ML20216J336
| ML20216J336 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 04/15/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20216J303 | List: |
| References | |
| 70-1201-98-01, 70-1201-98-1, NUDOCS 9804210356 | |
| Download: ML20216J336 (20) | |
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l U.S. NUCLEAR REGULATORY COMMISSION l REGION II Docket No.- 70-1201 l
License No. SNM-1168 Report No.- 70-1201/98-01 Licensee: Framatome Cogema Fuels Facility: Lynchburg Manufacturing Facility Location: Lynchburg. VA 24506 Dates: March 9-27, 1998 Inspectors: A. Gooden, Radiation Specialist i C. Hughey, Senior Resident Inspector D. Seymour. Seaior Fuel Facility Inspector 1
Accompanying ;
Personnel: S. Rohrer, Radiation Specialist l Approved By: E. McAlpine. Chief Fuel Facilities Branch Division of Nuclear Materials Safety l 1
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9804210356 980415 PDR ADOCK 07001201 C PDR .
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1 i EXECUTIVE SUMIMRY Framatome Cogema Fuels {<
70-1201/98-01
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l' This routine unannounced inspection involved a review of the licensee's actions for decommissioning of the wet weather stream: ana an evaluation of the licensee's emergency preparedness program state of readiness. The report i includes inspection efforts by three regional based inspectors. !
Emeraency Preparedness e The independent audit was detailed and provided a critical assessment of I AS-1106 Emergency Procedure (98-01. Section 2.a.3).
e Emergency Procedure AS-1106 provided inconsistent guidance regarding l notification to State and local authorities following an emergency declaration (98-01. Section 2.b.3).
e A non-cited violation (NCV) was identified for failure to complete respirator certification in accordance with Procedure SL-1140 (98-01.
Section 2.c.3).
e The current drill program was ineffective in testing the ability of the emergency organization to assess accident conditions and make a timely and correct emergency classification (98-01. Section 2.e.2).
e Drill critiques were candid. detailed, and fault finding assessments 1 (98-01. Section 2.e.2).
- A NCV was identified for failure to perform equipment maintenance in accordance with Procedure AS-1130 (98-01. Section 2.f.2).
e Improvements were necessary in management controls to ensure that the emergency response equipment was properly maintained (98-01.
Section 2.f.2).
Wet Weather Stream Decommissionina e The Nal gamma walkover surveys, the in-situ gamma spectroscopy surveys, i and the soil sampling, of the affected area surrounding the wet weather 1
stream, were performed in accordance with NUREG/CR-5849 (draft). Manual for Conducting Radiological Surveys in Support of License Termination (98-01. Section 4.c).
l e Instrumentation was properly calibrated prior to use, and the I technicians conducting the survey were professional, and knowledgeable of the survey methodology and the use of the instrumentation (98-01. ,
Section 4.c). l l
Attachment:
, Persons Contacted and Exit Interview l List of items Opened. Closed, and Discussed List of Acronyms
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REPORT DETAILS i l
- 1. Summary of Plant Status l During the assessment period, fuel assembly was shutdown, but normal rod l production, and typical activities for the service equipment l
refurbishment facility (SERF) were ongoing.
A routine inspection of the licensee's material control and l accountability program was conducted March 9-12, 1998, by inspectors l from the Office of Nuclear Materials Safety and Safeguards (ONMSS).
- 2. Emeraency Preoaredness(88050) (F3)
- a. Review of Proaram Chanaes (F3.01) l (1) Inspection Scope l
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l l Changes to the emergency response program since the last i
! inspection were reviewed to determine the effectiveness of l the program, and to verify that procedural changes were reviewed and approved by plant management. The adequacy of the emergency preparedness audit program was reviewed.
(2) Observations and Findings !
l Since the last inspection of the emergency response program ;
l (June 1995). several key organizational changes were made. !
l The position Manager Safety and Licensing was reassigned l effective August 1996: effective May 28, 1997, a new Plant l Manager was announced: and effective September 1997, a newly appointed Emergency Officer (EO) was designated. The aforementioned changes resulted from either resignation,
! promotion, or reorganization of the management structure.
l The E0 position, is assigned the day-to-day responsibility l for emergency planning. The current E0 has collateral duty l as the Health Physicist for activities associated with the j SERF program. The Manager, Safety and Licensing is assigned management oversight for the emergency program in addition to serving as the Alternate E0: and the Plant Manager
, assumes overall control during an emergency. The inspector l
reviewed documentation, and interviewed two of the newly assigned personnel regarding the stai.us of emergency response training and past experience in emergency preparedness. The inspector determined that training was primarily limited at this time to the required site emergency organization training for the E0. The primary E0 indicated some experience was attained previously as a member of the exercise scenario development team at a
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nuclear power plant. However, no formalized training in i emergency preparedness had been previously obtained. The E0
- indicated that potential training provided by private and/or ,
I governmental groups had been identified and was under {
consideration. )
i Regarding procedures equipment, and facilities, changes were made to Procedure AS-1106 entitled " Emergency '
Procedure." The referenced procedure outlined the actions to be taken by the emergency organization in response to any site emergency. The licensee was granted an exemption from maintaining a NRC approved Plan. In lieu of the NRC approved Plan, Procedure AS-1106 addressed the key areas of emergency preparedness. Procedure AS-1106 was periodically revised to reflect changes resulting from inspections.
l audits, drills, etc. The inspector noted from the record of revision pages a significant number of changes were made since the June 1995 inspection. However, the current E0 was not involved with emergency planning at the time and the l inspector was unable to fully discern all of the changes and l the basis for changes. Additional details associated with ;
the review of Procedure AS-1106 are included below in Section 2.b.2.
l Section 2.6 of the license application requires an annual l review of the Health and Safety procedures for technical correctness and applicability. Accordingly, the inspector examined this area to determine if the licensee had l performed an audit of Procedure AS-1106 which implements the i emergency response program and evaluated any significant !
l changes to AS-1106 on the emergency preparedness program.
l The inspector reviewed documentation from a quarterly j independent audit performed during January 28. 29. and February 3. 1997, by a Radiological Engineer from Framatome Technologies Incorporated. The audit included approximately l fourteen (14) hours reviewing procedures. records checking inventories, and conducting interviews with essential personnel. The audit appeared to be a very detailed review of procedures. Numerous procedural recommendations were '
provided to the licensee for incorporating into the next revision of AS-1106. Recommended changes were considered program improvements. The inspector noted that observations and comments from the audits and/or NRC inspections were captured as quality action reports (OARS) and assigned tracking numbers for follow up by the Quality Assurance (0A) group. According to the licensee contact, monthly reports were issued indicating the item status as opened or closed.
As verification, the inspector examined a OAR issued in l
3 response to a recent NRC report. This aspect of the licensee's program was a very formalized system for tracking and providing management with a status summary of the corrective actions. However, prior to the fourth quarter of 1997 observations and comments from the Emergency Team quarterly drills were not assigned to individuals and tracked for follow-up and/or corrective actions. A formal system was implemented during the fourth quarter 1997, referred to as the " Action Register." and includes the following details: action item individual assigned responsibility date due. item status, and comments. See Section 2.e of this report for further discussion regarding the lack of a tracking system for issues resulting from quarterly drills. The effectiveness of the Action Register commitment tracking system will be reviewed during a future inspection.
(3) Conclusions Since the last inspection. changes to Procedure AS-1106 were reviewed and approved in accordance with license and procedural requirements. The independent audit was detailed and provided a critical assessment of the emergency response program implementing procedure (AS-1106 Emergency Procedure).
- b. Implementina Procedures (F3.02)
(1) Inspection Scope In lieu of a NRC required Emergency Plan (exemption granted April 1994), the inspector reviewed licensee procedures governing the implementation of the emergency response program. Changes to Emergency Procedure AS-11CS were reviewed to determine the effectiveness on the emergency response program, and to verify the adequacy of procedure in the implementation of emergency acti es.
(2) Observations and Findings l Three procedures were reviewed in detail by the inspector:
I e AS-1106 " Emergency Procedure." The referenced l procedure outlined the actions to be taken in the event of a plant emergency. The inspector noted that the procedure did not appear to be very user-friendly due to the layout, and contained a significant amount of redundant information which may delay the user in
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! procedure was inconsistent in addressing the offsite notifications - 1) Section 3.0 read " Local State, and Federal authorities shall be notified as a courtesy and kept informed if their area of jurisdiction is affected by the incident:" 2) Section 16.15 read
" Determine if local. State or Federal offsite agencies should be notified; and Note: Typically notification l is not required: Notification would be as a courtesy;"
and 3) Section 19.14.1 stated " Perform offsite agency notifications when Emergency is declared." The exception to the aforementioned inconsistencies was in the event of an Alert (due to the loss of criticality control), or a Site Area Emergency (due to a '
criticality). Section 3.0 included a requirement that NRC must be notified. The inspector discussed as an area requiring corrective actions the inconsistency and lack of definitive criteria for procedure users in determining when offsite notifications (State / locals) were necessary. In response to the inspector's comments, the licensee provided internal review documentation which disclosed similar comments as noted by the inspector. The licensee indicated that i the procedure would be revised by September 30, 1998, to reflect comments from the audit discussed in Section 2.a and comments from members of the emergency organization. The inspector indicated that the
- enhancements to Procedure AS-1106 to include a i
consistent criteria for notifications to offsite agencies (State, local, and federal) was considered an inspector follow-up item (IFI 70-1201/90-01-01).
a AS-1130 "LMF Emergency Equipment Maintenance." The referenced procedure provided adequate guidance to personnel for ensuring that emergency equipment was maintained in a state of readiness. AS-1130 was l utilized by several response teams (HazMat. Fire Brigade. First Aid, etc.) in performing periodic l equipment maintenance. The procedure adequately addressed equipment / supplies inventory, equipment test {
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consistent with standards for periodic equipment maintenance and surveillance.
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5 e SL-1140 " Employee Safety Training." SL-1140 described the site training requirements for all workers and visitors. In addition, the procedure delineated the type and frequency of training for personnel assigned to the emergency response organization as discussed in Regulatory Guide 3.67 and 10 CFR 70.22.
Regarding changes to Emergency Procedure AS-1106, the inspector noted from the errata sheet that most of the changes were as follows: updates resulting from f organizational changes; the removal of NNFD as an offsite i support group: corrected grammatical errors; and procedural i clarifications regarding the status of utility service I (gas / electricity) during an event. The aforementioned '
changes did not appear to reduce the state of readiness or program effectiveness. As a change to the procedures program, the licensee was transitioning procedures from assignment to Health and Safety (designated by AS categorf) to Safety and Licensing (designated by SL category). For example. AS-1101 was replaced by SL-1140 under the transitioning process.
The inspector verified that a current copy of Emergency Procedure AS-1106 was available at the Emergency Operations Facility (EOF).
(3) Conclusion Based on interviews and the review of documentation, the inspector determined that the procedures selected for review provided adequate guidance for maintaining a response capability. However, the resolution of organization of information and inconsistent guidance in Emergency Procedure AS-1106 reg 6rding offsite notification warrants attention and will be tracked as an IFI (IFI 70-1201/98-01-01).
Procedures used for program implementation were maintained current and up-to-date. Revised procedures reviewed by the inspector did not appear to result in a decrease in the state of readiness.
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- c. Trainino and Staffino of Emeroency Oraanization (F3.03) i 1
(1) Inspection Scope Emergency response training was reviewed to determine if the .
l licensee had provided training to response personnel in l i
accordance with Section 9.0 of Procedure SL-1140. Employee i l Safety Training. and Section 25.0 of Procedure AS-1106,
! Emergency Procedure.
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l l (2) Observations and Findings j The inspector requested training records for calendar years (CYs) 1996 and 1997 for randomly selected individuals l assigned to the current Emergency Team Roster to verify that
! training was up-to-date. Based on the review of training j attendance sheets, physical exams, training course outline, l
l training database, and interviews with personnel assigned )
the responsibility for Emergency Team training, with one 1 l exception the required training was current. The exception j l involved several individuals assigned to the Fire l Brigade /HazMat team who failed to attend respiratory ;
i protection training and two members who failed to complete a l respirator physical during CY 97 in accordance with Procedure SL-1140. Section 8.6.3 of Procedure SL-1140 l required that respiratory protection training and a respirator physical must be completed annually. In response to the inspectors observations, the licensee conducted respiratory protection training during the inspection period (March 13, 1998) and two individuals were scheduled for l respiratory physicals on March 16, 1998. Subsequent to the exit meeting (March 13, 1998) with plant management to
, discuss the inspection findings, a Group kaining Record form was located by the licensee (dated March 31, 1997) to
( show selected individuals had attend respiratory protection l
training on March 31, 1997. When questioned regarding
- details to corroborate the status of the expired respiratory l physicals, one indivioual was confirmed as having been
! certified during 1997 and the remaining individuals' last l
respiratory physical was during CY 96. According to the licensee, appointments were made with the attending physician for administer Mg the physical examination but l
personnel failed to comply with the appointments. The inspector informed the licensee telephonically on March 17 and 20, 1998, that the respiratory protection training issue was resolved. 'The licensee indicated that the individual successfully completed the physical and medical review for respirator certification on March 16, 1998. The inspector
7 informed the licensee that the failure by one member of the brigade to complete a respirator physical in CY 97 was considered a violation of minor safety and environmental concern and was being treated as a non-cited violation (NCV) consistent with Section IV of the NRC Enforcement Policy and therefore will not be subject to formal enforcement action (NCV 70-1201/98-01-02: Failure to complete respirator physical in accordance with Section 8.6.3 of Employee Safety Training Procedure SL-1140).
The licensee conducted quarterly training using various accident scenarios to challenge the first aid, fire origade, and radiological monitoring teams. The critiques conducted following the drills provided the licensee with good performance based comments to improve the response program.
(3) Conclusions One NCV was identified for failure to complete respiratory certification in accordance with procedural requirements.
The critiques conducted following the quarterly training drills provided the licensee with good performance based comments to improve the response program.
- d. Offt!!r Sucoort (F3.04)
(1) Inspection Scope Licensee activity in the areas of training, agreements, and exercises, was reviewed to determine if the licensee was periodically involving offsite support groups (2) Observations and Findings
- Discussions were held with members of the licensee's staff regarding the coordination of emergency planning with offsite support agencies. In response, the inspector was provided for review a recently executed aareement letter with the Concord Volunteer Fire Department (VFD) dated March 3, 1998. The licensee indicated that a site familiarization tour was planned for Concord VFD at an undetermined date during CY 98. No other offsite support training and or coordination had been scheduled. The inspector questioned the licensee regarding what, if any, contact with the Lynchburg General Hospital since the last inspection of this area. The licensee stated that no agreement was in effect and no contact had been established at this time.
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i3) Conclusions 1 The licensee was proactive in establishing communications with the Concord VFD.
- e. Drills and Exercises (F3.05)
(1) Inspection Scope l
This area was reviewed to determine if the licensee was conducting evacuation drills and biennial exercises in accordance with Section 25 of Procedure AS-1106 and Section 9 of SL-1140: and if offsite organizations were invited to participate. Section 9 of Procedure SL-1140 required the emergency response organization to participate ]
biennially in an emergency exercise.
(2) Observations and Findings l l
Sections 25.2 and 25.3 of Emergency Procedure AS-1106 addressed the licensee's drill requirements. Section 25.2 '
required a plant evacuation dril? to be conducted annually.
Since the CY 95 inspection, evacuation drills were conducted annually in 1996 (December 16, 1996) and 1997 (December 30, 1997). Regarding the biennial drill commitment in Section 25.3 the inspector reviewed documentation to show biennial drills were conducted during 1995 and 1997. The 1995 biennial drill was conducted on November 29. 1995, and during 1997, the licensee took credit for a quarterly drill as fulfilling the requirements for a biennial drill. The inspector reviewed scenario details and critique items which resulted from the drills, and noted that the drill critiques were detailed, candid, and critical assessments of the response to the postulated accidents. However, the inspector also noted that the scenarios used for the biennial and/or quarterly drills did not include as an objective the classification of an emergency. The inspector determined that the current drill program was ineffective in testing the ability of the E0 and/or other members of the t emergency organization in making timely and correct I emergency classifications. In addition, the inspector j determined that the curr.ent concept of a biennial drill was I ineffective in testing the integrated capabilities and key I elements of the emergency response program (emergency classification offsite notification, exposure control, offsite coordination, etc.).
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, In response to the inspector's comments, the licensee issued i 0AR 98-17 to develop a scenario for biennial drills which
! would test key elements of the response program, and include
! periodically as a drill objective, the classification of an l emergency to ensure that emergency personnel can promptly and correctly classify the event.
j As discussed above, critiques were effective in the l identification of items requiring corrective actions. 1
- However, a lack of management oversight and a formal 4 tracking system prior to the fourth quarter 1997 resulted in corrective actions not being implemented and tracked to resolution. For example, there were repeat critique I
comments during CYs 96 and 97 drills ineolving pager activation problems by security personnel, and an inoperable i
fire truck. Corrective actions were identified but never implemented. Consequently, the adequacy of the licensee *s management control program for tracking and correcting deficiencies (Action Register) resulting from' drills and exercises will be tracked as an IFI (IFI 70-1201/98-01-03).
(3) Conclusions The current drill program was ineffective in testing the
, ability of the emergency organization to assess accident conditions and make a timely and correct emergency classification. The drill critiques were candid, critical assessments of the team response, and were effective in the identification of response problems and areas requiring corrective actions. However, the licensee's program for tracking and correcting deficiencies resulting from drills and exercises requires improvement.
- f. Emeraency Eauioment and Facilities (F3.06)
(1). Inspection Scope The EOF and equipment were inspected to determine whether the licensee's facilities, emergency response equipment, instrumentation, and supplies were maintained in a state of i operational readiness. i l (2) Observations and Findings The E0F and equipment was checked for operational readiness and operability. The E0F. although cluttered with l l equipment. appeared to be in a state of readiness for j staging key components of the organization. The inspector l
10 observed a member of the licensee's staff using communications equipment inside the E0F with no problem.
Radiation survey instruments were calibrated and responded properly to both battery and radioactive source checks.
Self-reading dosimeters stored in the EOF were also verified as being available for issuance to response personnel.
During the EOF tour, the inspector reviewed two copies of the Emergency Procedure AS-1106 used during emergencies for event classification and notification and determined that one of the two copies was a current version. When questioned by the inspector, the licensee contact indicated that the outdated copy was assigned to the previous Fire Brigade Team Captain who was no longer with the company.
The inspector informed the licensee that the superseded copy required updating as a control copy or discarding. Prompt actions were taken by the licensee to remove the outdated copy. The surveillance documentation for the evacuation alarm system was reviewed for CYs 96 and 97 to determine if l the system was functionally tested in accordance with
! procedure. Documentation showed that a functional test was l performed semiannually on the system in accordance with Procedure AS-1130 (LMF Emergency Equipment Maintenance).
h l Regarding respiratory protection equipment, the inspector l examined several cartridge type face masks and cartridges l for readiness. No problems were noted. The inspector also requested and observed the monthly performance test by the 1 Fire Brigade Captain on selected self-contained breathing l apparatus (SCBA) units. Each of the SCBA units appeared to i conform with the requirements in 29 CFR 1910.134, and were checked in ac' ~ dance with the criteria in Procedure AS-1130. As an additional verification of SCBA maintenance, i the inspector reviewed surveillance documentation covering ,
the period of January 4. 1996 through January 1998. It was '
l noted that SCBA units were not being checked in accordance l
with Procedure AS-1130 as eviden:ed by the following: 1
- 1) during period January thru Marc 5 1996, one unit was !
regularly omitted: 2) during perioe April thru August 1996, two units were regularly omitted: 3> during the period September and October 1996 four of ten units were omitted i from surveillance: and 4) during period November 1996 thru November 1997. one or more units were omitted from the AS-1130 surveillance checks. Section 8.1 of Procedure AS-1130 requires "each of the SCBA units used for emergency response be tested and inspected monthly to ensure proper operation."
In response to this finding the current Fire Brigade Team Captain indicated that previously. each brigade member was ;
assigned the responsibility for maintenance of individually l
11 assigned units. However. as of December 1997, the Fire Brigade Team Captain on a monthly basis verifies that units are checked.
One other aspect of fire brigade equipment that was not maintained in accordance with procedures was the fire brigade truck. Procedure AS-1130 required on a monthly basis that the fire truck engine be operated, and driven five to ten minutes, including a check of all fluids.
Contrary to procedure requirements there was no indication that the truck was driven during CYs 96 and 97 based on surveillance documentation. In addition, as discussed above in Section 2.e. a regular critique comment during CYs 96 and 97 was the inoperability of the fire truck. In response to the inspector's finding, the licensee indicated that a replacement vehicle was available from the facility maintenance group but delivery to the emergency response program was pending arrival of the new maintenance vehicle.
The inspector was also informed that interim measures were in place such as use of the security vehicle and a trailer supplied with the appropriate fire fighting equipment. The Manager. Safety and Licensing discussed the implementation of the Action Register tracking system to include all emergency response surveillance commitments to assure the proper state of readiness is being maintained. Prior to the exit meeting, the licensee demonstrated that the fire truck would start. The inspector informed the licensee that the findings involving the SCBA units and the fire truck were two examples of failure to maintain emergency equipment in accordance with Procedure AS-1130 and was considered a violation of minor safety and environmental concern. This minor violation is being treated as a NCV consistent with Section IV of the NRC Enforcement Policy and therefore will
, not be subject to formal enforcement act. ion (NCV 70-1201/98-l 01-04: Failure to perform emergency equipment maintenance in accordance with Sections 8.1 and 14.1 of CNFP Emergency Equipment Maintenance Procedure AS-1130).
(3) Conclusions Based on facility tours and surveillance documentation, the inspector concluded that the licensee's emergency response I
equipment required some additional oversight and management controls to assure that equipment was properly maintained.
One NCV was identified for failure to perform emergency equipment maintenance in accordance with procedures.
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- 3. Information Notice
- a. Inspection Scope The inspector reviewed the Information Notice (IN) 97-23.
Evaluation And Reporting Of Fires And Unplanned Chemical Reaction Events At Fuel Cycle Facilities, to determine if the information had been received by the licensee.
- b. Observations and Findings The inspector determined that the IN was received by the licensee, and reviewed for applicability. The licensee indicated that the lack of chemicals in significant quantities onsite did not require any further actions.
- c. Conclusions The licensee's actions to review and assess applicability were appropriate.
- 4. Wet Weather Stream Decommissionina (88014) (R2.07)
- a. Inspection Scope Until December 1987, uranium contaminated liquid effluents generated from the manufacturing operationt ce released into the wet weather stream. From March 16 to March 26, 1998, the I inspector reviewed documentation and observed acti.ities associated with the survey and remediation of the contaminated wet weather stream (WWS).
- b. Observation and Findings The area to be surveyed encompassed a stream bed flowing from a fire protection reservoir on FCF property. The area was approximately 240 meters in length and increased from about 30 meters in width at the pond overflow piping (outfall) into the ,
stream bed to about 100 meters at the furthest point from the :
outfall. The stream generally flowed f rom south to north. !
The area had been marked with stakes into (approximately) 75 grids. Each grid measured 10 meters by 10 meters. The inspector selectively verified that the area had been marked in ]
i j accordance with drawing PE-1451 E. Revision 0, Discharge Stream Contamination Sampling Grid Layout. In addition, 16 references i (or background) grids had been staked adjacent to the wet weather l l
stream. i
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I 13 The inspector noted that an area about 100 meters in length near the beginning of the outfall had been nartially cleared. The i debris from the clearing remained. The remaining area downstream j was wooded, t
i The licensee had contracted with A.B.B. Environmental Services to conduct survey activities. The inspector reviewed the services contract and noted it included a 100 percent gamma walkover survey using sodium iodide (Nal) detectors, an in-situ gamma spectroscopy survey of each grided area, gamma exposure rate surveys of selected areas, and soil sampling of selected areas including those with elevated 'adioactivity levtls. The surveys were to be l completed in accordance with NUREG/CR-5849 (draft). Manual for Conducting Radiological Surveys in Support of License Termination.
The constituents of concern (C0C) were U2 ", U23 s U 236 and U 238 The surveys were conducted Ly two contractor technicians. The inspectors interviewed the technicians to determine their knowledge of the survey methodology and the use of the instrumentation involved. The technicians appeared knowledgeable in these areas.
The inspector reviewed the following contractor procedures associated with the survey activities. Concerns are discussed below. !
. Operation of the Bicron Micro-Rem Meter. Revision 0, .
March 12, 1998.
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. Surface Measurements Using the ISOCS (In-situ Object Counting System) Gamma Spectroscopy System, Revision 0, March 12. 1998. This procedure did not contain specific operating instructions for the instrument. Contractor representatives indicated that specific instructions were contained within the equipment manual provided by the manufacturer, however, the manual was not at the job site.
The inspector requested the manual be made available on site prior to beginning gamma spectroscopy surveys. The inspector later verified that the manuals had been received prior to beginning these surveys.
. 0A Program for the ISOCS High Purity Germanium Gamma Spectroscopy System. Revision 0, March 12, 1998 l
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. Operation of the Ludlum 16/44-2 Nal Detector. Revision 0.
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. Radiological Volumetric Sampling. Revision 0. March 12.1998 e Radiological Surveys. Ravision 0. March 12. 1998 Walkover Survey The inspector observed portions of a 100 percent walkover survey of the affected area. The survey was conducted using two Ludlum Model 44-2 scintillation detectors each with a one inch by one inch sodium iodide crystal. The instruments were placed in the
" slow response" mode to offset background fluctuations.
The inspector reviewed calibration documentation for the instruments and verified that both had been calibrated within the last six months as specified by ' Operation of the Ludlum 16/44-2 Nal Detector." Specific information is documented below:
. Ludlum Model 16 (Analyzer-serial no. 74100) and Model 44-2 (Gamma Scintillator-serial no. 70290) were calibrated on November 14. 1997.
- Ludlem Model 16 (Analyzer-serial no. 95364) and Model 44-2 (Gamna Scintillator-serial no. 094095) were calibrated on
- March 10. 1998.
j e Both were calibrated using National Institute of Standards and Technology traceable standards, e Quality control checks were also performed at the site prior "
l to ano after survey activities were completed each day.
l e The scan sensitivities of the instruments were 140 u picocuries per gram total uranium based on NUREG/CR-1507.
! Minimum Detectable Concentrations with Typical Radiation Survey Instrumentation for Various Contaminants and Field Conditions, j The inspector observed the walkover survey being conducted by the contractor technicians on several occasions and noted that ten 4 parallel survey passes approximately three feet apart were being l l conducted on each grid. The scan rate was more conservative (slower) than the 0.5 meters per second recommended by NUREG/CR- 1 5849. The detectors were being held within two inches of tFe l ground in accessible areas. The maximum reading for each pass was recorded. The ten maximum readings for each grid were then averaged. In addition any elevated readings above background i levels were marked on the ground with a stake and recorded.
Background levels had been previously determined by surveys of the !
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15 l predetermined reference grids adjacent to the WWS. Several areas l were noted as above background levels and were marked for further l
investigation.
l In-situ Measurements Gamma spectroscopic surveys were conducted on each grid. The detector was placed one meter above the center of each grid and a 10-minute count was collected. Measurements were also made
, directly above each area of elevated activity identified during l the walkover survey. These measurements were made at 18 inches l above the soil at the point where the highest Nal survey reading was obtained. Total uranium was determined by multiplying the reported U 235 concentration by 25 in accordance with Appendix C of ANSI Guide N13.22-1995. Bioassay Program for Uranium (assuming four percent enrichment).
Remediation of Areas With Elevated Survev Readinas Nine areas were identified during the Nal gamma walkover survey as having elevated readings. Rough field calculations indicated that six of these areas might not meet the NRC's criteria for free release. The licensee decided to remediate these six areas and l resurvey them to determine if the remediation was effective. The i inspector observed much of the remediation activities. After an area of elevated readings was identified, the contractors resurveyed the area and bounded the area containing the elevated readings. The dirt in the bounded area was removed to a depth of approximately 18 inches. The removed dirt was drummed for low level radioactive waste disposal. The grids containing the l remediated areas were then resurveyed. This resurvey included the l 100% walkover survey with the Nal, an in-situ gamma spectroscopy survey in the middle of the grid at one meter from the soil surface, and an in-situ gamma spectroscopy survey performed where the highest reading was obtained pre-remediation. at 18 inches from the soil surface. The inspectors concluded these re-surveys
, adequately represented the grids.
l l Soil Samolina Activities t
i The inspector observed soil sampling for the nine areas which had
! elevated readings. Six of the areas were sampled after remediation. In each case, a composite soil sample was taken of -
the area within the boundaries of the elevated readings (or, in I the case of the remediated areas, where the elevated readings had !
occurred). The composite sample consisted of five core samples. ]
one at the point of the highest Nal reading (pre-remediation), and i four others. A composite sample was also obtained from the areas ;
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l used for these composite samples. Five additional composite l samples were also taken from different grids with lower but l varying Nal gamma survey readings All of these samples (20 in i
! all) were split with the NRC. The inspector maintained custody of the NRC split samples through the compositing, labeling, packaging, and shipping process (the samples were shipped to an l NRC contractor for analysis on March 26, 1998). One IFI was identified to compare the licensee's split WWS soil sample results with NRC soil sample results for confirmatory measurement purposes (IFI 70-1201/98-01-05).
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- c. Conclusions The inspector observed the NaI gamma walkover surveys, the in-situ l gamma spectroscopy sur veys. and the soil sampling. of the affected area surrounding the WWS, and concluded they were performed in i accordance with NUREG/CR-5849 (draft), Manual for Conducting l Radiological Surveys in Support of License Termination.
Instrumentation was properly calibrated prior to use, and the technicians conducting the surveys were professional, and l' knowledgeable of the survey methodology and the use of the instrumentation. The licensee's final report detailing the WWS decommissioning activities and the final analyses will be sent to the Office of Nuclear Material Safety and Safeguards for review
- and approval.
- 5. Exit Interview The inspection scope and results were summarized on March 13 and 27.
1998, with those persons indicated in the Attachment. On March 20, 1998, the inspector contacted the Manager. Safety and Licensing l~ telephonically to discuss the NCV regarding the failure to complete respirator physical in.accordance with procedure. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has l been deleted from this report. No dissenting comments were received from the licensee.
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17 l ATTACHMENT INSPECTION PROCEDURES USED IP 88050 Emergency Preparedness IP 88104 Decommissioning Inspection Procedure For Fu?1 Cycle Facilities LIST OF PERSONS CONTACTED i
licensee
- T. Allsep, Health Physicist / Emergency Officer
- D. Driscoll Regulatory Compliance Officer
- G. Elliott, Manager Safety and Licensing
- D. Gordon. Senior Health Physicist R. Irvin Mechanic G. Lindsey, Health Physicist
- J. Matheson, Plant Manager
- A. McKim Manager, Quality Assurance-Health / Safety 1 1
Other Licensee employees contacted included engineers, technicians, security ,
and office personnel.
l
- Attended exit meeting on March 13. 1998
- Attended exit meeting on March 27, 1998 LIST OF ITEMS OPENED AND CLOSED Item Number Status Descriotion 70-1201/98-01-01 Open IFI - Resolve Emergency Procedure AS-1106 inconsistency regarding when to notify offsite authorities following an emergency classification (Section 2.b.3).
70-1201/98-01-02 Closed NCV - Failure to complete respirator physical in accordance with Section 8.6.3 of Employee Safety Training Procedure SL-1140 (Section 2.c.2).
70-1201/98-01-03 Open IFI - Review the adequacy of the licensee's management control system for tracking and correcting deficiencies identified during drills / exercises (Section 2.e.2).
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18 70-1201/98-01-04 Closed NCV - Failure to perform equipment maintenance in accordance with Procedure AS-1130 (Section 2.f.2).
70-1201/98-01-05 Open IFI - Compare licensee split WWS soil sample results with NRC soil sample results for confirmatory measurement purposes (Section 4.b).
LIST OF ACRONYMS USED CFR Code of Federal Regulations CNFP Commercial Nuclear Fuel Plant CY Calendar Year EAL Emergency Action Level E0 Emergency Officer EOF Emergency Operations Facility IFI Inspector Followup Item IN Information Notice ISOCS In-situ Object Counting System LMF Lynchburg Manufacturing Facility LOA Letter of Agreement Nal Sodium Iodide NNFD Naval Nuclear Fuel Division NRC Nuclear Regulatory Commisrion OA Quality Assurance OAR Ouality Action Report SCBA Self Contained Breathing Apparatus SERF Service Equipment Refurbishment Facility WWS Wet Weather Stream
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