ML20033H268
| ML20033H268 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/12/1990 |
| From: | Bassett C, Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20033H265 | List: |
| References | |
| 70-1113-90-03, NUDOCS 9004190059 | |
| Download: ML20033H268 (20) | |
Text
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4 examples of unresolved items (UR!s)y identified NRC concerns as noted by selected addressing and correcting previousl, cited and non-cited violations (NCVs).
In
- general, managenent of the RP program was considered adequate to protect worker.
health and safety.
Within the areas inspected, the following violations were identified.
Failure to follow procedures for maintaining air. flow study documentation-associated with selected Facility Change Requests (Paragraph 4). Violation of License Condition No. 9.
Failure to have adequate radiological controls specified on RWP for contractor niaintenance activities (Paragraph 6 b).
Violation-of License.
Condition No. 9.
Characterized as a Non-cited Violation (NCV) as ' discussed-in Paragraph 6.b.
Failure to follow procedures for. posting -a radioactive waste queuing pad.
(Paragraph 6.c). Violation of License Condition No.'9.
Failure to follow procedures for maintaining 6 storage pad area locked (Paragraph 12.b). Violation of License Condition No. 9.
Failure to have adequate procedural guidance for the disposal of potential radioactive contaminated waste (Paragraph 12.b).
Violation of License Condition No. 9.
Not cited as discussed in Paragraph 12.b.
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i REPORT DETAILS 1.-
Persons Contacted Licensee. Employees
- W. Baker, Quality Control Engineering - Quality Assurance (QCE-QA) Systems
- D. Barbour,_ Shift Supervisor, Radiation Protection (RP)
'*B. Beane, Manager, Fuel Manufacturing Operation (FMO), Maintenance
- B. Bentley, Manager Fuel Manufacturing
- G. _ Bowman, Manager, Nuclear Safety Engineering (NSE)
- D. Brown, Manager, Uranium Recovery Unit / Waste Treatment
- A. Cameron, Fuel Support
- R. Foleck, Senior Specialist Licensing Engineering
- D.Hassler, Supervisor,HeatingVentilationAirConditioning(HVAC)
- R. Keenan, Senior-Engineer, NSE
- W. Lewis, Manager Nuclear Fuels and Component Manufacturing (NF&CM)
- R. McIver, Manager, Plant Engineering and Maintenance
- S. Murray, Senior Engineer, NSE-
- R. Pace, Manager, Powder Production Unit (PPU)-
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- H. Strickler, Senior Program Manager, Environmental Protection and Industrial Safety'
- R. Torres, Program Manager, RP C. Vaughan, Manager, Regulatory Compliance i
- H. Walker, Manager, Shipping and Traffic
- T.- Winslow, Manager, Licensing and Nuclear Material Management
- R. Yopp, Team Advisor, Shipping and Traffic Other licensee employees contacted included engineers,. technicians, operators, and office personnel.-
- Attended exit interview 2.
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 define l
the functions and general organization for the Nuclear (Radiation) Safety l
and Radiation Protection sections, respectively.
L a.
Organization l
The current organization structure, and section responsibility and lines of authority were reviewed with licensee representatives.
No changes since a previous radiation protection inspection conducted L
May 22-26, and June 12-15,1989, and documented in NRC Inspection -
L Report (IR) 70-1113/89-05. were identified for the program areas _
reviewed.
The Nuclear Safety Engineering (NSE) and Radiation-l Protection ' sections responsibilities for technical reviews and evaluations, for. selected training, and for day-to-day radiation l
2 protection activities remained the same.
The respective section managers continued to report to the Manager, Regulatory Compliance.
No violations or deviations were identified.
b.
Staffing Changes to NSE and RP staff since the. previous radiation protection inspection (IR 70-1113/89-05) were reviewed and-discussed with cognizant licensee representatives.
The RP technician staff levels were.not changed since the previous inspection.
However, licensee representatives stated - that during January 1990, a senior NSE engineer resigned from the staff.
This individual was knowledgeable of the computer codes utilized in bioassay program models and associated technical aspects of'the RP program. Two senior NSE_ staff members were delegated additional responsibi_lity for duties previously assigned to the vacated NSE position.
The inspector ~
noted that an extended vacancy for this senior NSE position would be considered a potential program weakness in that. two: individuals now '
were providing the majority of technical reviews and evaluations of
' health physics (HP) issues previously assigned to three senior level NSE staff positions. Licensee representatives stated.that staffing the vacated NSE position was considered'a priority issue and that a search for qualified candidates was initiated and applicants were contacted.
At the time of the inspection, interviews were completed and a job offer was extended to the leading candidate.
A reply concerning the applicant's decision was expected during February 1990 The inspector i
requested to licensee management to notify the _NRC Region !!- office '
regarding any extended delays in-filling the vacated position.
Licensee management agreed with the request.
No violations or deviations were identified.
3.
Training (83822) 10 CFR 19.12 requires the licensee to instruct all individuals working or frequenting any portions of the restricted = areas in the health protection aspects associated with exposure to radioactive material or radiation.~in precautions or procedures ' to minimize exposure, and' in-the' purpose and function of protection devit.es employed, applicable provisions of Commission 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.
Training and/or retraining provided to RP technicians and' general workers were reviewed and discussed with licensee representatives.
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a.
Radiation Protection Staff Tne inspector discussed RP technician and supervisor training with selected technicians and supervisors.
Licensee representatives stated that no formal. RP training, either onsite or at an offsite facility, was conducted.
Training. consisted of review and discussion of procedural and/or program changes conducted on an individuni basis.
Furthermore, no staff participated in onsite review -of RP program ^
activities at other commercial, government. or government contrcctor fuel facilities.
The inspector noted that although-training of.the RP staff was not required by license conditions.- the lack of. a formal RP training program was considered a program weakness.
Licensee representatives stated that constraints regarding disclosure of proprietary information prevented the review of, or the participation by staff, in other consnercial fuel facility RP programs.
No further discussions regarding the RP staff training programs were conducted.
No violations or deviations were' identified.
b.
Operations Personnel The inspector reviewed the routine training program for operator and maintenance ~ personnel potentially exposed to radioactive materials.
In particular, schedules for -general employee training / retraining, respirator and supplied air hood use were reviewed and discussed with cognizont licensee personnel.
The frequency of-training detailed in the licensee REMTRAC computer program required training for both supplied air hood and respirator use to be conducted once ' per 36 months.
General employee retraining was. required on an annual basis.
The inspector reviewed selected training records for personnel who had used both respirators and/or supplied air hoods during operations in the facility.
Review of training records of selected personnel from' the Vaporization, Slab Blender and New Decon facility areas, indicated that all individuals were trained in accordance with. the detailed schedule.
No review of the quality for the actual' training provided was conducted.
No violations or deviations were. identified.
4.
FacilityChangeRequests(83822)
License Condition Number (No.) 9 of Special Nuclear Material License No.1097 '(SNM-1097) requires that licensed material be used in accordance with statements, representations, and condltions of Part I of the License.
Application dated October 23, 1987-.
Part 1. 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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Nutlear Safety) Instruction (NSI) No. E-3.0 Nuclear Safety Review Request.
Revision (Rev.
14, dated December 14, 1989, requires for Facility Change i
Requests (FCRs) needing a radiological safety review that the NSE engineer compile and generate an index of all necessary documentation, including air flow verification data and drawings, i
NSI No. E-1.0, Nuclear Safety Review Recorcs, Rev. 13. dated December 19, l'
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.
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v NSI No. E-7.0, Radiological Safety Review for Process and Equipment Chenge 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 incluced in the request file folder.
The. inspector reviewed and. discussed with cognizant licensee l
representatives, selected evaluations / reviews and applicable FCRs submitted 1
for proposed changes to facilities, equipment or processes associated with r
recent and ongoing construction activities.
In particular, FCR 89.147, Remove Unused Dump Hood, dated July 19, 1989, and FCR 89.263; Demolition and Removal of Uranium Purification System (UPS) Digest / Cooling System' dated i
December 4, 1989, were reviewed and discussed.
For FCR 89.147, the inspector noted that although a NSE review was not' required, the licensee did conduct and document air flow analyses.
However, on February 8,'1990, while reviewing FCR 89.263 files which detailed construction activities for the UPS. system - the inspector noted that an NSE; review was conducted but records documenting the air : flow evaluations were not maintained.
A cognizant NSE engineer informed the inspector that evaluations of air flow t
for the innediate areas surrounding,.and within a containment structure L
erected for the UPS area were conducted and subsequent adjustments to the l
applicable fixed air samplers (FASs) were' made as necessary, but that no l
_ documentation was maintained.
The inspector informed licensee j
representatives that_ the failure to follow procedures _for. maintaining FCR i
air flow evaluation documentation was identified as an apparent violation (VIO)ofLicenseConditionNo.9(VIO: 70-1113/90-03-01).
One violation was identified.
q 5.
Respiratory Protection Program (83822) 10 CFR 20.103(c)(2) permits the licensee to maintain' and to implement :a i
respiratory protective program that includes, at a minimum: air sampling to i
identify the hazard; surveys and bioassays to evaluate ~ the actual exposures;.
1 written procedures to select, fit and. maintain respirators;' written f
. procedures regarding supervision and training of personne1' and issuance of.
I records; and determination by a physician prior to use of respirators, that the individual user is physically able to use - respiratory protective j
equipment.
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10 CFR 20 Appendix A, Footnote (d), requires adequate respirable air of the
-j quality and quantity in accordance with NIOSH/MSHA certification described i
in 30 CFR Part 11 to be provided for atmosphere-supplying respirators.
t a.
Training and Qualifications ~
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The inspector. reviewed and ' discussed fit testing and medical qualification program for selected personnel using. particulate and/or.
air supplied hoods at the facility... Review ofi training records indicated that selected personnel in the Veporization, Slab Blender. -
and New Decon facility areas were fit tested and nedically qualified in accordance with' procedural requirements.
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No violations or deviations were identified.
I b.
Breathing Air Quality I
q 30 CFR 11.121 requires that compressed, gaseous breathing air meets the; applicable minimum grade. requirements for TypeL1 gaseous air set forth' in the Compressed Gas Association Coninodity Specification for-Air, G-7.1 (Grade D or higher quality).
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Plant Engineering and Maintenance Section Administrative Routine,.
No. 310-25, Decon and Incinerator Facilities Calibration and-PM of the Breathing Air System, Rev. O, dated July 24, 1989,. detailed the calibration - and preventative maintenance - of the facility. fresh air breathing systems.
The procedure required weekly checks of the system I
carbon monoxide (CO) monitor humidifiers, filters, catalyst cylinders, and general material storage in the area which could contribute to
= intake air contamination.
Calibration of the system is required on a l
monthly basis.
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The inspector reviewed and discussed verification of air quality for i
air-supplied respiratory protective equipment used' at the facility, From review of December 1,;1989 through February 5.-1990; air supply 1
system surveillance and calibration records, the inspector verified that licensee activities were conducted.in accordance with the approved j
procedure.
In addition, the recent reduction of Grade D air CO limits, l.
from 20 to 10 parts per million (ppm), as specified:in the Compressed Gas Association, Inc. Standard, ANSI /CGA G7.1-1989.-. was discussed.
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during the inspection. Cognizant licensee representatives, stated that the 10 ppm C0 limiting value was to' be incorporated into the.
appropriate procedural guidance.
No violations or deviations were identified.
c.
Respirator Usage NSR/R Changeroom PROD No. 85.00, Rev. 6, dated December 13, 1989,.
requires in General Rule No. 6 d at "used" respirators be placed in designated. containers or taken ba d to the laundry. General Rule No. 7 b
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details that begged respirators be taken to work locations and placed on equipment or tool boxes for anticipated or short term use provided they are not abandoned.
During tours of the facility on February 6-8, 1990, the inspector observed bagged respirators in various authorized storage locations throughout the facility.
However, bagged respirators were also noted in two locations that were not-authorized by the NSR/R.
For example, a half-mask respirator was found in the drawer of a work desk in the B&W hhmmermill. area.
At the time, the area was not attended by personnel.
In addition, a full-face respirator was noted in the desk in the -
radiation protection work station (satellite office) in the Uranium -
Process Management Project (UPMP) area.
During these tours, the inspector also noted unbagged respirators that apparently had been taken to operation / production-areas and not returned to the laundry between work shif ts.
On February 6,_1990, one respirator was observed in the New Decon facility near the entrance to the decontamination and sorting room.
The-respirator, identifiable with a unique black mark on the left side of the face mask, was hanging on a storage rack designated for temporary use.
0n February 8, 1990, the marked respirator was observed hanging in the same location.on the storage rack.
Also.
on' February'8, 1990, a welder's respirator was.
observed on the welding machine inside the maintenance shop in the VPMP area. The next morning, the same respirator remained on the top'of the welding machine.
These issues were noted as examples of-an apparent violation for failure to follow procedures and were similar to. issues identified during a previous inspection conducted May.22-26, and June 12-15, 1989, and documented in IR 70-1113/89-05.
The inspector noted:that license representatives addressed the previous violation examples and ' proposed corrective actions in a reply to the NRC dated October 10,1989. - At that time, corrective actions..were to be completed by December 1990.
Furthermore, in a letter dated January 3,1990, the NRC Region 11 office requested a supplemental response regarding licensee corrective actions for these and other procedural issues - documented in IR-70-1113/89-05.- The inspector informed licensee management that pending the adequacy of their supplemental' response regarding corrective actions for previously identified similar violations this issue would be considered an URI* and tracked by the NRC-(URI: 70-1113/90-03-02).
One unresolved item was identified.
- An unres01Ted7 fem is ali' Hem about which more information is required to ascertain whether it is an acceptable item, a deviation, or violation, i
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7 6.
RadiationControls-(83822) a.
Surveys 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 regulations _ in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be-present.
Chapter 3, Section 3.2.4.6 of the License Application ' details removable surface contamination action levels requiring decontamination for controlled and uncontrolled areas.
During the onsite eudit, the inspector requested special contamination surveys performed for laboratory (equip) ment stored outside of facility.
radiologically. controlled areas RCAs and also' for pipe surfaces-within the New Decon hallway _ area.
For the laboratory equipment, removable surface contamination values were less than 200 disintegrations per minute alpha per 100 square centimeters-(dpm/100cm2).
For the New Decon hallway pipes, surface contamination 165 to 518 dpm/100 cm, and were below the values ranged from e
5,000 dpm/100 cm* limit requiring decontamination.
No violations or deviations were identified.
b.
RadiationWorkPermit(RWP) Implementation Chapter 3, Section 3.3.1 of the License Application _ requires Radiation Work Pennits (RWPs) to be issued for nonroutine operations which are not covered by operating procedures.
The RWP specifies the necessary radiation safety controls, as appropriate, including personnel monitoring devices, protective clothing, respiratory protective equipment, special air sampling, and additional precautionary measures to be taken.
During the inspection, the following RWPs associated with decontamination and construction activities for the UPS area and for activities associated with HEPA filter changeout were reviewed.
RWP Inspect 541 and 546 Exhaust Units and Change Filters, dated January 3, 1990.
RWP Construct Plastic Enclosure Around Entire UPS Demolition Area, dated January 18, 1990.
RWP UPS Digest, Precipitation and Cooling System Demolition, dated January 22, 1990.
Radiological controls specified for.use in the UPS by the applicable RWPs were reviewed-and discussed in detail with licensee-
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l representatives.
The inspector noted that controls implemented for contractors included daily briefings with responsible -RP personnel prior to initiating work, use of full-face respiratory protective equipment when specified, and the submittal of urine samples at the l
beginning and end of each work shift.
From discussion with licensee representatives, the inspector was informed of a contamination incident which occurred on February 5, 1990.
The incident involved the unexpectLi exposure to - airborne-uranium material and potential internal exposure for several contract workers.
The airborne contamination resulted when two maintenance personnel, wearing appropriate respiratory equipment,. entered and initiated cleaning of an upper area within the UPS containment structure.
Concurrently, four contractors, without respiratory protective equipment, were conducting activities in a location beneath the maintenance workers in the UPS area. The contractors were unaware of the initiation of the. maintenance activities which resulted in unexpected airborne concentrations -of soluble uranium material.
The exposure resulted in positive urinalysis results for the four workers as reviewed in Paragraph 8.b of this report.
Licensee representatives stated that identified deficiencies included the RWP. allowing separate radiological controls for conducting contractor and maintenance group activities concurrently within the UPS containment structure area.
Corrective actions included upgraded radiological controls for all-personnel when maintenance activities are conducted in the UPS area, and -the ' retraining of all personnel regarding RWP policy.-
Licensee evaluations of personnel internal exposures appeared. adequate and results were within established procedural and regulatory limits.
The inspector informed licensee representatives that based on their identification of the incident,. remedial actions conducted and thoroughness of exposure evaluations, the issue would be considered for characterization as a licensee-identified violation and would not be cited in the report (NCV: 70-1113/90-03-03).
One non-cited violation was identified.
c.
Labeling and Posting 10 CFR 20.203(e) requires each area in which licensed material is used or stored and which contains any radioactive material in an amount exceeding ten (10) times the quantity of such material specified in Appendix C of this part to be posted with a sign or signs bearing the radiation caution symbol and the words: " Caution,. Radioactive Material (s)."
10 CFR 20.203(f) requires each container of licensed material to bear a durable, clearly visible label identifying the radioactive contents and to provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures.
The label information includes, as appropriate, radiation levels, kinds of material,. estimate of activity, date for which activity is estimated, mass enrichment, etc.
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Chapter 1. Section 1.8.9 of the License Application requires for those areas within the Controlled Access 'Arca in which radioactive materials
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are processed, used, or stored, where-it is deemed impractical to label individual containers pursuant to 10 CFR 20.203(f), a sign stating "Every container in this area may contain radioactive material"'to be posted.
License Condition No. 9 SNM LiNnse No.1097 requires that licensed-
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material. be used in accordance with statements, representations, and conditions of Part 1.of the License Application dated October 23, 1987.
Part 1. Section 2.7.1 ofthe licensee's Application for License No.
SNM-1097 requires that radiation protection function activities be -
conducted in accordance with written procedures.
L Nuclear Safety Release / Requirements (NSR/R) Control No. 4.8.16, Rev. 8 dated November 7,1989, requires that the Queuing Pad in the Shop 1
Support area '(near the Incinerator Building) be clearly identified and posted " Caution - Radioactive Materials" and "Every Container In This t
. Area May Contain Radioactive Materials."=
During tours of the outside storage areas on February 7, 1990, postings provided at various storage and queuing pads were reviewed.
The inspectur noted that some posted signs were weathered and discolored i
making them difficult to read.
Some signs only were attached with one i
strand of_ wire or plastic tie to the fence or barrier surrounding the.
respective _ areas. _ Furthermore, while reviewing _- the posting of the Queuing Pad located south of the Incinerator Building.in the Shop Support area of responsibility, the inspector noted that the area was-not posted as a radioactive materials area.
In addition, there was no posting indicating that every container in the area could contain radioactive materials.
The inspector informed the licensee that failure to properly post the Queuing Pad as required by the NSR/R was an example of an apparent violation of License Condition No. 9 (VIO:
70-1113/90-03-04).
One violation was identified.
7.
External Exposure (83822) 10 CFR 20.101 requires that no licensee shall 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.
- i active blood forming organs, lens of the eyes, or gonads; :.nd 18.75 rems to the hands and forearms, feet and ankles.
NSI 0-7.0, Radiation TLD Badge Issuance and Control, Rev.11, dated October -
.20, 1990, and NSI 0-2.0, Investigation of Lost / Damaged TLD Badge and Estimate of Exposure, Rev. 9, dated January 1,1989, details use of e
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10 thermoluminescent dosimetry (TLD) for monitoring external exposure at the facility.
The inspector reviewed and discussed with licensee representatives, the January 1 through February 1,1990 external exposure results for selected personnel.
The inspector noted that no personnel exceeded regulatory limits.
For individuals monitored on a monthly basis, the maximum whole body exposures reported were approximately 280 millirem (mrem) and 30 mrem
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for gama and neutron measurements, respectively, In addition, review of quarterly monitoring _ data indicated maximum whole body exposure results of approximately 140 mren.
No violations or deviations were identified.
8.
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 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 20.203(a)(3) requires for purposes of. determining compliance with the recuirements of this section, the licensee to use measurements 1of racioactivity 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.
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 actions as are necessary to assure against recurrence.
The licensee shall maintain records of such.
occurrences, evaluations, and actions taken in a clear and readily identifiable form suitable for summary review and evaluation.
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The RP air sampling and bioassay programs for evaluating and-assessing personnel exposure to airborne radioactive material were reviewed, a.
Air Sampling The licensee's air sampling program for routine and nonroutine. work activities were discussed and reviewed.
Representativeness of FASs to monitor routine airborne - uranium concentrations for worker breathing zones is -verified using air-flow studies.
During tours of the' process facilities, the inspector.
verified operability of selected FASs.. Licensee representatives stated
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11 that in response to issues identified in a previous HP inspection _and documented in IR 70-1113/89-Ob. representativeness studies based on air f
flow evaluations were conducted and documented for FASs, as l
required.
However, the-inspector did not review the resultr, of these representativeness detenninations.
The adequacy of such 1
evaluations.was cited as a violation in Inspection Report No. 89-05.
1 A supplemental response to that violatice had not been reviewed at the time of this inspection.
T In addition, the repreventative sampling of worker breathing air for.
contracters involved in UPS construction activities were reviewed.
During tours of the facility, the inspector noted that the containment-i structure surrounding-the UPS construction area appeared to -impact several FASs. Licensee representatives stated that prior to initiation of work, the representativeness of air flow patterns for the FASs-within, and adjacent to the area were reviewed using smoke bomb / tube-methods.
Although documentation verifying the study was incomplete (Paragraph 4), licenste representatives stated that all necessary f
adjustments to selected FASs were completed.
In addition to six-FASs located within the UPS containment structure, numerous particulate air samples using periodic high-and. continuous -low-volume samplers were collected by the RP technician providing coverage for contractors working in specific UPS areas.
The inspector reviewed air sampling results, values ran centimeter-(uC1/cc)ging from 2.5 E-11 to 3.0-E-11 microcuries per-cubic-for samples collected during the February 5,1990, contractor exposure incident.
Based on discussion with licensee representatives, air sampling for contractor work within the. area appeared adequate.
No' violations or deviations were identified.
b.
Bioassay Program During the inspection the licensee's urinalysis program and lung. burden analysis programs were reviewed.
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NSI No. 0-2.0, Bioassay-Urinalysis Program, Rev.17, dated October 25, 1989, details the urinalysis program requirements for individuals assigned to work in areas where soluble uranium compounds are processed.- For personnel working in a job functional area (JFA) where
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the potential exposure is to uranyl nitrate, urinalysis results equal:
to or exceeding 15 micrograms per liter (mg/1) or any other urinalysis results exceeding 35 ug/1, require RP personnel to evaluate the time of l
uptake and to calculate the uptake in milligrams of total uranium (mg U) using the REMTRAC "U CALC" program or the equations listed in-Appe_ndix C.
The inspector reviewed selected urinalysis results for samples collected from July 1,1989 through February 5,1990. All initial and requested resample results were reviewed and calculations performed by
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RP technicians. as required.
No_ values exceeding the licensee action-level of 2.5 mg U uptake were reported.
L in addition
. selected evaluations and Maximum Permissible l
Concentration-hour (MPCa-hr) assignments for contractor' personnel exposed to airborne uranium materials in the.UPS containment structure i
l during the February 5, L1990 incident were reviewed.
For the workers without respiratory protective equipment, urinalysis results ranged from approximately 12 to 105 ug/1.
For the two maintenance workers who.
were full-face respirators, urinalysis results -were below detection limits.
Based on licensee calculations, a maximum uptake of l
.47 milligrams (mg) of ' total-uranium was calculated.
Based.on.
r 10 CFR 20, Appendix B, Table.1,' Column -1 airborne maximum permissible concentration (MpCa) -value for soluble uranium, an. exposure of.
approximately 1.2 MPC-hours was calculated for the maximally exposed individual.
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The inspector reviewed the July 1,4 989 through November 31, 1989,. lung i
burden analyses conducted by: onsite pendor personnel.- During the time.
I period reviewed lung burden analyses wereiconducted for approximately.
l 380 individuals.
Of the analyses aconducted, approximately. six -
individual lung burden 'results exceided 150 ug uranium-235 (U-235) which required reanalysis on a' month 17 schedule.
From discussion with the onsite vendor and review of the lung-burden records.:the inspector verified that routine mand special analyses -restrictions, and:
subsequent followup analyses were conducted as required..
The inspector noted that a1'1 evalua ions and followup: activities appeared to be conducted-.in accord
' ;with procedures and that.
4 implementation of the lung burden a sis program appeared adequate.
A No violations or deviations were identified, e
9.
. Audits and Inspections (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, a.
Radiation Safety Internal Audits t
Section 2.8.1 of the License Application, provides guidan.ce - 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 reviewed the third and fourth quarter internal compliance audits. conducted from September 12-22, 1989, and December 4-15, 1989, respectively.
The audits were conducted.and the findings tracked in accordance with the applicable license conditions and procedures..
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- In general, an overall reduction in the number ofi procedural noncompliances was identified with the majority of identified issues associated with improper storage.of respiratory protective equipment.-
The_ inspector informed licensee representatives that similar issues were identified as a~.; violation during a ' previous inspection (70-1113/89-05) and as an.URI~(70-1113/90-03-02) during-the current HP inspection, respectively, The inspectorinoted that the' failure to-prevent recurrence. of procedural. violations regarding - improper respirator use/ storage indicated that the short-term corrective actions.
documented in the licensee's response dated OctoberJ10,1989, to the previous NOV were not effective'.. Licensee representatives stated that,.
currently, additional review of proposed corrective ' actions. to~ minimize procedural-noncompliances wereL undergoing. review.
. The ' inspector informed licensee representatives that the failure to follow procedures for respirator use/ storage was an additional example-of the URI
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reviewed in Paragraph 5.c of this= report.
Oneunresolved.iYemwasidentified.
i b.
Outside Audits Section 2.8'.3' of t' e. License Application, provides guidance for h.
conducting biennial audits by an organization outside of the i
GE-Wilmington organization.
The inspector rey,iewed the 1989 Biennial Independent-Nuclear Safety Audit of. the Nti61 ear Fuel and Component Manufacturing facility, conducted Octobes#2-6, 1989.
The audit appeared to be.a comprehensive review of training, procedures. records'and compliance with regulatory a
requirements for RP program areasJ including radiological controls, d
radioactive wa);te, and transportation issues..
Deficiencies Tere 1
identified if the areas -of procedural. effectiveness record maintenance, and transportation of radioactive materials.
The inspector verified that corrective actions. were completed or. in progress for identified areas of concern.
j i
No violations or deviations were. identified.
c.
Radiation Protection Technician.'nspections From review of 'RP Technician audit reports conducted from January l' through February 8, 1990s the inspector noted that the inspections were conducted in accordance with the applicable schedule. The inspections-included review and evaluation of RWP and routine activities, posting-I and labeling, and general facility conditions such 'as cleanliness.
For identified items, corrective actions were implemented in a timely manner.
No violations or deviations were identified.
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'10.
Radioactive Solid Waste and Radioactive Waste Management (84850, 88035) a.'-
Waste Manifests 10 CFR 20.311(b)-and (d) require that a manifest system be used for shipments of waste to a licensed burial facility or licensed waste processor.
The inspector reviewed selected. shipping manifests for waste shipped to a licensed burial site for disposal.
All manifests were ' completed with the required information and ' forwarded to the proper authorities as appropriate.
No violations or deviations were identified, b.
Waste Classification, Characterization, and Labelling 10 CFR 20.311(d)(1) requires that the licensee ~ prepare all waste so that the waste is classified according to 10'CFR 61.55 and meets the waste characteristics requirements in 10 CFR 61.56. The waste must be classified and identified as-Class A, B, or C.
Classification of waste materials to meet 10'CFR 61.55 requirements was discussed with licensee representatives.
' All ' waste streams were classified utilizing material accountability for identification and quantification of radionuclides in each container. The containers were scanned using the licensee's " elephant gun" or Nal'. detector.' _The detector measured gamma radiation produced by a uranium daughter-product radionuclide.-
The containers are rotated in front of the detector and assayed to determine the. quantity of. Uranium-?35 (U-235) and U-238 within the waste.
The licensee'. indicated that D 1y Class A unstable waste had been shipped for burial.
Stability of the waste is-achieved with the shipping or disposal container.
No violations or deviations were identified.
- 11. TransportationActivities(86740) i a.
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.
The -inspector reviewed selected January 1,1989 through' December 31, 1989 records associated with radioactive waste shipped to a. licensed burial facility or radioactive material in the form of fuel elements or
-pellets shipped to various customers in the United States and in Japan.
The Radioactive Material Packaging and Shipping Records associated with each shipment were reviewed for adequacy and completeness as applicable. The items covered by the shipping records-included:
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. Radioactive materials packing lists Bills of: Lading Packaging requirements and classification
't
-Carrier certification Prior notification of shipment-Vehicle inspection and survey.for Exclusive Use Instructions to driver for Exclusive =Use Waste Manifest Forms - listing of ChemicalL Form, Physical-Form..
-i Container, Volume, Radiation Levels, and_ Surface Contamination Levels J
Rad Protection Survey Sheets
. aste Shipment. Checklists i
W All official shipment records reviewed were complete and the supplied
[
information appeared appropriate.
The inspector noted that some; a
calculational errors had been made on the internal forms used by the licensee.
These errors,'however, had not been~ transferred to~ the shipping documents.
. The inspector : reviewed these errors with' the-licensee and the_ possible use 'of a computerized system to aid' in processing shipping paperwork was discussed.
The-licensee; indicated
~
that the current procedures and' traffic = instructions governing shipment' ofradioactivematerialwerebeingrevisedandthatsuchrev)sions'were 1
expected to reduce the errors noted.-
1 No violations or deviaticr.: w re M nt;fieJ.
b.
Authorized Packages i
10 CFR 71, Subpart C authorfs.s the licensee to'use specific packages for ' transporting licensed material and specifies > the conditions' for using the packages.
The inspector reviewed: and ' discussed the use of authorized packages' with licensee representatives.
At.the time-of the inspection, the licensee maintained approximately ten current Certificates of Compliance- (C0Cs) for use in transportation program.activ_ities.
The 1
inspector verified that selected C0Cs and associated documentation were on file for-packages utilized by the licensee.
~
No violations or deviations were: identified.
- 12. ToursofFacilities(83822,84850,88035)'
a.
Work Practices During the inspection, radiological controls and work practices were observed during _ tours of the Fuel Manufacturing Operation (FMO) area
~.
and the FM0 Extension (FM0X) area. The inspector noted that there had been a great improvement in the physical cleanliness of the facility and in general housekeeping.
The' inspector'also noted that worker compliance with the NSR/Rs governing the use of protective clothing had
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improved.
Although only a small sampling of individuals were observed L
exiting the controlled area, there also appeared to be an improvement l
in compliance with the requirements for personnel monitoring.
L No violations or deviations were identified, b.
Facility Support' Area Radiation Controls License Condition No. 9 of SNM License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the License Application dated October 23, 1987.
i Part l',
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.
Process Requirements and Operator Document (PROD) No. 80.12, Rev. : 9 dated November 18, 1988; requires in. Step 15 of the FM0 Method Sheet that the-can storage pad be kept locked whenever unattended..
The areas surrounding.the FM0 and the.FM0X were inspected including the can storage, the-uranium hexafluoride (UF-6) cylinder storage, the-e waste box and drum storage,. the drum. refurbishing, and -the source L
storage areas.
During the inspection on ~ February 7; 1990,;from approximately 5:00 p.m. until 6:15 p.m., Can: Storage Padc2 was noted to.
be unlocked with the gate open'and no personnel working in or near the area.
The inspector contacted and discussed the identified issue with L
the Rad Protection Shift Supervisor.
The-supervisor then called the Shift Production Coordinator to inquire about the current use of the j'
storage pad.
From that discussion =it appeared that-the storage pad had' E
not been used since the: day shift (approximately 3:00 p.m.) but that a 1-can transfer from the pad was planned for the' shift in progress..The i
failure to follow-procedures for maintaining can storage pads' locked -
was identified as an example of a violation of License Condition No. 9 L
(V10:
70-1113/90-03-05).-
L Manufacturing Systems and Support Services Section, Maintenance -
Procedure No. 310-21. HEPA Filter Change and Certification,: Rev'.1, a
dated January 26, 1990, details actions,-including radiation controls, required for HEPA filter changes'for recirculation and exhaust systems
. serving selected facility buildings or areas.
Section 5.3.31 requires subsequent to completion of work on a system, protective paper used for contamination control to be rolled up and disposed properly.
During tours of the facility on February 8 1990, the inspector -
i observed two unlabeled plastic bags outside of, end placed against the doors leading into the New Decon facility. Subsequently, the inspector-observed that the bags were taken into the New Decon area.
From-discussion with New Decon facility workers present, the inspector determined that the bags contained potentially radioactive contaminated material, waste paper, generated during work on an HVAC filter system.
h
O 17.
From review and discussion of the applicable. procedure with the inspector, cognizant licensee representatives -agreed that the instructions'and/or the availability of. established areas for temporary storage of radioactive contaminated waste were inadequate. During the inspection, a procedure change was initiated which required that trash generated ; be placed inside the.New Decon room or. UPMP ' Waste Box:
Disposal area.
Further, if either of these areas ~is not available. the trash is.to be placed in-the.FM0-Old Decon area or the Gadolinium Box-Transfer area.
.The inspector informed -licensee representatives that the failure to have adequate procedures for the disposal.of potentially radioactive' contaminated waste was'a violation of License Condition No.
9; but the issue was not being cited because the criteria-specified-in Section V. A of the NRC. Enforcement Policy were satisfied (NCV:-
70-1113/90-03-06).-
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The inspector informed licensee representatives-that all maintenance j
and/or operations' procedures needed to be reviewed for similar concerns regarding storage / disposal of-potentially contaminated waste.- Du ring -
the Exit Interview conducted February 9,1990, licensee' management committed to review applicable ' procedures within'60 days to evaluate.
the identified concern and to conduct appropriate corrective actions',
as necessary..The inspector informed licensee-representatives that actions regarding their commitment' would be tracked by the NRC.as an InspectorFollowupItem(IFI:
70-1113/90-03-07).
One violation and one non-cited violation were identified.-
13.
ExitInterview(30703) l The inspection scope and results were summarized on-February 9,1990,Lwith l
those individuals indicated in Paragraph '1.
The inspector detailed the
.I general program areas reviewed and noted that several-issues previously identified and documented in IR 70-1113/89-05 were not reviewed pending j
receipt of a supplemental. response from the licensee.
Procedural noncompliances identified during this inspection were reviewed in detail.
The inspector noted that the failure to have adequate radiological' controls L
on a current RWP for maintenance activities and the failure to have adequate procedural guidance regarding. handling of potentially. contaminated waste l.
would be considered for categorization as-NCVs' in accordance with the l
Enforcement Policy outlined in.10'CFR 2.Section V.A.
In addition, as part l
of corrective actions to procedural inadequacies for handling potentially a
contaminated waste, licensee management committed to implement a review of
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applicable procedures within 60 days and take appropriate corrective actions. Furthermore, examples of procedural violations for respirator storage were characterized as similar to issues identified-during previous -
]
inspections.. However, the inspector stated that currently the licensee's 3
corrective actions regarding the previous violation were not scheduled to be
!=
completed until late 1990 and that the current issue would be considered an a
URI pending NRC evaluation of corrective actions in the licensee's 1
i.
supplemental response regarding IR 70-1113/89-05.
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18 h
Licensee representatives acknowledged the inspector's. comments.
The licensee did identify proprietary material reviewed by-the inspector during this inspection.
The inspector noted that no proprietary information would be used in the report.
On March 26, 1990, the licensee was_ informed by. telephone that the three instances of failure to follow procedures would be identified-as: three
-separate. violations.
Item Number Description and Reference 70-1113/90-03-01 VIO: Failure:to' follow procedures for-maintaining air flow study (Paragraph 4).- Violation documentation conducted-in association:with a FCR of License Condition No. 9.
70-1113/90-03-02 URI: _Reviewilicensee supplemental response for adequacy of proposed _ corrective actions to prevent recurrence of improper-respiratory protective equipment storage (Paragraph 5.c).
70-1113/90-03-03 NCV:
Failure'to have adequate-radiological controls specified on RWP for. contractor maintenance activities.-
Violation of ' License Condition No; 9.
Not cited as discussed in Paragraph 6.b.
70-1113/90-03-04 VIO:
Failure to follow procedures'for. posting-a radioactive waste Queuing Pad 1(Paragraph 6.c).
Violation of License Condition No.-9..
70-1113/90-03-05 VIO:
Failure to follow procedures for maintaining a storage pad area locked- (Paragraph -12.b). -
i Violation of License Condition No. 9.
70-1113/90-03-06 NCV:
Failure-to have adequate procedure guidance for the disposal of potentially radioactive contaminated ~ waste..
Violation of License Condition No. 9.
Not cited as discussed-in Paragraph 12.b.
70-1113/90-03-07 IFI: Review licensee's actions-regarding oral commitment to review maintenance procedures for inadequacies regarding handling of' potentially contaminated trash-and to_ implement corrective actions within 60_ days (Paragraph 12.b).
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