ML20056G871
| ML20056G871 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/24/1993 |
| From: | Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20056G865 | List: |
| References | |
| 70-1151-93-05, 70-1151-93-5, NUDOCS 9309070256 | |
| Download: ML20056G871 (8) | |
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UNITED STATES l
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NUCLEAR REGULATORY COMMISSION p '4 REGION 11 S
101 MARIETTA STREET, N.W., SUITE 2900 y
ATLANTA, GEORGIA 30323-0199 2...*
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Report'No.:- 70-1151/93-05 Licensee:_ Westinghouse Electric Corporation i
Commercial Nuclear fuel Division l
' Columbia, SC 29250 j
Docket No.: 70-1151_
License No.:
SNM-Il07 j
Fr.ility Name: Columbia Nuclear Fuel Plant j
Inspection Conducted: Duly 26-30,1993 Inspector: Nm Mh h
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E. D. Testa P.E.
Date $igned 24 !9 3-Approved by W. H. Rankin, Chief
/DatifSigned i
Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
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Scope:
This routine, unannounced inspection was conducted in the area of occupational radiation safety and included an examination of:
procedures, instruments, equipment, external exposure control, control of radioactive materials and l
contamination, surveys and monitoring, notifications and reports, and maintaining exposure ALARA. Also, the inspection involved followup and review of the violations identified during the previous Inspection Report i
'(IR) 70-1151/93-02 conducted during the period March 1-5, 1993.
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Results:
The radiation protection (RP) program functioned adequately to protect the health of occupational radiation workers and to promote the safe use of l
radioactive material. Management and staff were actively involved in methods and activities to reduce personnel exposure. The respiratory protection program was functioning adequately to protect workers in airborne l
radioactivity areas. Housekeeping was observed to be functioning effectively.
One Non-cited Violation (NCV) dealing with failure to post Form NRC-3,
" Notice to Employees," was identified during the inspection.
Licensee
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actions from two previous violations were reviewed and these items were also
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closed as a result of this inspection (70-1151/93-02-02, 70-1151/93-02-03) l-N fs2 l
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f (Paragraphs 10 a. and b.).
Licensee actions on two previous IFIs were reviewed and these items were closed (70-1151/93-02-04, 70-1151/93-02-05)
(Paragraphs 9 a. and b.).
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l REPORT DETAILS l
1.
Persons Contacted l
Licensee Employees l
- J. Berry, Manager, Pellet and Rod Manufacturing
- D. Goldbach, Jr., Manager, Chemical Process Engineering
- W. Goodwin, Manager, Regulatory Affairs
- J. Heath, Manager, Regulatory Operations l
- E. Keelen, Manager, Fuel Manufacturing
- G. La Bruyere, Manager, Conversion Services
- R. Likes, Regulatory Engineer
- S. Mcdonald, Technical Services Manager l
- E. Reitler, Manager, Regulatory Engineering i
- B. Smith, Supervisor, Maintenance
- W. Ward,. Manager, Uranium Recycle and Recovery 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 July 30, 1993 2.
Organization and Management Controls (83822)
The inspector reviewed changes made to the licensee's organization, staffing levels, and lines of authority as they related to radiation protection, and verified that the changes had not adversely affected the licensee's ability to ccntrol radiation exposures or radioactivity.
l The inspector was inforced that Regulatory Engineering (RE) was fully staffed and that no significant changes had been made to the group since the last inspection condacted March 1-5, 1993, and documented in Inspection Report (IR) 70-1151/93-02.
No violations or deviations were identified.
3.
External Exposure Control (83822) 10 CFR 20.101(a) requires that no licensee possess, use, or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter a total l
occupational dose in excess of 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads, and 18.75 rem to the hands and forearms, feet, and ankles.
10 CFR 20.202(a) requires each licensee to supply appropriate personnel monitoring equipment and requires the use of such equipment by each individual entering a restricted area under such circumstances that he l
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2 receives or is likely to receive, a dose in any calendar quarter in
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excess of 25 percent of the applicable value specified in 10 CFR 20.101(a).
10 CFR 20.202(b) defines personr,c1 monitoring j
equipment as devices designed to be worn or carried by an individual for the_ purpose of measuring the dose received.
i The inspector selectively reviewed and discussed external exposure programs, both extremity and whole body monitoring, for personnel i
involved in selected chemical and mechanical manufacturing area i
activities. ' Procedural changes, continuing monitoring efforts, and j
extremity dose reduction efforts were reviewed'in detail. The inspector l
reviewed changes and enhancements made to the external exposure control program since the previous inspection conducted March 1-5, 1993, and i
documented in IR 93-02. The inspector noted that the Thermoluminescent Dosimeters (TLDs) used to measure exposure were NVLAP accredited.
j a.
Extremity Monitoring Program j
The' inspector reviewed first-and second quarter extremity dose j
records.
The inspector determined that procedural guidance, j
l monitoring efforts and continuing exploration of ALARA initiatives were adequate and that the current extremity monitoring program was appropriate-to evaluate extremity exposure and to verify i
applicable _ license compliance.
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No violations or deviations were identified.
l b.
Whole Body Exposure l
l The inspector selectively reviewed the first and second quarter whole body dose records for employees working in process areas.
j Based on a review of the selected records and procedures, the inspector concluded that the licensee monitored whole body doses adequately, performed necessary investigations and assigned doses appropriately.
l No violations or deviations were identified.
4.
Internal Exposure Control (83822) l
.10 CFR 20.103(a)(1) states that no licensee shall possess, use, or i
- transfer licensed material in such a manner as to permit any individual
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in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would i
L result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
10 CFR 20.103(a)(3) requires for purposes of determining compliance with the requirements of this section, the licensee to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and e,
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3 in addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakas of radioactivity by exposed individuals.
l The inspector selectively reviewed implementation of selected areas of l
the licensee's air sampling, lung burden analysis, urinalysis, and i
respiratory protection programs. All values were small percentages of regulatory limits..
a.
Lung Burden Analysis Program The inspector selectively reviewed the 1993 results of the lung burden analysis program. All doses were small percentages of regulatory limits.
i No violations or deviations were identified.
b.
Internal Dose Assessment i
The inspector reviewed the results of the licensee's dose assessment from lung counting, fecal, and the urinalysis program.
All doses were small percentages of regulatory limits.
i No violations or deviations were identified.
5.
Radiation Controls (83822) a.
Survey 10 CFR 20.201(b) requires eech 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 radioactive hazards that may be present.
The inspector reviewed selected records of radiation and contamination surveys performed during the first and second quarters of 1993, and discussed the survey results with licensee representatives. The inspector verified that selected alpha contamination surveys were performed weekly in the controlled process area and radiation surveys were performed monthly as prescribed by procedures. The inspector also noted that survey results were below those action limits as specified by the applicable procedures.
The inspector independently verified contamination surveys by selectively sampling 56 locations including eating areas, step off pads, the Health Physics (HP) counting room NH tank area, Truck 3
Well 4, shop and tool storage area, vacuum cleaners, selected
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I equipment carts, and seven trailers of GE fuel stored onsite.
j Results of these independent surveys indicated that contamination
-levels met the alpha activity. control level of Table 3.2.5.1 of
- Section 3.2.5.1 of the License application..
No violations or deviations were identified.
b.
Instrumentation i
Section 3.2.1.2 of the License Application states that instruments require calibration following acquisition, and thereafter at least I
following major. repairs or semiannually, whichever occurs first.
The inspector verified that survey instruments at the main entrance / exit to the chemical manufacturing area (CMA) and at the step off pad of various egress points to the CMA were in calibration. The inspector noted that these instruments were also l
source checked by HP. The inspector also verified that the alpha counting systems in the HP lab were calibrated in accordance with j
the License Application..
j No violations or deviations were identified.
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- 6..
Audits'(83822)
Section 3.1.2.3'(7) of the License Application states that audits of licensed activities for compliance with applicable State and Federal regulations, licenses ands permits will be performed and that
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' documentation'of these audits ~will be used to facilitate corrective actions.
j Procedure RA-102 titled, " Plant Inspections Program for Regulatory Compliance," Revision.2, dated May 4, 1990, defines the program, schedule and inspections checklist for the Regulatory Affairs criticality safety, radiation protection, Special Nuclear Material safeguards, safety and fire prevention plan.
The inspector selectively reviewed'the HP aspects of the following audits-Regulatory Inspection Report - March 1993 Regulatory Inspection Report - April 1993 Regulatory Inspection Report -
May 1993 Regulatory Inspection Report - June 1993 l
The_ inspector accompanied an inspection team in the process area on July 29,1993 using a checklist from the procedure.
No major health or safety issues were observed during the July 29, 1993 accompaniment.
5 The inspector found the reports to be detailed, probing, and conducted j
by knowledgeable and technically qualified licensee personnel.
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No violations or deviations were identified.
l 7.
Regulatory Compliance Committee and ALARA Responsibilities (83822) t i
Section 3.1.2.5 of the license states.that the Regulatory Compliance Committee (RCC) shall be that organizational component of the licensed activity responsible for overall coordination of licensing, compliance, regulatory and radiation protection matters, and for developing policies and procedures relating to the use and storage of special nuclear materials.. Special responsibilities shall include:-
a.
Review and Assessment of the ALARA Programs The' inspector reviewed the ALARA Report for the period July I to December. 31, 1992..The following are selected major items and their trends.
The ADU Conversion Area experienced a downward trend over the last five years in airborne concentrations of r
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- 0.45 percent MPC/Qtr.
MAP experienced a' downward trend over the last two years in airborne concentrations of -0.82 percent MPC/Qtr.
The ADU Pellet Area experienced a downward trend over the a.
last two years in airborne concentrations of -0.80 percent MPC/Qtr.
Maintenance experienced an increasing exposure trend over the last two years of 1,49 MPC-Hrs /Qtr.
There were no statistically significant trends in urinalyses results.
MAP experienced a downward trend over the last two years in whole body dose of -4.85 mrem /Qtr.
Final inspection experienced an upward trend over the last two years in external skin dose of +8.82 mrem /Qtr.
All averages remain well below regulatory limits.
No violations or deviations were identified.
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6 b.
Regulatory Compliance Committee Membership The meeting shall be chaired by a qualified individual selected by the Plant Manager, and its membership shall consist of the Manager of the Radiation Protection Component and at least three other j
management personnel who are qualified to evQate plant operations from the ALARA' standpoint. The committee shall convene t
at least quarterly on a' routine basis, following-any major radiation incident, and when otherwise warranted by circumstances.
The committee's findings, conclusions and recommendations shall be i
reported directly-to the Plant Manager following each meeting.
l Appropriate action shall be taken, as required, to maintain and demonstrate compl_iance with ALARA regulatory requirements.
The inspector reviewed the meeting minutes from the following dates:
February 25, 1993, June 7, 1993, and June 22, 1993.
l The meeting minutes were found complete and addressed all areas of f
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_ special responsibilities and the individuals found qualified.
No violations or deviations were identified.
8.
Facility. Tours.(83822) a.
Notice to Employees 10 CFR 19.ll(a) and (b) require, in part, that the licensee post current copies of Part 19, Part 20, the license, license i
conditions,. documents incorporated into the license, license l
amendments and operating procedures, or that a licensee post a l
notice describing these documents and where they may be examined.
i 10 CFR 19.11(d) requires that a licensee post Form NRC-3, " Notice to Employees." Sufficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or from licensed activity locations.
During the onsite inspection, the inspector found that two of i
three copies of Form NRC-3 and notices referencing the appropriate 10 CFR Part 19 and Part 20 and licensee documents were not posted
.in accordance with the applicable regulation. The licensee immediately reposted the NRC Form-3 in the two missing locations.
This was identified as a violation of 10 ( A 19.ll(d). This NRC identified violation is not being cited because criteria specified in Section VII.B. of the NRC Enforcement Policy were satisified.
Non-cited. violation (NCV) 70-1151/93-05-01:
Failure to post copies of Form NRC-3, " Notice to Employees," as required by 10 CFR 19.11(d).
One NRC identified NCV and no deviations wert identified.
7 b.
Tours of Facilities Section 3.2.2.4 of the License Application requires each entrance or access point to the Controlled Access Area (CAA) be posted in accordance with 10 CFR 20.203, except for 20.203(f).
In lieu thereof, a sign bearing the legend "Every container or vessel in this area may contain radioactive material," shall be posted at entrances to each area in which radioactive materials are processed, used, or stored.
During routine tours and observations of the facility, the inspector noted that in-plant areas as well as areas outside the facility were generally clean and orderly. The inspector also observed individuals wearing protective clothing and dosimetry as required by procedures. The inspector observed that one worker in the UF, Gas Cylinder Recertification Area and several workers in the shop maintenance area may handle potentially contaminated objects and tools without hand protection. Although a limited review of invivo counting and bioassay results show no apparent statistical increase in internal uptakes, this appears to be a questionable work practice. The licensee agreed to review these work practices. The licensee was informed that this item will be tracked as an Inspector Followup Item (IFI).
IFI 70-1151/93-05-02:
Questionable HP practices while handling potentially contaminated tools in the UF, gas cylinder recertification area and tools in the shop maintenance area.
No violations or deviations were identified.
9.
Licensee Actions on Previous Inspection Findings a.
(Closed) IFI 70-1151/93-02-04: The inspector reviewed the script to be used in employee training and the periodic supervisory check of employees to determine if jewelry has been worn in the manufacturing area. The inspector found the licensee's actions acceptable.
The licensee was informed that this item would be considered closed.
b.
(Closed) IFI 70-1151/93-02-05: The inspector toured the facility and independently verified the removal of "old" compressed gas breather air supply bottles.
The licensee was informed that this item would be considered closed.
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8 10.
' Licensee Actions Regarding Previous Enforcement Items
-a.
(Closed) 70-1151/93-02-02: The inspector reviewed the Reply to a Notice ~of Violation dated May 28, 1993..The inspector independently verified the licensee actions to correct th violation and prevent its recurrence. Throuot tours and, elective i
-independent' surveys and contamination smears and their measurements (Paragraphs 6 and.8.b), the inspector determined that the licensee's. actions were appropriate.
The licensee was informed that this item would be considered closed.
i b.
(Closed) IFI.70-1151/93-02-03: The inspector reviewed the Reply l
to a Notice of Violation dated May 28, 1993. The inspector independently verified the licensee actions to correct the violation and prevent the recurrence. The inspector selectively reviewed audit reports and accompanied an audit team and determined that the licensee corrective actions were appropriate (Paragraph 6).
-The licensee was informed that this item would be considered' closed.
11.
Exit Meeting
.The inspector' met with licensee representatives indicated in Paragraph I at the conclusion of the inspection on July 30, 1993. The inspector l
summarized the scope and findings of the inspectior.
The inspector L.
informed licensee representatives that, although proprietary information was reviewed during this inspection. such material would not be included in the report.
Item Number Description and Reference 70-1151/93-05-01 NCV - Failure to post copies of Form NRC-3 " Notice to Employees" as l.
required by 10 CFR 19.ll(d) l (Paragraph 8.a).
70-1151/93-05-02_
IFI - Questionable HP practice while handling potentially contaminated tools in I
the UF, gas cylinder recertification area and tools in the shop maintenance area (Paragraph 8.b).
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