ML20151S448

Insp Rept 70-1113/88-08 on 880523-27.Violations Noted.Major Areas Inspected:Radiation Protection Program Areas,Including Radiation Protection Staff Organization & Training,Solid Radwaste Issues & Transportation Activities

ML20151S448
Person / Time
Site:	07001113
Issue date:	07/27/1988
From:	Hosey C, Kuzo G, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151S435	List: ML20151S431 ML20151S436 ML20151S448
References
70-1113-88-08, 70-1113-88-8, NUDOCS 8808150202
Download: ML20151S448 (16)

Text

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' s R Cfo . UNITED STATES o NUCLEAR REGULATORY COMMISSION 1

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, REGION li 101 MARIETTA STREET, N.W.

ATLANTA, GEORGI A 30323 '

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f JUL 2 71988 Report.No.: 70-1113/88-08 q

' Licensee: . General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conducted: May 23-27, 1988 Inspectors: bted 8 Me - 0S NM83 G. 8. Kuzo Date Signed

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M. T. Lager Phks*

(Tate Signed Approved by: M W C. M. Hosey, SectMon Chief 7/W/8 Date 5fgned ,

Division of Radiat' ion Safety and Safeguards

SUMMARY

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Scope: This routine - unannounced inspection involved review of radiation protection program ar,eas in_cluding radiation protection staff organization and training, radioactive contamination control, internal and external exposure evaluations, radioactive waste management, solid radioactive waste issues, transportation activities, and review of the ifcensee's actions regarding p(reviously ins).

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identified followup items, allegations, and NRC Information Notices Results: For the areas reviewed, the licensee's radiation protection program associated with waste processing, transportation activities, and "in vivo" (lung counting) analyses appeared well managed and technically adequate.

-Weaknesses rec uiring increased management attention included 3rocedural noncompliance ay personnel for radiation control activities anc inadequate evaluations of positive urinalysis results for personnel potentially exposed to airborne uranium concentrations.

Within the areas inspected, the following violations with several examples and one unresolved item were identified:

Failure to follow approved procedures for (1) conducting contamiration survey instrumentation performance checks and (2) maintaining an unattended rollup door closed between t.5e radiation controlled Old Decon Room and an adjacent uncontrolled area (Paragraph 2).

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Failure to assess of ' uranium for (1) selected properly personnel individuals expcsures to airborne having positive concentrations urinalysis sample results and (2) use of improper time interval between an exposure event and the subsequent urine sample collection (Paragraph 3.e).

Potential exposure of personnel to airborne uranium concentrations exceeding 10 CFR Part 20 limits (Paragrpah 3.e).

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a REPORT DETAILS

1. Licensee Employees Contacted D. Barbour, Supervisor, Radiation Protection

• B. Bentley, Manager, Fuel Production

• D. Brown, Manager, Uranium Recycle / Waste Treatment W. Cameron, Supervisor, Fuel Support

• W. McClanahan, Manager, Fuel Bundle Quality Control

• R. McIver, Manager, PE & M

• S. Murray, Senior Engineer, Nuclear Safety

• R. Pearson, Manager, Fuel Fabrication

• P. Stansbury, Senior Engineer, Nuclear Safety

• H. Strickler, Manager, Environmental Protection

• R. Torros, Manager, Radiation Protection

• P. Winslow, Manager, Licensing & Nuclear Material Management R. Yopp, Supervisor, Traffic Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.

Other Organizations J. Cox, Radiation Measurement Specialist, Radiation Management Corporation

• Attended exit interview

2. Tours Of The Facilities - Observation Of Radiation Control Practices (83822)

License Condition 9 of Special Nuclear Material (SNM) License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part 1 of the License Application dated October 23, 1987.

Part I, Section 2.2.1.4 of the licensee's application for license No. $NM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.

During tours of the facility, the licensee's radiological controls were evaluated in the fuel production and waste process areas; "Chemet" lat' oratory; radiation protection laboratory; Old Decon Area; and men's main change room to the process area. The following issues were reviewed in detail.

Nuclear Safety Instruction (NSI) 0-4.0, Rev. 24, dated August 24, 1987, requires all change room instrumentation to be inspected as prescribed by schedule. Appendix A of NSI 0-4.0 requires performance checks to be performed each shif t and the results entered into the instrument log.

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2 Appendix B of the procedure requires quarterly calibrations for the survey meter RM 19/20 with a AC-3 probe.

On May 23,1988, during tours of the men's change room for the main process areas, the inspector noted a personnel survey meter indicating elevated background counts, that is a count rate of approximately 300-350 counts per minute (cpm) compared to 50-100 cpm for other survey meters in the area. Review of the quality control logbook for the specific instrument indicated that background for the meter had been recorded as approximately 150 cpm and also indicated that it had alarmed at approximately 300 cpm. The inspector questioned the operability of the meter and requested licensee representatives to demonstrate that the instrument would alarm as specified using a check source. The meter failed to alarm as noted in the logbook and furthermore, had not even alarmed for a count rate greater than 400 cpm. The inspector noted that this particular instrument was utilized by personnel to survey upon leaving the change area and questioned whether the failure to alarm would have resulted in an inadequate personnel contamination survey. Licensee representatives stated that personnel were trained not to wait for an alarm but to interpret a change in the count rate of the instrument, approximately 100 cpm above background, to indicate potential contamination. In addition, licensea represent 6tives stated that random surveys are conducted after personnel leave the change room to verify that personnel contamination monitoring is adequate.

The licensee's inability to identify the degraded survey meter performance in a timely manner was discussed with the cognizant licensee manager.

Review of the survey instrument logs for survey meters in the main change room indicated numerous examples where the performance checks were being recorded once per day. Discussion with the radiation monitoring staff verified that the lack of entries in the logbook indicated that the required performance checks had not been conducted. The inspector noted that NSI 0-4.0 required checks to be conducted each shift. The failure to conduct performance checks of the personnel survey meters for each shift was identified as an apparent violation of License Condition No. 9 (70-113/88-08-01).

During tours of the facility, the inspector verified that personnel survey, radiation monitoring and airflow monitoring equipment were calibrated in accordance with approved procedures.

The inspector discussed with licensee representatives the untidiness of the main change room. The placement of receptacles for contaminated l clothes far from the step-off area between the controlled and uncontrolled l areas resulted in potentially contaminated coveralls being thrown and/or I

dragged on the floor. In addition, the inspector noted shoe covers thrown l inadvertantly in the clean uncontrolled areas while personnel were removing their protective clothing (PC). Licensee representatives stated that they were evaluating a new physical arrangement of benches and I clothing receptacles for the change room to facilitate the dress process I and improve both the cleanliness and order of the facility.

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Nuclear Safety Release / Requirement (NSR/R) Control No.1.1.23, Old Decon Room, Rev. 1, dated November 13, 1985, requires the roll up door in the Old Decon Room to remain closed except during the transfer of material to and from the Old Decon Room.

On May 23, 1988, during a tour of the Old Decon Room area, the inspector noted a flashing light which indicated that the roll up door separating the Old Decon Room, a radiation controlled area, from an uncontrolled or clean area leading to the outside environment was in the open position.

At the time potentially contaminated waste trash was stored in this area.

However, licensee personnel, excluding the licensee representative accompanying the inspector, were not present nor conducting work in the area. Licensee representative stated that the absence of personnel in the area, most likely, was a result of the normal shift change. The inspector ncted, that although no contaminated material appeared to have been moved into the uncontrolled area, the potential for unmonitored contaminated trash being moved to the uncontrolled area or, for personnel, from the uncontrolled area, to enter the Old Decon Room were increased because of the open and unattended entrance door. The licensee representative verified that the roll up door in the Old Decon Room is required by procedure to remain closed except during transfer of material to and from the old Decon Room. Failure to follow approved procedures for the Old Decon Room was an additional example of an apparent violation of License Condition No. 9 (70-113/88-08-01).

3. Radiation Control Programs (83822)

a. Organization and Staffing Current radiation monitor (RM) staffing levels and organization utilized to conduct routine radiation protection activities were reviewed with the radiation protection manager. The staff consisted of twelve radiation monitors, five radiation protection operators, a radiation protection technician, and two shift supervisors. The RMs are assigned duties in both the process areas and within the

, radiation protection laboratory. The radiation protection manager-stated that all current staff members were qualified to perform their duties and had extensive experience with radiation protection issues at the facility. Licensee representatives stated that the staff was adequate to complete the assigned duties.

! Training for the radiation protection staff was discussed in detail l with the radiation arotection manager. The RMs are required to complete eight to nine months of initial "hands-on" training, and pass a written test and oral board prior to being allowed to conduct i decision making actions regarding radiation protection activities.

Radiation protection operators initially are required to participate in a 90 day training period accompanying RMs performing routine radiation protection duties at the facility. No written tests were required for the operators, however, those personnel are not permitted to make decisions regarding health physics issues.

4 The inspector and licensee representatives discussed the use of additional training - to improve the radiation protection staff's identification of potential health physics deficiencies and to improve compliance with established ' procedures. The licensee does not conduct formal requalification training of the radiation protection staff subsequent to their initial training. The inspector noted that licensee representatives indicated that the violation concerning the failure to conduct required performance checks of survey instrumentation in the men's main change room (Paragraph 2) was attributable to the radiation protection personnel being confused about their responsibilities. In addition, the inspector questioned whether the failure of the radiation protection staff to identify

)otential survey instrument problems, tht is, consistently elevated Jackground counts for selected survey meters, indicated a need for retraining of staff. Licensee representatives stated that instructions or changes regarding radiation protection program areas are conducted through routine staff meetings and reading files. At the time of the inspection, licensee representatives stated that the improvements and the exchange of information regarding these radiation meetings. protection issues would be addressed through routine staff No violations or deviations were identified.

b. Radiation Protection Unusual Incident Report Review The inspector reviewed and discussed with cognizant licensee representatives the radiation protection unusual incident reports (UIRs) from September 1,1987 through April 30, 1988. The use of these reports is detailed by Nuclear Safety Instruction (NSI) 0-22.0 Incident Investigation, Rev. 10, dated April 28, 1988. The instruction provided guidance for identification of incidents and perturbations and their subsequent investigation, documentation, and review by the Nuclear Safety Engineering (NSE) staff.

The inspector reviewed a equipment and manufacturir,pproximately 44 UIRs g problems in the process associated areas. Of thewith UIRs reviewed, approximately 19 reports detailed elevated levels of airbnrne uranium concentrations associated with the vaporization, hydrolysis, milling and press areas. These reports were reviewed in detail with the highest assigned personnel exposure to uranium of approximately 16.9 maximum permissible concentration hours (MPC-hrs) resulting from a material leak in the vaporization area on September 23, 1987. No reports indicated estimated exposure values exceeding regulatory limits or requiring detailed evaluations as specified by the applicable sections of 10 CFR Part 20.

No violations or deviations were identified.

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-c. ' Radioactive Contamination Control Surveys The inspector reviewed and discussed with licensee representatives, alpha contamination survey results from March 1, 1988 through April 30, 1988, for selected locations within the Chemet laboratory.

The inspector verified that contamination levels were maintained below 2500 disintegrations per minute per 100 cm2 (dpm/100 cm2) and 250 dpm/100 cm2 as specified by procedures for the hood internals and all other open areas in the laboratory, respectively.

During tours of the laboratory the inspector noted a table where employees were handling selected materials, that is, pencils, papers, and calculators used in performing routine calculations without protective gloves. The inspector identified the observed work practices as having high potential for the spread of radioactive contamination to personnel and requested to review routine survey results for this area and its equipment. Licensee representatives stated that the table and equipment routinely were not surveyed but

, noted that the area was monitored on a random basis as part of discretionary surveys conducted by the RMs during the routine Chemet laboratory surveys. For the selected records reviewed, no contamination survey results for the specific area and equipment were available. Licensee representatives stated that required surveys by personnel exiting the Chemet area would have provided any indication of contamination problems for this area. However, licensee representatives agreed to survey the Table in a timely manner.

Results of the survey were not available at the end of the onsite inspection.

No violations or deviations were identified.

d. External Exposure 10 CFR 20.101 details the ap,plicable radiation dose ifmits to personnel. The inspector reviewed and discussed with the cognizant nuclear safety engineer the external exposure monitoring results from January 1,1987 to March 30, 1988. Approximately 935 employees at the facility were monitored for beta / gamma dose and the results were reported quarterly. In addition, approximately 100 of these personnel were monitored for neutron exposure. During 1987, approximately 900 persons were assigned exposures below 250 millirem (mrem) with the highest recorded exposure of 880 mrem, reported for a scanner operator assigned to quality assurance duties involving

! activity scanning of finished fuel. For the first cuarter of 1988, the highest external exposure measured was reportec as less than i 250 mrem.

No violations or deviations were identified.

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e. Internal Exposure

.The inspector reviewed and discussed licensee data regarding assigned c~

exposures to and/or intake of radioactive material by individuals based on air sampling and bioassay results. The review included both fixed air sampling data, urinalysis and lung counting results, licensee calculations of assigned exposures, and procedural action limits regarding intake of radioactive material.

(1) In Vivo lung Bioassy The inspector discussed with licensee representatives the lung counting "in vivo" analysis program used to detect and assess internally deposited radioactive materials. The onsite system is owned by the licensee but operation, technical support and detailed quality assurance review of results are provided by a licensee approved vendor. The licensee's "in vivo" detection system, f. e. lung counter, utilizes four, five inch diameter phoswich detectors mounted in a shielded bed. The current configuration of the counter allows a minimum detects.ble activity level (MdL) of approximately 50 micrograms (ug) of uranium 235 (U-235).

Part 1, Section 3.2.4.3.3 of the application for Licensc No. SNM-1097 requires that individuals assigned airborne exposures greater than 1.3 maximum permissible cancentration hours (MPC-hrs) per calendar quarter be given annual lung counts. Individuals with assigned airborne exposures of greater than 52 MPC-hrs per quarter or a previous positive count, that is, greater than the minimum dete: table level of 50 ug U-235, are required to have quarterly "in vivo" analyses. Individuals with analyses indicating lung burdens of greater than 150 ug U-235 are required to obtain lung counts on a monthly frequency.

The inspector reviewed lung count histories for selected individuals and verified that the required count frequencies were used when specified previous count results ar.d/or assigned airborne exposure totals were observed. From January 1,1988 l through May 25, 1963, licensee records indicated "in-vivo" analysis results exceeding the 150 ug U-235 control limit for 27 individuals. Licensee actions and evaluation of the l

"in-vivo" analyses limit appeared adequate.

In addition to the above action limits dictating count frequency, Part 1, Section 3.2.4.3.2 of the license application details action limits restricting individuals from working in areas containing airborne radioactive material. These work restriction action limits are specified for assigned airborne exposures greater than 40 MPC-hrs per week, 520 MPC-hrs per quarter, or an "in vivo" analysis indicating a lung burden greater than 250 ug U-235. Licensee criteria for recounts and l

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1 removal of work restrictions were reviewed and appeared adequate.

Review of relected individual lung count histories and time-in-arez records verified that individuals meeting the above criteria we e restricted from areas containing airborne radioactive naterial.

(2) Urinalysis Progn '

The inspector reviewed . the licentee's procedures, practices, records, and computerized data analysis / data stcrage system used to implement the urinalysis program for the detection and evaluation of internal exposures to airborne radioactive material. Licensee representatives stated that urinalyses are performed onsite by licensee personnel. Urine samples are chemically prepared (without chemical separation), diluted and analyzed using uranium phosphorescence analysis. The reported minimum detectable level for the analysis is 5 micrograms per liter (ug/1) of U-235 in urine.

Based, ca work location and/or special requests concerning abnormal occurrences, daily or weekly employee urinalysis sample frequencies are required by procedure. Part 1, Section 3.2.4.3.2 of the license application requires an investiga+. ion and calculation of U-235 uptake for urinel exceeding, or equal to 35 ug/l U-235 and 15 ug/yses resultsl U-235 for and weekly sample frequencies, respectively.

The inspector reviewed urinalysis data from April 1,1988 through April 30, 1988, for individuals working in areas in which daily or weekly :smpies are required by procedure and verified that appropriate sampling frequencies were used and that action limits, when exceeded, were properly investigated.

Investigation of elevated urinalysis results .for individuait whose normal job functional area (location) does not require routine daily nor weekly urine samples is discussed in Paragraph 3.e of this report.

Section 3.2.4.3.2 of the license application also requires that individuals whose calculated uptake exceeds 2.5 milligrams (mg)

U-235 in the bloed based on urinalysis results and subsequent calculations, be restricted immediately from further exposure to soluble uranium. The inspector reviewed calculated uptakes based on urinalysis results from January 4,1988 through biay 15, 1988. The hignest observed uptake, 0.86 mg U-235 was below the estab'ished action limit.

8 (3) Assessment of Urinalysis Results 10 CFR 20.103(a)(3) states that for aurposes of determining compliance with the requirements of t11s section, the licensee shall use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposed individuals.

Requirements for the assessment of urinalysis results are included in NSI No. 0.2.0, Bioassay-Urinalysis Program, Rev.15, dated January 6,1988. Appendix C of the procedure requires that to use correctly the equation for calculating u) takes of ufo or U0 F22 as derived from ANSI N341, July 1974, tie lapsed time between uranium material intake and sample co11cetion must be greater than four hours.

The licensee's computerized dose tracking system automatically "flag 15 ug /ls" and individual greaterurinalysis than or results equal togreater 35 ug/lthan or equal to if these individuals are ider.tified as workers required to submit weekly or daily urine samples, respectively, as required by procedure (Paragraph 3.e.2). Radiation protection personnel are then required to calculate uptake values using a separate computer algorithm for individuals whose results exceeded the specified action limits. The inspector independently calculated uptakes for selected urinalysis results greater than 35 ug/l and determined that on February 11, 1988, the ifcensee used a lapsed time interval between intake and sample collection of three hours for a UO F2 2 uptake calculation for a urinalysis result of 1988.

145 that ug/l submitted the failure cn February to meet the mini10' mum lapsed time intervalThe inspe s)ecified, invalidated the excretion model equation used and t1ereby, invalidated the exposure assessment conducted. The failure to assess adequately the intake of radioactivity by a person potentially exposed to airborne concentrations of U-235 was identified as an apparent violation of 10 CFR 20.103(a)(3) requirements (70-1113/88-08-02).

The inspector also reviewed year-to-date urinalysis results of individuals who do not normally work in a job functional area procedurally identified as requiring submittal of daily or

, weekly urine samples. The inspector noted that samples were l submitted by these individuals for various reasons including l working in areas affected by inadvertent releases, temporarily l working in areas with high potential for elevated airborne concentrations, or by individuals personally concerned about j their potential exposure. From a raview of licensee records, l numerous urinalysis results were noted by the inspector to have l

equalled and/or exceeded the 15 ug/l and 35 ug/l action levels

9 without the licensee assessing the exposure and/or performing intake calculations. The following were specific examples reviewed in detail by the inspector in which potential cc.tfon <

levels were exceeded but assessments were'not cenducted:

A sample result of 22 ug/l submitted on April 12,1980. A sample submitted by the worker four days earlier was reported as Minimum Detectable Limits (MDL).

A sample result of 35 ug/l submitted on April 14, 1988. A sample submitted by the worker on April 13, 1988, measured 72 ug/l and was evaluated.

A sample result of 53 ug/l submitted on A)ril 28, 1988. A sample was submitted five hours prior anc was reported as MOL.

Further review during the inspection of the calculated personnel exposures for these examples indicated no exposures in excess of 10 CFR Part 20 limits.

Licensee representatives stated that urine samples submitted by individuals not required by procedure to routinely submit daily or weekly samples, are not ' flagged" by the computer program nor by radiation protection personnel who review the urinalysis results. However, licensee representatives stated that an action limit of 36 ug/l or greater, which requires an evaluation and applies to all urino samples submitted, was instituted in 1986. Details of this action are outlined in a memo dated September 30, 1980, from a senior nuclear safety engineer to the Chemet Laboratory Manager which requested that the Chemet staff contact radiation protection when a urinalysis result is 36 ug/l or greater is observed regardless of the individuals job location. The inspector inquired as to the justification for using 36 ug/l or greater as the action limit for urinalysis results for this group of workers. The licensee was unsure of the decision criteria used in choosing this action limit and stated that a review of the adequacy of the Ifmit may be necessary.

The failure to apply and proceduralize bioassay administrative control levels for all personnel resulted in numerous licensee personnel exceeding urinalysis action limits of 15 and 35 ug/l which had been established for workers in selected job functional areas. The failure to assess these bioassay results was identified as an additional example of a violation of 10 CFR 20.103(a)(3) (70-1113/88-08-02). In addition, the inspector noted that the failure to properly assess the positive urinalyses results prevented the licensee from assigning each r individual's exposure and evaluating the results against the exposure limits specified in 10 CFR Part 20. The inspector

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10 informed the licensee that the potential for exceeding 10 CFR Part 20 exposure limits would be considered an unresolved item pending the licensee's evaluation of the exposure results (70-1113/88-08-03).

f. Respiratory Protection 10 CFR 20.103(c) details the requirements necessary for the licensee to make allowances for the use of respiratory protective equipment in estimating exposures of individuals to radioactive materials.

The inspector reviewed training and medical certification records for selected individuals exceeding the "in vivo" action limit of 150 ug discussed in Paragraph 3.e.(1) of this report. Training and medical certification for respiratar usage was current for all individuals reviewed.

4. Radioactive Waste Management (84850, 88035) 10 CFR 20.301 and 10 CFR 20.401 detail requirements for disposal of radioactive material and records of disposals. 10 CFR 20.311(d)(1) requires that the licensee prepare all waste so that the waste is classified according to 10 CFR 61.55 and meets the waste characteristics requirements in 10 CFR 61.56, 10 CFR 20.311(d)(3) requires that the licensee conduct a quality control program to assure compliance with 10 CFR 61.55 and 10 CFR 61.56, and the prcgram must include management evaluation of audits.

The licensee's method of demonstrating compliance to 10 CFR 61.55 utilizes classification by source and gross radioactivity measurements both of which are approved methods for waste classification as per NRC',s Office of Nuclear Material Safety and Safeguards Branch Technical Position, dated May 1983. Specifically, a NaI detector is used to detect gamma rays produced by a uranium daughter product radionuc:ide. The packed waste box is rotated in front of the detector. Because only slightly enriched uranium is processed at the facility, the boxes are only assayed to determine the amount of U-235 and U-238 within the waste. The licensee stated that only Class A unstable waste has been shipped for disposal in the past year. Stability of the waste is achieved with the disposal container as per 10 CFR 61.56(b)(1). An engineering evaluation was conducted for the type of disposal container used by the licensee and is discussed in Paragraph 5 of this report. Waste manifests reviewed by the inspector contained all of the information required by 10 CFR 20.311.

Specific manifests reviewed are listed in Paragraph 5. The inspector reviewed internal audits of the waste program dated September 20, 1987, and December 17, 1987. In addition, larger scale audits by an independent group previously conducted annually now are conducted every two years.

The inspector reviewed the annual audits conducted in 1985 and 1986. All audits reviewed were found to cover appropriate program areas, contain management review and include documentation of completed corrective action. Licensee representatives stated that as of May 23, 1988, 69 waste

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boxes (51.3 ft.3 per box) were being stored onsite awaiting'shipent for offsite disposal. '

No violations or deviations were identified.

5. Inspection of Transportatfor Activities (86740) 10 CFR 71.5 requires that each licensee who transports licensed material outside of the confines of its plant or other place of use, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of 00T in 49 CFR Parts 170 through 189. The following shipments were reviewed for the existence and adequacy of waste classification, package labeling, package radiation monitoring, cod shipping paper documentation:

Shipment No. 859253-3, August 18, 1987. 16 metal ooxes.

0.3 mrem /hr. at surface of vehicle. Listed as Radioactive Material, LSA, N.O.S UN2912.

Shipment No. 859253-12, March 22, 1988. 12 metei boxes with contaminated shop material. 0.02 mrem /hr at surface of vehicle.

Listed as Radioactive Material, LSA, N.0.5 UN2912.

Shipment No. 859253-13, May 17,1988. 17 metal boxes with shop material and incinerator ash. 0.3 mrem /hr at surface of vehicle.

Listed as Radioactive Material, LSA, N.0.S UN2912.

All shipments reviewed met NRC, 00T, ~, licensee procedure requirements.

NSI Nc. 0-17.0, Rev. 15, Shipment and Receipt of Radioactive riaterials and Shipping Containers, November 19, 1987, requires radiation surveys of incoming shipments within three hours of receipt during normal working hours and within 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> after normal workina hours as dictated by 10 CFR 20.205(b). The inspector reviewed selected incoming survey tin,es against receipt times on receiving papers and verified that surveys were performed within the time limit. During discussions with licensee representatives the inspector determined that some procedural clarification by the licensee of regular and non-regular working hours is

n. fed. Licensee representatives stated that they would assess the need fo ;1arification of these terms and take action as needed.

The inspector reviewed a Compliance Test Report dated August 2, 1984, use, to demonstrate compliance with 49 CFR 173.465, Type A packaging tests. Na concerns were identified. The licensee's Traffic Supervisor recently completed a week long course on shipping manifest completion for .

radioactive and hazardous materials. This individual is solely responsible for manifest completion at this facility.

The licensee's transportation program was indicative of management l committed to assuring the regulatory compliance and safety of radioactive l material shipments.

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6 .-- Inspector Followup Item (IFI) Review (92701)

(Closed) IFI 70-1113/86-22-16, Include an Evaluation of Cardiac Function in Medical Examinations for Fire Brigade Members.

An Operational Safety Assessment identified that the medical examinations required for fire brigade members did not evaluate the cardiac response to stresses encountered during firefighting exercises. The licensee reviewed the ass.igned function of their onsite fire brigades. Fire brigade members now are trained to respond only to small incipient fires. The licensee has not committed to perform a cardiac functional test on each fire brigade member, except where warranted by the physician.

7. Allegation Followup (99014)

a. Allegation No. RII 87-A-0114 On an unspecified date a new fuel shipment from General Electric, Wilmington, NC, to Hope Creek 1 Nuclear Power Plant, Salem, New Jersey, was found to contain a "hot spot" on the inside of a shipping container upon its arrival at the site. The alleger believed that the hot spot was caused by a hot particle, specifically activated zirconium. The alleger also expressed concern regarding exposure estimates for individuals exposed during transit and during receipt / handling at the site.

b. Discussion and Findings Pertinent information and the alleger's concerns were transmitted to the licensee with a request for an investigation and subsequent response. The licensee s response dated April 5,1988, partially subetantiated the allegat:on and indicated that the licensee was knowledgeable of a fuel bundle ihipping container received by the Hope Creek P? ant on October 31, 1985, in which higher than background radiation readings were observed. The licensee's investigation was thorough. The licensee's investigation indicated that the carticle had been on the box when it was returned to GE from a nuclear power station. The licenser.'s corrective action as stated in the April 5, 1988, response, was reviewed ducing the inspection and determined to be adequate and comalete. The licensee established a beta gamma survey of the shipping containers prior to reuse. The licensee's findings indicated that the container in question was returned to their facility. Upon receipt, a small silver-colored metal shaving measuring approximately 200 by 600 microns, as determined by electron microscope examination, was removed from the inside of the shipping container. Contact radiations levels on the particle measured 6 mram/h. Inferred dose rates outside the shipping container would have been negligible, within DOT regulations, and would have had an insignificant impact on collective dose to individuals during

13 transport and during container receipt / handling at the site. A spectral analysis by the licensee indicated that the particle was Co-60, having approximately 0.1 microcuries (uCi) of activity.

No violations or deviations were identified.

8. NRC Information Notices (ins) (92717)

The inspector determined that the following NRC Information Notices (ins) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that actions, as appropriate, were taken or scheduled.

a. IN 87-03; Segregation of Hazardous and Low - Level Radioactive Wastes

b. IN 8, /S: Cracks in Stiffing Rings on 48 - Inch-Of arreter UF6 Cylin' rs

c. IN 87-31: 81ocking, Bracing, and Securing of Radioactive Materials Packages in Transportation

d. IN 88-02: Lost or Stolen Gauges

e. IN 88-08: Chemical Reactions with Radioactive Waste Solidification Agents

9. Exit Interview (30703)

The inspection scope and findincs were summarized on May 26, 1988, with those persons indicated in Parag~raph 1. The inspector discussed the areas inspected in detail. Apparent violations concerning the failure to follow approved procedures for radiation control activities and the failure to conduct proper evaluations for selected groups of personnel potentially exposed to concentrations of airborne uranium material were discussed.

The potential for overexposure by personnel who were not evaluated was identified as an unresolved item pending further review by the licensee.

Licensee representatives acknowledged the inspector's comments. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.

Item Number Description and Reference 70-1113/88-08-01 Violation - Failure to follow approved procedures for (1) conducting contamination survey instrumentation performance checks and (2) maintaining an unattended roll up door closed between the radiation controlled Old Decon Room and an adjacent uncontrolled area (Paragraph 2).

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y 70-1113/88-08-02 Failure to assess properly personnel exposures to airborne concentrations of uranium - = for (1) selected individuals' havin '

urinalysis sample results and (2)g.usepositive of improper time interval between an exposure event and the subsequent urine sample collection (Paragraph.3.e).

7n-1113/88-08-03 Unresolved Item - Potential exposure of personnel to airborne uranium contentrations exceeding 10 CFR Part 20 limits (Paragrap,h 3.c).

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