ML20057E584
| ML20057E584 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 09/28/1993 |
| From: | Pharr E, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E573 | List: |
| References | |
| 70-1201-93-03, 70-1201-93-3, NUDOCS 9310120319 | |
| Download: ML20057E584 (15) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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[*2 REGloN ll 101 MARIETTA STREET, N.W., SUITE 2900 7,,
'. p ATLANTA. GEORGIA 30323-0199 k%.. "/
SEP 2 31993 Report No.: 70-1201/93-03 Licensee:
Babcock and Wilcox Fuel Company Commercial Nuclear Fuel Plant Lynchburg, VA 24505 Docket No.: 70-1201 License No.: SNM-1168 Facility Name: Commercial Nuclear Fuel Plant Inspection Conduc,ted:'Augdst 30,
, September 2, 1993 f
2'tb Inspector:
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Uate Signed A(l i
E. B.'Pharr i Approved by: '-(
h wb j g h8 W. H. Rankin, Chief' ate Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
r Scope:
This routine, unannounced inspection was conducted in the area of occupational radiation safety and included an examination of: organization and staffing, audits, radiation protection training, procedures, external exposure control, internal exposure control, control of radioactive materials, and surveys and monitoring.
In addition, licensee responses to previously identified inspection findings were reviewed.
Results:
The radiation protection (RP) program functioned adequately to protect the health of occupational radiation workers and to promote the safe use of 7
o radioactive materials. The organization and staffing within the safety and licensing group continued to be appropriate, eventhough one staff member was l
lost during a recent reduction in force.
Audits and Safety Review Board meetings were conducted as required by procedures and the License Application.
The licensee's program for providing radiation protection training had These undergone changes since the previous inspection of the RP program.
changes, as well as implementation of the Health Physics Information Management System (HPIMS), appeared to have been beneficial in better organizing and streamlining the licensee's training program. The inspector noted that the training material appeared to be appropriate for the level of work performed by licensee employees. All external and internal exposures 1
9310120319 930929
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{DR ADOCK 07001201 PDR j
we're within 10 CFR Part 20 limits. Radiation and contamination surveys were f
- performed appropriately and Radiation Work Permits (RWPs) contained appropriate health physics controls and incorporated ALARA awareness.
Based on licensee corrective actions and subsequent program implementation, two i
previously identified open items were closed.
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REPORT DETAILS i
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Persons Contacted 1
Licensee Employees
- T.
Ford, Director, CIP
- R. Gardner, Manager, Quality
- D. Gordon, Senior Health Physicist
- K. Knapp, Manager, Safety and Licensing L. Morrell, Compliance Officer
- G. Lindsey, Health Physicist
- R. Penoza, Manager, Field Services D. Sullivan, Supervisor, SERF-3 Other licensee employees contacted included engineers, technicians, and office personnel.
- Attended September 2, 1993 exit meeting 2.
Organization and Staffing (83822)
The inspector reviewed changes made to the licensee's Health-Safety organization and staffing levels since the previous inspection conducted September 21-25, 1992 and documented in Inspection Report (IR) 70-1201/92-06. The inspector noted that since this previous inspection the position of Health-Safety Foreman had been retitled so as to create another Health Physicist position within the section. The inspector also noted that the position of Industrial Safety and Environmental Control Officer, as well as the staff member which had previously held i
the position, had been relinquished.
In addition, the previous i
dosimetry clerk had assumed the newly created position of Compliance.
Officer.
Following these organizational changes the Health-Safety Section was comprised of a. Senior Health Physicist, a Health Physicist, l
and the Compliance Officer, which reported tirectly to the Safety and Licensing Manager. Additionally, five Health-Safety Monitors reported directly to the Health Physicist, the former Health-Safety Foreman.
During discussions with licensee personnel the inspector was informed that although the Health Physicist title was new, the position continued to te accountable for the responsibilities of the former Health-Safety Foreman.
The inspector was also informed that the Compliance Officer had assumed many of the responsibilities of the former Industrial Safety-and Environmental Control Officer. Those duties not assumed by the l
Compliance Officer had been delegated to the other staff members within.
l the Safety and Licensing organization.
Based on the inspector's review.
1 of licensee activities and daily operations, the inspector determined j
that the Health-Safety Section was adequately staffed and provided for appropriate oversight of licensed activities.
The inspector further noted that the licensee had recently implemented i
use of a Health Physics Information Management System (HPIMS). The inspector noted that presently the system was mainly used for access l
control purposes, but was planned to be extended to broadscope use j
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throughout the Health-Safety function.
The inspector was informed that the licensee was presently using the HPIMS to verify that workers entering Radiation Work Permit (RWP) areas were qualified to do so.
The HPIMS allowed personnel access for specific RWP Job classifications provided the worker's required training, bioassay, dosimetry, and respirator qualifications were complete and current. The inspector noted that the HPIMS appeared to have to been beneficial in providing for better organization and streamlining of personnel records and subsequent verification of personnel qualifications to provide enhanced access controls.
No violations or deviations were identified.
3.
Audits and Appraisals (83822)
Section 2.3 of the License Application delineates Safety Review Board members and requires the Board to meet at least quarterly.
During quarterly meetings the Board is required to review new or revised facilities, effectiveness of established controls, maintenance of ALARA criteria, as well as safety-related audit and inspection findings.
The inspector reviewed minutes from Safety Review Board meetings i
conducted since January 1, 1993.
Specifically, the inspector reviewed minutes from the March 16. May 6, and July 27, 1993 meetings. The inspector verified that the Board was meeting at least quarterly and that the meetings were appropriately attended by a quorum of supervisory personnel, as required by the License Application. The inspector further noted that, as required by the License Application, the Board reviewed facility projects, new and revised f acilities, procedural l
changes, audit findings, quarterly and annual ALARA tracking and trendings, occupational safety experience, and action items, which were r
then assigned to a responsible manager for completion.
The inspector also reviewed the 1992 Annual ALARA Report and first and second quarter 1993 ALARA Reports, as performed by the Health Physicist, and noted that the reports trended the year's exposure and monitoring data, and recognized and provided explanation for maximum or outlying data.
Section 2.7 of the License Application requires that an independent auditor conduct, as a minimum, semiannual nuclear safety, fire safety, and health physics inspections to consist of physical inspections and records reviews for the industrial, nuclear, and radiological safety elements of plant activities.
The inspector reviewed the semiannual Health Physics (HP) audit as performed by a health physicist from the Babcock and Wilcox Naval Nuclear Fuel Plant. The inspector noted that the independent auditor appeared qualified to perform the audit based on his educational background and operating experience at a fuel fabrication facility. The inspector reviewed the subject audit, HS-93-02, conducted June 23, 1993, 4
and noted that the auditor performed a review of the Employee Safety i
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3 Training program.
Identified deficiencies were reviewed by an i
appropriate level of plant management, with appropriate corrective actions being identified and implemented by the Health-Safety group.
i The inspector also reviewed audits which, although were not formally required by licensee procedure or the License Application, were performed periodically by the licensee's Senior Health Physicist. The inspector noted that the audits routinely included reviews of RWP compliance, housekeeping, storage of radioactive materials, posting, labeling, and work practices. Deficiencies identified during these plant tours required a response, regarding causal factors and corrective actions, by the responsible area manager. These responses were required i
to be submitted within a specified time period, usually 30 days, and
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were then reviewed and reaudited for closure by the Senior Health Physicist. The inspector also noted that, rather than a plant tour to review housekeeping, the most recent audit evaluated Health-Safety Monitor compliance with the procedure for preparation of the quarterly spiked urine sample. Deficiencies identified during this audit were also assigned to a responsible individual for completion of corrective actions. The inspector was informed that these audits, as performed by the Senior Health Physicist, would likely continue to review specific job evolutions for procedural or RWP compliance, as well as periodic i
plant tours.
The inspector noted that audits and meetings were conducted as required by the License Application. The inspector also noted that these auditing and self-assessment programs appeared to be beneficial in maintaining the overall effectiveness of the Health-Safety program.
t No violations or deviations were identified.
4.
Training (83822) 10 CFR 19.12 requit es the licensee to instruct all individuals working in or frequenting ariy portions of the restricted areas in the health i
protection aspects associated with exposure to radioactive material or l
radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of the Commission Regulations, individuals responsibilities, and the availability of radiation exposure data.
j The inspector reviewed the licensee's training procedure, AS-1101, i
Employee Safety Training, dated June 12, 1992, course outlines and examinations, and selected employees training records. The inspector i
noted that all site employees received initial General Employee Training i
(GET), and those employees which worked with radioactive materials also received Radiation Worker Training (RWT).
For those employees which also routinely entered Radiation Controlled Areas (RCAs) to perform their work activities, Controlled Area Access Training (CAAT) was required in addition to GET and RWT.
During a previous inspection conducted September 21-25, 1992 and documented in Inspection Report (IR) l 92-06, the inspector noted that the licensee had taken initiatives to i
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4 improve the training program. These positive initiatives included revising the training procedure, implementing a written and practical examination for RWT and CAAT, and improving maintenance of training records. The inspector noted that since that inspection the licensee had continued with efforts to further improve the training program and had focused attention on the training program during audits and Safety Review Board meetings.
Since the previous inspection, the inspector noted that the licensee had developed an Employee Safety Manual and a bypass examination for RWT. The Employee Safety Manual was intended to provide employees with background information for general safety and radiation protection at the facility. The manual was therefore used as a readily accessible refresher for employees during performance of their daily duties, as well as a study guide for RWT, including the bypass examination. The inspector noted that the examination questions were based on information provided in the Employee Safety Manual, thus making it an appropriate study guide for preparation for RWT.
The inspector also noted that the licensee was reviewing their training program to determine appropriate actions for personnel who failed the examinations, that is not answering 75 percent correctly. The licensee was currently allowing personnel who failed the bypass examination to participate in the routine training sessions and then attempt the followup examination.
For personnel not achieving a satisfactory score following completion of the training course, the licensee was allowing the employee 90 days to self-study with three additional attempts to i
4 successfully complete the examination.
Personnel, for which the failed training was required to carry out their normal work assignment, were required to work in the area under the cognizance of a qualified and trained individual.
For those not successfully completing the required training during the 90 day period, the licensee would decide to reassign i
or to dismiss the individual. The inspector did not identify any concerns with the licensee's training methods.
The inspector reviewed selected training records for workers signed on l
RWPs issued in association with various activities in the Pellet Loading Room (PLR) and Service Equipment Refurbishment Facility (SERF) areas.
For those records reviewed all RP training, to include GET, RWT, and CAAT, was current. During discussions with cognizant licensee representatives, the inspector was informed that the licensee had
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recently implemented a computerized access control system, which would not allow access to workers if their required training was not current.
The inspector noted that this system appeared to be beneficial for
.providing for better access contro s for both CNFP and contractor l
personnel, based on their training records status, j
From review of the Employee Safety Manual, course outlines, and examinations, the inspector determined that the training program provided to workers potentially exposed to or required to handle radioactive materials was appropriately indepth and met the provisions of 10 CFR 19.12.
No violations or deviations were identified.
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External Expcsure 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 occupational dose in excess of 1.25 rem to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; 7.5 rem to the skin of the whole body; and 18.75 rem to the hands and forearms, I
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 receives or is likely to receive, a dose in any calendar quarter in excess of 25 percent of the applicable value specified in 10 CFR 20.101(a).
j lhe inspector reviewed and discussed selected external exposure records for 1992 and to date during 1993.
Those selected personnel were routinely involved in work associated with various SERF and fuel fabrication operations. The inspector noted that during 1992 the licensee reduced the number of monitored personnel to 218 workers, with no one exceeding an annual whole body dose of greater than 1000 millirem (mrem). The inspector also noted that the majority of monitored personnel received an annual whole body dose of less than 750 mrem.
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inspector also reviewed first and second quarter exposure data for 1993 and noted that for those selected records reviewed the area 1
thermoluminescent dosimeter (TLD) with the maximum whole body dose was
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the assembly storage area, while the area TLD with the maximum skin dose i
was the PLR tunnel. During review of selected 1993 personnel records the inspector noted a maximum quarterly whole body dose of 89 mrem and a maximum skin dose of 880 mrem. The inspector noted that this maximally i
exposed individual was associated with PLR activities, i
The inspector also reviewed extremity monitoring data for 1992 and first l
and second quarter,1993.
The inspector noted that during 1992 the licensee changed vendor contracts for supply of extremity dosimetry.
The inspector further noted that licensee employees were instructed to wear this dosimetry on the base of the middle finger on each hand. The licensee determined this area of the extremity to routinely be receiving the. greatest exposure. The inspector noted that the dosimeter measured l
extremity dose appropriately at a tissue depth of seven milligrams per 2
square centimeter (mg/cm ).
The inspector was informed that during the period from April 15, to May 19, 1992 the licensee had provided extremity dosimetry to selected production personnel in order to perform an annual evaluation to determine the need for extremity monitoring as required by 10 CFR 20.202(a). The inspector nated that for those individuals monitored, one worker assigned to the PLR operations exceeded the 25 percent monitoring criteria wher. the vendor's correction l
1 factor for beta radiation exposure was applied to the TLD monitoring results.
For this one individual the licensee also conservatively 1
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6 estimated the extremity exposure for the period in which the individual was not monitored and therefore assigned the individual an annual i
extremity exposure of 8026.7 mrem.
Based on this 1992 data the license-monitored extremity exposures for production personnel again during l
February 1993. The survey again revealed one individual, who routinely worked in the PLR, which exceeded the 25 percent monitoring criteria.
/dthough most of the monitored population was below the continuous r
monitoring threshold, for the second consecutive monitoring period the licensee's study revealed exposures for an operator in the PLR which exceeded the monitoring threshold.
Based on this data the licensee revised their RWP for PLR operations to require usa of extremity dosimetry.
The inspector also noted that the licensee again l
- onservatively estimated extremity exposures for PLR operators for the i
period in which they were not monitored.
The inspector verified that no quarterly exposures exceeded procedural or regulatory limits.
i The inspector noted that the licensee appropriately monitored personnel external exposures and that all of the assigned exposures reviewed were within regulatory limits.
No violations or deviations were identified.
6.
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 in a restricted area to inhale a quantity of radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
10 CFR 20.103(a)(3) requires for purposes of determining compliance with the requirements of this section, the licensee use suitable measurements of concentrations of radioactive materials in air for detecting and i
evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body, j
measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposed individuals.
a.
Air Sampling Program RP-004, Airborne Radioactivity, Revision (Rev.) 2, dated May 25, l
1993 delineates the instructions necessary for the control and evaluation of airborne contaminants resulting from the handling of radioactive material. The procedure requires consecutive seven day totals be kept for MPC-hrs. Also, investigation and assessment will take place if any seven day total exceeds 10 MPC-hrs.
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The inspector reviewed the procedure, and the licensee's implementation, and noted that the established procedural controls were appropriate to ensure that personnel internal exposures were maintained ALARA during routine work Activities in potential airborne radioactivity areas. The inspector noted that the licensee determined internal exposures and action limits for maintaining airborne concentrations ALARA based on the Maximum l
Permissible Concentration (MPC) of insoluble uranium-235 (U-235) for areas in which unclad fuel pellets were handled, and normally i
on the NPC for cobalt-60 (Co-60) in mixed fission product (MFP) areas. The procedure also stated that if Co-60 is determined not i
to be the isotope of concern, based on shipment manifests performed in accordance with procedure RP-007, Shipment and Receipt of Radioactive Materials, then an evaluation of the isotopic components would be performed in order to determine the limiting MPC and appropriate actions and controls to be taken during work activities, i
i During a previous inspection conducted January 13-17, 1992, a violation, 92-01-04, regarding the licensee's failure to utilize the most restrictive MPC for evaluating SERF-1 workers' exposures i
to airborne radionuclides was identified. The licensee committed to revising RP-007, Shipment and Receipt of Radioactive Materials, l
by May 15, 1992 to reflect program changes.
During a followup inspection conducted September 21-25, 1992 and documented in IR 70-1201/92-06, the inspector determined that the licensee had failed to revise RP-007 to include this program change for i
determining the isotope of concern for MFP areas by the date l
committed to in their response to the violation. This failure to revise the procedure as committed resulted in a deviation, 92 !
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The inspector verified that the licensee had made the appropriate revisions to RP-007, Rev. 1, dated October 30, 1992, l
to provide for this verification tnat Co-60 was indeed the isotope of concern for MFP areas.
I The inspector was also informed that recently the licensee had determined that although iron-55 (Fe-55) had a less restrictive MPC than Co-60, if Fe-55 was indicated by shipment manifests to be in abundance greater than 90 percent, then the licensee would need to perform a similar isotopic evaluation as discussed above to i
determine if Fe-55 was the limiting MPC. The inspector was informed that RP-007 was again undergoing revisions and would incorporate this requirement to determine Fe-55 abundance. The inspector noted that although the current procedure did not yet specify the necessity for determining Fe-55 abundance, Health-i Safety Monitors had been informed to verify Fe-55 abundance of incoming MFP shipments in order to determine the limiting MPC.
The inspector determined that the licensee's current program for assigning exposures based on airborne radionuclide concentrations i
was appropriate.
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8 The inspector noted that the licensee continued to implement their air sampling program which required 100 percent lapel sampling for all work in the rediologically controlled area.
Personnel performing monitoring or supervisory functions, however, were not required to wear lapels. The inspector also noted that the current RWP and access controi process was reflective of this in that RWPs required all personnel performing actual work activities to wear lapel samplet s.
During facility tours the inspector observed work in progress in the PLR and noted that personnel were appropriately wearing lapel samplers in accordance with the 100 percent lapel policy. The inspector noted the License Application required that the licensee perform an annual evaluation to determine the representativeness of their stationary air sample *s.
The inspector was informed that personnel exposures were routinely based on lapel sampler assessments.
The licensee stated that there did not appear to be a justified need to determine the reprnentativeness of stationary samplers since they were not used to assign exposure to personnel already wearing lapel samplers and working in the area of the stationary samplers. The inspector r
discussed with licensee representatives the prudence of revising l
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the License Application during the next License Amendment to reflect their current air sampling program. The licensee acknowledged the inspector's comments and indicated that they would review their current program to determine the appropriate i
course of action.
The inspector also reviewed internal exposure assessments for i
personnel assigned to fuel fabrication and SERF activities during 1992 and 1993, to date. C -ing 1992 the inspector noted that the l
licensee had determined that over 50 percent of the total MPC-hours assigned during 1992 were associated with fuel downloading i
operations.
The inspector noted that the maximum assigned annual personnel internal exposure was 174.73 MPC-hours. The inspector noted that this individual was specifically involved with downloading operations as well as routine operations in the PLR.
j The inspector also noted that this individual, as well as other i
monitored personnel, did not exceed any regulatory limits for MPC-1 hours during the year. The inspector also reviewed MPC-hour trackings for selected workers during first and second quarters 1993 and noted that no individual exceeded 10 MPC-hours during any one week period, thus requiring an evaluation by the licensee.
We inspector verified that the licensee war manually reviewing a ven consecutive dav MPC-hour totals at the end/beginning of each nth since the licensee's corrent computerized tracking system d not perform this func' ion.
For those selected individuals reviewed the inspector Nted the maximum assigned quarterly exposure was 8.62 MPC-hours.
No violations er deviations were identified.
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Bioassay Program RP-006, Bioassay Program. Rev. 1, dated September 9, 1992, establishes which personnel shall participate in the bioassay program, the frequency and type of bioassay, action levels, and documentation requirements. The procedure also requires that as a quality control a quarterly urine sample be collected and contaminated with a spike solution.
Following analypis by the vendor the licensee's heath physicist will compareithe vendor's results with expected values and initiate corrective: actions if the variance is in excess of 20 percent.
The inspector reviewed first and second quarter,1993 internal exposure records for selected individuals assigned as Health-Safety Monitors, assigned to PLR and included in the routine uranium bioassay program, and assigned to SERF areas and included in the routine MFP bioassay program. The inspector verified that the individuals - re being included in the appropriate bioassay program, were prescrih;*a to the appropriate counting frequency, and that all bioassa.;
tults were less than the licensee's action limits.
The inspector also discussed with the licensee their in-vitro monitoring quality control program.
The inspector was informed that during 1991 and 1992 the vendor's analysis of the spiked quality control sample had differed from those results e..pected by the licensee by more than 20 percent, the procedural action limit.
During discussinns with licensee representatives the inspector was informed that the licensee's spike solution was a dissolved fuel pellet concentration, therefore, not a traceable standard. The inspector was also informed that the licensee had no calibration for their spike solution.
The inspector also noted that the licensee had attempted several evaluations to determine the actual concentration of radioactivity of the spike soiution in an effort to determine the cause of the difference in the expected and the vendor's spike sample results.
Since the previous inspection, condacted September 21-25, 1992 and documented in IR 70-1201/92-06, wnen this issue was opened as an unresolved item (URI), the licensee had purchased a traceable standard for performing the quality control check of the vendor's results. The inspector noted that during 1993 the licensee had used the traceable standard to spike a urine sample each quarter which was then sent to the vendor with the quarterly samples for urinalysis. The inspector noted that this sample was a urine specimen taken from a facility employee not assigned to work with radioactive materials.
The inspector verified that during both the first and second quarters of 1993 the vendor's results were within 20 percent of the results expected by the licensee for the spiked quality control sample.
Based on the licensee's purchase of a traceable standard for performing the quarterly quality control check and
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10 the vendor's current :ibility to be within a 20 percent variance of the licensee's expected results, the inspector informed licensee representatives that the URI would be closed.
j No violations or deviations were identified.
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Respiratory Protection Program i
l 10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protection program that includes, at a minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to select, fit and maintain respirators; written proceoures regarding j
the supervision and training of personnel and issuance of records; and determination by a physician prior to tfe use of respirators,
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that the individual is physically able to u >e respiratory protective equipment.
The inspector reviewed and discussed with licensee representatives the implementation and adequacy of the respiratory protection program.
The inspector was informed that the licensee required annual respiratory protection training and an annual medical examination to ensure that personnel were qualified to wear respiratory protective devices.
Following review of the licensee's training course outlines, the inspector noted that the training material appropriately addressed control of airborne radioactivity, air rampling, regulatory requirements and limits, types of respiratory protective devices, protection factors, criteria for qualification, and steps to take in einergency situations. The inspector also noted that since the full-face negative pressure respiratory protective devices received limited use at the facility, personnel were qualitatively fit-tested using a challenge atmosphere each time they were issued a respirator.
For selected individual records reviewed the inspector noted that training, including written examinations, and medical t
qualifications were current as required by the applicable procedures.
No violations or deviations were identified.
7.
Radiation Controls (83822) a.
Radiation Work Permits (RWPs) i i
The inspector reviewed selected RWPs issued in association with various activities in the PLR and SERF for appropriateness of the HP requirements based on work scope, location, and conditions.
The inspector reviewed records of surveys and monitoring provided during selected RWP activities and found them adequate to properly assess radiological conditions. The inspector noted that each RWP provided for as many as four categories of workers which could access the RWP.
Based on radiological survey data each work i
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category was required by the RWP to have specified monitoring devices, such as specific dosimetry, lapel samplers, or i
respiratory protective devices. As stated in Paragraph 2 of this IR the licensee had recently implemented a HPIMS which allowed personnel to access a particular controlled area and a particular RWP provided that they had completed the required training and had t
the proper monitoring devices for the work to be performed. The inspector also verified that appropriate controls were specified in the RWP to maintain exposures ALARA.
During review of the RWP for fuel downloading operations, the e
inspector noted that for one of the work categories, which met the job criteria for lapel sampler use in the area, use of a lapel sampler was not required by the RWP.
The inspector discussed this inconsistency with licensee representatives who informed the inspector that since incorporating the RWP and access control systems into the HPIMS, there had been no operations which would require use of this specific RWP.
Licensee representatives did however state that the particular work category would require lapel sample usage and that the-RWP would be revised to make the correction. The inspector had no further concerns regarding this issue.
No violations or deviations were identified.
b.
Surveys 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20 and are reasonable under the circumstances to evaluate the extent of radioactive hazards that may be present.
During facility tours the inspector independently verified postings, labelings, and radiation and contamination levels in i
various areas of the facility, including outside storage areas.
The inspector verified survey results against the appropriate licensee records of current radiation and contamination surveys.
The inspector also verified that selected surveys were performed y
at the appropriate frequency and that servey results were below those action limits as specified by the applicable procedures.
During review of 1993 routine survey records, the inspector noted.
that the licensee was utilizing appropriate instrumentation to perform the surveys, with those instruments having a current calibration. The inspector noted also that the licensee was performing semiannual calibrations for Self Reading Pocket Dosimeters (SRPDs) and weekly verifications of air flow velocity for hoods throughout the facility, in accordance with appropriate procedures.
In addition, the inspector verified that the licensee was performing smear surveys of respirators after usage to determine if the worker needed to perform a nasal smear due to the l
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No violations or deviations were identified.
c.
Facility Tours During facility tours the inspector verified that postings and labelings were appropriate as indicated by the latest area survey maps.
The inspector also determined that these postings and labelings were consistent with the licensee's procedures and License 8.pplication.
Additionally, during tours of the fuel fabrication and SERF areas the inspector noted personnel appropriately wearing their dosimetry on the front of the body between their neck and belt, as required by RP-005, Personnel Exposure Monitoring. The inspector also observed proper use anC removal of protective clothing, as well as proper personal monitoring upon exiting specific controlled areas.
In addition, the inspector observed personnel involved in work activities in fuel fabrication and SERF areas appropriately utilizing lapel air samplers as needed.
No violations or deviations were identified.
8.
Administrative Controls (83822) a.
Termination Records 10 CFR 20.408(b) and 20.409(b) require, in part, that licensees make a report to the Commission, and notify the individual involved, or his designee, of the radiation exposure of each individual who has terminated employment. The report is to be furnished within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier.
The inspector reviewed termination reports for SERF-3-workers which had terminated work assignment at the licensee's facility since January 1, 1993. The inspector noted that the SERF Supervisor was sending monthly status reports to the Health-Safety group informing them of a worker's termination of their current-work assignment at the licensee's facility. After gaining this information the worker's dosimetry was pulled and read so that the individual's termination letter could be initiated and their NRC Form-4 could be updated. The inspector also reviewed termination' reports for individuals which had terminated during a recent facility reduction in force. The inspector verified that for both situations the termination letters were appropriately being
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.ter tesvided within 30 a y
.icensee'rmination or n s after completion of work assigexposure determination s facility.
1The inspector determined thatnment at theor 90 days providing termination rep workers terminating employme t orts to licenseethe licensee's met the requirements employees and SERF-3 current program f n or No violations of 10 CFR Parts 20.408 andcompleting their 20.409 work assignment V b.
or deviations Notice to Employees were identified.
10 CFR 19.ll(a conditions, pies)of Par (t 19, quire, in part, that the lic current co and b) re amendments and operating prdocuments incorporated i tPart 20. the lic
, li ensee post notice describing these do ocedures n o the license, cense license cuments an,d where they may bor that a licensee post 10 CFR 19.11 to Employees"(d) requires that a licen e
posted to perm. Sufficient copies examined.
the required formssee post Form NRC-3 "Notic from licensed activity lit licensee workers to of that form NRC-3 and notiDuring tours of the facili observe them on the way to e
ocations.
are to be or ty buildings, the inspe t Part 19 and Part 20 and li ces referencing the appropricensee docum accordance with the applicabl c or verified determined that the fo viewed by all personnel on thwere posted in adequate loThe in e regulation.
rms e in activities.
eir way to No vialations or deviati or froin licensedcations to be
'see Actions ons were identified.
n ed) 70-1201/92-06-01:on Previously Identified I qentifiedduringaninspectioncommitted to in an April 1 as
.nted in IR
, 1992 response to violation 92 0 prior to May 15, 70-1201/92-01.
conducted January 13-17 pn current licensee imple, 1992 and hiting isotope to perform MPiate control actions for MFP mentetion of C-hour the program for (Paragraph 6.a) calcul operations, ations and for takingassessing this item is 70-1201 1
vendor-p/92-06-03:
considered rovided urinalysis progURI regarding the qualit
' quality control urinalysicurrent licensee implementati y control program ram.
(Paragraph 6.b) checks, this item isdh of the program for s
performing considered
m
~
13 provided within 30 days after exposure determination or 90 days after termination or completion of work assignment at the licensee's facility.
The inspector determined that the licensee's current program for providing terminatica reports to licensee employees and SERF-3 workers terminating employment or completing their work assignment met the requirements of 10 CFR Parts 20.408 and 20.409.
No violations or deviations were identified.
b.
Notice to Employees 10 CFR 19.11(a) and (b) require, in part, that the licensee. post current copies of Part 19, Part 20, the license, license conditions, documents incorporated into the license, license amendments and operating procedures, or that a licensee post a notice describing these documents and where they may be examined.
10 CFR 19.ll(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 tours of the facility buildings, the inspector verified that Form NRC-3 and notices referencing the appropriate 10 CFR Part 19 and Part 20 and licensee documents were posted in accordance with the applicable regulation. The inspector determined that the forms were posted in adequate locations to be viewed by all personnel on their way to or from licensed activities.
No violations or deviations were identified.
9.
Licensee Actions on Previously Identified Inspector Findings (92701)
I (Closed) 70-1201/92-06-01:
Failure to revise RP-007 prior to May 15, 1992 as committed to in an April 14, 1992 response to violation 92 04, identified during an inspection conducted January 13-17, 1992 and documented in IR 70-1201/92-01.
J Based on current licensee implementation of the program for assessing the limiting isotope to perform MPC-hour calculations and for taking appropriate control actions for MFP operations, this item is considered closed.
(Paragraph 6.a)
(Closed) 70-1201/92-06-03: URI regarding the quality control program for the vendor-provided urinalysis program.
Based on current licensee implementation of the program for performing quarterly quality control urinalysis checks, this item is considered closed.
(Paragraph 6.b)
14 10.
Exit Meeting The inspector met with licensee representatives indicated in Paragraph I at the conclusion of the inspection on September 2,1993. The inspector summarized the scope and findings of the inspection.
The inspector also s
discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection.
The licensee did not identify any such documents or processes as proprietary. Dissenting comments were not received from the licensee.
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