ML20010H134
| ML20010H134 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 02/19/1981 |
| From: | Goodwin W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20010H133 | List: |
| References | |
| FOIA-81-256 NUDOCS 8109230718 | |
| Download: ML20010H134 (1) | |
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Drav.cr R Cotumb a ScumCa:olina?9250 833 776 ?610 February 19, 1981 U. S. Nuclear Regulatory Cortmission Attn:
Mr. J. P. Stohr, Chief Region II Fuel Facilities and Materials Safety Branch Of fice of Inspection and Enforcement 101 Marietta Street, N.W.
Suite 3100 Atlanta, Georgia 30303 RE: RII:RLW 70-1151/80-29 Gentlemen:
Ir. response to your letter of February 6,1981, concerning your inspection of our facilities conducted November 4,1980, we have reviewed the subject inspection report and find that no proprietary information is identified.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION W. L. Goodwin, Mar,;er Regulatory Compl.:nce WLG:lb
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In Reply Refer To:
RII:CMH 70-1151/79-2 Westinghouse Electric Corporation ATTN:
M. D% ore, Manager Columbia Plant Nuclear Fuel Division Dr:2wer R g
Columbia, South Carolina 20205 Mi Gentlemen:
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Thank you for your letter of March 27, 1979, informing us of steps you have taken to correct the item of noncompliance concerning activities under NRC License No. SNM-1107 brought to your attention in our letter of March 7, 1979. We vill examine your correctiva actions and plans during subsequent inspections.
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We appreciate your cooperation with us.
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Fuel Facility and Materials Safety Branch M
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Local Public Document Room Washington Public Document Room Central Files Nuclear Safety Information Center
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State of South Carolina
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Electric Corporation March 27, 1979 U. S. Nuclear Regulatory Comniission ATTN: Mr. J. T. Sutherland, Chief Region II Fuel Facilities and Materials Safety Branch Office of Inspection and Enforcement 101 Marietta Street, Suite 3100, Atlanta, Georgia 30303 RE: RII: GLT 70-1151/79-2 Gentlemen:
In response to your letter of March 7, 1979, concerning your inspection of our facilities conducted January 30-February 2, 1979, and pursuant to the provisions of 10CFR2.201, the following comments are made:
All missing and/or detached warning signs hava been replaced on the outside UF6 bay door in question.
The Columbia Plant is now in full compliance with the requirements of 10CFR20.203(e) and Condition 12 of License SNM-1107.
In order to minimize the possibility of further noncompliance in this regard, the use of more permanent and durable warning signs on all plant access doors is being investigated.
For example, the use of metal, painted and stencilled signs is being considered for certain doors.
Our investigation should be completed and any program changes imple-mented by April 30, 1979.
In the interim, we will continue to conduct frequent audits to ensure compliance with all applicable posting re-quirements.
From our review of your inspection report, we have concluded that no proprie-tary information is identified.
We trust you find the above comments responsive to your letter.
If you have any questions regarding this matter, please write me at the above address or telephone me at (803) 776-2610.
Sincerely,
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In Reply Refer To:
RII:GLT 70-1151/79-2 Westinghouse Electric Corporation ATTN:
Mr. M. D' Amore, Manager Columbia Plant Nuclear Ft.el Division Drawer R Columbia, South Carolina 29205 1
m Centlemen:
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This refers to the inspection conducted by G. L. Troup of this office on
- ~9 January 30- February 2, 1979, of activities authorized by NRC License No.
SNM-1107 for the Columbia Fuel Fabrication facility, and to the discussion of our findings held with Mr. W. J. Hartnett at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report. Within these areas, the inspection consisted of ul selective examinations of procedures and representative records, interviews
$h'l with personnel, and observations by the inspectors.
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We have examined actions you h' ave taken with regard to previously reported unresolved items. The status of these items is discussed in the enclosid report.
During the inspection, it was found that certain activities under your license j
appear to be in noncompliance with NRC requirements. This item and references to pertinent requirements are listed in the Notice of Violation enclosed here-o:.'
with as Appendix A.
This notice is sent to you pursuant to the provisions of I
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Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within 20 days of your receipt of this notice, a written statement or expla-nation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further noncompliance; and (3) the date when full compliance will be achieved.
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'EP In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, M
Title l'0, Code of Federal Regulations, a copy of this letter and the enclosed H
inspection report will be placed in the NRC's Public Document Room.
If this l
report contains any information that you (or your contractor) believe to be proprieta ry, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of a
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.1litg which it is claimed that the information is proprietary, and should be proc ted a
f so that proprietary information identified in the application is ccntained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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Should you have any questions concerning this letter, we will be glad to discuss them with you.
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Sincerlly, (5;
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ck T. Sutherland, Chief iii:d Fuel Facility and Materials 9
Safety Branch t
Enclosures:
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Appendix A, Notice of Violation j
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Inspection Report No. 70-1151/79-2 1
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Report No.:
70-1151/79-2 Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Drawer R Columbia, Soe'h Carolina 29205 License No.:
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Inspecto rs:
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D hW F\\. M.' Collins, Radiation Specialist Date Signed 1
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Sh5 G. L. Wou), Radgation Specialist Dhte Signed
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Approved by:
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A. F. Gibson, Section Chief, FFMS Branch
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SUMMARY
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Inspection on January 30 - February 2,1979.
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This routine unannounced inspection involved 32 inspector-hours onsite in the areas of radiation protection instrumentation, external and internal exposure i
control, posting, labeling and cointrol, notification and reports, unusual
.2 ccurrences and previous inspection findings.
E"..i Results i....
M Of the six areas inspected, no apparent items of noncompliance or deviations were identified in five areas; one apparent item of noncompliance was found in one area (deficiency: posting of door into UF bay (79-02-01)). No apparent 6
deviations were found in six areas.
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Persons Contacted Licensee Employees
- W. J. Harnett, Manager, Materials
- R. C. Drescher, Manager, Chemical Operations
- W. L. Goodwin, Manager, Regulatory Compliance
- C. F. Sanders, Manager, Radiological and Environmental Engineering
- E. K. Reitler, Fellow Engineer 3
L. J. Weatherford, Manager, Health Physics Operations
- q; R. K. Burklin, R&E Engineer fiyi L. Coco, R&E Engineer R. Hayes, R&E Engineer R. Fischer, R&E Engineer J. Heath, Associate R&E Engirieer Other licensee employees contacted included 4 technicians, 1 operator.
- Attended exit interview.
,4 34 2.
Exit Interview dh!
The inspection scope and findings were summarized on February 2, 1979 with those persons indicated in Paragraph 1 above. With regard to the unlabeled burial boxes in the outside area (paragraph 7.d), licensee repre-sentatives stated that the boxes would be labeled and/or posted. With respect to the posting of the door to the UF bay, licensee representatives g
'y stated that a' more permanent method of posting would be investigated and the proper posting installed.
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Licensee Action on Previous Inspection Findings w
(0 pen) Unresolved Item (78-15-01) Labeling. ntaminated Scrap Disposal Boxes.
Disposal boxes in the outside a reas have not been labeled.
(paragraph 7.d.)
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Unresolved items were not identified during this inspection.
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External Exposure Control An inspector reviewed the licensee's program for external exposure a.
control, including review dosimetry records and exposure history files, observations of control practices, and discussions with
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Specific areas inspected were:
(1) personnel 4
monitoring requirements of 10 CFR 20.202.a; (2) permissible doses of 10 CFR 20.101.a; (3) extended permissible doses of 10 CFR 20.101.b; (4) exposure nistory requirements of 10 CFR 20.102; ar.d (5) exposure records of 10 CFR 20.401.a. The inspector reviewed both the report provided by the contractor who provides the dosimetry service and the plant exposure report in determining compliance with the exposure limits.
A licensee representative informed the inspector that no one was currently authorized to receive extended doses per 10 CFR 20.101.b. No items of noncompliance or deviations were identified.
b.
In reviewing the exposure report and records, the inspector noted that one individual had recieved doses to the skin which were
,g.y higher than other workers doing similar work. Although his quarterly Hid doses for the first three quarters of 1978 were within the limits
..f of 10 CFR 20.101.a, the total dose was higher than those of other workers.
A licensee representative stated that this would be reviewed and discussed with the individual to determine possible actions to reduce his doses to the skin.
The inspector had no further questions.
10 CFR 20.104 specifies the limits for occupational exposure (external c.
M..vd and internal) of minors.
A licensee representative informed the inspector that no minors were employed in the radiation controlled pig.,
areas of the plant. The inspector reviewed the dosimetry printout
+1 and determined from the dates of birth that no minors were included in the program.
The inspector had no further questions on the exposure of minors.
6.
Internal Exposure Control 3
10 CFR 20.103, 10 CFR 20.201, License Condition 25 and Section 3.2.2 of "Q
the license application, requires the licensee to limit intakes of radioactive material, to survey to verify that concentrations were below limits and to take actions at specified action points which are below the limits. An inspector reviewed list of personnel on work restriction, investigatica reports for exposures greater than permissible concentrations and records of any exposures greater than regulatory limits. A licensee representative stated that no pnrsonnel had been exposed to greater than the regulatory limits; this was confirmed by the work restriction and 3
investigation files. The inspector had no further questions.
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Posting d abeling and Control a.
10 CFR 20.203.(b) et.
seq. specifies the posting and control requirements for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive materials. License condition 12 specifies the posting requirement for containers in lieu of the requirements of 10 CFR 20.203.(f). During tours of the plant areas, n [...I I!! l
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the inspectors observed that entrances to the restricted area were q
posted as required and that the entrances to the health physics laboratory area were posted with the required container warning signs.
b.
On January 30, the inspectors observed that a door which provides access from the outside into the UF bay was not posted. Licensee 6
representative acknowledged that the door should have been posted as it provides access to radioactive materials areas as well as potential radiation and airborne radioactivity areas. On February 1, an inspector observed that the same door had a container warning sign affixed but no other warning signs.
Af ter investigating the j
situation, a licensee representative stated that the required signs d,[ 'ip had been affixed on January 31, but due to the door banging against a structural member when it was op,ened, the plastic signs had O
broken and fallen off. A licensee management representative state 3 that action to install more durable signs, such as painting the signs on the door or installing metal signs. The inspector informed licensee management that this was considered to be an item of noncompliance in that the door was not posted in accordance with 10 CFR 20.203(c) and License Condition 12; this was acknowledged by licensee management representatives.
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10 CFR 19.11 requires that current copies of certain documents be M!!
posted or a notice stating where the documents may be examined be h
posted and that Form NRC-3 m.: posted. An inspector observed that the required notice ond Form NRC-3 were posted in the main hall entrance to the restricted area. The inspector noted that the Form NRC-3 was not the current revision; during the inspection the licensee obtained copies of the current revision.
The inspector had no further questions.
j"U d.
In RII Report No. 70-1151/78-15, paragraph 6.a it was noted that
> -i three boxes were placed in the area outside of the main process
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huilding f-c the collection of contaminated material for shipment for offsite burial and licensee representatives had stated the boxes would be labeled to indicate that the boxes were only for, and contained, radioactive materials. On February 1, an inspector toured the outside area and observed that the three boxes had been removed; however, six new boxes were located in the area and co i-
[T I tained radioactive mate-ials but the boxes were not labeled.
f Licensee representatives stated that these boxes would be labeled ad}
or barricaded.
The inspector stated that Unresolved Item 78-15-01 M
remained open.
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License Conditions 18 and 26 require the licensee to limit and to survey for contaimination. An inspector discussed the contamination survey program with licensee representatives. Additionally during tours of the operating areas and non-contamination controlled areas of the plant, the inspector performed surveys for total and removable contamination. No items of. noncompliance were identified by the inspector.
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The inspector took smears fo'r No: e contamination in two areas. n the operating area which had just been wet mopped.
The smears j
indicated that the contamination levels in these areas were withf a g3.(
limits but were higher than expected for o just cleaned area. This was discussed with a licensee representative who acknowledged that i
the contamination levels were higher than usual and stated that f
this would be discussed with the cleanup personnel to assure that the cleanup effort does remove the contamination rather than spread it over a larger area. The inspector had no further qustions.
9.
Radiation Protection Instrumentation a.
Sectiens 2.2.4 and 3.2.1 of the license application requires that the licensee maintain and calibrate radiation survey instruments.
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10 CFR 20.103, 10 CFR 20.201(b) and Section 2.2.6 of the license
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application requires the licensee to perform air sampling. During tours of the work areas, the inspectors observed the operability and use of contamination survey instruments at controlled area exits, observed that current calibration stickers were affixed on survey instruments, portable air samplers and impingers, and observed the location and operation of various stationary air samplers. Thea inspectors also discussed the functional tests used to verify the operability of survey instruments with licensee representatives.
b.
On January 30, an inspector observed that the survey instrument at the UF exit door was not operating.
A licensee representative 6
accomp:.nying the inspector halted individuals from exiting through the door since they could not survey themselves for contamination.
The licensee representative then had a sign placed on the door notifying workers not to use the door as an exit.
The inspector L;f had no further questions.
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License condition 24 requires that the licensee replace HEPA filters c.
I in recirculating ventilation systems at a specified differential pressure.
The inspectors observed that selected recirculating systems had differential pressure gages installed and the gage readings were within the license limits. An inspector reviewed the log sheets for various filters and noted that the readings for two
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by a' licensee representative, who stated that the individuals taking the readings would be instructed on reading the gages. The inspector had no further questions.
- 10. Notification and Reports a.
10 CFR 20.405 and 10 CFR 20.408 requires that the licensee submit reports to the NRC for overexposures to radiation or radioactive materials and upon termination of work, respectively. The inspector discussed the _ exposure records with a licensee representative, reviewed the external exposure records for the first-three quarters, 1978 and the internal exposure restricted list for 1978 and various personnel expuare files.
Based on this review, the inspector fi!
determined that no overexposure reports were required and that b.
termination reports were submitted as required by 10 CFR 19.13.
p The inspector had no further questions.
b.
10 CFR 20.402 specifies the reporting requirements for the loss or thef t of licensed material.
The inspector discussed this with a licensee representative.
The licensee representative stated that no losses or thefts of NRC licensed material had occurred and that L.A no reports were required.
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10 CFR 20.403 specifies the rt, ting requirements for incidents c.
pi involving overexposures or the
. lease of radioactive materials.
l Based on the review of externai exposure records, the inspector determined that no overexposure incident reports were required. A licensee representative informed the inspector that an unplanned release had occurred on January 19, 1979 when excess vacuum in the L 'I ventilation system had drawn water from the scrubber in the scrap recovery area; the water leaked out of the ventilation duct and ran Ey into the storm drain.
The licensee representative stated that based on tce water sample concentrations and amounts of uranium y
released, no report was required.
The inspector reviewed the licensee's evaluation and had no further questions.
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In Reply Refer To:
NOV 161979 RII:CLT.
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M. D'Amore, Manager Columbia Plant Nuclear Fuel Division
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Centic:nen:
Thank you for your letter of November 1, 3979, inforuing us of steps you have taken to correct the ite:as of noncompliance concerning activities under NRC License No. SNM-1107 brought to your attention in our letter of October 16, 1979. We vill examina your corrective actions and plans 4
during subsequent inspections.
{.][tp Wu appreciate your cooporation with us.
Sincerely, i
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m Jack T. Sutherland, Chief-Fuel Facilit/ and Materials
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Washington Public Document Room i
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F03 7702010 November 1, 1979 U. S. Nuclear Regulatory Ccmnission ATIN: Mr. J. T. Sutherland, Chief Region II Fuel Facility and thterials Safety Branch Office of Inspection and Enforcement 101 Marietta Street, Suite 3100, Atlanta, Georgia 30303 RE: RII: GLT 70/1151/79-14 Gentimien:
In response to your letter of October 16, 1979, concerning your inspection of our facilities conducted September 17-21, 1979, and pursuant to the pro-visions of Section 2.201, Part 2, Title 10, Code of Federal Regulations, the follcuing omments are mde:
Agdendix A, Item A 1
As stated in the above referenced report, an investigation revealed l
that the materials had cane from a contamination control area on the rcof where facilities improvements were being performed on the ex-haust ventilation system. These materials w re not surveyed according to plant procedures prior to transfer to the scrap mtal box. To correct this prob 1cm, both operating and construction personnel wre i
reinstructed in the proper disposition of potentially contaminated itans. This was accomplished by October 16, 1979.
In addition, in-creased surveillance of outside activities has been inplanented to assure l
corpliance with plant procedures. These actions have been effective in preventing recurrence.
Westinghouse perfonred a ccuprehensive audit of waste wr 7ement pro-cedures, poltcies and facilities to determine whether additional in-provements in waste handling were necessary. Reccmnendations fran this audit are currently under mnapnent review. One of these reccm-mendations is to provide physical controls and surveillance for certain of the non-radioactive mntainers located outside the plant. This program will be inplemented by Decaber 21, 1979.
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.Noverober il 1979 Appendix A, Itan B The two recirculating air systans had been recently voved to their present locations frcm other areas of the plant. When this was done, personnel in-volved with the relocation failed to request the air sanpling be re-installed on the units.
To correct the problan, the two units were equipped with air sampling devices; this was acccruplished by Septanber 21, 1979.
Internal procedures require that rodifications of this nature be reviewd by Padiological and Environmental Engineering. All cognizant individuals were re-infonned of this requiranent. In addition, this itan is being anphasized during routine inspections of the Controlled Areas.
Frcm our revicw of your inspection report, we have concluded that no proprietary
'infonnation is identified. We tnist that you find the above cxxtm2nts responsive to your letter.
If you have any questions regarding this matter, please write tre at the above address or telephone me at (803) 776-2610.
Sincerely, f
WESTINQOUSE ELECTRIC CORP.
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W. L. Goodwin, Bhnager M. D'Am3re, Manager l
Regulatory Ccrupliance Manufacturing and Columbia Plant WIE/MD/le i
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J OCT 161979 In Reply Refer To:
RII:GLT 70-1151/79-14 Westinghouse Electric Corporation ATTN:
M. D'Amore, Manager Columbia Plant Nuclear Fuel Division
') rawer R Columbia, S C 29205 Gentlemen:
This refers to the inspection conducted by G. L. Troup of this office on September 17-21, 1979 of activities authorized by hTC License No. Sh71-1107 for the Columbia Nuclear Fuel Fabrication facility, and to the discussion of our findings held with R. J. Wiggins at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the i
enclosed inspection report. Within these areas, the inspection consisted of
'A selective examinations of procedures and representative records, interviers with personnel, and observations by the inspector.
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We have examined actions you have taken with regard to previously identified i
enforcement matters and unresolved items.
The status of these items is discussed in the enclosed report.
During the inspection, it was found that certain activities under your license l
appear to be in noncompliance with NRC requirements.
These items and references to pertinent requirements are listed in the Notice of Violation enclosed here-with as' Appendix A.
This notice is sent to you pursuant to the provisions of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, within 20 days of your receipt of this notice, a written statement or explanation in repl/
including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further noncom-pliance; and (3) the date when full com,iliance will be achieved.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of tLi: letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure.
Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so l
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[.dh that proprietary information identified in the application is contained in a h
(,,f separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, r
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. T. Sutherland, Chief Fuel Facility and Materials Safety Branch i
Enclosures:
1.
Appendix A, Notice of Violation l
2.
Inspection Report No. 70-1151/79-14
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APPENDTX A NOTICE OF VIOLATION
. A.
l Westinghouse Electric Corporation License No. SNM-1107 Columbia Nuclear Fuel Plant Based on the NRC inspection September 17-21, 1979, certain of your activities were apparently not conducted in full compliance with NRC requirements as indi-cated below. These items have been categorized as described in correspondence to you dated December 31, 1974.
A.
As required by Condition 38 of License SNM-1107, the licensee shall perform tests, measurements, or surveys as may be necessary for him.to comply with action points and limits in the license.
Contrary ta the above, materials were removed from a contamination control area and placed in the clean area of the plant on or about September 20, 1979 without the necessary surveys being performed to demonstrate compliance with Condition 18 and Annex C of the license.
This is an infraction.
B.
As required b, Condition 42 of License SNM-1107, by July 1, 1979 air sampling equipment shall have been installed and operating for repre-sentative sampling of air discharged from each recirculating air system.
Contrary to the above, on September 19, 1979 two recirculating air systems were in service in the pellet area which did not have air sampling equipment installed and in operation.
This is an infraction.
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REGION 11
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Report No. 70-1151/79-14 Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, South Carolina 29205 Facility Name:
Columbia Nuclear Fuel Plant License No. SNM-1107 Inspection at: Columbia; Sou g rolina' G. L. Trou'p ' M'
"//e/77 Inspector:
Date Signed Approved by:
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A. F. Gibson, Section Chief, FFMS Branch
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Dated Signed
SUMMARY
Date of Inspection: September 17-21, 1979 Areas Inspected:
This routine, unannounced inspection involved 34 inspector-hours onsite in the areas of the waste disposal program including liquid effluents, gaseous effluents, i
l reports of effluents discharged, monitoring instruments, radioactive solid waste disposal, followup on IE circular, bulletins and information notices, and followup l
l on unusual occurrences, t
Results Of the seven areas inspected, no apparent items of noncompliance or deviations were identified in five areas; two apparent items of noncompliance were found in (infraction - failure to survey (79-14-01); infraction - failure to two areas install air sampling equipe.ent (79-14-02); no apparent deviations were found.
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1 e A DETAILS 1.
Persons Contacted
- R. J. Wiggins, Acting Plant Manager
- W.'H. Brittin, Manager, Chemical Operations
- W. L. Goodwin, Manager, Regulatory Compliance
- C. F. Sanders, Manager, Radiological and Environmental Engineering L. J. Weatherford, Manager Health Physics Operations
- E. M. Philpot, General Supervisor, Chemical Operations
- E. K. Reitler, Fellow Engineer R. K. Burklin, R&E Engineer-L. Coco, R&E Engineer R. Hayes, R&E Engineer R. Fischer, R&E Engineer J. Heath, R&E Engineer R. Lewis, Shift Supervisor R. Peterson, Shift Supervisor Other licensee employees contacted included five technicians, and one office personnel.
Other Organizations J. Hayes, President, Delaware Custom Materials, Inc.
n, 2.
Exit Interview q,,
The inspection scope and findings were summarized on September 21, 1979, with those persons indicated in Paragraph I above. On September 25, 1979, the inspector discussed the release of material from the contamination control areas wihtout proper surveys with E. R. Reitler and informed him that this was considered to be an item of noncompliance against condition 38 of the license.
3.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (79-02-01) Posting of Radioactive Materials Areas.
The inspector observed that doors leading into the UF area as well as 6
other outside areas in the plant have been posted with painted signs. The inspector had no further c,uestions.
(Closed) Unresolved Item (78-15-01) Labeling Contaminated Scrap Disposal Boxes.
The disposal boxes in the outside areas have been labeled with appropriate signs. A licensee representative stated that boxes are posted when ready for use rather than when filled and ready for shipment.
4.
Unresolved Items Unresolved items were not identified during this inspection.
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5.
Control of Contaminated Material
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a.
On September 20, 1979, the inspector, accompanied by a licensee repre-sentative, toured the outside area and performed radiation surveys of materials in vaste containers and other materials. During a survey of material in a scrap metal box the inspector identified a piece of '.
sheet ' metal with readings as high as 1600 cpm (approximately 5200 2
dpm/100cm ) using a PAC-4S instrument. Other pieces in the box showed readings of 200-300 cpm above background.
b.
Licensee representatives removed the material form the box and performed both loose and fixed contamination surveys.
Condition 18 of license SP1 1107 requires that equipment and packages released from the plant or to clean areas on-site shall be less than the limits of Annex C to-the license. The survey results were less than the limits of Annex C but several pieces of metal had fixed contamination greater than the limits of plant procedure RP-201.
Those pieces were packaged as radioactive solid waste.
c.
The licensee investigated this condition and determined that the mater.ials had come from a contamination control area on the roof where construction work was being done on the ventilation system and had not been surveyed before being placed in the box. Condition 38 of license SNM-1107 requires that the licensee shall peform tests, measurements l
or surveys as may be necessary. The inspector stated that the movement
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of the material from the controlled area to a clean area without l
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adequate surveys was an item of noncompliance (79-14-01); this was l
acknowledged by a licensee representative.
l 6.
Radioactive Liquid Effluents t
The inspector reviewed the " Summary Effluent and Environmental Report" for l
the period January-July 1979 and the " Liquid Effluent Discharge Log" for the month of July 1979 to determine compliance with 10 CFR 20.106 and 10 CFR 20.201(b).
The inspector toured the waste treatment facility and i
observed the operation of the composite sampler. The inspector also dis-cussed the controls over liquid discharges with licensee representatives t
and discussed sample collection, composite sample preparation and samply analysis with radiation control personnel.
No items of noncompliance were identified by the inspector.
7.
Radioactive Caseous Effluents a.
Concentrations Released The inspector reviewed the " Summary t.ffluent and Enviromental Report" for the period January-June 1979, " Weekly Ef fluent Air Summary" for the period May 6-September 2, 1979, and " Gaseous Effluent Air Daily Results" for the period August 1 - September 14, 1979, to determine compliance with 10 CFR 20.106 and 10 CFR 20.201(b). The inspector s
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e also discussed the methods used to collect samples and to evaluate the (A
releases. No items of noncompliance or deviations were identified by s
the inspector.
b.
Calibration of Flow Meters The inspector reviewed 'the c311bration records for the flow meters associated with the effluent samplers and discussed the calibration with the responsible technician. In reviewing the records the inspector noted that some flow meters had entries of "no flow" or were out of tolerance.
A licensee re'presentative stated when these conditions were found corrective actions (such as clearing the sam'ple line) were taken and the flow meter recalibrated. However, the recalibration results were not included on the record form. The inspector pointed out that the recalibration records should reflect the actual calibration results; this was acknowledged by licensee representatives who stated that in the future when recalibration is required, both the initial and final calibration results will be included in the records. The inspector had no further questions.
8.
Recirculating Air Systems Condition 42 of license SNM-1107 requires that by July 1, 1979, air a.
sampling equipment shall have been installed and operating for repre-sentative sampling of air discharged from each recirculating air l
system. On September 19, 1979, the inspector observed two recirculating t
air units in operation in the pellet area which did not have air
'g sampling equipment installe:: and operating.
The inspector informed un s licensee representatives that this was an item of noncompliance (79-14-02).
Action was taken to install the equipment on the subject units by September 21.
t b.
The inspector observed that a copy of the operating procedure was attached to each recirculating air unit.
Step 1 of the procedure l
requires that the differential pressure across the filter be read and recorded daily.
The inspector reviewed the logs for units in the pellet and conversion areas and noted that +he readings were recorded for the units in the conversion area but had not been recorded since June or July for units in the pellet area. A licensee representative l
l acknowledged that the readings should be recorded and stated that the l
operators would be. reinstructed to record the reading and that the l
procedure would be reviewed. (79-14-03) 9.
Solid Wa.e Disposal l
a.
Shi, ments to Burial Grounds The inspector discussed the program for shipment of solid waste to burial grounds with licensee representatives and examined reocrds for seven shipments.
The inspector also determined that licensee has a current copy of the disposal site license on-site.
The inspector A
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The inspector had no further questions.'
b.
Burial of Waste 10 CFR 20.304 allows dispoal' of radioactive material by, burial provided that certain. requirements are met. A licensee representative informed the inspector that no radioactive material is disposed of by burial; all material is shipped to a licensed disposal site. 'The inspector had no further questions.
10.
Evacuation of Chemical Process Area i
On September 6, 1979, the chemical process area was evacuated due to a release of ammonimum diuranate. The inspector discussed the incident with the cognizant engineer and reviewed the air sample results of the areas.
The inspector also discussed the licensee's evaluation of personnel exposures with cognizant personnel. The licensee's evaluation concluded that personnel l
in_the area had been exposed to only a fraction of the limits of 10 CFR 20.103. The inspector had no further questions.
11.
IE Bulletins, Circulars and Information Notices
.j Circular 79-09, " Occurrences of Split or Punctured Regulator Diaphragms a.
in Certain Self Contained P,rrathing Apparatus". A licensee representa-tive stated that al)
-# tse subject units had been inspected and that no problems had been found. The licensee representative also stated,
j th:t a method of testing the diaphragm integrity was being studied and that test and inspection requirements would be incorporated into procedure RC-205 by December 22, 1979, which is before the next scheduled inspection (79-14-004).
b.
Circular 79-15, " Bursting of High Pressure Hose and Malfunction of Relief Valve and 0-ring in Certain Self-Contained Breathing Apparatus."
A licensee representative informed the inspector that no units described in the circular are used; the inspector had no further questions, Information Notice 79-8, Interconnection of Contaminated Systems c.
with Service Air Systems Used as the Source of Breathing Air." A licensee representative informed the inspector that the service air system is not used as a supply for respirable air; rather, res;>irable air is supplied from _mp'ressed air cylinders which aia filled at a contractor's facility. Consequently, there is no potential ' for cross-contamination. The inspector had no further questions.
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- 12. Reports of Effluents i
iV 10 CFR 70.59 requires that each licensee shall submit a report semi-annually specifying the quantity of each of the principal radionuclides released to unrestriced areas in liquid and gaseous effluents during the previous six months of operations. The inspector reviewed the reports for the periods January - June 1978, July - December 1978 and January - June 1979 and determined that the reports were submitted within the required period and contained the required information. The inspector had no further questions.
13.
ALARA Committee Report Condition 21 of the facility license requires that a formal report shall be made by the ALARA Committee to the Plant Manager every six months reviewing employee exposures and effluent release data. The inspector reviewed the ALARA Committee report for the period January 1-June 30,1979, and discussed the findings with licensee representatives. The inspector had no further questions.
14.
Control of Radiation Exposure for Transient Workers On June 18, 1979, the Director, Office of Standards Development, USNRC issued a notice to NRC licensees regarding changes to 10 CFR Parts 19 and 20 concerning control of radiation exposure for transient workers. The inspector discussed this notice with the cognizant supervisor and determined that the licensee had received the notice and had reviewed the exposure
'4 program for any changes necessary to implement the change; the licensee concluded that no procedural changes were necessary. The inspector had no
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Dia:.ct R Co'erbia Scuh Catchna 29250 1803 7762G10 thrch 12, 1980 U. S. Nuclear Pegulatory Ccnmission ATIN: Mr. J. Philip Stohr, Chief Riel Facility and Fhterial Safety Branch Office of Inspection ani Enforcement 101 Furietta Street, Suite 3100 Atlanta, Georgia 30303 IE: RII:GLT 70-1151/80-3 Gentlemen:
This letter confirms receipt of your above referenced correspondence concerning Mr. Troup'n February 4-8, 1980 inspection of the Columbia Plant. We appreciate your reviews of our radiation protection programs.
N' Sincerely, g,h?g-hzx-t W. L. Goodwin, Panager
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FEB 2 61980 RII:GLT 70-1151/80-3 Westinghouse Electric Corporation ATTN:
M. D'Amore, Manager Columbia Plant Nuclear Fuel Division Drawer R Columbia, SC 29205 Gentlemen:
This refers to the inspection conducted by G. L. Troup of this office on February 4-8, 1980, of activities authorized by NRC i,icense No. SNM-1107 for the Coltunbia Fuel Fabrication facility, and to the discussion of our findings held with M. D'Amore at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were disclosed.
We have examined actions you have taken with regard to previously identified enforcement matters. These are discussed in the enclosed inspection report.
In accordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the inforraation is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document.
If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
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ej Westinghouse Electric Corporation Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, 4
J. Philip Stohr, Chief Fuel Facility and Materials Safety Branch
Enclosure:
Inspection Report No. 70-1151/80-3 bec w/ encl:
Local Public Document Room Washington Public Document Room Central Files Nuclear Safety Information Center Technical Information Center IE Mail and File Region II Reading Room State of South Carolina
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UNITED STATES NUCLEAR REGULATORY COMMISSION n
I REGION 11 8,
101 MARIETTA ST N.W.,SuliE 3100
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' Report No. 70-1151/80-0l$
Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, SC 29205 License No.
SNM-1107 Inspected y:
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G. L. Troup.
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8!h Approvedh:
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_f A. F. Gibson,' ection hief, FF&MS Branch D te Signed SIM1ARY Inspection on February 4-8, 1980 l
Areas Inspected l
This routine, unannounced inspection involved 31 inspector-hours on site in the areas of radiation protection instrumentation, external and internal exposure conf.rol, posting and labeling, notifications and reports, unusual occurrences, previous inspection findings and the installation of new ventilation systems.
Results Of the seven areas inspected, no items of noncompliance or deviations were identified.
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DETAILS i
1.
Persons Contacted Licensee Employees
'*H. D'Amore, Plant Manager
- E. Buonanno, Manager, Chemical Operations
- W. Britton, Manager, Manufacturing l
- W. J. !!artnett, ifanager, Materials
- W. L. Goodwin, Manager, Regulatory Compliance
- C. F. Sanders, Manager, Radiological arid Environmental Engineering L. S. Veatherford, Manager, Ilealth Physics Operations l
- E. K. Reitler, Fellow Engineer R. K. Burklin R&E Engineer L. Coco, R&E Engineer i
R.~ !! ayes, R&E' Engineer R. Fischer, R&E Engineer H. 't. King, R&E Engineer J. IIcath, R&E Engineer G. Lowder, General Supervisor, Chemical ifanufacturing S. Sabo, Supervisor, Maintenance Other licensee employees contacted inc1;ided 4 technicians.
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on February 8, 1980 with those persons indicated in Paragraph 1 above.
Regarding the monitoring of filter dP on recirculating air systems (Paragraph 9), Mr. D' Amore stated that the situation would be reviewed and the procedures revised as appro-l priate and, in the interim, supervisors would be instructed to ensure that this is being done.
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l 3.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (79-14-01).
Failure to Survey.
The corrective actions specified in the Westinghouse letter of November 1,1979, were reviewed with cognizant personnel. The inspector reviewed the report of l
the low level radioactive waste audit of October 22, 1979, and observed the physical controls on non-radioactive waste containers in outside areas.
A licensee representative stated that a program for semi-annual audits of the i
vaste program has been set up and that the implementat ion of findings from the waste audit were being accomplished in conjunction with the actions of IE Bulletin 79-19.
tic inspector had no further questions.
(Closed) Noncompliance'(79-14-02).
Failure to Install Air Sampling Equipment. The corrective actions specified in the Westinghouse letter of November 1, 1979, were reviewed with cognizant personnel. The inspector
2-reviewed tive revised " Controlled Area H.P. and Criticality Checklists",
which now includes a verification that the recirculating air systems have operable air samplers installed. The inspector had no further questions.
4.
Ucresolved Items Unresolved items were not identified during this inspection.
5.
External Exposure Control The inspector reviewed the licensce's program for external exposure a.
centrol, including the review of dosimetry records and exposure history files, observations of control practices,and discussions with licensee personnel. Specific areas inspected were:
(1) personnel monitoring requirements of 10 CFR 20.202(a); (2) permissible doses of 10 CFR 20.101(a); (3) extended permissible doses of 10 CFR 20.101(b); (4) exposure history requirements of 10 CFR 20.102; and (5) exposure records of 10 CFR 20.401(a). The inspector reviewed both the report provided,by the contractor who provides the dosimetry service and the plant exposure report in determining compliance with the exposure limits.
A licensee representative informed the inspector thr.t no one was currently authorized to receive extended doses per 10 CFR 20.101(b).
No items of noncompliance or deviations were identified.
b.
10 CFR 20.104 specifies the limits for occupational exposure (external and internal) of mic9rs. A licensee representative informed the inspector that no mi..srs were employed in the radiation controlled areas of the plant. The inspector reviewed the dosimetry printout and determined from the dates of birth that no minors were included in the program.
The inspector had no further questions on the exposure of minors.
6.
Internal Exposure Control 10 CFR 20.103, 10 CFR 20.201, License Condition 25 and Section 3.2.2 a.
ot the license application require the licensee to limit intakes of radioactive material, to perform surveys to verify that concentrations were below limits, and to take acticas at specified concentration action points which are below the limits. The inspector reviewed the following records to determine if the required surveys had been performed and applicabic actions taken:
(1) "7 Day Summaries - In-Plant Air," for September-December 1979.
(2) " Unusual Occurrence Reports", for October 1979-January 1980.
(3) " Airborne HPC-Hour Average" for the 4th quarter 1979.
(4) " Persons on Work Restriction" for September 1979-January 1980.
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-3 No exposures greater than regulatory limits or failure to comply with action 1cve): were identified.
i b.
10 CFR 20.103, License Condition 47 and Section 3.2.3 of license application require the licensee to conduct a bioassay program and to take. actions at specified action levels. The inspector reviewed the following records, in addition to those reports listed above, to determine if the bioassay program was being conducted and applicabic i
actions taken:
(1) " Monthly Summary Reports-Lung Counts" for September-December 1979.
(2) " Personnel 2xposure Analysis-Ai; borne" for October-December 1979.
No exposures greater than the limits '- failure to comply with action Icvels were identified. The inspector also observed that schedules were posted in various areas delineating when individuals were to provide specimens for the bioassay program, 10 CFR 20.103(b)(1) requires that the licensee use process or other c.
engineering controls, to the extent practicable, to limit concentra-Lions of radioactive materials in air.
During tours of plant areas, the inspector observed the installation of new enclosures around process equipment and modifications in the ventilation in the pellet inspection area to reduce airborne Icvels and discussed the use of these controls with licensee representatives.
The inspector had no furt her questions.
l l
7.
Radiation Protection Instrumentation l
l Sections 2,2.4 and 3.2.1 of the license application requires that the a.
licensee maintain and calibrate radiation survey instruments.
10 CFR 20.103, 10 CFR 20.201(b) and Section 2.2.6 of the license application requires the licensee to perform air sampling.
During tours of the work areas, the inspector observed the operability and use of contami-nation survey instruments at controlled area exitr. observed that current calibration stickers were affixed to survey instruments and portable air samplers, and observed the location and operation of various stationary air samplers.
l b.
The inspector reviewed the calibration records for portable survey l
instruments and portable air samplers to verify that the calibrations l
had been performed at the required frequencies and after repairs.
The
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inspector had no further questions.
c.
In RII report 70-1151/79-14, paragraph 7.b, it was noted that calibra-tion records for air flow meters did not indicate that recalibrations had been performed after maintenance or if the initial calibrations I
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were out of tolerance. The inspector reviewed the air sampler flow meter calibrations during the fourth quarter and observed that those flow meters requiring corrective action were identified and the records showed thct recalibration had been performed after the maintenance.
The inspector had no further quest. ions.
8.
Ventilation System ifodifications The licensee is presently installing new exhaust ventilation systems a.
for various areas of the plant and a new make-up air system which filters and recirculates the majority of the air and exhausts a portion of the flow. The inspector toured several of the new installations wit'n licensee representatives. As several subsystems were in operation at the time, the inspector verified that air samplers were installed and were operating to monitor the discharges.
b.
The inspector reviewed the contractor's test report for the DOP testing of the filters in the make-up air system conducted on September 20, 1979, which showed a system ef ficiency of greater than 99.95%.
The inspector also discussed the DOP testing of the other new filter installations with the cognizant engineer.
The engineer stated that efficiency determinations are being made for the system of filters and that tests are being performed periodically as work on the ventialtion system progresses. The inspector discussed the testing with a licensee management representative and stated that the final test results of each filter system should be documented and include D0P results, flow rate verifications and any other tests which are performed.
This was acknowledged by the licensee represenatative, who stated that the test results would be documented (80-03-01).
i 9.
Status of Previously Identified Open items (Open) 79-14-03 Recording of Filter dP Data on Recirculat ing Air Units.
The inspector reviewed the dP log sheets for several recirculating air l
systems in the powder, pellet and QC areas and noted that the readings were not being recorded daily as required by the operating procedures.
A licensee representative discussed the loading of the filters and air sample results, both of which indicate that the filter dP will not increase drastically in short period of t ime under normal conditions.
Ilowever, licensee manage-a ment representatives acknowledged that as the operating procedures require that the dP readings be made and logged daily, personnel should record the readings. A senior representative stated that supervisors would be instructed to carry out these actions until the procedures and other data are reviewed and the procedures left unchanged or revised.
(Closed) 79-14-04 Testing of SCBA Units.
IE Circular 79-09 identified a problem with certain types of self-contained breathing apparatus and requested that licensees establish a program for the examination of these devices.
The licensee had previously conducted an examination of the units.
Procedure RC-205 was revised on December 21, 1979, to include a pressure test of the e
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' diaphragm at six month intervals. A licensee representative informed the inspector that the six month interval was selected rather than a one month interval recommended by NIOSH based on the recommendation of the equipment manufacturer and the fact that the devices are used in a different mode than that in which' operating problems have occurred and that the units are inspected monthly for operability as part of the respiratory protection program. The inspector had no further questions.
i 10.
Posting,-Labeling and Control 10 CFR 20.203(b) et seq. specifies the posting and control requirements a.
for radiation areas, high radiation areas, airborne radioactivity areas, and radioactive materials.
License Condition 12 specifies the posting requirement for containers in lieu of the requirements of 10 CFR 20.203(f). During tours of the plant areas, the inspector observed that entrances to the restricted area were posted as required and that the entrances to the health physics laboratory area were posted with the required container warning signs.
l b.
10 CFR 19.11 requires that current copies of certain documents be l
posted or a notice stating where the documents may be examined be l
posted and that Form NRC-3 Le posted.
An inspector observed that the required notice and Form NRC-3 were posted in the main hall entrance to the restricted area. The inspector had no further questions.
l 11.
Notification and Reports i
a.
10 CFR 20.405 and 10 CFR 20.408 require that the licensee submit l
reports to the NRC for overexposures to radiation or radioactive r.aterials and upon termination of work.
The inspector discussed the exposure results with a licensee representative, reviewed the external l
exposure records for the second and third quarters of 1979 and the l
internal exposure restricted list for 1979 and various personnel exposure files. Based on this review, the inspector determined that no overexposure reports were required and that termination reports were submitted as required by 10 CFR 19.13.
The inspector had no i
further questions.
b.
10 CFR 20.402 specifies the reporting requirements for the loss or theft of licensed material. The inspector discussed this with a licensee representative. The licensee representative stated that no losses or thefts of NRC licensed material had occurred and that no reports were required.
c.
10 CFR 20.403 specifies the reporting requirements for incidents involving everexposures or the release of radioactive materials.
Based on the review of external exposure records, the inspector determined that no overexposure incident reports were required.
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UNITED STATES i
8 NUCLEAR REGULATORY COMMISSION n
S I
REGION 11 j
o 101 MARIETTA sT N.W., SulTE 3100 l
ATLANTA, GEORGIA 30303 o
FEB - 61981 Westinghouse Electric Corporation ATTN:
M. D'Amore, Manager Cc'umbla Plaat Nuclear Fuel Division Drawer R Columbia, SC 29205 Gentlemen:
Subject:
Report No. 70-1151/80-29 This refers to the inspection conducted by R. L. Woodruff and W. J. Millsap of this office on November 14, 1980, of activities authorized by NRC License No.
SNM-1107 for the Columbia, South Carolina facility, and to the discussion of our findings at the conclusion of the inspection.
Areas examined. during the inspection and our findings are discussed in the i
enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.
Within the scope of this inspection, no items of noncompliance were disclosed.
The consultant representatives identified recommendations for improvement of your monitoring program. These items will be referred to our Office of Nuclear Material Safety and Safeguards for consideration.
In ar.cordance with Section 2.790 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed
' inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you (or your contractor) believe to be proprietary, it is necessary that you make a written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared so that proprietary information identified in the application is contained in a separate part of the document. If we do not hear from you in this regard within the specified period, the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, Am iilip S hr, Chief Fuel Facill y and Materials Safety Branch
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Enclosure:
Inspection Report No. 70-1151/80-29 4
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I NbCLEAR REGULATORY COMMISSION
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8 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGI A 30303 Report No. 70-1151/80-29 Licensee:
Westinghouse Electric Corporation l
Nuclear Fuel Division Columbia, SC 29205 License No. SNM-ll07 l
Inspection at:
Columbia, South rolina plant Inspector : _
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R. L. Woodruff Date Signed 2lClE/
- 9. J. Millsap
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Approved by[-A. F. Gibson, ChTef'f' Radiation Support Section, Date Signed l
r FF&MS Branch Date of Inspection:
November 14, 1980 l
Areas Inspected i
This special, announced inspection involved 16 inspector-hours onsite in the areas of groundwater environmental monitoring.
Resul ts In the area inspected, no items of noncompliance or deviation were identified.
Recommendations for improvement of the groundwater monitoring program which were identified by the NRC consultant representatives are being. referred to the Office of Nuclear Material Safety and Safeguards for consideration.
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r DETAILS 1.
Persons Contacted Licensee Employees
- M. D' Amore, Plant Manager
- C F. Sanders, Manager, Radiological and Environmental Engineering
- W. L. Goodwin, Manager, Regulatory Compliance
- R. E. Fisher, Radiological and Envionmental Engineer NRC Consultant Representatives
- E. B. Fowler, Los Alamos Scientific Laboratory (LASL)
- E. W. Essington, Los Alamos Scientific Laboratory (LASL)
- W. L. Polzer, Los Alamos Scientific Laboratory (LASL)
- Attended exit interview 2.
Exit Interview The inspection scope and findings were sunmarized on 11-14-80 with those persons indicated in Paragraph 1 above.
3.
Purpose 1
The purpose of this inspection was to review the groundwater monitoring practices and to reevaluate the adequacy of the groundwater monitoring program with respect to detection and quantification of any migration of radiological contaminants in the soil.
4.
Consultant Review The three (LASL) consultants identified in item 1 above, conducted a general site review, interviewed licensee representatives, and reviewed specific site data to determine or evaluate the following:
(a) identification of isotopes that could be released into the soil, their cr.2mical and physical forms, level of activity and volume of discharge; (b) w. ste treatment systems, including both sanitary and chemical systems and thei rerpective transfer, hold-up, and storage features; (c) the environmental monitoring systems for on-site and off-site detection, including air, vegetation, soil, surface water, groundwater, and potable water sampling; (d) analytical procedures used by the licensee for environmental sample evaluation, including sample collection, frequency of sampling, sample preparations, radiological analysis, and quality control; and (e) hydrology data relative to groundwater monitoring.
No items of noncompliance concerning monitoring requirements in the Facility license were identified.
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Consultant Recommendations following the review of current groundwater monitoring practices, the consultants discussed with licensee management several recommend-ations to refine the current methods of detection of waste migration or provide more comprehensive documentation.
These reconmendations will be referred to the Office of Nuclear Materials Safety and Safe-guards for consideration of possible licensing action.
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