ML20035B728

Insp Rept 70-1257/93-01 on 930204-11.Violations Noted.Major Areas Inspected:Radiation Protection Program Including Procedures,Instrument & Equipment & Contamination Surveys

ML20035B728
Person / Time
Site:	Framatome ANP Richland
Issue date:	03/09/1993
From:	Hooker C, Nader Mamish, Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20035B719	List: ML20035B718 ML20035B728
References
70-1257-93-01, 70-1257-93-1, NUDOCS 9304050041
Download: ML20035B728 (11)

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U.S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/93-01 License No. SNM-1227 Licensee:

Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130 Facility Name: Siemens Power Corporation Inspection Location: Richland, Washington Inspection Duration:

February 4-11, 1993 and February 26, 1993 M Mf5 N'

• d Inspected By:

C. A. Hooker, Fuel Facilities Inspector Date Signed A $( fM 3/9 / 9A N.

/. 11 amish, Radi ti pecialist Date Signed 3!/D/13 f

hru ih Approved by:

j Date Signed H. Reese, Chieff a.acil"jties Radiological Protection Branch Summary:

Routine unannounced inspection of radiation protection.

Areas Inspected:

Selected areas of the licensee's Radiation Protection Program were examined e

involving; radiation protection procedures, instrument and equipment, exposure control, posting and labeling controls, contamination surveys, and ALARA.

Inspection procedures 30703 and 83822 were used.

I In the areas inspected, the licensee's performance appeared Results:

The following items were of particular note:

satisfactory.

Strenoths:

The licensee's prompt corrective actions to issues identified by (1) the NRC (Sections 2.b, 2.c, and 2.d).

The Airborne Contamination Task Team efforts in tracking and (2) reducing airborne contamination (Section 2.f(3)).

Violations:

One violation was identified for failure to calibrate surface barrier detectors, as required by the Safety Manual (Section 2.b).

(1)

One non-cited violation was identified for failure to post (2) entrances to buildings in which radioactive materir.ls were used, stored, or handled, as required by the License Conditions (Section 2.d).

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.j DETAllS 1.

Persons Contacted Siemens Power Corporation (SPC) i R. K. Burklin, Health Physicist

• J. B. Edgar, Staff Engineer, Licensing

• E. L. Foster; Health and Safety Specialist

• R. B. Logsdan, General Supervisor, Ceramic 0perations

• L. J. Maas, Manager, Regulatory Compliance

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• C. D. Manning, Criticality Safety Specialist

• M. K. Valentine, Manager, Manufacturing Engineering

• R. E. Vaughan, Manager,~ Safety, Security and Licensing NRC C. A. Hooker, Fuel Facilities Inspector

• N. L. Hamish, Radiation Specialist i

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• J. H. Reese, Chief, Facilities Radiological Protection Branch

• Denotes those individuals who participated in the exit meeting'on j

February 26, 1993.

In addition to the' individuals noted above, the 4

inspectors met and held discussions with other members of the licensee's-staff.

i 2.

Radiation Protection 83822 The inspector examined the licensee's Radiation Protection (RP) Program by interviewing cognizant personnel, reviewing pertinent documents and procedures, observing work in progress,.and conducting facility tours.

Specifically, the inspector focused the inspection on instruments &

6 equipment, exposure control, and posting & labeling.

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a.

Radiation Protection Procedures i

l The licensee had been instituting 2 series of new procedures:

Radiological Safety Procedures and Site Radiological Operating Procedures (EMF-1507 and EMF-1508 series respectively). At the

.j time of the inspection, the licensee had developed and approved i

approximately 20% of the Radiological Safety. Procedures.

Licensee staff indicated that the remaining Radiological Safety' Procedures would be implemented by the end of 1993. The Site Operating Procedures had not been written.

The inspector reviewed the _ newly developed and approved.

Radiological Safety Procedures (RSPs) and held discussions with licensee staff regarding the requirements within the RSPs. The inspector noted that the RSPs did not appear-to be comprehensive; however, they provided the basic elements of an adequate ' radiation-protection program and were consistent with the license requirements.

No violations or deviations were identified.

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2 b.

Instruments & Eauipment I

The inspector examined this program area by review of procedures and calibration records, field verification of instruments' operation, and discussion with licensee personnel.

The licensee performs annual calibrations on rotometers used to measure air flow rates through air sampling stations, and l

semiannual calibrations on radiation detection instruments.

Instruments due for calibration were identified by plant maintenance, located by plant radiological safety, and calibrated by plant maintenance.

In touring the radiation controlled area, the inspector examined and verified the operability of field instruments.

Instruments, in general, were free of physical damage, had an affixed

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calibration sticker, and appeared to be properly operating. The inspector discussed with licensee personnel the various calibration and operation checks performed on the Surface Barrier

'l Detectors (SBDs).

The SBDs were used by plant radiological safety for counting routine and special air samples.

l The licensee performed a background check and five 1-minute source l

checks daily on each SBD.

If four out of five 1-minute source checks fell inside the 95% confidence. level, an SBD was considered to be appropriately operating and may be used for. counting air samples.

Jf two, or more, out of five 1-minute source checks fell outside the 95% confidence level, an SBD was tagged out of service and a Chi Square test was performed.

The Chi Square test, which is a measure of the SBDs deviation relative to the expected deviation, is performed to ensure the SBD's counter is properly functioning.

In addition,-a Chi Square test establishes an SBD's upper and lower efficiency _ limits.

r Based on discussions with the licensee, a Chi Square test was performed under the following conditions:

On quarterly basis.

Following a two, or more, out five 1-minute source check failures.

Following maintenance on the SBDs.

(1)

Observed Condition:

I In review of calibration and daily source check records, the inspector noted the following deficiencies-(a)

The licensee had not been calibrating all surface barrier detectors used by plant radiological safety for counting routine and special air samples.

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The detectors had been used by the licensee since August 22, 1985.

(b)

Multiple source check failures and Chi Square tests had been performed on the detectors. As many as 6 Chi Square tests were performed since December 1, 1992 on Detector D in the U0, building. Detectors B, F, and.H had each undergone 5 Ch: 3quare tests since December l

1, 1992.

t (2)

Licensee Assessment:

Radiological safety staff concurred with the inspector's r

observation and stated that they were unaware that the instrument had not been calibrated.or had undergone multiple Chi Square tests.

In subsequent discussions, however, plant maintenance staff indicated that Chi Square tests l

a constituted a calibration.

I (3)

NRC Assessment:

l The inspector pointed out the following:

(a)

A Chi Square Test d a s not include adjustment of the l

upper and lower disceimir.'or levels (i.e. window) i within an SBD to ensure Tat all alpha garticles emitted by uranium isotopes (i.e. ""U,

'U, and ""U).

were in fact captured by the SBD.

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(b)

Despite multiple source check failures by four SBDs i

since December 1, 1992, no corrective action had been i

implemented to effectively investigate and/or repair

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the SBDs.

t (c)

The licensee had not. established and approved i

procedures documenting that a chi. square constituted a j

calibration.

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(4)

Licensee Corrective Action:

i The licensee stated that a calibration procedure that sets forth calibration requirements for the SBDs would be established and approved. All SBDs were fully calibrated i

including adjustments of the upper and lower discriminator levels. As'of February 22, 1993, the licensee had j

implemented the calibration procedure and calibrated all j

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five SBDs.

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(5)

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Conclusion:==

1 License Condition No. 9 of License No. SNM-1227 authorizes' the use of licensed materials in accordance with the-I 4

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statements, representations, and conditions contained in Part I of the licensee's application dated July 1987, and l

supplements dated November 12, 1987, through March 25, 1992.

Section 2.5 " Operating Procedures, Standards and Guides,"

Part I of the license application, states in part that the licensee conducts its business in accordance with a system i'

of Standard Operating Procedures, Company Standards, and Policy Guides.

Section 2.5, " Instrument and Equipment," Chapter 2, i

" Radiological Protection Standards," of the Safety Manual-EMF-30, states in part-

"All radiation detection and dose rate instruments shall be inspected and calibrated per Regulatory Guide t

8.24 at least semiannually."

The inspectors concluded that the licensee's failure to calibrate all SBDs (5) in service at the time of the inspection, as required by the Safety Manual, constituted a l

violation (70-1257/93-01-01).

With the exception of the discrepancies noted, the licensee's-program for instrument and equipment appeared adequate in accomplishing the licensee's safety objectives.

I One violation of NRC requirements was identified.

c.

Exposure Control The inspectors reviewed the licensee's methods for controlling internal and external exposure by examining licensee procedures, i

review of records, and observations of work in progress.

Specific observations were made in relation to air sample counting practices and respiratory protection.

(1)

External Exposure Control

'i The inspector reviewed a selection of personnel exposure records for compliance with 10 CFR 20 Sections 101, 102, 104, and 408.

In all cases reviewed, records were complete.

Forms NRC-4 and NRC-5, or equivalent, records of whole body' exposures, and in-vivo counting had been properly maintained.

For terminateo employees, letters documenting exposures had been appropriately sent in accordance with 10 f

CFR 20.408.

i (2)

Internal Exposure Control The inspector reviewed this area of inspection by examining e

the licensee's air sampling program, and performing field j

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observations of sampling and counting techniques.

The i

bioassay program was not inspected during this inspection.

The licensee employed engineering controls, including l

process, containment, and ventilation equipment to limit concentrations of radioactive material in air As low As l

Reasonably Achievable (ALAPA).

In addition, the licensee l

maintained a comprehensive program for assessing concentrations of uranium in air for each area where operations could expose workers to the intake of quantities exceeding those specified in 10 CFR 20.103.

Air sampling was accomplished by using 325 fixed location samplers for basic evaluation. Personal (lapel) samplers were used for supportive measurements and special studies.

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Air samples were normally collected and analyzed each shift.

If airborne concentrations exceeded 1.0 E-11 pCi/ml (10% of uranium MPC) in certain areas, then air samples were collected at least every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in those zones.

j The inspector accompanied a Health Physics Technician (HPT) that was performing the shiftily air samples changeout.

While the HPT was collecting air samples, the inspector noted that rotometer No. C09 (i.e. flow rate meter) appeared to be malfunctioning. The HPT performing the air samples changeout promptly notified the plant maintenance to replace the rotometer.

In subsequent tours during the same shift, the inspector verified that the rotometer was in fact changed. Air sample results, obtained following the replacement of the rotometer, indicated that uranium airborne concentration had been well below 10 CFR 20 limits.

In observation of counting techniques, the inspector raised j

some concerns regarding the handling of potentially contaminated air samples. The inspector noted that HPTs did l

i not take proper radiological precautions while loading air samples into the counting instruments (i.e. were not using tweezers or gloves).

Licensee staff acknowledged the inspector's observation and stated that HPTs should be using tweezers. On February 9, l

1993, the license issued a memorandum requiring the f

following:

Use of tweezers or gloves when handling air samples.

No drinking or smoking be allowed in the health and safety technician offices.

l Air sample counting procedures be changed to reflect the new requirements.

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6 Overall, the licensee's air sampling program, in the areas l

reviewed, appeared to be good. The licensee's prompt j

corrective actions relating to the rotometer replacement and radiological safety practices were quite satisfactory.

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(3)

Respiratory Protection

-i The inspector evaluated the licensee's practices for control l

of respiratory protection equipment and supplies. Specific l

i observations were made in relation to respirator issuance controls and fit test record keeping.

l (a)

Respirator Issuance Controls i

The inspector observed several HPTs distributing respirators to employees without verifying the workers l

were on the respirator approval list.

In discussion with the inspector, the licensee indicated that this l

problem was identified in the January 1993 audit. As a corrective action, the licensee implemented a respirator issuance procedure requiring HPTs to verify the workers were on the respirator fit test approval j

l list prior to issuing respirators.

(b)

Fit Test Record Keepina In review of physical, training, and respirator fit-l test records, an administrative deficiency was identified regarding record keeping. The inspector i

i noted that several'of fit test records were not present in the personnel files. The licensee was able to obtain the missing records readily. The licensee l

indicated that this deficiency had also been identified by an in-house audit and added that the cause of deficiency appeared to be the vendor's i

failure to transmit the fit test records to the site in a timely manner. -

As a corrective action, the licensee had implemented a tracking system to ensure that fit test records were received and filed in an acceptable time frame.

In addition, the licensee stated that a full review of records would be performed within.30 days.

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review would include fit test records transmitted by the vendor prior to the-implementation of the tracking system.

t The licensee's exposure control programs, in the aspects observed, appeared effective in controlling internal and external exposures.

No violations or deviations were identified.

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d.

Postino. Labelino. and Contamination Controls The inspectors evaluated the licensee's practices of posting, labeling, and contamination controls by review of licensee Radiation Work Procedures (RWPs), discussion with licensee staff, and observation of work in contaminated areas. Two observations were made regarding contamination controls and posting & labeling practices.

3 (1)

Contamination Controls The inspectors observed several instances' where plant operators and maintenance personnel were working in the contamination controlled area without donning the minimum protective clothing as required by their RWPs. For example:

A maintenance worker not wearing gloves while operating the Line 1 Calciner Control Panel. When questioned, the worker stated that he thought panel was clean.

The inspectors observed a plant operator manipulating valves associated with the powder preparation system without wearing gloves.

In discussion with the inspector, the licensee indicated that plant supervision and management would amind 'everyone

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to fully comply with their RWPs. The licensee further indicated that some changes to RWPs may be made to stress and underline adherence to minimum protective clothing requirements.

Subsequent field observations'by the inspectors indicated that workers were fully complying with their RWP requirements.

(2)

Postino and labelino Radiological posting, in general, appeared to meet the requirements of 10 CFR 20.203 and Part I of the License Condition.

Radiation levels measured by the inspector correspond, in all cases, to recent licensee surveys. The inspector noted instances, however, in which the licensee was not in full compliance with the requirements set forth in 10 CFR 203(f):

(a)

Reculatory Criteria:

10 CFR 20.203(f) requires containers of radioactive material (with certain exceptions) to bear an identifying label.. The label must bear the radiation symbol-and the words, CAUTION RADI0 ACTIVE liATERIAL." In addition, the label-must t

provide sufficient information to permit individuals handing or using the containers, or working in the

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l vicinity thereof, to take precautions to avoid or i

minimize exposures.

j The licensee, however, is exempted from 10 CFR 20.203(f) as stated in Part I of the License

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Conditions.

i Section 1.6.4 of Part I states that "All areas in -

which radioactive materials are stored, handled or used shall be posted with signs meeting the-requirements of Title 10, CFR Part 20.203, except that

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i of 20.203(f).

In~ lieu of 20.203(f) requirements, a sign bearing the legend, 'Every container or vessel in this area, unless otherwise identified, may contain radioactive material," may be posted at entrances to each building in which radioactive materials are used,

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stored or handled.

(b)

Observed Condition: During a tour of the site on February 10, 1993, the inspector observed 6 entrances to various buildings in which radioactive materials were used, stored or handled, that were not. posted as i

required.

In subsequent tours with the licensee, the inspector t

pointed out some of the unposted entrances.

Licensee staff acknowledged the inspector's observation and stated that some of the unposted entrances were 1

previously posted. The licensee added that, perhaps, I

when doors to entrances were replaced, labels were not placed on the new doors as required by the License

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Conditions.

i (c)

Licensee Corrective Actions: The licensee took immediate corrective actions by examining entrances to j

all buildings on site and repost entrances as necessary. On February 11, 1993 the licensee informed the inspector that sixteen out of forty eight l

entrances had not been posted as required, but added that all doors or entrances had been properly posted.-

(d)

NRC

Conclusion:

The inspectors concluded that the failure to post entrances to buildings in which radioactive materials were used, stored or handled, constituted a violation of the license conditions (70-1257/93-01-02). The licensee acknowledged the l

inspectors' observations. This violation is not being

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cited because the criteria specified in Section VII.B 1

of the Enforcement Policy were satisfied.

One non-cited violation was identified in the area of posting, labeling, and contamination control.

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e.

Contamination Surveys The inspector reviewed daily, weekly, and monthly survey records for January 1993.

Contamination surveys had been performed in accordance with EMF-1507 6.1, " Area / Facility Removable Contamination Control," Revision 1, dated January 4,1993.

In all cases, surveys were completed as required and were well cocumented. No deficiencies were identified.

f.

ALARA The inspector reviewed the licensee's ALARA performance by interviewing cognizant personnel, reviewing the 1991 ALARA Committee Report, and observing work in progress. Specifically, e

the inspector centered on the liquid and gaseous effluent discharges, whole body exposures, and the Airborne Contamination Task Team.

(1)

Liouid and Gaseous Effluent Discharaes: The total annual microcurie OuCi) of the gaseous effluents was well below the licensee's limit of 50 pCi/ quarter; likewise, the total Curie (Ci) content in the liquid waste discharge was well under the limit of I Ci/ year.-

(2)

Whole Body Exoosures: The total whole body exposure for the work force rose from 33.47 to 38.81 person-rem. However, the licensee stated that the increase in manpower and production were largely responsible for the increase in external exposure. The inspector noted'that although it had increased, average personnel external exposure was still well below the regulatory limits.

(3)

Airborne Contamination Task Team (ACTT):

In 1992 the licensee established the ACTT.with the objective of implementing actions needed to achieve the lowest practical level of airborne contamination. The team included representatives from plant engineering, operations, and-radiological safety.

Projects that reflected the efforts of the team include (a)

Installation of ventilation on Lines 2 and 3 bag filter hoppers.

(b)

Design and installation of hoods on all bag filters. -

(c)

Tracking and trending airborne contamination in the contamination controlled area.

The inspector concluded that the licensee ALARA performance and y

the efforts of the ACTT appeared effective in reducing dose and keeping airborne contamination ALARA. No violations or deviations were identified.

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3.

Inspection Exit Meetina (30703) r During a telephone conversation on February 26, 1993, the inspector j

discussed with licensee representatives, the scope and findings'of.the i

inspection.

The inspector noted that the discrepancies related-to the SBDs suggested the need for improved supervisory review and increased management

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involvement in theses areas. The licensee acknowledged the inspectors' i

observations.

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