ML20154G098

Forwards Detailed Info to Suppl 880425 Presentation Made at Region I Re Insp Rept 70-0361/88-02

ML20154G098
Person / Time
Site:	07000371
Issue date:	04/22/1988
From:	Kaufman N UNC, INC. (FORMERLY UNC RESOURCES, INC.)
To:	Congel F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20154G090	List: ML20154G086 ML20154G094 ML20154G098
References
NUDOCS 8805240220
Download: ML20154G098 (74)

Text

"

N.C. Kaufman o,nwt UiiC NavalProducts

?"L".a'.':='

u cas e c m e v : m w

.T 3 6491!11 April 22,1988 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Attention:

Mr. Frank J. Congel, Acting Director Division of Radiation Safety and Safeguards Gentlemen:

Subject:

Inspection Report No. 70-371/88-02 Please find attached detailed information to supplement the presentation made at Region I with respect to the subject inspection report on April 25, 1988.

This information is presented to assist in clarifying classification of the audit findings.

Sincerely,

// '

d'~

bl Attachment 8805240220 890516 PDR ADOCK 07000371 A(WC Corcey

$NLU Ub

L

. i,

o NRC INSPECTION 70-371/88-02 UNC NAVAL PRODUCTS BETAILEDINFORMATION ADDRESSING INSPECTION ITEMS

\\

s e

INSPECTION ITEM 70-371/88-02-01

F -

'.%\\i

-o ETEM DESq8IPTION i

/

(70-371/88-02-01) Antindividual received 48 1 MPC-hours in a 7 day per'iod.

-10CFR20.1.Pd(b) ( 2 ) requires expostges in excess of 40 MPC-hours in 7 days)to have evaluations madrg and proper records maintained of such evaluations.

The inspection states that the evaluation performed was inadequate in that it failed to\\1dentify the root caust or to specify what actions were taken to prevent, recurrence.

It also implies that the record kept did not meet the 10CFR record keeping requirements.

UNC RESPONSE 1C agrees with the inspector's observation that an individual was xposed to greater than 40 MPC-hours in seven consecutive days.

This Information was documented on a UNC MPC-hour tracking sheet set up specifically for the individual and was reviewed by the inspector in records made available in the Health Physics Laboratory.

Additional information and comment is provided.

1.

/ Following the inspector's initial comments on this situation an evaluation folder was immediately presented for review from the Health Physics Office incident file.

This file contained copies of pertinent air sample data, MPC tracking log, all'available machine use logs for the evaluation period, ahd a. summary review (attached) of a management reeting held on 12/3/86 to evaluate this incident.

The MPC data was, presented and reviewed in conjunction with the operator who did the work, an individual not normally assigrted to this operation; management was reminded of twi apparently similar past situations when MPC hours were t

accumulated in similar circumstances.

The requirement to keep excosure below 40 MPC-hours in any seven days was g

emphasized. Engineering controls both taken and planned were discussed.

In order to maintain ALhRA below 40 MPC-hours as

'well as a maximum of 520 MPC-hours '.h any week, Operations personnel were reminded of the possible effects of work time limitations, respirator use and increased surveillance.

2.

Regarding the inspection report note on the recommendation for an in-line blower...

This suggestion was made by the Production Supervisor to Facilities Engineering independently and prior to the management meeting.

Engineering stated that in this case the booster by itself would not have the desired effect.

In a different situation l

a booster fan was installed by Engineering as a succestful engineered control and the production supervisor was /

relating to this.

J.<.

l

9

\\

O 3.

Regarding the incpsction report noto that the evaluation was ir.cdsquats... The equipment (the shear in sectioning) that was the source of the exposure had been the subject of a continking evaluation and incremental corrective actions aimed at reducing the airborne material and worker exposures!

Thus, the lack of a definitive report for this specific instance is not indicative of a failure to address the situation and to take corrective action.

In addition, Health Physics Inspection Report 86-11 (attached) further documented in Item C.2. and highlighted for management awareness the unsatisfactory airborne control for the shear operation during this period.

The root cause of this incident was the temporary assignment of an employee to B-South machining operations.

Althcugh he had performed machining operations (shear work) outside B-South, and was being trained by experienced operators, the additional cleaning and handling required for successful use of the B-South shear must be developed through practice and on-the-job training.

Corrective action in terms of increased on-the-job training and better personnel selection was taken.

The effectiveness of this corrective action is best demonstrated by the fact that the incident occurred in November, 1986 and as discussed in the inspectors report, no further accumulations of >40 MPC hours have occurred since then.

The shear operation continues to be addressed by UNC.

Room has been made,available in the work area by moving equipment and engineering, as part of a containment upgrade, can now relocate the machine closer to tha main exhaust lines and introduce additional engineering controls.

The records, though handwritten, were in a complete file of the incident, and considered to.be records of such occurrences, evaluations, and actions taken in a clear and readily identifiable form suitable for summary review and evaluation.

T/C CONCLUSION 1

Fi believe that our actions and practices were in full compliance with the NRC license and 10CFR.

UNC ACTION We will develop and implement a checklist / action form for investigations of this nature.

d...:.skitunc nsOnt paooucvs. 45 7.-

ik.4

.l -wg V :.

l 70-371/88-02-01 oevi on or unc n.soure... inc. : o j.4.'s7 sancy oese<t nood ' 4' '

8 Uf1C a e f

,',!,lI*Y.'.%,f56.ME ' } 'l unc ima.;cg,cycupass2.osei ~

Tei pnon. 203/84s.isii Memoranduin NIS-86-12-17 Ta D.

McFadden osie: December 16, 1986 rrorrt D.

R.. Luster sveject HEALTH PHYSICS INSPECTION NUMBER 86-11 Attached is the 12-4-86 Health Physics inspection with actions requested. If you have any questions, please call on Ext. 2561.

This audit will remain in an "Open" status until recommen-dations are committed for resoultion or are resolved. A written. reply is requested.within three (3) weeks of receipt of this inspection report by those designated with ". Responsibility".in the detailed report.

Responses are to be in one of the two formats as appli-cable:

1.

Recommendation (s) accepted and the acti6n(s) stated below have been completed or will be completed by

4. -a, -

...~ r 2.

Do not agree with recommended action. Request a re-evaluation of the recommended action because of the reasons stated below.

N D. R.

LUSTER, Specialist Radiological and Environmental Control DRL/jmp Attachments cc:

J. Wilkinson N.. Grenon J. Brady P.

Fuery M.

Cassidy H.P.

Lab.

maee e eae

-),

,, j.,

HEAI.T YSICS, INSPECTION NO.

/

A R E A _$p ftnutun l l) 2 C. 0A/ '

Performed Bys Doy L ts A fe M 4y 4.*

d.,.

..y fs{:M.r

'-s.,. Production Mana ement U^

IA '.

~

. Contact C,.$,a v e r' ?

T,

(*. e ll s o V

f (0 f.s.

y.. t v.p '.

., *%

.s:

. 4}?

~*

SL. f.

c.

..lo.. fi

(..,

yollow up Memo No.

y/3 l f5 6 - ll - / 7 INSPECTION ITEM "3

.C.

A.

Area Remarks / Action 1.

Protective Clothing

[

2.

Personnel Monitoring Equipment 3.

Air Samplers

[

shear da g er pisTe pse m Ily slosed 4.

Process Equipment U

Uu n'd ou ti D e) h e tile tx decoa 5.

Contaminated Waste Handling U

R elea s e So o m 6 South 5 n o t ro c.

acoA 6.

Training / Awareness O

b e l'I le

[e y p e sa / i M e hver Iwq cav##v5 B.

General Inspection Items 1.

New or Modified Operations e e-.v,

e.-

srP-i.e. + If Idb c8d 2.

Unusual occurrences e em paci,e cJ4c : #

• C-3.

Fuel Handling' Review O

C.

Personnel Radiation Protection 1.

• Contamination Control 2.

• Airborne Control f

3.

Use of Monitors D.

Previous Items 4

E.

Additional Comments / Requested Action (I) la E A vio sIa ve, u o f c,oyece,[ d vi.,'a op ers f, o g v.

• Those items inspected against previous month's HP records for area.

Inopection Code:

S-Satisfactcry Q-Questionable U-Unsatisfactory

.---...a

t,.

c.

c.,

~.

. y !@,:?" I UrHC DETAILS OF INSPECT!0N 86-11 12-16-86 INSPECTION ITEM DETAILS RESPONSIBILITY (A)

(4)

It was observed that the damper plate on the shear exhaust.was only half open.

The damper was immediately placed in-the fully open position.

This item should be included in the equipment check list under preparation.

O. McFadden (A)

(5)

A half gallon plastic bottle was sitting on the decon table.

Although i t had a radioactive sticker label, there was no ident-ification of contents. Bottle was opened, contained metal pieces which were identified as having come from Unit 1.

All 1/2 gal. bottles require contents identification. Any bottle from one area to another requires i dentification.

J. Wilkinson (A)

(6)

An empty gas cylinder had been surveyed and cleared by HP and a green tag issued on 12-1-86 for removal from B-South. It was still there on 12-4-86. The release ticket expires after 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> so this removal will require extra surveys / work.

Don't ask HP to clear an item if it can't be removed within the release period.

Monthly Awarenes item for All Are r,_

7._m

._._..-.,e__

'.n

)-0ETAIL5OFINSPECTION86-11 12-16-86 INSPECTION ITEM DETAILS RESPONSIBILITY A full nitric acid gallon bottle was observed stored under the decon bench. When questioned,the sectioning operator stated he thought bottle was full of water'and that this is how<decon personnel rinse the bottles prior to dis-posal. Empties should be rinsed and dispositioned in one step.

J.

BRADY (B)

(2)

A rubber glove is on top of the old compactor cage area. This glove should be r'emoved since it gives the appearance, rightly or wrongly, that it was thrown there.

J. BRADY NMC crib area had 2-3 lab coats and shoe covers laying in the work area. The tech indicated the clothing would be used for new people coming into the area.

Protective clothing should be stored in the change room or boxed in the NMC locker only.

N.

GREN0N

.(8)

(3)

A newly assigned cutomatic oper-ator was observed deburring sec-tioned fuel pieces improperly.

Requested the lead operator to instruct him to do it differently.

This item should be included in the equipment check list under preparation.

D. McFADDEN

4

, s.1 f

DETAILS OF INSPECTION 86-11 12-16-86 INSPECTION ITEM DETAIL RESPONSIBilliY (C)

(2)

Elevated airborne samples recorded from shear operation in November. Problem discussed with management and corrective D. Luster actions taken.

D.

McFadden (E)

(1)

The 12 E autoclave is being operated without its insulated cover. Requested process engin-eering to check this out due to past concerns over temperature fluctuations.

If its not going to be used it could be stored.

P. Fuery 9

I

o 70-371/88-02-01 i

I 2. s v (LZ<o ny_. l p'-

M.

lD I & F a h,r ;.M W.'

m tc -

cLJs LA<

t*Y v.-5f.. D h dw - 4

& O#

2 % )u M

L:

b-n-r y w%A

@ ut % w id~-

so mee %

a,7Lp

&y N

.') w % 4 &

L L.J.LJe w 4444 N

h e

% s&-

nsnan LA~

10 m e c. /~

>l C)LG M4'l,f' age e.,<,1 p r;L

" A A

%u, y u, w - n o -

in& - ~.

w a

~, ua%

J. -

a 4

su m n.-

G e

INSPECTION ITEM 70-371/88-02-02 l

l l

L

~ ltem Description (70-371/88-02-02)

The inspector reviewed records of positive in vivo measurements (lung counts) with respect to the nature of the70rfithe Individuals performed.

lhe inspector determined that all of these Individuals worked in areas in which loose uranium material could be present i

Routine air sampling was performed using fixed location heads. Inspection of the placement of the air sampler showed thatsampling the air sampling heads were located away from the breathing zone area of the worker's face and approximately one to five feet away.

Review of the air sampling data indicated that there were no documented airborne concentrations of uranium present that could explain the positive lung counts. When work was performed that had the 30tential to generate airborne concentrations of uranium, breatilng zone (lapel) air samplers were not routinely used. The inspector discussed with the licensee the representativeness of their air samples.

The ins)ector stated that considering the nature of the process material involve (d (high density particulates), the relative) location potential Jor localized airborne activity and the and distance of the fixed air samplers from the worker's breathing zone did not represent suitable measurements for evaluating the intake of radioactive material ay workers. The inspector noted the following examples of air sample locations that were not considered representative:

Example 1 Sample location 75 (Sectioning) was used to monitor shearing operations on March 1 andwaslocatedapproximatelyl2,11and15,1988,1/2 feet above and to the right of the operators head. 'Ibe source of the p(otential airborne materials was a work enclosure approximately one cubic foot located 1 foot below and in front of the operators) breathing zone.

Example 2

- The "Rework" room (approximately 5'x6') has a work table with local exhaust located on the left side of the room, lhe air sampler (location 39I was located on the right wall roughly five feet off the floo)r. This placed the air sampler, approximately 4 to 5 feet from the breathing zone of any worker.

- On March 14, hood.,The distance from the work table to the Example 3 1988 a vacuum cleaner was cleaned using the "old" decon hood opening was approximately 3 feet.

The fixed air sample location was 3 feet above the table at the entrance to the hood.

Example 4

- On March 14, 1988, a maintenance worker entered into one

(

Item Description (70-371/88-02-02) end of a large contaminated process enclosure. lie placed approximately 3 opening. Prior /4 of his upper body inside the enclosure to performing any maintenance operations, the individual decontaminated the immediate work area within the enclosure with alcohol. The fixed air sampler was located outside and above the opening from which the individual entered.

Example 5-Through discussions with workers in the radiologically controlled area, the inspector determined that certain equipment cleanups were performed by opening selected glove ports to wipe down accessible equi with alcohol. After the initial cleanup,pment surfaces the Health Physics technicians performed a contamination survey of those areas reachable through the glove port o>enings.

Results of the survey were used to determine wiether or not personnel should be allowed to enter into the equipment.

The inspector found throuch review of records that contamination levels inslie the equipment in November,1986, February,dijin[egrationspe,rminuteper100squarecentimeters 1987 and August 1987, were typically a few thousand (dpm/100cm contamination) of alpha activity. In una instance, thg level was as high as 37,000 dpm/100 cm.

Results indicated a highly nonuniform distribution of equipment contamination. Cleanup of the equipment was further accomplished by allowing at least one individual to crawl inside the equiiment. During the cleanup operations, no air samples were ta(en inside the equipment to evaluate the concentrations of airborne radioactive material that the individual may have been ex decontamination activities. posed to as a result of the The inspector stated that this was an apparent vlnlation of 10 CFR 20.103(a)(3) which states "the licensee shall use suitable measurements of concentrations of radioactive materials in air for detectin and evaluatin airborne radioactivity in restricted 70 371/88 02-02) g areas."

Excmple 3 Air samples taken at the "old" decon hood during the vacuum cleaner l

(cgain) clean-out sh0wed that airborne radioactivity concentrations in the general work area were 80% to 90% of HPC during the work evolution, f

No measurements were taken in the breathing zone of the worker.

The inspector stated that this was another example of failure to use I

l suitable measurements of concentrations of radioactive material in air for detecting and evaluating airborne radioactivity as specified in 10 CFR 20.103(a)(3) (70-371/88-02 02).

l l

l

UtiC RESPol1SE Example 1 The shear and air sample location I-75 are shown.

This sampler is located 10 to 11 inches from the operator's nose, not 1-1/2 feet.

We have considered this to be representative of air breathed.

Attempts to bring the sample closer to the operators face interfere with his operation of the equipment.

If this fixed air sample location cannot be determined to be representative of the breathing zone air, then lapel air sample will be done on a continuous basis.

0) i 2

a. '

I)

?

e s

s -

y,1 I'

t e

ec !w l

I

.s l lNP.i A'".111 Irn

[T) t

).,. !(

l.

b; 53 e/.

\\

\\

I i

g' llNP.lE "l! 4 Il

4 UNC RESPONSE Examole 2 This fixed air sample monitors room air concentrations.

Confirmatory BZ sampling will be done by lapels.

Examole 3 and Examole 6 i

The vacuum cleaner cleanout discussed by the NRC report was reviewed and authorized under Special Work Permit 88-15.

A previous cleanout had been reviewed and authorized under Special Work Permit 87-91.

That job was completed in 25 minutes and BZ lapel air sampler was

<10% MPC.

The subject vacuum cleaner cleanout (SWP 88-15) was scoped out as being slightly different from the previous cleanout in that the vacuum and filter had to be visually examined to verify the absence of fuel.

This was required because Accountability at the time indicated there was some material unaccounted for from the Unit 1 operations.

Health Physics felt 6.he job itself could be completed in 30 minutes but recognized some adcitional handling of the vacuum cleaner would be required.

Since a lapel sampler unit could possibly be obstructive to the operator, and since there was a prior lapel evaluation, no lapel sampling was performed.

A sampler was set up as close as possible to the left of the operator.

A second fixed air sampler was in place and operating such that the operator was working between the two samples.

The operator who performed the work wore a respirator (no credit taken) and has over twenty years experience in B South operations.

The work was done under a low velocity exhaust.

UNC has reviewed the circumstances surrounding this particular job and stands by the original assessment (decision not to wear the lapel sampler) and job set up based on:

(a)

The short term nature of the job (approx. 3/4 hour)

(b)

Most experienced operators assigned to job (c)

Use of respirator (d)

Double air samples as close as possible without interfering with job (e)

Work area under large vertical exhausting hood (f)

Less than 1 MPC/hr. measured in the immediate work area Under the circumstances, UNC considers that suitable measurements of concentrations of radioactive material were performed as specified in 10 CFR 20.103(a)(3).

p EXAMPLE 3 AND 6 PICTURES Ib '-

f k$)

p.

1 s

/

l J N!'.!

.i

+

lif t! 'y 4

I i

E j

e N

i l

i l

l

\\

inrn von nn<

l Unc nRVRL PRODUCTS C

70-37u sa-o2-02 Extmple 3 Health Physics Special Work Permit M ginator Name Work P, emit flo. N- / 5 a Haintenance Service Order No.

O Engineering GQ (Labsroductio^nJQC -1e* rm W. Wit.tiyJoM Date 3 2 V O

Part I To be completed by Originator of Attached Service Order (1) Work Location (Be Specific)

U tJ I T* # 1

'(2)' Description of Problem or Job CLEM our oF WIT */

ff W 30X M uun C Le,nupL (3) Will outside Contractor be involved flo Yes Name of Contractor Part II To be completed by Maintenance or Engineering (1) Scope of specific' Repair / Work to be Done (describe in sufficient detail to permit Health Physics evaluation of proposed work) b2/ S Yht'uaw

. 9'aM h miesnn DMb4

//

/ V (2) Scheduled Starting Date and Shift A-N/

/5 Estimated Time Required / //

,(3) Signature for Maintenance or Engineering Part III To be Completed by Health Physics (1) Advance Notice of Health Physics Required Before Starting This Job.

Yes No (2) Bioassay Sample Required:

Before Starting Job-Yes flo Af ter Work Complete-Yes_,tio, (3)PrtectiveEquipmentRequired Coveralis/GlovestfShoe Covers Lab Coat Respirator

/ Cuff Taping

/ Head Cover Other (4) Special Health Physics Monitoring Required No Yes /

(NOTE:

Self-Monitoring Required W en Exitin Q $4 skr Jula usd' j

(S) Precautions /Special Instructions M[c b G ose cr/v cdcol sde cM ed-n 6

J (6)Signat of Understandin g quired * )

Not Required N

en

• To be signed by people'coing work, o_r_ UNC representative for Job.

l 1 HEALTH PHYSICS USE Job cempleted on 3 - l'/-f' T

',. ne~/,

w Cross Reference R9cqrds Retention ForgHealth/ Physics Bicassay Yes dNo)

Lapel Sample (Yest,flo Process Air Sample West No

__ Names of Personnel involved in Work 2,,..

m

e DO 70-37 /88-02-02 Health Physics Special Work Femit 97-fl ricinator_

Name Work Pemit No.

a Maintenance Service Order No.

O Engineering ofreduction/QC

,/

Date m

eflabs S We&d.

j Part I To be completed by Originater of Attached Service Order (1) Work Location (Be Specific) / N O

[om-Ma

//

A &A maus/d (2) Description of Problem er Job F w

onsuu

/

/

//

(3) Will outside Contractor be involved No /Yes Name of Contractor Part II To be completed by Maintenance or Engineering (1) Scepe of specific Repair / Work to be Dene (describe in sufficient detail to pemit Health Physics evaluation of proposed work)

See abne (2) Scheduled Starting Date and Shift /J-9-f7

/SYM,f'dEstimatedTimeRequired_L[r.

,(3) Signature for Maintenance or Engineering Part III To be Ccapleted by Health Physics (1) Advance Notice of Health Physics Required Before Starting This Job.

Yes[No (2) Bioassay Sample Required:

Ecfore Starting Job-Yes No / Af ter Work Cccolete-Yes Mc/

(3) Protective Equipment Requi ed

_ Coveralls! Gloves hoe Covers ab Coat Respirator Cuff Taping

/HeadCover

!Other Ioe/,sodt

/OR! Ja s>ye Mr (4) pecial Health Physics Monitoring Required No Yes

/

l NOTE: Self-Monitoring Required When Exiting)

/

fc/e,,,4 (S) Precautions /Special Instructicns N#

(6) Signature of Understanding equi Not Required naurs kuu

• T6 ce signed oy people coing work, or, UNC representative for Job.

FOR HEALTH PHYSICS USE ul

\\

Job ccmpleted on

/ A 57 mi NAtb &

Cross Reference Recorcs Recention For heairtn Physics l

Bioassay Yes,_(ND Lacel Sample (Yes1 No Process Air SampirTest No Names of Personnel Involveo in Work M h. 7 kl 0,.\\cd nik Rev. 2 1/83

,/

j -

70-371/88-02-02 000h/

AMdY Cd SWP 87-91 h/jD fafer Ohwn bod o>W en kky m

@ JPo,o sn vseaar 16 h?och nedas/ m/o L&t,y av, o-

3) op racaaw dxe. od pV otaM 6 s as es>< od 9

Y ' "/

/

+ +)' Hareas ese ad f a4 49 adh ss/ hyed op c) fuP' aw Jac} o>i a%4 b a at/ >(yed y y

& >41 vseaum ou % - eme & c s/Ai

7) fa9 h&, p>' m a n-a me 6 ase &Mr

& kJ

%.-Acenn>6Lhfy l

i

--..-,-c

,,,~-,r--

'l W,r N' k gr,$iM., RE CORD 70-37U88-02-02 l

t w t.

Example 3 gf[VP87-91

' hfRP..NEALTH PH15lCS, A SAFETY.

• PCA COTD0oA.SAMPt 25 oNLY FoA Att 5%MA5

/4rdco CF SAWt.iW6 i hta wwo

' )

f

] CiaAt, C LOW TO NM IN0004.

O CAJ S3re O""

O iaeAcon

] c),0 coy

. O "co(2^'t O ou't coo'-

D oa' S'rt fora'*

b 3 ANN O=

0 exa mst srAc4 sm us TANEW N#

• ^"

u *f 't::e i r; CONCDITRATION W 1DCATICH ' -

.'e'**

%uun (%e 4 %

cle o UA ~I 90,0 Ari

i. di 3-f,

_ l 2-Ar' 2

3, " di S Y's 3

4 4 4

$ft g

3

- - - ~ ~ ~

~

Fit O M i

UNtlL l TOT. MIM,1 AIR F Lo w R AT L i

SAMRMcLUML

/d$$

/Y&

N h.D f oOY '

UNMW-1 f

om 0"

I I

UfftS/MM r

3 F*

P*

q_,._...____.,,,

q' Dill 3/MIP4 e

C O '.I '; I t 's G

'i*2 Daft AND E4Mrtt.

TOTAL COUNTS couNr5 GEfaNo Cott Em CHtCKM) iNE I

hMLCouMTED Act Nthufes NL MiNutt y==

ym FAcrot.

4f gy rtMt 10.00 15 38 0.30 1.90 20.00 /

g g

g bD hY 2

/

l l

i

__. /

//

i

/

/

(h%145 All A &J Osri (4)4 Atahdnx d ah > ~ 4t A u & - or u

d y

J

{'

J UNC RESPONSE

^

Examole 4 l

l The maintenance worker leaned into the tunnel end of Unit 1 to adjust i

a limit switch.

The work was conducted under approved special work l

permit No. 88-22.

l The area was decontaminated prior to entry and paper was placed on the work surface.

The maintenance operator leaned on the paper while performing this ten minute adjustment.

Examole 5 t

Subiect - Health Physics Evaluation - Unit 1 Box Cleanun Cleanup of the Unit i fabrication box is required whenever production runs shift between product types.

This process, referred to as Type I.

1, 2, or 3 cleanup, consists of wiping and picking up as much contamination as possible from outside the box and from the captive cuits.

Health Physics performs representative contamination surveys and "releases" the box for opening when thgse surveys indicate curface contamination is 5 1000 dpm/100 cm Figure 1 illustrates the box.

The shaded area represents the areas that can be cleaned from outside the box.

Approximately 15 square feet must be cleaned from inside the box.

Once the box is released for opening, operator (s) enter from the tunnel end and the captive suit end to perform final cleaning to 5 100 dpm/100 cm.

Operators wear fresh air masks (no credit taken) and crawl in the box over paper which has been laid down on the floor.

The potential for airborne contamination is low due to the "heavy" nature of the material, the uneven distribution with the "worst case" areas being in the vicinity of the captive suit and (which is completely cleaned prior to entry), and the small surface area remaining to be cleaned.

The inspection report's discussion of contamination levels inside the

box,

"...a few thousand disintegrations per minute per 100 square centimeters..." in gne instance the contamination level was as high as 37,000 dpa/100ca' should be clarified.

These levels were measuredgnitially,priortocleaningandwerecleanedtobelow1000 dpm/100cm prior to releasing the box for final cleanup.

It is possible to estimate the amount of surface contamination which may become airborne.

This is called a.resuspengion factor, and is defined as the ratig of air contamination yC1/m / to sugface mination pCi/m.

Values quot d vary from 3 x 10 -

to 2 x contg /m.

A mean value of 5 x 10 -g/m is conservatively 10 -

considered to be appropriate for general conditions (1).

Using this figure and the 10 CFR 20 Table 1 value for occupational apc air for i

uranium, a be 2 x 10 gerived gorking limit fog) contamination is calculated to pCi/cm.

(= 440 dpm/cm

Unc GAVf;L PRODUCTS

• Uf1C 70- m /88-o2-02 Excmpin 4 Health Physics Special Work Pennit

.icinator Name Work Pennit No. N-31 o Maintenance Service Order No.

I O Encineering

//

WCRtoducticryQC 7. Wit.r/nsoN Cate 3//'//W o

o Labs Part I To be ccmpleted by Originater of Attached Service Order (1) Work Location (Be Specific) UNir # I

' R ".s c o r 54 (2) Description of Problem or Job BRoter/

A /u/ r sawren m /TcSS mawsc.

(3) Will outside Contractor be involved NoX Yes Name of Contractor Part II To be completed by Maintenance or Engineering (1) Scope of specific Repair / Work to be Done (describe in sufficient detail to per: nit Health Physics evaluation of proposed work)

/h>f f, N 'l SMTC.L

/M M v1 h # /

v (2) Scheduled Starting Date and Shi

• N[N

/

Estimated Time neouired a 5

,(3) Signatu

/

2.-

for Maintenance of'EngMeering part III To be Completed by Health Physics (1) Advance Notice of Health Physics Required Before Starting This Job.

Yes / No (2) Bioassay Sample Required:

Before Starting Job-Yes No After Work Complete-Yes_j::.

(3)ProtectiveEquipmentRequired Ceveralls aloves /ShoeCovers Lab Coat espirator Cuff Taping Head Cover Other Yes ! w m x /dc. e e.d i n m (4) Special Health Physics Monitoring Required No (NOTE: Self-Monitoring Required When Exiting)

-- r (5) Precautions /Special Instructions pe ms occ D

(6) Signat re of Under andi

- # quired Not Required e

s

• To 'oe s11ried oy people coing work, ~or UNC representative for Job.

'OR HEALTH PHYSICS USE l

Job ccepleted on S F/.9f

-nY, ' my,.I Cross Reference Recorcs setention Fcr/ealtn. Physics Bicissay Ye s, (Wo3 _ _

Lapel Sample Yes, Woj Process Air Suple Yes, Names of Personnel involv(No) ec in Work t

[

DaA b',i n.v. p 1/mi

0 e

V AREA DECONNED TH AU GLOYE POATS AND SUITS s

^

4--

2 6" 88" u

s k

- 36" 50" U

UNIT I ENCLOS U AE FIGURE 1 l

l

UNC RESPONSE The IAEA used similar rationale to calculate a derived working contamination limit for Plutonium 239, the most toxic alpha emitter, and relaxed the allowable surface contamination level by a factor of 2.5 based on the fact that widespread uniform contamination is not usually found in practice and all resuspended material is not of respirable size.

This same logic can most certainly be applied to thefjNCsitugtion,resultinginasurfacecontaminationfigureof5x 10 ~ juCi/cm or 1110 dpm/cm Since all assumptions are conservative, particularly the resuspension factor, this calculation has been used to constitute an adequate survey within the intent of 10 CFR 20.202.

The current surveys would be representative of box contamination because of the nature of the operation.

The unsurveyed portion "sees" a lot of motion from the die movement.

This would be expected to disperse contamination to the areas surveyed rather than preferentially concentrate it.

The cleanup / survey, in this particular case *, should not be considered to be inadequate *(paper down, method of cleaning, fresh breathing air).

(1) "Monitoring of Radioactive Contamination on Surfaces," Technical Report Series No. 120, International Atomic Energy Agency, Vienna, 1970.

UNC CONCLUSION Examole 1 and 2 We will acknowledge this item of noncompliance for examples 1 and 2.

Exancie 3.

4, 5.

and 6 We believe that our actions were in full compliance with license requirements and 10 CFR 20.

I

UNC ACTIONS For All Examoles 1.

Immediate/Short Term 1)

UNC is implementing the use of breathing zone air samplers (e.g.,

lapel air samplars), for those routine (e.g.,

shearing) and non-routine (e.g., personnel entrance into closed areas for equipment cleanout) operations which have a high potential for generation and intake of airborne radioactive materials.

2)

The location of fixed air samplers is being reviewed for all routine operations which have the potential for generation and intake of airborne radioactive materials (e.g.,

the "rework" room), and will relocate those which are not felt to be representative of the air being breathed by the persons performing the work.

2.

Lona Term Procrammatic UNC will evaluate those operations which have a potential for generation and intake of airborne radioactive materials (e.g.,

non-routine operations such as vacuum cleaner cleanout) for the implementation of engineered controls, to provide greater protection against the generation of airborne radioactive materials in a manner such that they are available for personnel i

inhalation.

i

.---n-

1 e

8 o

INSPECTION ITEM 70-371/88-02-03

/

l ITEM DESCRIPTION l

(70-371/88-02-03) The inspection report indicates that:

l a) the fact that UNC does not use "filter self-absorption factors" when evaluating the results of measurements made on glass fiber air

, sampling filters (pages 8 and 9 of report),

b) failure to use bioassay data to perform MPC-hour calculations (specific reference to inspection item 88-02-04, report page 11), and c) failure to require self-monitoring of areas other than the hands for people leaving B-South (report page 13; again specific reference is made to inspection item 88-02-04) are apparent violations of 10 CFR 20.201(b).

This requirement deals with making surveys to evaluate the extent of radiation hazards that may be present.

UNC RESPONSE (A)

ESTABLISHMENT OF GLASS FIBER TYPE FILTERS WITH KNOWN ?.LPHA ABSORPTION Technical literature

• verifies at least two glass fiber type filters with little or no absorption of alpha activity,...

Whatman GF/A at 0 fraction of alpha activity absorbed and Gelman E at 0.09 fraction of cipha activity absorbed.

The Whatman GF/A thickness tested was 450 microns; the Gelman E was 625 microns.

COMPARISON TO FILTER USED AT NAVAL PRODUCTS UNC uses the Gelman A/E type glass fiber filter similar to the Whatman GF/A at 450 microns.

The main difference between the Gelman E and A/E is the greater thickness of the Gelman E and the absence of a binder in the A/E type.

Whatman GF/A is also without a binder.

The NRC indicated alpha activity absorbed could be as high as a factor of two.

UNC stated such correction factors were not associated with the Gelman glass fiber but rather with a cellulose type paper commonly cssociated with Whatman 41, a relatively inexpensive paper in use by a number of licensees.

The same study which evaluated the Whatman Cnd Gelman glass fiber filters also lists Whatman 41 at 40% fraction of alpha activity absorbed.

The NRC commented that UNC's glass fiber was approximately 1.3 mm thick.

As stated above, the Gelman A/E in use by UNC is 450 pm, cimilar to the tested Whatman GF/A and thinner than the tested Gelman E.

UNC uses a glass fiber paper manufactured by Whatman for its lapel campling.

This glass fiber, like the Gelman, will collect particles 2 1 micron on or close to the surface resulting in minimal, if any losses of alpha activity due to absorption.

• "Radiological Suveilliance of Airborne Contaminants in the Working Environment" International Safety Series #49 International Atomic Energy Agency, Vienna, 1979

• "Particle Size Analysis in Estimating the Significance of Airborne Contamination" Technical Reports Series No. 179 International Atomic Energy Agency, Vienna, 1978

Tho technical data which eupporto tho prGviouc diccuccion hco b3cn copied from the reference documents and is attached.

We have been in contact with both filter paper manufacturers, however neither one had any additional information on alpha absorption.

UNC CONCLUSION

~

1.

The long term use of these particular glass fiber air filters in UNC's air s cling program was based on reputable information from several sources in the referenced publication.

We selected this type because it represented the best combination of filter properties for the intended use - good handling properties, compatibility with a laboratory environment, surface collection of alpha particles.

2.

The previously cited document issued by the International Atomic Energy Agency included test data which established that similar glass fiber filters yielding no or minimal

(< 9%) alpha absorption, i.e., confirms surface collection of particulates.

3.

Under these circumstances we feel that our activities were in compliance with 10 GFR 20.201(b) in that quantitive measurements of airborne concentrations have been sufficiently accurate to enable UNC to comply with the regula: ions of 20.201(b) and sufficiently accurate under the circumstances to evaluate the extent of radiation hazards that may be present.

UNC ACTION We are applying a 15% correction factor against all calculated airbornc concentrations pending completion of a program to determine the absorption factor of the filters in use.

i

70-371/88-02-63 i

ATTACHMENT 1 SAFETY SERIES NO. 49 i

t IAEA Pg. 76 i

TABLE XIV. CilARACTERISTICS OF FILTERS USED IN PENETRATION STUDIES [1541 Pore or fibre Thickness Area.lensity Porosity Falter Type s!pha activity Activity diameter tym )

Immt Img cm-2) 1-a absorbed i.!

3 l AF-150 itembrane 0.

- 1.0 0.150 5.0 0.80 Th C-C AAF Glass nbre 2t 1.0 0.250 5.6 0.90 Air monitoring Cellulose libre I5 - 25 0.250 11.0 0.70 5-P blue Cellulose fibre 0.175 Th C-C 5-P pink Cellulose-asbestos 5bres 0.-

0.400 I 6. 2 0.74 0.33 Th C-C

• lillipore VC liembrane 0.1 : 0.08 0.130 a0 Th C-C Millipore AA 11embrane 0.5 : 0.05 0.150 4.7 0.31 20 Th C-C

%harman GF, A Glass 6bre 0.-

0.450 5.0 0.95 30 Pu-234 l

• Aharman 41 Cellulose fibre 0.013 9.1 0.65 0.40 Th C-C Ra A-C

'Vhatman Ap;A Polystyrene fibre 0.750 21 0 Tn C-C Ra A-C 1

Microsorban Polystyrene fibre 0.0 -0.5 1.33 0.43 Th C-C Ra A-C Gelman E Glass Gbre 0.625 0.09 Th C-C Ra A-C HV-70 Cellulose-nbestos 6bre 0.1-35 0.225 0.77 0.1 S Th C-C Ra A-C HV-70 Cellulose-asbestos 6bre C.1 -35 0.500 0.79 0.23 Th C-C Ra A-C

s.

70-371/88-02-03 l

Technical Reports Series No. 179 IAEA pg. 54 m

4 6

TABLE 3.1.6. ABSORPTION OF ALPHA PARTICLES IN FILTERS s

Tilter Type Thickness Area densir, Porosity Alpha Fraction Ref.

(mm)

(mmtem')

activity absorteci f

I tF-150 Membrane 0.15 5.0 0.80 Th C-C'

[3.1.38l iP-pink Cellu:ose-asbestos 0.40 16.2 0.74 Th C-C' O.33

[3.1.37]

fibres

.tillipore VC Membrane 0.13 5.6 0.74 Th C{'

c0

[3.1.37]

l' 1

Jillipora AA Membrane 0.15 4.9 0.79 Th C-C' cG

[3.1.371 n

thatman GF/A Glass fibre 0.45 5.0 0.95 "Pu e0

[3.1.39)

x:

6 Th C<.

2 1

thatman 4i Cellulose fibre

0. I 8 9.1 0.65 0.40

[3.1.40!

x

(-

m Ra A-C, w

t-thatman Ap/A Polystyrene fibre 0.75 Ra A-C'

^0

[3.1.40l f

lierosorban Polystyrene fibre 1.88 Ra A-C' O.43

[3.1.40]

f Ielman E Glass fibre 0.625 Ra A-C' O.09

[3.1.40l I-Y IV 70 Cellulose-asbestos 0.225 0.77 Ra A-C' O.18

[3.1.40]

fibre p

iV 70 Cellulose-asbestos -

0.500 0.79 Ra A-C' O.23

[3.1.40]

.=

.o i

i l

con c.esos 4

m

[

70-371/88-02-03 y os n

.f

?

o b

h

/

N#TACHMENT 3 d

ll 8

c o4

/

h

6 I

i t.3 I

2 SAFETY SERIES NO. 4 ~)

~

f or f

f l

t*~

o-0 4

s e

so

=

v raaracts osanatran i,,as j

FIG.15. Frectnonelgranty setthng losses an condusts as a functson of vertucle dsemeter and tube lemth, a.here flow rates are !$0 tsmes the conduss Janneter.

a i

I a

==t In addition to reduced transmission efficiency there may also be. on occasion.

l-a retntrainment of deposits which have accumuisted over a period of time. This

~

can increase the activity on the filter to the extent that it can be confused as j

ese i

resulting from a radiation accident.

]

1,m To minimize deposition in sampling conduits it is important - in addition I

to taicing the steps already mentioned in relation to gases - to keep the pipes as

• j l

short as possible and avoid abrupt necks; the pipes sho*!!d not be pasitioned j

horizontally. and the air velocity should be selected to suit the charactenstics of 1

i the aerosof. Information regarding the determinatron of deposition can be obtained Inc flow rate' I

from Refs [140.142.148.149-151].

,15 gives the fractional it is then necessary to know how the contaminant wss. behave in the retention

,i

! seter tnd tube length system once it arrives there. generally somewha attenuated owng to uptake.'nd transmission efficiencies less than 1(XTi. The many factors to be considered Mt from adsorption includc the amount of contaminant samplet the penetration of partic!cs intc ** *

cs can be minimized filters.and the effect of mixing of contan.mants.

' cc. which may also P 6.11.3. Burialloss

& with diameters

~ f larger particles When sampling with filter papers. some of the particles penetrate into the i

turbulent How depth of the paper before being captured. The depth of penetration of course faction. In addition.

1 depends on the type of the filter paper. Some 61ter papers like Millipore AA and

2sc of pipes made of glass fibre filter paper. Whatman GF A. collect all partides on or close to the j

}

surface.

i 6

75 J

t

i 70-371/88-02-03 Thickness' i

Aerossi K' ' A '

O.

s Pitterlypet Compositierr (mits),

DOP, 0.3nm-af520mm lif I.. ~

', liter / min /cm sk t

ATTACIIMENT 4 m'

Retention >

a J

GELMAII SCIEl:CES J

Type A/E TIIE FILTER BOOK

'1 l

Glass Fiber Glass fiber 450 (18) 299.98 %

45 1986 Catalog Filter without binder, low trace metals l

pg. 34 Extra Thick Glass Fiber Glass fiber with acrylic 1300(50)

>99.9%

26 Filter binder (Binderis 5% of j

totalmatenal.)

Metrigard t

l Ultrafine glass fiber 430(17) 299.999 21 l

with acryhc binder (Binderis5%of total matena!.)

l l

Polypropylene i

(Separator) l Polypropylene 127(5)

NA 40

[

Y

• Tested according to ASTM D 2986-71, "Standard Method for Evaluation of Air Assay Media by the Mono-2 disperse DOP (Dioctyl Phthalate) Smoke Test" with standard test parameters of 32 fitersimin through 100 cm of filter media.

g

• • pH-Ge! man Procedure (A) 500mLdistilledwater T-(B) Add 15 drops saturated kcl solution (C) Shread one 8~ x 10~ sheet and soak in prepared water for one hour (B) Run pH at ambient tsmperature.

l NA = Not Applicable l

G l

l l

in the U S A. ca1 Ge man tod-free G8 at 800-521-1520 or 313-665 0651 in M:ch gan j

Outs::e the U S A centact your nerast G# man off ce c te ex

]..

ATTACHMENT 5 70-371/88-02-03 F. AIR SAMPLING AND ASSESSh!ENT sum srazzs no, 4, IN3VASTE DISPOSAL zm AND DECONTAMINATION AREAS AT AERE F 1. INTRODUCTION To guard against the airborne hazard in the Decontamination Centre at AERE, lla.well, work is carried out either in extracted fume hoods or in a sealed area. Although most of the decontamination methods used involve liquids (detergent solutions, complexing agent solutions or mineral acids), agitation with steel wool or brushes leads to radioactive material becoming airborne.

A major problem associated with air sampling in the waste disposal and decontam!..ation areas in large establishments is the possible presence of any radionuclide other than those with very short halflives. Therefore any airborne radioactivity must be considered as being due to the most restrictive nuclide for its type (23'Pu for alpha and ' Sr for beta). liigh sensitivity is therefore required. The presence of radon and thoron daughters from radium and thorium waste accumulations and contaminated equipment makes early positive detection of more hazardous alpha particle emitters extremely difficult.

F 2. SAMPLING Particulate air samples are collected on glass fibra filter papers Type AGF/A, V

6 cm in diameter. These have a low resistance to flow, high efficiency and surface collection characteristics giving low alpha particle absorption [l].

Alarm monitors are situated in areas of potential hazard with reference to the air flow patterns which are determined using Guorescent powder. They 3

sarnple at 2 m /h and are compensated for radon background. They alarm at alpha levels corresponding to 20 MPC h of 39Pu.

2 Air samples for measurement and assessment after sampling are of three types:

(a) Environmental samples from installed equipment with the sampling heads as ciose as possible to the operator positions and sampling 3

3 rates of 2 m /h. The filter paper is changed at daily or weekly intervals to provide long term control and for record keeping.

(b) Special samples of short duration using portable equipment at rates of 3

2 m /h taken before or during a specific operation to assess the hazard.

3 (c) Personal samples using battery operated pumps at 0.12 m /h which are issued to individual operators when significant levels (> 0.1 MPC) are expected in order to assess their exposure. Papers are changed daily or weekly.

N.=

UNC RESPONSE (C) 6.2 Exitina Survev

" Hands are washed first to clear the most probable area of contamination prior to any monitoring.

NRC Regulatory Guide 8.24, Paragraph 1.6 recognizes this practice as stated.

We concur that personnel performing work activities or having personal habits that could contaminate other body areas (e.g.,

face, hair, wrists) or clothing (e.g., shosa, pant legs, shirt necks) chould be instructed to survey such areas during exiting.

The posted instructions will be modified to amplify upon existing instructions.

The inspection report cites as an example of inadequate control of radioactive material the external contamination of an individual which resulted in a 1932 MPC-hour in-vivo reading.

As reported by the Helgeson Scientific Service, the before and after shower readings were 286 and 94 ugm. U-235.

The shower is therefore assumed to have removed an amount of U-235 which, had it been in the lungs, would total 192 ugm. U-235.

Helgeson informs UNC that each ugn U-235 on the surface can be cxpected to register 10 cpm in the counter based on 186 Kev gamma.

For a person with a 10 inch thick chest, the counter would record 1.6 cpm for the same one uga U-235 in the lungs.

We therefore, estimate that the total surface contamination was 31 ogm U-235, or 3 x 10 -3 uc.

Spread over an area of four sq. ft. frontal areas for an individual, we estimate that the surface activity for this individual was 6600 dpm/4 sq.

ft., or 200 dpm/100 sq/ cm.

We would expect probe detectors to have problems detecting this level of activity, and feel that UNC personnel exercised reasonable diligence in performing curveys as required by 10CFR 20.201 (b).

Review of the lung count data shows such incidents are unusual and that external contamination of people as identified by the extremely censitive phoswich detectors is a rare occurrence.

Sectioning personnel (as was this person) normally shower at the end of a work chift.

This person had worked before his initial morning count and did not shower prior to reporting to the lung counter.

UNC CONCLUSION Wo believe that our practices were in full compliance with 10CFR and the license.

UNC ACTION The posted instructions will be modified as indicated above.

9 9

m INSPECTION ITEMS 70-371/88 02-04 AND 05

ITEM DESCRIPTION (70-371/88-02-04), (70-371/88-02-05) The inspection report indicates that the whole body count for an individual in 1986, when converted to

~

MPC-hours, results in an internal contamination level of 635 MPC-hours, which exceeds the calendar quarter limit of 520 which is derived from the values indicated in 10 CFR 20.103 (a) (1).

In addition, the report indicates an apparent violation of the 10 CFR 20.201(b) requirement to report such over-exposures to the NRC within 30 days.

UNC RESPONSE The NRC utilized an in-vivo count obtained on May 22, 1986 as the basis for citing an overexposure to airborne concentration limits during the 2nd quarter of that year. Specifically, the NRC raport states "The individual's only documented exposure prior to the lung count was during the quarter of the in-vivo measurement (May 1986.)".

Additional data is available:

1-Shop records confirm that this individual worked full time in Unit 1 for the prior calender quarter (Jan.

1, 1986 thru Mar. 31, 1986), and had been in that area for a considerable time before Jan.

1, 1986.

Health physics records show that he participated in the bio-assay programs which are maintained for all B-South personnel. This individual's urine data for the prior quarter is as follows Jan.

30, 1986 0

Feb.

28, 1986 0

March 31, 1986 14.0 1 8 dpm/ liter 7he urine results are qualitative but indicative of exposure.

Health physics records show that Unit 1 operates with mean airborne levels of 5 10 % of MPC. In accordance with the provisions of 10CFR 20.103 (3) individual monitoring of persons in that area are not required, and Unit 1 exposure records are therefore not maintained for this individual, or for others who work in that area.

Accordingly, it was appropriate at the time that the invivo data was received to consider that the reading in question occurred over a period considerably in excess of 520 hours0.00602 days <br />0.144 hours <br />8.597884e-4 weeks <br />1.9786e-4 months <br />. Therefore this case did not violate the requirements of 10CFR 20.103 (a) (1). Because the 1

l uptake (if actual) occurred over an extended period of time, UNC j

reviewed the reading against its limit for equilibrum lung burdens, l

which is 70% of 180 ugm U-235. No further evaluation was called for.

l 2-As illustrated to UNC representatives at the time of the inspection, this NRC analysis assumed that the total lung count of 94 ugm U-235 was due to long biological half life deep lung deposition.

This assumption is questionable because this specific count, and generally most all in-vivo measurements at UNC are obtained during the course of the normal work day, and will include that fraction of any uptake which was swallowed to the G.

I.

tract.

Section V of ICRP Publication 2 assigns a value of 50% of inhalation to this fraction.

The count in question was the second for that individual in one day.

The prior count showed external contamination, evidencing his very recent exposure to contamination, and the likelihood of a recent transfer to the G.

I. Tract.

This transfer would increase the apparent amount of material recorded for a lung count, and effectively reduce the multiplier by which the deep lung burden should be increased to estimate exposure to airborne contamination. For this reason, the calculation of 635 MPC hr exposure is not valid.

Finally, in Section 6.1.4.1 the inspection report states "The final values reported (micrograms) are quantitive measurements of Uranium-235 only, and have not taken into account the other isotopes of uranium that may be present."

As was discussed with NRC inspectors, UNC imposes lung burden limits which are below those established in Reg. Guide 8.11 precisely because of the elevated levels of U-234 found in Government supplied fuel.

UNC CONCLUSIONS 1-No overexposure in violation of 10CFR 20.103 (a) (1) occurred.

2-There was no failure to evaluate bio-assay data as required by 10CFR 20.201 (b).

The values obtained, though not frequently encountered, were not of an unusual level, and the exposures were for a sufficiently long period of time to preclude any consideration beyond the action levels normally employed.

3-Because there was no bioassay evidence of an overexposure, there was no violation of reporting requirements set forth in 10 CFR

20. 4 05 (a) (1) (ii).

4-In-vivo dosimetry results, as evaluated by UNC using INDOS, confirm t

the consistently low levels of exposure indicated by air sampling surveys. INDOS is a computer program which implements the methodology set forth in NUREG CR/4884, alternately identified as NUREG-52063, and entitled "Interpretation of Bio-Assay Measurements". This follows the model established in ICRP Publication 30.

As an example, an individual exposed for 3000 days to a concentration of 0.1 MPC hrs / hr. of 1 micron particle Class Y U-235 would have a lung burden of 157 ugm. U-235.

This well exceeds any lung burdens seen at UNC.

UNC ACTION We are currently evaluating improved methods of tracking and summarizing personnel exposures.

l

O INSPECTION ITEM 70-371/88-02-07

)

l l

1

ITEM DESCRIPTION (70-371/88-02-07) The inspection report cites three specific examples wherein HP Technician measurement of air flow direction between areas having differing contamination levels showed rejectable conditions that remained uncorrected over extended periods of time.

This is identified as a violation of the requirement in our NRC License that air flow be from areas of lower to areas (f higher contamination.

UNC RESPONS_E The noted air balance conditions occur entirely within our B-South facility between an area of slightly higher contamination potential to an area of lower contamination potential as noted and not to an area free of contamination.

When the reversal of air flow is present, the air velocity in the "wrong" direction is extremely low.

Review of air sample data demonstrates that airborne contamination to which personnel are exposed in any area of B-South does not exceed 10% of the Derived Air Concentration (DAC) established in 10 CFR Part 20 "Standards for Protection Against Radiation," averaged over 1 quarter.

The infrequent occurrence of localized "bubbles" within the area of a specific machine or operation will not result in general area air contamination that could be transferred in any significance to another area in the B-South facility.

In the specific cases of the Chem Lab., Spec. Lab., and Pack Assembly Change Room, continuous air samples together with smear samples have not indicated any increase in contamination as a result of the reverse air flow direction.

The number of separate ventilation systems, rooms, doors, hoods, vents and temperature preferences make it difficult to maintain continuous localized flow direction within B-South.

Higher air flows than now present would be needed to maintain directionality in spite of door openings, hood use, etc.

Such flow rates would result in greater air velocities during transient conditions, negatively affecting operations such as hood air flows, weighing operations, higher dust transport and similar situations.

Under the ALARA concept (i.e. as low as reasonably achievable),

we believe it is unreasonable to continue to apply the words of Section 4.4.2.2 as currently stated to such low contamination levels.

The 1

words were acceptable at a previous point in time prior to the eccumulation of significant operating experience in the new facilities and processes at Montville as compared to the old facilities and old processes that were used in the New Haven facilities and which were the original basis for the wording.

l i

l

- - - = _ - _ _. - _ -

While it is desirable to maintain air flows from local areas of lower potential contamination to local areas of higher potential, it is

~

more important to gaintain air flow from clean areas outside B-South into B-South.

We had previously addressed this problem in our renewal application, reference (1).

Revision of paragraph 4.4.2.2 proposed recognition of DAC (Derived Air Concentration ) bases as a means of determining air flow direction concerns.

Resolution of the license renewal never occurred and the existing license was extended.

(1) Letter W.

F. Kirk to R. G. Page (NRC Washington) on Renewal of SNM License #368 dated February 24, 1982.

UNC CONCLUSION UNC agrees with the conclusions of the NRC Inspection Report.

UNC ACTIONS Air flow has been restored to the license requirements with the cxception of the pack assembly room.

A.

license amendment request will be promptly submitted to the NRC to clarify the application of air balancing to areas within B-South and to request exemption of the Pack Assembly Room due to Government Contract Technical Code requirements.

A system will be put in place to bring delays in corrective action to the attention of higher management.

i l

9 4

e 9

em INSPECTION ITEM 70-371/88-02-08 i

ITEM DESCRIPTION (70-371/88-02-08) The inspection report indicates that the vacuum cleaner cleanout was done in an area which does not comply with the license requirement for ventilation exhaust equipment for certain levels of airborne material.

UNC RESPONSE The vacuum cleaner cleanout discussed in the inspection report was a n2D-routine short term ooeration, reviewed by Health Physics and authorized under Special Work Permit 88-15.

The job was estimated to take 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

A similar cleanout had occurred on 12-9-87 authorized under work permit 87-91.

Experience from that job indicat'ed the job could be completed in 30-35 minutes.

The work area was set up under a hood within a fenced-in area to take cdvantage of the local exhaust hood available in this area.

It was known and recognized that this hood was not a process hood and was never designed to meet the flow requirements specified in 4.4.2.1 of the license.

This license paragraph was written and approved for continuous routine operations.

A review of license section 4.4.2.1 cnd 4.1.2, which is cross referenced, confirms this and the intent of a process exhaust for routine operations.

"4.4.2.1 Local Exhaust only portions of Building B handle exposed uranium, very small amounts of which can become airborne.

Hoods, glove boxes, or local exhaust shall be provided as required to maintain airborne and surface contamination within acceptable limits as defined in 4.1.2.

Ventilation exhaust equipment shall be required for routine operations generating airborne concentrations in excess of 25% of MPC with minimum air movement requirements as follows Fume Hood Face Velocity

- 50 linear ft.per minute General Purpose Hood Face Velocity

-100 linear ft. per minute Local Exhaust

-100 linear ft. per minute Glove Boxes

-Slight negative pressure (Except inert atmosphere boxes)"

l All process exhaust systems that discharge more than l

25% of MPC during dry operations shall be filtered through high efficiency filters (2 99.95% for particles l

larger than 0.3 microns),

i

"4.1.2 Air and Gaseous Effluent Concentrations The concentration of airborne radioactivity shall be in accordance with Title 10 Code of Federal Regulations Part 20.

Any gaseous or liquid effluent discharge samples that are 25% of the 10 CFR Part 20 limits shall be immediately resampled and an investigation of the source of the release shall be made.

Samples which are ds high as 50% of the 10 CFR Part 20 limits shall result in partially restricted operation and an increase in sampling frequency for determining the source of the release problem.

If samples exceed 50%

of the 10 CFR Part 20 limits, an evaluation shall be made to determine if a shutdown is necessary ".

The vacuum cleaner cleanout was a non-routine job, over in 30 minutes.

The use of the exhaust hood was for ALARA purposes to avoid / minimize the generation of any general area airborne concentrations.

The vacuum cleaner cleanout completed on 12-9-87 was accomplished using Lapel air sample and results indicated less than 10% MPC for that work Feriod.

Therefore, establishing an initial experience basis for expecting low airborne material for the operation.

UNC CONCLUSIONS We believe that our activities and practices were in full compliance with the license.

The license requirements are specifically related to "routine operations", and not to those of a sporadic, non-routine nature such as vacuum cleaner cleanouts.

That operation was being done with an SWP (Special Work Permit) under the cognizance of a Health Physics Technician, and the hood in question was being used for ALARA purposes - not because it was required by the license.

UNC ACTIONS SHORT TERM Although we believe we were in full compliance, we are not satisfied with the technique which was used in this instance, and will perform future vacuum cleaner cleanouts under the hood in the Unit 1 area which was previously used, or in alternate areas acceptable to Health Physics as assuring protection against personnel inhalation of cirborr.a materials.

In addition, we will evaluate that area to casure ', hat the available exhaust volume is protecting the worker cgains; airborne materials.

Engineering modifications will be made, if ner,essary, to provide that protectirn.

LONG TERM We will evaluate other non-routine operations having the potential to generate airborne radioactivity which may be ingested by personnel, cnd take appropriate action to protect against such intake.

---

_n----------,

e e

W INSPECTION ITEM 70-371/88-02-09 l

~

ITEM DESCRIPTION (70-371/88-02-09) The inspection report indicates that current Health Physics procedures are not adequate to meet the license requirement that they provide the controls needed to insure compliance with all applicable provisions of the license and 10 CFR 20.

UNC RESPONSE Health Physics Soecial Work Permits-Since only experienced H.P.

technicians or the H.P.

Specialist participate in the completion of HPSWPs, we consider that the form is self explanatory.

The need for use of the form is set forth in the Supervisor's Health Physics Guide cnd other UNC procedures.

Radiological survey data associated with the particular work is available.

However we have chosen to ceparately tabulate such information rather than include it on the form as suggested by the NRC.

NRC inspection report 85-09 includes the following comment:

4.4 "Seecial Work Permits The issuance, adherence to and adequacy of the licensee's special work permits (SWPs) were reviewed against commitments provided in Subsection 4.6.3 ("Special Operations") of the licensee's application.

The SWP process was reviewed by examination of the SWP Log, selected SWPs and associated radiation protection surveys and during discussions with health physics technicians.

Within the scope of this review, no violations or deviations were noted."

SWP practices have not changed since 1985.

Bioassay Procram Procedures - The basic procedural document is Section 4.2.3 of the NRC approved license.

The Supervisor's H.P.

Guide sets forth the bioassay program for personnel information.

While improvements can and will be made, we believe that UNC is in compliance with the NRC license.

Task Instruction 2 The reference to TI 2-14 was accidental since it (TI 2-14) had been incorporated into TI 2-9 prior to formal issue.

The question of an absorption factor for a glass fiber filter is the subject of a separate item in this inspection.

Task Instruction 5 The statement in paragraph 2.1.4 of this instruction.

"Use at Exhaust Ocaninas: If the exhaust opening is large (at least 3 square feet) and the air velocities low, as in spray booths, chemical hoods, etc., the velometer itself can be held in the air stream.

The instrument should be held so that the left hand port of the meter is flush with the exhaust opening."

is correct as stated. Clarification will be made on normally surveying the central portion of exhaust openings.

Additional instruction could be provided concerning how to move the flow meter to take into account the presence of air curtains, special equipment in a hood, blocking part of the suction, or similar factors which are difficult to describe from a licensing viewpoint.

Part I, Section 4.1 of SNM License #368 allows "Internal procedures and/or data forms shall be used in performing and documenting health physics functions in accordance with this section".

A strict view would further conclude that paragraph 4.1 applied to 4.1.1 Surface Contamination 4.1.2 Air and Gaseous Effluent Concentrations 4.1.3 In-Plant action / control concentrations 4.1.4 Records cnd to no other sections of Chapter 4.

Based on the above, no violation of the license occurred.

The lack of significant findings in the area of H.P. instructions over many years of inspection supports the abovo conclusion. We currently have approximately 67 H.P. procedures as per the attached list.

UNC CONCLUSION We believe that our procedures are in full compliance with license requirements.

UNC ACTION A review of existing H.P. procedures will be conducted for accuracy and improved instruction, and the desirability of additional procedures.

A comparison will be made to H.P. procedures from an essociated UNC company.

The entire program will be completed by September, 1988.

l I

i

-r

88-02-09 UNC Naval Products l

~

SUPERVISOR'S HEALTH PHYSICS GUIDE R

DIVISION :

1 REVIS ON :

1 GUIDE :

GENERAL RE@LATIONS ISSUE DATE : 11/87 INDEX DIVISION 1 - GENERAL REGULATIONS GUIDE 1.1

- RESPONSIBILITY FOR CONTROL OF CONTAMINATION AND RADIATION HAZARD 1.2

- HEALTH PHYSICS SURVEILLANCE AND EVALUATIONS 1.3

- CLASSIFICATION OF HEALTH PHYSICS CONTROLLED AREAS 1.4

- BASIC BUILDING B SOUTH CONTAMINATION CONTROL REGULATIONS 1.5

- GENERAL RULES FOR HANDLING RADIOACTIVE MATERIALS 1.6

- VENDOR, CONTRACTOR OR VISITOR INDOCTRINATION 1.7

- HEALTH PHYSICS RECORDS GENERATED AND RETAINED E

APPROVALS s

PAGE 1 Wfhv 1

au s-ne n/a /s7 II-I V 8 7

88-02-09 UNC Naval Products SUPERVISOR'S HEALTH PHYSICS GUIDE l DIVISION:

II REVISION : 1 l GUIDE:

RADIATION CONTROL ISSUE DATE 11/87 l

INDEX DIVISION 2 - RADIATION CONTROL GUIDE 2.1

- SURFACE CONTAMINATION CONTROL 2.2

- AIRBORNE CONTAMINATION CONTROL 2.3

- EXTERNAL RADIATION CONTROL 2.4

- 13IOASSAY PROGRAM p

2.5

- PROTECTIVE CLOTHING 2.6

- SMOKING, EATING AND DRINKING IN CONTROLLED AREAS l

l l

P I

]

APPROVALS l98 % [p,/a(,/s7 N

1

\\ms-8/

/i 0F p g W 3

88-02-09

,.UNC Naval Products

\\

SUPERVISOR'S HEALTH PHYSICS GUIDE i DMSION :

111

(,-

REVISION : I f GUIDE:

ENVIRONMEttTAL C0;iTROL ISSUE DATE :11/87 i

i l

l INDEX

?

DIVISION 3 - ENVIRONMENTAL CONTROL

~

j GUIDE 3.1

- LIQUID WASTE AND EFFLUENTS l

l i

l l

i l'

i i

i l

l i

t l

i l

i F

i l

l APPROVALS

,/v PAGE I 9 8' k2 M((j/)

M I5-H P u/it./

or 1

L M W -

~

88-02-09

~UNC NavalProducts HEALTH PHYSICS MANUAL TASK INSTRUCTION m

TITLE:

HEALTH PHYSICS MONITORING SECTION 2 i

2-1 Procedure for Taking Surveys for Transferable Contamination 2-2 Preparation of Bionssay Samples For Halling 2-3 Personnel Filr, Badge Collection and Distribution 2-4 Use of Health Physics Removal Tags 2-5 Monitoring Hard-to-Monitor Areas (Nose, Ears) 2-6 Monitoring of Maintenance Tools and Equipment Prior to Removal from B-South l

2-7. Determination of Airborne Particulate Radioactivity 2-8 Procedure for Leak Checking Radioactivity Source Containment 2-9 Assessment of Individual's Exposure to Airborne Radioactivity 2-10 Respirator Decontamination i

s,

.,3.

aummL -

M

()

APPROVALS g

.t@ ' 4 W PAGE _

H. P SPECIAUST9 M [A i

M ANAGER, NIS

-M 4g

,,.. o,0 N

83-02-09

'UNC NavalProducts HEALTH PHYSICS MANUAL - TASK INSTRUCTION TITLE:

HEALTH PHYSICS INSTRUMENTATION INDEX SECTION 3 3-1 Calibration of Alpha Counter / Scaler Systems 3-2 Operation of Beta / Gamma Counter / Scaler Systems 3-3 Calibration and Testing of Portable Alpha Counters - PAC 4-G's Eberline Radiation Monitor Model RM-19 Calibration and Testing 3-4 3-5 Calibration and Testing of Neutron Meters I

3-6 Rotating Vacuum Pump for Central Vacuum System 3-7 Eberline Radiation Monitor RM Calibration and Testing.

3-8 Eberline Radiation Monitor RM Calibration and Testing.

3-9 Eberline Geiger Counter Model E-530 - Calibration and Testing.

3-10 Eberline Geiger Counter Model E-120 - Calibration and Testing.

L 3-11 Calibration of Alpha Survey Instruments 3-12 Pre-Operational check of Alpha Survey Instrumentation 3-13 Operation of Alpha Counter / Scaler Systems 3-14, Check and Calibration of Fixed Air Sampling Equipment i

3-15 Use and Operation of Hi-Vol Air Samples (l}

APPROVALS ISSUE 0 ATE,(@. 4 g1 PAGE j H P SPECIALIST 9 M ~Di9 M ANAGER, NIS

/22[M[

REVISION 0

Or g

8bO2-@

tG ava roducts HEALTH PHYSICS MANUAL TASK INSTRUCTION TITLI:

RAD WASTE SYSTEM SECTfDN 4 4-1 Operating the Rad Waste System 4-2 Sampling of Receiving Tanks 1 and 2 Before Discharge 4-3 Standpipe Procedure for Handling Filt'er Changes, Rad Waste Filters 4-3A Internal Transfer Filter Changes (Short Version) 4-4 Preparation of Receiving Tanks 1 and 2 for Overnight and Weekend Service 4-5 Transfer of nad Waste from Raschig Ring Tanks to Centrifuge Receiving Tank 4-6 Transfer of Rad Waste from Centrifugo Receiving Tank or Shower Tank to Retention Tanks Discharge of Rad Waste from Retention Tank to Septic 4-7 Tank 4-8 Preparation of Liquid Waste Analysis Samples 4-8A Radiometric Assay of Rad Waste - Short Form 4-9 Hand Cleaning Raschig Rings 4-10 Centrifuge Bowl Cleanout 4-11 Heasuring Raschig Ring Levels in Receiving Tanks i

4-12 Disposition of Interna Transfer Rad Waste Filters 1

4-13 Radioactive Sludge Control 4-14 Rad Waste Alpha Attenuation Evaluation 4-15 Dewatering Internal and Dizcharge Rad Waste Filters 4-16 Drum Packing Internal and Discharge Rad Waste Filters l

APPROVALS ggy $ g ggr H. P. SPECIAUSO M Eb M ANAGER. NIS dd MMM.

REVISION 0

or 1

88-02-09 HEALTH PHYSICS MANUAL - TASK INSTRUCTION V

t i

TITLE: SECTION 5 - PRODUCTION / EQUIPMENT OPERATIONS SECTION 5 5-1 Standpipe Filter Changes 5-2 Cleanout of Standpipe Systems 5-3 Hood Velocity Measurements 5-4 Reserved 5-5 Absolute Filter Manometer Readinge 5-6 Changing controlled Area Vacuum Cleaner Filters 5-7 DOP Testing of HEPA Filters 5-8 Disposal of Autoclave Water 5-9 Cutomatic Cleanout - HP Coverage 5-10 Reserved 5-11 Disposition of Sectioning Area Pickling Acid 5-12 Clean out Procedure - Electrode Grinding Room Torit Dust Collector f9506 5-13 B South Air Salance Measurement i

5-14 Cleanout of Rotoclone Sludge Tank 5-15 Rotoclone Bag Filter Change 5-16 Colag. Filter Change t

i

! ('

APPROVALS gy

,y j

I MANAGEA.NIS H. P. SPECIALISTbf. N3 )

)f kMM-REVISION O

1 og ___

88-02-09

. m e1gr

~

F M,'f.

'r1 a

MANUAL - TASK INSTRUCTION I

l TITLE: SECTION 6 ENVIRONMENTAL MONITORING SECTION 6 6-1 Ambient Air Sampling for NOx 6-2 Reserved 6-3 Sampling of site Test Wells 6-4 Surface Water Sampling 6-5 Water Level Readings in Test Wells 6-6 Process Pond Discharge Sampling 6-7 Norwich City Water Sampling 6-8 Septic Tank sludge Sampling

(

6-9 Septic Tank Effluent Sampling 6-10 Soil Sampling 6-11 Wind Recorder Operation l

6-12 Calibration and Testing of pH Meter 6-13 Radiation Survey of Zirc Scrap t

i l

l i

, k.

APPROVALS WI)V 16 31 l

l H P. SPECIAtlST 9 O _D9 ISSUE DATE PAGE -

0 M ANAGER, NIS

[<I4 NYM_

REVISION l

eg L i

i f

i t

t t

i r

INSPECTION ITEM 70-371/88-02-10 i

i 5

6 9

i I

r I

E I

i, f

3 F

i k

a i

}

[

f f

r b

I I

I t

i i

i i

l i

b 1

I 2

i b

a i

l I

t 1

1 r

I 1

I I

i e

I i

+'

l i

s

.l t

4 i

t

[

!..,,_,.r.,_,._,_-......,.-._,._._,.__-,_

_,.---..m-.---..-

ITEM DESCRIPTION (70-371/88-02-10) The inspection report indicates that the annual HP cudits performed by ANI do not satify the license requirement of "a comprehensive review of the total protection or control aspects of the... Health Physics Program."

UNC RESPONSE The program is not intended as a detailed item by item check, but is intended to be an overall review of major items.

As a result of a thorough interchange of viewpoints on NRC inspection 70-371/80-07, UNC proceeded with a request to amend our license dated April 30, 1981.

The wording on audits was modified so that the ANI Audits could be used to satisfy license requirements.

Amendment No. 16 dated 12/15/81 modified audit programs as follows:

1.

It added "The methodology used and the areas of review shall be determined by the person (s) performing the audit".

2.

It added "Written audit plans shall be used.

The plans shall be reviewed and approved in a manner established by the President, UNC Naval Products".

The approved plan recommends that 50% of the listed suggested audit topics should be addressed in the audit.

UNC's view of this audits (1) the comprehensive comments desired concerning the Health Physics program are the type given by ANI "executive" summary (2) We were targeting this audit to give UNC general recommendations, new ideas or improvements, industry problems and similar comments rather than a very detailed item checklist as done by the NRC.

Some of the items mentioned by the NRC as not being a part of the ANI cudits have been reviewed by ANI.

Fcr example:

Health Physics procedures were commented upon in a 1930 audit.

Exposura data has been reviewed several times, see the 1986 report.

Items of licensee non-compliance have been brought to our attention by ANI and reviewed.

Cur discussions with ANI in the past have confirmed the thoroughness of their inspections and their expectatien of covering over a period of inspections, all areas appropriate to a good evaluation of the Health Physics program.

We believe that the NRC requirements for the exposure protection of the individual are very similar, if not identical to the requirements of a nuclear insurance company for the cxposure protection of the individual (and avoidance of claima).

Since the incorporation of Amendment #16 to our SUM license in December of 1981, 7 ANI audits, including those referenced in the current NRC inspection report, have been reviewed by 3 different NRC inspectors in 4 different inspections and found acceptable as follows:

~ ** ERC IC p:OtiCD 83-04, 5.

!!ealth Physics Audits Audits of the facility health 1hysics pro 0 ram were conducted on llay 4-5, 1902 and flovetnber 15-16, 1902 Jy personnel from outside the flaval Product Division.

Areas covered included:

shop safety committee reports,llRC inspections, environmental releases the Radiological Contingency Plan, llRC license amendments, exposure records, invivo measurements, toassay sampling, and inplant air and stack sampling data.

Results of t audits included recommendations for improving the facility health physics pro-gram.

The inspector reviewed licensee follow-up on several of these recommendations and found that the licensee had implemented the suggested

changes, flo violations were identified.

NRC Inspection 85-06, g.

llealth physics Audits Audits of the facility health physics program were conducted on May 31 - June 1, 1983, February 7-8, 1984 and Hovember 7-8, 1984 by personnel from outside the llaval Products Olvision.

Areas covered included:

shop safety committee reports, liRC Inspections, enyl-ronmental releases, the Radiological Contingency Plan, itRC license amendments, exposure records, in vivo measurements, bloassay sampling, anti in plant air and stack sampling data.

Results of the audits included recommendations for improving the facility health physics program.

The inspector reviewed licensee followup on several of these recommendations and'found that the licensee had implemented the suggested changes.

The inspector.noted that these audits were being conducted by the, licensee's insurer, American iluelear Insurers.

NRC Inspection 85-09, 4.1 Audits and Inspections The licensee's program for daily checks, monthly inspections and periodic audits of radiation protection activities was reviewed against criteria provided in Section 2.7, ("Inrpections and Audits"), of the licensee's application for Silf1*368.

The licensee's performance relative to these criteria was determined by:

discussions and interviews of the liealth Physics Specialist and members of his staf f; revtew of monthly inspection reports by the Health physics

!pecialist from January 1984 through Apri1 1985; and review of ani audit repor t by Amertcan fivelear Inst rers (Revision dated 1/7/85).

Within the scope of this review, no deviations f'om commitments l

made in the Itcensee's appitcation were noted.

t

. NRC Inspection 86-09, 4.0 Hanagement Oversight and Controls

.The licensee's management overstght and control over the health physics program was reviewed against criteria contained in Special Nuclear Material license No. SNH-368, Chapter 2.

The Itcensee's performance With respect t.o the ' bo've criteria was a

determined by:

discussionswithlicenseepersonnel; reytew of *,he llealth physics manual and Task Instructions for control of activities; review of selected special work permits (SWPs);

review of the llealth Physics Specialist monthly inspections frem January to July 1986; and review of the 1986 ANI audit, dated March 25, 1906, and licenset's subsequent reply to the audit, dated April 15, 1986.

Within the scope of this review, no violations or deviations were identi-fled.

The inspector noted that the licensee's response to audit findings l

(AHI audit and the internal monthly inspections) was thorough and timely, and all concerns were addressed for proposed resolution when necessary.

UNC CONCLUSION Wa believe that the audits were conducted in full compliance with license requirements.

UNC ACTICNS UNC has discontinued the use of ANI audits to satisfy the license rcquirement, and is currently having a comprehensive outside audit parformed by Health Physics specialists from another UNC operation.

I

L UNC NavalProducts

~

~_

W i

PRESENTATION FOR i

MEETING l

WITH USNRC INSPECTION 70-371/88-02 APRIL 25,1988 i

,i r

l I

1

=.

t AGENDA i

i t

l 0

MANAGEMENT OVERVIEW i

I o

SUMMARY

REVIEW 0F UNC EVALUATION OF AUDIT ISSUES

!f

,.a o

DISTRIBUTION OF DETAILED EVALUATION i.

8 i

o

SUMMARY

AND COMMITMENT j

i

.I I

I DAY-TO-DAY VS.

PROGRAMMATIC FOCUS

! i I.

i

e l...

RESULTS OF f1RC HEALTH PHYSICS IllSPECTIOtiS OF UtJC f1AVAL PRODUCTS 1981 THRU 1988 18 ti U

10 M

B E

8 R

6 O

F 4

1 T

E 2

M 0

1981 1982 1983 1984 1985 1986 1987 1988 (YTD)

YEAR HP ltJSPECTIOtt P

Fif1AL HP tlO f1C O f.iP LI A tlc E ITEMS f10 tiCO f.1P LI A f1C E IT E f.1S m.

46 4-em r

_4

,a e

ee-

1; M A N A G_E_lLE N T I S S_U_E_S t

o FOCUS ON COMPLIANCE RATHER THAN ASSURING THAT PERSONNEL EXPOSURES ARE MAINTAINED ALARA i

o FAILURE TO ASSESS OBJECTIVELY AND ADEQUATELY THE HEALTH' j;

PHYSICS

PROGRAM, RECOGNIZE NEEDED IMPROVEMENT AND TAKE EFFECTIVE ACTION l

o LACK 0F EFFECTIVE, INDEPENDENT OVERSIGHT PROGRAMS o

LIMITED USE OF MANAGEMENT CHANNELS TO ADDRESS AND l

I' SUES RESOLVE S

o

~ COMPLACENCY:

NO INDUSTRY PARTICIPATION, NO COMMITMENT TO CONTINUING IMPROVEMENT, NO AGGRESSIVE

RESPONSE

TO POT ENTIAL EXPOSURES i

i o

LACK OF PERSONNEL DEPTH AND SUCCESSION PLANNING i

i

.1 8

PLANNED ACTI0NS o

MANAGEMENT / ORGANIZATION AND FOCUS WILL CHANGE-

~

PERSONAL PROTECTION ALARA PRACTICE CONSTANT PROGRAM IMPROVEMENT i

COMPLIANCE

,i o

,00TSIDE ASSISTANCE HAS BEEN SCHEDULED FOR MAY o

OUR PROGRAM WILL BE STRENGTHENED

,i I

INDEPENDENT AUDIT AND OVERSIGHT WILL BE STRENGTHENED INSIDE AND OUTSIDE MAY PERSONNEL-WILL BE EXPECTED TO MAINTAIN INDUSTRY PARTICIPATION MAY I

DOCUMENTED FOLLOWUP WILL BE REQUIRED FOR ALL l

POSITIVE BIOLOGICAL INDICATIONS NOW AIRBORNE MONITORING WILL BE IMPROVED-MAY l

l l

ACCESS TO AND MANAGEMENT SUPPORT WILL BE PROVIDED -

NOW PROCEDURES AND PRACTICES WILL BE EVALUATED FOR COVERAGE AND ADEQUACY JUNE t

-l !

I

I h

BASIC INSPECTION ISSUES

1. REPRESENTATIVENESS OF BREATHING ZONE AIR MONITORING (ITEM 88-02-02)

DRY BOX CLEANOUT SECTIONING SHEAR PRODUCT REWORK VACUUM CLEANER CLEANOUT MAINTENANCE WORKER IN ENCLOSURE

2. ADEQUACY OF SURVEYS (ITEM 88-02-03)

FILTER SELF-ABSORPTION FACTORS BIO-ASSAY MPC-HR EVALUATIONS SELF-MONITORING

3. CORRECTNESS OF EXPOSURE EVALUATIONS AND FOLLOW-UP ACTIONS SHEAR OPERATOR / >40 MPC-HOURS IN 7 DAYS (ITEM 88-02-01)

WORKER WITH >520 MPC-HRS IN QUARTER (ITEMS 88-02-04, 05)

4. ADEQUACY OF AIR BALANCE MAINTENANCE (ITEM 88-02-07) l

5. ADEQUACY OF PREVENTION OF AIRBORNE MATERIALS (ITEM 88-02-08) l VACUUM CLEANER CLEANOUT l

6. ADEQUACY OF HEALTH PHYSICS PROCEDURES (ITEM 88-02-09)

~

7. ACCEPTABILITY OF ANNUAL HEALTH PHYSICS

- AUDITS BY ANI (ITEM 88-02-10) a

~

REPRESENTATIVENESS OF BREATHING ZONE AIR MONITORING (ITEM 88-02-02)

AGREE WITH THE AUDIT COMMENTS

1. ADDITIONAL BREATHING ZONE AIR SAMPLERS WILL BE PROCURED, AND WILL BE USED FOR THOSE OPERATIONS, BOTH ROUTINE AND NON-ROUTINE, WHICH HAVE A HIGH POTENTIAL FOR GENERATION OF AIRBORNE RADIOACTIVITY AVAILABLE FOR PERSONNEL INHALATION.

2. THE LOCATION OF FIXED AIR SAMPLERS IS BEING REVIEWED FOR ALL ROUTINE OPERATIONS WHICH HAVE A POTENTIAL FOR GENERATION AND INHALATION OF AIRBORNE RADIOACTIVITY.

i i

3. OPERATIONS / ACTIVITIES INDICATED ABOVE WILL BE REVIEWED FOR THE FEASIBILITY OF IMPLEMENTATION OF ENGINEERED CONTROLS l

TO PROVIDE GREATER PROTECTION AGAINST l

GENERATION OF BREATHABLE AIRBORNE.

~

~

~

,e e-.p-

ADEQUACY OF SURVEYS (ITEM 88-02-03)

DISAGREE WITH THE AUDIT'S CONCLUSION

1. BASED ON PUBLISHED LITERATURE, UNC'S TECHNICAL JUDGEMENT WAS, AND IS, THAT THERE WOULD BE LITTLE OR NO ABSORPTION BY THE FILTER WHICH WE USE, AND THAT THERE WOULD BE NO SIGNIFICANT UNDER ESTIMATION OF THE ACTUAL AIRBORNE ACTIVITY USING THAT AS A BASIS FOR OUR MEASUREMENTS. HOWEVER, WE ARE TAKING L

THE FOLLOWING ACTION:

A FILTER SELF-ABSORPTION FACTOR OF 15% IS BEING USED, PENDING COMPLETION OF TESTS BEING PERFORMED TO DETERMINE WHAT, IF ANY, ABSORPTION FACTOR IS APPLICABLE TO THE FILTERS BEING USED.

2. IN-VIVO BIO-ASSAY RESULTS HAVE BEEN EVALUATED IN ACCORDANCE WITH SECTION 4.2.3 OF SNM-368. IN l

THE FUTURE UNC WILL SUPPLEMENT THESE EVALUATIONS USING IMPROVED METHODS OF TRACKING AND SUMMARIZING PERSONNEL EXPOSURE.

i_

~

~

~~~.

~

~

ADEQUACY OF SURVEYS (ITEM 88-02-03)

3. WHILE IT IS IMPROBABLE THAT THE AMOUNT OF CONTAMINATION ON THE INDIVIDUAL IN THE NRC'S EXAMPLE WOULD HAVE BEEN SEEN BY PERSONAL MONITORING EQUIPMENT, UNC IS EVALUATING THIS CONCERN AND WILL MAKE APPROPRIATE REVISIONS TO GUIDELINES AND PROCEDURES TO ADDRESS PERSONAL MONITORING REQUIREMENTS FOR THOSE OPERATIONS / ACTIVITIES WHICH HAVE S!GNIFICANT POTENTIAL FOR PERSONNEL CONTAMINATION.

1 l

Mw

~

e6 y.

W-g y

e

-.y,.39g-

---p

--w-m yt,_w

.ygr -a t

- vv. y 7m*--,e.,

r e CORRECTNESS OF EXPOSURE EVALUATIONS AND

~

FOLLOW-UP ACTIONS (ITEM 88-02-01)

DISAGREE WITH THE AUDIT'S CONCLUSION THIS EXPOSURE RESULTED FROM THE EMPLOYEE'S WORK AT A WORK STATION WHICH HAD PREVIOUSLY BEEN RECOGNIZED AS HAVING A HIGH POTENTIAL FOR GENERATION OF AIRBORNE MATERIALS, AND FOR WHICH IMPROVEMENT ACTIONS HAD BEEN UNDERWAY FOR SOME TIME. IN UNC'S OPINION, ADEQUATE RECORDS EXIST RELATIVE TO THAT OVERALL IMPROVEMENT PROGRAM, INCLUDING THIS SPECIFIC EXPOSURE, TO MEET THE 10 CFR RECORDS KEEPING REQUIREMENTS.

IN ADDITION, THE ACTIONS TAKEN HAVE BEEN EFFECTIVE, IN THAT NO EXPOSURES IN EXCESS OF 40 MPC-HRS HAVE BEEN SEEN SINCE THIS SITUATION.

UNC IS CONTINUING TO EVALUATE THIS WORK STATION, AND IS MAKING FURTHER ENGINEERED I

IMPROVEMENTS TO REDUCE THE POTENTIAL FOR AIRBORNE MATERIALS.

m.r_e

c CORRECTNESS OF EXPOSURE EVALUATIONS AND FOLLOW-UP ACTIONS (ITEMS 88-02-04 AND -05)

DISAGREE WITH THE AUDIT'S ANALYSIS

1. THE DETERMINATION OF >520 MPC-HOURS IN THE QUARTER WAS BASED, IN PART, ON TWO FACTORS:

a) THERE WAS NO EXPOSURE IN THE PREVIOUS QUARTER.

b) THE U-235 SEEN BY Ti-lE IN-VIVO COUNT REPRESENTS 1/8th OF THE TOTAL INTAKE (LONG BIOLOGICAL HALF LIFE DEEP LUNG DEPOSITION)

THE RECORDS SHOW THAT THE INDIVIDUAL HAD AN ELEVATED URINE COUNT IN UNIT I LATE IN THE QUARTER PRECEEDING THE IN-VlVO COUNT, THUS INDICATING THAT A PORTION OF THE COUNT IS ATTRIBUTABLE TO A PRIOR PERIOD.

THE 1/8th FACTOR DOES NOT ACKNOWLEDGE THAT THE INDIVIDUAL INGESTED SOME MATERIAL IN THE FEW HOURS PRIOR TO THE IN-VIVO COUNT - SOME OF THAT MATERIAL WOULD BE IN PARTS OF THE BODY OTHER lAN THE LUNG, AS IT HAD NOT HAD TIME TO CLEAR THE INDIVIDUAL'S SYSTEM.

L e

ADEQUACY OF AIR BALANCE MAINTENANCE (ITEM 88-02-07)

AGREE WITH THE AUDIT'S EVALUATION

1. IN THE SPECIFIC CASE, TWO OF THE THREE AREAS IN QUESTION HAVE BEEN BROUGHT INTO COMPLIANCE. THE THIRD AREA (PACK ASSEMBLY)

CANNOT BE CORRECTED WITHOUT VIOLATING GOVERNMENT CONTRACT TECHNICAL REQUIREMENTS. AN AMENDMENT TO OUR NRC LICENSE WILL BE SUBMITTED TO MODIFY THE CURRENT AIR BALANCE REQUIREMENTS, WHILE MAINTAINING ESSENTIAL CONTROL OF CONTAMINATION.

2. A SYSTEM WILL BE INSTITUTED WHEREIN FAILURE TO OBTAIN TIMELY CORRECTIVE ACTIONS OF THIS NATURE WILL BE FORMALLY BROUGHT TO THE ATTENTION OF HIGHER MANAGEMENT TO ASSURE PROMPT ACTION AND COMPLIANCE.

,g..

ADEQUACY OF PREVENTION OF AIRBORNE MATERIALS (ITEM 88-02-08)

DISAGREE h/ITH THE AUDIT CONCLUSION THERE IS NO LICENSE REQUIREMENT APPLICABLE TO THE HOOD WHICH WAS USED FOR ALARA PURPOSES IN THE VACUUM CLEANER CLEANOUT. THE REQUIREMENT CITED APPLIES TO HOODS USED FOR "ROUTINE OPERATIONS", AND NOT TO HOODS USED FOR NON-ROUTINE OPERATIONS SUCH AS THIS INSTANCE.

UNC WILL, HOWEVER, TAKE THE FOLLOWING ACTIONS TO FURTHER IMPROVE ON OUR ALARA APPROACH TO EXPOSURE PREVENTION:

I

1. THE VACUUM CLEANER WILL BE CLEANED UNDER A HIGH AIR VOLUME HOOD, DRY BOX, OR OTHER SUCH ENCLOSURE IN THE FUTURE.

2. OTHER NON-ROUTINE OPERATIONS HAVING THE POTENTIAL TO GENERATE AIRBORNE RADIOACTIVE MATERIAL WILL BE EVALUATED, AND APPROPRIATE ACTIONS TAKEN TO MINIMlZE OR PREVENT SLICH AIRBORNE AND TO PROTECT AGAINST PERSONNEL INHALATION.

1

~

• M"

r _

ADEQUACY OF HEALTH PHYSICS PROCEDURES i

(ITEM 88-02-09)

)

l l

DISAGREE WITH THE AUDIT CONCLUSION THE NUMBER AND DETAIL OF PROCEDURES FOR ANY PURPOSE IS A HIGHLY SUBJECTIVE MATTER, SUBJECT TO THE INTERPRETATION OF THE INDIVIDUAL GENERATING OR REVIEWING THE PROCEDURES.

WE ARE TAKING ACTION TO REVIEW ALL OF OUR HEALTH PHYSICS PROCEDURES AND THE NRC'S COMMENTS, WITH THE INTENT OF STRENGTHENING THIS AREA OF OUR HEALTH PHYSICS PROGRAM.

l 2

M m.h a

eh-

ACCEPTABILITY OF ANNUAL HEALTH PHYSICS AUDITS BY ANI (ITEM 88-02-10)

DISAGREE WITH THE AUDIT'S EVALUATION THE ANI AUDITS REFERENCED IN THE INSPECTION REPORT WERE PREVIOUSLY REVIEWED AND ACCEPTED BY THE NRC, AS SPECIFICALLY COVERED IN INSPECTION REPORTS 85-06,85-09, AND 86-09.

UNC WiLL DISCONTINUE THE USE OF ANI AUDITS TO SATISFY THE LICENSE REQUIREMENT, AND IS CURRENTLY HAVING A COMPREHENSIVE OUTSIDE AUD!T PERFORMED BY HEALTH PHYSICS SPECIALISTS FROM ANOTHER UNC OPERATION.

l k.

• =

%S

.,