RadiationWorkPermit(RWP) Implementation Chapter 3, Section 3.3.1 of the License. Application requires RWPs to be - issued-for nonroutine operations which are not covered by operating procedures.

The RKP specifies the necessary radiation safety controls, as appropriate, including personnel monitoring devices, lr sampling, 'and additional precautionary measures to be orotective clothing, respiratory protective equipment,

'i special a taken.

NSI 0-9.0, Radiation Work Permit, Rev.19, dated April 17, 1990, documents the licensee RWP program and requires documentation of any problems.

The. inspector discussed implementation of the RWP program with cognizant licensee personnel.

The assignment of a full-time RP technician for implementing and reviewing contractor RWP activities

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continued.

All contractors are required to document that they have read the RWP details.

Copies of the active RWPs are maintained in the main RP office and, in addition, are posted for easy reference in the Radiation Safety Offices.for the process areas.

Licensee representatives stated that upgrades to the program included maintaining - a " Lessons Learned Manual" to identify good and poor e

practices from current activities.

' Identified issues included reduction in the use of personal equipment / tools moved into the controlled area, and selection of type of decontamination utilized for specific activities.

Files of previous tasks were being

- maintained for 6 months.

The use of historical RWP data for subsequent planning purposes was not required.

Licensee representatives stated that no significant problems with contractor activities were identified since the previous NRC audit.

No violations or deviations were identified.

5.

Administrative Controls (83822) a.

Radiation Safety Committee Chapter 2, Section 2.3 of the License Application to License No. SNM-1097 details the purpose and functions of the Radiation Safety Committee (RSC).

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11 P/P 40-31,' Operational Radiation ' Safety Committee, Rev. 3, dated April 23,1990, requires the RSC to promote continued improvements in-limiting employee radiological exposures and potential radiological-health and safety hazards and to hold meetings at'least monthly. The-inrpector examined the duties and accomplishments of the operational RS; which was established in accordance with Chapter 2 of the SNM-1097 license application.

The RSC members receive and/or identify operational nuclear safety concerns. A course of action to improve the concern is developed by the Committee as a project.- The projects are pricritized and goals' established by' the RSC. The Committee regularly tracks the progress of the projects and closes-the projects when appropriate.

The inspector reviewed RSC meeting minutes from January 1,1988 to June 20, 1990.

Review of the records $1dicated that the RSC conducted monthly meetings as required.

Various RSC. projects included reduction of airborne exposure in the Radwaste, Slab Blender and Slugger areas.

No violations or deviations were identified.

b.

AuditsandInspections(83822)

Chapter 2, Section 2.8 of the License Application to SNM-1097 details guidance for performing nuclear safety inspections and radiation safety audits by selected site and outside groups.

Section 2.8.1 of the License Application, provides guidance for conducting quarterly (not to exceed 100 days) safety audits and weekly inspections of nuclear manufacturing and support areas to determine that-actual operations conform to criticality and radiation safety requirements.

The inspector verified that weekly inspections and quarterly audits were being conducted as required.

During the onsite audit, licensee representatives were conducting the second quarter 1990 safety audit.

The preliminary licensee findings were not reviewed by the inspector.

No violations or deviations were identified.

t c.

Facility Change Requests (83822)

License Condition No. 9 of SNM-1097 requires that licensed material be used in accordance with statements, representations, and l

conditions of Part I of the License Application.

Part I, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.

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I NSI No. E-3.0 - Nuclear Safety Review Request, Rev.14, dated December 14, 1989, requires for Facility Change Requests (FCRs) requiring a radiological safety' review that tne NSE engineer compile' and generate an index of all necessary documentation including, air flow verification data and drawings.

NFI No. E-1.0, Nuclear Safety Review Records, Rev. 13, dated December 19, 1990, details required air flow verification-letter / memo records, and pertinent drawings and sketches, as applicable, to be included as part of the Nuclear Safety Review records.

NSI No. E-7.0, Radiological Safety Review for Process and Equipment Change Request, Rev. 11, dated October 12, 1989, requires the assigned NSE engineer to ensure that the required documents per NSI E-1.0, as appropriate, be included in the request file folder..

1 Selected FCRs initiated and/or completed from January 1 through June 23, 1990, were reviewed.

FCR No. 90.001, dated March 18, 1990, i

regarding ir,stallation and movement -of selected process equipment i

~

within a process RCA was reviewed in detail. The inspector verified that air flow evaluations were complete and documented appropriately.

No violations or deviations were identified.

d.

Termination Reports 4

10 CFR 20.408(b) and 20.409(b) eequire that the licensee make a report to the Commission, and notify the individual involved, of the radiation exposure of each individual who has terminated employment.

NSI E-6.0, Personnel Dose Reporting, Rev. 16, dated January 11, 1990,-

defines the NSE procedure to assure complete and accurate reporting L

of exposures to employees as required by 10 CFR Parts 19 and 20. The 7

NSE group is responsible for monthly tracking of site terminations and providing either the actual or an estimate of exposure results within 90 days subsequent to an individual's termination from the Nuclear Fuel and Component Manufacturing (NF&CM) division.

The inspector-reviewed and discussed with cognizant licensee representatives the process for issuance of termination exposure l;

results for employees terminating employment from the FM0 area operations.

For NF&CM employees terminating from GE or transferring to a non-nuclear division at the site, a termination letter is L

required to be issued within 90 days.

However, for personnel transferring from the FM0 area to either the Fuel Component Organization (FCO) or Services Component Organization (SCO)

I departments, a termination letter is not issued although personal dosimetry is not required for work within either the SCO or FC0 areas.

The inspector discussed the possibility that FC0 and SCO personnel originally transferred from FM0 to these departments, would not be issued the required individual dose report after termination L

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F 13-from the NFECM division.

Cognizant licensee representatives stated that personnel ~ transferred from FM0 to'either area remained active in regard to their termination status within the nuclear division. The inspector reviewed' selected FM0 personnel transfers from the FM0 to either the 500 or FC0 departments and veri?ied that their status for NSE radiological reporting purposes was appropriate.

The inspector requested the Employee and Comunity Relations group to provide hourly employee terminations initiated from January 1, through June 1, 1990.

For the identified individuals, the NSE group issued the appropriate individual termination letters within the required 90 day period.

Furthermore, the inspector verified that the reports contained the applicable. external and internal exposure data as requested in_a letter from the NRC to all fuel Cycle and Katerials Licensees dated May 3, 1985.

No violations or deviations were identified.

6.

Training (83822))

10 CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of thc. restricted areas in the health protection aspects associated with 'expc:,ure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection. devices employed, applicable provisions of Consnission Regulations, individual's responsibilities and the availability of radiation exposure data.

Chapter. 2, Section 2.6 of the License Application requires that employees complete formal nuclear safety training prior to unescorted access _in the controlled area and with retraining to be conducted biennially.

During the current audit, the - inspector verified that training was provided to selected operators from the URU and Chemical area of the facility.

For the records reviewed, all individuals were trained or l

retrained at the scheduled frequency.

No violations or deviations were identified.

-7.

Respiratory Protection Program (83822) 10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protective program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual l

exposures; written procedures to select, fit and maintain respirators; l

written procedures regarding supervision and training of personnel and l

issuance of records; and determination by a physician prior to use of respirators, that the individual user is physically able to use E

respiratory protective equipment.

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14 PROD No. 85.06, Rev. 6, issued ' December 13, 1989, requires that "used" respirators should be placed in designated containers or taken back to the laundry.

This PROD also states that bagged (used or unused)-respirators may be taken to work locations and placed on equipment or tool boxes for anticipated or short term use provided they are not abandoned.

The inspector reviewed the licensee's program for implementing their respiratory protection program at the facility. A training film covering several. subjects, including respirator usage, was also viewed by the inspector. The film was used to train new personnel and also was provided i

as supplemental training to retrain or requalify all employees-who are-required to wear respiratory protection. The film emphasized the fact that, af ter completion of each - shif t, those who ~ used respiratory protection during the shift were required to return them to designated containers where they would be collected for cleaning.

Or, if workers could do so, they were encouraged to return the used respirators to the laundry.

Through observations of various operations in progress, the inspector determined that personnel were wearing respiratcrs when required in controlled areas and that there was a sufficient quantity of respirators available for ute.

However, a problem was noted concerning the disposition of used respirators.

During a tour of the facility on June 18, 1990, the inspector noted several unbagged respirators that had been left in various locations throughout the facility,-apparently after they had been worn during a job.

L The used respirators had not been left in areas where they mi at become b

contaminated or damaged but had been stored in storage cabinets or on racks designed for that purpose.

This appeared to-be in accordance with the supplemental training that had been provided to all workers during training on the use of respiratory protective devices.

However, on June 19, 1990, again during a tour of the facility, the inspector noted 1

that one used, unbagged respirator had been left in the Slab Blender area from the day before.. All of the other used respirators that had been observed the day before had been collected and returned to a designated container or to the laundry.

The licensee was informed that failure to return a used respirator to a designated container or to the laundry was an. apparent violation of License Condition No. 9 (70-1113/90-07-06). The inspector noted that this item was similar to violaticns and an unresolved item identified during two p;avious NRC inspections conduc'ed_ May 22 through June 23, 1989, and February 5 through 9,1990, and documented in Inspection Reports (irs) 70-1113/89-05 and 70-1113/90-03, respectively.

Furthermore, the inspector noted that IR 70-1113/89-05 documented concerns regarding respiratory protective equipment storage as identified by licensee Audits in 1988 and 1989.

' The inspector dit;ussed with licensee representatives concerns regarding potential contamination of bagged respirators stored in work areas.

The licensee indicated that this was not a problem for several reasons.

First, according to an internal memorandum generated for use within the

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Radiation Safety group, a begged respirator can be left in a work area (such as on a piece of eouipment or on a work desk) for 3-4 days before it is considered abandoned.

Second, although the term " abandoned" was specifically used in conjunction with begged (used or unused) respirators 16 *t in the work area, the licensee also extended this to refer to those that had been used but left unbagged on a storage rack or in a cabinet.

In discussing the established guidance with various workers, the inspector determined that they were under the impression that a used respirator was required to be returned to a designated container or taken back to the laundry following the shift. They were unaware of the interpretation that a used (unbagged) respirator could be left in an area for 3-4 days before it was considered abandoned and had to be disposed of in a container or taken to the laundry.

The inspector informed licensee representatives that differences presented in the training film, procedures, and the internal memorandum were considered a respiratory program weakness.

One apparent violation for failing to follow radiation protection pro d ures for respiratory protective equipment was identified.

8.

FacilityTours(83822)

License Condition 9 of INM-1097 requires that licensed material be used in accordance with statemen's, representations, and conditions of Part I of the License Application.

Part I, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be l

conducted in accordance with written procedures.

During the onsite audit, the inspector selectively toured the licensee's facility and storage areas, observed facility operations, and observed work being performed in various JFAs to evaluate the implementation and effectiveness of the licensee's radiation protection program.

The following specific radiation protection conditions, practices, and items were noted and/or discussed with licensee representatives.

I a.

UseofProtactiveClothing(PCs)

PROD No. 85.05, Protective Clothing Rules, Rev. 4, dated August 13, 1987, requires that specified PCs be worn by observation and working personnel.

Posted instructions at the entrance to the controlled area also stipulate that working personnel and observation personnel wear PCs.

During tours of the facility on June 18 - 21, 1990, the inspector observed licensee personnel wearing PCs in the RCA.

All persons observed were wearing their PCs in the manner prescribed by the PROD.

No violations or deviations were identified.

s 16 b.

Personal TLD Use PROD No. 85.02, Rev. 4, dated April 22, 1988, requires personnel to wear TLD bcdges at all times while working 'in the bundle assembly area.

During tours of the facility, the inspector observed worker practices pertaining to personnel dosimetry usage.

While touring the bundle assembly area on June 20, 1990, the inspector observed two individuals working in the immediate vicinity of the Automated Rod Scanner.

The scanner contains gamma and neutron emitting sealed sources and the area was posted

" radiation area TLD required for entry."

The inspector noted that one of the two individuals was not wearing the required dosimetry.

Upon notification, the individual immediately returned to the TLD sLrage location to retrieve the appropriate dosimetry.

The insmetor informed licensee represent-t atives that failure to follow personal radiation protection procedures for wearing a TLD while working in the bundle assembly l

area was an additional example of apparent violation of License Condition No. 9(70-1113/90-07-06).

One apparent violation for failure to follow radiation protection procedures for wearing appropriate dosimetry was identified.

c.

Area Postings NSR/R No. 4.8.6 Storage Pad 6. Rev.17, dated April 9,1990, requires in Part 3 of the Radiation Safety section that the Secondary Nitrate Waste Treatment (SNWT) can array (s) be roped off and posted as " Caution - Radiation Area".

During tours of the storage areas outside the FM0/FM0X building on June 19, 1990, the inspector observed personnel working in the i

Storage Pad No. 6 area.

The individuals entered a roped off area within the storage pad that was reported to be a SNWT storage area.

The inspector reviewed the requirements listed on the NSR/R posted at the entrance to Pad 6.

The NSR/R required that the SNWT can array be roped off or barriered and posted as a radiation area. The inspector observed that, while the SNWT can array was ropeJ off as required and a sign was hanging on the rope at the access point or entrance where I

I the people entered the area, there was nothing listed on the sign to designate this area as a radiation area.

Upon further investigation, one sign was noted along one side of the rope barrier (at a location where people do not normally enter) that did state " Caution -

Radiation Area". No other signs were posted on any other side of the i

area indicating that the area was a radiation area.

Subsequently, licensee representatives informed the inspector that during a quarterly audit of the area later in the day, the posting problem had been noted and the Radiation Safety personnel were informed.

The licensee stated that the problem was corrected by l

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17 June 20, 1990.

The inspector noted that similar violations regarding posting / barrier requirements were identified during an inspection conducted November 29 through December 2,1988 and May 22 through June 23, 1989, and documented in irs 70-1113/88-18 and 70-1113/89-05, respectively. Licensee representatives were informed that failure to adequately post the storage pad as a radiation area as required by the hSR/R was an apparent violation of License Condition No. 9 (70-1113/90-07-06).

One apparent violation for failure to follow radiation protection procedures for adequately posting an area was identified.

d.

Personnel Contamination Surveys NSR/R No. 85-08. Personal Survey Leaving Controlled Area, Rev. 7, dated December 8, 1986, requires that personal surveys be conducted by placing the scanner probe on an area to be surveyed, holding the probe in place for 1-2 seconds, and monitoring the hands, wrists, chest, TLD badge, neck, face, hair, ankles, and shoes at a minimum.

Following - tours of the facility on June 18 through 21, 1990, the inspector observed various individuals exit the controlled area and perform a personal survey.

No problems were noted with those personal surveys observed.

However, one practice was noted that could pose a potential problem.

On June 21, 1990, at the S0P or control point in the URU area, the inspector noted that several pairs of shoes were lined up next to the raised tile portion of the floor that separated the controlled area from the uncontrolled area.

At approximately 12:00 hrs, one worker was noted leaving the RCA.

As he removed his PCs and stepped across to the uncontrolled side of the RCA control point, he immediately put on his " clean" shoes, went over to the survey meter, and began to monitor himself for contamination.

When the individual almost had completed the frisk, he realized that his feet could not be surveyed properly while wearing his clean shoes.

The worker immediately removed his shoes, surveyed his feet, put on the shoes and proceeded out of the area.

When informed about this practice, licensee representatives stated that they were aware of the problem and were stressing, through the training program, that this was not a good practice.

The licensee also indicated that responsible area managers were required occasionally to cbserve people exiting the various RCA control points and to correct any identified mistakes.

Individuals noted performing an inadequate frisk could be subject to disciplinary actions up to and including dismissal.

No violations or deviations were identified.

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UF6 Cylinder Storage NSR/R No. 4.8.42, Empty Container Storage Area, Rev.1. dated February 20, 1989, requires in Part 3 of the Radiation Safety section that combustible material may not be stored or accumulated within 15 feet of the UF6 cylinders.

During the tours of the outside storage areas on June 19, 1990, the inspector noted a storage area north of the FM0/FM0X building in which BU-7 containers, empty 4x4 metal boxes, and empty UF6 cylinders were stored.

Upon reviewing the NSR/R posted at the entrance to the t

storage area, the inspector noted one requirement which stipulated that no combustible material be stored near the UF6 cylinders.

Adjacent to the storage area entrance, the inspector noted a pile of approximately twelve 2"x4" pieces of wood of varying lengths and other miscellaneous pieces of wood.

This wood was placed beside the fence surrounding the area and was located approximately 2 feet from several stored UF6 cylinders.

I This matter was brought to the attention of the licensee.

The licensee investigated the problem and later indicated that the material was placed there by a worker knowledgeable of the NSR/R requirement regarding the wood accumulation near the UF6 cylinder.

The wood was moved and the worker was given a verbal reprimand. The inspector informed the licensee that accumulating combustible material within 2 feet of the UF6 cylinder storage area was an example of an apparent violation of License Condition No. 9 (70-1113/90-07-06).

One apparent violation for failure to follow procedures for storage of combustible material near empty UF6 cylinders was identified, f.

Contamination Control PROD No. 85.04 Rev. 8, dated August 16, 1989, requires that workers take extra care to prevent airborne contamination and prevent spread of contamination.

PROD No. 80.96 U02 Blend System, Control No. El, Rev.17, dated I

December 12, 1989, requires in the Equipment Operating Instruction (E01) that the operator wear a respirator while removing / replacing the filter bag from the baghouse, place the used bag in a plastic bag which should be taped to the baghouse during the changeout, and handle the used bag and plastic bag so as to limit airborne I

contamination, i

During a tour of the powder and pellet production areas on June 19, 1990, the inspector observed production and maintenance activities.

One operation, a bag-out (change-out) of a filter bag from the baghouse on top of the Slab Blender, was observed in detail.

Because the blender containment was being breached, respiratory protection l

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19 was required to be worn and the area around the blender was barriered-off using a yellow and magenta rope.

During the change out, the operator wore a full-face respirator.

The inspector noted that a plastic bag was not taped to the baghouse as stipulated in the E01 for such an operation to limit airborne contamination and to prevent the spread of contamination.

Subsequent to removing the used filter bsg from the baghouse, the operator 11 aced it on the baghouse platform, and pushed it along the floor with his foot until he reached the edge of the platform.

The ~ operator then climbed down from the platform.

He then got a plastic bag, returned to the r

platform, and finally placed the used filter bag inside the plastic bag and disposed of it.

Through discussions with cognizant licensee representatives, the inspector verified that this was not the appropriate method to i

change-out a used filter bag. The licensee was informed that failure of the operator to take extra care to prevent airborne contamination and prevent the spread of contamination was another example of an apparent violation of License Condition No. 9(70-1113/90-07-06).

On June 20, 1990, the inspector requested that a contamination survey of the blender platform be performed.

The survey indicated no contamination levels exceeding 5,000 disintegrations per minute per 100 square centimeters (dpm/100 cm ).

A review of the area air e

samples results (averaged for the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift period) did not reveal any significantly elevated levels of airborne contamination.

The inspector had no further questions regarding this issue.

One violation for failure to follow operation procedures to prevent airborne contamination and its subsequent spread was identified, g.

Empty Can Storage in the FM0/FM0X NSR/R Control No.1.1.26, Empty Can Storage - FMO, Rev. 3, dated May 11,1990, requires in Parts 1 and 2 of the Radiation Safety section that:

(1) an empty can must have a lid and lock ring in place and (2) that an empty can must be free of visible contamina-tion.

During tours of the facility on June 19, 1990, the inspector noted that numerous cans were in storage throughout the facility.

While touring the B&W Blender area, the inspector noted an empty can located on the conveyor next to the stacker fence.

The can had a lid but no lock ring in place.

Visible contamination was observed in the bottom of the can.

In the B&W hammermill area, the inspector noted an empty can on the conveyor system between the two hammermills in the area.

The can had neither a lid nor a lock ring in place.

Upon further investigation, cans without lids and lock rings were noted in other areas as well.

In the REDCAP area, the inspector noted one can in the empty can storage area without a lid or a lock ring.

While in the 421 (or Stacker) Warehouse, another empty can without the l

c 20 required lid or lock ring was noted in the empty can storage area.

The failure to follow procedures for storage of empty cans with the required lids and lock rings in place was identified as an apparent violation of License Condition No. 9 (70-1113/90-07-06).

The inspector noted that this specific violation of operations-radiation control requirements regarding enipty can storage was similar to a violation identified during an inspection conducted i

May 22 through June 23, 1989 and documented in IR 70-1113/89-05.

Furthermore, the referenced inspection report detailed additional examples of the violation identified within the licensee's 1988 and 1989 quarterly audits.

From discussions with the licensee, the inspector determined that empty can storage apparently was a continuing problem and that various solutions were proposed including abolishing the requirerent.

However, no solution to the problem had yet been agreed upon.

One apparent violation for failure to follow operations procedures for empty can storage was identified, h.

Surveys - Contamination Measurement and Control 10 CFR 20.201(b) re such surveys as (1) quires each licensee to make or cause to be made may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

10 CFR 20.201(a) defines a survey to mean an evaluation of the radiation prot iction hazards incident to the production, use, release, disposal or presence of radioactive materials or other sources of radiation under a specific set of conditions.

When appropriate, such evaluation includes a physical survey of the location of niaterials and equipment, and measurements of levels of radiation or concentrations of radioactive materials present.

NSI No. 0-6.0, Contamination Measurement and Control, Rev. 20, dated l

July 14, 1989, states in Part 5.2.11.1 that items meeting acceptable criteria will be unconditionally released.

Depending on the size, history, and anticipated use, an item can be unconditionally released based on established criteria and training.

l During tours of the facility on June 18, 1990, the inspector observed the can filling process involving the powder pack screener hood in the controlled area of the FM0 designated as the pack area.

The licensee indv.ated that, once a can is filled with powder in the screener hood. it is removed from the hood, wiped clean of any visible contamination, and sent to the uncontrolled area where it is eventually packed in a BU7 container for shipment to a customer.

When asked whether or not a survey is performed on the cans before they leave the controlled side of the pack area, i;he licensee indicated that no such surveys are conducted.

The inspector requested to review previously performed studies verifying that such

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a practice was evaluated and that conclusions were made that no surveys were necessary.

After searching the files, the licensee indicated that apparently no such study had been conducted, although most people in management and those in Radiation Safety could remember that that was the way that cans had always been handled in this area.

The licensee did locate and review the results of random personnel surveys conducted by Radiation Safety supervisors of personnel wno work in the pack area.

These random personnel surveys included individuals who routinely work on non-controlled side of the pack area where the cans are sent following the filling process in the screener hood.

None of these random surveys for the past two years indicated contamination on personnel working in the non-controlled area.

The licensee noted that a review of the surveys conducted in the REDCAP area (the controlled area immediately adjacent to the screener hood room) indicated that ten percent of the sn+ars taken were contaminated.

The licensee also pointed out that only new cans are used in this process and that a plastic bag is placed in the can before filling.

The plastic bag is of sufficient size that it can be folded down over the can during the screener / filling process and after the can is filled, the plastic bag is pulled up from around the can, sealed, and the sealed end placed inside the can.

Each can is also required to be clean of visible powder before going (to the non-controlled area by the NSR/R controlling work in the area NSR/R4.1.4).

From review of licensee operations the inspector could not determine that workers verified that the entire surface of each can was free of visible contamination prior to transfer from the controlled area.

The inspector informed the licensee that the failure to follow procedures to verify that containers released from the FM0 pack area met acceptable criteria for release to uncontrolled areas was an apparent violation of License Condition No. 9.

During an August 16, 1990 teleconference, licensee representatives informed the inspector that a FCR, dated June 8,1972, was located which established the current operating methods which did not require a survey of fuel containers transferred from the FM0 pack area. The FCR established the use of monthly contamination surveys of selected uncontrolled areas to verify contamination levels were less than 200 dpm/100 cmr smearable and 2,000 dpm/200 cmr fixed as required.

Subsequently, the frequency of contamination surveys was increased to a weekly basis.

The licensee indicated that survey data were available for review which they believed indicated, indirectly, that contamination hazards associated with the release of fuel containers were evaluated properly.

The inspector informed licensee representatives that the previously identified violation now would be considered an unresolved item * (URI) pending NRC review of their evaluations FCR, and applicable survey data (70-1113/90-07-07).

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• An unresolved item is an i~tIem about which more information is required to ascertain whether it is an acceptable item, a deviation, or violation.

s a 22 An unresolved item regarding the adequacy of the licensee's evaluation for releasing fuel containers from the RCA was identified.

9.

SNM Sealed Source Radiological Controls (83822)

License Condition No. 9 requires the licensee to use licensed material in accordance with statements, representations, and conditions contained in the License Application dated October 23, 1987.

Part I Section 3.2.4.10 of the License Application for License No. SNM-1097 requires the licensee to perform a leak test on all plutonium sealed sources every three months.

NSI 0-3.0, Sealed Source Control Rev. 12 dated November 27, 1989, requires the licensee to perform a physical inventory and leak test of all S'fM sealed sources every three months.

The inspector reviewed records of sealed source physical inventories and j

leak tests performed fem January 1,1088 to June 21, 1990.

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indicated that from Notember 1, 1989 to March 15, 1990, a period which i

exceeded three months, the licensee failed to perform a physical inventory or leak test on four SNM sealed sources Nos. 92072, 92073, 92074, and 92075.

The inspector discussed the inventory control and leak testing of SNM sealed sources with licensee personnel responsible for performing the tests.

Responsible individuals initially stated the procedure required

" quarterly" surveys.

The inspector discussed with cognizant licensee personnel the definition of " quarterly" and "every three months."

The inspector and all licensee personnel contacted stated that " quarterly" was defined as within a calendar quarter and that "every three months" was defined as three consecutive months, approximately 92 days. The inspector informed the licensee that from November 1, 1989 to March 15, 1990, was a period of 134 days which exceeded the required survey frequency by 46 percent.

The inspector informed the licensee representatives that the

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failure to perform a physical inventory and leak test on SNM sealed sources in accordance with established procedures was identified as an apparent violation of License Condition No. 9 (70-1113/90-07-06).

One apparent violation for failure to conduct SNM sealed source leak test and inventory as required by written procedures was identified.

10. Transportation of Radioactive Materials (86740)

I 10 CFR 71.5 requires that each licensee who transports licensed material outside the confines of its plant or other place of use, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 -

189.

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23 The inspector reviewed selected records from August 1989 through May 1990 associated with radioactive waste shipped to a licensed burial facility and radioactive material in the form of fuel elements, pellets, or powder shipped to various customers in the United States and in Japan.

The Radioactive Material Packaging and Shipping Records of each shipment were reviewed for adequacy and completeness as applicable.

The items covered by the shipping records included:

Radioactive materials packing lists Bills of lading Packaging requirements and classification Carrier certification Prict notification of shipment Vehicle inspection and survey for Exclusive Use Designated shipments Instructions to the driver for maintaining Exclusive Use controls Waste Manifest forms including such information as chemiceN form, physical form, ccntainer volume, radiation levels, and contamination levels Radiation Safety survey records Waste shipment checklists All official shipment records reviewed were complete and the supplied information appeared to be appropriate except for one area.

While reviewing the shipping paper information for 7 shipments of radioactive waste shipped during the period from August 1989 to May 1990, the inspector noted that the licensee had changed the format of the instructions given to drivers of exclusive use vehicles.

Prior to about January 1990, the licensee had included the required instructions to drivers for maintaining exclusive use-shipment controls on the Bill of Lading itself.

Subsequent to January 1990, the licensee had generated a special form to give the driver more complete instructions for exclusive use shipments.

The inspector reviewed the exclusive use vehicle instructions form and determined that it appeared to be very comprehensive and adequate for such use.

However, the inspector also noted that 3 of 7 shipping paper information packages, which were maintained by the

'i licensee as a record of radioactive waste shipments, did not have the exclusive use vehicle instructions included with the packages.

Through discussions with licensee representatives concerning this issue, the inspector was informed that submittal of the required instructions to the drivers of the shipments in question were not verifiable immediately.

The inspector noted that the checklist for making radioactive shipments did not include a step to ensure that exclusive use instructions are given to the driver.

The licensee indicated that the carrier involved would be contacted to determine whether or not the instructions were actually provided to the drivers of the shipments.

As of the end of the onsite inspection, the licensee had not verified that the documents were presented to the driver.

The licensee was informed that failure to include the exclusive use vehicle instructions normt.11y given to the carrier's drivers with the shipping paper information packages was an apparent violation of 10 CFR 71.5 requirements (70-1113/90-07-08).

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i One apparent violation of 10 CFR 71.5 requirements for failing to provide exclusive use vehicle instructions to drivers was identified.

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11. Nuclear Safety Engineering and Radiation Control Organization and Staffing (83822)

Chapter 2, Sections 2.2.1.3 and 2.2.1.4 of the License Application for License No. $NM-1097 define the functions and general organization for the i

Nuclear-(Radiation) Safety and RP sections, respectively.

Chapter 2 Section 2.5.2 of the License Application requires the Nuclear Safety Manager to hold a B.S. degree in science or eagineering, to have at least five years of experience in a responsible position in the nuclear field such as engineering, physics or chemistry, at least three years of which shall have been in an activity which would develop an understanding of criticality problems and five years experience in assignments involving radiation safety.

Chapter 2, Section 2.5.2.2 of the License Application requires Nuclear Safety engineers to be approved by the Nuclear Safety Manager and the i

Regulatory Compliance Manager.

The inspector reviewed the licensee's organizational changes implemented since the last NRC inspection of the RP program conducted in February 1990 and documented in IR 70-1113/90-03.

Changes in the Regulatory Compliance organization and Tffing included the formation of a Compliance Improvement Mana' position, the appointment of a new Nuclear Safety Manager, and hir..g of two Nuclear Safety engineers, a.

Organization The current organization structure, and section responsibility and lines of authority were reviewed and discussed with licensee representatives.

i A newly created position, Compliance Improvement Manager, was filled by the previous Nuclear Safety Manager. The inspector noted that no position responsibility and requirements were listed in the License Application.

Licensee representatives stated that the position was created to evaluate both internal and external audits; trend applicable results; and coordinate and evaluate proposed and/or completed corrective actions. Based on the previous experience within the Compliance organization, the Compliance Improvement Manager was qualified to perform the stated duties of the position.

The NSE and RP sections responsibilities for technical reviews and evaluations, for selected training, and for day-to-day radiation protection activities remained the same.

The respective section managers continued to report to the Manager, Regulatory Compliance.

No violations or deviations were identified.

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Staffing Changes to NSE and RP staff since the previous NRC radiation protection inspection (IR 70-1113/90-03) were reviewed and discussed with cognizant licensee representatives..

The RP technician staff levels were not changed since the previous NRC inspection.

However, changes were made in the NSE staff. Since the previous inspection a senior NSE staff member was assigned to the Manager of Nuclear Safety position.

Furthermore, within the Nuclear Safety organization an additional engineering position and senior i

engineering position were filled.

The inspector reviewed and verified the qualifications of the. newly appointed Nuclear Safety Manager, Nucicar Safety Engineer, and Senior Nuclear Safety Engineer against the position requirements as specified in the License Application.

Personal qualifications for the individuals reviewed met the conditions specified in the application.

No violations or deviations were identified.

12. FollowupItems(92701)

The following inspector followup items (IFIs) and NRC ins were reviewed i

and were discussed with cognizant licensee representatives.

a.

Inspector Followup Items (Closed) IFI 70-1113/89-05-01:

Review licensee actions-regarding the development of guidance detailing RSC functions.

This issue concerned the lack of written guidance regarding the r

RSC functions.

The inspector reviewed P/P 40-31, Operational Radiation Safety Committee, Rev. 3, dated March 23, 1990. The procedure details operations of the RSC committee including, methods of input to the committee, draft. concerns, development of new projects, and the function of radiation protection personnel.

Based on the review of completed actions the inspector informed licensee representatives that this issue was considered closed.

(0 pen) IFI 70-1113/89-05-02:

Review of licensee actions regarding lack of " root cause" analyses associated with quarterly audit reviews.

This issue concerned the lack of " root cause" analyses for potential noncompliances (PNCs) identified during the routine l

quarterly audits.

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o 26 In response to the issue, the audit form for documenting and reviewing identified PNCs was bpdated in December 1989 to include a section on recommendations for correcting identified issues.

The inspector noted that the use of individuals' reconrnendations possibly would not systematically and objectively review factors, for example historical trends, staffing, adequacy of training, and/or equipment concerns, potentially contributing to an identified PNC.

Licensee representatives stated that their actions vere believed to be adequate and that " root cause" analyses w:re not expected to be included in review of PNCs.

The inspector had no additional comments regarding this issue at this time.

(Closed) IFI 70-1113/89-05-03:

Review licensee actions regarding development of guidance for respiratory protective equipment.

This issue concerned the lack of written guidance concerning the required use of respiratory protective equipment based on contamination levels.

Licensee representatives informed the inspector that the required use of respiratory protective equipment was based on routine tasks at the facility.

During the current onsite inspection, the guidance for equipment use for associatea tasks-was reviewed and verified in the applicable procedure.

The inspector noted that some nonroutine tasks involved respiratory protective equipment.

Licensee representatives stated that for these tasks, the respiratory protective requirements were specified in the applicable RWP.

The inspector noted that during discussions with RP technicians, several individuals stated that selection of respiratory protective equirment was based on contamination levels rather than the specilic task.

Licensee representatives believed that the technician: were referring to RWP activities.

Licensee representatives stated that this issue would be reviewed.

The inspector noted that based on this review and licensee actions to evaluate the identified discrepancies, this item was considered closed.

(Closed) IFI 70-1113/89-05-04:

Review licensee actions regarding lack of pre-job reviews, status briefings, and post-job reviews in the RWP program.

l This issue concerned the licensee's evaluation of RWP program components discussed during the referenced inspection.

RWP program status and changes were reviewed with cognizant licensee representatives during the current inspection (Paragraph 4.d).

Overall improvements in pre-job reviews, u

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4 27 training, briefing and overview of contractor activities, and implementation of lessons learned for subsequent RWP implementa-tion were noted.

L Based on the review of licensee actions the inspector informed licensee representatives that this issue was consiaered closed.

L (Closed) IFI 70-1113/89-05-07:

Review licensee actions regarding control and accountability for respirators stored in separate process area locations.

This issue concerned the need for routine verification of used

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end unused respiratory equipment status maintained in the process work areas.

Cognizant licensee representatives stated that PROD No 80.84 NSR/R 4.1.16, Respirator Testing, Method Sheet, Rev. 4, dated

-December 21, 1989, was revised to require, at a minimum, respirators to be returned for maintenance every 120 days.

On a routine frequency, laundry personnel were requested to tour process areas and to check the status of both used and unused respirators.

In addition to used respirators, those unused respirators which exceeded the 120 day limit, are required to be collected and returned to the laundry for maintenance service, i'

Based on the review of licensee actions the inspector informed licensee representatives that this issue was considered closed.

(Closed) IFI 70-1113/90-03-07:

Review licensee actions regarding commitment to review applicable maintenance procedures for inadequacies regarding handling of potentially contaminated trash and to implement corrective actions within 60 days.

The licensee committed to review applicable maintenance procedures and RWP guidance to improve handling / disposal of potentially contaminated trash.

Licensee representatives stated that in addition to the Section Administrative Routines and RWPs associated with the Heating Ventilation Air Conditioning system approximately 57 additional Nuclear Safety Release / Requirements were reviewed and revised.

The inspector noted from review of the updates that the revised guidance was for areas within the process building but outside of normal airborne control areas and for areas outside of the process buildings.

Based on the review of licensee actions the inspector informed licensee representatives that this issue was considered closed, b.

Information Notices The inspector verified that the following ins were received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.

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28 IN 86-TX - Draft -Interpretation of Bioassay Measurements; Assessment of Intakes IN 89 Alternative Waste Managenent Procedures in Case of Denial of Access to Low-Level Waste Disposal Sites IN 89-24 -_ Nuclear Criticality Safety IN 89 Loss and Theft of Unsecured Licensed Material IN 90 Importance of Proper Response to Self-Identified Violations by Licensees IN 90 Extended Interim Storage of Low-Level Radioactive Waste by Fuel Cycle and Materials Licensees IN 90 Accidental Disposal of Radioactive Materials IN 90 Personnel Injuries Resulting from Improper Operation of Radwaste Incinerators IN 90 Clarification of the Recent Revisions to the Regulatory Requirenents for Packaging of Uranium Hexafluoride for Transportation IN 90 Update on Waste Form and High Integrity Container Topical Report Review Status, Identification of Problems with Cenent Solidification, and Reporting of Waste Mishaps IN 90 Transportation of Type A Quantities of Non-Fissile Radioactive Materials-

13. LicenseeActiononPreviousEnforcementAction(92702) a.-

(Closed) VIO 70-1113/89-05-09:

Failure to conduct adequate contamination surveys and/or follow contamination control requirements for (1) the Powder Warehouse area and. (2) process equipment (slugger) parts.

The inspect:r reviewed and verified implementation of corrective actions stated in General Electric's Nuclear Fuel and Component Manufacturing (GE's, NF&CM) response dated October 10, 1990.

Contamination surveys for selected process areas and implementation 1

of upgraded housekeeping activities were reviewed.

In general, results indicated effective licensee actions regarding contamination control.

Part 2 of the identified violation was withdrawn as a result L

procedural requirements clarified by the licensee's response.

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This item was-considered closed based'on licensee actions and the continued worker awareness regarding contamination control.

b.

(Closed) V10 70-1113/90-03-01:

Failure to follow procedures for maintaining FCR air flow evaluation documentation.

This issue concerned the licensee's failure to maintain all required air flow evaluation documentation for a specific Facility Change Request (FCR) package.

The inspector reviewed and verified implementation of corrective actions stated in General Electric's Nuclear Fuel and Component Manufacturing (GE's, NF&CM) response dated May 4,1990.

The inspector reviewed results of t1e air flow verification studies conducted for the referenced FCR.

The study was completed and the results were documented as required.

In addition, the inspector verified that current licensee FCR operations requiring the completion of air flow studies were being conducted and documented in accordance with procedures.

Based on the review of licensee actions the inspector informed licensee representatives that this issue was considered closed.

c.

(Closed) VIO 70-1113/90-03-04:

Failure to follow procedures for posting a radioactive queuing pad.

This issue concerned the failure to have signs posted the Queuing Pad Shop Support Area indicating " Caution - Radioactive Materials" and "Every Container in this Area May Contain Radioictive Materials."

The inspector reviewed and verified. implementation of corrective actions stated in GE's, NF&CM response dated May 4, 1990.

Based on the review of licensec actionr the inspector informed licensee representatives that this i~see was considered closed.

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(Withdrawn) VIO 70-1113/90-03-05:

Failure to follow procedures for maintaining a storage pad area locked.

1 This violation was withdrawn following receipt of the licensee's i

reply dated May 4,1990, to the subject Notice of Violation dated Match 27, 1990.

14.

ExitInterview(30703)

The inspection scope and results were summarized on June 22, 1990, with those individuals indicated in Paragraph 1.

The general program areas reviewed and the potential noncompliances identified during this inspection and listed below were reviewed in detail.

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Licensee representatives acknowledged the inspector's comments.

The licensee did identify proprietary material reviewed by the inspector i

l during-this inspection, however, the inspector noted that no propriet'iry information would be used in the report.

t An additional exit interview was conducted on August 3,1990, regarding identified concerns with the licensee's extremity monitoring program. The inspector noted that the identified concerns resulted in three potential overexposures to the skin of the hands for operators handling unclad uranium materials.

Licensee representatives requested that the potential overexposures be considered an unresolved item pending their review of the issue.

The inspector stated that their request would be discussed with regional management and they would be informed of the final status.

During a teleconference conducted on August 6,1990, the inspector informed licensee' representatives that the calculated doses to the skin of the hand would be considered potential overexposures.

Item Number Description and Reference 70-1113/90-07-01 Failure to have written procedures for conducting the extremity monitoring program for personnel routinely handling unclad uraniummaterial(Paragraph 2.a).

Violation of License Condition No. 9.

70-1113/90-07-02 Failure to monitor and record exposure to t

the extremities in accordance with instructions provided in Form NRC-5 (Paragraph 2.a)..

Violation of 1

10CFR20.401(a) requirements.

70-1113/90-07-03 Failure to supply and to require the use of 4

appropriate extremity exposure monitoring equipment by individuals potentially exceeding 25 percent of 10CFR20.101(a) limits (Paragraph 2.b). Violation of 10 CFR 20.202(a)(1) requirements.

70-1113/90-07-04 Failure to maintain occupational doses to the skin of the hands below 18.75 rem per quarter for individuals handling unciad uranium material (Paragraph 2.c).

Violation of 10 CFR 20.101(a) requirements.

70-1113/90-07-05 Failure to conduct adequate surveys /

evaluations of the hazards present to detect radioactive contamination on the skin of the foot by a URV worker exiting the RCA (Paragraph 4.c).

Violation of 10 CFR 20.201(b) requirements.

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31 70-1113/90-07-06 Failure to follow procedures' for the following radiation protection program areas / activities.

Multiple examples of a t'

violation of License Condition No. 9.

Personal radiation protection guidance for:

2) thermoluminescent dosimeter (TLD) )u

1) respirator storage (Paragraph 7 ;

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Paragraph 8.b);and(3)postingaradiation F.

areawithinastoragepad(Paragraph 8.c).

Process / recovery operations procedures for

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(1) storing combustible materials near empty UF6 cylinders (Paragraph 8.e); (2) bagging process equipment filters (Paragraph 8.f);

and (3) maintaining lids and locks for storage cans.

Inventorying and' leak testing of SNM sealed sources (Paragraph 9).

70-113/90-07-07 URI concerning adequacy of licensee's method-to ensure fuel containers transferred from the FM0 pack area to the adjacent uncontrolled area was adequate to meet rocedural and 10 CFR Part 20 requirements p(Paragraph 8.h).

70-1113/90-07-08 Failure to provide exclusive use vehicle instructions to drivers in accordance with 49CFR173.425(b)(9) requirements (Paragrarh10).

' Violation of 10 CFR 71.5 requirements.

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