ML20127K738
| ML20127K738 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/25/1985 |
| From: | Hosey C, Jenkins D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127J983 | List: |
| References | |
| 70-1113-84-17, NUDOCS 8505220174 | |
| Download: ML20127K738 (19) | |
Text
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NUCLEAR REOULATORY COMMISSION REG 10N Il
.101 MARIETTA STREET.N.W.
'i-8 ATLANTA, GEORGIA 30303 Q*****f JAN 311985 s
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, Report No.: ;70-1113/84-17 i
Licensee:
General Electric-Company
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Wilmington,-NC 28401
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! Docket No.:' 70-1113 License No.:
SNM-1097 c
. Facility;Name:. Nuclear Fuel Manufacturing Department Inspection Conducted:'
ovember 27 - 30, 1984 Inspector:
A
/ Mf C. M. Hostyv Date' Signed
- Approved' by: 'k flG A
/[dd7D
" G. R. Jenkin's, Sgtion Chief
'Date' Signed Division of Radiation Safety and Safeguards
SUMMARY
Scope: This special, unannounced inspection entailed 38 inspector-hours on site in the areas of followup on worker concerns and an unresolved item.
'Results: Two violations - Failure to make -suitable measurements of concentra-tions of radioactive materials in air in the CHEMET Lab and failure to furnish Jthe NRC a report of a terminated individual's radiation exposure within 30 days after the exposure had been determined.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- J._E.' Bergman, Manager, Fuel Manufacturing
- W. C. Peters, Manager, Nuclear Safety Engineering
- C. M. Vaughan, Acting Manager, Regulatory Compli.ance
- T. P. Winslow; Manager,- CHEMET Lab
- R. L. Torres, Manager, Radiation Protection D. T. Barbour, Radiation Protection Shift Supervisor
- S. P. Murray_, Nuclear Safety Engineer
- P. S. Stansbury, Nuclear Safety Engineer E..L. Jeffords,. Nuclear Safety Engineer
- B. J. Beane, Senior Engineer J. R. Swepson, Foreman, Special Material Order and Control J. Williams,-Radiation Protection Technician H. W. Ganious, CHEMET Lab Technician
- R. L. Brown, CHEMET Lab Test Operator-A G. M. Coronado, CHEMET. Lab Technician G. W. Shiver, CHEMET Lab Test Operator-A H.~ W. Fields,' CHEMET Lab Technician L. W. Brown, CHEMET Lab Test Operator-A
' W. A.' Wells, CHEMET Lab Technician H. B. Pierce, CHEMET Lab Technician C. G. McLamb, CHEMET Lab Shift Superviscr W. Lacewell,-CHEMET Lab Shift Supervisor J. R. Sutton, CHEMET Lab iest Operator-A
- 0. L. Swepson, CHEMET Lab Technician
- Attended exit interview 2.-
Exit Interview The inspection scope and findings were summarized on November 30, 1984, with those ersons indicated in paragraph 1 above. The failure to make suitable meae. sments of concentrations of radioactive materials in air in the CHENET.
Lab Lsaragraph 5) and failure to furnish the NRC a report of a terminated individual's radiation exposure within 30 days after the exposure of the
~
individual had been determined (paragraph 4) were discussed in detail. The licensee acknowledged the inspection findings and took no exceptions.
The weaknesses in the contamination control program in the CHEMET Lab, were discussed.
Aspects of program discussed included frequency and scope of contamination surveys, survey requirements for removing paperwork, samples and personal items from the lab, and management attention and commitment to a radiologically clean working environment in the laboratory.
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~~ management agreed 'to review this-area and to take appropriate actions to improve the program.~
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Improved lighting for; the bulletin board where the documents required by
'10 CFR 19.11:are posted was discussed. ! Licensee managsment agreed to take
~ action.to improve the lighting' in the vicinity.of' this bulletin. board.
The :: installation :of local area exhaust ' systems - to remove noxious fumes
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~ 9enerated 5 during various analyses-was discussed. The licensee agreed to t
perform dichromate titrations-in a. vented hood or to install an exhaust
.directly over the work' station.
W 3.
-Licensee Action on Previous Enforcement Matters 4
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?(Closed)'UNR (84-13-01) This item was-determined to be a. violation an'd :is discussed in paragraph 5.
14.
Allegations, Discussions and Findings Note! ' The pronoun."he" is used throughout this report without regard to -the~
sex of.the individual to protect the identity of confidential sources'to tha J
-maximum' extent possible.
-a.
LA11egation Employees ~ ' were toic not to talk to or answer questions of NRC inspectors.
Discussion 4
101 CFR 19.15(b) states, in. part,. that during the course of an inspection : any' worker may ' bring privately to the attention of = the fr inspectors, either orally or. in writing, any past or present condition which he has reason to believe may have contributed :o or caused any
, violation of ' the Act, the_ regulations.in this chapter, or license Econdition', 'or any unnecessary exposure.of an' individual to radiation fr'om licensed radioactive material under.the licensee s. control.
'In addition, Form NRC-3, Notice to Employees, states that an employee may talk with an NRC inspector. This form is required to be posted by 10:CFR 19.11' in a sufficient number of places to permit individuals
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engaged in. licensed activities to observe them on the way to and from lany particular-licensed activity. location.to which the document applies.
A total of twelve CHEMET Lab technicians, test operators and first-liv supervisors were asked whether or not theyJhad been advised or told not N-to talk.to NRC' inspectors.- Each individual stated that they had never been 'so advised. One' individual did state that his supervisor once
' told him to refer NRC -inspectors to the -supervisor if they had any
- questions.
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3 During inspections at the licensee's facility between 1982.and 1984, the inspector has never encountered an individual who refused to talk with him. The inspector has on occasion been stopped by workers 'and asked questions.
Findings This allegation was'not substantiated. The inspector found no evidence
-which would -indicate that workers were prohibited or discouraged from talking with NRC inspectors.
No violations or deviations were identi fied.
b.
Allegation 10 CFR 19.11 required posting has become less accessible to employees than in the past. At the near guard house location, the bulletin board is poorly lighted.
Dust and dirt make posted material almost illegible.
Discussion 10 CFR 19.11(d) requires that documents, notices, or forms posted pursuant-to this section appear. in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or f rom any particular licensed material activity location to which the document applies, shall be conspicuous, and shall be replaced if defaced or altered.
The inspector observed the posting of the documents required by 10 CFR '19.11 at the personnel ent', ace to the licensee's controlled access area during daylight and nignt hours.
Findings The allegation was partially substantiated. Although the postings may be less accessible than in the past, they met the requirement of 10 CFR 19.11 in that employees engaged in licensed activities could observe them on the way to and from any particular licensed activity.
The documents 1 required by 10 CFR 19.11 were conspicuously posted and have
- been neither defaced nor altered. The postings were legible during the daylight hours. The postings were also legible during the night hours, although lighting in _ the area could be improved.
Licensee management agreed in the exit interview to install better lighting in the vicinity of the bulletin boards.
L c.
Allegation Dumping of uranium powder outside hoods and the release of gas fumes in s
L the lab may be the cause of sinus problems and other nasal difficulties F
experienced by lab personnel.
I L.
4 Discussion Twelve, laboratory personnel were asked if.they had experienced sinus problems or other nasal difficulties while working in the lab. One-
. individual stated that he had a nasal. rash from nitric acid fumes four or: five years ago when performing isotopic analysis and has had a -
problem with hydrofluoric' acid fumes at. times in the lab.
The cremaining eleven individuals interviewed stated they had not experienced sinus or nasal prcblems while working in the lab.
Findings-The allegation was.not substantiated. One. individual out of the twelve
' interviewed indicated he had any sinus or nasal problems while working
.in t_he_ lab.
It appears that nasal or si.nus problems are not as
- pervasive in the lab as indicated in the allegation.
No association between dumping Uranium Powder and sinus problems was established.-
Industrial' exposure to concentrated acid is outside the purview of the NRC's responsibilities. However, this worker concern has been referred to OSHA. ' No violations or deviations were ! identified.
d.
Allegation There was a violation of a laboratory procedure in accepting contami-nated sample vials and paperwork in the lab. Supervisors were lax and condoned this.
Discussion Plant Procedure Calibration and Operation Instruction (COI) 6, Rev.1,.
Control of Samples in the CHEMET LAB, states in Paragraph 3.1.6 that
" samples received in the controlled lab are to be handled as contami-p
_nated material."
In addition, Nuclear Safety Release 6.1.0, ' Radio-logical Safety Requirements for the CHEMET Lab, specifies that all personnel working in the CHEMET Lab must wear lab coats and safety glasses and that gloves will be worn when handling samples coming from the controlled area, working with visibly contaminated laboratory waste
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or equipment, working inside hoods, and any time the individual feels gloves are required.
The inspector made several unannounced visite, to the CHEMET Lab on different shifts and observed laboratory personnel's adherence to the requirements of the Nuclear Safety Release.
l Findings The allegation was not substantiated.
The licensee recognizes that samples that come from the production area may be contaminated. Plant g
Procedures caution CHEMET Lab personnel that samples may be contaminated and require the use of appropriate protective clothing for L
lab personnel. The inspector did not observe any violations of the I
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Nuclear Safety Release.while. he was in the laboratory. No violations or deviations were identified.
e.
Allegation
- A11eger's work area was deliberately contaminated by another person or persons on a' previous shift.
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Discussion A total of five CHEMET Lab personnel were asked if they knew of any cases where a lab worker's work station was deliberately contaminated by someone else. One individual states he was not aware of such an incident.
One individual stated he had no first hand know' edge, however, he had' heard that it happened. Two individuals stated that they knew that the alleger contaminated his own work station to. test whether or not radiation safety personnel could find the contamination during a routine survey. Another individual stated that he and the alleger observed another worker using poor work practices which resulted in a spill and didn't tell anyone. They used the spill to test radiation safety personnel's ability to find the contamination in a routine survey.
Findings
.This allegation could not be substantiated.
It is conceivable that either the work bench was accidentally contaminated on a previous shift u
rather than deliberately contaminated, or contaminated as indicated by the individuals interviewed, however, the specific cause could not be determined. No violations or deviations were identified.
f.
Allegation Radiation Safety personnel were lax on monitoring for contamination and requiring cleanup.
Radiation' safety people who cover the analytical lab do not know what to look for.
Radiation Safety visits were rare and they never got
~after people and. told them'to decontaminate.
Discussion License Condition 9 requires that licensed material be used in accordance with statements, representations and conditions of Part I of the licensee's application.
Part I, Section 3.2.4.6 discusses the minimum frequency, action ' limits for removable surface cor tamination, and maximum delay permitted in initiating decontamination action.
Plant Procedure Nqclear Safety Instruction 0-6.0, Rev. 14, Contamina-tion Measurement and Control, provides the guidelines for the conduct of the contamination measurement program, evaluation and documentation
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of the results and the required action based upon the contamination survey findings.
The inspector reviewed the weekly contamination survey results for 1984 and the -licensee performed special surface contamination surveys, under the direct observation of the inspector.
The inspector discussed the frequency, scope and time of day of the surveys with licensee representatives.
Twelve CHEMET Lab personnel were questioned concerning the frequency of surveys by the radiation safety staff and the timeliness of decontamination if contamination was identified during the survey. All twelve individuals indicated when' radiation safety identified a contaminated area in the lab, the lab was notified and the area was promptly cleaned up, and then resurveyed by radiation safety.
Findings This allegation was partially substantiated.
Contamination surveys were performed at the minimum frequency required by the license. The inspector found no evidence which would indicate that radiation safety did not notify the laboratory of contamination and that decontamination was not initiated within the time limit imposed by the license.
Licensee representatives stated that the CHEMET lab surveys were performed weekly on the day shift. If an individual was assigned to a back shift in the CHEMET Lab, he might conclude that radiation safety didn't perform frequent surveys in the Lab.
The review of the contamination survey results and observations by the inspector indicate that surveys performed by the radiation safety technicians are
-generally in the same locations which are often not the areas with the highest potential for becoming contaminated. The inspector stated that the licensee should familiarize the radiation safety technicians with the operations in the CHEMET Lab so that they can ensure that they survey those areas where the - potential for spills exist (sample preparation nea, weighing area, etc.). Random surveys for contamina-tion shodd be performed at least daily and detailed surveys of the entire lab should be performed weekly since the licensee utilizes the same administrative limits for contamination as are required for uncontrolled areas and there is a greater potential for a contaminating event. The licensee has no policy requiring notification of radiation safety in the event of a spill in the Lab. The inspector stated that the r6Jiation safety group should be notified in the event of a spill so that a survey can be performed after decontamination to ensure the area is clean prior to resuming work in the area.
A licensee -
representative stated that this area would be reviewed and appropriate actions taken. The inspector stated that this area will be reviewed daring a subsequent inspection (IFI 84-17-04).
No violations or deviations were identified.
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Allegation The 1979 change of the analytical lab from a " controlled area" to
" semi-controlled area" was a violation of the employee relations manual. Supervisor's putting the employee manual under lock and key was a violation of GE Policy.
Discussion-In discussions with licensee representatives, the inspector determined that the change -in ' the designation of the laboratory to " semi controlled" in the early 70's only involved'a change in the types of protective clothing worn. Personnel in the lab were permitted to wear lab coats and surgical gloves rather ~ than full protective clothing required in the production area.
The-inspector reviewed the GE Employee Relations Manual.
Findings This allegation was not substantiated. The change in the designation of the CHEMET, Lab is not discussed in the Employee Relations Manual.
The clothing requirements for work in the CHEMET Lab are considered acceptable to the NRC and are typical of what is used at similar NRC licensed facilities.
The accessibility of the Employee Relations Manual is a matter reserved to the licensee and is outside the purview of NRC regulations. No violations or deviations were identified.
h.
Allegation j
Spill areas, and contamination areas, were not marked off to caution other people in the analytical area.
Discussion Plant Procedures Nuclear Safety Instruction 0-6.0, Contamination Measurement and Control, requires that contamination surveys be reviewed with the foreman or supervisor of an area if contamination above the action level is found.
This action should apprise the supervisor / foreman of that part of his facility which is contaminated.
The' licensee does not have a procedural requirement, nor do they rope off or otherwise mark contamination areas.
Findings
'This allegation was substantiated.
However, the marking off of contaminated areas is not required by NRC regulations, license conditions or licensee procedures.
No violations or deviations were identified.
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' Allegation The practice of dumping heated Uranium pellets into open containers and allowing them to cool in uncovered containers outside a vented hood is unsafe.
Discussion
~ This pertains to samples of scintered pellets removed from.the LEC0 Hydrogen and Oxygen analyzers.
The inspector reviewed the technical manua'l for the LEC0 Model RR-IEN Automatic H2 Determinator and plant procedure CM&S 1.2.8.4, Rev.11, 12/16/83, Hydrogen Determination.
The analyzer is equipped with a purge _ system which is vented to an exhaust system. The analyzer raises the temperature of the pellet to approximately 1800C. During heat up the pellet fractures due to rapid therma 1 expansion.
The analyzer measures the _ hydrogen which evolves during this heating cycle. The
-inspector observed the analysis of samples using the LEC0 Hydrogen
~ Analyzer. The pellet pieces are cooled substantially before the cycle ends and the -analyzer is opened to remove the pieces. Upon removal, the' pieces are placed.in a stainless steel container for cooling.
Twelve CHEMET Lab personnel were questioned concerning the emission of fumes while the samples are cooling in the open container.
Seven of the twelve indicated that fumes were not given off during the cooling process, one individual thought fumes were a problem and four individuals had never performed the test and stated they didn't know.
Finding The allegation was not substantiated.
Based on observation by the inspector and interviews with laboratory personnel the cooling scintered pellets-in the open is not a radiological or industrial safety problem.
No violations or deviations were identified.
J.
Allegation Dichromate titrations were done in the open and not in a vented hood and this was a safety hazard.
Discussion The licensee's Chemical, Metallurgical and Spectrochemical Laboratory Manual, Section 1.2.21.6, Rev. 5, 8/25/82, Determination of Uranium by Dichromate Titration, describe the procedure for preparing the samples and performing the dichromate titration.
In step 5.1 under special precautions, the procedure states that " proper radiation protection should be taken to prevent inhalation or ingestion of solid or liquid samples containing Uranium during all handling operations." However, the procedures does not specify what specific actions should be taken.
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The procedure contains no precautions concerning the inhalation of acid
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fumes that evolve from the titration.
t Of the twelve CHEMET Lab personnel questioned concerning the evaluation
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4 of fumes from this titration, six of eight individual who have performed the titration stated that fumes are given off and most 8
believed it should be performed in a hood.
The remaining four individuals had not performed the titratiori and had no comments.
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The inspector observed a CHEMET Lab technician perform the dichromate titration and noted that fumet, although n.ot visibly could be smelled
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during the addition of concentrated acids to the sample.
Findings
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I-The al' legation was substantiated.
Based on observation by the inspector and interviews with laboratory personnel the performance of the dichromate titration outside a hood does release acid fumes into b
the laboratory in the immediate vicinity of the work area. The Uranium 3
I is in solution before the addition of : concentrated acids thus
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minimizing the possible airborne radioact'ivity hazard.
Since weekly 7
radiological contamination surveys performed by the licensee in 1984, j-b did not identify contamination above the action level at this work a
t station, the radiological hazards of working at this station are E
minimal. The only potential safety hazard is that resulting from the
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evolution of acid fumes during the titration.
In discussions with licensee management, the inspector stated that the titrations should be performed in a hood to eliminate the potential for inhaling noxious p
fumes.
During these discussions, licensee representatives stated that j
l the licensee would consider relocating the work station to a hood or installing a special exhaust system for this station.
Neither NRC J
regulations, nor license conditions address industrial safety in the 7
laboratory. This allegation was referred to OSHA.
y No violations or deviations were identified.
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Allegation 3
a While working in an uncontrolled area of the plant, the alleger found a 4
stores requisition with yellowed fingerprints on the lower right hand
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corner indicating contamination.
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i Discussion f
[s4 The inspector accompanied a licensee representative to the archives for j
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stores requisitions and had the representative pull several requisi-tions, including the one identified by the alleger.
The identified
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requisition did in f act have yellow marking on the lower right hand T
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This requisition, along with several others were surveyed for 4;
radioactivity by the inspector and none was found.
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J he exits from the : plant's controlled areas,
- Notices posted at t
- including the. CHEMET. Lab, state that equipment and material must be z
' surveyed tur radiation protection prior to. unconditioaed release.
.During tours! of - the plant, the :inspectorn noted 'that the posted instructionsiatLthe exits from the' controlled are'as did ' notl specify what > survey requirements should - be followed. when - removing paper, 1
. notebooks and personal items from the~ controlled area.
In. di scussions -
with the -inspector, a licensee t representative stated that small items such as paper,' notebooks and personal items should be surveyed by the.
- individual prior to exiting the. controlled area and that at one time
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- signs to this effect
- were posted at the exits. The licensee repre-
. sentative stated that signs specifying the survey' requirements for all Ematerial,and equipment _would be reposted.~
Findings "The. allegation was not substantiated. The inspector found no evidence
, hich would indicate contaminated material is being removed from the w
controlled area without proper controls.
No-violations cr-deviations were~ identified.
1.
iA11egation Some~ 1aboratory personnel were not' monitoring themselves for contamina-tion when leaving the job at the end of their.workshifts.
Discussion Plant Procedure' Nuclear. Safety Release 6.1.0, Revision 4, Radiological LSafety for the.-CHEMET Lab, specifies that all personnel exiting from the laboratory controlled area must monitor themselves for radioactive
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hl contami nati on.-
The general -consensus of -the individuals from the CHEMET Lab who were interviewed was that visitors -to the lab are the ones in 'the past who
' have failed to monitor themselves when they exited the laboratory. The interviewees indicated that the violators of the monitoring requirement were Lgenerally individuals' who entered the laboratory to deliver, or pickup paperwork-or to discuss sample. results with laboratory supervisors and who did not enter the potentially contaminated part of cthe lab.
Interviewees indicated that the number of ' individuals who.
.were observed leaving the lab without monitoring has diminished and it
-is a rare occasion that individuals have to be stopped and asked to return to monitor-properly.
cThe~ inspector, from an inconspicuous vantage point, observed the CHEMET
. Lab controlled area exit point, on several ' occasions during the inspection to determine if individuals were exiting the area without
- performing proper monitoring.
These observations were made on all
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shifts and especially at times when the number of personnel exiting k.-
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.would t$e the [ highest (e.g., end of shift and at meal times). The inspector did not observe anyone exiting from the CHEMET Lab without performing a proper survey.
In discussions with the inspector, a licensee representative stated
.that the radiation protection staff-had performed more than 1000 special surveys of personnel after they had monitored themselves and have identified one individual with detectable contamination.
This individual had exited the production area. The surveys are unannounced and personnel are randomly ' selected.
The licensee has established
- disciplinary action for personnel who are observed not frisking or who frisk improperly as determined by the detection of. contamination on personnel by the radiation protection staff during the special checks.
Finding The allegation was not substantiated. The inspector did not observe, nor did he find any evidence which would indicate individuals are exiting the controlled area without monitoring properly.
No violations or deviations were identified.
m.
Allegation Answers to radiation safety tests are available before the test is given.
Discussion A total of twelve CHEMET Lab personnel wehe questioned concerning the availability of answers to the radiation safety exam prior to taking the test, the instructor teaching the test or specifically identifying answers to' test questions during the training or cheating during the exam. Ten of the twelve indi'iduals indicated that they did not know of answers to the test being made available prior to the test, the instructor pointing out answers to. specific test questions during training or cheating during the test. One individual indicated he had observed cheating during a past test and another individual indicated that the answers to the test were available-before the test a number of years ago. In discussion with licensee representatives, the inspector ascertained that the licensee administers a written exam enly after the employee's initial radiation safety training.
No exam is required following the annual retraining.
Finding The allegation was not substantiated. The inspector found no evidence which would indicate answers to test questions are systematically provided to trainees prior to radiation safety training. While the NRC does not condone cheating on an examination neither NRC regulations nor license conditions require the licensee to administer a written a
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12 examination following training.
- The written examination is a self-imposed licensee requirement.
No violations or deviations were identified.
n.
. Allegation The alleger has byen furnished incomplete. radiation exposure results.
L The record is incomplete for film badge (or TLD), urinalysis, and whole body count results.
Discussion i
10 CFR 19.13(b) requires that at the request of any_ worker, each licensee shall advise such worker annually of the worker's exposure to radiation or radioactive material as shown.in records maintained by the licensee pursuant to paragraph 20.401(a).and (c),
I requires at the request of a worker formerly engaged in licensed activities controlled by the licensee, that each licensee furnish to
-the worker.a report of the worker's exposure to radiation or radio-active material.
Such reports shall be furnished within 30 days from the _ time 'the request is made, or within 30 ' days after - the exposure of the individual has been determined by the licensee, whichever is later.
Plant Procedure Nuclear Safety Instruction E-6.0, Rev.11, Personnel Dose Reporting, requires that a worker be provided a report of his radiation exposure within 30 days of the request. Although how the request should be made is not specified in the procedure, discussions with licensee representatives indicate that the worker is asked to make the request in writing, so' that compliance with 10 CFR 19.13 can be formally documented.
The inspector reviewed the exposure record $ for the alleger and several other_ licensee employees who worked in licensed activities.
The inspector noted that radiation exposure data (film badge or TLD) for the period prior to 1976 was not available'for personnel who worked in the CHEMET lab. In discussions with the inspector, a licensee repre-sentative stated that he believes CHEMET lab personnel were not issued film badges prior to 1976. However, the film badge issue records were at another licensee facility being microfiched and not available for review.
10 CFR 20.202(a) requires that each licensee supply appropriate personnel monitoring equipment to, and require the use of such equipment by each for individuals who enter a restricted area under 'such circumstances that he receive, or is likely to receive, a dose in a calendar quarter in excess of 25 percent of the applicable value specified in paragraph (a) of 20.101. In reviewing the exposure data for CHEMET Lab personnel since 1976, it appears that personnel monitoring required by 10 CFR 20.202 probably would not have been required by CHEMET Lab personnel. However, if dosimetry was provided, then the licensee is required to include the results in any report to the individual or the NRC.
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13 The licensee uses an assigned airborne exposure value derived from the time' spent; in the work area and the air concentration measured in the work area to determine compliance with 10 CFR 20'103(b) and to calculate: the internal dose assigned to the individual. During the review of the exposure records for CHEMET Lab. personnel, the inspector
~-noted that the data for -the period of February 1979 through May 1982
~
-was omitted from the data available on some. individuals. The licensee determined that the omission of L the data was the result of a change over in computer programs, and that the data for the period was available.
A licensee representative stated that the assignment-of sairborne exposures of personnel in the CHEMET Lab began in late 1973.
However, during-the inspection the licensee could not provide evidence that would establish the starting date for the assigned airborne program.
'In. addition to using suitable measurements of concentration of radio-active materials in -air for detecting and evaluating airborne radio-activity in restricted areas, 10 CFR 20.103(a)(3) requires the licensee 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 timely detection and assessment of individual intakes of radioactivity by exposed individuals. Paragraph 3.2._4.3.3 of Part 1, to the licensee's application for license renewal specifies that. routine in-vivo lung counting frequencies are established for individuals who normally work in areas where nontransportable uranium compounds are provided.
Individuals are scheduled for in vivo lung counting based upon their airborne exposure assignments and previous counting results. Plant Procedure and Practices 40-19, Bioassay Program, implements the license requirement.
-The alleger received an annual whole body count from 1977 through 1984.
All were reported on the exposure report provided to the alleger.
Licensee representatives, in discussions with the inspector, stated that they believe that the licensee began using whole body counts for evaluating the uptake of insoluble radioactivity in 1977.
- However, they could not provide any evidence to support this belief.
Nuclear Safety Release 0-2.0, Bioassay Urinalysis Program implements the licensee's internal monitoring program for assessing the uptake of soluble radioactive material.
Appendix A,
Paragraph D of this procedure specifies the frequency of sampling for CHEMET Lab personnel.
The inspector reviewed the urinalysis data provided to the allecer in the' termination report.
During this review, the inspector noted that the data for the exposure period prior to January 1983 was not included.
In discussions with licensee representatives the inspector was informed that the prior data was not included in the computer and therefore was not 'a part of the report.
However, the licensee S
representative stated that the results of urinalysis performed prior to 1983 for the CHEMET Lab personnel were available in hard copy and could be included in the report. Due to the low levels normally reported for
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CHEMET Lab personnel, adding the results probably would not alter the
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final estimate of internal dose reported for the alleger. However, the inspector stated that a complete report of bioassay results should be provided to each individual who requests the report or who-terminates.
The-inspector stated that failure to provide a worker with a complete report of exposure to radiation or radioactive material as shown in records maintained-by the' licensee pursuant _to 20.401(a) and (c) would be a violation of - 10 CFR.19.13(a).
The 1'nspector stated that this
' issue would be unresolved
- pending establishment by the licensee of the dates when. whole body counts, external monitoring, urinalysis and
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assigned airborne programs began and the preparation of revised dose reports for CHEMET Lab personnel and a review of the reports during a subsequent inspection (84-17-01).
~10 CFR -'20.408(b) requires that when an individual terminates employ-
.g ment, the licensee furnish the NRC with a, report of the individual's exposure within 30 days after the exposure of the individual has.been determinec.
On July 26, 1984, a licensee employee te minated.
The individual's exposure had been determined on July.17, 1984. On this-date, a report of' exposure was provided to the individual at their request. The date of last exposure was in March, 1984. The report of the individual's -
exposure sent to the NRC was dated October 19, 1984, 94 days after the exposure of-the individual was determined.
The inspector stated that c
failure of the licensee to submit the exposure report of a terminated employee within 30 days after the exposure was determined is a viola-tion of 10 CFR 20.408(b) (84-17-02).
Finding This allegation was substantiated. The licensee did not provide the alleger with complete urinalysis results, in that available data prior to 1983 was not included. Also, the assigned airborne exposure data
'for t'1e period of ' March 1979 through May 1982 was erroneously omitted from the exposure report. The extent to which data required to be
-provided the individual by NRC regulations was omitted is an unresolved issue until the licensee provides documentation establishing the starting dates for performing whole body counts, assigned airborne exposure determinations, TLD/ film badge issue and
'the performance of urinalysis and the information is reviewed by the inspector.
A violation of NRC requirements to submit termination reports to the NRC'in a timely manner was identified during the review of this allegation, although timely reporting of information was not a part of this allegation.
- Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
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Allegation An airborne hazard was created when bubbly hot uranium material was removed from a microwave oven and allowed to cool in the open and not in a vented hood.
Discussion Licensee procedure Calibration and Operation Instruction (COI) 409,-
Revision 2, 7/25/84, Isotopic and U/0 Preparation Using Gravimetric Techniques, Steps 3.9 requires that the crucible be covered immediately after the addition of nitric acid.
Step 3.11 of COI 409 requires the tray of crucibles to be removed from the microwave oven and placed in a hood to cool.
Three of the twelve CHEMET Lab personnel (nterviewed commented on the location of the cooling rack for samples removed from the microwave.
The three individuals indicated that up until early 1984 the cooling rack set outside the hood next to the microwave oven. In early 1984 it was placed in the hood. A total of twelve CHEMET Lab personnel were asled if they had noted any problems with fumes coming from the microwave oven during heating or while samples were being cooled outside the hood. One individual indicated he had a nasal rash 4 or 5 years ago as a result of nitric acid fumes, however since they started covering the crucibles with a watch glass after the addition of nitric acid he has not had a problem. Another individual stated that he had noted a problem with acid fumes one time when the hood was not working.
However, the supervisor took prompt action.to get the hood ventilation system restored. The remaining 10 individuals stated that they had not noted any problems with fumes from cooling, samples.
During the inspection, the inspector used a smoke tube to evaluate the air flow in the vicinity of the hood and microwave oven.
Smoke discharged in the immediate vicinity of the microwave oven door is drawn into the microwave by the exhaust system installed to remove any fumes generated during heating of samples.
The flow in the work area around the microwave oven is toward the wall behind the microwave, up toward the ceiling and generally away from personnel who might be in the area of the microwave oven.
The inspector reviewed the bioassay data for selected personnel assigned to the CHEMET Lab. During the review of results of the weekly urinalysis for personnel in the CHEMET Lab for 1984, the inspector noted that 20 out of 28 individuals checked had at least one positive urinalysis result (greater than the minimum detectable activity value of 5 micrograms per liter). The highest value noted was 19 micrograms per liter. This value is well below NRC internal exposure limits and the licensee's action level. There was not a significant difference in the number of positive results bafore and after the cooling rack was placed in the hood, which would indicate the small intake of radioactive material occurred as the result of other activities in the e
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16 lab._ A review of whole body counts indicated that depositions of radioactivity by CHEMET Lab personnel have been less than the minimum detectable level of the _ whole body counter of approximately 75 micrograms of Uranium 235.
The general-air flow from the area of the microwave oven is toward the intake of the recirculation system. A review of results of contamina-tion surveys performed while the cooling rack was outside the hood indicated that contamination has not been found along the path of the air toward the air recirculation system intake. At the request of the inspector and under the direct observation of the inspector, the licensee performed a surface contamination survey in the recirculation system intake ducts prior to the high efficiency filters. The highest survey result was 300 dpm/100 cm? These results indicate that general airborne radioactivity levels in the lab have been minimal.
The reci-culation system has been in operation since the lab started up.
Licensee representatives stated that the duct work had never been decontaminated.
The contamination is probably the result of a gradual buildup over the years since the sys'.em was placed in service, r
The contamination levels were very low, in fact Licence Conditions would permit this duct work to be released for unrestricted use.
Findings The allegation was not substantiated.
The inspector could find no evidence which would substantiate the allegation that' an airborne hazard was created by cooling samples outside a hood. Bioassay data indicate that uptakes of radioactivity by CHEMET Lab personnel have been very small and in most cases not significantly greater than the minimum detectable level for the instrurrent used for the analysis. Interviews with laboratory personnel indicated that only one individual noted fumes evolving from cooling samples, particularly since the use of watch glass covers over the crucibles was initiated several years ago.
Interviews with lab personnel indicated that the cooling rack was located next to the microwave oven and outside a hood for an undetermined period of time prior to early 1984.
The current revision of Procedure COI 409 (Revision 2) and previous revisions of the procedure required the samples to be removed from the microwave and placed in a hood for cooling. During unannounced tours of the laboratory, the inspector observed that the cooling rack was in the hood as required by procedure. No violations or deviations were identified.
Air sampling in the CHEMET Lab was reviewed during an inspection performed September 17-21,1984 (Inspection Report 70-1113/84-13). An unresolved item was identified.
Followup on this item is discuss in Paragraph 6 af this report.
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Air Sampling in the CHEMET' Laboratory Air - sampling in the CHEMET' Lab was identified as an unresolved _-item in Region II Inspection Report 70-1113/84-13,. pending a review of ' the documentation.which the licensee indicated would furnish information on evaluations made to determine the air sampling program in the CHEMET Lab.
Followup Lon the allegations listed below resulted in the identification of the unresolved item:
a.
-An airborne haza'rd was' created when bubbly hot -uranium material was removed from a, microwave oven and allowed to cool in the open and not on a vented hood,.
~b.
leaks around ~ the ' microwave oven, used for dissolution of uranium samples in crucibles, created an airborne hazard from uranium gas vapors, and c.
uranium powers were _ dumped from crucibles outside hoods causing airborne contamination and surface area contamination and supervision was-reluctant to do anything about it.
10 CFR 20.103(a)(3) requires the licensee to use suitable measurements of concentration of. radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
The_ licensee's air sampling program in the' main work area of the CHEMET Lab
~is a single air. sampler located approximately seven feet off the floor in the north west corner of the' lab. 'The filters are removed ecch shift and analyzed.
The inspector reviewed the contamination surveys performed by the licensee l
in the CHEMET Lab in 1984, air sample results-for 1984, and interviewed laboratory personnel concerning operations in the lab.
The inspector also used a smoke' tube to evaluate the flow of air.around the work stations where uncontained Uranium was handled.
During tours of the lab, and through interviews with lab personnel the inspector determined that operations such as sample preparation and powder weighing take ' place at locations-far removed from the single air sampler.
During review of the contamination survey data for 1984, the inspector noted
-that sample preparation areas-(work bench and floor) in the vicinity of hood number 1 and the weighing ' stations are areas where loose surface
. contamination has been identified above the licensee's administrative action level for initiating cleanup.
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The air flow studies performed by the inspecter showed that air flow in the lab -is' away from the air sampler, even 'at the work stations in the immediate
-vicinity of the air - sampler.
The air flow ' studies also indicated that airborne radioactivity 'if it occurred' would probably remain in the general area of the individual performing weighing operations,at several places in the lab because of the partial enclosure around the balances. In discussion-with licensee representatives, the inspector ascertained that the CHEMET Lab exhaust sentilation system had been modified within the past year. This system exhausts through the various hoods in the lab and 'is the principal air exhaust system for the lab. In addition, the lab has'an approximately-
.5000 cfm recirculation system for_ general room air, which has several air registers above the grated ceiling in the lab and -a - single air return located on the north east corner of the lab. The inspector stated that air samplers L50uld be located in the areas of the lab where potential exists
- for the mater.ial handled to become airborne, such as sample preparation areas, areas.where. samples are heated to high temperatures and weighing stations, and: that the - air samplers should be located where the sample collected is representative of the airborne concentrations breathed by the worker. Since~ the ventilation. system had been modified 'after the previous evaluation of air sampling in the -lab, that study was not considered relev' ant. The inspector stated that failure to make suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in the CHEMET Lab was a violation of 10 CFR 20.103(a)(3).
(84-17-03).
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