ML20196H931
| ML20196H931 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 06/25/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20196H918 | List: |
| References | |
| 70-1201-99-01, 70-1201-99-1, NUDOCS 9907070052 | |
| Download: ML20196H931 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION ll l
I Docket No.: 70-1201 i License No.: SNM-1168 I
Report No.: 70-1201/99-01 Licensee: Frematome Cogema Fuels, Inc.
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Facility: Lynchburg Manufacturing Facility ;
i Location: Lynchburg, VA Dates: May 24-28,1998 ,
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Inspectors: A. Gooden, Radiation Specialist D. A. Seymour, Senior Fuel Facility inspector l
R. E. Swatzell, Fuel Facility inspector Approved by: E. J. McAlpirE, Chief j
Fuel Facilities Branch Division of Nuclear Materials Safety 1
1 Encloure 2 9907070052 990625 PDR ADOCK 07001201 !
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4 t g EXECUTIVE
SUMMARY
Frematome Cogema Fuels NRC Inspection Report 70-1201/99-01 This routine, announced inspection focused on the observation and evaluation of the licensee's operations, maintenance, training, transportation, and waste management programs. The report covers a one week period and includes the inspection efforts of three regional fuel facility inspectors.
Based upon the results of this inspection, the licensee's operations, management organization and controls, radiation protection, environmental protechon, waste management, transportation and maintenance programs were acceptable. Vdabons of license requirements were found in the areas of plant operations, secunty, and radiation protection. The inspection idenbfied the following aspects of the program as outlined below-Plant Operations e Operations were performed in accordance with established safety requirements. The licnes implemented improvements to the ventilation system in the pellet downloading room. (Paragraph 2.a) e The licensee's storage safety controls were adequately implemented. (Paragraph 2.b) e The licensee's housekeeping was adequate to maintain accessibility to routes of egress and emergency equipment. (Paragraph 2.c)
Manaaement Oraanization and Controls I
e No problems were noted with the recent changes that had been made in the licensee's ,i organization. Individuals were aware of their responsibilities with respect to nuclear I criticality and radiological safety. The organization met the structure and qualification requirements specified in the License Application (LA). (Paragraph 3.a)
- A violation was identified for failure to review four operating procedures once every two years as required by the LA. (Paragraph 3.b) ,
i e The Safety Review Board meeting and intemal safety audits were conducted in a timely i manner, and covered a wide range of safety concems. The intemal reviews and audits !
were adequate for detecting potential safety concems. The audits were detailed and ,
thorough. (Paragraph 3.c) l Secunty l
e A violation was identified for the failure to provide proper surveillance of the controlled access area perimeter fence Gate 6 while this gate was open to accommodate decommissioning activities at the Wet Weather Stream site. (Paragraph 4.a)
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2 Radiatior) Protection e Exposure results were significantly less than the limits in 10 CFR 20 as evidenced by the I
maximum assigned Total Effective Dose Equivalent (TEDE) (1.14 rem) and Committed Effective Dose Equivalent (CEDE) (0.824 rem). (Paragraph 5.a and 5.b) e The collective exposures for calendar year 1998 when compared to 1997 resulted l in a reduction in both the TEDE (14 percent) and CEDE (23 percent) exposures.
(Paragraph 5.a and 5.b) l- e Exposures and compliance issues were tracked for resolution and trending to identify undesirable trends. (Paragraph 5.c) e A violation was identified for failure to perform the semiannual in-vitro bioassays for the second half of 1997. (Paragraph 5.d) >
l Environmental Protection e The licensee adequately met the environmental monitoring requirements as set forth in Chapter 5 of Special Nuclear Material (SNM) License Number 1168 and licensee Procedure SL-1270. Environmental samples indicated that plant operations had not significantly affected radioactivity concentration levels offsite. Site remediation activities wers canducted in accordance with the approved sampling plan, and significant progress was achieved in characterization and remediation of the Wet Weather Stream site. (Paragraph 6.a)
Waste Manaaement 1
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- The licensee had an effective program for monitoring radiological constituents in plant l gaseous effluents which met the safety requirements of license SNM License Number ,
1168 and the regulatory constraints of 10 CFR 20. (Paragraph 7.a) e The licensee's program for the shipping of low level radioactive solid wastes for disposal adequately met safety performance requirements. (Paragraph 7.b)
Transoortation e Activities associated with preparation of shipping papers, packaging, and the conduct of radiation / contamination surveys were conducted in a manner to provide for safety during transport of material. (Paragraph 8.a and 8.b)
Maintenance / Surveillance e Maintenance and surveillance testing of the ventilation systems was performed in accordance with fatemal procedural and the I.A requirements. (Paragraph 9.a)
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Training I
- The licensee's General Employee Training met the requirements of Section 2.5,
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Training, of the LA and of 10 CFR 19.12. The training was in-depth and thorough.
(Paragraph 10.a) - l
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4 Attachment List of Persons Contacted inspechon Procedures Used List of items Opened, Closed, Discussed List of Acronyms Used l
REPORT DETAILS
- 1. Summary of Plant Status This report covered the efforts of three regional inspectors during a one week period.
Routine operations were ongomg at Fram'etome during the week. There were no unusual plant operational occurrences during the onsite inspection.
- 2. Plant Operations (IP 88020)(03)
- a. Conduct of Operations (03.01)
(1) Insoechon Scope Operations in the fuel rod loading, fuel assembly fabrication and Service Equipment Refurbishment Facility (SERF) areas were observed for adherence to safety significant requirements.
(2) Observations and Findinos The inspector observed pellet loading and fuel assemblies being constructed in the manufacturing area and noted that operations were performed in accordance with the safety requirements in posted instructions and procedures. The inspector noted that the licensee had implemented improvements to the pellet downloading room ventilation system to improve (reduce) airbome concentrations.
(3) Conclusions Operations were performed in accordance with established safety requirements. The licensee implemented improvements to the ventilation system in the pellet downloading room,
- b. Imolementation of Storaae Safety Controls (03,04)
(1) Inspection Scope Safety controls identified for storage of pellets, rods, assemblies, and contaminated equipment were reviewed for compliance with requirements in procedures and postings.
(2) Observations and Findinas The !nspector observed the storage of pellet-filled rods in the manufacturing area storage bins and the storage and handling of completed fuel assemblies prior to packaging for shipment. The inspector found that the rods and assemblies were stored in accordance with nuclear criticality safety requirements posted in each area.
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2 (3) Ggnclusions The licensee's storage safety controls were adequately implemented.
- c. Hougekeeoina (03.06)
(1). Insoection Scoce , l th:i::$5 prachoes throughout the plant were reviewed to identify safety significant problem areas.
(2) Observations and Findinos During process tours, the inspector observed routes of emergency egress, accessibility to safety equipment and overall housekeeping throughout the plant. The inspector observed that the er.orgency routes of oc was.were clear of debris and equipment. The inspector also observed that safety equipment (fire extinguishers, electrical switchgear,
- etc.) were readi!y accessible with no significant obstructions. Outdoor areas continued to -
contain numerous storage containers for equipment to be processed in one of the SERF areas, but such storage did not significantly hinder the ability to vacate the' premises in case of emergency.
(3) Conclusions The licensee's housekeeping was adequate to maintain accessibility to routes of egress and emergency equipment.
- 3. Management Organization and Controls (IP 88005) (05)
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. a. Oraanizational Structure (O5.01)
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(1) Inspection Scoos The inspector reviewed the licensee's organizational structure to determine whether it met the requirements in the License Application (LA) for structure and personnel i qualifications, and to determine if key individuals were aware of their responsibilities with j respect to nuclear criticality and radiological safety. 1 1
(2). Observations and Findinas 1
The inspector reviewed the licensee's organization structure and the resumes of several I individuals in key positions and determined that the licensee's organization met the requirements specified in the LA Discussions with selected individuals indicated that l the personnel were aware of their responsibilities with respect to nuclear criticality and !
radiological safety. I l
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(3) Conclusions ,
No problems were noted with the recent changes that had been made in the licensee's organization. Individuals were aware of their responsibilities with respect to nuclear criticality and radiological safety. The organization met the structure and qualification requirements specified in the LA.
- b. Procedure Controls (05.02) l (1) Inspection Scoos The inspector reviewed selected operating procedures to determine if they had been reviewed at least once every two years by the appropriate production manager and the manager of Radiation Protection, as required by the LA.
(2) Observations and Findinos
- The inspector reviewed several operating procedures and determined that four of these ,
procedures were not reviewed in the last two years, as required by the LA. Discussion with the licensee indicated that they considered the two year review of material control i and accounting procedures and safety procedures (both of which are referenced in the operating procedures) as meeting the LA requirements for the review of operating procedures. However, the licensee agreed, after further consideration and discussion, that these procedure reviews did not meet the intent of the LA for an operating procedure review. This failure is considered safety significant due to the potential effect of process changes not being properly reflected in operating procedures. In addition, the inspector noted that this failure was similar to Non-cited Violation (NCV) 70-1201/97-05-02 for failing to perform the required reviews of two procedures. This is a concem because the corrective actions for the NCV should have prevented recurrence of this problem. The failure identified in this inspection report for not meeting LA requirements for reviewing operating procedures is identified as a violation (VIO) (Violation 70-1201/99-01-01, Failure to review operating procedures as required by the LA).
The licensee's short term corrective actions included: (1) identifying operating procedures which fell outside of the two year review period and (2) initiating the review of these procedures. The licensee's long term corrective actions included the development i of a procedure review program for the different types of procedures at the site (operating, j health-safety, accounting, etc.), determining their review periods, who is ;esponsible for the review, and implementing a system to ensure that the precedures are reviewed in a timely manner and in accordance with the requirements in the LA. This effort is scheduled to be completed by December 31,1999. l (3) Conclusions j l
A violation was identified for failure to review four operating procedures once everv two !
years as required by the LA.
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, c. Intemal Reviews and Audds (05.03) .
Safety Committees (05.04) i (1)' inspection Scope The licensee's system for performing intomal reviews and audits was examined to ,
determine its adequacy for detecting potential safety concems. l 1
(2) Observations and Findings I The inspector reviewed the Safety Review Board (SRB) reports for 1998 and the first quarter of 1999, the licensee's monthly safety audits, and the licensee's semiannual audits for nuclear safety, fire safety, and health physics for 1998. The inspector noted that the audits were conducted as required, covered a wide range of concems, and were
-detailed and thorough.
r' (3) Conclusions l
. I' The SRB meeting and intamal safety audits were conducted in a timely manner, and covered a wide range of safety concems. The inspector concluded that the intemal l reviews and audits were adequate for detecting potential safety concems. The audits -i were detailed and thorough. I
- 4. Security (IP 81431)(S2)
- a. Access Controls (S2.04)
(1) insoection Scope The inspector performed a routine inspection of the licensee's perimeter fence to determine compliance with the instituted Security Plan for the Controlled Access Area (CAA).
'(2) Observations and Findings While performing an inspection of the CAA perimeter fence, the inspector observed that Gate 6 was open and that vehicles were entering and exiting the Framatome Cogema site through this portal. The inspector observed that no immediate security personnel were available to provide adequate surveillance of vehicle portage through Gate 6. The l inspector inquired into this situation and was informed that Gate 6 was continually left
. open to allow vehicles associated with the Wet Weather Stream decommissioning '
activit'es access to the plant site. The inspector noted that these vehicles used the gate on a ' itermittent basis, and that the gate was'not visible from the Wet Weather Stream.
The inspector noted that this was not in compliance with the Site Security Plan which requires that Gate 6 will remain closed and locked, except when in use or attended. The inspector observed that the plant's main secunty gate could not reasonably be
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considered a suitable observation point for Gate 6 ingress and egress due to: (1) the distance between the main plant entrance and Gate 6 (approximately 200 yards), (2) the fact that security personnel do not always roan the main plant entrance, and (3) security personnel at the main plant entrance could become preoccupied with additional duties (entrance, exiting, etc.). This is considered safety significant due to the potential for members of the public to enter the radioactive materials areas without proper safety training or escorts, or with malicious intent. . This violation is identified as VIO 70-1201/
99-01-02, Failure to secure security gate. The licensee's immediate corrective actions were to secure the gate. The licensee's long term corrective actions include a revision to the procedure requiring two levels of management approval prior to allowing an exception to the security plan with regard to security gates. The procedure revision should be completed by August 31,1999.
(3) Conclusions A violation was identified for the failure to provide proper surveillance of the CAA perimeter fence Gate 6 while this gate was open to accommodate decommissioning actuties at the Wet Weather Stream site. -
- 5. Radiation Protection (IP 83822) (R1)
- a. Extemal Exoosure Control (R1.04)
(1) Inspechon Scoos The inspector reviewed licensee procedures to determine if controls were in place to monitor occupational dose, and verify that soministrative limits were established to control occupational dose as low as reasonably achievable (ALARA). Personnel exposure data for calendar year (CY) 1998 was examined to determine if exposures were in compliance with 10 CFR Part 20 limits.
(2) Observations and Findinas Exposure results were significantly less than the limits in 10 CFR 20 (See Table 1 below). The CY 98 collective exposure of 25.6 person-rem resulted in a reduction of approximately fourteen percent when compared to CY 97 results (29.8 person-rem).
The 1.14 rem maximum assigned TEDE was less than the ALARA goal of 1.50 rem.
Table 1 Annual Exposures Year Deep Shallow Dose TEDE Collective CEDE Dose Equivalent TEDE Equivalent (SDE) (person-rem)
(DDE) 1997 0.659 rem 5.23 rem 1.28 rem 29.6 1.06 rem 1996 0.180 rem 2.49 rom 1.14 rem 25.6 0.024 rem
6 (3) Conclusions Based on the records review and interviews, the inspector concluded that the licensee's ,
extemal exposure control program was adequate for evaluating and monitoring l personnel exposures. Exposure results were significantly less than the limits in 10 CFR 20 as evidenced by the maximuni assigned TEDE which was 23 percent of limit and the maximum assigned DDE was approximately 3.6 percent of 10 CFR Part 20 limits.
- b. Intemal Exposure Control (R1.05)
(1) Insoection Scope The inspector reviewed licensee procedures for assessing intemal exposure to determine if controls were in place to monitor occupational dose, and verify that the administrative limits were established to control occupational dose ALARA. Exposure data for CY 97 and 98 was reviewed to determine if exposures were in compliance with 10 CFR Part 20 limits.
(2) Observations and Findinas i
Administrative limits were established below federal limits to ensure personnel l exposures did not exceed limits in 10 CFR 20. Table 1 above presents the maximum j assigned CEDE exposure data for CYs 97 and 98. The maximum assigned CEDE ;
in CY 98 (0.824 rem) was approximately 22 percent less than the CY 97 exposure l (1.06 rem).
l (3) Conclusions i
Based on the interviews and documentation reviewed, the inspector determined that the licensee's intomal exposure control program was adequate for evaluating and monitoring personnel exposures. Administrative dose limits were established and all assigned exposures were well below the regulatory limits. The collective CEDE for CY 98 (8.16 person-rom) was approximately 23 percent less than CY 97 (10.58 person-rem) and the maximum assigned CEDE was approximately 16 percent of limits in 10 CFR 20.
- c. Imolementation of ALARA Proaram (R1.10)
(1) InsDection Scope The licensee's Al. ARA program was reviewed to determine if the program and ALARA goals were being developed and implemented in accordance with the license. In addition, the program for reinforcing ALARA concepts among employees was assessed
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7 (2) Observations and Findmgs Based on site access training, a review of the Employee Safety Handbook and interviews with workers, the inspector determitied that the training detailed several aspects of ALARA including the site philosophy, definition, employes's role in ALARA, and examples of ALARA.
During CY 98, quarterly meetings were held by the Safety Review Board (SRB) to review action items, personnel exposure trends, radiological deficiencies and status of ALARA recommendations. ' Evpa* Lees and compliance issues were tracked for resolution and trending to identify undesirable trends. The annual ALARA Report for CY 98 as required by Procedure SL-1170 had not been prepared at the time of the inspection.
-(3) . Conclusions The training program for reinforcing ALARA concept among employees was adequately implemented. The quarterly SRB meetings provided an opportunity for the licensee to
- identify undesirable trends involving exposures, compliance issues, and progress in ,
achieving the ALARA goals and commitments.
- d. Followuo on Previously Identified lasues (IP 92701) (R1.12)
(1) Inspection Scoce The inspector reviewed the licensee's actions to correct previous issues to verify that the corrective actions were adequate and complete.
I (2) Observations and Findinas (a) - (Closed) Inspector Followup item (IFI) 70-1201/98-03-01: Review the corrective actions to upgrade the waming system for the loss of ventilation.
Since the last inspection, the licensee had upgraded the waming system to include both a visual (red revolving light) and audible alarm. The previous waming was limited to the red revolving light. The inspector observed a test of the pellet loading room wamirg system for verification of operation and effectiveness and no problems were noted.
(b) (Closed) Unresolved item (URI) 70-1201/98-03-02: Inability to demonstrate that semiannual bioassay samples were collected and analyzed.
This item was closed and a violation identified for failure to perform the semiannual in-vitro bioassay for the second half of CY 97. Section 8.0 of Procedure SL-1250 required that routine in-vitro analysis (urine samples) be performed on a semiannual basis of program participants. This is considered safety significant due to the potential for undetected worker intake of radioactive material, which could become significant if uncorrected. The licensee attributed, as the root cause for the violation, the failure to track the completion of intemal program requirements, and an ineffective designed
8 routine and non-routine tasks sheet. In response, the appropriate check-list was redesigned. The inspector reviewed the status of the uranium bioassay (in-vitro and in-vivo) sampling and analysis program for CY 98 and thus far in CY 99. No problems were noted. In-vitro samples were collected and shipped in a timely manner for analysis. The licensee's corrective actions appeared to have been effective in preventing a recurrence.
The failure to perform the semiannual in-vitro bioassays in accordance with Procedure SL 1250 is identified as Violation 99-01-03. Because appropriate and effective corrective actions were completed prior to the issuance of this report, this violation is also considered closed.
(c) (Closed) IFl 70-1201/98-03-03: Verify that routine bioassay samples are sent in a timely manner for analysis.
A revi3w of the documentation associated with the routine sample collection and analysis disclosed that for CY 98, and thus far in CY 99, samples were collected and shipped within seven days of collection. 1 (d) - (Closed) IFl 70-1201/98-03-04: Lack of criteria in procedure addressing bioassay data .
evaluation.
Procedure SL-1250 entitled Bioassay Program was revised to incorporate criteria in Section 10.3 for satisfactory performance of urine sample blank, spike, and duplicate l samples.
t (3) Conclusions A violation was identified for the failure to perform the semiannual in-vitro bioassays for the second half of 1997. The corrective actions for the violation and other items noted l above were acceptable and effective, j
- 6. Environmental Protection (IP 88045) (R2) a i
- a. Monitorina Prooram Results (R2.02)
(1) Inspection Scooe The inspector reviewed the licensee's environmental surveillance program for compliance with the requirements as set forth in Chapter 5 of License SNM-1168 and the ;
licensee's guidancs procedure SL-1270. Monitoring results for surface water, soil, i vegetation, sediment and environmental air samples were reviewed to assess the i radiological impact to the environment due to plant operations. )
l (2) Observations and Findinas The inspector reviewed the licensee's most recent results for surface water, soil, vegetation, sediment, and environmental air samples, and observed that samples were acquired at the prescribed frequency and that the gross alpha and gross beta activity
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levels were consistently below licensee established action level limits. In addition, no I upward trends were distinguishable in the reviewed environmental results as the I reported activity levels for environmental samples remained consistent with the results reported for previous monitonng periods.
The inspector also observed the licensee's continued characterization and remediation activities at the Wet Weather Stream contaminated site. Further characterization of previously identified contaminated areas and adjacent areas to known contamination was being performed using a sodium iodide spectroscopy system. Significant progress had been achieved in charactenzation of the Wet Weather Stream site and characterization activities were being conducted according to the approved sampling plan. The inspector requested sufficient notification prior to acquisition of confirmatory samples to allow for split sampling for duplicate analysis.
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(3) Conclusion The licensee adequately met the environmental monitoring requirements as set forth in Chapter 5 of license SNM-1168 and licensee procedure SL-1270. Environmental ,
samples indicated that plant operations had not significantly affected radioactivity concentration levels offsite. Site remediation activities were conducted in accordance with the approved sampling plan, and significant progress was achieved in characterization and remediation of the Wet Weather Stream site.
- 7. Waste Management (IPs 88035 and 84850) (R3) '
- a. Airbome Effluent Controls. Instrumenteisen. and Monitorina Results (R3.03 and R3.04) ,
(1) Inspection Scope The inspector reviewed the licensee's gaseous emuents program for compliance with the safety requirements per 10 CFR Part 20 and the license requirements of Chapter 3 of SNM-1168. The inspector also toured the licensee's gaseous emuent sampling stations and observed the acquisition of samples for monitoring purposes.
(2) Observations and Findings The inspector reviewed the licensee's semi-annual gaseous emuent report for the second half of 1998 and monitoring results for the first and second quarters of 1999, and observed that radiological emuents (predominantly uranium isotopes) were approximately 53 percent (sum of fractions methods) of the limits speafied in 10 CFR 20. j in addition, main plant stack gross alpha activity emissions for the second half of 1998 !'
remained consistent (2.35 pCi to 2.33 pCi) when compared to the previous reporting period. A merked decrease in gross beta (cobalt-60) activity in gaseous emuents (approximately 27 pCi to 52 pCi) was observed for the second half of 1998 in comparison to the first half of 1998. This decrease in emuent beta activity was primarily j due to decreased activity levels in SERF-4 radiologically controlled area (RCA) facility i emuents. The inspector also observed the acquisition of routine samples at the l
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I e 10 individual gaseous effluent sampling stations and observed that personnel were adequately trained in the acquisition of radiological samples and sampling equipment was well maintained and property calibrated.
(3) Conclusions The licensee had an effechvo program for monitoring radiological constituents in plant gaseous effluents which met the safety requirements of license SNM-1168 and the regulatory constraints of 10 CFR 20.
- b. Radioactive Solid Waste fR3.05. R3.06. R3.08. and R3 09)
(1) Inspechon Scone The inspector reviewed the licensee's program for the classification, packaging, shipping, and tracking of low level radioachve waste pursuant to the safety requirements of 10 CFR 20.2006, Appendix G of 10 CFR Part 20, and 10 CFR Part 61.55 and 61.56.
The inspection involved the review of shipping manifests, tracking of radioactive .
shipments, and instrumentation calibration and quality control records.
(2) Observations and Findinas Two low level radioactive waste shipments in November and December of 1998 were l reviewed for acceptable licensee safety performance it was observed that wastes were !
classified correctly and that the waste manifests contained the required information l (identified radionuclides, activity and mass quantities, shipping weight, etc.). The hcensed waste receipt facility was notified prior to shipment of the radioactive material and the licensee had established a system for verification of acknowledgment of receipt I from the disposal facility within the required time frame. The inspector also reviewed the ;
' calibration records for the drum counter system (used for determining U" content) and observed that the required calibrations and system checks (standards and background) i were performed properly and at the designated frequency.
(3) Conclusions The licensee's program for the shipping of low level radioactive solid wastes for disposal adequately met safety performance requirements.
- 8. TranspoMation (IP 86740)(R4)
- a. P.gsereion of Packaoes for Shioment (R4.01. R4.02)
(1) Insoaction Scoce Transportation activities associated with the packaging and shipment of radioactive material were reviewed, to verify that activities were in accordance with NRC and Department of Transportation (DOT) safety requirements in 10 CFR 71 and 49 CFR Parts 171-189.
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(2) Observations and Findinas The inspector reviewed procedures and observed the licensee's performance in vehicle loading and placarding for a shipment involving low specific activity (LSA) material.
Based on inspector observations, the appropriate container labeling, radiation and ,
contamination surveys, and container markings were applied. Shipping papers included l the appropnote emergency response information and a twenty-four hour emergency response t'J,ene number. The performance by radiation protection personnel in conducting surveys was effective in demonstratmg that the radiation / contamination limits (vehicle and package) were in accordance with the limits in 49 CFR 173.
(3) Gonclusions Activities associated with preparation of shipping papers, packaging, and the conduct of i radiation / contamination surveys were conducted in a manner to provide for safety during transport of material.
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- b. Receipt of Packaoes (R4 03) l I
-(1) Insoection Scoos 1 l The inspector observed transportation activities associated with the receipt of an l exclusive use shipment to determine if procedures were in place and activities were I conducted in accordance with 10 CFR 20.1906.
l (2) Observations and Findinas The inspector reviewed Procedure SL-1600 entitled " Shipment and Receipt of Radioactive Material" and noted that the requirements in 10 CFR 20.1906 for package !
receipt were adequately addressed. Radiation control personreel conducted effective surveys to determine if the radiation / contamination limits were acceptable prior to the !
receipt of contaminated equipment assigned to the SERF Close agreement was noted !
between the shipper and receiver regarding the radiation survey results. 1 (3) Conclusions -
t Actions by radiation control personnel were effective in determining whether radiation / contamination limits were acceptable prior to receipt of packages. Procedures were in place to ensure that the activities associated with package receipt was conducted in a safe manner.
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- c. Certificates of Compliance (R4.04)
(1). Insooction Scone Verify that the licensee's Certificates of Compliance (CoC) were maintained current and comphed with requirements in 10 CFR Part 71.
(2) ' Observations and Findmas The inspector reviewed documentation for Model B shipping containers used to transport fuel assemblies during the period January 1999 through February 1999. Based on documentation and an interview with a member of the license's staff, the CoC for the Model B shipping containers (CoC 6206) expiration date was SeptemLer 30, 2000.
(3) Conclusions A current CoC was available for the selected container.
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- 9. . Maintenance / Surveillance (IP 88025) (F1)
- a. Survedlance Testina (F1.06)
(1) Insoection Scoce Maintenance activities were reviewed to determine adequate implementation of licensee '
intamal procedures for conducting maintenance, and performing surveillance tests.
(?) Observations and Findinos The inspector reviewed the periodic maintenance requirements and surveillance tests for the facility's ventilation systems. This review of the maintenance requirements included !
a review of pressure drop measurements across high efficiency particulate air (HEPA) filters, isokinetic sample verifications, records of filter change-outs, and dioctyi phthalate (DOP) testing of the HEPA filters. The inspector reviewed records and audit reports which indicated that these tests were performed as required. No discrepancies with applicable procedures were noted.
(3) Conclusions Maintenance and surveillance testing of the ventilation systems were performed in l
accordance with intemal procedural and the L.A requirements. I 1
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' b. Followuo on Previousiv identified teete (IP 92701) (F1.08)
(1) inspection Scoce The inspector reviewed the licensee's actions to correct a previous issue to verify that the corrective actions were adequate and complete.
(2) Obaarvations and Findings IFl 70-1201/98-02-03 Lack of instnactions in Safety Pramd was t for Handlina Abnormal Condshons
' The inspector reviewed the licensee's response to the IFl and determined that the
' licensee had revised the amtilation procedures to include steps delineating the actions to be taken when test results exceeded accepted limits. The inspector reviewed the corrective actu,ns and determined that they were acceptable and complete.
(3) Conclusions -
- This item is closed.
- 10. Training (IP 88010)(F2)
- a. 10 CFR 19.12 Trainina (F2.01)
General Nuclear Criticality Safety Training (F2.02)
General Radiological Training (F2.03)
General Emergency Trainina (F2.04)
(1) Inspection Scoos
- The licensee's General Employee Training (GET) was reviewed to verify compliance with Section 2.5, Training, of the LA, and with 10 CFR 19.12 requirements.
(2) Findings and Observations The inspector attended sessions of the licensee's GET and Fire Safety Training. This training involved the initial indoctrination training provided to new employees, and annual I refresher training. The training included industrial safety concepts, radiological safety, cribcality cafety, emergency response, chemical safety, and fire safety. Safety principles j and safe prachces were emphasized in the class. The inspector noted that the training ;
incorporated the subject areas required by the LA and 10 CFR 19.12. The GET training i was in-depth and thorough.
(3) Conclusions !
l The inspector concluded that the training met the requirements of Section 2.5, Training, j of the LA, and 10 CFR 19.12. The GET training was in-depth and thorough. l 4
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- 11. Exit Interview The inspechon scope and results were summarized on May 28,1999, with those persons indicated in the Attachment. Although propnetary documents and processes were occasionally reviewed during this inspechon, the proprietary information is not included ln this report. Dissenting comments were not received from the licensee.
ATTACHMENT LIST OF PERSONS CONTACTED Licensee
- T. Alisep, Manager, Radiation Protection
'C. Armontrout, Manger, Licensing and Quality Systems T. Blanks, Technician, Radiation Protection
- D. Gordon, Project Engineer
- A. Jenkins, Manager, SERF 3 and 4 Facilities -
- G. Lindsey, Health Physicist j
- J. Matheson, Plant Manager D. Mayberry, Technician, Radiation Protection
- M. Moore, Manger, Facility and Services l
C. Sanders, Consultant '
'V. Holaday, Manager, Assembly Product Center
- J. Whitt, Manager, Compliance and Skills Training Program
- T. Wilkerson, Manager, Quality, Health / Safety and Licensing INSPECTION PROCEDURES USED IP 81431 Security, Low Enriched Facilities IP 83822 Radiation Protection IP 84850 Radioactive Waste Management IP 86740 Transportation Activities IP 88005 Management Organization and Controls
. IP 88010 Operator Training / Retraining IP 88020 Regional Nuclear Criticality Safety inspection Program IP 88025 Maintenance and Surveillance Testing IP 88035 Radioactive Waste Management IP 88045 Environmental Protection -
IP g2701 Follow up 1
J
E.
i 2
LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED item Number Sinha Description 70-1201/99-01-01 Open VIO - Failure to perform a two year review of operating procedures (Paragraph 3.b).'
70-1201/99-01-02 Open VIO - Failure to secure a security gate (Paragraph 4.a).
70-1201/98-03-01 Closed . lFI - Review the corrective schons to upgrade the woming system for the loss of ventilation (Paragraph 5.d.(2) (a)).
LIST OF ITEMS OPENED. CLOSED. AND DISCU8L9ED (continM 70-1201/98-03-02 Closed URI - Inability to demonstrate that semiannual bionssay samples were collected and analyzed (Paragraph 5.d.(2) ;
(b)).
~
70-1201/99-01-03 Open/ VIO - Failure to perform semiannual in-vitro bioassay in Closed accordance with Procedure SL-1250 (Paragraph 5.d.(2)
(b)).
70-1201/98-03-03 Closed IFl - Verify that routine bioassay samples are sent in a timely manner for analysis (Paragraph 5.d.(2) (c)).
70-1201/98-03-04 Closed IFl - Lack of criteria in prococlure addressing bionssay data evaluation (Paragraph 5.d.(2) (d)).
70-1201/98-02-03 Closed IFl - Lack of instructions in safety procedures for handling ;
abnormal conditions (Paragraph 9.t').
LIST OF ACRONYMS USED
\
ALARA As Low as is Reasonably Achievable CAA Controlled Access Area CEDE Committed Effective Dose Equivalent CFR Code of Federal Regulations CoC Certificate of Compliance CY Calendar Year DDE Deep Dose Equivalent DOT Department of Transportation GET General Employee Training HEPA High Efficiency Particulate Air IFl inspector Followup item 4 LA License Application I I
LSA Low Specific Activity
p.
...f,
, 3 MDA Minimum Detectable Activity pCl Microcurie NRC Nuclear Regulatory Commission RCA- Radiologically Controlled Area 3
- SDE Skin Dose Equivalent -
SRB Safety Review Board 1 SERF Service Equipment Refurbishment Facility k
-/- .
TEDE Total Effectwo Dose Equivalent !
U888 Uranium-235 .
URI Unresolved item -
VIO Violation -
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4 9
9 ao s.
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