ML20211P795
| ML20211P795 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 02/12/1987 |
| From: | Collins T, Hosey C, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211P730 | List: |
| References | |
| 70-1151-87-02, 70-1151-87-2, NUDOCS 8703020435 | |
| Download: ML20211P795 (12) | |
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UNITE 3 STATES
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o NUCLEAR REGULATORY COMMISSION REGION 11
.h 101 MARIEITA STREET,N.W.
ATLANTA, GEORGI A 30323
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FEB 181987 m.*
- Report _No.:
70-1151/87-02.
Licensee: -Westinghouse Electric Corporation
. Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM-1107
. Facility Name: Westinghouse (Fuel Division)
Inspection Conducted: January 26-30, 1987 Inspector:
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T. R. Collins Date Signed f,
7//Zl77 A t F. W. Wright
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' Approved by: hM m
M/L/d 7 C. M. Hose),'Section\\ Chief Date Signed Division of Radiatiod Safety and Safeguards
SUMMARY
Scope: This routine, unannounced inspection ' included the areas of transportation of radioactive material, radioactive waste disposal, radiation protection, and followup on previously identified items and enforcement issues.
Results:
One violation was identified - failure to follow the requirements of approved radiation-protection procedures.
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2 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. A. Procopio, Acting Plant Manager
- E. E. Keelen, Manager, Manufacturing
- W. L. Goodwin, Manager, Regulatory Affairs
- E. X. Reitler, Manager, Radiological and Environmental (R&E) Engineering
- J. W. Heath, Manager, Health Physics Operations B. Condo, Manager, Waste and Disposal R. E. Fisher, Senior R&E Engineer R. K. Burklin, Senior R&E Engineer R. D. Montgomery, R&E Engineer T. Shannon, R&E Technician Other licensee employees contacted included construction craftsmen and technicians.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on January 30, 1987, with those persons indicated in Paragraph 1 above. The inspectors described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
One violation regarding the failure to follow approved radiation protection procedures was discussed in detail.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
l' 3.
Licensee Action on Previous Enforcement Matters (92702)
I (Closed) Violation 70-1151/86-12-01, Failure to follow approved radiation protection procedures and inadequate radiation protection procedures.
The inspector reviewed the licensee's response dated October 2, 1986, and verified that the corrective actions specified in the response to Example 1, 3 and 4 of the Violation had been completed.
In regard to Example 2 of the Notice of Violation, a similar violation observed _during this inspection is addressed in Paragraph 5.
4.
Followup on Inspector Identified Items (92701)
(Closed) Inspector Followup Item (IFI) 86-12-03, Evaluate frequency of daily surveys.
The inspectors reviewed the licensee's routine survey program for l
contamination control and concluded that a five day frequency was appropriate in accordance with license requirements.
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3 (Closed) IFI 86-12-03, Establish intermediate action level for routine bioassay program.
The inspectors reviewed the licensee's bioassay program to control personnel exposures and concluded that the administrative limits established by the licensee were adequate to control exposures within regulatory limits.
(Closed) IFI 86-12-04, Establish procedure for controlling personnel exposure logs.
The inspectors reviewed the licensee's Procedure 05-064,
" Respirator. Issuance," Revision 0, dated January 8,1987, which incorporated an exposure log for controlling personnel exposures.
(Closed) IFI 86-12-05, Evaluate location of air sampler for waste compactor.
The inspectors discussed this issue with licensee representatives and determined that the licensee had concluded the air sampler was to be relocated inside containment at the waste compactor to evaluate-personnel exposures.
However, at the time of the inspection the air sampler had not i
been relocated.
The licensee provided the inspectors an approved purchase order (P0) which authorized the relocation of the air sampler. in question.
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The inspectors informed licensee representatives that this item would be considered complete since an approved P0 had been issued to relocate the air sampler.
5.
Radiation Protection (83822) a.
Sealed Source Leak Test 4
Administrative Procedure HP-05-046, " Leak Testing Sealed Sources,"
specifies the requirements for sealed source leak test. The inspectors reviewed the licensee's program for controlling sealed sources and leak test in accordance with their Procedure HP-05-046.
i No violations or deviations were identified.
b.
Instrumentation Section 3.2.1.2(1) of the Application for License SNM-1107 states. that i
instruments shall be routinely calibrated on a schedule established by the Radiation Protection Component.
The schedule shall require calibration following acquisition, and thereafter at least following major repairs or semiannually, whichever occurs first. Alpha counting equipment used in the laboratory also shall be checked each working day, when in use, to determine background activity and a calibrated source shall b-e counted to assure proper instrument functioning.
A voltage plateau and the proper counting voltage of each laboratory alpha counting instrument shall be determined quarterly.
Instrument calibration records shall be maintained for a period of one year.
The inspectors reviewed the calibration schedule and records for y
portable health physics survey instruments, and the results of quality control checks for selected laboratory alpha counting equipment.
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4 Section 3.2.1.2(5) of _ the Application for License SNM-1107 states that air flow measuring devices on the fixed inplant air sample system shall be calibrated annually..
The inspectors reviewed the calibration -records of. air flow measuring-devices.
No violations or deviations were identified.
c.
Internal Exposure Control and Assessment The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403, and 20.405 to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptakes.
The Application for License No. SNM-1107, Sections 2 and 3 also include commitments regarding internal exposure control and assessment.
10 CFR 20.103(a) establishes the limits for exposure of individuals to concentrations of radioactive materials in air in restricted areas.
This section also requires that suitable measurements of concentrations of radioactive materials in air be performed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate bioassays be performed to detect and assess individual' intakes of radioactivity.
(1) Air Sampling Section 3.2.3.4 of the Application for License SNM-1107 states that all areas where exposed radioactive materials are handled shall be sampled for airborne radioactive particulate matter by using appropriate samplers to obtain reasonably representative samples during operations, on a schedule established by the Radiation Protection Component, and when indicated by a particular operation.
f Section 3.2.3.5 of the Application for License SNM-1107 requires y
the licensee to investigate and/or increase sampling if airborne radioactive concentrations not directly the result of a specific l'
known cause, exceed action levels specified in Table 3.2.3.1 of l
the Application.
The facility's air is sampled by approximately 250 fixed air samplers.
The air sampling media 'is changed each shift.
The L
licensee health physics section performs a preliminary analysis of each sample collected to locate potential airborne areas and notifies the responsible. supervisor.of_ airborne activity. requiring exposure investigations or worker protection.
i In order to limit exposures of individuals to airborne radioactivity material.
The licensee limits employee access to potential airborne radioactivity areas based upon daily exposures.
l
5 The daily exposures are' determined'through investigations'that are initiated whenever air survey results indicate concentrations of airborne radioactive material in excess of MPC values.
The inspectors reviewed the sampling, analysis, and investigation procedures associated with the airborne radioactivity monitoring program.
The inspectors also reviewed selected airborne survey resul ts.
No violations or deviations were identified.
(2) Bioassay Program 10 CFR 20.103(a)(3) requires the licensee to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
Section 3.2.4.3 of the Application for License SNM-1107 requires the licensee to evaluate the extent of actual exposure whenever any single air sample exceeds 250 percent of MPC such that personnel exposure is likely to exceed 20 MPC-hours or in the event-that unusual occurrences cause personnel exposures in excess of 40 MPC-hours in a seven consecutive day period.
The inspectors' reviewed selected evaluation reports for exposures to concentrations of radioactive materials exceeding 250 percent of MPC values.
Section 3.2.1.2 of the Application for License SNM-1107,
" Measurement Control Procedures (8)" states the in-vivo counter shall be routinely calibrated at least annually and functionally tested daily when the counter is in operation.
The inspectors reviewed the licensee's in-vivo detector procedures and records for calibration, resolution checks, and background measurements.
The inspectors did not identify any problems with the results or methods utilized by the licensee for in-vivo detector performance checks and calibration.
However, the procedures for determining background and calibration lacked sufficient detail to ensure calibration and performance _ objects,were met.
The licensee's in-vivo detector procedures for background determination and calibration were written with minimum procedural detail to allow a qualified individual to perform the task with flexibility.
The procedures did not specify the methodologies to use, or consider for use, and did not specify the acceptance criteria. applicable to the results.
The inspectors discussed the lack of procedural detail with licensee representatives.
Licensee representatives acknowledged the inspectors comments that methodologies and definitive acceptance criteria for determining background count rate and calibration of the in-vivo detector should be specified
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6
-in the procedures. _ The inspectors stated that this would be reviewed during future inspections (70-1151/87-02-02).
Section C.2.1.2(7) of the Application for License SNM-1107 states that the. Radiation Protection Component shall perform an evaluation every two years (or more frequently if a problem is
-identified) of vendors used to analyze environmental or bioassay samples.
The inspectors reviewed the licensee reports documenting evaluations made of the vendor utilized to provide bioassay analysis.
The licensee's health physics personnel performed an evaluation in May 1984.
A review of the vendors program was made in March 1986, by the corporate quality assurance section, which was accomranied by health physics personnel.
The licensee representatives did not report any findings in any of the evaluations reviewed by the inspectors.
The licensee conducted another evaluation of the vendors program in December 1986, however, the results of the~ evaluation had not been documented prior to the inspectors' review.
No violations or deviations were identified.
(3) Controls 10 CFR 20.103(b) requires the licensee to use process or other engineering control s,
to extent practicable, to limit concentrations of radioactive material in air to levels below that specified in Part 20, Appendix B, Table 1, Column 1, or limit concentrations, when averaged over the number of hours in any week during which individuals are in the area, to less than 25 percent of the specified concentrations.
The licensee utilizes ventilation and containment gloveboxes for control of airborne radioactive material.
The use of process and engineering controls to limit airborne radioactivity concentrations in the plant was discussed with licensee representatives and the use of such controls observed during tours of the plant.
No violations or deviations were idc..tified.
(4) MPC Tracking Individual exposures to concentrations of radioactivity in air are calculated by the licensee utilizing air sample data for a specific area and records listing stay times of employees in the specific areas.
The licensee is developing a computer program to calculate the individual MPC hour exposures from stay time and air survey data.
During the inspection, licensee representatives could not give a projected date when the system would be able to
7 provide the licensee with up-to-date MPC hours exposure i
information.
No violations or deviations were identified.
d.
Caution, Signs, Labels and Controls 10 CFR 20.203 specifies the posting, labeling and control requirements i
for radiation areas, high radiation areas, airborne radioactivity areas l
and radioactive material.
License No. SNM-1107, Condition 9, required that licensed material be used in accordance with statements, representations, and conditions contained in Sections 2, 3, and 4 of the Application dated January 4, 1985, and supplements thereto.
The license an exception from the requirements of 10 CFR 20.303(provides f).
Section 3.2.2.4 of the Application for License SNM-1107 states that each entrance or access point to the controlled Access Area shall be posted in accordance with 10 CFR 20.203 except for 10 CFR 20.303(f).
In lieu thereof, a sign bearing the legend, "Every container or vessel in this area may contain radioactive material," shall be posted at entrances to each area in which radioactive materials are processed, used, or stored.
During tours of the facility, the inspectors reviewed the licensee's posting and control of radiation areas, airborne radioactivity areas, contaminated areas, and radioactive material areas.
The inspectors found posting and labeling adequate to meet licensee's license conditions and 10 CFR 20 requirements.
No violations or deviations were identified, e.
Surveys The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to maintain records of such surveys necessary to show compliance with regulatory requirements.
The Application for License No. SNM-1107, Condition 9, required that licensed material be used in accordance with statements, representations, and conditions contained in Sections 2, 3, and 4 of the Application dated March 26, 1984, and supplements thereto.
Paragraph 3.2.1.1 of the Application for License SNM-1107 stated that written procedures describing general radiation protection requirements shall be maintained and followed.
(1) Facility Surveys Section 3.2.5 of the Application for License SNM-1107 states that contamination surveys shall be performed on a continuing basis to evaluate the potential spread of radioactive contamination.
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The inspectors reviewed Regulatory Affairs Prohedure, RA-201,
" Contamination Control," Revision 4, dated Syptember 26, 1986, which specified minimum frequencies for performing facility surveys as well as action levels for decentamination of various areas. The inspectors reviewed selected contamination surveys for; results greater than the action limits which require the licensee to initiate decontamination efforts.
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No violations or deviations were identified.
(2) Personal Frisking
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Regulatory Affairs Procedure RA-200, " Protective Clothing,"
Revision 5, August 6,1984, Paragraph 213, required that when personnel exit the' Controlled Area, they are to wash their hands thoroughly and monitor,per posted instructions.
m.
Regulatory Affairs Procedure RA-203, " General Health Physics Rules and Recommendations," Revision 6, September 18, 1985, stated that t
posted instructions at contamination control area step-off-pads and change rooms shall be followed.
Regulatory Affairs Procedure,RA-217, " Personnel Monitoring Requirements," Revision 0, D*ctimber 8, 1986, Paragraph 2.1, required that when personnel exit the Controlled Area, they are to follow posted instructions forL morfitoring at step-off pads, controlled area change rooms and/or any other designated areas.
During tours,0f' the; plant, the inspectos observed the exit of approximately 25 to 30 licensee and vendor employees from contamination control te clean areas to determine if frisking was performed as requirhd.
Several personnel observed picked up the s
probe and quickly passed the probe over hands and feet; the probe being one to several inches from the body dt; ring Jhe survey rather than at contact as required by the postings.
The probe movement during the frisk was sufficiently fast so that the contamination limit would not have been detected but instead, a significant ancunt of. contamination would have had to be present on ar, individual in order for the instrument audible response tyham indicated that en area needed additional.friskicg..
Posted instructions at frisker stations also requirkd 'that prior to frisking, personaci must push the reset buttot to zero on the instrument because the check source is attached to the bottom of the probe to evaluate adequate response.
Of the indivitals observed exiting from the Controlled Area, one individual faile?-
to reset the instrument as required / The posted instructions also specified that hands, shoes, and clothing be monitored.
In numerous instances, individuals failed to monitor the area required.
The licensee was infornEd that failure to ' monitor as-required by Procedures RA-200, RA-203 'and RA-219 would be
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considered an apparent violation of License Condition 9 (70-1151/87-02-01).
No deviations wereLidentified.
f.
ALARA Review
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Section 3.1.2.5.1 of the Application for License SNM-1107 states that a C
formal report shall be made by the Regulatory Compliance Committee to 9-the Plant Manger every six months reviewing personnel exposure data to determine:
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(1) if there.are any upward trends developing in personnel exposures for identifiable categories of workers or types of operations, (2) 'ii.~ ' exposure; might be lowered in accordance with the ALARA
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corcept;and; (3) if equipmept for exposure control is being properly used
..vf maintained and. inspected.
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.The report shall include. review of other required audits and inspections performed during 4he reporting period and review of the data from the following areas:
personnel exposures, bioassay results unusual occurrences and inplant airborne radioactivity.
4 The inspectors reviewed the most recent report dated September 18, 1
1986, covering the period,ending June 30, 1986.
The following are f.
highlights of the report.
External personnel exppsures/ for both, whole body _ a_nd.. skin i
continued to average luss than 25% of the legal dose limit of
- e 1,250 mrem and 7,500 mrem respectively.
c Internal personnel exposures, as monitored by airborne exposures in MPC-hours remained less than 15% of established limits.
i Due to the installation of a new whole body counting system and possible changes to the prelimina5y results, departmental _ averages were not presented.
i The Controlled Area airborne radioactivity average was approximately 11% MPC for - tM 'first six months of 1986, j
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representing a 15% reduction in air concentrations.
L The number of cir sample stations exceeding an average of 25% MPC q
decreased from 19 during the last.6 months of 1985 to 6 during the 1,
ifirst half of 1986.
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The number of airborne radioactivity spikes exceeding 100% MPC
<dacreaser by approximately 48% during the first six months of 1986 U compared with the last six months of 1985.
Licensee representatives stated that the draft of the ALARA Report for the second half of 1986 is in the process of being reviewed and that the final version of the report is expected to be issued during the month of February.
No vfolations or deviations were identified.
6.
TransporationActivities(86740)
QualityAssuranceProgram a.
10 CFR 71.12 provides a general license to transport, or to deliver to a carrier for transport, licensed materials in packages for which a e
license or -certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR'71, Part H.
The inspectors determined that the licensee had an NRC approved quality assurance program for packaging, approved under Docket 71-0251, with an expiration date of January 31, 1990.
b.
Selection of Packagings The inspectors discussed the use of packages which require an NRC Certificate of Compliance (C0C) with cognizant licensee representatives.
The licensee had received a renewal of the C0C for fuel shipping containers.
A C0C had been issued for the licensee to ship UF cylinders; heels in cylinders were shipped in accordance with g
49 CFR I73.417.
Licensee representatives stated that no packages were used which were foreign-approved packaging which would require D0T i
revalidation (49 CFR 173 or 10 CFR 71.16).
The inspectors determined through discussions that D0T Spec 55 containers were not used and the licensee was aware of the prohibition of use (49 CFR 173.415(b)), that no plutonium shipments had been made nor were planned to be made by air (10 CFR 71.88), and the licensee did not rely on s ecial form determinations to qualify shipments (49 CFR 173.469.
c.
Preparation of Packages and Delivery to Carrier The inspectors determined from review of applicable procedures, review of shipping checklists and review of shipping papers, as well as discussions with licensee representatives, that the following b,
requirements were being met:
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11 Routine use of container (10 CFR 71.01)
Liquid package requirement (49 CFR 173.412(n))
Package weight.(49 CFR 173.411)
Package marking (49 CFR 172.300 et. seq.)
Radiation surveys (49 CFR 173.442)
Bracing of packages (49 CFR 173.442)
Shipping paper documentation (49 CFR 172, Subpart C)
Notification of consignee (10 CFR 20.311)
No violations or deviations were identified.
7.
Radioactive Waste Management (84850) a.
Waste Manifests 10 CFR 20.311(b) and (c) require that a manifest system be used for all shipments of waste to a licensed burial facility.
The inspectors detennined that the nanifests had been completed and forwarded as required for the three waste shipments reviewed.
b.
Waste Classification, Characterization, and Labeling 10 CFR 61.55 requires that waste be classified and identified as Class A, B, and C.
The inspectors reviewed the isotopic survey results for containers in three waste shipments and determined that the classifications shown on the manifests were in agreement with 10 CFR 61.55.
c.
Tracking of Shipments The Radioactive Material Shipment procedures and checklists included -
provisions for determining the estimated date of arrival of the shipment, and written and telephone notification of the receiver. The
' inspectors verified that the three waste shipments had been verified as having been received at the disposal site.
The licensee's procedures included a seven day receipt requirement by the receiver and provisions for tracing the shipment if notification of receipt is not received.
No violations or deviations were identified.
8.
Radioactive Solid Waste (88035)
The inspectors reviewed the procedures, shipping records and license requirements for shipments of radioactive waste to the disposal site.
Regulatory requirements in 10 CFR 20.301 and 10 CFR 20.401 for the disposal of waste were also reviewed.
10 CFR 20.304 specified the general requirements for disposal of waste by burial in soil.
Licensee representatives stated that no disposals have been made under the provisions of this regulation.
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12 The inspectors discussed the radwaste volume reduction program with licensee representatives and was informed that the licensee has contracted a waste compactor's agreement with Hittman Inc.
The service provided by the contractor provides the licensee a super heavy duty waste compactor which reduces the volume of waste shipped for burial. The inspectors was informed that the volume of waste shipped for burial from 1985 to 1986 was 23,514 ft3 and 12,407 ft3 respectively.
No violations or deviations were identified.
9.
IE Information Notices (IEN) (92717)
The inspectors determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.
85-06 Contamination of Breathing Air Systems 85-07 Contaminated Radiography Source Shipments 85-31 Build-up of Enriched U in Ventilation Ducts and Associated i
Effluent Treatment Systems 85-48 Respirator Users Notice:
Defective SCBA Air Cylinders 85-60 Defective Negative Pressure, Air Purifying Full Facepiece Respirators 85-92 Surveys of Wastes Before Disposal from Nuclear Power Facilities j
85-97 Jail Term for Former Contractor Employee who Intentionally Falsified Welding Inspection Records 86-17 Failure of Automatic Sprinkler System Valves to Operate 86-24 Respirator Users Notice:
Increased Inspection Frequency for Certain SCBA Air Cylinders 86-54 Criminal Prosecution of a Former Radiation Safety Officer who Willfully Directed an Unqualified Individual to Perform Radiography