ML20058F922
| ML20058F922 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/15/1982 |
| From: | Barr K, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058F885 | List: |
| References | |
| 70-1113-82-10, NUDOCS 8208030145 | |
| Download: ML20058F922 (8) | |
Text
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fErei,*g UNITED STATES y
8 NUCLEAR REGULATORY COMMISSION o
y a
REGION 11 a
o 101 MARlETTA ST., N.W., SUITE 3100 o
ATLANTA, GEORGIA 30303 Report No. 70-1113/82-10 Licensee: General Electric P. O. Box 780 Wilmington, NC 28402 Facility Name: Wilmington Manufacturing Department Docket No. 70-1113 License No SNM-1097 Inspection at Wilmington, North Carolina Inspec'or:
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0ats' Signed Approved by:
M d //f!8L' K. P.' Barr, Section Chief
'Dat6 Signed Technical Inspection Branch Division of Engineering and Technical Programs o
SUMMARY
Inspectior: on May 17-22, 1982 Areas Inspected This routine, unannounced inspection involved 37 inspector-hours on site in the areas of radiation protection, including internal and external exposure control, radiological surveys, radiation protection training, respiratory protection training, posting, labeling and control of radiological areas, review of radiolcgical aspects of a new incinerator and followup on previous enforcement and inspector followup items.
Results Of the four areas inspected, no violations or deviations were identified in three areas; one violation was found in one area (Failure to follow personnel survey procedure when exiting the control area).
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8208030145 820726 PDR ADOCK 07001113 C
r REPORT DETAILS 1.
Persons Contacted Licensee Employees "W. J Hendry, Manager, Regulatory Compliance
- R. G. Patterson, Manager, Fuel Fabrication Operation
- 0. W. Brown, Manager, Powder Production Unit A. G. Dada, Manager, Chemical Technology M. E. McLain, Manager, Nuclear Safety Engineering C. M. Vaughan, Manager, Licensing and Nuclear Materials Management
- J. H. Bradberry, Jr., Emergency Preparedness Coordinator
- R. L. Torres, Radiation Protection Supervisor
- R. Foleck, Senior Licensing Engineering Specialist
- S. P. Murray, Nuclear Safety Engineer D. Barbour, Radiation Protectics Shift Supervisor R. Lewis, Radiation Protection Shift Supervisor E. L. Jefferds, Nuclear Safety Engineer Otner licensee employees contacted included three technicians, two operators and three office personnel.
- Attended exit interview 2
Exit Interview
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The inspection scope and firdings were summarized on May 21, 1982, with those persons indicated in paragraph 1 above. The status of three inspector identified items and one previous violation were discussed with licensee management.
The inspector identified two apparent violations (Failure to follow personnel survey procedure and failure to post a radioactive material area).
The manager of Quality Assurance acknowledged the inspector's comments. The inspector also stated that one item would remain unresolved (air sampling during maintenance activities) pending further review of previous air sampling during similar activities and a review of air sample results which may have been taken during the maintenance. Licensee manage-ment stated that they thought documentation could be provided which would support relying on fixed samplers in the work area for demonstrating compliance with 10 CFR 20.103 in lieu of taking grab samples in the immediate work area.
On June 8,1982 the licensee was informed that failure to post the radio-active material area would not be considered a violation of NRC require-ments.
Upon further review of the item by the regional staf f, it was determined that the exception to posting radioactive material prepared and packaged for transport contained in 10 CFR 20.204(d) was applicable to the loaded trailer awaiting pickup by the carrier.
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3.
Licensee Action on Previous Inspection Findings Closed (Violation) 81-11-04, Failure to Follow Personnel Survey Procedure.
See paragraph 6 of this report fcr a discussion of this item.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 7.
5.
Licensee Action on Previous Inspector Identified Items a.
Closed (IFI) 81-07-02, Monthly Inspection of Full Face Mask.
The inspector reviewed the methods used by the licensee to ensure that respirators are periodically inspected and had no further questions.
b.
Closed (IFI) 81-07-03, Inventory of Respirators.
The inspector reviewed the licensee's method of inventory for respirators and had no further questions.
c.
Closed (IFI) 81-07-04, Storage of Respirators. The inspector observed the storage of respirators in new storage cabinets and had no further questions.
6.
Personnel Monitoring Licensee condition 9 of the license requires that licensed material be used in accordance with statements, representation and conditions of Appendix A, as contained in the licensee's application.
Appendix A.
Section 4.1 requires that operations and activities shall be directed by the designated i
area manager who shall establish written operating procedures.
Procedure PROD No. ICR08, Personal Survey - Leaving Controlled Area, requires that individuals hold the scanner probe approximately 1/4 inch away and slowly pass it over the hair, face, chest, hands, waist, ankles, shoes and TLD badge.
1 In response to a violation reported in IE Report 70-1113/81-11, The licensee has conducted training sessions in the proper methods of performing personnel surveys for contaimination. In addition licensee managers perform daily audit of personnel monitoring in the change rooms. Approximately 59 i
audits. are performed each week. Over the last 20 weeks over 1000 audits 2
have been performed.
These audits have only identified 15 people who surveyed themselves improperly.
In each case, the individual resurveyed himself prior to leaving the controlled area.
On May 20th the inspector, accompanied by a licensee representative, observed three out of approximately ten workers exit the ceramic area change room after performing an improper frisk. In each case, the probe was held several inches away from the body and/or move much too rapidly to detect
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3 alpha contamination at levels equal to or less than the licensee's limit.
'The licensee representative stopped the worker and had them frish properly.
On May 21, the inspector and a licensee representative observed that two out of ten workers monitored themselves improperly upon exiting the controlled area. One worker was asked to remonitor himself af ter the improper frisk was pointed out to the licensee representative accompanying the inspector.
The other worker was not stopped by the licensee representative.
In discussions concerning frisking practices of workers, licensee management stated that they recognize the need to have someone continuously monitoring the frisking process. They also stated that plans are being finalized to modify the change rooms so that there is single exit and that at this exit the workers will be required to monitor themselves under the constant surveillance of a licensee representative. The inspector stated that it appears that licensee personnel who audit the frisking activities may not know what constitutes a thorough frisk for personnel contamination.
The inspector further stated that there is no reason to believe that what he observed on May 20 and 21 is not typical.
The inspector stated that failure of licensee personnel to perform personnel contamination monitoring in accordance with plant procedures is a violation of license condition 9(82-10-01).
7.
Surveys The inspector selectively reviewed records of radiation and contamination surveys performed in 1982, discussed the survey results with licensee representatives and observed radiation protection technicians performing surveys. The inspector also reviewed the results of airborne radioactivity surveys performed in 1982 using the approximately 160 fixed station air sampler installed throughout the controlled area. Air samples are removed and analyzed each shift Results that exceeded administrative controls were investigated and appropriate corrective actions taken.
10 CFR 20.103(a)(3) states in part, that for purposes - of determining compliance with the requirements of this section the licensee shall use suitable measurements of concentrations cf radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
On May 21, the inspector observed that the area around the blender was posted w
as an " airborne radioactivity area, full-face respirator required for entry." The inspector also observed a worker remove a screen (prefilter) from a filter housing and bag the item.
The worker was wearing a respirator. Immediately upon replacing the filter housing cover, the worker descended a ladder and removed the respirator; however, he remained in the area. Two additional individuals entered area without wearing a respirator.
During discussions with the radiation protection staff, a licensee representative stated that air samples removed and analyzed on the graveyard shift on May 21 indicated airborne radioactivity concentration in the vicinity of the blender had increased over normal levels. It was suspected that the exhaust system maintaining negative pressure on the blender
4 containment (glove box) may not have been functioning properly. The area was posted as an airborne radioactivity area on the graveyard shift. Work in the area was suspended and action to determine the actual cause of the increased activity was begun on the graveyard shift.
In addition to changing the containment ventilation system prefilter, a piece of duct going from the containment to the ventilation system filter housing was removed.
The inspector observed loose Uranium powder on the floor below where the piece of duct had been removed.
When the inspector asked the radiation protection technician covering the work on the day shift about air samples performed during the removal of the s
filter and the transition piece he indicated that he did not take any air samples to support the work. The inspecter stated that air samples should be performed during the work to determine if the respiratory protection being provided is appropriate. Additional air samples should be taken after the work is completed, and prior to allowing entry into the area without a respirator, to ensure that airborne concentrations have been reduced below that which would require a respirator.
A licensee representative stated that significant data was.available to indicate that airborne radioactivity concentrations were below regulatory limits during such maintenance activities. He also stated that the fixed station air samples were monitoring the work area.
The inspector stated that fixed air samplers located 10-15 feet away were not suitable tu deter-mine air concentrations in the breathing zone of workers during maintenance activities with high potential for producing airborne radioactivity.
Immediately prior to the exit meeting, a licensee representative informed that inspector that they thought air samples had been taken during the early stages of the work; however, the results could not be located The inspector stated that failure to make suitable measurements of concentration of radioactive material in air for detecting and evaluating airborne radioactivity in restricted areas would be a violation of 10 CFR 20.103 (a)(3). This item will remain unresolved (82-10-02) pending a more detailed review of the licensee's air sampling program during a subsequent inspec-tion.
8.
Internal Exposure Control a.
The inspector selectively reviewed the bioassay procedures and records, toured the plant's whole body counter and discussed the plant's bioassay program with licensee representatives.
No violations or deviations were identified.
b.
Nuclear Safety Instruction No. 0-1.0, Rev. 5, Respiratory Protection -
Training and Fitting, specifies the requirements for training and fit-testing prior to an individual wearing a respirator. To evaluate the plant's training and fit-testing program for respirators the inspector asked that the training be given to him and that he be fit tested. The training and fit test is normally given by a member of radiation protection staf f.
A licensee representative stated that the training
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usually takes approximately 15 minutes, followed by the fit test.
4 During the training, the inspector noted that overal of the areas which NSIO-1.0 states should be presented in the training were omitted, i
such as a discussion of airborne contaminants that the wearer is to be protected against, physical properties, MPC's, physiological behavior, toxicity, consequence of not wearing a respirator, discussion of the construction, operation, purpose, types and limitations of the available respiratory protection equipment, and instructions in the i
emergency action to be taken in event of malfunction of respiratory i
protection devices.
In discussion with licensee representatives, several indicated that these items are normally included in the training. The inspector stated that methods should be developed to ensure that all the information contained in NSI 0-1.0 is presented to each individual trained, as well as the pertinent information contained in NUREG 0041 and the plant's license (82-10-03).
j No violations or deviations were identified.
9.
External Exposure Control 1
During tours of the plant, the inspector observed workers wearing the appropriate TLD badges.
Personnel working around neutron sources wore special TLDs that also monitored the neutron exposure.
The inspector discussed the dose monitoring program with licensee representatives. The inspector also reviewed the monthly and quarterly computer printouts for the period of January, 1982 through March, 1982 and verified that the radiation i
doses recorded for plant personnel were well within NRC limits.
The licensee was maintaining the records of radiation exposure required by l
i No violations or deviations were identified.
i 10.
Radiation Protection Training i
The inspector attended the radiation protection and criticality safety 1
orientation given to new employees who need unescorted access to this controlled area. The overall training appears to cover the information required by 10 CFR 19.19 and Regulatory Guide 8.13.
In discussions with licensee representatives, the inspector stated that the training should be modified to better emphasize the worker's responsibility for radiation and nuclear safety, to clarify the part 19 requirement that workers should i
report violations or potential violations of NRC regulations to plant management and to emphasize the procedure for removing material or equipment from the controlled area (82-10-04).
i 11 Posting of Notices 1
10 CFR 19.11 requires, in part, that each licensee post current copies 10 CFR 19 and 10 CFR 20 or if posting of the documents is not practicable, I
the licensee may post a notice which describes the document and states where it may be examined. 10 CFR 19.11 further requires that copies of any Notice i
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4 of Violation involving radiological working conditions be conspicuously posted within two working days af ter receipt of the documents from the Commission.
The inspector observed the posting of notices required by 10 CFR 19.11 and had no questions.
I 12.
Posting, Labeling and Control i
The inspector reviewed the licensee's posting and control of radiation areas, airborne radioactivity areas, ccntamination areas, and radioactive material areas and the labeling of radioactive material during tours of the plant.
On May 20, 1982 the inspector observed four trailers, each loaded with 14 boxes containing fuel bundles, located in an outside storage area at the northeast corner of the FM0 building.
The area was not posted as a radioactive material area.
A licensee representative stated that the trailers had been received from an off site storage location and would be j
shipped to a reactor licensee promptly.
10 CFR20.203(e) states that areas where licensed material is used or stored and contains greater than ten j
times Appendix C quantities of material (greater than 0.1 microcurie U-235)
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shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words " caution - radioactive material."
The inspector initially told the licensee that failure to post the area where the trailers were stored as a radioactive material area was a violation of 10 CFR 20.203(e).
A licensee representative stated that the fence surrounding the FM0 and outside storage areas was properly posted as a radioactive material area. However the inspector stated that no signs were visible to individuals entering the area walking or by vehicle. Tnerefore, the area was not conspicuously posted.
Later in the day, the appropriate l
signs were placed at the personnel and vehicle gates.
In further review of the posting requirements and discussions with NRC Region II management, it was determined that the exception to posting the area contained in 10 CFR 20.204(d) was applicable, since the material was prepared for transport and packaged and labeled in accordance with the regulations of the Department of Transportation. Therefore, no violation of NRC requirements occurred.
13.
Radiological Aspects of New Incinerator Amendment 25 to the license authorized the licensee to use a new incinerator j
subject to specific conditions contained in the amendment.
The inspector toured the new incinerator, discussed the operation of the incinerator and the special monitoring requirements during the first 30 days of operation with licensee representative and reviewed the temporary operating procedure.
During the inspection, the licensee was making the final burns of non-t radioactive material. Following cleanout of incinerator, the licensee will begin making controlled burns of spiked boxes of waste to test the account-ability procedures.
Personnel operating the facility appear to be very knowledgeable of the facility and the specific radiological and nuclear safety requirements.
The inspector stated that the temporary operating procedure appeared to be adequate; however, the procedure should include
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7 specific radiological control requirements for replacing the liquid filter in the scruober water cleanup system.
14.
Airborne Radioactivity Release On May 12, 1982 a duct on the No. 5 defluorinator ruptured causing an airborne radioactivity release in the calciner area.
The area was immediately evacuated.
Personnel who entered the area to idertti fy and correct the cause wore appropriate respiratory protection equipment.
The inspector reviewed air sample results, bioassay results for personnel who were in the area or who entered during the event, and stack sample results.
No NRC limits were exceeded. No violations or deviations were identified.
15.
Emergency Response On May 18,1982 at 2:17 p.m. the criticality alarm for outside waste storage pads 5, 6, 7 and 5 sounded during a thunderstorm.
The area was evacuated and the licensee promptly manned the plant's emergency control center.
Radiation survey teams performed radiation surveys in the area and found that all radiation levels were normal.
The licensee determined that lightning struck the radiation monitor cabinet at the time the alarm sounded.
The licensee's response was timely and satisfactory. Actions taken by the licensee to determine if real emergency existed were appropriate.
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