ML20236H193

Insp Rept 70-1201/98-03 on 980518-22.No Violations Noted. Major Areas Inspected:Review of Licensee Radiation Protection Program

ML20236H193
Person / Time
Site:	07001201
Issue date:	06/12/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236H181	List: ML20236H178 ML20236H193
References
70-1201-98-03, 70-1201-98-3, NUDOCS 9807070118
Download: ML20236H193 (14)

Text

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U.S. NUCLEAR REGULATORY' COMMISSION REGION II Docket No.: '70-1201-License No.: SNM-1168 1

Report No.': 70-1201/98-03~

I Lic'ensee: Framatome Cogema Fuels Facility: Lynchburg Manufacturing. Facility i Location: Lynchburg.: VA 24506 -

Dates: May 18-22. 1998

' Inspector: 'A. Gooden~,' Radiation Specialist Approved By:. .

E. McAlpine Chief Fuel Facilities Branch.

Division of Nuclear Materials Safety 1

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9907070118 990612 II POR 'ADOCK 07001201 L C PDR ll p ,

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EXECUTIVE

SUMMARY

Framatome Cogema Fuels NRC Inspection Report No. 70-1201/98-03 This routine unannounced inspection involved a review of the licensee's radiation protection )rogram. The report entails one week of inspection effort by a regional-)ased inspector.

Within the areas examined, the licensee's radiation protection program was adequate to ensure safety and compliance commensurate with requirements in 10 CFR 20 and the license. The inspection results disclosed the following aspects of the program:

• The licensee's administrative controls appeared to provide assurance that radiation arotection instruments were maintained operational and calibrated at tie required frequency. The ventilation warning system )

required enhancements to ensure that area workers were notified in the j event of a loss of ventilation (Section 2.a.3).  !

• Maximum assigned exposures were significantly less than limits in 10 CFR 20 (Sections 2.b.3 and 2.c.3).  !

• The collective exposure for 1997 (29.772 rem) was significantly higher when compared to 1996 (18.661 rem). and slightly increased (21.610 rem) !

over 1995. The licensee attributed this increase to an increase in activities associated with Service Equipment Refurbishment Facility operations (Section 2.c.2).

• Improvements were necessary to the routine bioassay (urine) sample collection and shipping program (Section 2.c.2).

• A chewing gum wrapper was located inside the Pellet Loading Room (PLR).

although no worker was observed actually chewing or eating (Section 2.e.2).

• A number of radiological deficiency reports were issued due to airborne activity exceeding the daily action level (Section 2.g.2).

• Management controls were in place and adequate for monitoring program compliance with the regulations and license requirements (Section 2.g.3).

Attachment:

Persons Contacted and Exit Meeting List of Items Opened. Closed, and Discussed List of Acronyms

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REPORT DETAILS

1. Sumary of Plant Status During the assessment period, there were no unusual plant occurrences.

Routine rod loading'and assembly operations were conducted. Routine decontamination and refurbishment activities were also-conducted in the Service Equipment Refurbishment Facilities (SERF).

.2. Radiation Protection (83822)' (R1) -l a; Radiation Protection Instruments and Eauioment (R1.03)

(1) Inspection Scope l The inspector reviewed the operability. calibration, and maintenance of equipment to determine if equipment was adequately maintained and reliable to perform the intended i safety function.

(2) Observations and Findings Survey instruments and whole body friskers were observed for current calibration stickers and operability during tours of the SERF. PLR and health ph sics technicians office. All instruments responded proper y to battery and/or source checks. Fixed air sampling ocations were examined and samplers were found operational, calibrated, and flow rates ,

were within set points. No concerns were. identified. l

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The inspector requested documentation in support of i instrument calibrations for several portable instruments. l and examined the documentation in support of the daily  !

-background and efficiency checks performed on the alpha / beta counting system. Based on the work orders and calibration L

documentation, the inspector determined that the instruments selected for maintenance and calibration reviews were properly maintained and no evidence of poor reliability was i apparent. The inspector toured the instrument calibration '

facility and noted that positive controls were in place to 1 prevent unauthorized use and/or entry to the facility and J calibration sources. I During the observation of activities inside the PLR. the inspector noted that the red revolving light indicating a i loss of ventilation was activated. In response. personnel I are required to stop work and evacuate the area. However, i workers performing equipment maintenance inside the PLR were unaware that the light was activated. Health physics personnel promptly informed PLR personnel regarding the  !

. light and the potential evacuation pending confirmation of ventilation problems. Safety personnel confirmed that the

2 activation resulted not from loss of ventilation, but was a spurious activation resulting from human error. The inspector noted that the. current location for the light was inadequate in that duct work and piping components prevented recognition of the light depending on the occupant's location within the facility. In response to the .

inspector's observations, the licensee conducted additional l surveys for adequacy and determined an area within the SERF also recuired corrective actions. The inspector was informec that the corrective actions to those areas identified as inadequate would be system u -l both a visual and audible warning signal.The pgrades to include corrective J actions to upgrade the ventilation warning system inside the PLR and SERF will be tracked as Inspector Followup Item (IFI) 98-03-01. l (3) Conclusions Based on performance during tours and documentation in support of calibration, maintenance, and daily operability checks, the selected instruments and equi xnent performed the intended function in a reliable manner. rurther, the

. licensee *s administrative controls appeared to provide assurance that instruments were maintained operational and calibrated at the required frequency. The ventilation warning system required enhancements to ensure that area workers were notified in the event of a loss of ventilation.

b. External Exoosure Control (R1.04)

(1) Inspection Scope The inspector reviewed licensee procedures to determine whether controls were in place to monitor occupational doses, and if administrative limits were established to control occupational dose as low as reasonably achievable (ALARA). Exposure data was reviewed to determine if exposures were in compliance with 10 CFR Part 20 limitc.

(2) Observation and Findings The inspector reviewed radiation protection procedures and discussed with a licensee representative the requirements for monitoring personnel and determined that the licensee *s monitoring program was consistent with requirements in 10.CFR 20. The inspector noted that procedures contained exposure action levels, but no administrative exposure l uits were included. During the ALARA program review, the inspector noted that the ALARA program included as a goal to limit the total effective dose equivalent (TEDE) to 1.5 rem / year.

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The inspector reviewed documentation and discussed with a licensee contact exposures for calendar year (CY) 1996, 1997, and exposures as of May 21. 1998. During CY 96.

463 individuals were monitored. The maximum deep dose equivalent (DDE) was 0.349 rem assigned to a fuel assembly Quality Assurance Inspector. The maximum assigned extremity exposure for CY 96 was 3.192 rem skin dose equivalent (SDE) 4 assigned to a worker in the PLR. The maximum lens dose i' equivalent (LDE) was 0.605 rem assigned to a PLR worker.

Regarding CY 97 exposure data. 588 individuals were monitored. The maximum assigned DDE was 0.659 rem assigned to a worker in the PLR involved with fuel downloading. The maximum assigned extremity exposure for CY 97 was 5.225 rem  !

SDE and the LDE was 0.679 rem. Projected exposure based on estimated thermoluminescent data (TLD) as of May 21, 1998 4 was 0.071 rem DDE. The exposure data depicted an increase in the DDE exposure during CY 97. The licensee contact attributed the increase to an increase in activities associated with SERF operations.

The inspector reviewed the instructor's training material for Radiation Worker training. interviewed a member of the licensee's staff, and reviewed Section 9.3 of Procedure RP-005 (External Radiation Exposure Monitoring) regarding the licensee's exposure control program for declared j pregnancies. The review disclosed a formalized program was in place which met the intent of 10 CFR 20.1208. When questioned regarding any declared pregnancies. the licensee provided documentation for two employees declared pregnant during CY 97. The documentation demonstrated that health 3hysics personnel discussed and reviewed with employees legulatory Guide 8.13 (Instruction Concerning Prenatal Radiation Exposure). prior exposure history, and allowable exposures after declaration of pregnancy.

(3)' Conclusions Based on the records review and interviews. the inspector concluded that the licensee's external exposure control program was adequate for evaluating and monitoring personnel exposures. All assigned exposures were well below limits in 10 CFR 20. The licensee's program for declaring pregnancy was adequately implemented for ensuring that personnel monitoring and exposure control was consistent with 10 CFR 20.1208.

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C,- Internal Exoosure Control (R1.05)

~( 1) Inspection Scope TheLinspector reviewed exposure data based on air sampling and routine bioassay results to determine if exposures were in compliance with 10 CFR Part 20 limits. The inspector reviewed licensee procedures to determine.1f controls' were in place to monitor occupational doses, and if administrative limits were established to control

.occu)ational dose as low as is reasonably achievable

( ALAM) .

(2) Observations and Findings The inspector discussed with licensee contacts and reviewed SL-1250 (Bioassay Program Revision 0, dated November 4, 1997). and RP-005 (External Radiation Exposure Monitoring, Revision 3. dated May 31, 1994) for a description of the exposure control program. The inspector determined that the internal exposure program included breathing zone air samples and/or bioassay samples. The bioassay

- divided into two sections: (1) routine, and (2) program specialwas .

monitoring. The program utilized either in-vivo (lung and whole body counting). or in-vitro (urine and fecal) evaluations. Section 8.0 of SL-1250 required that routine in-vitro analysis (urine samples) be performed on a semiannual basis of program participants. As verification that. routine measurements were performed during CY 97, the inspector requested documentation to show that the semiannual sample collection and urinalysis were performed.

.In response, results were available to' confirm routine sampling and analysis for the first half of CY 97. However, no documentation was available to show sample collection.

shipping, or analysis for the second half of CY 97. The licensee contacted the vendor's lab for assistance in locating documentation to show samples were received and analyzed. The inability to demonstrate via documentation that the samples were collected and sent for analysis will be tracked as Unresolved Item-(URI) 98-03-02. pending an additional search by the licensee and vendor's laboratory.

The inspector examined the timeliness of routine sample shipment. and the vendor lab's participation in a split sampling program. It was noted that during CY 97, samples were not sent in a timely manner and/or inadvertently not collected and provided at all. Documentation as discussed above was unavailable for the second half of CY 97, and the o samples collected during the first half were not shipped to L the vendor for almost two months. According to licensee

[ records, samples were collected on February 5, 1997, but L

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5 were not shipped until April 1997. Thus far in CY 98.

routine sam)les were collected on February 7. 1998, and shipped on rebruary 19, 1998. Exhibit A. Section 1.7 of Procedure SL-1250 states that " Samples shall be sent as soon as possible for analysis." The inspector discussed with the licensee the corrective actions to ensure that routine bioassay samples were sent in a timely manner for analysis.

The implementation of these corrective actions will be tracked as IFI 98-03-03. The vendor's lab participated in a blind sampling program. The inspector reviewed documentation from sample analyses to verify agreement with blind sample results. However, the inspector noted the licensee's procedure addressing the bioassay data evaluation lacked criteria or guidance regarding what is considered satisfactory performance on the urine sample blank, spike, and duplicate samples. The lack of criteria in the licensee's procedure for bioassay data evaluation will be tracked as IFI 98-03-04.

The maximum assigned total effective dose equivalent (TEDE) for 1996 was 0.962 rem as compared to 1.498 rem in CY 95.

For CY 97. the maximum assigned TEDE was 1.275 rem assigned-to an individual in the PLR. The estimated TEDE for CY 98 as of May 21, 1998 was 0.434 rem. The licensee indicated the slight increase-in CY 97 over CY 96 may be attributed to

.the reduced use of respirators and more design changes. The.

inspector was informed that the decrease in exposure from CY 95.(1.498 rem) to 96 (0.962 rem) was credited to the-increased use of respiratory protection by aersonnel performing fuel down-loading operations. T1e individual assigned the maximum TEDE for CY 97 was also assigned the'

' highest committed effective dose equivalent (CEDE) of 1.061 rem. The before mentioned worker was assigned to the PLR. The CY 96 maximum assigned CEDE was 0.753 rem and in CY 95 was 1.249 rem assigned to a PLR worker. Regarding committed dose equivalent (CDE) during CY 97 the maximum assigned was 8.840 rem assigned to a PLR worker. In CY 96.

the maximum assigned was 6.275 rem, and in CY 95.

10.402 rem. Thus far in CY 98. the estimated exposures as of May 21, 1998 were 3.382 rem CDE and 0.406 rem CEDE assigned to a PLR worker.

The inspector requested details and discussed the collective exposure for CY 95 (21.610 rem). CY 96 (18.661 rem), and

-CY 97 (29.772 rem). The licensee attributed the change in

' exposures from CY 95 to CY 97 to an increase in work activities associated with SERF 4. A number of radiological i deficiency re> orts (RDR) were issued during CY 97 as a result of air)orne activity exceeding the daily action level of four derived air concentration-hours (DAC-Hrs). The

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6 inspector reviewed bioassay data that revealed that action levels re exceeded. quiring employee work restrictions were not (3) Conclusions Based on the records review. observation of work practices, and interviews, the inspector determined that the licensee's internal exposure control program was adequate for evaluating and monitoring personnel exposures. All assigned exposures were well below regulatory limits as evidenced by the following: 1) maximum assigned TEDE for CY 97 was approximately 26 percent of the limit in 10 CFR 20: 2) the maximum CEDE assigned was approximately 15 percent of 10 CFR 20 limits: 3) maximum assigned CDE was 17 percent of the limit: and 4) the maximum assigned DDE for CY 97 was approximately 13 percent. Workers in PLR continue to be assigned the highest exposures. Based on the bioassay data reviewed. no action levels were exceeded requiring that employee (s) be placed on work restrictions.

d. Postino. Labelina. and Control (R1.07)

(1) Inspection Scope.

The inspector reviewed the licensee's program for posting as required by 10 CFR 19.11 to determine if documents were posted in sufficient places to permit individuals engaged in licensed activity to observe them.

(2) Observations and Findings The inspector noted that the licensee's posting 3rogram was formalized and discussed in Procedure SL-1130 (~)osting of Safety and Licensing Information," Revision 0, dated June 24, 1997). During tours of the facility the inspector noted that the applicable documents and/or references to their locations were posted at several bulletin boards such that workers may observe documents or obtain details as to where documents may be examined. The inspector noted that at each of the locations was a copy of NRC Form 3 (Notice to Employees).

(3) Conclusions All postings as required by 10 CFR 19 " w istent I with the. regulations and guidance in '.i" a 4.edure

'. SL-1130. Posted documentation also i' 'auu les of the

, license. 10 CFR Parts 19 and 20. and red.:e r .ere

! available in the office of the Manage, Sa N ; and Licensing.

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e. Surveys (R1 08f L(1) Inspection Scope The licensee's contamination control survey program was

. reviewed to determine ~1f the )rogram was adequate and implemented in accordance witi 10 CFR 20. license conditions, and procedures.

-(2) Observations and Findings The inspector observed Health and Safety personnel conducting smear surveys and direct radiation measurements within the SERF-4 and PLR to determine if surveys were in accordance with procedures and action limits. In addition to facility surveys, the inspector observed personnel performing direct radiation measurements and smear surveys on a transport vehicle returning service equi ment from field o>erations. During the observations. tie inspector noted t1at personnel were ~3miliar with both the procedures for conducting surveys and the potential areas of contamination. In those cases where direct radiation measurements were taken, the inspector noted that the appropriate equipment was used and proper operability checks were performed prior to leaving the health physics laboratory.

During the performance of surveys discussed above, the inspector did not identify any significant weaknesses in the licensee's materials, program nor with ~toareamaintain and control postings.- radioactive!

However, the inspector found one exam)le of'a discarded chewing gum wrapper on the floor inside t1e PLR. Actual consumption or. chewing was not observed. The PLR posting prohibits eating. drinking, smoking, or chewing inside the radiological. controlled area-(RCA)- . The inspector discussed with a licensee representative that, although this appeared to be an isolated example, the continued presence of such material-could indicate employee disregard for area postings and exposure controls. The licensee took prompt corrective actions to provide training to all employees (assigned to Product Quality. Manufacturing, and Safety-and Licensing) regarding the prohibition of tobacco products.' drinking, and eating while in the RCA.

The inspector reviewed documentation and records covering the period October 1997 to January 1998, to verify L . contamination control surveys of SERF 4 (High Bay areas) and l the PLR were being conducted in accordance with procedure t

SL-1290 (Radiological Surveys. Revision 0. dated July 31, 1997). No problems were noted. Surveys were performed at l

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(3) Conclusions Based on personnel performance during routine and transportation related smears and surveys, the inspector determined that the licensee's program was adequate for identifying the presence of contamination. and survey procedures provided actions for ensuring that contamination was controlled.

f. Implementation of ALARA Proaram (R1.10)

(1) Inspection Scope The licensee's ALARA program was reviewed to determine if the program and' ALAPA goals were being developed and implemented.on an annual basis. In addition, the program I for reinforcing ALARA concept among employees was assessed.

.(2) Observations and Findings Based on an employee interview, and 'a review of'the instructor training guide for Radiation Worker training, the ins)ector determined that the annual training for radiation worcers discussed in detail the definition, concept, and implementation of ALARA. As verification that training was current, names were randomly selected of individuals assigned to the PLR and manufacturing area. No problems

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The Safety Review Board (SRB) functioned as the ALARA l Committee. The inspector confirmed via. review of SRB meeting minutes that the SRB composition was consistent with Section 2.3 of the license and Section 5.0 of procedure SL-1170 (Safety Review Board. Revision 0 dated June 30.

1997). SRB quarterly meeting minutes conducted during the period February 20. 1997 to March 30. 1998 showed that the ,

SRB was tracking action items and ALARA recommendations via i the Action Register, and providing status updates during i

. quarterly meetings. The implementation of the Action  ;

Register since the last. inspection as a tracking system was  !

considered-a program improvement. The 1995 Annual ALARA Report was presented and discussed during the May 13. 1997.  ;

SRB meeting. In accordance with Section 2.3 of the license, i the ALARA' Report was'by memo transmitted to the Plant Manager. The CY 97 ALARA Report had not been completed at the time of the inspection.

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9 (3)- Conclusions

' Since the-last inspection. the licensee had implemented a method of tracking (action items and ALARA recommendations) know as-the " Action Register." The CY 96 ALARA recommendations-were tracked and reviewed by the SRB during quarterly meetings. The inspector determined, based on an  !

employee interview, and a review of training material, that the employee's role in ensuring ALARA practices in all.

aspects of plant operations was clearly communicated.

g. Manaaement Oversicht of Proaram (R1 11) i (1) Inspection Scope j The inspector reviewed the adequacy of management controls -

for ensuring program con'pliance with the regulations and license requirements.

(2) Observations and Findings )

The inspector reviewed the annual ALARA Report for CY 96. l and the results-from an independent audit conducted during-  ;

the period December 29, 1997, to' January 5.-1998. .The i inspector reviewed the audit results and interviewed the  !

lead auditor. Based on the documentation and interview, the  :

health physics audit appeared to include the areas discussed -I in Section 2.7 of the license. The inspector also reviewed documentation dated May 7. 1998. which detailed the corrective actions and root cause for the audit findings and.

recommendations, and noted that a response was provided for each of the audit recommendations.

l Radiological Deficiency Reports (RDR) were issued by health physics personnel to report any unusual occurrence involving radiation safety requiring management attention. The inspector reviewed RDRs-for the period January to September 1997 to. determine if the licensee was taking actions in response to incidents consistent with procedural requirements. Based on documentation from RDRs and bioassay results, the licensee was properly documenting and responding to RDRs in a timely manner. The review  !

period (January to September 1997) disclosed a significant

-number of RDRs continue to be associated with air samples exceeding the daily action level of four (4) derived air concentration-hours (DAC-Hrs.). No personnel overexposure j resulted. Other problems documented included failure to -

follow procedures or radiation work permit requirements.

improper wearing of lapel samplers, and transportation i

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10 related problems. The RDR_ process appeared to be an effective tool for obtaining management attention to problems.

(3) Conclusions The annual ALARA report semiannual health abysics audit, and the RDR program provided management wit 1 a mechanism for review and taking actions as appropriate to ensure compliance with commitments and regulations. The before mentioned re) orts provided management with summary details for establis11ng goals and commitments to ensure the radiation protection program was implemented in a manner to reduce and minimize exposure. . A significant number of RDRs continue to be associated with air samples exceeding the daily action level of four DAC-Hrs.

3. Exit Interview The inspection scope and results were summarized on May 22, 1998, with those persons indicated in the Attachment. The inspector discussed the inspection findings in detail. Although propriety documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report. No dissenting comments were received from the licensee.

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A_TTACHMENT INSPECTION PROCEDURES USED IP 83822 RADIATION PROTECTION LIST OF PERSONS CONTACTED Licensee

• T. Allsep, Health Physicist D. Driscoll. Regulatory Compliance Officer S. Carter, Manager Inventory and Availability

• G. Elliott, Manager. Safety and Licensing

• D. Gordon, Senior Health Physicist

• A. Jenkins, Manager. SERF 3 and 4 Facilities

• G. Lindsey. Health Physicist

• J. Matheson. Plant Manager

• A. McKim, Manager. Quality Assurance-Health / Safety T. Osborne, Associate Health Physicist Other Licensee employees contacted included engineers, technicians, security and office personnel.

• Attended exit meeting on May 22, 1998 LIST OF ITEMS OPENED AND CLOSED Item Number Status Description 70-1201/98-03-01 Open IFI - Review the corrective actions to upgrade the warning system for the loss of ventilation (Section 2.a.3).

70-1201/98-03-02 Open URI - Inability to demonstrate that semiannual bioassay samples were collected and analyzed (Section 2.c.2).

70-1201/98-03-03 Open IFI - Verify that routine bioassay samples are sent in a timely manner for analysis (Section 2.c.2).

70-1201/98-03-04 Open IFI - Lack of criteria in procedure addressing bioassay data evaluation (Section 2.c.2).

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LIST OFLACRONYMS USED

-ALARA As low as'is Reasonably Achievable CDE Comitted Dose Equivalent

" CEDE- -Comitted Effective Dose Equivalent

.CFR Code of Federal Regulations

'CY Calendar Year DAC- Derived Air Concentration

'DDE Deep Dose Equivalent IFI Inspector Followup Item-IR Inspection Report LDE Lens Dose Equivalent  ;

'NRC Nuclear Regulatory Commission I PLR Pellet Loading Room I QA Quality Assurance RCA Radiation Controlled Area RDR' ~ Radiological Deficiency Report Revision 4

Rev. '

SDE Skin Dose Equivalent' SRB Safety Review Board SERF  ; Service Equipment Refurbishment Facility

,TEDE. . Total. Effective Dose Equivalent--

TLD 1Thermoluminescent Dosimeter URI Unresolved Item-l

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