ML20237E591

Insp Rept 70-0371/87-08 on 871102-06.Violation Noted.Major Areas Inspected:Internal Exposure Controls & Implementation of Radiation Program

ML20237E591
Person / Time
Site:	07000371
Issue date:	12/11/1987
From:	Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237E575	List: ML20237E572 ML20237E587 ML20237E591
References
70-0371-87-08, 70-371-87-8, NUDOCS 8712290073
Download: ML20237E591 (4)

Text

m:

?

' t J' 1

l U. S. NUCLEAR REGULATORY COMMISSION REGION I .

Report No. 87-08 Docket No.70-371 ,

License No. SNM-368 Priority 1 Category UHFF f-3 f

Licensee: UNC Naval Products Division 67 Sandy Desert Road ,

Uncasville, Connecticut 063iff A i ~

Facility Name: UNC Naval Products ,

Inspection At: Montville, Connecticut Inspection Conducted: November.2-6, 1987 l

M Mq M Inspectors: 47//o/8 7 ,

Robert'toesch, Radiation Specialist

' date Approved by: M g,d/[/(

date

~J Mohamed Shanbaky, Chief f l Facilities Radiation Protection Section Inspection Summary: Inspection on November 2-6, 1987 (Report No. l 70-371/87-08). i y ,

]

Areas Inspected: Routine, unannounced inspection of the licensee's radiation i protection program. The following areas were reviewed: internal exposure '

controls and implementation of the Radiation Protection Program.

5 Results: One violation was identified, failure.to have approved Health Physics Procedures, i

l l

l p C C

.i_ . ._ a - -_- a

1 t

i

'?

.. )

~

DETAILS 1.0 Personnel Contacted

• N. Kaufman, President, UNC Naval Products

"~ >

l *G. Waugh, Executive Vice President, Operations

• W. Kirk, Manager, Nuclear and Industrial Sasfety l

• R. Greg,' Director, Technical Services j

• D. Luster, Specialist, Health Physics & Environmental Control  !

g~

• Denotes attendance iat the exit interview on November 6, 1987.

2.0 Purpose '

The purpose of this routine, unannounced inspection was to review the l licensee's radiation protection program with respect to the following

. elements:

! r i l

- Implementation of the Radiation Protection Program Internal Exposure Controls 3.0 Jgplegentation of the Radiation Protection Program The. lit.ensee's program for the control of radioactive materials; posting and labeling of areas; airborne and radiation monitoring; and minimizing contamination to mair.tain personnel exposures as low as is reasonably achiev:3ble (ALARA) was reviewed against criteria contained in:

- 10 CFR 20;

- SNM-368, Chapter 4, " Health Physics Standards";

l Regulatory Guide 8.24 " Health Physics Surveys during Enriched Uranium-235 Processing and Fuel Fabrication"; and

- ANSI N7.2-1963, " Radiation Protection in Nuclear Reactor Fuel l Fabrication Plants".

l The licensee's performance relative to the above criteria was determined by:

- observations made during tours of the facility;

- . review of selected air sample records for Building "B" South;

- review of selected records of HEPA filter D0P tests;

~ review of selected Special Work Permits (SWPs); and

- discussions with licensee personnel.

Withfu the scope of this inspection, the following violation was identi-fied.

t.

The inspector noted that, no approved Health Physics procedures for performing and documenting compliance with 10 CFR 20 were available.

Lack of formalized procedures has been previously brought to the licensee's attention in Inspection Reports 83-04, 85-09, and 87-03. The s

' - _ - - _ - - _ _ _ _ . _ _ _ - _ _ _ _ _ ~

3 licensee stated that draft procedures were almost complete, but were progressing slowly pending the completion of higher priority tasks. This was also the licensee's position as stated in Inspection Report 85-09.

Although several " Task Instructions" were available to the Health Physics staff, all were unapproved, draft copies, several with extensive crossouts and hand written changes. The inspector stated that failure to use approved written procedures to comply with all applicable regulations in 10 CFR 20 is an apparent violation of your license, SNM-368, Section 4.1 (Item No. 70-371/87-08-01).

All ventilation systcms installed with HEPA filters are periodically monitored for loading and changed out prior to reaching a differential pressure of four inches of water. Maintenance personnel perform D0P tests on all newly installed filter systems to verify adequate performance. HEPA filters require a minimum efficiency of 99.95% as specified in license SNM-368. Inspector review of the logs indicated that filter subsystems E-34 and E-39A, located in the 'B' Building Unit 2 area, had both been placed in service without adequate review of the filter efficiency test results. Subsystem E-34 was tested August 19, 1986, at 99.88% and subsystem E-39A on March 12, 1986, at 99.84%.

Inspector discussions with the Health Physics technicians indicated that although they were aware of the 99.95% requirement, the minor discrepancy in the test results was not identified. When this item was brought to the licensee's attention, iroediate corrective action was taken to assure that the filter subsystems will have the required efficiency, hon-routine jobs are performed under a "Special Work Permit "(SWP).

Fart I is completed by the requesting authority, Part II by either the Electrical or Maintenance Groups and Part III by Health Physics. The inspector noted that of the 81 SWP's issued to date for 1987, several did not contain job descriptions in Parts 1 & II with adequate detail to allow the Health Physics technicians to properly evaluate the proposed job. The licensee stated that if any job description was lacking in detail, the technicians would call the requester for additional informa-tion prior to issuing the SWP. The inspector noted that all available information was not routinely documented on the SWP form. The licensee stated that additional information as to the specific nature and location of tasks will be documented on future SWPs.

4.0 Internal Exposure Controls The licensee's program for monitoring the internal exposure of their personnel was reviewed with respect to criteria contained in:

10 CFR Sections 20.103, 20.108 and 20.401; SNM-368, Section 4.2.3, " Bioassay Program";

Regulatory Guide 8.11, " Applications of Bioassay for Uranium"; and

- ANSI N7.2-1963, " Radiation Protection in Nuclear Fuel Fabrication Plants."

l 4

l l

The licensee's performance relative to the above criteria was determined by:

- discussions with licensee personnel;

- review of selected whole body counting records;

- review of urinalysis results for selected individuals and vendor QC checks; and

- review of process air sample results.

Within the scope of this inspection, no violations were identified. No.

significant uptakes of radioactive materials were measured by urinalysis or by whole body counting. The following weakness was identified.

The licensee utilized two outside vendors for support of their bioassay program, one for uranium lung counting, the other.for urinalysis. As a check on vendor quality, the licensee has periodically spiked both acidified water and normal urine samples using a standard obtained from New Brunswick Labs. Samples submitted in 1984 were reported, on the average,15% to 30% low for the water samples and a factor of 2-4 low for the urine samples. The licensee again tested the vendor lab in 1986.

The water standard results improved, but the spiked urine samples were again reported low, this time by a factor of approximately 100. Although the licensee was aware of the results, no actions were underway to determine the cause of the anomalous results. In an effort to resolve this discrepancy, the licensee has committed to participate in a split sample cross comparison between their vendor and Idaho National Labs.

This item is left unresolved and will be reviewed in a following inspec-tion (Item No. 87-08-02).

5.0 Exit The inspector met with the licensee's representatives (denoted in Para-graph 1) at the conclusion of this inspection on November 6, 1987. The l inspector summarized the purpose and scope of the inspection and findings as described in this report.

J I

l l

l l

_