ML20042E758
| ML20042E758 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 04/13/1990 |
| From: | Bassett C, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20042E752 | List: |
| References | |
| 70-1201-90-02, 70-1201-90-2, NUDOCS 9005030043 | |
| Download: ML20042E758 (18) | |
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' p#4400 UNITE 3 STATES
- 9 NUCLEAR REIULATORY COMMIS$1:N
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APR 181990
- Report No.: 70-1201/90-02 l
Lic'ensee: %W Fuul @ panj ~
Comr.iereIn NucQi;r Fuel P1 ant Lynchhury,VA 24505 Docket No.: 70-1201 License No.: SNM-1168 i
facility Name:
Commercial Nuclear Fuel Plant (CNFP)
. Inspection Conducted:
- rck 6 9, 1990
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Inspector:
ims 13 io -
. H. Bassett Radf atif.4ecialist Date'51gned N#
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Approved by:
E. J. McAlpine, Chief Date Signed Radiation Safety Proiects Section l
Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards i
SUMMARY
L Scope:
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This routine, unannounced. inspection involved review of the radiation
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protection (RP) program including _ RP staffing and organization; audits, training and qualifications; internal and external-exposure control; surveys.
and contamination control; radioactive waste management and control; transportation of radioactive material; and,. follow-up on licensee actions concerning previously identified items.
Results:
The licensee's RP staffing and organization appeared to be adequate and in-compliance with the license requirements.
A, change'was noted in the position of Health Physicist at the facility and another RP technician is.being added to.
the staff.
External exposure control appeared to-be adequate with most personnel receiving an annual dose of less than 100 millirem. One weakness was o
noted in the area ^of intern 61 exposure control involving incorrect calculation-of Maximum Permissible Concentration-hours (MPC-hrs) assigned to individuals t
. working in the Service Equipment Refurbishment Facility (SERF) area.
This weakness was corrected during the inspection.;'Another weakness was noted with
~ investigations conducted by.the licensee which resulted from apparent high j
airborne concentrations in specific. areas.
An Inspector Fol'lowup Item was established to ensure that corrective actions will have been adequate to correct the problem.
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Control of radioactive material appeared to be adequate, as did management and control of radioactive waste.
Another weakness was noted with procedures used at the facility.
A review of selected tiP procedures indicated that they generally contain only broad guidelines with few specific limits or job-related L
l instructions.
Problems were noted in the areas of posting radiation areas and transportation of radioactive material.
In general, however, management of the facility radiation protection program was considered adequate to protect worker and public health and safety.
Within the areas inspected, the following violations were identified:
Failure to post a radiation area outside the main building in the vicinity of a service equipment trailer.
This issue was characterized as a Non-cited Violation (Paragraph 5).
3 Failure to provide all the required information on a waste manifest which accompanied a shipment of radioactive waste (Paragraph 6).
Various examples of failure to comply with 10 CFR 71.5 requiring compliance with the regulations of the Department of Transportation (DOT) 49 CFR 170-189 for transportation of radioactive material (Paragraph 7) including:
1)
Failure to specify on the shipping papers the activity contained in each package of a waste shipment and the physical form of the material being shipped in a shipment of field service equipment; i
2)
Failure to survey the external surfaces of one-empty Uranium l
flexafluoride (UF6) cylinder for radiation or contamination l
levels and the containers of' two fuel shipments for beta-gamma contamination levels; and, 3)
Failure to survey the internal surfaces of any of five shipments l
of the UF6 cylinders for contamination levels and failure to include a statement on the shipping papers of the UF6 cylinders l
verifying that the cylinders were in conformance with the specified limitations for empty packages.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees l
- R. Alto, Plant Manager 1
- E. Coppola, Manager, Quality and Safety J. Ford, Manager, Fuel Manufacturing
- K. Lester, Manager, Health Physics and Licensing
- G. Lindsey, Foreman, Health Safety
- B. Pugh, Manager, Production and Material Control i
- K. Shy Industrial Safety and Environmental Control Officer
- C. Speight, Manager, Facilities l
Other licensee employees contacted during the inspection -included engineers, technicians, operators, and office personnel.
- Attended the exit interview 2.
Radiation Protection Organization, Staffing and Control' (83822) a.
Organization and Staffing l
Parts 5.1 and 5.3 of Section V of the Application for License Number SNM-1168, dated February 4,1987, and subsequent revisions thereto (hereafter referenced as the License Application) outline the-organization and staffing requirements for the health-safety group in the facility organization.
Radiation protection responsibilities are also outlined, as are qualifications for the positions of the Health Physicist and health-safety group leader.
The inspector reviewed tha organization and staffing level of the.
facility health physics (HP) or health-safety group.
The current organization is staffed by a Health Physicist who is in charge of the HP group. The Health Physicist also has the title of Manager, Health.
Physics and Licensing.
Operational staffing under the facility ~
Health Physicist includes a health-safety group leader or foreman and three technicians.
During the inspection, the licensee indicated -
that another person had been hired as a technician in the HP group.
This person will be used primarily to provide added coverage in the recently established SERF area.
During review of the organization, the inspector noted that the individual who is currently the facility Health Physicist had previously been responsible only for licensing and compliance but now has responsibility for both functions.
The former Health Physicist was given the position of Industrial Safety and Environmental Control Officer. The inspector also reviewed the qualifications of the newly
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oppointed Health Physicist and verified that all the requirements l
stipulated by the license were met.
The inspector observed that the organization established to provide radiation protection for the facility and management of the radiation protection program were adequate.
b.
Audits Part 5.4 of Section V of the License Application requires that -
independent auditors shall be appointed to ascertain the overall performance of the plant functions in providing adequate controls, surveillance, and follow-up to assure safety and license compliance, t
Part 6.6 of Section V requires weekly and quarterly audits of plant-l activities related to health and safety.
The inspector reviewed selected-quarterly and weekly' health-safety l audits.
The quarterly audits were conducted by personnel'. from the -
B&W Navy Nuclear Fuel Division plant who provided an independent or-
"outside" assessment of the facility.
Weekly audits were conducted I
by personnel from the health-safety group.
The inspector also 4
reviewed the procedure which was used to provide-guidence for conducting the audits.
Procedure No. AS-1125 Health-Safety Audits, Revision No. 8, dated February 11, 1988, outlines the steps to be folicwed in completing quarterly and weekly audits,- and daily inspections.
However, the procedure appeared to lack sufficient guidance to ensure that all aspects of the radiation protection i
program are audited at a specified frequency, i.e. annually, 7
biennially, etc.
The licensee agreed to review the procedure for adequacy and revise it if necessary.
The quarterly and weekly audits were being performed as required and various deficiencies had been identified as-a result. - The inspector i
reviewed the deficiencies outlined and the corrective actions taken.
It was noted that there was no fonnal follow-up system established to ensure that the corrective actions to be taken by the affected supervisors or managers were actually completed.
The licensee indicated that these actions had been informally tracked by the Health Physicist in the past and that all issues had baen closed.
The weekly audits, on the other hand, were formatted such that the corrective actions were required to be completed before the audit form could be closed out.
c.
Health Physics Procedures During the inspection, the inspector reviewed numerous licensee Health Physics or radiation protection procedures.
While some procedures appeared to be adequate, most appeared to be general in na ture.
They contained only broad guidelines with few specific limits concerning airborne or radiation levels that should not be
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l-exceeded.
Also, they generally did not contain job-related I
instructions such as how to perform an operation.
Although most of the licensee's HP technicians have worked at the facility for a number of years and have a great deal of experience with the problems associated with fuel handling and assembly, new personnel would not-i I
have that knowledge or experience.
Through discussions with licensee-l representatives, they indicated that they were aware of ~the potential I
problemc with the prc:cdures and were. already in the process-of I
revising them.
No violations or deviations were identified.
3.
External Exposure Control (83822) a.
Exposure Data l
10 CFR 20.101 and 20.102 requires each licensee' to maintain. workers' 4
doses below specified levels.
Through review of the 1989 exposure data,-the inspector verified that-the doses received by radiation workers at the facility were generally 1cw and that most' indiviouals received less than 100 millirem (mrem).
The highest dose of anyone working at the facility was received by an individual in the field services group. 'This' l
worker had a total dose of.1,819 mrem for 1989.- The dose was due to the fact that field service personnel are. dispatched.to various power.
reactor sites and perform such jobs as steam generator and fuel' pool work.
Of those production workers receiving more than 100 mrem, the highest dose received was 532 mrem.
Thistdose was received by the individual who performs the final inspection of completed fuel assemblies prior to shipment.
A review of the quarterly and annual exposure totals indicated that no regulatory limits had been exceeded.
b.
Dosimetry Program i
10 CFR 20.202 requires each licensee to supply appropriate personnel.
monitoring devices to specific individuals and requires the use of such equipment.
The inspector discussed personnel monitoring with licensee l
representatives.
Licensee personnel who work in the production of fuel assemblies or who perform field service work are monitored by thennoluminescent don..oters (TLDs) supplied by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited vendor.
Production workers' dosimeters are read out on a quarterly cycle.
Licensee representatives indicated that field service personnel TLDs were being read on e quarterly cycle but will be changed to a monthly read out beginning in April. This is being done to allow more timely tracking of these individuals' doses because they generally receive
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more dose than do the fuel production workers who always rema;n at a
the facility.
1 Following an. assessment of TLD usage and doses received, the licensee has decided that certain individuals at the facility did not need to be monitored.
These are office personnel who do not perform work in a regulated area and do not routinely visit-such areas.
Area or environmental TLDs will continue to be posted in the office areas to ensure that no dose above ' background is received-by these individuals.
c.
Extremity Exposure The inspector reviewed selected quarterly extremity exposure 'results -
for personnel working at the pellet loading station, and at the~
pellet weighing,- the peilet inspection, the fuel bundle' inspection, 1
the fuel bundle cleaning. the fuel rod gamma scanning, the fuel rod second weld, and the fuel bundle final inspection stations.
The calculated quarterly totals were well below the regulatory limits for-exposure to the extremities.
d.
Records Review l
10 CFR 20.405 and 20.409 require each licensee to issue reports l
concerning overexposures and to issue reports to - personnel upon termination of employment or work.-
The inspector reviewed selected dose records to verify that reports were being issued concerning any suspected overexposures and that I
reports were being issued within the time allotted to personnel who l
had terminated employment.
The licensee indicated that no potential overexposures had been investigated or reported-during the time period since the previous NRC inspection.
The' inspector verified that no reports had been issued on overexposures and that reports were being transmitted to individuals who had' terminated employment at the facility within the time frame required by the regulations.
No violations or deviations were identified.
4.
Internal Exposure Control (83822) a.
Exposure Evaluations 10 CFR 20.103 (a)(1) requires that the quantity of radioactive-material inhaled by an individual be limited to 520 MPC-hrs per calendar quarter as determined using concentrations of radioactive material in air specified in Appendix B, Table I, Column 1.
The licensee's Quarterly MPC-Hour Assignment Records for 1989 were reviewed.
These included daily, seven day cumulati entar.n# quarter 4%
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i cumulative exposure totals for each individual who was monitored.
The inspector noted that, for the first three quarters of 1989, the highest daily total was 7.71 MPC-hrs and the highest quarterly total was 24.41 MPC-hrs.
However, some of the fourth quarter. exposure totals were significantly higher.
The inspector noted that during the fourth quarter one individual who had been working in the SERF area had received an assignment of 11.72 MPC-hrs during a one day period.
When asked about the circumstances' surrounding this exposure, the licensee indicated that-they-would investigate the incident.
After reviewing -the case,- the licensee determined that there had been a computational error made and that I
the MPC-hrs reported were incorrect.
Upon further investigation, the i
licensee found that, when the SERF area was fortcally established 'in December 1989 and an air sampling -program set up. the air samples were to be analyzed for the presence of both byproduct isotopes (beta-gamma) and uranium _(alpha).
The computer. program,. which was established to-calculate the MPC-hrs, inadvertently used the uranium Maximum Permissible Concentrations- (MPCs) to calculate both MPC-hr-totals.
Therefore, the uranium MPC of IE-10 microcuries - per milliliter (uCi/ml) was used instead.of the general byproduct MPC of 9E-9 uC1/ml.
This resulted in higher than' usual MTC-hr assignments I
(11.72 being. the highest) but - the assignments wre -in the i
conservative direction.
When asked why the licensee had not noted this problem earlier.
l licensee representatives _ indicated that the Air Sample-Records -are reviewed to determine whether or not any abnormally -~high air.-
concentrations have been detected.
Following this' review, any high airborne concentrations are investigated and the MPC-hrs are reviewed as well.
Because no high airborne concentrations were ever indicated; during this time period. according to the air sample analyses,'the MPC-hr Assignment records were not reviewed in detail.
During the inspection, the licensee corrected the computer program and recalculated all the MPC-hrs that had been assigned in the SERF area since Decemher.
The inspector ~ reviewed the corrected MPC-hr Assignment Record and determined that the highest daily total for the fourth quarter of 1989 was 1.4 MPC-hrs and the highest quarterly total for the same period was 19.16 MPC-hrs.
The licensee also indicated that the MPC-hr Assignment' Record would be reviewed at the same frequency as the air sampling results and in greater detail ~ to avoid such problems in the future.
6 b.
Respiratory Protection Program The inspector verified that-the respiratory equipment used_ at the facility had been certified by the National Institute of Occupational Safety and Health (NIOSH).
The inspector also determined that the licensee was using the appropriate protection factors in assigning 1
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6 airborne exposures relative to the respiratory equipment being used.
Through review of selected individuals' records, the inspector also verified that training had been given to.those using respirators and that they were medically qualified to use the equipment.
c.
Air Sampling 10 CFR 20.103(a)(3) requires that, for purposes of determining complience with the requirements of this section, the licensee shall use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
Quarterly airborne concentration averages for 1989 were reviewed by the inspector.
These data included stationary and lapel sample results which were broken down by specific work locations.
Most stutionary sample results averaged less than one percent of the MPC for the work location and most lapel sample results averaged less than five percent of the MPC.
Part 8.2.3 of Section V of the License Application requires that, if occurrence shall be investigated.
' location and any one air sample measures 100 percent of MPC, th l
The inspector reviewed the results of the -investigations that. had
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l been performed during 1989 as a result.of apparent high airborne concentrations.
Of six investigations performed, four. involved the operation of changing out a vacuum cleaner bag.
Because-of this I
frequent recurrence of this type of problem, the records for 1988 were reviewed.
During 1988, only one investigation was performed but it dealt with change out of a vacuum cleaner bag.. When asked about this apparent continuing problem, the licensee -indicated that -
l operator technique was determined to be the root cause in these l
operations.
As a result, one individual was not allowed to change vacuum cleaner bags and the other operators were instructed on the I
proper method to perform a bag change out.
The licensee indicated that more emphasis has bl%n placed on this particular' operation by l
management and that supervisors have been instructed to watch when a vacuum cleaner bag is being changed.
Two change outs have occurred since the instruction and added attention have been provided-for this operation with no problems noted.
Although the problem: has apparently been corrected, the NRC will track this as an Inspector Follow-up Item (IFI) and it will be reviewed during a subsequent inspection (70-1201/90-02-01).
.,e d.
Bioassay Program Part 8.4.3 of Secticn V of the License Application requires that persons who routinely work in areas where there is a potential for bodily intake of radioactive materials shall be subject to
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detennination of the extent of intake and retention by analysis of excreta or body counting.
i Through discussions with licensee representatives-and review of-records, the inspector determined that the whole body counting for licensee personnel is performed by.a vendor using portable counting equipment.
The equipment is brought to the site twice a year but -
that frequency may be increasea to four times annually.
Urinalysis is performed by an offsite vendor laboratory on a quarterly basis for 4
licensee 1ersonnel.
Whole b(JP count and urinalysis results" of selected individuals-were reviewed by the inspector for_ the period from July 1989 through February 1990.
Only a limited number of results were above the specified lower' limits of detection (LLDs).
No results were noted which approached or exceeded the licensee's
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action levels.
No violations or deviations were identified.
5.
Control of Radioactive Material and Contamination a.
Labeling of Containers 10 CFR 20,203(f) requires, with certain exceptions, that containers of radioactive material bear a durable, clearly visible label-identifying-the radioactive contents. However, Part 6.3 of Section V of the License Application provides an exemption to this requirement provided that all entrances to the plant are conspicuously posted in-accordance with 10 CFR 20.203(e)(1) and the words "Any Area or Container-Within the Plant May Contain Radioactive Materials."
The inspector determined that the entrances-to-the plant were posted as required with the aforementioned words. -The containers in 'the plant were not labeled in accordance with the exemption cited above.
No violations or deviations were identified.
l b.
Posting Radiation Areas 10 CFR 20.203(b) requires the licensee to conspicuously _ post each radiation area with a sign or signs bearing the radiation caution symbol and the words:
" CAUTION, RADIATION ' AREA".
10 CFR 20.202(b)(2) defines " radiation area" as any area, accessible to personnel, in which there exists radiation, originating. in whole or in part within licensed material, at such levels that a major i
portion of the body could receive in any one hour a dose in excess of 5 millirem (mrem) or in any-5 consecutive days a dose in ' excess of 100 mrem.
During tours of the facility and yard area, the inspector noted -
I several large trailers which are used by licensee personnel ~ as support facilities when at poecr reactor sites.
A radiation level 9
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L survey around the perimeter of one of the-trailers, which was parked northwest of the main building, indicated a-general area radiation level of 3 - 4 mrem per hour (mrem /hr) at approximately 3 feet from the trailer's exterior surface.
A licensee representative indicated that the trailer was used, on occasion, to store contaminated equipment used by the' field service personnel.
The inspector noted that the area was not posted with a caution sign which would indicate that this was a radiation : area.
The licensee representative-acknowledged that it was the practice to post an area as a radiation area when radiation level readings of 2.5. mrem or greater were indicated.
The licensee subsequently erected a barrier around the entire trailer and placed radiation area signs _ on all sides.-
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The inspector informed licensee representatives that failure to post t
the area around the service support trailer as a radiation area was?
i an apparent violation of 10 CFR 20.203(b).. However, this NRC identified violation.was not' being cited because the criteria-specified in Section V.A of the NRC Enforcement Policy were satisfied (70-1201/90-02-02).
Onenon-citedviolation(NCV)wasidentified, c.
Contamination Controlled Areas l
Section V, Part 8.4.5 of the License Application establishes l
contamination levels for clean areas, change room areas, and l
controlled areas.
Through discussions with the licensee, the inspector determined that, prior to establishment of-the SERF. area, the total area under contamination controls was approximately 2,400 square feet. When the SERF area became-functional in December, another 4,000 square feet of area was added to that under contamination controls.
Operations in the SERF area include decontamination and refurbishment of contaminated equipment used at power reactor sites, other-
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decontamination activities, and training in the-proper methods of-using the various pieces of equipment used at the reactor facilities.
No violations or deviations were identified.
d.
Skin / Extremity Dose Assessment The inspector determined that two skin / extremity dose assessments had been performed during the period since the last NRC inspection.
Procedure No. AS-1139, Personnel Contamination, Decontamination, and Dose Assessment, Rev. O, dated January 22, 1990, provided guidance for completing the assessments.
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1)
Hot Particle Detected November 17, 1989 On November 17, 1989, a licensee field-service worker alarmed l-the portal monitor at the Oconee. Nuclear Power Station.while l-exiting the restricted area.
The worker had not entered a l
radiation area at the reactor site.
Subsequent; surveys performed by the Oconee station health physics staff revealed that the individual had a hot particle under the insole (" odor eater") in his left shoe.
The worker had apparently acquired l
the hot particle at CNFP while working'with radioactive material:
prior to going to the Oconee site. An interview with the worker also indicated that he had failed to perform an adequate frisk prior to exiting the work area at CNFP, The part_icle, consisting of 0.77 microcuries (uC1) of Cr-51, 0.24 uCi of Mn-54, 0.35 uCi of Fe-59, 0.05 uCi of Co-58, and 0.61 uCi of Co-60, was determined to have a beta ' dose ~ rate of 35 millirem per hour (mr/hr) and a gamma dose rate of 326 mr/hr.
Based on a total exposure time of 31.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the= licensee calculated a total dose to the extremity (left foot).of 11.37 rem.
To alleviate this problem in the future, the licensee accelerated a capital appropriation request for the purchase of a portal monitor to be 'used when exiting the-SERF area.
The e
annual radiation safety training was also revised to place special emphasis on the potential of hot particle contamination during operations in the SERF area and -on proper-frisking techniques.
2)
Hot Particle Detected February 26, 1990 On February 26, 1990, prior to entering a controlled area, a-licensee field service worker alitrmed the' portal monitor at the McGuire Nuclear Power Station.
Followup surveys by _the McGuire health physics staff indicated that. the individual had a hot particle located on the iiiside sleeve of his jacket. As in the previous instance, the worker had apparently acquired the hot particle before going to the McGuire. site while working in the SERF area loading packages of radioactive' material onto a truck.-
It was determined that this individual had not performed a personal survey prior to exiting the work area.
The particle, consisting of 6.3E-3 uCi of Cr-51, 1.74E-2 eCi of Mn-54 1.63E-3 uCi of Nb-95 1.3E-2_ uti - of Co-58, and 2.62E-2 uCi of Co-60, was determined to have a beta dose. rate of 125 mr/hr and a gamma dose rate of 14 mr/hr.
Based on a total exposure time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the licensee calculated a. total dose to the extremity of 556 millirem.
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l Because of this second occurrence, the licensee performed a l
gross smear survey (total wipe down) of the' SERF controlled'and l
uncontrolled areas.
No hot particles were detected and only. low' levels of contamination were found in the controlled areas.
The SERF change room was also surveyed with no detec. table-contamination being detected.
An adjacent area, the $2 Building I
was also surveyed and no contamination was found. The licensee l
also initiated the policy of requiring a whole body. frisk following any work in the SERF area-or any work involving
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loading or unloading radioactive. material _ associated with SERF l
operations.
Also, employees that access the SERF area during the wod Jay are required to go to the B&W Naval-Nuclear Fuel Division site (approximately one mile from the CNFP site) and pass therut h a portal monitor before going home.
The licensee l
indicated s hat the portal monitor purchased for their facility is anticip ted to be installed in April.
The inspector reviewed the skin dose. assessments performed by the licensee and determined that they were adequate.
The corrective actions, especially acquisition.of a portal monitor to be used after exiting the SERF area, appeared to be adequate.
I No violations or deviations were identified.
l 6.
Radioactive Waste Management (84850) 1 a.
Management Controls The licensee has established procedures for the packaging and i
shipping of solid radioactive wastes and radioactive scrap material which is transferred to a vendor for compaction and final disposal.
Procedure AS-1110 Waste Control, Rev.12, dated December 8,1988, and Procedure AS-1111, Shipment of Radioactive Materials, Rev. 20, dated October 16, 1989, provide guidance and. outline the responsibilities of various groups at the facility for o*perations such as container inspection, packaging, surveying, and reviewing the completed paperwork.
No violations or deviations were identified.
b.
Waste Manifests 4
10 CFR 20.311(d) requires that a shipment manifest be completed for each radioactive waste shipment sent to a licensed waste processor and that the manifest meet the requirements of Part 20.311(b) and (c) including information concerning the physical description of the waste, the volume, radionuclide identity and quantity, the principal chemical form, and the total radioactivity.
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1 Through review of the shipping records and discussions with licensee representatives, the inspector determined that only one waste i
shipment had been made in 1989.
The waste was shipped on June 15, l
1989, to Quadrex, Inc. for reprocessing.
_The waste manifest l-indicated that the waste, tyhich was contained in 67 steel drums and
? wooden box, was shipped as an exclusive use shipment.
After faraier review of the t:aste manifest, the inspector noted that the proper shipping name listed on the form was incorrect. The manifest listed the shipping name as "Rsdioactive Material, n.o.s., UN 2982"'
while the shipping papers listed the shipping name as " Radioactive Material, LSA, n.o.s., UN 2912".
The inspector also noted that_the
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waste manifest did not list any figure indicating the total redioactivity in the shipment but continuation sheets attached to the l
manifest indicated the activity contained in each package, i
Because the waste manifest did not contain all the information required by the DOT and NRC regulations, the licensee was informed that this would be considered an apparent violation of.10 CFR20.311(d)(70-1201/90-02-03).
10 CFR 71.5 requires that each licensee who transports licensed material outside the confines of its plant or other place of use comply with the applicable requirements of the D0T in 49 CFR Parts 170 through 189.
49 CFR 172.203(d)(iii) requires that the shipping papers that I
accompany the shipment of radioactive material specify the activity contained in each package of the shipment in terms of curies, millicuries, or microcuries.
Licensee Procedure AS-1111 Shipment of Radioactive Materials, Rev. 20, dated October 16, 1989, requires is Section 7.1(E) that the shipping paper must include the activity contained in each package of the shipment in terms of curies, millicuries, or microcuries.
During the review of the waste manifest, the inspector also reviewed the accorapanying shipping papers for the waste shipment. The maximum radiation level at contact with the shipping container (a Sea Van) was 5 mr/hr and the_ radiation level at 2 meters was 0.5 mr/hr, The shipment had been surveyed for alpha and beta-gamma contamination and was within the limits specified in 49 CFR 173.443.
The shipping paperwork listed the total radioactivity as 54.7 millicuries but did not list the activity contained in each package as required.
The licensee was informed that failure to list the activity contained %
each package was an apparent violation of 10 CFR 71 5 (70-1201/90-02-04).
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c.
Waste Classification and Characterization 10 CFR 61.55 requires that radioactive waste be classified and identified as Class A, B, er C.
10 CFR 61.56 requires that the waste have certain characteristics including stability.
The licensee ships only Class A-Unstable waste to the vendor for r
reprocessing and disposal..The inspector determined that the waste shipped on June 15, 1989, was properly classified and characterized.
No violations or deviations were identified.
d.
Tracking of Waste Shipments By review of the waste shipment records and the applicable shipping t
procedure, the inspector verified <that the licensee has a program in.
place for forwarding manifests to the waste processor-and for tracking shipments to assure that the. shipment was received by the processor.
No violations or deviations were identified.
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Transportation of Radioactive Materials (86740) i 10 CFR 71.5 requires that each licensee who transports licensed material l-outside the confites of its plant or other place of use comply with the applicable recuirements of the DOT in 49 CFR Parts 170 through 189.
a.
Fuel Shipments 49 CFR 173.443 requires that the.non-fixed (removable)' radioactive-l contamination on the external surfaces of each package offered for i
snipment must be below specified levels.
The maximum permissible limit for oeta-gamma contamination is 2200 disintegrations per minute per 100 square centimeters (dpm/100 cm2).
The a;ximum for alpha contamination is 220 dpm/100 cm2 Under certain conditions, thes.'
levels may be increased by _a factor of ten.
The inspector reviewed the shipping paperwork associated with two fuel shipments.
One shipment, Bill of Lading Number (B/L No.) 01201, shipped on October 12, 1989, was composed of 6 steel containers which contained enriched uranium in a solid form as uranium dioxide pellets.
The shipment was a Radioactive Material III, Fissile Class II shipment and each container had a transport index (TI) of 6.3.
The second shipment, B/L No. 01253, was shipped on January 11, 1990, and consisted of 6 steel containers as well.
The containers were filled with the same type of material and' had the same radioactive material and fissile classification as the previous shipment.
a N
e
?
13 In reviewing the surveys that had been conducted on the outgoing.
shipments, the inspector noted that no beta-gamma contamination-surveys had been performed for either shipment.
The licensee indicated that beta-gamma contamination _ surveys are not routinely
-j performed for fuel shipments. The licensee was informed that failure to perform beta-gama contamination surveys on the external surfaces l
of each package offered-for shipment M an apparent violation of 10CFR71.5(70-1021/90-02-05),
b.
Empty Uranium Hexafluoride (UF6) Cylinder Shipments 49 CFR 173.427(c) requires that-internal contamination levels of empty-containers not exceed 100 times the limits specified in-1 173.443.
49 CFR 173.427(e) provides that empty radioactive materials packages are excepted from the shipping paper and certification, marking, and labeling requirements of this subchapter (referring to 49 CFR 172.203) provided that the package is prepared for shipment as I
specified in 173.421-1.
~
49 CFR 173.421-1(a) requires that excepted radioactive materials -
packages prepared for shipment-under the provisions of 173.i?7 (empty packages) must be certified as being acceptable for transportation by having a notice enclosed in or on the package, included with the
_l packing list, or otherwise forwarded with the package. -The notice must include the name of the consignor or consignee and the statement "This package conforms to the conditions and-limitations specified in 49 CFR 173.427 for excepted radioactive material, empty packages, UN2908."
The in:pector reviewed the shipping paperwork' associated with five shipments of empty UF6 cylinders shipped - on June -12,1989.
The shipments, B/L No. 56742, 56746, 56747,. 56748, and. 56749, each consitted of 3 empty cylinders except for 56749 which consisted of-only 2 empty cylinders.
The paperwork indicated that all cylinders last contained UF6 but there.was no statement verifying that the empty cylinders conformed to the conditions and limitations specified.
in 173.427 as required in 49 CFR 173.421-1.
It was also noted that no surveys of the internals of the cylinders had been performed. B/L No. 56749 also indicated that 3 cylinders were shipped but only 2 cylinder identification numbers were listed and only 2 cylinder '
surveys and other pertinent information were included with the shipping paperwork.
During discussions with the licensee concerning the empty cylinder snipments, licensee representatives indicated that these cylinders had been received from C0GEMA, Inc.
This company had performed-maintenance on the cylinders including washing the insides.
COGEMA v
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2 l
14 4
l had forwarded the " Washing Certificates" for each cylinder to the licensee and these were provided to the inspector for review. -
3 Although the certificates indicated that each container had been washed and was " free of UF6." only radiation level survey results were listed on the forms.
The licensee was informed that failure to survey the insides-of any of the cylinders ard failure to include on the shipping papers the-proper statement verifying that the empty packages conformed to the specified limitations, were further examples of an apparent violation i
of10CFR71.5-(70-1201/90-02-06).~
49 CFR 173.475 requires that before each shipment of any radioactive material package, the shipper shall ensure by appropriate test that the external radiation and contaminMion levels are within allowable limits.
49 CFR 173.443 requires that the non-fixed (removable) radioactive contamination on the external surfaces of each package offered for shipment must be below specified levels.
The maximum permissible r
limit for beta-gamma contaniination is 2200 dpm/100 cm. The maximum-for alpha contamination is 220 dpm/100 cm.
Under certain r
conditions, these levels may be increased by a factor of tu.
A review of the paperwork associated with the five shipments of empty UF6 cylinders also indicated that each container surveyed had a radiation level at contact eith the cylinder of less than 0.1 mr/hr and alpha contamination levels of less than 100 dpm/50 cm8 as i
measured by direct scan of the cylinders.
The inspector noted; I
however, that according to the surveys that had been performed, one l
cylinder (No. 6918) had not-been surveyed.for radiation or contamination levels.
The licensee was informed that failure to perform radiation and contamination level surveys on one cylinder would be considered as l
another example of an apparent violation of 10 CFR 71.5 (70-1201/90-02-05).
c.
Field Service Equipment Shipments and Receipts l
49 CFR 172.203(d)(11) requires that a description of the physical and chemical form of the material being shipped be ind :ded on the l
l shipping paperwork.
The inspector reviewed selected shipping paperwork associated with the shipment and receipt of equipment used by the licensee at various power reactor sites.
The shipment with B/L No. 56752, shipped on March 2,1990, consisted of pressurized drilling twin towers which were shipped to a reactor site.
The inspector noted that both beta-gamma and alpha contamination survey results were listed for this shipment.
The shipment included most of the required
15 l
I information but did not specify ti,e physical form of the radionuclides.
The chemical form was listed as metal oxides.
The licensee was inft,rmed that failure to specify the physical form -on
)
the shipping pa erwork was another example of an apparent violation of 10 CFR 71.5 70-1201/90-02-04).
8.
LicenseeActionofInspectorFollowupItems(92701) a L
a.
(Closed)IFI 89-07-01: Prepare a f
i Procedure to Control Welding and Burning The inspector reviewed a new procedure which had beers written by the licensee to control welding and burning activities.
The procedure, AS-1138, Ignition Source Permits, Rev. O, dated October 24, 1989, appeared to be adequate.
b.
(0 pen) IFI 89-07-02:
Complete Construction of 'a Chemical Storage Facility Through discussions with licensee representatives, the inspector l
determined that this facility had not been constructed to date.
The licensee indicated, = however, that capital appropriations had been made and would become available during the first quarter of their '
fiscal year (beginning in April).
The licensee expected to start construction sometime during the first quarter of their fiscal year.
9.
Exit Interview The inspection scope and findings were summarized on March 8,1990, with those persons indicated in Paragraph I above. - Subsequent inspection.
findincjs were summarized and discussed with the facility Health Physicist and the Plant Manager on March 9, 1990.
The inspector described the areas-inspected and discussed in detail the inspection findings. The problem in i
calculating MPC-hrs assigned to individuals working in the SERF area was discussed.
The item of investigations of problems resulting from apparent high airborne concentrations and the licensee's corrective actions was also discussed.
The apparent generality of HP procedures was also discussed. The apparent violations were reviewed as well:
- 1) an apparent NCV for failure to post a radiation area around a service equipment-trailer, 2) failure to include all required information un-a waste manifest, and 3) various examples of failure to comply with DOT requirements for shipping radioactive material.-
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during the -inspection.-
The licensee acknowledged the inspector's comments and had no dissenting comments. The licensee was informed that one item discussed in. Paragraph 8 was considered closed while the item concerning construction of a chemical storage facility would remain open.
~
o 16 Item Number Description and Reference-70-1201/90-02-01 IFI: Review the licensee's corrective actions-following apparent high airborne concentrations during vacuumcleanerbagchangeout(Paragraph 4).
70-1201/90-02-02 NCV:
Failure to post a radiation area outside of the main building in the vicinity of a service equipment trailer (Paragraph 5).
70-1201/90-02-03 VIO:
Failure to comply with 10 CFR 20,311(d) requirements for including the total radioactivity.in the shipment on the accompanying-waste _ manifest (Paragraph 6).
70-1201/90-02-04 VIO:
Failure to provide adequate information required on shipping papers (Paragraphs 6 end 7).
70-1201/90-02-05 VIO:
Failure to survey the external. surfaces of one empty UF6 cylinder for radiation or contamination levels and the containers of two fuel shipments for beta-ganina contamination levels (Paragraph 7).
70-1202/90-02-06 VIO:
Failure to survey the internal surfaces of any of the UF6 cylinders in five shipments and failure to include a statement on the shipping papers for the cylinders verifying that the cylinders were in compliance with-specified limits for empty packages (Paragraph 7).
l i
1
4, pt
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- si
-4;r Interactions-Beyond Fiscal Year 1990 Interaction Type.
Scenario Development and; construction LTechnicall Exchange
_ o ;a _ Comp ementary Cumulative l Distri-f l
_ bution~ Function -
Natural Resources Technica1' Exchange Radionuclide Retardation Testing:and <
-Technical Meeting /
Technical 1 Exchange Modelling 4
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