ML20248C141
| ML20248C141 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/27/1989 |
| From: | Bassett C, Kuzo G, Lauer M, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20248C091 | List: |
| References | |
| 70-1113-89-05, 70-1113-89-5, NUDOCS 8908090444 | |
| Download: ML20248C141 (50) | |
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UNITED STATES
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. NUCLEAR REGULATORY COMMISSION
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REGION ll '
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.j 101 MARIETTA STREET, N.W.
ATLANTA, GEORGI A 30323 Q
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3 JUL 27W i
....70-1113/89-05 l
> Report No..
W Licensee: GeneralLElectric Company
'Wilmington, NC 28401 Occket No. 70-1113' License No.: SNM-1097
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-Facility Name: General Electric Company l
l Inspection Conducte : May 22
. 26',' June 12 - 15, and June 23, 1989 f
Inspectors:
,[
[/J7/7 G. SVKul ' ~
DaYe Signed j
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[h C. VBa s tt Date'41cfned i
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-7/N}ht M. 7. L e D(te/ Signed Approved by:
7 DrtefSigned i
J.M. Potter, Chief a
Facilities Radiation Protection Section Emergency Preparedness and Radiological Protection 4
Branch i
Division of Radiation Safety and Safeguards.
SUMMARY
s Scope:
This special, unannounced inspection involved review of licensee radiation 1
protection programs for assurin5 personnnel' exposures were maintained as, low as reasonably achievable (ALARA), and review of.previously identified inspector' followup items (IFIs)' and enforcement items concerning radiation protection-activities.
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~Results:
l-The following strengths were noted:
(1) there was a well defined management commitment to the ALARA philosophy; (2);there was a system for incorporation of ALARA considerations into reviews and engineering evaluations for initial designs and/or modification's of equipment or processes; (3) use of engineering controls to reduce concentrations of uranium; (4) there was an effective annual ALARA review of routine processes and/or work areas; with identified concerns prioritized, and subsequent corrective actions developed and implemented in a s
14 timely manner; (5) the use of annual retraining to stress ALARA concepts; and (6) the prompt distribution of stationary air sample results to line management for action.
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2 Weaknesses noted in the ALARA program included:
(1) attention to cleanliness and housekeeping within the process facilities was minimal; (2) numerous inconsistencies were noted for employee interpretations of posting requirements; (3) licensee audits were ineffective in reducing the repetitive nature of audit findings; (4) minimum supervisory review of routine activities; (5) the extent and thoroughness of radiation protection staff. coverage; (6) absence of formal radiation protection staff training; (7) lack of i
evaluation by technical personnel of detailed pre-work, on going, and post-work Radiation Work Permit (RWP) controls; and (8) the lack of formalization of the Radiation Safety Committee (RSC) ALARA review process.
Overall, the deficiencies identified for procedural adequacy and adherence, degree of management involvement, technical
- reviews, timeliness and thoroughness of licensee evaluations, and radiation protection coverage adequacy, decreased ALARA program effectiveness.
Within the areas inspected, the following violations were identified:
l l
Failure to conduct sufficient surveys of surface and airborne radioactive contamination to evaluate the hazards present for personnel involved in the installation of the Heating Ventilation Air Conditioning (HVAC)
Management and Control system upgrade (Paragraph '4) is an example of a violation of 10 CFR 20.201(b).
Failure to adhere to licensee procedures for conducting decontamination activities for:
(1) the FMO Powder Warehouse area (Paragraph 13); and l
(2) process equipment (Slugger) parts maintained in the controlled area during maintenance activities (Paragraph 13) are examples of a violation of License Condition No. 9, License Application, Part 1, Section 2 2.1.4.
Failure to follow approved procedures for (1) area posting requirements (Paragraph 11.c); (2) protective clothing usage (Paragraphs 11.a and l
11.b);
(3) respiratory protective equipment inspection and storage j
(Paragraphs 11.d-f); (4) personnel contamination surveys (Paragraph 11.g);
i (5) respiratory training and qualifications (Paragraphs 12.a and 12.b);
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(6) empty can storage (Paragraph 11.h); and failure to have adequate procedures for (7) evaluation of activities resulting in personnel internal exposures exceeding soluble uranium action guidelines (Paragraph 14) are multiple examples of a violation of License Condition No. 9, License Application, Part 1, Section 2.2.1.4.
Failure to adequatcly demonstrate representativeness of fixed air sampling points relative to air breathed by workers (Paragraph 10) is a violation of License Condition No.
9, License Application, Part 1,
Section 3.2.4.2.1.
s, 4
REPORT DETAILS 1.
Persons Contacted
- D. Barbour, Supervisor, Radiation Protection H
- B. Beane, Principal Engineer, Facilities
- B. Bentley, Manager, Fuel Production
- G. Bowman, Senior Program Manager, Nuclear Safety Engineering
- J. Bradberry, Program Manager, Security and Emergency Preparedness
- D. Brown, Manager, Uranium Recovery Unit (URU)/ Waste Treatment
- T. Crawford, Acting Manager, Environmental Protection and Industrial Safety
- R. Foleck, Senior Specialist, Licensing Engineering
- M. Gray, Manager, Organization and Staffing
- R. Hawk, Manager, Materials
- R. Keenan, Senior Engineer, Nuclear Safety "E. Lees, Manager, Nuclear Fuel and Component Manufacturing (NF&CM)
- R. McIver, Manager, Plant Engineering and Maintenance (PE&M)
- W. McMahon, Manager, Fuel Manufacturing Engineering (FME)
- S. Murray, Senior Engineer, Nuclear Safety
- R. Pace, Manager, Powder Production Unit
- R.' Patterson, Manager, FME
- W. Peters, Acting Manager, (PE&M)
- D. Pensinger, Acting Manager, Quality Assurance
- P. Sick, Manager, Quality Assurance
- P. Stansbury, Senior Engineer, Nuclear Safety H. Strickler, Manager, Environmental Protection
- R. Torres, Manager, Radiation Protection
- C. Vaughan, Manager, Regulatory Compliance
- R. Winslow, Manager, Licensing & Nuclear Material Management Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
Nuclear Regulatory Commission
- T. Decker, Section Chief Radiation Safety Projects Nuclear Materials and Scfety Safeguards Branch Division of Radiation Safety and Safeguards (DRSS)
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- J. Potter, Section Chief Facilities and Radiation Protection Section, Emergency Preparedness.nd Radiation Protection Branch, DRSS
- Attended exit interview on May 26, 1989
- Attended exit interview on June 15, 1989 1
2 2.
Mc9agement. Involvement with ALARA (83822) a.
ALARA Policy Corporate management's commitment to and involvement with ALARA issues for the General Electric (GE) facility at Wilmington, designated the Wilmington Manufacturing Department (WMD), were reviewed and discussed with selected licensee representatives.
Licensee management stated that the company has had an ALARA program for approximately ten years.
Current general company policy is contained in the GE Organization and Policy Guide, Policy 20.3, Health, Safety, and Environmental Protection, dated December 15, 1986.
The policy is implemented by the GE Company procedure, Procedure For Implementation of Health, Safety, and Environmental Protection Policy, dated December 15, 1986. That policy is restated at the Nuclear Division level in the Nuclear Energy Business Operations (NEBO) Policy and Procedure (P/P) No. 70-4, Employee Health and Safety and Environmental Protection, dated May,1988 and implemented by NEB 0 P/P No. 70-17, Nuclear Safety Assurance in GE Nuclear Energy Facilities and Offsite Activities, dated July,1988.
At the local WMD level, P/P 40-7, Occupational Radiation Exposure Control, Revision (Rev.) 8, dated October 13, 1987, states the ALARA philosophy and implements NEB 0 P/P 70-17.
Company policies' and procadures require the development and implementation of written procedures to protect the health and safety of employees and limit, to the lowest practicable levels, adverse effects on human health and the environment. The nuclear departmer;t policies and procedures specify that measures are to be taken to protect the health and safety of employees and the public in accordance with the ALARA philosophy.
The NEB 0 P/Ps also establish the facility manager as the person responsible for nuclear safety and specifically include maintaining occupational exposures ALARA as one of the manager's responsibilities.
The WMD site policies and procedures require an annual review of ALARA programs and policies, delegate the responsibility for ensuring safe operation and control of activities conductea at the facility to Area Managers, and require written procedures that incorporate radiation safety into all activities conducted at the site. Excluding the annual review of the ALARA program, the procedures do not require upper management involvement and do not establish criteria for evaluating the effectiveness of the program.
l Other site procedures relating to ALARA and the ALARA program were j
reviewed. These are as follows:
P/P 40-1, Wilmington Safety Review Committee, Rev.1, dated October 23, 1987.
P/P 40-4, Nuclear Safety Design Criteria, Rev.
7, dated August 16, 1988.
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P/P 40-5, Nuclear Safety Review System, Rev 5, dated April 22, l
1987.
P/P 40-18, Regulatory ~ Compliance Administrative Action Cuidelines, Rev. 8, dated March 9, 1989.
P/P 40-31, Occupational Radiation Safety Committee, Rev. 2, dated April 22, 1988.
In general, the management system for implementing ALARA policy through procedures was adequate although the licensee's procedures concerning the ALARA program, as well as procedures governing other radiation protection programs at the facility, often are not detailed.
Specific examples of procedural deficiencies are noted within this report.
b.
Management and Organizational Responsibility The facility organization and management oversight of and involvement in implementing the ALARA program at the site were reviewed. The Wilmington Safety Review Committee (WSRC) serves as the site functional review group for all facility ALAP.A programs and policies as detailed in Section 2.3.1 of the License Application.
As specified in its charter, the WSRC, among other responsibilities, annually reviews: (1) ALARA programs and projects, (2) performance indicator trends including airborne concentrations, personnel exposures, and environc> ental monitoring results, and (3) programs for improving the effectiveness of equipment used for effluent and exposure control.
The WSRC fulfills this funrtion by requiring an annual presentation from the Nuclear Safety Engineering-(NSE) group.
In order to meet this requirement, the NSE group reviews data which have been collected, analyzed, and trended by the facility Radiation Protection (RP) Section and by the RSC. The NSE group also compiles data on the progress of the RSC toward completion of ALARA projects established by the RSC.
The RSC is further discussed in Paragraph 2.c.
Based upon the data provided, the NSE group generates the required presentation.
Other than the required annual review, GE WMD management's involvement in the ALARA program was :dentified by the Manager, WMD, as that of allocating funds for the completion of selected ALARA and safety-related projects.
Upper level management's involvement is, therefore, indirect rather than direct. WMD management's commitment to develop and maintain an effective ALARA program appears to be established and directed entirely through the RSC.
Following the annual allocation of funds for ALARA projects, the RSC determines which projects to complete. By allowing the RSC to function in a mostly autonomous manner, management effectively has relegated direction and operation of the ALARA program to tne RSC.
e 4
c.
ALARA Program Implementation The ALARA program is implemented at WMD by the site.RSC.
Currently, the RSC is comprised of 18 persons who occupy positions in the WMD organizational structure below the department manager level, such as program
- managers, unit
- managers, supervisors, and senior contributors. The number of personnel and organizations represented on the RSC include one perron from the RP Section who serves as Chairman of the RSC; five individuals from Shop Operations; five persons from Engineering; two individuals from Maintenance one of whom serves as Secretary of the RSC; two persons from NSE; and one each from Quality Assurance (QA), Technology, and the Value Adding Manufacturing (VAM) groups.
The RSC is required, by Section 2.3.? of the License Application, to meet monthly to maintain a continual awareness of the status of containment projects, performance measurements and trends, and the current shop operation radiation safety conditions. The RSC often meets more frequently, as required by operational conditions, and a written report of each meeting is sent to all area managers and upper management as well.
Minutes of the RSC meetings from May 1988 to May 1989 were reviewed and discussed with licensee representatives. The committee met as required with an average attendance of 11 members.
The meeting minutes indicated th6t the majority of the items reviewed were ALARA issues.
Typical projects which were addressed included improved containment for piping in the vaporization area to reduce airborne concentrations in the area, relocation of air samplers to improve i
measurements, containment control for the waste box stnrage area, a l
compliance project aimed at reducing internal audit findings and improved criticality controls in the radwaste area. The inspector l-noted that the RSC had a 95 percer.t completion or success ratio for al? projects initiated since the RSC was organized.
Actual ALARA program implementation by the RSC is on an annual basis, but projects can be added continually if the current ones are completed before the end of the program year. Each fall the committee considers different projects or concerns submitted by members of the RSC A "strawman" or list of possible projects to be acted upon is developed through a rankino systam which numerically rates each project in several categorles including safety and ALARA considerations.
Department managers are informed of the "strawman" and are permitted to make
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comments or suggestions concernir,g the listed projects.
After discussions and comments are received, the RSC adopts a list l
consisting of 10 to 20 projects to be worked during the year.
Successful completion of each project is judged on criteria established by the RSC. As projects are completed, and if they meet the completion criteria, they are removed from the list and other projects are added as time and funds permit.
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Following' selection of the projects to be worked, the" RSC meets,-
i assigns one of its members as project chairman, and assigns money to-be used from-funds allocated by upper management. The. Chairman then
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-has the responsibility to ensure. that the assigned-project lo completed.
The Chairman assigns tasks to other members of the
. committee -and/or sol.icits and receives he1p from other organizations on site. All of these duties and assignments are in addition to.those normally held by the. individuals involved.
- The inspector discussed the manner in which the RSC' functio'ns and L
prioritizes~ the list of projects to be developed as improvements. to the. facility..At.present, the committee is functioning without any.
procedures.that stipulate the actual process, criteria, and adoption of-the improvement list for action. Although the process appears to be functioning; adequately, there are no written procedures to provide guidance for. the committee or the process used.
Licensee representatives stated that more written guidance.is needed for the RSC.
Licensee actions' regarding the establishment of procedura1 guidance outlining.RSC functions will be reviewed by the NRC as an Ir:spector Followup Item (IFI) (70-1113/89-05-01).
The. implementation of the ALARA program on a working leval basis was l
less than adequate.
It was not apparent that_ anyone other ' than members ' of the RSC had direct input to, or responsibility and l-accountability for the ALARA program.
That is, it did not appear
/
that workers were used as a source for ALARA improvements or R
suggestions. Although general workers appeared to be aware of their responsibility to keep their exposures as low as possible, the
' inspector noted that. the structure of the program suggested that ALARA and ALARA initiatives and improvements-are the sole responsibility of the RSC members.
Licensee _ representatives indicated that although no formal ALARA -
suggestion program existed, suggestions or ideas on ways to improve.
the working environment and conditions were everyone's l
l~
responsibility.
The inspector noted that the recently established VAM teams, involving workers from every organization, would be an applicable metnod through which ideas for.ALARA improvements could be solicited. Through interviews with workers, the inspector determined I
that the VAM team was, in fact, the means that most workers would use to make suggestions on improvements to the ALARA progrem.
The potential to use the VAM teams to improve worker commitment and input to ALARA policies at the facility was seen as a program strength.
d.
ALARA Program Evaluation By Management As one means to determine the amount of involvement in and evaluation of ALARA and radiation protection programs by management personnel, the inspector reviewed records of time spent by management in the I
controlled areas of the facility.. During all of 1988, the inspector l-noted that the maximum number of hours spent in the Controlled Area
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6 by any manager was 182, with the average time approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> or.less than one work week. To date for 1989, the maximum number of hours spent in the controlled area by a manager was 61 hours7.060185e-4 days <br />0.0169 hours <br />1.008598e-4 weeks <br />2.32105e-5 months <br />, while the average was approximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
Through discussions with licensee representatives, the inspector indicated that increased
" time in area" (TIA) possibly would allow management personnel to identify and improve procedural adequacy and adherence to deficiencies identified during this audit.
It was also noted that more TIA spent and more frequent tours of the controlled areas by management personnel.could produce positive effects by reinforcing, not only the ALARA concept, but the concepts of proper procedure compliance, proper maintenance, and better housekeeping of the facility.
Lack of TIA spent by management in the controlled work areas was regarded as an ALARA program weakness.
e.
Process and Procedural Modifications The inspector reviewed the incorporation of ALARA considerations into new operations and/or procedures at the facility. WMD procedures P/P 40-4 and P/P 40-5, as well as Nuclear Safety Instruction (NSI)
E-3.0, Nuclear Safety Review Requests, Rev. 13, dated January 18, 1989, and NSI E-7.0, Radiological Safety Review for Process and Equipment Changes Requests, Rev. 10, dated October 14, 1988, provide details of the review and evaluation process to be used.
These procedures require the NSE group to provide the radiation and criticality safety review of initial designs and/or modifications of equipment or processes in the facility.
In addition, new procedures are tent to the NSE group for radiological and ALARA reviews.
Review of new designs or modifications is accomplished by requiring all the Process and Equipment / Facility Change Requests (FCRs) to be tent to NSE group for review.
The nuclear safety (NS) engineer, assigned to review the project or change, determines if a radiological safety review is necessary. The NS engineer makes this determination based on previous experience and knowledge of conditions of the facility.
If no review is deemed necessary, the FCR is sent to Radiation Protection where a Radiation Work Permit (RWP) is prepared to cover the work involved.
A review is required by NSI E-7.0 when: (1) potential radiation exposure may exceed the approved action guidelines, (2) radiation exposure cannot be adequately controlled by routine methods and existing programs for radiation exposure assessment, (3) procurement, use, or relocation of sealed sources of hazard potential or x-ray machines is involved, and (4) changes in existing equipment, processes, or operations may affect currently approved methods of radiation exposure assessment or impact previous dose rate measurements.
NSI E-7.0 also contains a list of considerations to be used during a radiological analysis / review. Although the list appeared to be adequate, licensee representatives indicated that it was seldom used. Those performing this review relied on their past experience and knowledge of the areas to complete this process. Reliance on past experience without 1
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7' referencing an. appropriate checklist for analysis / review' of.
radiological considerations. of work to be performed was notedf as having a possible negative: impact on the ALARA program.
'Following completion of the new design or modification project, the NSE group ~ also performs 'a preoperational audit and evaluation to-ensure that -the equipment' or process is functioning as initially
. designed. This preoperational audit,'as well as the FCR, review and.
other. records, are then maintained on file by the NSE group.
The inspector reviewed selected FCRs for 1988 and 1989.
The FCRs -
were being sent. to the NSE group for rev_iew and, in_ general, the -
reviews appeared adequatei
- However, an exception was-noted concerning a review of activities associated with contract work in the overhead areas of the Fuel Manufacturing Operation / Fuel'
- Manufacturing Operation' Extension (FM0/FM0X) building, where an extensive' review using the NSI E-7.0' checklist was applicable but not conducted. -In that instance, the 'FCR' was sent to Radiation Protection for. preparation of an RWP and initiation of' work.
The potential for unmonitored internal exposures to radioactive materials subsequently developed due to ' inadequate surveys and evaluations of selected areas where modifications and maintenance work were conducted.
This' issue is discussed further in Paragraph 14.
The lack of requiring detailed controls, checklists, for the FCR system to ensure adequate radiological review of all routine and non-routine work' activities by. technical NSE personnel as-illustrated by the above example, was noted as a weakness.
3.
Audits The inspector reviewed licensee's audit programs used to evaluate radiation. protection issues affecting ALARA program effectiveness.
Reviews of the plant functional areas which impact the effectiveness of the ALARA program are accomplished during licensee-required formal quarterly audits and, in addition, during
" Radiation Protection i
Inspections" conducted by RP monitors (technicians) during weekly routine surveillance, a.
Quarterly Audits The quarterly audit function is accomplished by the NSE group.
E l'
Guidance regarding the formal audits is outlined in the following l
procedures.
l P/P 40-6 Regulatory Compliance Audits, Rev. 11, dated November 17, 1988.
F NSI No. E-2.0, Internal Nuclear Safety Audits, Rev. 16, dated January 18, 1989.
4 8
Details of the formal audit procedures were reviewed and discussed with licensee. representatives. The procedures establish the Regulatory Compliance group, within the NSE group as responsible for implementing ~the audit program, assigning responsibility for audits and their conduct, reviewing findings, and conducting followup regarding identified potential noncompliance (PNCs).
In addition, all audit findings are reviewed by the Manager of Regulatory Compliance.
Each Manager of the area / subsection audited is required to accompany the auditors, review audits, commit to and concur with identified actions and target dates, and evaluate and respond to findings.
Subsection Managers are required to implement committed actions and to document item completion for the Regulatory Compliance Unit Manager.
The procedures also establish time limits for resolution of issues, responses, and corrective actions. All PNCs are tracked by the Licensing and Nuclear Materials Management Group.
The inspector reviewed and discussed selected quarterly audits conducted from January 1987 through June 1989. The audits reviewed compliance with documented procedures and requirements, and in
- addition, assessed radiological
" good practices" and general housekeeping when nece s sa ry.
During reviews of the audits, the inspector discussed and reviewed with cognizant licensee representatives the following identified PNCs and, in particular, noted their similarity to NRC-identified procedural violations reported for the current inspection.
First quarter 689: Improper mask storage - Vaporization and Bundle Assembly ares; Uncovered empty cans - Waste Treatment area.
Fourth Quarter 1988: Undated Full-face respirator - Chemical area; Improperly stored Half-mask respirator - Fabrication area; Internally contaminated equipment not wrapped nor posted - area adjacent to the Incinerator building.
Second Quarter 1988: Contaminated foreman's changeroom - URU and New Decon room.
First Quarter 1988:
Respirator laying on exposed contaminated surface - Chemical area; Two uncovereo cans process area.
Third and Fourth Quarter 1937: Improper respirator storage -
Fuel Support area.
Second Quarter 1987. Undated Respirator Canister process area.
First Quarter 1987. Excess Material Accumulation process area.
The failure of the licensee audit program to achieve long-term prevention of these repeat PNCs/ violations was discussed with licensee representatives.
From discussion with licensee representatives and review of records, the inspector determined that
\\
a.
9 root cause analyses are not conducted for identified PNC items.
Review of selected PNC Forms which describe audit findings, committed actions, and current status, indicated that the majority of corrective actions were conducted immediately, for example, l
correcting the noted PNC during the audit and discussing the issue i
with immediate unit area workers and supervisors.
Extensive and thorough actions, for example, conducting training of all workers.
potentially involved in similar practices and reviewing all applicable procedures for deficiencies, thus minimizing potential for recurrence in other areas, were not noted on the PNC Forms.
Furthermore, the inspector noted that the procedures did not address actions required for identified repeat'PNCs. The failure to conduct root cause analyses for the quarterly audit PNCs was identified as a program weakness. The repeat violations noted during this current inspection, for example, improper respirator maintenance, can storage, and excess material accumulation, increase the potential for contamination and internal exposure.
The licensee agreed to review the audit process.
Licensee actions to review and improve their formal audit program effectiveness was identified as an IFI and will be reviaa ' during a subsequent inspection (70-1113/89-05-02),
b.
Radiation Protection Inspections The inspector discussed with the Radiation Protection Manager (RPM) the use of the weekly RP Inspections conducted by RP monitors to provide an audit function regarding ALARA concerns.
Currently, the RP monitors identify and report qualitative items / concerns identified during weekly inspections conducted throughout the facility.
The items are classified into approximately 26 distinct categories, for example, improper respirator use, improper protective clothing (PC),
excessive contamination requiring clean-up, etc.
Where possible, identified issues / concerns are resolved immediately.
Furthermore, these data are assimilated by the RPM for presentation to the RSC for use in the annual ALARA review.
The inspector was in formed by licensee representatives that procedures outlining the use of the Radiation Safety Inspection data in an audit function had not been developed.
Their use in the RSC annual ALARA review was dependent upon the RPM. The use of these data in defining and selecting improvements projects during the annual RSC ALARA review appeared adequate.
However, this adequacy, most li kely, resulted from the long-term RPM's knowledge of the facility and the ALARA review process.
The inspector noted that changes in personnel would be expected to reduce the effectiveness of the process and the lack of guidance implementing the program was considered a weakness. This lack of procedural guidance involving the RSC review process previously was identified as a NRC IFI (Paragraph 2.c; 70-1113/89-05-01).
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10 4.
Training The inspector discussed.with cognizant licensee representatives the incorporation of ALARA concepts into general training and/or specialized training provided to facility workers.
a.
Controlled Area General Training Guidance for implementing the Controlled Area general training programs, as detailed in P/P 40-17, Nuclear Safety Training, Rev. 5, dated November 12, 1987, was reviewed and discussed with cognizant licensee representatives. The procedure implements training required by the license, 10 CFR Part 19.12, and the GE Nuclear Division procedures regarding worker health and safety, that is, NEB 0 70-04 and NEBO-70-14.
Managers are assigned responsibility to ensure licensee, contractors and visitors entering the Controlled Area are trained appropriately.
The NSE group establishes the training
- content, develops instructional materials, conducts training / retraining courses, administers exams, and provides reports of training status / restriction.
Formal training for new hires is provided monthly. The Plant Engineering and Maintenance personnel are responsible for implementing and administering the Basic and Formal Nuclear Safety training for contractors.
The Manufacturing Training and Training Development (MT&TD) group provides interim training which allows employees unescorted access into the facilities for 30 days while awaiting completion of the required formal training.
This unescorted access at the facility based on interim training can be extended to 60 days at the discretion of the NSE manager.
General Controlled Area training information is detailed in NS-203, Operational Airborne Controlled Area Training.
Lesson plans for general training and selected interim training checklists were reviewed by the inspector and discussed with cognizant licensee personnel. The inspector noted that no direct reference to the ALARA concept was made, however, indirect reference was inferred -by reference to actions necessary to reduce external dose and internal exposure to radioactive materials. Specifically, reference was made to the importance of area cleanliness, removal of visible contamination, air flow requirements, respirator and PC use, and requirements for adequate personnel surveys.
In addition, the interim training reviewed topics regarding Change Room and Controlled Area policy, PC use, personal surveys, radiation safety, masks, nuclear material hazards, signs, housekeeping, and criticality.
The majority of workers at the site are required to complete the applicable training.
However, the inspector noted that the NSE, Radiation Protection, and MT&TD personnel are not required to complete the general training In addition, Subsection and Section Managers can challenge the exam and do not have to undergo training.
4 4
11 The lack of training for all personnel or least a challenge exam to allow unescorted access to the process was considered a weakness.
.To demonstrate proficiency in the subject material presented, personnel are required to take a written examination, with a score of 75 percent' correct required to pass, and they must also demonstrc'.e proficiency in practical factors regarding PC use and personal surveys. The inspector reviewed the test material and noted that the examination adequately demonstrated employee understanding of the concepts presented.
Retraining for general employees is provided on an annual frequency and selected issues concerning site ALARA concepts are reviewed. The inspector reviewed and discussed retraining outlines developed for previous courses and determined that the review topics included issues noted during routine NSE audits and/or NRC audits, for example change room policy, respiratory protective equipment use, and process area housekeeping. ' No examination is required for retraining. The use of an annual retraining program to stress and review identified radiation protection issues which affect ALARA at the site was considered a program strength.
The inspector reviewed records of general training conducted from January 1988 to May 1989, for selected site personnel. The record review indicated general training / retraining was conducted in accordance with the established procedures. However, as a result of the repeat violations noted during this inspection, it appeared that application of the concepts discussed during training / retraining needed to be stressed.
b.
Specialized Training As a result of concerns regarding improper use/ storage of respiratory protective equipment noted during the current inspection, the l
licensee's respiratory protection training for workers within the j
i Controlled Areas was reviewed.
Guidance for the specialized respiratory training is detailed in P/P 40-22, Respiratory Protection Program, Rev. 5, dated March 23, 1988. The cognizant area managers are responsible for scheduling training and REMTRAC data entry, and the NSE section is responsible for maintaining the training status report and providing periodic training.
Training details are l
outlined in established courses, RP 201, Respirator Training for Controlled Area Workers; RP-202, Self-Contained Breathing Apparatus (SCBA); and RP-203, Supplied Air Hood.
Excluding, RP-202 training l
which is provided on an annual basis, training in these areas is provided at 36 month intervals. Licensee representatives stated that j-the longer intervals between required training sessions for the Respirator and Supplied Air Hood training relative to SCBA training resulted from the familiarity of workers with this equipment relative to the SCBA and selected review of these topics during the annual l.
training or retraining.
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L The inspector reviewed selected status. reports regarding required respiratory. protection equipment training. Concerns were identified regarding this training.
Details of the identified concerns are discussed in Paragraph 12.b.
L The inspector noted that the radiological concepts and practices presented for both the general and specialized training were adequate to inform and l'
instruct licensee personnel regarding the established ALARA concepts.
However, the failure of licensee personnel to apply the concepts presented (Paragraph 11)' minimized the positive effect of the training program on the ALARA program.
5.
Radiation Protection Staff Training-The inspector discussed Radiation Protection staff training with licensee representatives. Training guinnce is established in the applicable job descriptions for the radiation protection monitors (RMs) and the radiation protection operators (R0s).
The RMs complete eigat to nine months of initial on-the-job training (0JT) and must pass a written test (70 percent correct), and an oral board regarding radiation protection activitia within the facility. The R0s initially participate in a 90 day training period accompanying RMs performing routine radiation protection duties at the facility. No written tests are required for the R0s.
(The Radiation Protection staff for the facility has low turnover in personnel.
From discussion with the Radiation Protection Manager, the inspector determined L
that the staff personnel had not been involved in any formal radiation protection training since their initial. RM and/or OJT training.)
Retraining activities for the RP staff was reviewed. Currently, no formal program has been established to retrain RP staff in various health physics
~
activities.
Informal updates of the RP staff regarding applicable radiation protection issues are provided by the use of a reading file maintained in the RP office.
The need for increased formal retraining of the RP staff to minimize noted inconsistencies and poor practices was discussed with licensee personnel.
The inspector informed licensee representatives that during this audit a consistent bias was observed between contamination surveys performed in selected areas by various RP staff.
For example, one individual consistently reported measured contamination requiring decontamination activities, in specific areas, whereas similar contamination was ~ not observed when the surveys were conducted by other technicians Most likely, the noted bias resulted from differing or inadequate techniques used by the various RP technicians.
In addition, during this current audit, the inspectors observed facility areas and process equipment (Paragraph 13) having measurable surface activity contamination values which required decontamination.
The inspector noted that these contaminated surfaces and equipment were in areas routinely surveyed or observed by the RP staff; however, review of the technician's activity did not indicate that decontamination activities were conducted recently or scheduled as required.
i
13 4
The absence of a formal RP staff retraining program was identified as an weakness.
6.
Health Physics Staffing The inspector discussed the current RP organization staffing levels with licensee representatives.
The current RPM's staff includes two shift supervisors, one program technician, 13 RP monitors (technicians), and five RP operators.
This staffing level allows day shift coverage by six
-technicians', two operators, and one shift supervisor. Coverage on both the second and third shifts is provided by three RP monitors and one RP operator. Reduced RP coverage is provided during weekends and holidays, with one RM and one R0. The shift supervisors work 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> shifts, four days per week.
No supervisory coverage ~ is provided during a four hour period between the day and night shifts, and during the night shift of each Friday. In addition, no routine sur:rvisory coverage is provided on weekends and holidays.'
The ir.spector discussed the effectiveness of the current RP staff with the
. RPM in regards to the numerous examples of procedural violations, inadequate surveys, and lack of cleanliness observed during this-inspection. The RPM stated that following the identification of concerns involving contractor employees, an additional staff member was hired to i
develop RWPs and provide additional coverage of nonroutine activities.
For routine activities, the RPM stated that no serious problems resulted from the present RP coverage provided.
In addition, the inspector noted that overtime hours have remained constant for the RP staff.
The hiring of a RWP Coordinator for contractor activities was considered l
an ALARA program strength.
7.
Respiratory Protection Program a.
P'rocedures 1
The licensee is required by Section 3.2.4.5 of the license 1
application to have a respiratory protection program. The inspector reviewed the licensee's program to evaluate its effectiveness in maintaining personnel exposures to airborne radioactivity ALARA. The respiratory protection program is outlined at the facility by the following procedLres:
P/P 40-22, Respiratory Protection Program, Rev. 5, dated March 23, 1988.
NSI 0-1.0, Respiratory Protection - Training and Fitting, Rev. 15, dated March 8, 1989.
Process Requirements and Operator Documents (PROD) No. 80.20, Breathing Air System, Rev. 7, dated November 9, 1988.
i l
- p.
4 14 PROD.No. 81.07, Incinerator Fresh Air Breathing System, Rev. O, dated February 26, 1987.
Nuclear Safety Release / Requirements (NSR/R) No. 85.06, Face Mask Rules, Rev. 5, dated April 22, 1988.
NSR/R Control No.1.1.40, Supplied Breathing Air System, Rev.1, dated February 5, 1988.
NSR/R Control No. 4.3.16, Breathing Air System, Rev. O, dated January 6, 1987.
NSR/R Control No. 4.7.19, Breathing Air System, Rev. O, dated l
February 11, 1987.
From review of the licensee's respiratory protection program, as outlined in the procedures, the inspector determined that the program
' as established in accordance with appropriate guidance and w
regulations.
Procedures were being reviewed and approved as required.
- Hewever, on
- occasion, program implemw tation (Paragraph 7.b) did not appear consistent with the philosophy of maintaining personnel exposures ALARA.
b.
Program Implementation Through observations, discussions and interviews with licensee representatives, and review of operations, the inspector determined that personnel were wearing respirators when required in controlled areas and that there was a sufficient quantity of respirators available for use.
However, concerns were noted and discussed with cognizant licensee representatives regarding other aspects of program implementation.
After completion of tasks involving the use of respiratory protective equipment, used respirators were lef t in areas where they might become contaminated or damaged.
This practice is not consistent with the ALARA concept and a good ALARA program.
Details regarding this issue are discussed further in Paragraphs 11.d and 11.e.
Also, following the completion of tasks which required workers to use half-face respirators, the masks were being left suspended around the workers' necks by one of the straps that hold the masks in place over the face. The inspector noted that this could allow the masks to come in contact with the potentially contaminated protective clothing worn by the workers. This, in turn, could cause facial contamination and result in possible internal exposure the next time the worker used the half-face respirator.
Such actions, again, appeared inconsistent with, and have a negative impact on, the ALARA program.
Licensee representatives indicated that this practice was 'not a problem aecause the workers were instructed to place the outer surface of the mask against the surface of the protective clothing,
15 l
l thus eliminatir.g the possibility of facial contamination due to l
cross-contamination. from the mask, unless the mask flipped back over.
The inspector determined that the licensee's program for selection and fitting of respiratory protection equipment was adequate, but the i
training and medical qualifications for selected personnel were not L
always adequate and in accordance with applicable procedures.
These L
problems are detailed in Paragraph 12.
The personnel who were contracted to clean, decontaminate, inspect, and maintain the respiratory protection equipment had received sufficient training for performing their required tasks. Respi rators were being maintained and tested properly except for a retest required by procedure after thirty days if a respirator had not been used within that time period.
This is discussed further in Paragraph 11,f.
During a review of respirator use requirements, the inspector noted that respirators were required to be worn when the area radioactive airborne concentration reached the airborne Maximum Permissible Concentration (MPCa) listed in 10 CFR 20, Appendix B, Table 1, Column 1, or greater.
The inspector and licensee representatives discussed the use of a lower action guideline requiring respirator use, that is, at concentrations of 25 percent MPCa or greater.
In addition, the use of smearable contamination survey results, as another criterion requiring the use of rent ratory protective equipment, was discussed.
These actions would be consiocred an improvement to the licensee ALARA program. Licensee icpresentatives indicated that the need for changes in the current guidelines would be reviewed.
Actions regarding these issues will be tracked by the NRC as an IFI and will be reviewed during subsequent inspections (70-1113/89-05-03).
c.
Engineering Controls 10 CFR 20.103(b)(1) states that the licensee shall, as a precautionary procedure, use process or other engineering controls, to the extent practicable, to limit concentrations of radioactive materials in air to levels below those which delimit an airborne radioactivity area as defined in 10 CFR 20.203.
The inspector discussed engineering controls with licensee I
representatives who described several past and present RSC projects concerning engineering controls.
Some of these projects included:
l l
Installation of an automatic damper in the exhaust system of the l
l Rad Waste /Old Decon area.
m..
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W 16 Modification of anj existing ~ hood and increasing the exhaust in the screener. room. This resulted in :a 40 percent reduction in airborne levels and a 75 percent reduction in decon requests.
Installation of a hood over the exit end of the incinerator which reduced airborne levels by 35 percent.
Installation of improved offgas scrubbers which reduced'calciner pressurization by.85 percent.
Licensee representatives demonstrated a computerized HVAC monitoring system recently installed and currently under testing.
From a central console an operator can monitor and trend HVAC performance parameters.such as, damper positions, air
- flows, pressure
.;L'
' differentials across HEPA filters, pressures within hoods and glove boxes, and fan motor status. The system also was capable o# alerting the operator of. abnormal values observed for any of the parameters.
Licensee representatives stated that future projects 'ncluded the possible installation of a prototype containment structure around the Slab Blender to decrease the area's high airborne levels currently.
observed.
Section 3.2.2.2 of the License Application requires that air flow through openings in containment devices be measured monthly as a minimum, to assure adequate system performance necessary for protection of personnel.
It states minimum air flows for the openings.
The inspector reviewed monthly hood and exhaust flow velocity measurements for 1989 and verified that the instrument used-to perform those measurements, a thermal anemometer, had been calibrated within the past year.
Engineering controls to reduce airborne concentrations of uranium were found to a programmatic strength in the licensee's ALARA program.
8.
Radiation Work Permits a.
Procedures Section 2.2.1.4 of the L.icense Application - specifies that the Radiation Protection function is responsible for administering the RWP program at the facility.
Licensee procedures P/P 40-8, Classification and Posting of Areas, Rev. 8, dated June 9,71988 and P/P 40-9, Service Work in Controlled A-eas, Rev. 8, dated June 14, 1988, refer to the RWP program. However, the program is outlined and implemented by NSI No. 0-9.0, Radiation Work Permits, Rev. 17,. dated April 17,1989. The inspector reviewed the RWP program procedure to determine the effectiveness of incorporating ALARA considerations into the RWPs written.
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~ 17' b.
Pre-job 1 Briefings and Reviews RWP procedure, NSI No. 0-9.0, ~ requires that nonroutine construction, service, and maintenance operations which could lead to; potential external: and/or internal exposures from smearable, fixed or airborne contamination.must be centro 11ed and documented by an RWP to protect the health and safety of the personnel involved.
The inspector discussed the initiation of RWPs for nonroutine work, and the extent of pre-job coordination and review with licensee representatives.
The lice'nsee indicated.that pre-job briefings are not ' required but that informal reviews occasionally are performed.
The ' inspector -
noted that all work in the overhead areas of the. facility have special pre-job coordination and review. 'This was required as part of the licensee's corrective actions in response to an October 18, 1988, contract worker internal exposure incident.
NSI No. 0-9.0 -requires that, when an RWP is requested,-a RP monitor or shift supervisor should first get a general description of the
. work to be done and a list of.the people involved. The job location, the names of personnel (if possible) performing the work, and a brief description of the task are to be detailed on the RWP.
Protective-equipment-requirements' and other applicable safety requirements, as necessary, also are to be listed.
Licensee representatives stated that, in the past, the RWPs were written by an RP monitor based on that individual's experience and knowledge of the work area 'and conditions.
However, in response to the previously mentioned internal exposure incident, one RP monitor had been assigned complete responsibility for writing contract work RWPs, following the work performed under the RWPs, and ensuring that the RWPs are terminated and maintained on file as required after the work is completed. The RWP procedure does riot require pre-job reviews or briefings nor documentation of those pre-job reviews or briefings that may be deemed necessary in accordance with the work being performed. Also, no surveys and/or evaluations of. the work area are required by procedure as part of the pre-job review.
c.
Post-job Reviews The licensee indicated that, following completion of the job, post-job reviews involving the job planners, engineers, workers and Radiation Protection monitors covering the work are not routinely performad. However, very complex jobs or facility changes generally are reviewed by the NSE group during their preoperational audits of projects. The records of those reviews are kept by the NSE group and I.
are not readily available to the RP group.
No post-job review (to document probiums encountered, the solutions to the problems, or newly developed successful work practices) is required by the RWP procedure.
L__________-__-______
}
18 Licensee management was informed that the lack of required pre-job reviews, status briefings, and post-job ' reviews in the RWP program would be considered a weakness.
Corrective actions regarding these weaknesses will be tracked by the NRC as an IFI and will be reviewed during subsequent inspections (70-1113/89-05-04).
9.
Routine Bioassay Program 10 CFR 20.103(a)(3) requires the use of measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements to determine compliance with the requirements of 10 CFR 20.103. Additional requirements are documented in Sections 3.2.4.3.2 and 3.2.4.3.3 of the License Application for urinalysis and in vivo lung counting, respectively.
Also, the licensee conducts routine measurements of internally deposited radioactive material to verify the adequacy of the established air sampling program.
In addition to NRC and licensee monitoring requirements, the establishment of ALARA goals requires the licensee to maintain mechanisms which provide for accurate and timely detection of ingested or inhaled radioactive material. Manufacturing processes utilized at this facility involve both soluble and insoluble uranium compounds.
Urinalysis is used to detect uptake of soluble compounds, while in vivo analysis, specifically lung burden analysis, is utilized by the licensee to detect intake of insoluble uranium compounds. The use of the bioassay programs to meet established ALARA goals was reviewed.
a.
Urinalysis Analytical detection capabilities of the urinalysis program were reviewed by the inspector. The licensee performs urinalysis onsite with Chemet laboratory personnel using uranium phosphorescence analysis (laser induced fluorescence) methodology.
The minimum detection limit (MDL) for the process is approximately 5 micrograms of uranium per liter (ug/1) of urine.
Applicable sections of the License Application require weekly or daily routine urine sampling frequencies to be established for all individuals assigned to work in areas where soluble uranium compounds are processed.
The assigned sampling frequency is a function of chemical solubility.
Implementation of the requirements is controlled by P/P 40-19, Bioassay Program, Rev. 7, dated August 15, 1989, and NSI 0-2.0 Bioassay - Urinalysis Program, Rev.16, dated September 11, 1988.
The inspector reviewed and discussed the applicable procedures, including specifics on selected process areas and their required sampling frequency. The frequency of sampling was found to be commensurate with the solublity of the most probable compound the worker would potentially be exposed to during routine activities.
The weekly / daily sampling frequencies, prompt analysis capability, and MDL of the urine analysis were found to be ALARA, based on WASH-1251 guidance.
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4 3 9 _-
Urinalysis program. implementation was reviewed by the. inspector. The review included examination of-the - urine sample processing from initial collection, analytical. analysis, through-final ' data reporting. The sample collection area in the changeroom'was: orderly,_
clean, and well stocked with. specimen containers and markers.
Instructions; and work - area codes were posted.
Workers' were knowledgeable of areas _ requiring daily or weekly - submittal. of urine samples' as _well as incidents requiring a nonroutine sample.
Discussions with the ' Chemet laboratory _ technician performing the-analyses' indicated adequate sample logging. and tracking technique during the anaylsis process to minimize. sample and' anaylsis result mismatching.
Data obtained from phosphorescence and the associated sample identification numbers are input. manually into a computer.for-calculation of the uranium concentration in the urine. Subsequently, results are _ transferred electronically ' to various data bases, matched. to the appropriate personnel - records, and compared to applicable action guidelines. or limits.
. Control s '. for the laboratory analysis of the urine samples were documented in
- Chemical,
_ Metallurgical, and Spectroscopy Manual 1.2.21.10, Measurement of Trace Uranium in Urine Using the
.Scintrex UA-3 Analyzer, Rev.
2, dated August 30, 1988.
This-procedure contained instructions for instrument calibration, standardization, and normalization.
Additional requirements addressed quality control / quality assurance' (QC/QA) through' the use of blind (double blind) samples once per shift and the use of known standards before and after each sample lot (usually.15 samples).
Comparison of individual urinalysis results with applicable action guidelines or limits ' ere performed automatically using the licensee w
computer based exposure data analysis, management system, REMTRAC.
REMTRAC programs ensured that individuals with job functional areas (JFAs) requiring routine urine samples had a sample result documented for the day or the week, as applicable.
All urinalysis results exceeding 15 ug/l or 35 ug/l as applicable, are evaluated by a REMTRAC subroutine using additional data, including solubility of material most likely inhaled, JFA assigned for that day / week, and best estimate of the time interval between intake and sample submission.
The subroutine estimates uptake in milligrams (mg) uranium which 'is compared to a licensee established restricti.on action level of 2.5 mg, corresponding to about 15 ug/l in urine after one week following a single Class D uptake. This value is slightly less than the 2.7 mg U nephrotoxin blood level (WASH-1251) for soluble low-enriched uranium compounds and is significantly below the 10_ CFR 20, Appendix B, Note 4 limit of 9.6 mg U intake per 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> week, based on a permissible 0.2 mg/m3 airborne concentration and a breathing rate of 20 liters per minute. Assuming 43 percent of an acute 9.6 mg intake is absorbed into the blood, the nephrotoxin level could be exceeded fc. a few hours per week, however, irreversible damage is unlikely, due to the rapid excretion of soluble uranium.
If the 2.5 mg action level is not exceeded then the urinalysis result
20 is compared against urine concentration actlon guidelines of 15 ug/l or 35 ug/l depending on the solubility of the inhaled compound.
The 15 ug/l guide is used for uranyl nitrate and related compounds and the 35 ug/1 1s for UF6 and related compounds. The 15 ug/l for 2.5 percent enrichment corresponds to an initial uptake, one day earlier of 0.13 mg U which corresponds to 0.25 MPC-hrs. The 35 ug/l corresponds to the initial uptake one day.earler of 0.88 mg U, which corresponds to 1.7 MPC-hrs.
For June 1988 - May 1989, 22. workers exceeded 15 ug/l and 25 workers exceeded 35 ug/1, excluding resample cases.
Persons having values exceeding the appropriate guides are automatically required to provide a resample through a REMTRAC request.
REMTRAC automatically prints a resample request for the following day.
If a resample is required the individuals are notified by postings on an information board at the entrance to the change' room and a resample request is trasmitted to the individual's supervisor.
The licensee's urinalysis program was structured such that identification of specified elevated samples was assured, and the levels at which samples are defined as requiring restriction appeared to be appropriate to demonstrate a commitment to the ALARA philosophy.
The licensee's urinalysis thresholds for worker restriction are considered to be ALARA at 0.25 MPC-hrs (15 ug/1) and 1.7 MPC-hrs (35 ug/1) for soluble and less soluble uranium areas, provided daily sampling is specified. A weekly sampling, revealing 15 ug/1, could be indicative of a single uptake of 2.5 mg U, seven days earlier, which is close to the nephrotoxin level of 2.7 mg U in blood, but considerably less than the 10 CFR 20, Appendix B, Note 4, permitted weekly average limit of 9.6 mg U soluble intake for enrichments less than five percent.
Therefore, weekly sampling for workers who perform modifications or installations in or around soluble process areas is probably ALARA.
b.
In Vivo Measurements The licensee currently conducts in vivo analyses onsite utilizing a shielded bed lung counter with four, five (5) inch diameter phoswich detectors. This geometry configuration provides a MDL analysis value of approximately 50 ug U-235.
The lung counter is operated and maintained by a contract vendor.
Section 3.2.4.3.3 of the ~ License Application details analysis frequencies based upon individual airborne exposure assignments and previous counting results.
The minimum frequency, an annual lung burden analysis is specified for workers in areas that process non-transportable (insoluble) uranium compounds and who are assigned airborne exposures greater than i-1.3 MPC-hrs or less.
Administrative controls for analysis frequencies, reanalyses, and work restrictions are documented in P/P 40-18, Regulatory Compliance Administrative Action Guidelines, Rev. 8, dated March 9,1989, and P/P 40-19, Bioassay, Rev. 7, dated September 15, 1989.
Licensee representatives stated that for i
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+
21 individuals with lung burdens measured and verfied to exceed 250 ug are placed on temporary: restriction, i.e. prevented from working in areas. containing airborne radioactive material.
Methods to ensure that an individual.does. not enter-pctential contamination ' areas included informing the individual. of his' status-at the time of his lung. count, placing the individual's.name on an;information board'at the entrance 'to the changeroom, and. notifying the individual's supervisor; Licensee representatives stated that in the future, the automated Personnel Accountability and Controli (PAC). access system will also'be used to physically prevent an. individual on restriction-from passing through the. changeroom turnstile.
For.1988, nine' a'
workers once exceeded. 250. ug U-235 for 'a ' few days, or else twice exceeded 200 ug U-235 for a few days. For 1985-1987, the percentage of in vivo counts above the MDL trended slightly downward but the.
number of. workers on-restriction followed 'a somewhat bimodal distribution over time.
The inspector reviewed and discussed with licensee representatives the QC/QA program for in vivo' analyses ' including comparison methods, such as comparing analyses with results from other facility's' lung counters and using spiked phantoms.
Licensee representatives. stated.
that in - 1984 the facility participated in a - national _ study using a humanoid phantom of unknown activity.. The -licensee's ' counting.
equipment was found 'to have activity' results higher, (more conservative), than otherwise reported. for: the_ true activity of the spiked. phantom.
Also, in 1988 fourteen individuals with positive lung burdens from another facility were anal; ed by the licensee.
These individuals also were counted 'at two oth r facilities. Results from all facilities were transmitted to the censee but were not available for review by the inspector.at the time of the inspection.
Licensee representatives stated that differences between the results for this facility and the other facilities count results were minimal.
To ensure continued quality assurance and support services from the contractor responsible for in vivo analysis, the licensee performs
. annual reviews at the vendor's corporate office as detailed in NSI A-3.0, Vendor Review and Approval, Rev. 5, dated September 22, 1989. The inspector reviewed trip reports documenting the vendor reviews performed in 1986, 1987, and 1988. Licensee representatives l
stated that vendor management personnel also performed internal audits of onsite lung counting activities twice a year-and that these onsite visits were used to update the lung counting equipment and/or operator technique.
10.
Stationary Air Sampling Program a.
Program Elements and Implementation License Application Section 3.2.4.2.1, Routine Air Sampling in the Controlled Area, states that air samples are continuously taken from
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. each process area where licensed material is being handled ~in
.dispersible form in order to assess the concentrations' of: uranium in air.
' ~
The licensee's. ability to accurately determine the concentration of
' airborne. material!present in the work area and the existence of a -
program to: ensure'that this determination results in minimizing acute.
and chronic uptakes is indicative of a program operating. under the ALARA concept.
The inspector discussed with licensee representatives, the structure and implementation of the stationary air sampling program ' which provides for accurate and timely detection of airborne contamination.
The program utilizes approximately 300 to 320 SASS which are changed and analyzed once per : shift.
The particulate filter samples are collected at the beginning of each shift.
Utilizing two automated (Tennelec alpha ' proportional) counters, analysis of the samples is usually completed by midshift.
Timeliness of detection of elevated airborne uranium concentrations was evaluated.
The MDA for the counter was typically 4 E-13 uCi/ml.
To accomplish timely detection,=the automated counters produced "high sample reports" listing all samples greater than 100 percent of the 10 CFR Part 20, Appendix B, airborne MPCa for uranium.. Subsequently, RP technicians are assioned to investigate the areas where the elevated samples results were indicated during the previous shift.
Licensee representatives also stated that timely detection of elevated samples is added by the technician's observation of filter paper color during sample changeouts.
Discolored samples are analyzed expeditiously. An additional ~ level of review for possible identification of elevateo airborne levels was the distribution, to area supervisors, of air sample results from the previous day - for samplers located.in their area (s) of responsibility.
Based on the supervisor's familiarity with airborne concentrations routinely observed in his. area, samole results which are unexpectedly elevated but do not exceed the-100 percent MPCa investigative level also may-be identified for further investigation. To ensure that upper level managers are cogr.izent of the airborne conditions in their areas, weekly reports conveying unscheduled and scheduled perturbations of airborne uranium concer.tration levels are distributed.
This; report includes probable cause for the perturbations, if knownT' The j.
inspector also observed that some informal air sample data. review was H
being performed by members of the NSE staff.
The fixed air sample program for the timely detection and evaluation of airborne uranium concentrations are considered an ALARA program strength.
To demonstrate compliance with 10 CFR 20.103 internal exposure limits, the licensee assigns MPCa-hour exposures based on air sample results and time-in-area data, rather than bioassay data.
The inspector reviewed the program aspects which assigned and controlled MPCa-hr exposures.
P/P 40-18, Regulatory Compliance Administrative 7 -
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23-Action' Guidelines, -Rev.
8, dated March 9,
1989,- defines administrative levels requiring " prompt" action for -individuals with exposures - greater than' 30 MPCa-hrs per week and 450 MPCa-hrs per -
quarter. Through discussions with. licensee personnel, the inspector determined that MPCa-hr calculation and assignment was performed by.
REMTRAC based on time-in-area data, logged by. the individual's ' floor supervisor and manually input into REMTRAC, and' air sample results electronically input.into REMTRAC from the automated sample counters.
The inspector noted that respirator use of'15 minutes or :less was
~
often -not noted on Time-in-Area logs..The failure to take credit for respirator protection factors adds conservatism to the' exposure data.
The licensee's. program to assign MPC-br exposures 1 for low-enriched-uranium was adequate _ to meet established ALARA commitments. provided
.the samples are representative of the airborne activity breathed by.
the worker, as discussed below.
Accuracy of.the licensee'5AS analytical measurements was reviewed.
The calculation methodology used to determine the MPCa from activity detected on. the SAS ~ filter paper was verified.
Values used for counter efficiency, alpha absorption, filter collection efficiency, and air volume conversions appeared appropriate.
l Section-3.2.4.2.1 of the License Application requires that L
rotameters, which indicate flow rate of air sampled,'be. calibrated or l
. replaced at least every 18 months.
Licensee representatives.. stated that in the past all SAS flowmeters were replaced every 18 months
~
with the old flowmeters discarded. However, approximately two years ago a certified flow standard was purchased and used to calibrate the SAS flowmeters.
SAS flowmeters found to be ' outside 10 percent of -
the standard are replaced.
The. inspector verified vendor certification of the flow standard device and reviewed the SAS flowmeter calibration documentation' for 1988.'
b.
Demonstration of Air Sample Representativeness Section 3.2.4.2.1 of the License Application requires that the radiation safety function annually evaluate the fixed sampling points for representativeness of personnel exposures. The licensee's SAS program is the primary method used to evaluate and assign personnel exposures to airborne radioactive material under 10 CFR 20.103.
l Therefore,.it is necessary to demonstrate that the air being sampled is representative of the air being breathed by the worker, rather than lower or higher concentrations from elsewhere.
1 During the inspaction, the representativeness of the SASS relative to
')
.the air breathed by workers was reviewed. For some selected tasks,
]
the use of general area SASS did not appear to be a representative
]
breathing zone sample.
For example, during a tour of selected process' areas on May 23, 1989, the inspector observed a worker, who was provided with a respirator, breach a containment structure, I,
specifically the filter " bag house" in the Slab Blender area.
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24 i
. Licensee representatives stated that this was a routine activity
- during the blending operation. Approximate 1y'three SASS were in the area, however, none were in. close proximity to the bag house..The L
inspector inquired as - to the methods used to verify air sample 1
representativeness other than visual observation of-the alignment of
- worker position, SAS location, and the closest, most probable source of airborne contamination.. The licensee stated that two additional
- supporting methods are used and performed annually.. A statistical comparison _between the in vivo measured lung burdens-relative to empirically derived lung burdens from, assigned airborne? resultsis
- performed.
In addition, air flow studies are performed in each work--
~
area.
The - inspector-reviewed and discussed with licensee
. representatives both verification methods.
'~
The annual statistical study of measured in vivo results, compared to the derived lung burdens, 'uses a subset _of the workers authorized access _to the Radiation Control area. For the-1987 comparison, data from approximately 60 individuals were used. -The derived uranium lung content v'alue is calculated using a model which -predicts lung burden. based on history of assigned airborne exposure.
Data from these individuals, derived versus measured values, are graphed. A reference line with a slope of one is drawn on the graph and statistical analyses are performed to evaluate the distribution of data points relative to the reference line. The analyses _ demonstrate that the majority of data points are located above the reference line, thus, indicating greater derived lung content values than are actually measured by lung burden analyses. Licensee representatives stated that since most measured lung burdens for the 60 individuals were less than the derived lung contact values, then the air samples are representative. The following weaknesses in this analysis were identified by the inspector and discussed with licensee representatives.
The same group of individuals are included in the study each year.
Thus, not all SASS are reviewed for representativeness.
This study only applies to insoluble uranium compounds.
Both soluble and insoluble compounds are monitored by the SAS program.
The inferred conservatism of the results does not implh that SASS are representative.
The degree of bias - needs"to be accurately known to demonstrate representativeness.
Licensee biases resulting in conservative
- results, specifically, over-estimating assigned MPCa-brs, included overestimating time-in-area data and not assigning protection factors for use of respirators for select instances, that is, use of a respirator less than 15 minutes.
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.s 25 The degree of in vivo measurement accuracy is uncertain and thus is not included in the evaluation.
The compounding of statistical errors associated with instrumentation; the use of an average value based on multiple lung burden analyses for some individuals and single data points for other workers; and errors associated with time-weighted averages based on when the analyses were conducted within the calendar year. are not considered in the study.
Variables used in the model to estimate the time dependent uranium lung burdens, based on the concentration of uranium in the air breathed, are not documented in NRC accepted models.
In addition, comparison study details, such as sample calculations, assumptions used, data used, or supporting scientific or industry studies, were not documented.
This lack of documentation did not facilitate management control, consistency in calculation results, adequate data quality control, or auditablity.
Because of the above weaknesses the inspector stated to licensee representatives that the comparison study of measured and derived lung burdens was, by itself, not persuasive to demonstrate representativeness of the entire SAS program.
In addition to the comparison study, licensee representatives stated that air flow studies are performed in each work area annually. The inspector reviewed guidance on air flow studies, including criteria used for locating samplers, guidance on how to perform and assess the air flow study, including location of smoke tubes relative to SAS and worker location, listing of work areas to be studied; and the number of smoke tubes to be used in each area.
Licensee repres9ntatives stated that no detailed documentation or ' formal administrative controls existed for the annual air flow studies. This was considered to be a weakness.
In 1985, the licensee performed detailed air flow studies using smoke bombs.
In this study direct observation of the direction and magnitude of air flow throughout entire work areas was reviewed. The inspector reviewed the documentation of this study, " Air Sampler Representativeness Study," dated July 31, 1985, and noted that the study could not be evaluated since it did not indicate SAS locations, worker positions, and suggested SAS relocations on diagrams indicating the observed air flows.
After 1985, the air flow studies consisted of localized observation of air flow using hand held smoke tubes similiar to those used for qualitative respirator fit testing.
The inspector reviewed documentation regarding the annual Air Sampler Representativeness Study dated August 1, 1986, July 31, 1987, and August 8, 1988. These I
documents, that is, Memorandums, lacked detail concerning the air i
flow tests. These Memorandum simply noted completion of the studies i
26 and made' general conclusions, for example, " samplers were suitably located" or "several recommendations for SAS placement were made and will be pursued in-a seperate memo." The inspector informed licensee personnel that to verify the adequacy of the air flow studies, additional information was needed, including specific work areas reviewed, individuals performing the smoke tube tests, and specific SASS indentified for relocation. The inspector also determined that no supplemental documentation existed verifing which areas had been reviewed during the 1986, 1987, or 1988 studies.
Licensee representatives. stated that for the 1989 air flow studies, individuals performing the smoke tube tests were noting and initialling completion of the tests on specific area audit sheets used to support Regulatory Compliance Audits. The inspector reviewed the applicable procedure, P/P 40-06, Regulatory Compliance Audits, Rev. 11, dated November 17, 1988, and noted no guidance concerning air flow studies using smoke tubes.
A review of the 1989 audit sheets identified several completed audit sheets that did not document the smoke tube studies which had been performed. Licensee representatives stated that the studies had been completed but that the auditor failed to note it on the audit sheet.
In addition, the inspector was concerned that the small volume of airborne particulate material produced by smoke tubes was not l
sufficient to assess adequately, the general area air flows, especially following facility or equipment changes.
The licensee stated that smoke bomb tests would usually be performed subsequent to l
those facility / equipment modifications having the potential to significantly change air flows.
Licensee representatives provided documentation for air flow studies, using smoke bombs, which were completed on June 22, 1987, following modifications in the Uramium Recovery Unit (URU) area, Dissolution room, and FMOX Blender Warehouse.
As in previous studies, the diagrams indicating the observed air flow did not irclude SAS or worker location.
Furthermore, the inspector selectively reviewed the following specific FCRs which potentially could have affected air flows within the applicable facility area.
l l
FCR #87.081, Install 8" diameter flexible exhe.ust line on
~
blender opening.
FCR #87.236, Install a clear strip plastic curtain around line I hydrolysis.
FCR #87.144, Replace " bird" centrifuge in UPMP radwaste with a Sharples P660 Super-D-Canter centrifuge.
FCR #87.130, Construct 3' X
3' window in wall of Swiss Electronics Crib. Wall separated controlled and uncontrolled areas.
27 For these facility or process modifications potentially affecting air.
flows, no smoke tube or smoke bomb air flow studies were documented.
Licensee _ representatives stated that smoke tube air. flow' studies are sometimes performed after modifications and not documented.
In addition, for FCR #87.130, which required verification of air flow from a uncontrolled to controlled area following installation of a window, only air flow studies between the controlled and uncontrolled areas was perforned.
The inspector informed the licensee that the weaknesses in the air
' flow studies minimized their use in demonstrating air. sample representativeness.
The inspector also informed the licensee that even if these weaknesses are corrected, use of air flow studies alone may not be adequate for demonstrating air sample representativeness particularly where operations may produce local high airborne concentrations.
Failure to perform adequate evaluations of stationary ~ air sample representativeness annually and after facility / equipment changes was identified as a violation of License Condition 9,(70-1113/89-05-05).
II.
Facility Tours During the inspection periods May 22 - 26 and June 12 - 15, 1989, the inspector selectively toured licensee facilities and areas, observed facility operaticns and work being performed, and interviewed workers to evaluate the degree of integration of ALARA concepts into the licensee's radiation protection program. The following concerns regarding radiation protection conditions and practices were noted and/or discussed with licensee representatives.
a.
Improper Protective Clothing (PC) Use i
License Condition 9 of Special Nuclear Material (SNM) License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part 1 of the License Application dated October 23, 1987.
{
Part 1, Section 2.2.1.4 of the licensee's Application for License No.
SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.
Nuclear Safety Release / Requirement (NSR/R) No. 85.05 Protective Clothing Rules, Rev. 4, dated August 13, 1987, requires that head coverings be worn by observing and working personnel and that the head coverings cover all hair possible.
Posted instructions at the entrance to the controlled area stipulates that working personnel and observing personnel wear a cap covering all hair.
i
28 During tours of the facility on May 23, 24, and 25, 1989, the inspector observed -licensee personnel wearing PCs in the Controlled Area.. It was noted that in certain work areas, such as the maintenance shop, the pellet press area, and the milling area, workers were not always wearing rubber gloves. When asked about this practice, the licensee indicated that ' workers are allowed to enter the Controlled Area without wearing gloves.
However, they are required to wear gloves to operate any equipment or handle any material. Personnel are encouraged not to wear gloves when filling out paperwork documenting results of their work and when entering i
data irto.the computer system using the keyboards in various areas.
Also, the licensee indicated that numerous surveys have been performed in the past and the areas continue to be surveyed routinely. These surveys have seldom indicated surface contamination problems in these areas. Also, the workers are instructed-to wipe areas where they fill out their paperwork and wipe the computer keyboards frequently in order to maintain the areas free of contamination. With these precautions in place, and because people perform a personal contamination survey prior to exiting the Controlled Area, the licensee indicated that the practice was permitted and that no personnel contamination problems had been noted.
During facility tours, the inspector also noted that of approximately 100 workers observed, ; approximately 10 were wearing their caps in such a manner as not to cover all the hair possible. Some workers had deliberately rolled up the lower portion of the cap up in order to remain cooler. This practice was. noted most frequently in the sintering furnace area where general area temperatures were elevated.
Other workers apparently had placed the cap on their heaa incorrectly when dressing out in their PCs.
During tours of the facility on June 13 and 14,1989, the inspector again noted persons not wearing their protective clothing caps in the prescribed manner. Of approximately 100 workers observed, nine were wearing their caps such that not all the hair was covered. Again, it was noted that some workers had apparently rolled up the back portion of the caps due to the elevated temperatures in the areas.
Failure to follow procedures for wearing the required PCs to cover all hair possible was identified as an example of an appiarent l
violation of License Condition 9 (70-1113/89-05-06).
~~
l b.
Failure to Use PCs NSR/R 85.04, General Controlled Area Rules, Rev. 7, dated April 26, 1988, requires that only authorized personnel wearing appropriate PC/ equipment are permitted within a marked off contaminated area.
6,..
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NSR/R 85.05, Protective Clothing Rules, Rev. 4, dated August 12, i
l 1987, also requires that protective clothing be worn by all personnel entering Controlled Areas.
During tours of areas outside the FM0/FM0X Building on June 14, 1989, the inspector noted two large tanks, designated V103 and V106, located to the west of the building. As the inspector approached the tanks, a licensee employee was. observed preparing to enter an area beneath the V106 tank. After removing a rope / chain barrier hanging across the entry way to the area beneath the tank and laying it on the ground, the worker entered the area. After a short period, the employee exited the' area beneath the tank, replaced the rope / chain-l barrier and left the general arce.Upon closer investigation of the area beneath the tanks, the inspector noted that the area was roped off and posted as a controlled surface contamination area (CSCA).
The area beneath the V103 tank was posted as requiring an RWP for entry while the area beneath the V106 tank, which was almost completely enclosed by metal support structure, was only posted as a CSCA.
The inspector observed that the individual who had entered the area beneath V106 had not used any PCs to enter the posted CSCA.
It was also noted that the person had not performed a personal. contamination survey (frisk) upon exiting the CSCA nor was a survey meter present to use after exiting the area.
When the inspector informed licensee representatives of the actions of this individual, the manager of the affected area was called and personnel interviewed to ascertain who had entered the area.
The person was found and his clothing surveyed by RP monitors.
The individual's shoes were found to be contaminated, but he indicated that he did not believe that entering the area beneath the tank had caused this problem.
The area beneath the tank was surveyed and no contamination above 220 dpm/100 cm2 was found except under a sample pan on the northeast side of the enclosed area. The person's shoes were decontaminated and rcicased.
Failure to wear PC in a Controlled Area was identified as another example of an apparent violation of License Condition 9 (70-1113/89-05-06).
c.
Posting, Labeling, and Decontamination NSR/R No. 85.04, General Controlled Area Rules, Rev.
7, dated April 26,1988, requires the use of one or more of the following to alert personnel to conditions causing a high airborne contamination area: (1) yellow and magenta rope or tape and yellow and magenta signs displaying various warnings or protection requirements (example:
full face mask required), and/or (2) a flashing yellow light.
30 1
NSI No. 0-6.0, Contamination Measurement and Control, Rev.19, dated I
June 7,1988. requires in Appendix C that Controlled Area equipment with. smearable contamination levels exceeding 25,000 dpm/100 cm2 alpha be cleaned immediately.
During tours of the powder and pellet production areas on May 25, 1989, the inspector observed production and maintenance activities.
I One operation, a vacuum filter change and an enrichment cleanout which required workers to use respirators, was noted in the Slab Blender area.
The area requiring respiratory protection had been barriered-off using a yellow and magenta rope, but no warning signs were posted to display the hazards or protection requirements necessary for work in the area.
Upon completion of the work, the l
barrier rope was taken down, the workers removed their respirators, and production. work continued.
Discussion of this practice with licensee representatives indicated that workers are instructed not to cross a Radietion Safety barrier (the yellow and magenta rope / tape barrier) unless aware of the hazards and necessary precautions.
During tours of the powder production area during the morning and afternoon of May 25, 1989, the inspector observed maintenance activities on the No. 3 Slugger.
The slugger had been partially disassembled during the previous day and a barrier rope had been posted around the work area. No work in progress was observed at the time of the tour, but parts of the slugger were noted lying on various carts in another area.
The area containing the parts was across from Slugger No. 3, between the No. 3 and No. 4 Calciners, and had been partially barriered-off with yellow and magenta tape. Some of the parts were wrapped in plastic while other parts were unwrapped.
Visible contamination was noted on some of the unwrapped slugger parts.
Subsequent surveys of the unwrapped parts indicated maximum direct reading alpha contamination levels of 42,000 dpm per 2
probe area and smearable contamination levels of 60,000 dpm/100 cm alpha.
The inspector noted that, due to the contamina. tion levels, the area was required to be barriered-off and posted on all accessible sides.
The area was barriered on one accessible side with yellow and magenta rope and posted with signs indicating an airborne radioactivity area and full face respirators required for entry. However, the yellow and magenta barrier rope on the other accessible side of the~ area was i
noted lying on the floor with the warning signs not readily' visible.
The inspector also noted that, due to the number of carts in the area, even if the rope had been up and in place, it would not have I
l been of sufficient length to encompass the entire area occupied by the carts and slugger parts.
Failure to follow procedures to adequately barrier and post areas and to immediately clean the Slugger No. 3 parts was identified as an example of an apparent violation of License Condition 9 (70-1113/E9-05-06).
L____________._____
e.
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1 d.
Resp'irator Use and Storage P/P No. 40-22, Respiratory protection Program, Rev.
5, dated March-23, 1988, Appendix B, Step A.2 requires that individuals return respirators to designated storage areas or controlled area laundry when immediate use/need is fulfilled.
NSI No. 0-1.0, Respirator Protection - Training and Fitting, Rev.15, dated March 8,1989, Appendix B, Stcp A.2 requires that individuals return respirators to designated storage areas when immediate I
use/need is fulfilled.
NSR/R No. 85.06, Face Mask Rules, Rev. 5, dated April 20, 1988, requires that respirators not be left on equipment and/or tool boxes when no longer needed.
During tours of the facility on May 23, 1989, the inspector observed the use of respiratory equipment. Individuals requiring respirators obtain them from cabinets loccted at designated locations throughout l
the facility.
The respirators are placed in these cabinets after being cleaned, decontaminated, inspected, and tested. To ensure that individuals acquire a clean respirator af ter being decontaminated and cleaned, the respirators are placed in plastic bags for storage.
Workers can ensure that the canister on the respirator is still in usable condition (canisters typically have a one year service life following initial installation) by noting the date when the canister is placed in service which is etched on the bottom of each canister.
However, respirators at the facility do not have individually numbered identification tags attached and no record is kept of which respirator an individual uses or when it is returned. A respirator may be used more than once during a shif t if, after each use, it is stored in a plastic bag to maintain it in a clean state inside and l
out and if it is stored properiy during periods when not in use.
" Mask tree" storage areas and metal / plexiglas storage cabinets have been provided where workers may store used, clean respirators during the shift.
Unused, clean respirators also are stored in these locations for future use.
During tours of the Gadolinia (Gad) Area, the powder production area, and the URU area on May 23, 1989, the inspector noted improperly stored respirators.
In the Gad area, an unwrapped respirator was noted at a work station.
In the Slab Blender area, an unwrapped respirator was noted lying on top of a can.
In the URU area, two respirators, a full face and a half mask, wrapped in plastic were found inside a fire hose station cabinet.
During tours of the facility on May 25, 1989, more examples were noted of improper l
storage of respirators. An unwrapped respirator had been placed on a work stand across from the control panel in the Slab Blender area.
One respirator, wrapped in plastic, was noted lying on the partially disassembled Slugger No. 3 inside a posted airborne area during morning and afternoon tours of the powder production area.
o.
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4 4
32 During tours of facility on June 12-15, 1989, additional examples of improper respirator storage were noted. On June 13, the inspector found an unwrapped respirator in a cardboard box underneath cleaning rags and other cardboard pieces..The box was located behind Hammermill No. 3.
An unwrapped respirator was noted on top of the electrical control panel in front of Hammermill No. 3.
Several i
minutes later the inspector noted that a won,er returned to the area and donned this respirator and continued work in an airborne area that had been established around Hammermill No.
3.
One unwrapped half-mask respirator was found in the drawer of a work station desk in the'B&W Blender area. A respirator wrapped in plastic was noted lying on the back side of Slugger No. I with oil dripping on the bag.
Another respirator, wrapped in plastic, was found inside the drawer of a work station desk behind Slugger No.
5.
On June 14, an unwrapped respirator was noted on a can in the Slab Blender area and another unwrapped respirator was noted on a work station beside Hammermill No. 3.
Failure to follow procedures to properly store respirators when no longer needed or in use was identified c aa example of an apparent vir?stion of License Condition 9 (70-1113/89-05-06).
e.
Respirators Left in the Controlled Area p/P No. 40-22, Respiratory Protection Program, Rev.
5, dated March 23,'1988, Appendix B, Step C 5, requires that used respirators are not to be left in the controlled area from one shift to another but should be placed in the " dirty mask" receptacles or returned to the laundry.
Training and Fitting, NSI No.
0-1.0, Respiratory Protection Rev.15, dated March 8,1989, Appendix B, Step C.5, requires that used respirators not be hung or laid on equipment at any time, nor left in the Controlled Area from one shift to another.
During tours of the facility on May 23-25 and June 13-14, 1989, various examples of respi ators left in the controlled area from one shift to another were noted.
Unwrapped respirators, left between shif ts (on top of cans), were noted in the Slab Blender area on May 23 and June 14.
Several instances involving unwrapped respirators that were discovered in drawers or in a box and numerous
)
unwrapped respirators noted stored in the metal / plexiglas' ' storage locations throughout the facility also indicated that wearers were failing to deposit the respirators in the " dirty mask" receptacles at the end of a shift as required by procedure. In discussions with the licensee, the inspector stated that this poor practice increases the potential for inadvertent intake of radioactive material and/or facial contamination and negatively impacts the ALARA program'.
1
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33 Failure to follow proceduies for removal of used respirators from the controlled area at the end of each shift was identified as an example of an apparent violation of License Condition 9 (70-1113/89-05-05),
f.
Respirator Inspection NSR/R Control No.
4.1.16, Respiratory Testing, Rev.
O, dated January 21, 1982, associated with PROD No. 80.84, Respi ratory Testing, Rev. 7, dated April 10, 1989, requires that full face masks not used after 30 days be returned to the laundry for reinspection.
During tours of the facility on June 14, a storage cabinet for enused respirators., located in the URV controlled area, was inspected. When cleaned respirators are placed in the cabinet by contract workers, the current date is written in grease pencil on a plexiglas. sheet attached to the inside surface of the cabinet door. The insp?ctor noted that the date written on the plexiglass sheet indicated that the respirators had been placed in the cabinet on April 24, 1939.
The inspector also noted that the respirators inside the cabinet were wrapped in plastic and none had a date of initial use etched on the canister.later than April 24, 1989.
Failure to follow procedures for inspecting unused respirators after
' 30 days as required was identified as an example of an apparent violation of License Condition 9 (70-1113/89-05-06).
During tours of the facility on May 23-25, as well as on June 13-14, 1989, the inspector noted that there were unused respirators " stored" in various ' cations throughout the facility. Respirators were being
" stored" o n " mask trees," in the metal / plexiglas storage lockers provided, in work station desk drawers, in fire hose cabinets, and on equipment.
Through discussions with licensee representatives the inspector determined that it could not be ascertained how long these respirators had been stored in these locations and thus, no control or accountability existed over the respirators in these scattered locations. The licensee agreed that improvements in this area were needed. This was noted as a program weakness and will be followed as a
an NRC IFI.
Corrective actions to this problem will be inspected i
during subsequent inspections (70-1113/89-05-07).
g.
Personnel Contamination Surveys NSR/R No. 85.08, Personal Survey Upon Leaving Controlled Area, Rev. 7, dated December 8, 1986, requires that surveys be conducted by placing the scanner probe on an area to be surveyed, holding the probe in place for 1-2 seconds, and monitoring the hands, wrists, l
chest, TLD badge, neck, face, hair, ankles, and shoes at a minimum.
During tours of the facility on May 23, 1989, the inspector observed a total of two workers exiting the Controlled Area from the powder /pollet production area and one individual from the URU area.
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Both workers exiting from the powder / pellet production area, as well as the person exiting from the URU area, performed - a personal contaraination survey by moving the probe rapidly over the hands, head, ankles, and feet. None of the workers, held the probe in place for 1-2 seconds nor were their chests or TLD badges surveyed, i_
Fe'.u<'ng tours of the facility on May 25, 1989, the inspector again ob..eri ed workers exiting the Controlled Area from the powder / pellet p'ed,m tion area.
Of 22 individuals noted exiting the Controlled Arua, six performed inadequate personal contamination surveys.
The same problems were identified as noted on May 23, 1989, with the six individuals.
The workers either moved the probe to'o rapidly and/or did not survey all required areas.
i As'noted in Paragraph 11.b above, on June 14, the inspector observed an individual leaving a controlled surface contamination area under the V106 tank.
The worker had not worn PC while in the area and, after exiting the Controlled Area, did not perform a personal contamination survey.
Failure to follow procedures to perform adequate personal contamination surveys after exiting Controlled Areas was identified as an example of an apparent violation of License Condition 9 (70-1113/89-05-06).
h.
Empty Can Storage at the Facility NSR/R Control No. 1.1.26, Empty Can Storage - FMO, Rev. 2, dated June 3, 1987, associated with PROD No. 10.53, Empty can Drop Chute, Rev.1, dated May 2,1989, Steps 1 and 2 requires that an empty can must have a lid and lock ring in place and that an empty can must be free of visible contamination.
During tours of the facility on June 13, 1989, the inspector noted that numerous cans are used throughout the facility.
The cans containing powder are processed and transferred between areas by means of elevators, drop chutes, and conveyor / roller tracks.
Cans containing powder are also required to have lids affixed to the top and a lock ring attached.
While touring the B&W Blender area, the inspector noted vari 6us empty cans along one wall that were stacked and stored inside one'another.
Four separate locations within the B&W Blender area were noted where a can or several cans were stored without the required lid and/or lock ring in place. One can contained a small amount of powder in the bottom.
Upon further investigation, the inspector noted cans without. lids and/or lock rings in other facility locations. A can with no lock ring was noted behind Slugger No.
5.
Approximately 10 cans were being stored in the Radwaste hallway leading to the old
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l decontamination area without lock rings securing the lids in place.
One empty can without a lid or lock ring in place was noted in the Stacker Warehouse area. On June 14, two cans lacking the required lock rings were noted in the B&W Hammermill area.
Failure to follow procedures for storage of empty cans with the required lids and lock rings in place was identified as an apparent violation of License Condition 9 (70-1113/89-05-06).
- 12. Training and Qualifications Review Details a.
Medical Qualifications for Respirator Wearers P/P No. 40-22, Respiratory Protection Program, Rev.
5, dated March 23, 1988, requires that Plant Medical personnel determine that an individual is medically capable te wear a respirator and annually reevaluate this determination.
The licensee's Medical Department uses the criteria found in Appendix D of the Cotton Dust Standard as specified in the Federal Register, Volume 43, Number 122, dated June 23, 1978, to determine whether or not an individual is medically capable of wearing a respirator.
The Appendix 0 technique used f.o measure the ability of a person to wear a respirator consists of a measurement of forced vital capacity (FVC).
The technique requires a minimum of three forced expirations to be carried out by the person being tested. The technique also states that a person shall be judged unacceptable to wear a respirator when excessive variability, as measured by an instrumer.t showing these efforts graphically, is demonstrated.
Excessive variability is defined as a variation greater than 10 percent between the two largest FVC's and FEVI's (forced expiration volume in one second) of the three satisfactory graph tracings.
While examining medical records of selected licensee employees requiring use of respiratory protective equipment, one record was found which graphically displayed only two FVC tracings.
Another record was found which showed a variation greater that 10 percent between the two largest FVC's and FEV1's. When asked about these records, the licensee indicated that these tracings had been performed by a contract nurse who was no longer employed at the facility.
The licensee also rescheduled both of these examinations for June 15, 1989.
These repeated FVC's were examined by the inspector on June 15, 1989, and found to be acceptable.
Failure to follow precedures for perfor.,ing the required number of forced expirations and to obtain satisfactory results for variation between tracings was 1oentified as an example of an apparent violation of License Condition 9 (70-1113/89-05-06).
1 I
3 36 b.
Training P/P 40-22, Respiratory Protection Program, Rev. 5, dated March 22, 1988, details cognizant managers as responsible for scheduling respiratory protection training and REMTRAC data entry, and the Nuclear Safety Engineering Section as responsible for issuing REMTRAC Status Reports for Fitting / Training status and providing periodic respiratory protection training.
On May 25,1989, during review of REMTRAC status reports regarding employee respiratory protective equipment qualifications, the inspector noted approximately 13 individuals who had not received the annually required SCBA training.
Further discussion with cognizant NSE personnel indicated that on March 24, 1989, several of the individuals required the annual SCBA retraining and that notices were sent to the responsible managers for each subsequent month regarding the trainiri, status.
During that internal, no SCBA training as prcvided nor was the specific training requirer.ent cancelled for any of the individuals.
During the inspection, NSE personnel contacted the affected managers and determined that for the 13 workers requiring training, none had utilized SCBA equipment.
Furthermore, the cognizant managers informed the NSE group that these individuals would not be required to use SCBA in the future and the training requirement would be removed from the appropriate tracking system.
The inspector noted that the tracking system rcquired adherence to the procedure by the cognuant managers to maintain up-to-date training for facility employees.
The inspector informed licensee representatives that the failure of cognizant managers to schedule or to change the status of the annually scheduled SCBA training for 13 individuals was identified as an example of a violation of License Condition 9 (70-1113/89-05-06).
13.
Contamination Surveys License Condition 9 of Special Nuclear Material (SNM) License No.1097 requires that licensed material be used in accordance with statements, 1
representations, and conditions of Part 1 of the License Application dated October 23, 1987.
Part 1,
Section 2.2.1.4 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.
NSI No. 0-6.0, Contamination Measurement and Control, Rev. 19, dated l
June 7, 1988, Appendix C, requires that smearable contamination in excess of 10,000 dpm/100 cm2 or visible contamination on floors and 25,000 dpm/100 cm2 on controlled area equipment be cleaned immediately.
1 L
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- p 37 During tours of the facility on May 25, 1989, the inspector observed the continuing maintenance activities on the No. 3 Slugger. As mentioned in Paragraph.11.c above, the slugger had been partially disassembled the previous day and the parts had been placed on several carts. Some of the parts were wrapped in plastic while other parts were not _ covered. These unwrapped. parts were present during morning and afternoon tours of the
+
area, but during the afternoon tour, the inspector noted, upon closer direct observation, visible contamination on the parts that were not wrapped or covered.
Following the tour, the inspector requested that a
- survey be performed on the unwrapped parts. The results of this survey indicated direct reading alpha contamination levels of 42,000 dpm and smearable contamination levels of 60,000 dpm/100 cm2 alpha.
Failure to adhere to contamination control procedures was identified as an example of an apparent violation of License Condition 9 (70-1113/89-05-08).
Facility tours during the week of May 22-26, 1989, the inspector noted what appeared to be visible dust in various areas of the facility. Upon closer inspection on June 14, 1989, the inspector noted that the dust material in the FM0 Powder or Press Dump Warehouse appeared to be powder.
- This material was noted on stair railings in the warehouse, on railings of the can roller transfer system railing, and on the walkways in various locations.
Because the dust appeared to be powder, the inspector contacted a RP monitor in the area and requested that smear surveys of several locations in the warehouse be performed.
Results of the surveys indicated that there was smearable contamination, values ranging from 10,000 to 30,000 dpm/100 cm2 on the railings in the area.
After the tour, the inspector informed the licensee of the survey findings and also reviewed survey maps of the area which had been completed during the preceding first half of 1989.
These surveys indicated that the area was generally found to have contamination levels less than 5,000 dpm/100 2 alpha except when the survey was performed by a specific RP monitor.
cm In general, for surveys conducted by this RP monitor, levels requiring decontamination were usually found.
The inspector discussed this bias l
with licensee representatives who indicated that this individual was relatively new to the group and had only worked in the group for three years.
The inspector indicated that this could be indicative of an inadequate retraining program for those RP monitors who had been employed for a longer period of time.
During the subsequent shift, the inspector walked by the area to review the required cleanup efforts. No areas requiring decontamination had been cleaned at that time.
In discussions with licensee representatives, the inspector stated that failure to clean up areas found to be contaminated was indicative of a weak ALARA prcgram.
Lack of aggressive actions to decontaminate areas found with contamination levels to 30,000 dpm/100 cm2 has a negative impact on the ALARA program and does not reinforce concepts presented in general Radiatio, Control Area training.
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1 Failure to adhere to contamination control procedures was identified as an example of an apparent violation of License Condition 9 (70-1113/89-05-08).
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14.
Review and Evaluation of Nonroutine Radiation Protection Activities 10 CFR 20.201(b) requires each licensee to make or cause to be made such.
surveys as (1) may be necessary for the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.201(b) defines a survey to mean an evaluation of the radiation protection hazards incident' to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a-specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment,.and measurements of levels of radiation or concentrations of radioactive materials present.
10 CFR 20.103(a)(3) requires the licensee for purposes of determining compliance with the requirements of this section, to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, 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.
During the inspection, RP activities associated with specific nonroutine maintenance activites were reviewed and discussed with licensee representatives.
Specifically, two extensive maintenance tasks, the HVAC Management and Control system upgrade installation, and the subfloor excavation of contaminated material in the Hydroly:is area were discussed with licensee representatives.
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a.
HVAC Management and Control System Installation During review of radiation controls used during HVAC system work, the inspector noted changes to the applicable RWP, and the identification of licensee concerns resulting in an Class I investigation 6 being conducted.
Discussion with cognizant licensee representatives indicated that the change to the RWP (RWP 851) and also a subsequent Incident Investigation were implemented by the NSE group as a result of unexpected elevated bioassay data for two contractors working on the project.
Further discussion with licensee representatives and review of applicable records, resulted in findings regarding required surveys, representative air sampling, evaluation of the contractor bioassay results, and determination of other personnel potentially exposed to elevated concentrations of airborne uranium as a result of the HVAC upgrade project.
These issues are discussed below.
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u 39 The events resulting in elevated contract worker bioassay results and the licensee. classifying the issues as a Class I incident were reviewed and discussed with licensee representative., Initial activities for installing the HVAC system upgrade, including work in overhead Radiation Controlled areas, was controlled by a broad RWP, RWP 851, Install Pneumatic Tubing and Flow Meters in All HVAC Systems dated August 5, 1988. At that time, the RWP did not require the use of.a full face mask respirator nor the submittal of urine samples for analysis.
On September 1,
1988, a contractor's urine sample, submitted as a resuit of work conducted in a JFA requi< ing daily urinalyses, indicated elevated concentrations of total uranium (U),
99 ug U/1 estimated as an uptake of b.22 mg U.
At that time, the RWP was revised to include use of a full face mask respirator for overhead work.
On October 6, 1988, a second contract worker's urinalysis result, 72 ug U/1 (0.16 mg uptake) exceeded the licensee action guidelines of 35 ug U/1. No review of the incident resulting in the elevated value was conducted. For urine samples submitted on October 18, the two contract workers indicated unusually elevated urinalysis results, 605 ug/l (0.9 mg U intake) and 193 ug U/1 (0.7 mg U intake), respectively.
At that time, NSE personnel determined that the contractors ware not aware of the changes to the RWP requiring use of a respirator and the submittal of a urine sample. Fortunately, the urine samples were submitted subsequent to the contractors experiencing a peculiar taste in their mouths after working in the overhead areas above the Sluggers. At that time, the incident was classified as a Class I incident, and all nonroutine work in normally unaccessed areas, for example the overhead areas, was suspended until approval through the NSE group. The two contract workers' exposures to elevated concentrations of uranium were evaluated.
Licensee analyses indicated a ratio of 60 percent to 40 percent insoluble material for the HVAC overhead areas located above the Sluggers.
Based on urinialysis results, exposure was estimated to be less than 40 MPCa-hrs for the October 18, 1988 incident.
Lung burden analyses conducted on October 24, 1988 indicated lung burdens of 167 and 226 uj U-235. A second set of lung burden analyses for the workers indicated levels below the analysis MLD of 50 to 60 ug U-235.
From October 21 through February 17, 1989, licensee representatives completed their investigation, identified the root cause of the incident, and initiated and finalized corrective actions regarding contract work in the overhead areas. Licensee representatives stated that the root cause of the elevated exposures was a too broad-based RWP developed for the HVAC project, whereas, the overhead areas required special contr31s. In addition, the licensee's investigation noted that training for the contractors regarding RWP implementation was inadequate. Furthermore, problems in identifying changes to the RWP, that is the interactions between the contractors and the RP group was ineffective, thus resulting in inadequate understanding of the requirements to perform the tasks.
The licensee's corrective actions included changes to RWP training, the development of an
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" Overhead Work' Checklist" improving' 'RWP revi sion/ communication -
controls; and assignment of a-RP monitor dedicated entirely _to assist in _ contractor; and-re-emphasize the potential. hazards to contractor.
'All' corrective actions were completed by March 1989.
The' inspecto'r discussed the ' licensee's investigation and evaluation andnoted the positive actions including improved radiological,
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controls for work in overhead areas, inproved training for contractos and the assignment of' a RWP coordinator -for the contract workers.
However, the following deficiencies in the ' licensee's RP program for nonroutine activities, did not appear. to. be cddressed : by the licensee's. investigation.
The licensee's evaluation of the Class I incident did not review the - potential for other contract workers to be exposed to elevated concentrations of uranium while conducting HVAC work in the overhead areas.
Prior. to the October 18, 1988 ' incident, radiation. surveys, either quantitative or qualitative, were not conducted for the overhead areas. Even after the initial determination of elevated bioassay samples on September 1,1988, requiring use of a full-face : respirator for. conducting work in the overhead, SASS-to:
meet the requirements of 10 CFR 20.103(a)(3) were not conducted.
The licensee's evaluation' failed to review applicable bioassay procedures. for adequacy in identifying potentially hazardous conditions.
For example, bicassay sample results for the two contractors. exceeded action guidelines prior to the October 18, 1988, samples but.no_ concerns with. tbe contract-work were identified.
The licensee estimated the contractor exposures for the October 18, 1988 sample and did not review the contractors exposure to soluble uranium concentrations during a 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week against the 10 CFR 20.103(a)(2) limits.
The failure of RP personnel to identify the-improper use of RWP controls by contractors. prior to October 18, 1988, may indicate a need for training requalification of the RP monitors"and 7
operators.
The inspector informed licensee representatives that the failure to conduct surveys prior te and during installation of the HVAC upgrade system in the control'ed area to evaluate the hazards present for the contract workers was considered a violation of 10 CFR 20.201(b) requirements (70-1113/89-05-09).
The inspector reviewed and discussed with the licensee the following procedures associated with investigation and/or evaluation of elevated biassay samples.
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l P/P 40-12, Nuclear and Environmental Incident Investigation, Rev. 6, dated December 4, 1987.
P/P 40-18, Regulatory Compliance Administrative Action Guidelines, Rev. 7, dated June 9, 1987.
NSI 0-22.0, Incident Investigation, Rev. 11, March 30, 1989.
1 NSI 0-2.0 Bioassay - Urinalysis Program, Rev 15, dated January 6, 1988.
P/P 40-12 defines the method for investigating and subsequently reporting incidents where regulatory limits for radiation exposures may have been exceeded. T N procedure reguires immediate action when the estimated uptake exceeds 2.5 mg total V.
P/P 40.18 establishes the Regulatory Compliance Action Guidelines for exposure and contamination control.
For urinalysis samples submitted on a daily or weekly basis, results exceeding 35 ug U/1 and 15 ug U/1 urine, respectively, only require e resample to be submitted. NSI 0-22.0 regt.i re s that an unanticipated internal radiatien exposure of "significant" magnitude requires an inquiry, gathering of data, determination of the event significance, communicating with I
supervisors, request for bioassays, tracking of items, and documenta+. ion of the report for submittal to the NSE Senior' Program Man'ger.
From discussion with licensee represer.tatives, the insl ector determined that urinalysis samples exceeding the action guidelines of 35 and/or 15 ug U/1 were not considered significant.
The use of action guidelines to identify potentially hazardous situations for review by technical personnel
- discussed. Improved evaluation of the elevated contractors b',
results measured prior to the October 18, 1988 sample woulo '
<ierted the licensee to the concerns identified, including the.ack of appropriate contamination and SASS.
In addition, the need to evaluate other personnel who potentially may be affected by the same or a similar situation need to be included in the evaluation l
During discussion regarding the need to review incidents resulting in urinalysis values exceeding action guidelines, licensee representatives stated that if all results exceeding 15 or 35 ug U/1 required detailed evaluation, the eask would be an excessive burden on the current RP staff. The inspector reviewed bioassay results from June 1, 1988 through May 31, 1989, and noted approximately 22 and 25 individual values which exceeded the 35 ug U/1 and 15 ug U/1 action guidelines, respectively. This freqency of results did not appear too excessive to complete a detailed investigation, including identifying other personnel involved in the incident.
Furthermore, the inspector noted that NSI 0-2.0, requires, if necessary, the use of similar information to estimate the time of intake for use in calcu?. ting exposure to soluble uranium compounds.
The inspector
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42 noted that ' determination of other personnel involved in an incident j
d did not appear to require significant additional personnel resources.
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The' inspector informed licensee representatives that the procedural 1
guidance for reviewing bioassay results exceeding established guidelines was inadequate in that details regarding the incident, including other personnel involved, were not required.
This was identified as a
violation of License Condition No.
9 (70-1113/89-05-06).
On May 26,1988, the inspector requested licensee' representatives to determine the contractors working in Controlled Area overhead locations from August 5, 1988, (intiation of the project) to October 24, 1989, and their potential for exposure to airborne uranium concentrations Licensee representatives indicated that data regarding the contractors time working on the HVAC system was not tracked using the licensee REMTRAC system nor using signup sheets associated with the applicable RWP. The actual time on the HVAC was available through the applicable billing documents for various components of the project. These records were not directly available to Radiation Protection or NSE personnel.
Licensee representatives had not completed the requested evaluation by June 25, 1989, the end of the second week of the onsite inspection. The inspector noted that the licensee's ability to determine for contract workers time spent on nenroutine activities for radiological protection assessment purposes was inadequate.
During the NRC exit on June 15, 1989, licensee representatives committed to providing the requested information to the NRC by June 23, 1989.
During a teleconference on June 23, 1989, licensee and NRC representatives reviewed and discussed the final evaluations conducted for the contractors.
In addition to the two contractors initially identified as exposed to elevated concentrations of uranium material through bioassay analyses, 13 additional persons were noted to have been involved in the project.
These individuals were classified into three groups representing high, intermediate, and low potential for exposure, based on their actual job functions. The individuals, analyses conducted and results are as follow.
Five individuals, conducting wire and tube pulling in Controlled Area overhead locations, were included in the high ekposure potential group. One individual had submitted eight ^ bioassay samples prior to, and four had submitted single samples on October 24, 1988.
None of the sample results exceeded 35 ug U/1.
No results were obtained fsr one individual. The results of lurag burden analyses, conducted between October 17, through Jum 1989, were less than the MDL of 50 to 60 ug U-235.
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i Three; individuals, performing wire pulling outside the Centrolled Area, were included in the intermediate potential exposure group. All three -individuals urinalysis results supplied for samples collected on October 24, 1988 were below the MDL of approximately 5 ug U/1. Lung burden analyses for two of the individuals were below MDL and the third individual had L
terminated employment prior to the analyses.
Five individuals, four' of whom worked on electrical panels, which are not airborne contamination areas, and a tool room attendant were included in the low potential group and were not required to provide bioassay samples nor'to complete lung burden analyses.
However, a lung burden analysis on March 22, 1989, for one of the individuals indicated negative results.
As a result of the short retention time for soluble uranium and the absence of. adequate air samples, licensee representatives stated that definite conclusions regarding potential exposure to soluble uranium compounds would not be possible for the 13 individuals evaluated.
For the two' contractors having positive urinalysis results on October 18, 1988, the licensee estimated the maximum MPCa-br exposures to soluble uranium for. a seven day period to be 9.8 and 7.2 MPCa-hrs, respectively.
Licensee representatives stated that these values would be included in the employees official records.
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Excavation of Contaminated Material The inspector reviewed RP activity in regarding excavation of process area subfloor contaminated material. The review included RWP controls, RP coverage, air sampling, and environmental monitoring controls used to demonstrate licensee commitments to ALARA principles.
The project was initiated to determine the extent of contaminated under the Hydrolysis area floor following the discovery on November 17, 1988, of contaminated liquid seeping into a hole in the concrete beneath the 1A Hydrolysis pump Licensee records indicated a curb initially was constructed around the hole to minimize flow of contaminated material through the hole into the ground.
Initial maintenance activities were conducted in accordance with RWP 893, Excavate and Repair Under No. 1 Pump in Hydrolysis, dated November 17, 1988, and RWP 940, Complete Excavation at IA Location, Fill With Sand, and Repair Ceilcote, also Repair IA,3A, 4A, and 4B Bases, dated December 8, 1988. Radiological controls included use of respirators as required and applicable PCs.
On November 18, 1988, the immediate area was roped off and posted and the flooring around the hole was chipped and removed. All work was conducted in a
full-face respirator.
Airborne uranium
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1 concentrations, values ranging from 5.3 E-11 to 30 E-11 uCih1, were determined using Hi-Vol air samplers during removal of the concrete floor. The inspector verified RP coverage as noted in the RP shift log. No air samples were collected while excavating approximately three gallons of contaminated material from directly beneath the i
floor. Licensee representatives stated that the subfloor material was moist and elevated airborne concentrations as a result of removal of j
the material was not expected.
Uranium concentrations in the excavated material were 16,400 parts per million (ppm) U at or near the surface, and 11,300 ppm at soil depths of approximately 25 and 38 inches, respectively.
The excavated area was covered and an additional curb constructed to prevent infiltration of additional contaminated material into the ground.
On November 21, 1989, excavation of all loose material was completed and additional core sample results indicated subfloor material concentrations ranging from approximately 5,166 to 14,000 ppm U.
The issue was classified as a Class I incident.
On November 22, 1988, a meeting. was held to describe interim steps to be conducted including removal-of the 2A and 3B hydrolysis pumps to repair the floor and to conduct further evaluations of other pumps which could leak, thus resulting in similar corrosion and subfloor contamination problems.
In a Memoradum to File, Class I Investigation - Subfloor Contamination, the completion of the excavation of the contaminated material was outlined.
Based on changes -in color of the subfloor material, the remaining contamination was stated to be contaminated material previously noted beneath selected process areas.
No additional ef forts were made by the licensee at this time to remove the old contamination material.
All contaminated material, uranium concentrations ranging from 550 to 14751 ppm, which was removed, was accumulated in 73 five gallon containers.
Licensee representatives stated that all material was maintained or disposed of properly.
The inspector reviewed documentation regarding the previous survey project which determined the extent of contamination beneath the bui.1 ding. The contamination was not determined to be severe enough to require immediate decontamination of the area.
Removal of this material is expected to be conducted during final decommissioning of the facility.
Licensee representatives verified that GE his taken steps to archive and maintain records relating to incidents", spills or releases to the environment until the end of plant life to provide additional information for use in decommissioning activities.
In addition, to monitor the pctential for migration of radioactive and chemical materials away from the site, a groundwater monitoring program was established.
The inspector reviewed and discussed with the Manager, Environmental Protection and Industrial Safety, the ground water monitoring program for the facility. Review of uranium concentrations in monitoring wells from 1985 through 1988, indicated 1
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45-no significant' trends' or. changes for the data reported.
For 1989, monitoring 'well _ uranium concentration results were below the analytica11 detection limit of 0.02 ppm. In addition, - results of selected chemical ' analyses required in the - groundwater monitoring m
program were reviewed.
No significant trends were noted.
'The _ inspector noted that radiological controls for the completion of the. subfloor. excavation of' contamination' appeared appropriate and that current ~ ground ' water ' monitoring indicated no migration of-radioactive materials -into the local groundwater.
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- 15.- Followup on Violations (92702) a.
-(Closed) ' Violation '(VIO) 70-1113/88-08-01:
Fatiure to follow-
. approved procedures. for (1) conducting contamination survey instrumentation performance checks and (E) maintianing an unattended:
roll-up door closed between the Radiation Controlled Area Old Decon Room and an adjacent' uncontrolled area.
The inspector reviewed and. verified implementation of corrective actions stated-in GE's responses dated August 26, 1988'and September.
28, 1988. The inspector verified that RP work-assignment sheets had been updated to include survey meter performance checks and that the
- performance checks were being completed and documented each shift 'as l
required by procedure.
-The above referenced Reply to the Notice of Violation-also stated that the roll-up door had been equipped with a timer and audible alarm which will sound. if the door remains open longer - than 1
approximately three minutes..This action. was confirmed by the-inspector. In addition, licensee representatives stated that "round 1
table" discussions had been completed with affected personnel to emphasize the requirement to maintain the door closed in accordance with procedures.
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-(Closed) VIO 70-1113/88-08-02: Failure to assess properly, personnel exposure to airborne concentrations of uranium for (1) selected 1
individuals having positive urinalysis sample results and (2) use of improper time interval between an exposure event and the subsequent urine sample collection.
j The inspector reviewed and verified implementation of corrective actions stated in GE's responses dated.Sugust 26, 1988 and September 28, 1988.
Based on discussions with licensee representatives, j
subsequent to the referenced inspection, item one was revised to pertain to a single individual rather than multiple individuals improperly assessed for internal exposures.
Follew-up actions for i
1 this individual were reviewed by the inspector.
Corrective actions to prevent use of improper sample collection time wtervals for j
certain exposure assessments included procedure ch0nges and j
modification of the licensee's computer software which were verified
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memo to the' production area managers sensitizing them to the correct urine sample collection time required for proper assessment of potential exposure, c.
(Closed) VIO 70-1113/88-18-03: Failure to follow approved procedures for radiological controls associated with a storage pad area.
The inspector reviewed and verified implementation of corrective actions stated in GE's response dated February 22, 1989.
During tours of the outside areas, the inspector verified that all storage pads were properly posted and barriered off according to the licensee's procedures.
The inspector also verified that "round table" discussions had been completed with affected personnel.
16.
Inspector Followup Item (IFI) and Unresolved Item (URI) Review (92701) a.
(Closed) URI 70-1113/88-08-03:
Potential exposure of personnel to airborne uranium concentrations exceeding 10 CFR Part 20 limits.
This item concerned the potential for the existence of additional personnel exposed to airborne uranium concentration cases undiscovered.
Following discussion ' of the details and review of licensee records by the i n spector-, no unmonitored or unreviewed analyses were indicated for the time period involved.
b.
-(Closed) IFI 70-1113/88-18-02:
Review results of radiological surveys of pellet press equipment subsequent to decontamination activities.
This IFI dealt with background information used by the licensee to justify the failure to perform radiation surveys during selected routine maintenance activities associated with the pellet presses.
The inspector reviewed high volume air sampling performed during past pellet press cleanouts and a series of smear surveys performed after 1
pellet press cleanouts on various lines from January 10, 1989 thru January 24, 1989.
Results of these radiological surveys substantiated the licensee's actions, c.
(Closed) IFI 70-1113/88-18-05: Review of audit checklists associated with transportation activities.
During a previous insp?ction, internal audits documenting the licensee's transportation activities did not include specific items which are required to be reviewed for determining program adequacy.
The inspector reviewed actual check lists used by the auditors and found them to contain a comprehensive list of areas and items to be reviewed.
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1 17.
Exit Interview (30703)
The inspection scope and finr"ngs initially were summarized on May 26, 1989, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below. Details regarding both strengths and weaknesses of t
the licensee's RP and ALARA programs were reviewed.
In addition, violations of numerous procedures and inadequate radiation surveys regarding nonroutine activities were reviewed in detail.
Closecut of previous IFIs and violations listed in Paragraphs 15 and 16 were reviewed.
Licensee representatives acknowledged the inspector's comments.
On June 15, 1989, following completion of the second onsite review, additional violations concerning procedural noncompliance and survey inadequacies were detailed to licensee representatives.
One unresolved item, regarding adequacy of the licensee's SAS representativeness studies was identified. The inspector noted that additional information regarding the evaluation of all contract personnel potentially exposed to elevated airborne uramium concentrations while installing the HVAC system, was requested during the week of May 26, 1989, but as of June 15, 1989, the review had not been completed. Licensee representatives acknowledged the inspector's comments and committed to providing the requested information to the NRC Region II office by Juu 23, 1989.
During a teleconference between licensee and NRC Region II representatives on June 23, 1989, details regarding their evaluation for potential unmonitored internal exposures for contract personnel installing the HVAC system upgrade were discussed.
In addition, during a teleconference on July 14,1989, NRC Region II personnel informed -licensee representatives that following additional review and discussion with NRC Region II management and Headquarters personnel, the unresolved item concerning SAS air sampling representativeness was identified as an apparent violation of license conditions.
Although proprietary material was reviewed during this inspection, proprietary information is not contained in this report.
Item Number Description and Reference 70-1113/89-05-01 IFI - Review licensee actions regarding the development of guidance detailing RSC functions (Paragraph 2.c).
70-1113/89-05-02 IFI - Review licensee actions regarding lack of " root cause" analyses associated with quarterly audit reviews (Paragraph 3.a).
70-1113/89-05-03 IFI - Review licensee actions regarding development of guidance for re spi ratory protective equipment use (Paragraph 7.b).
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48 70-1113/89-05-04 IFI - Review corrective actions regarding lack of pre-job reviews, status briefings, and post-job reviews in the RWP. program (Paragraph 8).
70-1113/89-05-05 VIO - Failure to demonstrate representativeness of SAS locations relative to air breathed by workers (Paragraph 10.b).
Violation of License Condition No. 9, Part 1, Section 3.2.4.2.1.
70-1113/89-05-06.
VIO - Failure to follow approved and/or inadequate procedures for (1) area posting requirements (Paragraph 11.c), (2) PC use (Paragraphs 11.a and 11.b), (3) respiratory protective equipment inspection and storage (Paragraphs 11.d, 11.e, and 11.f),
(4) personnel contamination surveys (Paragraph 11.g),
(5) training and qualifications for respiratory protection (Paragraph 12),
(6) empty can storage (Paragraph 11.h),
and (7) evaluation of activities associated with personnel exceeding soluble uranium action guidelines (Paragraph 14).
Multiple examples of a violation of License Condition' No. 9, Part 1, Section 2.2.1.4.
70-1113/89-05-07 IFI - Review licensee actions regarding control and accountability for revirators stored in separate process area locations (Paragraph 11.f).
70-1113/89-05-08 VIO - Failure to adhere to contamination l
control procedures for (1) the Powder l
Warehouse area (Paragraph 13),
and (2) process equipment (Slugger) parts maintained in the Controlled Area during maintenance activities (Paragraph 13).
Multiple examples of a violation of License Condition No. 9, Part 1, Section 2.2.1.4.
l 70-1113/89-05-09 VIO - Failure to conduct, adequate surface
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and/or airborne radioactive contamination surveys to evaluate the hazards present for
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personnel installing the HVAC Management and Control System (Paragraph 14). Violation of 10 CFR 20.201(b) requirements.
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