ML20196A397

Insp Rept 70-1151/99-03 on 990510-14.No Violations Noted. Major Areas Inspected:Observation of Work Activities,Review of Selected Records & Interview with Plant Personnel in Areas of EP & Radiation Protection

ML20196A397
Person / Time
Site:	Westinghouse
Issue date:	06/11/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20196A388	List: ML20196A384 ML20196A397
References
70-1151-99-03, 70-1151-99-3, NUDOCS 9906220216
Download: ML20196A397 (14)

Text

f lb U.S. NUCLEAR REGULATORY COMMISSION

REGION 11 i

Docket No.: 70-1151 l

License No.: SNM-1107 Report No.: 70-1151/99-03 l

Lhensee: Westinghouse Electric Corporation i

Facility Name: Commercial Nuclear Fuel Division Date: May 10-14,1999 Inspector: A. Gooden, Radiation Specialist Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety i

s Enclosure l '

9906220216 990611 PDR C ADOCK 07001151 '

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EXECUTIVE

SUMMARY

Commercial Nuclear Fuel Division NRC Inspection Report 70-1151/99-03 I

This routine unannounced inspection involved observation of work activities, a review of j selected records, and interviews with plant personnel in the areas of emergency preparedness l and radiation protection. The report entails one week of inspection effort by a regional-based radiation specialist.-

Radiation Protection

• Based on the records review and interviews, the inspector concluded that the licensee's l external exposure control program was adequate for evaluating and monitoring personnel exposures (Paragraphs 2.a.(3) and b.(3)).

• 1998 exposures were reduced with the exception of the maximum assigned extremity which increased 61 percent, and the collective exposure increased approximately ten percent (Paragraph 2.a.(2)).

• When compared to the 1997 maximum assigned committed effective dose equivalent (CEDE) of 2.73 rem, the maximum exposure for 1998 (2.50 rem) resulted in an eight percent reduction (Paragraph 2.b.(2)).

• Administrative dose limits were established and all assigned exposures were well below the regulatory limits (Paragraph 2.b.(3)).

• The periodic survey (direct radiation, air, and smears) program provided the mechanism for revising control area postings as a function of changing radiation levels (Paragraph 2.c.(3)).

Emeroency Preoaredness

• Personnel conducting the audit were technically qualified to perform the audit, and the audit plan contained guidance to ewre that the audit was performed in a manner consistent with Section 7.8 of the Emergency Plan (Paragraph 3.a.(3)).

• . Emergency procedures were organized and written in a checklist' format for ease of use.

However, the hazardous weather emergency action level (EAL) required clarification and guidance to ensure consistency in the emergency classification by procedure users j (Paragraph 3.b.(3)).

• The licensee's use of pre-planned scenarios, with the details provided to participants in i advance of the practice drills, would not appear to provide an adequate test or challenge j to response personnel (Paragraph 3.e.(3)).  !

• The onsite system for measuring wind speed and direction was no longer serviceable and the licensee was investigating a replacement system (Paragraph 3.f.(3)). l

Attachment:

(See Page 2)

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Attachment:

Persons Contacted and Exit Interview

. List of items Opened, Closed, and Discussed

' List of Acronyms

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FC REPORT DETAILS

1. . Summarv of Plant Status i

This report covered a period of one week. There were no unusual plant operational occurrences during the inspection. Plant operations _were normal with routine maintenance activities and the commencement of activities associated with the refabrication of Zion fuel assemblies.

2. Radiation Protection (83822)(R1)

a. External Exoosure Control (R1.04)

(1) Insoection Scooe The inspector reviewed licensee procedures to determine if the licensee's monitoring program was consistent with requirements in 10 CFR 20, and if controls were in place to maintain occupational dose As Low As Reasonable Achievable (ALARA). Personnel exposure data was examined to determine if exposures were in compliance with 10 CFR Part 20 limits.

(2) Observations and Findinas Plant personnel were observed inside the radiation control areas wearing the appropriate dosimetry. Based on exposure data for 1998, the occupational dose to plant workers continue to be maintained well below the limits in 10 CFR Part 20.1201. Wi+.h two exceptions, calendar year (CY) 1998 exposures were reduced approximately seven to eight percent when compared to CY 97 data (See Table 1 below). The two exceptions were the maximum assigned extremity exposure which increased 61 percent in CY 98 (27.1 rem) over CY 97 (16.8 rem); and the site collective dose increased approximately ten percent (206 person-rem) in CY 98 over CY 97 (188 person-rem). The licensee attributed the increase in i extremity exposure to an increase in production. The maximum assigned i deep dose. equivalent (DDE) of 1.70 rem was investigated and considered an aberration based on exposure historical data and the associated exposures for area workers, p

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2 Table 1 Annual Exposures Year Deep Dose Maximum Total Effective Collective Committed Equivalent ' Dose Dose TEDE Effective Dose (DDE) Extremity Equivalent Equivalent (MDE) (TEDE) (CEDE) 1997 0.00 rom 16.8 rem 2.95 rem 188 2.73 rem person-rom 1998 *1.70 rem 27.1 rem 2.73 rem 206 2.50 rem person-rom

• NOTE : Licensee investigation attributed the exposure to contamination of the j badge holder.

(3) Conclusions Based on the recards review and interviews, the inspector concluded that the licensee's exposure control program was adequate for evaluating and monitoring exposures to ensure that occupational exposures are less than 10 CFR 20 limits.

b. Intemal Exoosure Control (R1.05)

.(1) Insoection Scooe The inspector reviewed licensee procedures for assessing intemal l exposure to determine if controls were in place to monitor occupational doses, and verify that the administrative limits were established to control l

1 occupational dose ALARA. Exposure data based on air sampling results were reviewed to determine if exposures were in compliance with 10 CFR Part 20 limits.

(2) Observations and Findinos Procedures contained action limits which were set below federal limits to ensure personnel exposures did not exceed limits in 10 CFR 20.

Exposures were frequently reviewed to determine if administrative limits were met so that appropriate actions were taken to preclude exceeding

- limits in 10 CFR Part 20. Table 1 above presents the maximum assigned exposure data for CY 98 and 97. The maximum assigned CEDE for CY 98 was 2.50 rem, an approximately eight percent reduction from CY 97, and was assigned to a worker in chemical conversion. Thus far in CY 99 (as of May) the estimated CEDE was 1.40 rem.

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L (3) Conclusions Based on interviews and records review, the licensee's intemal exposure control program was adequate for evaluating and monitoring personnel exposures. Administrative dose limits were established and assigned exposures were well below the regulatory limits.

c. Postinos. Labelina. Control (R1.07)

(1) Inspection Scope The program for posting notices as required by 10 CFR 19.11 was reviewed to determine if documents were posted in sufficient places to permit individuals engaged in licensed activity to observe them. Several work locations were reviewed to assess the adequacy of contamination control barriers and posting of radiation areas as required by 10 CFR 20.1902.

(2) Observations and Findinas l.

! Bulletin boards were posted such that workers may observe documents l

or obtain details as to where documents may be examined. Regarding posting of radiation areas, the inspector reviewed quarterly direct radiation surveys of the facility and noted that the maximum radiation level measured was twelve millirem per hour (mr/hr) in the vicinity of the fuel assembly storage area. The inspector toured the fuel assembly storage area and the temporary work area for the Zion Project and determined that based on the current radiation data, areas were posted consistent with requirements in 10 CFR 20.1902. j l

(3) Conclusions i Based on tours and a review of radiation survey data, postings were consistent with the license and requirements in 10 CFR Parts 19.11 and  ;

20.1902. The periodic sampling (direct radiation, air, and smears) program provided the mechanism for revising posting as a function of

changing radiation levels.

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d. Notifications and Reoorts (R1.09)

(1) Insoection Scope The licensee's Unusual incident Report (UIR) file was reviewed for determining the reportability of events to NRC and workers.

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(2) Observations and Findinos Randomly selected incidents from the period September 1998 through ,

February 1999 were reviewed by the inspector and no problems noted. l The selected incidents required worker notification to ensure that the workers involved in the incident were aware of the potential for exposure.

Notification to NRC was not required for the selected events. The licensee provided followup in the event the employee required work restrictions.

(3) Conclusions No issues were identified. The licensee's performance in reporting of the I selected incidents was both appropriate and timely. j

3. Emeraency Preoaredness (88050) (F3) i

a. Review of Proaram Chanaes (F3.01) l (1) Insoection Scoce Changes to the Columbia Site Emergency Plan (CSEP), emergency ,

procedures, organization, facilities, and equipment were reviewed to assess the impact on the effectiveness of the program; and to verify that the changes met commitments and license conditions; and that Site Emergency Plan (SEP) changes were provided to NRC in accordance with 10 CFR 70.32(i). Examine the independent audit to verify adequacy of scope and depth of the audit, technical capability of auditor, and documentation of findings and corrective actions.

(2) Observations and Findinas Since the September 1998 inspection, no changes were made to the SEP, facilities, organization, or major equipment. Changes were made to Emergency Procedure A-01 " Emergency Response Organization" to improve the activation and staffing of the organization during an emergency.

The independent audit was conducted during December 15-16,1998.

Personnel conducting the audit were technically qualified to perform the audit, and the areas audited were consistent with the audit plan and Section 7.8 of the SEP. No deficiencies were identified. The audit report documented what appeared to have been a detailed, compliance-oriented audit to verify that the program was maintained in a state of operational

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5 (3) Conclusions Personnel conducting the audit were technically qualified to pe audit, and the audit plan contained guidance to ensure that the performed in a manner consistent with Section 7.8 of the SEP.

b.

lmolementino Procedures (F3.02)

(1) Insoection Scooe implementation of the SEP. Select emergency procedures w (2)

Observations and Findinos (Hazardous Weather) and A-04 Emergency C consistency in addressing emerg(ency action levels assoc event emergency classification in the SEP and pr to users regarding conditions that e.g.

constitut speed) so that the appropriate classification would be made. The lac guidance was further demonstrated during walkthroughs postu onsite wind speeds of more than 70 miles per hour (mph). Two of interviewees incorrectly classified the postulated accident as a loc force winds (>70 mph) experienced on site. Th procedures lacked guidance for wind speed and/or criteria for str winds. The 1.9spectorinformed the licensee that the corrective ac ensure consistency in the event classification for hazardous weather would be tracked as an inspector followup item (IFl 70-1151/99.

(3) Conclusions Procedures were organized and written in a checklist format for ea use. However, Emergency Procedures C-07 and A-04 regarding the hazardous weather emergency action level (EAL and guidance procedure users. to ensure consistency inclassification emergenc)y, by required clarification c.

Trainino and Staffino of Emeroency Oroanization (F3.04)

(1) Insoection Scoce Emergency response training was reviewed to determine if the lice had provided training to response personnelin accordance with S 7.2 of the Plan. The adequacy of the administrative and/or physical

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notification system for staffing the emergency organization with trained personnel during off hours was reviewed. 1 1

(2) Observations and Findinas I

The CY 98 hand-out for the Emergency Brigade (also known as Fire l- Brigade) radiological response training provided trainees with excellent

! details regarding the types of hazards present and the necessary precautions during emergency response. As discussed above (see l _ Paragraph 3b.(2)), walkthroughs were conducted with three individuals -

assigned to the emergency organization with responsibilities as the Emergency Coordinator and/or interim Emergency Director during

i. back-shift operations. Interviews were conducted and included postulated i

accident conditions presented for interviewees to assess for classification and determination regarding the implementation of the SEP. Based on walkthrough results, additional training opportunities for Emergency Coordinators in the implementation of the emelgency procedures and the classification logic would serve as a training program improvement.

Regarding emergency response organization (ERO) staffing and j activation during backshifts and off-hours, the inspector noted that since the last inspection, only one drill was conducted, but the results appeared to reflect an improvement to the licensee's administrative system for ensuring timely activation and staffing. Future drill results will be reviewed by the inspector to determine the effectiveness of the licensee's actions.

l (3) Conclusions The Fire Brigade training was very specific to brigade members and provided excellent details to assist personnel in combating fires involving various compounds located onsite. Walkthrough results disclosed training for personnel designated as Emergency Coordinators would be enhanced by including more opportunities to demonstrate familiarity with emergency procedures implementation and use of the emergency classification logic diagram.

d. Offsite Suooort (F3.04)

(1) Insoection Scooe_

Licensee activity in the areas of training, agreements, and exercises, was reviewed to determine if the licensee was properly coordinating with offsite authorities.

(2) Observations and Findinas Training documentation and an interview with the licensee personnel conducting the training revealed that offsite support training was o

7 conducted on November 20,1998, and the attendance roster showed good participation by State, local, and key licensee personnel.

(3) Conclusions Based on documentation, offsite support groups were offered training on an annual basis and were contacted biennially for participation in the

a. onsite emergency exercise.

e. Drills and Exercises (F3.05) 1 (1) Insoection Scope Section 7.4 of the SEP required that one biennial on-site exercise will be performed involving a full-scale test of the entire emergency response organization. The inspector reviewed the licensee's exercise scenarios and records to assess the degree of challenge posed by scenarios and to verify that primary and altemates to the ERO participated in a drill and/or exercise.

(2) Observations and Findinas The last full scale exercise conducted in fulfillment of the requirements in the SEP was conducted September 1997. The licensee indicated that the next biennial exercise was scheduled for September 1999. The inspector determined from interviews that the licensee's program for conducting practice drills involved the use of pre-planned scenarios with details provided to participants in advance of the drill. The practice of providing scenario details in advance would not appear to test or challenge response personnel regarding their role and responsibility. The inspector discussed this approach with the licensee as potentially inadequate for ensuring a very high level of proficiency among response personnel. All primary and attemates to the ERO had participated in a drill.

(3)- Conclusions The inspector concluded the licensee's use of pre-planned scenarios, with the detels provided to participants in advance of the practice drills, would not appe ir to provide an adequate test or challenge to response persormel. 1

f. Emcraency Eauioment and Facilities (F3.06)

(1) Insoection Scooe Emergency equipment was inspected to determine whether the licensee maintained response equipment, instrumentation, and supplies in a state )

of operational readiness.

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r E 8 (2) Observations and Findinas The inspector verified the operability of equipment during a facility tour, and determined via review of periodic maintenance documentation that with one exception, selected equipment was calibrated and operated in accordance with the design and intended use. The one exception was the onsite system for measuring wind speed and direction (anemometer).

The anemometer was no longer serviceable and the licensee was investigating a replacement system. The licensee indicated that the onsite capability for measuring wind speed and direction would be restored by July 1,1999. The inspector informed the licensee that the corrective actions to restore the onsite capability for measuring wind speed and direction would be tracked as IFl 70-1151/99-03-02.

(3) Conclusions Based on facility tours, interviews, and surveillance documentation, with l the exception of the onsite anemometer, equipment selected was operationally ready for the intended use during an emergency.

g. Followuo on Previousiv identified items (1) Insoection Scoos The inspector reviewed actions taken by the licensee to correct previous issues to verify that the corrective actions were adequate and had been completed.

(2) Observations and Firghngs The following items were reviewed but left opened pending additional corrective actions:

• (Open) IFl 70-1151/98-05-01: Verify corrective action to resolve procedural non-compliances associated with Thermoluminescent Dosimeter (TLD) issuance, collection, and storage.

e (Open) IFl 70-1151/98-07-01: Review corrective actions to j improve timely activation and staffing of the Emergency Control 1 Center (ECC).  !

(3) Conclusions I The licensee had taken corrective actions in response to both items, but I additional actions were necessary to clearly demonstrate the i effectiveness of the corrective actions.

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h. Information Notice (IN) l (3) Insoection Scooe The inspector reviewed the following IN to determine if the information ,

had been received by the licensee:

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IN 98-20: Problems Wth Emergency Preparedness Respiratory Protection Programs.

(2) Observations and Findinas The inspector determined that IN 98-20 had been received by the licencee, distributed to appropriate personnel, and reviewed for applicability. The licensee reviewer did not identify any areas requiring actions.

(5) Conclusion The licensee's actions were appropriate.

3. Exit Interview The inspection scope and results were summarized on May 14,1999, with those persons indicated in the Attachment. The inspector described the areas inspected and discussed in detail the inspection results below. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of j these documents or processes has been deleted from this report. Dissenting comments  !

were not received from the hcensee.  !

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ATTACHMENT

- 1. ' PERSONS CONTACTED '

Licensee Personnel-

• G. ' Bullock, Conversion Team Manager .

• R. Close, Maintenance Team Manager

' Di Gadberry, Supervisor, Security .

' *S. Gantt, Senior Regulatory Engineer

• D; Goldbach,' Manager, Chemical Operations

• W. Goodwin, Manager, Regulatory Affairs

• J. Heath,' Manager, Regulatory Engineering and Operations

• R. Likes, Senior Regulatory Engineer.

• S. Mcdonald, Manager, Technical Services

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

security, and office personnel.

• Denotes those present at the exit meeting on May 14,1999.

2. INSPECTION PROCEDURES USED IP 83822 - Radiation Protection IP 88050 ' Emergency Preparedness

3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED ltem Number. Sigiga Description 70-1151/98-05-01 Open IFl - Verify corrective actions to resolve procedural non-compliances associated with TLD issuance, j collection, and storage.  ;

70-1151/98-07-01 Open IFl - Review corrective actions to improve timely activation and staffing of the ECC.  !

70-1151/99-03-01 Open IFl - Review corrective actions to ensure i consistency in the event classification for hazardous weather, 70-1151/99-03-02 Open IFl -Verify corrective actions taken to restore the onsite capability for measuring wind speed and l direction.

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4. LIST OF ACRONYMS ALARA As Low as is Reasonably Achievable

' CEDE. ' Committed Effective Dose Equivalent

'CSEP

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Columbia Site Emergency Plan 1 CY Calendar Year DDE Deep Dose Equivalent EAL' Emergency Action Level ECC Emergency Control Center ERO Emergency Response Organization IFl Inspector Follow-up item IN information Notice MDE Maximum Dose Extremity MPH Miles Per Hour

.mr/br millirem per hour -

NRC Nuclear Regulatory Commission SEP Site Emergency Plan TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter  ;

UIR Unusualincident Report  !

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