ML20210P711

Insp Rept 70-7002/99-11 on 990719-23.No Violations Noted. Major Areas Inspected:Plant Support.Inspector Concluded That Certificatee Was Effectively Implementing Radioactive Matls Transportation Program

ML20210P711
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	08/10/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210P702	List: ML20210P698 ML20210P711
References
70-7002-99-11, NUDOCS 9908130067
Download: ML20210P711 (11)

Text

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1 U.S. NUCLEAR REGULATORY COMMISSION REGIONlil

' Docket No: 70-7002-Certificate No: GDP-2 Report No: 70-7002/99011(DNMS)

Facility Operator: United States Enrichment Corporation Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH 45661 Dates: July 19 through July 23,1999 inspector: T. D. Reidinger, Senior Fuel Facilities inspector Approved By: Patrick L. Hiland, Chief, Fuel Cycle Branch Division of Nuclear Materials Safety 9900130067 990810 PDR ADOCK 07007002 C PDR ,.

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EXECUTIVE

SUMMARY

1 United States Enrichment Corporation Paducah Gaseous Diffusion Plant NRC Inspection Report 70 7002/99011(DNMS)

Plant Sucoorf e The inspector noted that the staff's response to a minor uranium hexafluoride release in Buil6ng X-710 was effective and consistent with the guidance provided in the alarm j response, off-normal and emergency procedures. (Section P1.1) e The inspector noted that routine radiation survey requirements were met, radiological j instrumentat!on was properly maintained, and sealed source leak test and survey l

techniques were satisfactorily conducted in accordance with the appropriate procedures. l (Section R1.1)

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• The inspector noted that the internal dosimetry program was effectively implemented in accordance with Safety Analysis Report Section 5.3.2.3. The inspector concluded that

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i the As-Low-As-Reasonably-Achievable Program for 1998 was effectively implemented  !

based on exposure results. Improvement in employee participation in the routine urinalysis bioassay program was also observed. Plant staff satisfactorily conducted quantitative uranium measurements of various urine samples per plant procedure.

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(Section R1.2).

e The inspector concluded that the certificatee was effectively implementing its radioactive materials transportation program. Selected records and surveys reviewed for the shipment of radioactive materials were in accordance with both the Department of Transportation and NRC regulations. Procedures for the performance of transportation activities were effective. (Section A1.1) e The inspector concluded that the waste management staff implemented an effective program for the management of various waste streams generated onsite, as evidenced by overall reduction in waste streams over the past several calender years. (Section W1.1) 2

L Report Details IV. Plant Support P1. . Conduct of Emeraency Preoaredness Activities P1.1 Buildina X-710 Emeraency Resoonse Observations

a. Insoection Scope (88050)

The inspector observed the plant staff's response to a minor uranium hexafluoride (UF.)

release in Building X-710.

b. Observations and Findinas On July 23, a Building X-710 laboratory technician was hydrolyzing approximately 4 grams of UF in a sample tube when a minor amount of UF was unexpectedly released from the tube, contaminating the laboratory technician and the immediate work area in Room 120. During the evacuation of the room, the building emergency alarms were activated by the laboratory staff. The building custodian promptly notified the Plant Shift Superintendent (PSS) of the event. The PSS initiated an emergency squad response to the scene.

During the emergency squad response, which lasted approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the PSS, acting as the Incident Commander, directed several actions, including: I e the evacuation and transport of the contaminated technician to the onsite hospital dispensary for immediate decontamination and bloassay; e the coordination of Health Physics (HP) staff to conduct bloassays of five other technicians who were conducting work activities in the room; e the evacuation and sheltering of all building personnel, as appropriate; e the monitoring and assessment of airborne UF. hydrolyzation products such as uranyl and hydrogen fluorides; e the coordinating, with the building custodian, of actions required to isolate the room and to verify that the leak was minor in nature; and, e the mitigation, cleanup, and subsequent retum of the affected areas to normal operations.

Following the event, the inspector reviewed operations alarm response, off-normal, and emergency procedures relative to the event. The inspector noted that the staff's actions were consistent with the procedures. The inspector reviewed the bioassay results which indicated the exposed technicians did not exceed any admin!strative action levels.

(See Section R1.2)

c. Conclusions The inspector noted that the staff's actions were effective and consistent with the guidance provided in the alarm response, off-normal, and emergency procedures for a .

small UF release. j I

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R1. Radiation Protection R1.1 Radiation Protection Routine Ooerations

a. Insoection Scope (83822)

The inspector interviewed health physics technicians (HPT) and accompanied HPTs on l routine radiological surveys. In addition, the inspector checked the radiation calibration j facility and the operability of radiological instrumentation during facility tours. The inspector also reviewed various documents relating to the radiation protection program. ,

l b. Observations and Findinas The inspector accompanied HPTs on numerous routine radiological contamination j surveys and observed radiological surveys of various floors and major pieces of l equipment. Survey techniques were consistent with good health physics practices and Procedure XP2-HP-HO2032," Radiological Surveys." A review of routine survey frequencies and randomly selected survey records indicated that the requirements of  ;

l Policy X38300-99-012, " Health Physics Routine Radiological Survey Program," were l met. During tours, the inspector checked calibration intervals and daily radiological i i instrumentation source check records. Radiological instrumentation was either.in l

calibration, with a daily source check performed, or properly tagged out of service, per the requirements.of Procedure UE2-HP-RP1033,"Radiologicalinstrumentation." The l inspector noted that the sealed source leak tests were consistent with applicable health physics quarterly test requirements.

l During the inspection of the radiation calibration facility, the inspector observed that l electronic calibration staff had calibrated various pieces of radiologicalinstrumentation in accordance with applicable vendor technical manuals. Review of the training records

! for the electronic calibration staff and manager indicated that the training was consistent and current with applicable administrative guidelines. The inspector noted that although the electronic calibration facility had demonstrated the capability to calibrate approximately 20 different types of radiological instrumentation, the staff did not have qualification records that documented specific training received for conducting calibrationa for each of the different pieces of radiologicalinstrumentation. Senior managers informed the inspector that although specific documentation was not required by procedure, the calibration qualification issue would be reviewed and addressed l accordingly. In addition, the senior managers indicated that the technicians were qualified to conduct specific calibration activities on assigned instrumentation.

interviews with the calibration staff and manager indicated that staff and managers were knowledgeable regarding industrial practices relating to current calibration techniques for radiological instrumentation. The inspector selectively verified that radiological instrumentation had been calibrated with calibration sources traceable to applicable National Institute of Science and Technology standards.

i_ The inspector reviewed the 1997 and 1998 annual radiation protection program audits.

The audits were conducted by either the radiation protection staff or the intemal assessment staff. The audits evaluated the adequacy and effectiveness of the radiation )

protection program to assure compliance with the regulatory requirements. In addition, i the audits addressed conduct of operations, training, and field operations. The audit scope including surveys and contamination control, dosimetry, instrumentation,

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radiological work permits, and site characterization using performance-based observations of field activities, compliance reviews and staff interviews. The inspector noted that the audit findings were adequately addressed by the staff via the corrective action program. The inspector agreed with the audit recommendations which included addressing the adverse trend in routine bioassay delinquencies. (See Section R1.2 ).

During interviews with HP managers, the inspector noted a consistency between plant policies and issuance of problem reports. The inspector noted that managers understood when problem reports should be initiated. During the inspection, the inspector observed several instances of problem reports being processed for various radiation protection issues identified by the HP staff.

Plant Procedure XP2-HP-DS1030, " Distribution of Dosimetry Badges," required that personnel nuclear accident dosimeters (PNADs) be distributed to non-USEC personnel (i.e., delivery services) and UF, cylinder truck drivers who accessed areas that required a thermoluminescence dosimeter. The inspector observed that all the UF.

cylinder truck drivers were properly issued PNADs . The inspector noted (hat approximately 23 PNADs were issued in 1998 and that the radiation exposure results indicated that the average deep dose equivalent levels were essentially the same as the average plant radiation background levels,

c. Conclusions ,

The inspector noted that routine radiation survey requirements were met, radiological instrumentation was properly maintained, and sealed source leak test and survey techniques were satisfactorily conducted with the appropriate procedures. Training records for the electronic calibration . staff and managers indicated that the training was consistent and current with applicable administrative guidelines. Audit findings were adequately addressed by the staff via the corrective action program. Issuance of PNADs was per procedure.

R1.2 Internal Dosimetry Proaram

a. Insoection Scope (83822)

The inspector reviewed the plant's internal dosimetry program and current bioassay data for plant personnel. Several intemal dose investigations for bioassay results, in exceedance of administrative plant limits, were also reviewed.

~ b. Observations and Findinas The inspector reviewed the internal dosimetry program procedures and noted that the

_ procedures implemented the internal dosimetry program as described in Safety Analysis Report Section 5.3.2.3. Plant staff whose routine duties required entry into  ;

radiological contaminated areas or duties requiring direct contact with radioactive l material participated in the routine bloassay program. Employees scheduled for i sampling were required to submit routine urine samples within 3 weeks of being notified.

The inspector reviewed the non-submission rates associated with the bioassay program and noted that the urine sample delinquency rates had increased over the last 3 quarters of 1998 from 17 to 26 percent. The inspector noted that the General Manager issued a memorandum to plant staff on November 11,1998, instructing 5

workers to participate in the routine urinalysis program. The inspector determined that as a result of management intervention, the current delinquency rate as of June 4,1999, was approximately 5 percent which was under the plant goal of 10 percent.  ;

l The inspector verified that employees, who did not submit samples within 3 weeks of the scheduled test date, were placed on the delinquency list until the routine bioassay was ,

I performed. A review of internal dosimetry data indicated that exposure levels remained below regulatory limits in 1998. Therefore, the inspector noted that there was no potential for significant internal exposure associated with the non-submission of urine l

samples.

1 Procedure XP2-HP-SH1031, " Urinalysis Program," listed scheduling criteria, frequencies and protocols for the bioassay program. The inspector reviewed the current list of plant personnel participating in the internal dosimetry program and found the practices to be

, in accordance with the procedural requirements. Intemal dosimetry logs indicated l 'special bioassays were conducted according to the criteria described in the procedure.

l Appendix A of Procedure XP2-HP-SH1031 established two administrative action l levels (flags) for routine uranium bioassay exposure results. . The limits were .50 and l 20 micrograms per liter of uranium ( g/L) based on a sampling frequency greater than 4 weeks. Bioassay results greater than the .50 g/L limit required re-sampling. 1 Bioassay results in excess of 20 pg/L required an investigation and an intake restriction evaluation, in addition to periodic re-sampling until bloassay results retumed to levels below .5 g/L. In addition, bioassay results in excess of 20 g/L required employees to be restricted from duties involving radiological work activities. The inspector reviewed corresponding investigation reports of four bloassay results that exceeded 20 g/L from January 1,1998, to July 24,1999. The inspector determined the investigations were thorough and extensive in determining the root cause of the uptakes. In all cases, the investigation results determined that the intakes were less than the toxicity limit for soluble uranium of 10 mg/ week required by 10 CFR 20.1201(e).

l Several other investigations for bioassay results above .50 g/L, but below 20 g/L, were also reviewed and determined to be equally thorough and extensive. All re-samples for bioassays above administrative limits were conducted until a final result below .50 g/L was observed. The inspector verified that workers whose bioassays l

were in excess of 20 g/L were placed on a work restriction until bloassay re-samples indicated results below .50 g/L.

Section 5.11 of the procedure required the submittal of baseline urinalysis samples for l all new hires (contractors) during employee orientation. The inspector noted that the HP l staff on occasion was not kept aware of the status of the new hires until after orientation had been completed. However, the inspector determined that the required baseline urinalysis surveys were performed prior to contractors conducting radiological work activities. Piant management informed the inspector that the procedure would be reviewed and revised accordingly to address the inconsistency in the implementation of  ;

Section 5.11. I L

The inspector reviewed," Summary and Anc!ysis of Urine Double Blind Controls," a report prepared in 1997. Double blind control samples were submitted for analysis l_ each week over a 12 month period by Building X-710 staff. Actual urine from  !

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l non-exposed plant staff was spiked with 250,500, and 750 nanograms / liter total uranium. The samples were then analyzed as routine samples during the year. The inspector determined that the analytical results were within acceptance criteria stated in ANSI N13.30. The inspector observed that a laboratory technician satisfactorily conducted quantitative uranium characterization measurements of various urine samples per Procedure XP4-TS-RL7800, " Analysis of Urine For Uranium 235 (Um) and Uranium 238 (Um) by Inductively Coupled Plasma-Mass Spectrometry." The inspector also verified that the laboratory technician calibrated the mass spectrometer prior to each sample batch and conducted a calibration verification at the required frequency of every 16 samples as required by Safety Analysis Report Table 5.7.1.

A review of 1998 and 1999 (first quarter) dosimetry data for the plant illustrated that the maximum Committed Effective Dose Equivalent respectively was 16 mill! rem and 3 millirem. The maximum Total Effective Dose Equivalent for 1998 and 1999 (first quarter) respectively was 285 millirem and 61 millirem. These maxima were below 10 percent of the 10 CFR 20 maximum dose limits for radiation workers. The inspector determined that the As-Low-As-Reasonable-Achievable (ALARA) program for 1998 was effectively implemented based on exposure results.

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c. Conclusions The inspector noted that the internal dosimetry program was effectively implemented through extensive dose investigations in addition to improved employre participation in the routine urinalysis bioassay program. The intemal dosimetry program was  ;

implemented in accordance with Safety Analysis Report Section 5.3.2.3. The inspector concluded that the ALARA program for 1998 was effectively implemented based on exposure results. A laboratory technician satisfactorily conducted quantitative uranium measurements of various urine samples per plant procedure.

A1 Conduct of Transportation Activities A1.1 Observation of Radioactive Material Shioments

a. Inspection Scoce (86740)  ;

The inspector reviewed selected records for the shipment of radioactive materials, including surveys of packages for radioactive contamination, internal process i documentation, and shipping papers. I

b. Observations and Findinas The inspector reviewed the final packaging of randomly selected shipments and shipping papers of various radioactive shipments made to authorized licenses. The inspector's review included the following: 1) bills of lading; 2) shipping records;

3) procedure inspection forms; and, 4) exclusive use vehicle instructions to carriers as applicable for approximately ten shipments made between January 5,1998, and May 18,1999. The review of documentation regarding the radioactive shipments indicated that the appropriate radiological sur/eys and inspections of packages were performed prior to shipment, and removable ccn! amination and radiological surveys were below the limits specified in 49 CFR 173.443. A review of shipping papers also verified that the information required by both 49 CFR 172 and 10 CFR 20 was available 7

in the shipping documentation. In addition, the shipments were appropriately labeled, placarded, and marked in accordance with 49 CFR 172.

The inspector observed four trailers that were loaded with either empty or full UF, cylinders prior to transport. The loaded cylinders were appropriately marked, labeled, braced, and fastened for shipment as required by 10 CFR 71 and the Department of Transportation (DOT) regulations. Shipping papers prepared for the shipments contained the bill of lading with correct identification of container contents, shipper's certification, exclusive use requirements as applicable, and emergency response information, as required by DOT regulations. In addition, the inspector noted that the trailers were appropriately placarded for the shipment. The inspector observed and discussed the shipment of radioactive material with the Traffic Manager and senior traffic staff who were both certified as packaging and transportation specialists. In addition, the inspector determined that the following applicable transportation documents were current: 1) Certificates of Competent Authority for international radiological shipment; 2) Certificates of Compliance for domestic radiological shipments, and 3) DOT exemptions for radiological shipments.

In addition, the inspector reviewed the training records and the certificatee's procedures for the shipment of radioactive material. The inspector noted the transportation staff training was consistent with requirements listed in the training development and administrative guidelines. Interviews with the transportation staff indicated that the staff was knowledgeable of the applicable transportation requirements and that the transportation procedures contained adequate information for the preparation and shipment of radioactive materials from the plant site.

c. Conclusions The inspector concluded that the certificatee was effectively implementing its radioactive materials transportation program. Staff performing these activities were adequately trained on the procedures and qualified for the applicable assigned tasks. Selected records and surveys reviewed for the shipment of radioactive materials were in accordance with both the DOT and NRC regulations. Procedures for the performance of transportation activities were effective and provided plant staff with the appropriate information to ship materials in accordance with the DOT and NRC regulations.

W1 Conduct of Radioactive Waste Management Activities (88035)

W1.1 Review of Onsite Radioactive Waste Manaaement

a. Inspection Scoce (88035)

The inspector reviewed the overall implementation of the onsite radioactive waste management program with the waste management staff. The inspector also observed the shipment of low level radioactive waste offsite.

b. Observations and Findinas The inspector reviewed and discussed overall waste management data from calender year 1997 to the present with cognizant waste management staff. Waste management data indicated that for the hazardous and mixed waste streams onsite, an overall 8

average reduction of 46 percent of the waste volume was observed from 1997 to the present. The inspector also reviewed data for low level radioactive waste generated ,

onsite. Data for the low level radioactive waste streams onsite indicated an overall average reduction of 32 percent of the waste volume from 1997 to present.

Per Nuclear Criticality Safety Approval Plant 18, trending of Un3 concentrations was j required in seven dry active waste (DAW) streams, and if an increase of greater than 20 percent of Un3 was detected in any of the streams, an investigation was required to be conducted and results reported to the nuclear criticality safety (NCS) staff. The inspector reviewed several trend analyses of different DAW streams from May to

.lj July 1999 that indicated a 20 percent increase in Un3. The inspector determined that the required investigations were conducted and that the investigations were thorough and extensive in determining the root cause of the waste stream increase and possible methods to reduce the uranium content in the waste streams. Review of applicable documentation indicated that the investigation results were promptly reported to the ,

NCS staff as required. j The inspector observed that a production support technician satisfactorily conducted quantitative radioactive characterization measurements of several boxes of DAW I (B-25 boxes) per Procedure XP4-TS-AN7010, Quantitative Measurements of Boxed l Waste." In addition, the inspector observed several waste management HPs )

satisfactorily conduct drum crushing operations per Procedure "XP4-EW-WM2061,  !

" Operation of Drum Crusher."

The inspector reviewed copies of three disposal site licenses and noted that two of the licenses were not current. The waste management staff informed the inspector that controlled copies of the licenses were being mailed by the respective disposallicensees. ,

Later in the inspection, the inspector was given copies of the licenses and no problems were noted,

c. Conclusions The inspector concluded that the waste management staff implemented an effective ,

program for the management of various waste streams gerierated onsite, as evidenced j by overall reduction in waste streams over the past several calendar years. Plant staff satisfactorily conducted evolutions in accordance with applicable waste management procedures.

V. Manaaement Meetina X Exit Meeting Summary The inspector presented the inspection results to members of the plant staff and management at the conclusion of the inspection on July 24,1999. The plant staff acknowledged the findings presented. The inspector asked the plant staff whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED United States Enrichment Corporation

• M. Brown, General Manager

• S. Casto, Work Control Manager

• L. Fink, Safety, Safeguards & Quality Manager

• R. Helme, Engineering Manager-

• P. Miner, Regulatory Affairs Manager

• P. Musser, Enrichment Plant Manager

• R. Smith, Production Support Manger

• Denotes those present at the exit meeting on July 24,1999.

INSPECTION PROCEDURES USED -

l lP 83822: Radiation Protection IP 88050: Emergency Preparedness IP 86740: Transportation IP 88035: Radioactive Waste Management

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ITEMS OPENED, CLOSED, AND DISCUSSED Ooened None

. Closed j i

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None Discussed None I

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LIST OF ACRONYMS USED ALARA As-Low-As-Reasonably-Achievable CFR Code of Federal Regulations DAW Dry Active Waste DNMS Division of Nuclear Material Safety DOT Department Of Transportation HP Heath Physics HPT Health Physics Technician IP Inspection Procedure NCS. Nuclear Criticality Safety ng/L Nanograms Per Liter NRC Nuclear Regulatory Commission PNAD Personnel Nuclear Accident Dosimeters PSS Plant Shift Superintendent ug/L Micrograms Per Liter UF, Uranium Hexafluoride

' Uns - Uranium 235 USEC United States Enrichment Corporation 4

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