ML20214M640

Insp Rept 70-1151/86-12 on 860728-0801.Violation Noted: Failure to Follow Requirements of Approved Radiation Protection Procedures

ML20214M640
Person / Time
Site:	Westinghouse
Issue date:	08/18/1986
From:	Hosey C, Revsin B, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214M623	List: ML20214M619 ML20214M630 ML20214M640
References
70-1151-86-12, IEIN-86-024, IEIN-86-046, IEIN-86-24, IEIN-86-46, NUDOCS 8609110208
Download: ML20214M640 (9)

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UNITED STATES f p KE!g]o NUCLEAR REGULATORY COMMISSION

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REGION ll 3 j 101 MARIETTA STREET N.W.

• ATLANTA, GEORGI A 30323

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SEP 0 41986.

Report No.: 70,-l151/86-12' Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, SC 29250 Docket No. :' 70-1151 (Fuel Division) License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection Conducted: Jul 2 1986 - August 1, 1986 Inspectors:

G. L. Troup

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N/f!dT, Date Signed JANL "6Y/4f8fo B. K. Revsin L Date Signed Accompanying Personnel: C M.psey Approved by: d! /444<_ h C.M.Hosey,SectionChieg/

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D6te Signed Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection included the areas of transportation of radioactive materials, radioactive waste disposal, radiation protection, and followup on previously identified items.

Results: One violation was identified - failure to follow the requirements of approved radiation protection procedures.

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} 3' REPORT DETAILS

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1. Persons Contacted Licensee Employees g

• W. J. Hartnett, Materials. Manager

• E. E. Keelen, Manager, Manufacturing (

• W. L. Goodwin, Manager, Regulatory Affairs. +

• E. K. Reitler, Manager, R&E Engineering

• J. W. Heath, Manager, Health Physics Operations  ;

. R. E. Fischer, Senior R&E Engineer '

R. K. Burklin, Senior R&E Engineer -

R. D. Montgomery, R&E Engineer '

B. M. Wilt, R&E; Engineer N ,

W. K. Herman, Jr., WR&D Supervisor s \

\ U Other licensee employees contacted included constructior craftsmen, and technicians. ' )' i

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• Attended exit interview ,<

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2. Exit Interview ( V, 3 s s

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The inspection scope and findings were summarized on August 1,1986, with those persons indicated in paragraph above.. The inspectors described the , ,,

areas inspe'c4.ed and discussed in detail the inspection findings. No S-'

dissentingscomments were' received from theslicensee.

Ope violett regarding the failure to follow approved radiation protection l '

' procedures, including several examples, was discussed in' detail. The m

, inspectors also em?hasized that several of the IFIs identified dealt with '?

"the need to improve procedural requirements for activities required by the

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,q Ihe licensee did not identify as proprietary any of the materials provided .

to or reviewed by the inspectors during this inspection. i a

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3. Licensee fibtion on PreYious, Enforcement Matters ~

(Closed) 86-04-01, Failtire to ship radioactive materials tanker in accordance with D0T regulations. The inspector reviewed 'the licensee's response to the Notice o N 101ation, dated April 25,1986,' upd verified that ,

• the specifkt actiens hadfbeen implemented. The inspector informed licensee i

"; management /that 'there were no furthersquestions and that thia item was .e closed.,.es

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4. Surveys (83822)

The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to maintain records of such surveys necessary to show compliance with regulatory limits.

License No. SNM-1107, Condition 9, required that licensed material be used in accordance with statements, representations, and conditions contained in Sections 2, 3, and 4 of the application dated March 26, 1984, and supplements thereto.

Paragraph 3.2.1.1 stated that written procedures describing general radiation protection requirements shall be maintained and followed.

a. Facility Surveys The inspector reviewed Regulatory Affairs Procedure, RA-201, 3"

Contamination Control, Revision 3, May 29, 1985, which specified minimum frequencies for performing facility surveys as well as action levels for decontamination of various areas. RA-201 was implemented by 4 J Health Physics Operating Procedure (HP0P)05-014, Revision 5, April 22, 3

'- 1985. Paragraph 7.5.1 of HPOP 05-014 stated that if a given smear was greater than the action level, decontamination was required within

'D* 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> .or three working shifts. The action level specified for the r.f c;tqtrolled side of the step-off-pads was 1000 disintegrations per a nnnute per 100 square centimeters (1000 dpm/100 cm2).

The inspector' reviewed the daily contamination surveys performed at the main step-off-pad from the Controlled Area. Between March 21, 1986, and July 14, 1986, 18 instances of contamination in excess of the 1000 dp/100cm2 action level for the controlled side of the i step-off-pad were documented. On these 18 occasions contamination

! level ranged from 1006 to 2071 dpm/100cm2 Decontamination was not initiated on any of these occasions. A licensee representative stated l

that verbal instructions had been issued to raise the action level for decontanmation to 3000 dpm/100cm2 during October or November 1985, and that HPOP 45-014 had not been revised to reflect that practice. The

inspector Ji.formsd the license that failure to decontaminate at levels

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required by the) procedure would be considered an apparent violation of y License Ccndition' 9 (70-1151/86-12-01).

.[n HPOP 05-014 defined daily survey as one performed five times per week.

7' The licensee indicated that even though the processing areas ran on a E, seven day'per week schedule, the HP staff was minimal on week-ends, and

? con",equently, daily surveys were relegated to Monday through Friday.

The licensee stated that they had not evaluated this practice and were unaware whether or not increased incidence of contamination were found 6

after a week-end. The licensee further stated that they would conduct an evaluation to determine whether established survey frequencies were adequate to control the levels of contamination within the facility.

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.The inspector informed the licensee that this area would be considered a followup item (70-1151/86-12-02).

b. Personal Frisking Regulatory Affairs Procedure RA-200, " Protective Clothing," Revision 5, August 6,1984, Paragraph 2.3, required that when personnel exit the Controlled Area, they are to wash their hands thoroughly and monitor per posted instructions.

Regulatory Affairs Procedure RA-203, " General Health Physics Rules and Recommendations," Revision 6, September 18, 1985, stated that posted instructions at contamination control area step-off-pads and change rooms shall be followed.

During tours of the plant, the inspector observed the exit of approximately 35 to 45 licensee and vendor employees from contamination control to clean areas to determine if frisking was performed as required". Generally, personnel picked up the probe without first frisking their hands and quickly passed the probe over hands and feet; the probe being cne to several inches from the body during the survey rather than 1/4 to 1/8 inches as required by the postings. The probe movement during the frisk was sufficiently fast that the contamination limit would not have been detected but instead, a significant amount of contamination would have had to be present on an individual in order for the instrument audible response to have indicated that an area needed additional frisking. Posted instructions at frisker stations also required that prior to frisking, personnel perform a response check of the instrument using the source attached to the top of the instrument casing. Of the individuals observed exiting from the Controlled Area, only one performed a' response check of the probe. The posted instructions also specified that forearms and lower legs be monitored. In numerous instances, individuals failed to monitor the

, areas required. The licensee was informed that failure to monitor as required by procedures RA-200 and RA-203 would be considered a second example of an apparent violation of License Condition 9 (70-1151/86-12-01).

During tours of the facility, the inspector noted that access to the cheniistry laboratory was through an office area and that the instrument I for personal frisking after handling uranium was located in the outer corridor. Consequently it was possible for an individual to become

contaminated and procee,d into the office area to work without

! monitoring for contamination. The laboratory supervisor stated that l they relied on a visual check to determine whether one had become l contaminated. Discussion with licensee representatives revealed that i

at one time a frisker station had been located at the doorway prior to i entry into the office area, but this station had been removed due to l expansion of the laboratory computer facilities. The licensee stated that the chemistry laboratory was considered a " limited" area and that frisking upon exiting such an area was not required. A review of l

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5 procedures RA-200 and RA-203, which specified the facility personnel monitoring requirements, confirmed the licensee's statement in that it did not specify monitoring requirements for personnel exiting " limited" areas. The licensee was informed that due to the above, RA-200 and RA-203 were inadequate and would be considered a third example of an apparent violation of License Condition 9(70-1151/86-12-01).

5. Internal Exposure (83822)

The licensee was required by 10 CFR 20.103, 20.201(b), and 20.401 to control uptakes of radioactive material, assess such uptakes, and to keep records of such uptakes. The inspector reviewed HP0P 04-001, Routine Urine Sampling Program, Revision 3, April 2,1985, which established routine urine sampling frequencies for individuals who worked in process areas for transportable uranium compounds. Table 1 of HPOP 04-001 specified action levels for various concentrations of uranium when detected in the urine. Between concentrations of 15 and 1000 micrograms uranium per liter, the licensee action specified was to resample and confirm the results. The licensee did not perform the urine uranium determinations onsite but sent them to an

, offsite vendor and therefore, seven to nine days were required to obtain the results. Consequently, when a routine urinanalysis showed a positive result, 14 to 18 days had elapsed before a final determination had been made that the result was true or false. During this time period, the worker was permitted to continue working and no evaluation of the exposure or cause of the exposure was required procedurally. In discussions with licensee representatives concerning an action level below 1000 micrograms per liter the licensee stated that they would proceduralize a 45 microgram per liter action level into the routine bioassay program which would trigger an evaluation of the cause and the individual's Maximum Permissible Concentration (MPC) hour assignment. The inspector stated that this would l

be reviewed during future inspections (70-1151/86-12-03).

The inspector reviewed the method for calculating MPC-hours for routine exposures to airborne radioactive materials. Routinely, MPC-hours were calculated from time weighted averages measured at fixed air sample locations and the amount of time the worker spent at each fixed air sample station. The licensee stated that the computer generated Personnel Exposure (PE) forms prior to each shift which were in turn distributed to the

! cognizant shift foremen. The shift foremen were responsible for completing l

the form at the end of each shift and for indicating the time and type of respirator usage, if any. The PE forms served as the issuance record for respiratory protective equipment although this was not stated in a procedure, nor were the requirements or methods for completing a PE form covered by a written, approved procedure. The licensee stated that these areas wouid be incorporated into procedures. This area will be reviewed during future inspections (70-1151/86-12-04).

During tours of the facility, the inspector noted that the fixed air sample station for the waste compactor in the UF6vaporization area was located on the outside of the containment structure surrounding the compactor. The licensee explained that the air sampler had been located outside the l

6 enclosure since the individual working with the compactor inside the tent always wore a respirator. The inspector stated that since the airborne radioactivity inside the tent was unmonitored, it would not be possible to know when or if the protective factor (PF) of the respirator was exceeded.

The licensee stated that historically, airborne radioactivity concentrations inside the tent had not exceeded the PF of the respirator; however, the placement of the fixed air sampler would be re-evaluated. The inspector stated that this would be reviewed during future inspections (70-1151/86-12-05).

Section 2.2.6.3 of the application required that air sampling representativeness of fixed air samplers be performed at specified intervals. The inspector reviewed the data sheets and methods used to perform these evaluations and questioned the criteria used in the evaluations. Licensee representatives stated that different methods had been tried and the comparison between the fixed sampler and a second sampler had been shown to work the best. Licensee representatives acknowledged the inspectors comments that definitive criteria for the placement evaluation and acceptance of the samplers used to verify a representativeness should be specified in the procedure. The inspector stated that this would be reviewed during future inspections (70-1151/86-12-06).

No violations or deviations were identified.

6. Respiratory Protection Program (83822)

The -licensee was required by 10 CFR 20.103 to establish a respiratory protection program if allowance for the use of respiratory protective equipment was made in estimating exposures of individuals to airborne radioactivity.

The licensee utilized an offsite vendor for cleaning and maintenance of respirators. The licensee checked a number of each type of respirator being cleaned to verify that contamination levels were within specified limits and that the physical integrity of the respirator components was acceptable.

The inspector reviewed the vendor procedure for cleaning and maintenance and the licensee checks on the vendor program between March 1, 1986, and July 1, 1986.

No violations or deviations were identified.

7. Tiansportation Activities (86740)

a. Quality Assurance Program 10 CFR 71.12 provides a general license to transport, or to deliver to a carrier for transport, licensed materials in packages for which a license or certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR 71, Part H.

7 The inspector determined that the licensee had an NRC approved quality assurance program for packaging, approved under Docket 71-0251, with an expiration date of January 31, 1990.

b. Selection of Packagings The inspector discussed the use of packages which require an NRC Certificate of Compliance (C0C) with cognizant licensee representatives. The licensee had received a renewal of the C0C for fuel shipping containers. A C0C had been issued for the licensee to ship UFg cylinders; h6els in cylinders were shipped in accordance with 49 CFR I73.417. Licensee representatives stated that no packages were used which were foreign-approved packaging which would require D0T revalidation (49 CFR 173 or 10 CFR 71.16).

The inspector determined through discussions that D0T Spec 55 containers were not used and the licensee was a n of the prohibition of use (49 CFR 173.415(b)), that no plutonium shig ints had been made nor were planned to be made by air (10 CFR 71.88), and the licensee did not rely on s ecial form determinations to quality shipments (49 CFR 173.469 .

c. Preparation of Packages and Delivery to Carrier The inspector determined froia review of applicable procedures, review of shipping checklists and review of shipping papers, as well as discussions with licensee representatives, that the following requirements were applied:

Routine use of container (10 CFR 71.01)

Liquid package requirement (49 CFR 173.412(n))

Package weight (49 CFR 173.411)

Package marking (49 CFR 172.300 et. seq.)

Radiation surveys (49 CFR 173.441)

Bracing of packages (49 CFR 173.442)

Shipping paper documentation (49 CFR 172, Subpart C)

Notification of consignee (10 CFR 20.311)

d. Shipping Papers The inspector reviewed the shipping documents for three shipments of radioactive waste to a disposal site. The waste manifest and description of materials on the Bill of Lading indicated that only waste and solidified wastes had been shipped. However, the Bill of Lading indicated that " flammable solid" labels and placards had been applied. Licensee representatives explained that a standard Bill of Lading was used, which includes a category of waste which was classed as a " flammable solid (UN1932)"; when that material is shipped, then the labels and placards are applied. For the material actually shipped, these labels and placards were not applied nor required.

During the inspection, licensee representatives initiated a change to

8 the Bill of Lading standard printout to make it clear which labels and placards actually were required and were applied to a given shipment.

No violations or deviations were identified

8. Radioactive Waste Management (84850)

a. Waste Manifests 10 CFR 20.311(b) and (c) require that a manifest system be used for all shipments of waste to a licensed burial facility. The inspector determined that the manifests had been completed and forwarded as required for the three waste shipments reviewed.

b. Waste Classification, Characterization, and Labeling 10 CFR 61.55 requires that waste be classified and identified as Class A, B, and C. The inspector reviewed the isotopic survey results for containers in three waste shipments and determined that the classifications shown on the manifests were in agreement with 10 CFR 61.55.

c. Tracking of Shipments The Radioactive Material Shipment procedures and checklists included provisions for determining the estimated date of arrival of the shipment, and written and telephone notification nf the receiver. The inspector verified that the three waste shipments had been verified as having been received at the disposal site. The licensee's procedures included a seven day receipt requirement by the receiver and provisions for tracing the shipment if notification of receipt is not received.

No violations or deviations were identified.

9. Radioactive Solid Waste (88035)

! a. The inspector reviewed the procedures, shipping records and license l requirements for shipments of radioactive waste to the disposal site.

l Regulatory requirements in 10 CFR 20.301 and 10 CFR 20.401 for the i disposal of waste were also reviewed.

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b. 10 CFR 20.304 specified the general requirements for disposal of waste by burial in soil. Licensee representatives stated that no disposals have been made under the provisions of this regulation.

No violations or deviations were identified.

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10. 'IE Information Notices (IEN) (92717)

The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, had been taken.

IEN 86-24 Respiratory Users Notice: Increased Inspection

Frequency for Certain Self-Contained Breathing Apparatus Air Cylinders IEN 86-46 Improper Cleaning and Decontamination of Respiratory Protection Equipment

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