ML20239A409

Insp Rept 70-1151/98-05 on 980727-31.No Violations Noted. Major Areas Inspected:Observation of Work Activities & Review of Licensee Radiation Protection Program

ML20239A409
Person / Time
Site:	Westinghouse
Issue date:	08/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20239A406	List: ML20239A405 ML20239A409
References
70-1151-98-05, 70-1151-98-5, NUDOCS 9809090136
Download: ML20239A409 (12)

Text

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'U.S. NUCLEAR REGULATORY COMMISSION REGION II j Docket No.: 70-1151 License No.: SNM-1107 Report No.: 70-1151/98-05 Licensee: Westinghouse Electric Corporation Facility Name: Comercial Nuclear Fuel Division i

Date: July 27-31. 1998

Inspector

A. Gooden. Radiation Specialist Approved by: E. J. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Safety l

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i Enclosure 9909090136 990821 "

1 PDR ADOCK 07001151 C PDR i

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. EXECUTIVE

SUMMARY

Commercial Nuclear Fuel Division NRC Inspection Report 70-1151/98-05 This routine unannounced inspection involved observation of work activities and a review of the licensee's radiation protection )rogram. The re entails one week of inspection effort by a regional-)ased inspector. port Within the areas examined, the licensee's radiation protection program was implemented commensurate with requirements in 10 CFR 20 and the license. The inspection results disclosed the following aspects of the program:

-e The licensee's external and internal exposure control programs were adequate for evaluating, and monitoring personnel exposures: and the controls were in place to maintain exposures less than 10 CFR Part 20 limits (Paragraphs 2.b.3 and 2.c.3).

e- The annual assessment of exposure data was adequate, but untimely for identifying which employees or categories of workers required monitoring (Paragraph-2.b.3).

e Employees failed to follow procedures associated with the issuance, storage, and collection of TLDs (Paragraph 2.b.3).

e .The maximum assigned total effective dose equivalent (TEDE) for calendar year (CY) 97 of 2.95 rem was less than the 3.41 rem assigned in CY 96 (Paragraph 2.c.3).

e The collective exposure in 1997 (188 person-rem) was significantly less than the 1996 results of 276 person-rem (Paragraph 2.c.3).

e The licensee's posting was consistent with the license and requirements in 10 CFR Part 20 (Paragraph 2.d.3).

e The licensee's role in ensuring As Low as is Reasonably Achievable (ALARA) practices in all aspects of plant operations was clearly communicated. The ALARA program was considered a program strength (Paragraph 2.f.3).

e Corrective actions were untimely (Paragraph 2.g.3).

Attachmeivt:

Persons Contacted and Exit Interview

. List of Items Opened. Closed, and Discussed List of Acronyms I

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i Reoort Details

1. Summary of Plant Status This report covered a one week period. There were no unusual plant operational occurrences during the onsite inspection.

2. Radiation Protection (83822) (R1)

a. Radiation Protection Proaram Implementation (R1.01)

(1) Inspection Scope l

The inspector conducted interviews and reviewed licensee documentation to ascertain the status of program i implementation. 1 (2) Observations and Findings The inspector reviewed various Regulatory Affairs procedures )

for verification that programs were in place to ensure that I license commitments and requirements in 10 CFR Part 20 were satisfied. The inspector also reviewed the annual As Low as -

is Reasonably Achievable (ALARA) Report which included an assessment of the following key areas of program implementation:

• Internal and external exposures e In-plant radiological conditions e Audits and inspections e ALARA The details included in the ALARA Report documented the licensee's program implementation.

(3) Conclusions B3sedonthedetailscontainedwithintheiibAReport, observation of work activities, and discussions with radiation protection personnel, the inspector concluded that the licensee's radiation protection program was implemented consistent with license commitments and requirements.

b. External Exoosure Control (R1.04_) _

(1) Inspection Scope The inspector reviewed licensee procedures to determine if controls were in place to monitor occupational doses, and verify that administrative limits were established to control occupational dose ALARA. .The inspector reviewed w__________ _.

. 2 personnel exposure data for calendar years (CY) 1997 and 1998 as of July, to determine if exposures were in compliance with 10 CFR Part 20 limits.

(2) Observations and Findings The inspector reviewed radiation protection procedures, and discussed with licensee representatives the personnel monitoring requirements based on documentation from the licensee's evaluation of historical dosimetry data. The inspector determined that the licensee's monitoring program was consistent with requirements in 10 CFR Part 20.

The , inspector reviewed documentation from thermoluminescent dosimeter (TLD) data and discussed with a licensee-representative personnel exposures for CY 1997 and 1998.

External exposures as obtained via TLDs disclosed the maximum deep dose equivalent (DDE) was 0.601 rem in 1997, and 0.174 rem based on the first quarter results.for

'CY 1998. The maximum exposed individual in 1997 was a maintenance worker. The next highest exposure in CY 1997 was assigned to a worker in the fuel bundle final assembly area. Thus far in CY 1998, the maximum exposed was an ammonium diuranate (ADU) conversion employee. The inspector questioned the licensee regarding the maximum DDE assigned to the maintenance worker in light of the assigned dose being a factor of three maintenance worker dose.and greater than theexposure the average next highestfor maintenance workers in CY 1997 was 0.047 rem. 'The licensee acknowledged the exposure as an anomaly and attributed the assigned ex TLD badge.The posure to thenoted inspector employee's improper during the reviewstorage of of the documentation (TLD log book. TLD summary report) additional procedural non-compliances associated with the issuance, collection, and return of'TLD badges during CY 1997 and continued during the second quarter of CY 1998. Many of the non-compliances were also previously identified during an internal audit by the licensee. In response to previous findings, the licensee's corrective actions were effective in reducing the number of missing badges or badges that were not returned for processing. During facility tours, the inspector found no examples where personnel failed to wear TLDs while working in an area with the potential for exposure to radiation. In response to the procedural non-compliances involving the issuance. pro)er storage, and failure to report lost or misplaced TLDs, t1e licensee a discussed the following items as possible corrective actions  !

to prevent similar or recurring non-conformance: review and revise the procedure governing the issuance of TLDs to incorporate information recording and retention l . requirements: all Regulatory Engineering and Operations (RE0) personnel be required to perform a detailed review of assigned procedures specific to assigned tasks to ensure i

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procedural adherence: RE0 personnel be periodically tested l on procedure requirements for assigned tasks; increase the '

audit frequency of badge storage areas: and disciplinary actions where warranted for reaeat procedure violations.

The inspector indicated that tie corrective actions to resolve the procedural non-compliances associated with TLD issuance, collection, and storage will be tracked as an i Inspector Foilowup Item (IFI) (IFI 98-05-01). I Regarding extremity exposures, the maximum exposure in i CY 1997 was 16.76 rem and 8.06 rem thus far in CY 1998 i assigned to a Pellet Operator. The inspector reviewed I calculations performed by the licensee to show that monitoring and re was not required. porting of the lens The calculations dose that showed equivalent the (LDE) l thickness of safety glasses worn by employees and i contractors provided protection against beta radiation such i that the required limits for monitoring were not achieved.

An additional assessment aerformed by the licensee (dated September 23. 1997 and Fe)ruary 11. 1998) was an evaluation of historical dosimetry data for prior years to determine I

which personnel should participate in the monitoring program i for CY 1997 and 1998. A procedure was developed and issued '

June 14. 1998. providing guidance on performing the assessment. One aspect of the procedure requiring improvement was the lack of a time requirement for  ;

conducting the evaluation. To ensure that the appropriate personnel would be included in the first quarter of monitoring for the CY following the evaluation it was i

necessary that the assessment be conducted during the fourth quarter of the CY prior to the next monitoring year. The inspector noted the evaluations were untimely for both  !

CY 1997 (dated September 23. 1997) and 1998 (February 11.

1998). ]

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The collective exposure for 1997 was 188 person-rem. The average worker dose in CY 1997 was 0.54 rem in comparison to  !

CY 1996 of 0.45 rem. l (3) Conclusions Based on the exposure records review and interviews, the inspector determined that the licensee *s external exposure control program was adequate for monitoring personnel exposures. The ar.nual assessment of exposure data was adequate, but untimely for identifying which employees or categories of workers required monitoring. The exposure controls were in place to maintain exposures less than 10 CFR Part 20 limits. When administrative action limits were exceeded and required investigation into causal factor, the investigation was thorough and extensive in attempts to determine the cause. Employees failed to follow procedures a

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c. Internal Exoosure (R1.05) ,

(1) Inspection Scope The inspector reviewed licensee procedures for assessing internal exposure to determine if controls were in place to monitor occupational doses, and verify that the administrative limits were established to control occupational dose ALARA. Exposure data based on air sampling results for CY 1997 and the period ending July 1998 were reviewed to determine if exposures were in compliance with 10 CFR Part 20 limits.

(2) Observations and Findings The licensee's primary method of assigning internal exposures to personnel was based on fixed air sample results. In addition to the air sampling program, employees that were assigned to potentially contaminated and/or airborne areas participated in the bioassay program for exposure verification. The inspector reviewed the results for CY 1997 based on data for January through December 1997.

The maximum committed effective dose equivalent (CEDE) in 1997 was 2.73 rem, and thus far in CY 1998 was 1.02 rem.

The maximum assigned CEDE was to an ADU conversion employee.

The next highest exposure was assigned to a worker in Pellet manufacturing (2.56 rem). During CY 1996, the maximum assigned CEDE was 3.09 rem.

The maximum assigned total effective dose equivalent (TEDE) for CY 1997 was 2.95 rem assigned to an ADU conversion employee. The ALARA goal for CY 1997 was less than four

(<4) rem. The maximum assigned TEDE as of July 98 based on estimated TLD data for four months and air samaling data through June 98, was 1.21 rem assigned to an A)U conversion employee. The maximum assigned TEDE (2.95 rem) and collective exposure (188 person-rem) for CY 1997 was less than CY 1996 (3.41 rem and 276 person-rem respectively) as a result of the reduction in airborne activity during CY 1997.

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l The inspector discussed with the hcensee the invivo '

counting system and the licensee's participation in a 1 cross-check program for accuracy and verification of l equipment operability. The inspector was informed that the system was inoperable at the time of the inspection, and the last cross-check was performed during December 1993.

According to the interviewee. the system down time thus far in CY 1998 had been approximately 30 percent due to calibration and repairs. The inspector expressed concern i

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(3) Conclusions Based on the interviews and exposure records reviewed, the inspector determined that the licensee's internal exposure control program was adequate for evaluating and monitoring personnel exposures. The licensee was effectively tracking and trending occupational exposures. Administrative dose limits were established and all assigned exposures were well below the regulatory limits. The maximum assigned TEDE (2.95 rem) and collective exposure (188 person-rem) for CY 1997 was less than CY 1996 (3.41 rem and 276 person-rem respectively) as a result of the reduction in airborne activity during CY 1997.

d. Postina. Labelina. and Control (R1.07) l (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. The inspector reviewed selected areas based on direct radiation surveys to verify the adequacy of posting.

(2) Observations and Findings During tours of the facility, the inspector noted locations where the applicable dccuments and/or references to their locations were posted such that workers may observe documents or obtain details as to where documents may be examined. ihe ins)ector noted that at each of the locations was a copy of the iRC Form 3. Regarding pnsting of radiation areas, the inspector reviewed data for CY 1997 and 98 direct radiation surveys end noted that the maximum reading obtained from any location was eight millirem per hour (mr/hr). The inspector toured each of the areas from which the measurements were made and confirmed that the areas were osted as radiation areas consistent with ,

10 CFR 20.1 02 (greater than 5 mr/hr).

J j (3) Conclusions

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. 6 Based on tours and survey data, the inspector determined that the licensee's posting was consistent with the license and requirements in 10 CFR Part 20. The licensee's air samaling and direct radiation survey program provided the meclanism for revising posting as a function of changing radiation levels.

e. Notifications and Reoorts (Rl.09) l (1) Inspection Scope The licensee's Unusual Incident Report (UIR) file was reviewed for determining the deportability of events to NRC and workers. .

(2) Observations and Findings Three incidents from CY 1997 were reviewed by the inspector for applicability in re)ortita. NRC reporting was not required. However, worcers involved in the incidents were notified because of the potential for exposure from the incidents. The licensee provided notification in addition to followup in the event the individual was placed on work restrictions.

(3) Conclusions No concerns were noted. Based on the three incidents reviewed, the licensee's performance in deportability, exposure assessment, and causal factors was detailed and thorough.

f. Implementation of ALARA Proaram (Rl.10)'

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

(2) Observations and Findings Based on em)loyee interviews, and a review of section 1 of the rad worter. training manual, the inspector determined that the annual training for radiction workers discussed in detail the definition, concept, and policy on ALARA.

The Regulatory Compliance Committee (RCC) functioned as the site ALARA Committee. However, the Airborne Reduct'.on Team (ART) is chartered by the RCC to implement the ALARA 3rogram by establishing goals and objectives. Minutes from tie RCC and ART meetings conducted during the period December 11, w________- _ _ _ - _ _ _ _ _ ._ _ _ _ ___ - _ a

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. 7 1997 to June 19. 1998, showed that tne licensee was tracking action items and ALARA recommendations, and providing status updates during periodic meetings. On a quarterly basis, the licensee held mini ALARA meetjngs that were effective in reviewing and trending data to identify undesirable trends.

The 1997 Annual ALARA Report was reviewed and discussed l during the March 11. 1998 mini ALARA meeting.

(3) Conclusions Based on em)loyee interviews, and a review of training material, tie licensee's role in ensuring ALARA practices in all aspects of plant operations was clearly communicated.

The ALARA 3rogram was considered a program strength as I

evidenced ]y the continued downward trend in airborne activity.

g. Manaaement Oversicht of Proaram (RI.11)

(1) Inspection Scope The inspector reviewed the adequacy of management controls for ensuring program compliance with the regulations and license requirements.

(2) Observations and Findings The inspector reviewed the annual ALARA Report for CY 1997.

the internal daily audits performed by RE0 technicians for the period May through July 1998, and the Unusual Incident Report (UIR) file. The before mentioned reports provided management with summary details for ensuring the radiation protection program was properly implemented.

Open items from audits were tracked and adequately trended.

However, the timeliness of resolution appears to require management attention as evidenced by items remaining open for more than two years. Examples were as follows:

e The development of a Health Physics Technician training package was assigned on January 19, 1995, but corrective actions closure was not until March 9. 1998.  ;

e Actions to revise and update the respirator training video tape was assigned on April 28, 1995, and remained open as of July 98. 1 1

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L__________-________-________________________ . _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -. ___ _ _ _ _ . ._ _ _ _ _A

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The inspector was informed by the licensee that a new 3rogram initiative known as the Safety Marain Improvement 3rogram (SMIP) was recently implemented. According to the

' licensee, the SMIP will provide increased awareness to plant management to assure coordination of project priorities, resources, schedules, and commitment dates.

(3) Conclusions Althuugh the tracking system was in place and properly maintained additional involvement by management was necessary to ensure corrective actions are completed in a timely manner. The annual ALARA report. internal health physics audit, and the UIR program provided management with a mechanism for review and taking actions as appropriate to ensure compliance with commitments and regulations,

h. Information Notice (1) Inspection Scope The inspector reviewed the Information Notice (IN) 96-70.

Year 2000 Effect on Computer System Software (2) Observations and Findings The inspector determined that the IN was received by the licensee, and reviewed for applicability. Licensee documentation showed that radiation protection equipment  !

and/or software potentially impacted by year 2000 had been '

identified along with the actions necessary for ensuring compliance.

(3) Conclusions Based on interviews and documentation, the licensee had conducted a systematic review of equipment and software based on the safety significance, and importance of equipment and/or software in assuring compliance with the requirements of the license. 10 CFR 20. and procedures.

3. Exit Interview The inspection scope and results were summarized on July 31, 1998, with those persons indicated in the Attachment. The inspector described the areas inspected and discussed in detail the inspection results below.

Although proprietary documents and processes were occasionally reviewed l during this inspection, the proprietary nature of these documents or

! processes has been deleted from this report. Dissenting comments were not received from the licensee.

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f ATTACHMENT

1. PEPSONS CONTACTED Licensee Personnel ,

• J. Allen. Plant Manager

• J. Bush Manager. Manufacturing

• W. Dougherty. Manager. Respirator Team

• R. Fischer. Senior Engineer. Regulatory Engineering and Operations K. Fowler. Manager. Information Systens S. Gantt. Engineer. Regulatory Engineering and Operations

• D. Goldbach, Manager. Chemical Operations

• W. Goodwin. Manager. Regulatory Affairs

• J. Heath. Manager. Regulatory Engineering and Operations R. Irving. Senior Engineer

• A. Kaminsky Manager. Human Resources

• R. Likes. Senior Regulatory Engineer

• E. Reitler Fellow Engineer Other licensee employees contacted included engineers, technicians, production staff security, and office personnel.

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• Denotes those present at the exit meeting on July 31, 1998.

2. INSPECTION PROCEDURES USED IP 83822 Radiation Protection

3. LIST OF ITEMS OPENED CLOSED, AND DISCUSSED ltem Number Status Description 70-1151/98-05-01 Opened IFI - Verify corrective action to l resolve procedural non-compliances '

associated with TLD issuance, i collection, and storage.

70-1151/98-05-02 Opened IFI - Review invivo counting system cross-check results for accuracy and efficiency.

4. LIST OF ACRONYMS ALARA As Low as is Reasonably Achievable ADU Ammonium Diuranate ART Air Reduction Team CEDE Committed Effective Dose Equivalent CY Calendar Year DDE Deep Dose Equivalent IFI Inspector Follow-up Item

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2 l IN Information Notice IR Inspection Report LDE Lens Dose Equivalent j mr/hr millirem per hour NRC Nuclear Regulatory Commission, RCC Regulatory Compliance Committee RE0 Regulatory Engineering and Operations SMIP Safety Margin Im)rovement Program TEDE Total Effective Jose Equivalent TLD Thermoluminescent Dosimeter

, VIR Unusual Incident Report

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