ML20036A816
| ML20036A816 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 04/21/1993 |
| From: | Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20036A808 | List: |
| References | |
| 70-1151-93-02, 70-1151-93-2, NUDOCS 9305170044 | |
| Download: ML20036A816 (9) | |
Text
OMITED STATES
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NUCLEAR REGULATORY COMMISslON
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101 MARIETTA STREET, N.W.
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ATLANT A. GEORGIA 30373
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APR 29 N Report No.:
70-1151/93-02 Licensee: Westinghouse Electric Corporation Commercial Nuclear fuel Division Columbia, SC 29250 Docket No.:
70-1151 License No.: SNM-Il07 Facility Name: Columbia Nuclear Fuel Plant Inspection Conducted: March 1-5, 1993 and subsequent telecon conversations on March 31 and April 1, 1993 4-AE 4/1//d Inspector:
E. D. Testa, P. E.
Da'te signed 1
Approved om
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W. H. Rankin, Chief Date 61gned Facilities Radiation Protection Section Radiological Protection and Emergency Protection' Branch Division of Radiation Safety and Safeguards I
SUMMARY
Scope:
This routine, unannounced inspectica was conducted in the area of occupational radiation safety and included an examination of: procedures, instruments, l
equipment, external exposure control, control of radioactive materials and contamination, surveys and monitoring, notifications and reports, and maintaining exposure ALARA. Also, the inspection involved followup and review of the weaknesses and unresolved items identified during the Operational Safety Assessment conducted during.the period August 17-28, 1992.
Results:
Within the scope of the inspection, various issues were identified that-appeared to be violations of license conditions. These included problems identified during the Operational Safety Assessment as well as problems noted during the current inspection. These issues included:
One Licensee Identified Violation (Non-Cited) for failure to followia Radiation Work Permit procedure (Paragraph 3).
Multiple examples of failure to adequately control radioactive contamination (Paragraphs 4, 8.a).
9305170044 930429
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An example of failure to follow plant procedures (Paragraph C.b).
There are concerns identified in regard to radioactive contamination control, procedural compliance, a weak audit / review program, and apparent inadequate actions to correct Health Physics program weaknesses.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- W. Dougherty, Staffing Services Site Coordinator
- J. Fici, Plant Manager
- S. Gantt, Senior Regulatory Engineer
- D. Goldbach, Manager, Chemical Process Engineering
- W. Goodwin, Manager, Regulatory Affairs
- J. Heath, Manager, Regulatory Operations
- E. Keelen, Manager, Fuel Manufacturing
- R. Koga, General Manager, Commercial Nuclear Fuel Division
- R. Likes, Regulatory Engineer
- S. Mcdonald, Manager, Technical Services
- E. Reitler, Manager, Regulatory Engineering
- C. Sanders, Manager, Nuclear Materials Management & Product Records
- C. Thomas, E:.gineer
- C. Wu, Advisory Engineer, Technical Services
- R. Williams, Technical Coordinator, Regulatory Affairs-Other licensee employees contacted during the inspection included engineers, technicians, operators, and office personnel.
- Attended the exit interview on March 5, 1993 2.
Purpose of the Inspection (83822)
During the period of August 17-28, 1992, the NRC conducted an-Operational Safety Assessment (0SA) of the licensee's safety programs at the Commercial Nuclear Fuel Plant in Columbia, South Carolina. The results of the OSA were documented in NRC Inspection Report (IR)
No. 70-1151/92-04 dated November 25, 1992. The OSA team noted a number of weaknesses and unresolved items which were identified by the designat.7n of "92-04 " plus two more digits.
The last-two digits indicab. the numerical sequence of that issue as it appeared in the OSA.
report. Several of those items appeared to be violations of the licensee's license requirements. As a result, this inspection was performed to review thcse items and determine if violations had, in fact, occurred and to initiate appropriate enforcement action.
3.
Pre-Job and Post-Job ALARA Review Checklists (Item 92-04-29)
The OSA indicated that pre-job and post-job ALARA review checklists were not consistently documented as required per Procedure RA-207, Radiation Work Permit, Revision 7, dated September 2, 1992.
The inspector reviewed licensee documents that indicated that'this weakness had been observed and identified in the "LINC" file on Monday August 17, 1992, the day prior to the OSA team arrival-onsite. At'that time, Radiation Work Permits (RWP) 92-17 and lower had. been completed a
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2 and were in the file.
RWP 92-18 was still in effect. This item was considered a licensee identified violation and is therefore not cited.
Results of this inspection indicate subsequent satisfactory RWP i
i performance with adequate corrective action for the non-cited violation (NCV) and therefore it is considered closed.
l NCV 70/1151/93-02-01:
Licensee identified violation for failure to i
follow procedure RA-207, Revision 7.
One NCV was identified.
4.
Survey and Contamination Control Program (Item 92-04-30)
The OSA indicated that numerous weaknesses were noted in the licensee's i
survey and contamination control program including, failure to perform surveys of incoming shipments of radioactive material, inadequate surveys of food preparation, eating, and drinking areas, and inadequate i
HP coverage for some work performed under RWPs. Telecon discussions on March 31 and April 1, 1993 and the requested material transmitted in.a memo dated April 1, ;993 provided additional details and explanations of.
the OSA weaknesses.
Review of supporting inspection data from IR 92-04 indicated that significant numbers of procedures or procedural steps were apparently observed to be violated. Among the procedures violated included the following:
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Procedure RA-201, Contamination Control, Revision 5, dated April 28, 1987 j
b.
Procedure RA-203, General Health Physics Rules and i
Recommendations, Revision 11;' dated April 30, 1992 c.
Procedure RA-204, Bioassay Program, Revision 6, dated January 14, 1991 d.
Procedure RA-207, Radiation Work Permit, Revision 6, dated June 27, 1989 e.
Procedure RA-211, Low-Level Radioactive Scrap, Revision 6, dated i
November 8, 1990 f.
Procedure RA-217, Personnel Monitoring Requirements, Revision 1, dated May 12, 1987 g.
Procedure R0-02-008, Survey of Incoming Shipments of Radioactive Materials, Revision _1 h.
Procedure R0-05-014, Performing Contamination Survey of the
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Westinghouse Facility, Revision 10 These weaknesses were irientified to the licensee as examples of an apparent violation of the above' listed procedures. See Paragraph 8.a for additional examples and the violation citation in Paragraph 8.a.
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5.
Possible Intake of Radioactive Material (Item 92-04-33) i The OSA indicated a possible intake of radioactive material in excess of the limits specified in 10 CFR Part 20.
The licensee was to review the actual intakes.
The inspector reviewed the wholebody count data and dose assessment analysis performed by the licensee on the subject individual's data and the independent assessment performed by the licensee's consultant.
The j
inspector concluded that the data and analyses did not support the l
possible intake of radioactive material in excess of the limits specified in 10 CFR Part 20. This item has been closed.
6.
Inspector Followup Items (IFIs) a.
(Closed) Item 92-04-28:
Followup on the adequacy of the HP i
technician training program.
The inspector reviewed the closure material provided by the licensee. The most recent procedural changes have been made on an electronic procedure system.
The system highlights the changes or
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additions to the procedures so that they are easily identified.
In addition a memo to each of the HP technicians has been. issued advising them of procedural changes and informing them of what actions are needed. Additional; HP training' has been conducted by ~
sending techniciacs to a similar fuel fabrication facility.
The corrective actions were reviewed by the inspector and this item has'been closed.
b.
(Closed) Item 92-04-31:
Followup on the lack of-air monitoring devices in the Honing Area of Waste Recovery and Disposal. (WR&D).
The inspector toured the facility and observed that the air-sampler in question was associated with a new piece of equipment that had not been placed in service at the time of the OSA-inspection.
At the time of this inspection, the flow meter was observed to be in place with all necessary tubing.
The sampling station had been placed in service concurrent with the operation of the equipment. The inspector observed the operation of the air sampler and reviewed sampler results. The inspector found the i
sampler results representative of the worker's breathing zone,.and concluded that the sampler head placement and sample results were satisfactory. This item has been closed.
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(Closed) Item 92-04-32:
Followup on the' timeliness of urine sample analyses.
.The inspector reviewed the timeliness of urinalysis sample turnaround time:and observed.that san. oles are now being sent i
" rush" and that actual turnaround has been reduced from about P
three weeks to about seven days. This appears to be acceptable.
This item has been closed.
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d.
(Closed) Item 92-01-01:
Evaluation of Extremity Doses for Rod Operators.
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The inspector reviewed the licensee's Commitment Tracking System Report item NRC9201-RA.100 file dated June 30, 1992, dealing with i
the IFI. The file indicates that the licensee has taken an aggressive approach to reducing the extremity doses to-the rod operators.
Examples included the use of an automatic boat loader and the Pellet Visual Inspection System. Other remote handling-devices and protective wear for extremities are being investigated on a continuing basis. This item has been closed.
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(Closed) Item 92-01-02:
Evaluate the possible overexposure of an individual having a 4th quarter extremity exposure of 6.747 rem at the base of the finger.
i The inspector reviewed the material contained in the licensee's i
file NRC 9201-08.100 dated June 24, 1992.
The information showed a fingertip to knuckle ratio of 1.54 thus giving a fingertip exposure of 10.400 rem which is below regulatory limits. This item has been closed.
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(Closed) Item 92-01-03: Complete wholebody in vivo cross checks by April 1992.
The inspector reviewed the material contained in the licensee's file NRC9201-CC.100. A memo from R. D. Likes to E. K. Reitler dated May 1992, documented the March 26, 1992 in vivo Cross Check Counts performed at the. Savannah River Site.
The limited data seemed to indicate that the licensee's counting system was consistent with the U-235 burden analysis at the Savannah River Site; however, a recommendation was made to continue the cross checks and' incorporate some lessons learned to enhance the reproducibility of these counts.
This item has been closed.
9 (Closed) ltem 92-01-04: Develop formal program documentation for internal dose assessment calculations, including validation and verification.
The inspector reviewed the licensee's file NRC9201-CD.100 containing a memo from R. D. Likes to E. K. Reitler dated August 16, 1992 (RE-RDL-92-48). The file contained formal documentation describing the methodology used to estimate workers' intakes of uranium.
Review of sample calculations. and the independent review performed by the licensee's consultant appear to provide reasonable assurance of reproducible dose calculations consistent with current acceptable guidance. This item has been closed.
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Licensee Actions Regarding Previous Enforcement Items (Closed) Item 92-01-05:
NRC Identified Violation involving four examples of failure to follow Procedure RA-402.
3 The inspector reviewed the closure package of the licensee's response to the violation dated June 29, 1992, and found that the actions outlined f
in the closure package had been satisfactorily completed as described.
i The inspector toured the area where the violations were identified and found the area clear and a limited survey detected no additional contamination.
This item was closed.
8.
New Items Noted During the Follnwup Inspection l
a.
Condition 9 of Special Nuclear Material License Number 1107 (SNM-1107) requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the application dated March 26, 1984, and supplements thereto.
Chapter 3, Sections 3.2.2.2 and 3.2.2.3 of the application states that " access points to the Controlled Areas are established r
through change rooms and step-off pads. Each access point includes a ' hot' side and a ' cold' side, with a step-off area provided between the hot and cold sides." The application further states
"... used protective clothing is stored on the hot side and collected there for laundering."
The inspector noted during a tour of the outside areas that the
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uranyl nitrate tank (UNH) area had three access points to a controlled area but had no stepoff pads and that used contaminated protective clothing was stored outside the controlled area in the cold side. Surveys of the stepoff pad areas revealed smearable 2
contamination present (approximately 69 dpm/100 cm 2
with a 50 dpm/100 cm limit) as well as fixed contamination of approximately 2500 cpm.
During the same tour of the outside facilities and procedure review, the inspector identified multiple examples of failure to control contamination. A contaminated work glove (approximately 500 cpm)-was found in a clean trash dumpster. This is a violation of Procedure RA-402, Step 1.2 and Procedure RA-211.1.
A trailer, which had been relocated from the storage area, was observed in.
the truck bay on loading dock #3 with the doors folded back obscuring the posting.
Contamination was found on the loading r
dock (approximately 3000 cpm) and the portable acce.ss stairs to 1
the loading dock (approximately 500 cpm). A used respirator was found to be contaminated on the external surface (approximately
'1000 cpm) with multiple expended chemical cartridges, gum wrappers, and a carbonated soda can were found in a storage locker
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i in the advanced waste water treatment area. This is a limited access area and is contaminated. This is an apparent violation of licensee Procedures RA-207 and RA-402. This was identified as an apparent violation of multiple procedures that address contamination control.
t Violation (VIO) 70-1151/93-02-02: Multiple examples of failure to control radioactive contamination.
b.
The inspector reviewed Procedure RA-102, Plant Inspection Program j
for Regulatory Compliance. The procedure defines the program, schedule and inspections checklist for the Regulatory Affairs inspection plan.
Formal inspections shall also be performed in accordance with a written inspection plan at least monthly during
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operations. Observed violations and required corrective actions i
are assigned area responsibility and completion dates, and shall be documented in an inspection report transmitted to area management. The Radiation Protection Inspection Plan was not performed.as stated in the procedure nor were findings documented as required nor were corrective actions adequately implemented.
These were identified as an apparent' violation of failure to follow plant inspection procedure.
VIO 70-1151/93-02-03: An example of failure to follow plant
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procedures.
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The inspector also observed _ numerous workers in the manufacturing area wearing jewelry which is contrary to the employee training -
provided. The licensee was informed that this item will be tracked as an IFI.
IFI 70-1151/93-02-04:
Reemphasize during employee training and by periodic personnel observation that wearing jewelry in the manufacturing area is discouraged.
d.
Two compressed breathing air bottles', that at least one employee believed was an emergency breathing air supply, were found. These compressed air bottles were not part of the current emergency j
breathing air supply system.
Fittings and couplings were not compatible with respirators currently in use. Employee training should correct the misconception of the bottles intended use and the remaining bottles should be removed. The licensee was informed that this item will be tracked as an IFI.
IFI 70-1151/93-02-05:
Remove all remaining "old" breathing air supply bott'es init are not part of the approved emergency breathing a.r p:ogram.
i Two violations with multiple examples, two IFIs and no deviations were
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observed.
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Exit Meeting The scope and results of this followup inspection were summarized on March 5, 1993, with those persons indicated in Paragraph 1 above. The inspector described the issues reviewed and discussed in detail the inspection results and observations.
No dissenting comments were received from the licensee. Although proprietary material was reviewed i
and discussed during this inspection, proprietary information is not contained in this report.
Item Number Description and Reference l'
70-1151/93-02-01 VIO - NCV - Licensee identified violation.
i Failure to follow Procedure RA-207, Radiation l
Work Permit (Paragraph 3).
70-1151/93-02-02 VIO - Multiple examples of failure to control radioactive contamination (Paragraphs 4 and 8.a).
l 70-1151/93-02-03 VIO - An example of failure to follow plant procedures (Paragraph 8.b).
70-1151/93-02-04 IFI - Reemphasize during employee training and-by periodic personnel observations that wearing jewelry in the manufacturing area is di.scouraged (Paragraph 8.c).
70-1151/93-02-05 IFI - Remove all remaining "old" compressed gas breathing air supply bottles that are not part of the current approved emergency breathing air program and provide worker update training.
(Paragraph 8.d).
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