ML20205D037

Insp Rept 70-1151/88-13 on 880829-0902.Violations Noted. Major Areas Inspected:Radiation Protection Program,Including Adequacy of Adherence to Procedures & Use of Radiation Detection Instruments

ML20205D037
Person / Time
Site:	Westinghouse
Issue date:	10/06/1988
From:	Hosey C, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205D016	List: ML20205D012 ML20205D025 ML20205D037
References
70-1151-88-13, IEIN-88-032, IEIN-88-062, IEIN-88-32, IEIN-88-62, NUDOCS 8810270048
Download: ML20205D037 (11)

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I Report No.: 70-11,1/88-13 Licensee: Westing iouse Electric Corporation Connerc al Nuclear Fuel Division Columbit. SC 29250 Docket No.: 70-1151(FuelDivision) License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection Conducted: August 29 - September 2. 1988 Inspector: /

K. T.;Liuer M A'N/#

Mate Signed Approved by:

C. M. Hosey. Sectio 4 Chief

/o/(/N Date Signed Division of Radiaticin Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection involved review of the radiation protection program including adequacy of and adherence to procedures, use of radiation detection instruments and equipment, internal exposure control, control of radioactive material, and ALARA aspects of the radiation protection program. A review of the licensee's actions regarding NRC Information Notices (ins) and previous Inspector Followup Items (IFis) was also performed.

Results: For the areas reviewed, the licensee's radiation protection program appeared adequate to accomplish its objectives regarding the health of occupational workers and the safe use of radioactive material. However, increased attention, by the licensee. is required in the area of self-indentification of deficiencies in routine. Iow profile radiation protection activities.

Within the areas inspected, the following violations were identified:

- Failure to properly post a radioactive naterials area (Paragraph 2.e.(1)).

Failure to follow procedures for contamination limits for equipment in storage cutside the cuntamination controlled area (Paragraph 2.e.(2)).

Failure to perform continuous, adequate contanination surveys of newly employed expansion areas of the plant (Paragraph 2.e.(3)).

l SG10270043 881012 PDR ADOCK 07001151 C PDC

l REPORT DETAILS

1. Persons Contacted Licensee Employees R. Burklin, Senior Engineer, Radiological and Environmental (0&T)

Engineering

• R. Fisher, Senior Engineer, R&E Engineering H. Foster, Senior Engineer, R&E Engineering

• W. Goodwin, Manager, Regulatory Affairs

• W. Hartnett, Manager, Columbia Customer Support

• J. W :th Manager, Health Physics Operations

• E. Keelen, m..uger, Manufacturing

• E. Reitler, Manager, R&E Engineering T. Shannon, R&E Technician Other licensee employees contacted during this inspection included engineers, technicians, operators, and office personnel.

• Attended exit interview

2. RadiationProtection(83822)

a. Organization and Management (1) Staffing Through discussions with licensee management the inspector verified that no significant staff changes had occured since the last inspection, Report No.70-1151/88-03. Daily radiation protection activities were performed by seven technicians during day shift and eight technicians with a supervisor during backshift.

(2) Management Controls The daily oversight responsibilities of the Health Physics (HP)

Operations Manager and HP Operations Supervisor were reviewed by the inspector.

The daily documentation and data review processes appeared adequate to allow management to identify anomalies in reutine radiation protection parameters, such as elevated air sample results and abnormal instrument calibration checks. The inspector noted appropriate management identification and initiation of upgrades in programs and equipment. Hewever, as evidenced by the identified violations, management's effort to identify and correct inadequacies in existing HP activities and J

2 responsibilities could be strengthened to prevent possible trends towards performance complacency, i

No violations or deviations were identified

b. Radiation Protection Procedures '

Selected radiological protection procedures were reviewed to verify  ;

that the guidance provided was consistent with regulations and license requirements. Findings and comments concerning specific procedures are documented in this report in the paragraphs covering the associated program area.

Section 2.6.2 of the License Application for License No SNM-1151 henceforth referred to as the License Application, requires that 7 Regulatory Affairs (RA) Procedures and HP Operating Frocedures be reviewed on an annual frequency. The inspector verWied that all  ;

procedure review / revisions had been completed within the required l frequency. The inspector noted that the tracking system which is l used to identify procedures requiring review consisted of several i typed and handwritten lists or simply handwritte.n notations on the procedures themselves. The licensee agreed that a more formal and e

organized tracking system was needed and would be implemented in the ,

near tutt'e. t' No violations or deviations were identified.

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c. Training and Qualifications (1) Jeneral Employee Training 10 CFh 19.12 requir , that all individuals working in or frequenting any pcrt ,n of a restricted area shall be provided c with basic radiation protection training. [

j The inspectcc reviewed lesson plans and a video tape used for general employee training and verified that all topics specified ,

in 10 CFR 19.12 were covered during the training. Selected training records of licensee personnel working in the radiation l controi area were reviewed. Training medical qualificat on.

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I and respirator fit testing records fo,r selected individuals  ;

issued resotrators were also reviewed.  ;

(2) HP Technician Training  !

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! Licensee representatives stated that restructuring of the HP f technician grcup, as refetenced in Inspection Report No. 70-1151/88-03, is still in the planning stages. Current plans call for the implementation of a knowledge and performance l based training program. Ccmpletion of successive levels of training will be a decision criteria used to assign technicians

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3 increased responsibilities with associated promotion potential.

Also planned, is a greater differentiation of technician l positions based on his or her knowledge and performance.

Currently, the terms "technician" (including techs in training) and "lead technician" are used to define position in the organization. The program improvements allow for five promotion levels for technicians. The inspector noted that the changes in  ;

the HP technician program, proposed by the licensee, exemplifies "

the licensee's desire to assure that first line radiation protection personnel are qualified and able to perform their assigned duties.

l Ho violations or deviations were identified. ,

d. Radiation Detection Instruments and Equipment j i

j Section 3.2.1.2 of the License Application requires that alpha I

counting equipment used in the laboratory shall be checked each working day in use, to determine background activity and that a i calibrated source be counted to assure proper instrument functioning. l In addition, a voltage plateau and the proper counting voltage of each instrument shall be determined quarterly. The inspector i reviewed Source Checks /'2fficiency Data Sheets for the laboratory l~

Tennelec Counters, through August 1988, and verified that the l l required checks were performed each shift; a more frequent schedule '

than required. The inspector also reviewed Tennelec Counter l

calibration data, through July 1988, and verified that thc  !

calibrations were performed monthly and complied with HP Operating Procedure 01-025. "Calibration of Tennelec LB 5100 Autematic Sample  :

Counters". Rev. 1.

During plant tours, the inspector observed the proper use and ,

selection of portable instruments appropriate for the radiation protection activity in progress. The inspector verified that  ;

instruments in use or available for use had been calibrated within the prescribed time period.

Thr agh discussions with licensee representatives, the inspector i detennined that the licensee was assessing the purchase of several j new pieces of equipment. New respirator fit testing equipment was  ;

being reviewed which did not require a booth or detectable aerosol, '

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i.e., irritant smoke, banana oil, etc. A respirator with interior sampling ports is used to compare ambient room air with filtered air within the respirator using a computerized analysis instrument.

Also, under consideration for possible purchase was a new gama spectroneter and an advanced alpha / beta counter.

No violations or deviations were identified.

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e. Posting, Labeling, and Control of Radioactive Material (1) Posting and Labeling Section 3.2.2.4 of the License Application states that each entrance or access point to the Controlled Access Area shall be i posted in accordance with 10 CFR 20.203 except for 10 CFR 20.203(f). In lieu thereof, a sign bearing the legend, "Every container or vessel in this area may contain radioactive l material", shall be posted at entrances to each area in which radioactive materials are processed, useo, or stored. During  :

tours of the plant the inspector noteo an entrance to a Controlled Access Area, specifically, the outside yard area which lacked the above specified sign. The inspector verified i that possible routes to that entrance also lacked such signs. A tour of the yard did not reveal the existence of any container ,

or vessel containing radioactive material except that referenced below. The licensee posted the entrance in question and initiated the identification and correction of any other possible unposted Controlled Access entrances.

10 CFR 20.203(e) requires that each area or room in which t licensed material is used or stored and which contains any radioactive material in an amount exceeding 10 times the quantity of such material specified in Appendix C of this part i shall be conspicuously posted with a sign or signs bearing the ,

radiation caution symbol and the words "CAUTION, RADI0 ACTIVE 4 MATERIAL (S)."

During a tour of the outside yard area, the inspector observed unlocked, open storage trailers containing contaminated material i and lacking the required posting, as stated above. At the request of the inspector, surveys of the material in one of the

, trailers were perfonned. These surveys indicated significant .

levels (specified in Paragraph 2.e.(2)) of smearable and fixed i contamination. The inspector informed licensee representatives that failure to post an area in which licensed material is ,

l stored with the radiation caution symbol and the words "CAUTION,  !

RADI0 ACTIVE MATERI AL." would be identified as an apparent i violation of 10 CFR 20.203(e) (70-1151/88-13-02).

(2) Control of Radioactive Material The inspector observed numerous individuals exiting the control point, in all cases, the individuals performed appropriate surveys of their person and personal items. The inspector also l

observed proper use and placement of step-off pads to control the spread of contamination to uncontrolled atdas.

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5 License Condition No. 9 of Special Nuclear Material (SNM)

License No.1107 requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the application dated  !

March 26, 1984, and supplements thereof.

Chapter 3, Section 3.2.1.1 of the License Application requires that written procedures describing general radiation protection ,

l requirements shall be maintained and followed.

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! HP Operation Procedu e 05-015. "Abandonment or Disposition of Material or Equipment " Revision 7, requires that contaminated j i items which need to be removed from the Cordamination Controlled Area for the purpose of storage on the plant site shall comply i with the following contamination limits: 220 disintegrations  :

per minute per 100 square centimeters (dpm/100cm8), smearable. [

or 3,000 counts per minute (cpm) per probe area, maximum fixed.

Alternately, they may be bagged out and taped to prevent i dispersion of radioactive materials.  :

Contamination surveys of material found in the storage trailer referenced in Paragraph 2.e.(1) of this report, were performed '

on September 1, 1988, and indicated a maximum smearable contamination level of 28,540 dpm/100 cmt and a direct reading radiation level of 35,000 cpm / probe area. The intpector e observed that the material was not bagged; however, deteriorated pieces of plastic sheeting were on the floor of the trailer.

Licensee representatives stated that the material having the greatest contamination levels was an old pellet press. Licensee  :

representatives stated that when it was removed from the '

Contamination Controlled Area, possibly over a year ago, the bagging option was used rather than decontamination. The licensee believes that environmental conditions caused the bag I

to deteriorate and fall away from the press. At the time of the l inspection, the licensee could not produce the original release l survey or any subsequent surveys and was unsure whether such surveys were perfoired. The inspector also questioned the <

containment integrity of the trailer. A survay of the outside l of the trailer and surrounding area indicated negligible '

l contamination levels. Failure to meet contamination limits for material in storage was identified as an apparent violation of License Condition No. 9 (70-1151/88-13-03).

(3) Radioactive Contamination Surveys Chapter 3, Section 3.2.5.1 of the License Application requires that contesination surveys be performed on a continuing basis to evaluate the potential spread of radioactive contamination, and specifies a minimum survey frequency of weekly for controlled areas.

6 The licensee recently completed an expansion of the plant. Part of this expansion included a three room area of approximately 4,500 square feet (ftr) in which contaminated material and trash were being stored and various materials and production equipment decontaminated. The inspector reviewed survey data and noted that pre-printed maps did not exist for this area and that the area was not specified on a Contamination Smear Survey Audit sheet which lists all areas requiring routine surveys and the i

frequency of those surveys. This area is adjacent to the Waste Recovery and Disposal (WR&D) area which is surveyed weekly. A review of WR&D Contamination Surveys indicated that from

February 23, 1988 through August 29, 1988, approximately l 17 surveys were taken in the expansion decontamination / storage  !

area with time between surveys ranging from one to three weeks.

These surveys also indicated that only one to three smears were .

taken for each survey of the decontamination area and no evidence existed for smears taken in the storage area. Since the pre-printed maps of the WR&D area did not show the expansion area, the smear location was denoted on the edge of the raap,

' including a description of the location. The inspector also noted that some previous survey results in this area exceeded license mandated action levels and required decontamination.

l The inspector stated to licensee representatives that one to i

three smears for an area as large as the area in question was not considered adequate to evaluate the potential spread of t

contamination and that the lack of adequate surveys and failure ,

I to continuously survey tne area on a weekly frequency would be f identified as an apparent violation of License Condition No. 9 s I

(70-1151/88-13-04).

The inspector reviewed selected smear survey data for other j centrolled areas through August 1988, and verified that the I required frequencies were met and that when decontamination  ;

l action levels were observr', the areas were cleaned and I

resurveyed in the required interval.

f. Internal Exposure Control -

(1) Bicassay Section 3.2.4.3 of the License Application requires that i diagnostic bioassay be performed whenever personnel exposure is j likely to exceed 20 Maximum Pertnissible Concentration hours (HPC-hours). This requirement is also reiterated in HP 4 Operating Procedure 05-025 "Bioassay Program - Unusual  ;

incidents", Revision 9. The inspector verified, through review  !

of Unusual Incident Reports, that individuals getting an l assigned exposure of greater than 20 MPC-hours in one day were given a urinalysis and restricted from working in airborne l l

areas.

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The inspector reviewed the licensee's Urinalysis Program and I inquired as to the decision criteria and basis used to establish l monthly sampling frequencies for a uranium compound with a biological halfitfe of several hours. Licensee representatives statert that some of the criteria used included the following: i

- Representative air sampling is a better exposure control technique than urinalysis which has value for preparatory l evaluation (pre-employment baseline data), exposure ,

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evaluations with respect to trends, and for diagnostic purposes (followingincidents).

- The employment of an extensive air sampling program ,

including conservative action limits for investigations and l urinalyses, j

- The low probability of an undetected exposure due to the  !

uranium compound's visual detectability and irritant  ;

characteristics.

- An a aggressive leak detection and clean-up program. ,

- The staggering of urine samples taken of individuals in the same work location to better represent the ongoing potential uptake of the group, t A review of the licensee's air sampling program is documented in f Paragraph 2.f.(2). The inspector verified, through frequent  !

plant tours, that leaks were quickly contained and cleaned up.  !

Licensee representatives stated that staggering of urine samples i is accepted practice at the facility; however, no documentation dictating this practice existed. The inspector noted to licensee representatives that to provide adequate administrative t control for this practice, a guidance document should be  !

developed. The licensee agreed to include the addition of the i staggered urinalysis sampling requirement in a procedure or policy document. Documentation for the administrative control i of staggered urinalysis sampling will be reviewed during a  :

subsequent inspection and tracked by the NRC as an l IFT (70-1151/88-13-05). j No violations or deviations were identified.

(2) Respiratory Protection Section 2.2.6 of the License Application requires the establishment of an air sampling program to detect and evaluate the concentration of airborne radicactive particulates at work stations. The inspector accompanied a technician during the change-out of air samples. Air sampler placement appeared appropriate considering the airborne source and worker location.

8 Licensee representatives stated that approximately 260 air samples were taken every shift and "quick-counted" prior to the arrival of the next shif t. A more accurate analysis is  ;

perforned at a later time. The inspector reviewed selected Seven Day Air Sample Reports, through August 1988. HP Airborne '

Personnel Exposure: Weekly Exposure Analysis Reports for June and July 1988, were also reviewed.

The inspector reviewed the airborne contamination protection aspects of the newly operational liquid honing booth used for abrasive decontamination. Appropriate airborne contamination l

l protection equipment and adequate radiological hazard evaluation t and monitoring activities were verified. l l

Section 2.2.5.2 of the License Application requires that l

ventilation systems servicing laboratory type hoods, production l l hoods and/or primary containments where uncontained SNM is l

handled shall provide an average face velocity of at least 100 linear feet per minute for all openings. The inspector i reviewed Controlled Area Velocity Checks for 1988 through July 1988, and verified that checks were conducted monthly and j that the minimum velocities were met. The inspector also .

verified that the velometers used to demonstrate compliance with this license condition had been calibrated April 1988, by a l vendor using standards certified by the National Bureau of  ;

Standards. 1 The inspector toured the new Integral Fuel Burnable Absorber (IFBA) production facility. Extensive airborne contamination l l

control initiatives were designed and built into this facility.

l Survey and airborne sample data indicated that the licensee was l

successful in its goal to operate the IFBA area as a "clean" areat however, contamination control requirements and restrictions are employed and enforced as in other parts of the l l

facility.

License Amendment No. 12 to License No. ShM-1107, dated February 9, 1988, authorizes the use of positive pressure gloveboxes, provided an interlock mechanism is used, to prevent over pressuritation and that the interlock exhausts to a high efficiency (HEPA) filter system. The inspector verified the existence of the interlock mechanism and associated HEPA exhaust on the positive pressure glovebox used in the IFBA area.

The licensee's use of airline respirators was reviewed by the inspector. Regulatory Affairs Procedure RA-205, "Respiratory Protection," Revision 11, requires that a vendor, on a monthly basis, inspect all airline respirators in use or available for use. The inspector reviewed 1988 monthly inspection sheets for I each cylinder pressure gauge used to supply airline respirators. I It was determined that many cylinder pressure gauges did not i l

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l have unique identification numbers and could not be traced to '

their unique monthly inspection sheet. The inspector noted to licensee represeatatives that these gauges are used to set proper airline pressures required to maintain respirator NIOSH

certification. The vendor was contacted and stated that the I gauges were installed with numbered stickers. The licensee agreed that to maintain proper quality control of the respirator program all pressure gauges should be uniquely and durably l identified. The inspector stated to licensee representatives l

I that the unique identification of airline pressure gauges would be reviewed during a subsequent inspection and tracked by the NRC as an IFI (70-1151/88-13-06).

No violations or deviations were identified.

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3. NRCInformationNotices(ins)(92717)

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

scheduled,

a. IN 88-32: Prompt Reporting to NRC of Significant Incidents Involving Radioactive Material,

b. IN 88-62: Recent Findings Concerning implementation of Quality Assurance Programs By Suppliers of Iransport Packages.

4. Exit Interview  !

The inspection scope and results were sumarized en September 2,1988, '

with those persons indicated in Paragraph 1. The inspector described the l areas inspected and discussed in detail the inspection findings listed i below. No dissenting coments were received frem the licensee. Although proprietary material was reviewed during the inspection, proprietary information is not contained in the report. .

Item Number Description and Reference i 70-1151/88-13-01 Violation -Failure to properly post a radioactive materials area (Paragraph 2.e).

70-1151/88-13-02 Violation - Failure to follow procedures for contamination limits for equipment in storage outside the contamination controlled area (Paragraph 2.e).

70-1151/88-13-03 Violation - Failure to perform continuous, adequate contamination surveys of areas within the new expansion area (Paragraph 2.e),

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70-1151/es 13-04 IFI - Documentation for the administrative i control of staggered urinalysis sampling (Paragraph 2.f).

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70-1151/88-13-05 IFl - Unique, durable identification of airline pressure gauges (Paragraph 2.f). l l

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