ML20153E493
| ML20153E493 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 04/28/1988 |
| From: | Collins T, Hosey T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20153E479 | List: |
| References | |
| 70-1151-88-03, 70-1151-88-3, IEIN-87-003, IEIN-87-007, IEIN-87-026, IEIN-87-031, IEIN-87-26, IEIN-87-3, IEIN-87-31, IEIN-87-7, IEIN-88-008, IEIN-88-8, NUDOCS 8805100025 | |
| Download: ML20153E493 (14) | |
Text
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[. Sa sto,q NUCLEAR REGULATORY COMMISSION o,#
.? '
i REGION 11 k,
M 101 MARIETT A STREET. N.W.
' s AT L ANT A. GEORGI A 30323 f
APR 2 81988 Report No.: 70-1151/SS-03 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.:
SNM-1107 Facility Name:
Westinghouse M rch 29 - April 1, 19S3 Inspection Conducted:
4 Inspector: r~
N D'te Signed E R. Collins a
Accompanying Personnel:
H. Bermudez Approved by: 3_ / 1 2d
_f C. M. 'Hosey, Settion Chief Date s'igned Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of radiation protection program, transportation of radioactive traterial, solid waste management, followup on previous enforcement items and IE Information 6
Notices.
Results:
No violations or deviations were identified.
8805100025 880428 l
PDR ADOCK 07001151 C
DCD i
REPORT DETAILS 1.
Persons Contacted i
Licensee Employees i
J. Baker, Senior Regulatory Engineer R. Burklin, Senior Regulatory Engineer R. Condo, Manager, Waste and Reccvery
- R. Fischer, Senior Engineer H. Foster, Senior Regulatory Engineer
- W. Goodwin, Manager, Regulatory Affairs "J. Heath, Manager, Health Physics
- P. Loch, Plant Manager R. Montgomery, Regulatory Engineer Other licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security of fice members, and office personnel.
- Attended exit interview 2.
Exit Interview (30703)
The inspection scope and findings were summarized on March 31, 1983, with those persons indicated in Paragraph 1 above. The inspectea described the areas inspected and discussed in detail the inspection 'indings.
No dissenting comments were received from the licensee. The 1.censee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (Closed) Violation 70-1151/87-12-02, Failure sc include the Transport Index (TI) on a Radioactive Material Shipment, identified is Radioactive Material Fissile N.O.S., UN-2918, bearing Radioactive Yellow-II labels.
The inspector reviewed the licensee's response dated September 11, 1987, and verified that the corrective actions specified in the response had been completed.
4 Radiation Protection (83822) a.
Instrumentation Section 3.2.1.2(1) of the Application for License SNM-1107 states that instruments shall be routinely calibrated on a schedule established by the Radiation Protection component.
The schedule shall require calibration following acquisition, and thereaf ter at least following major repairs or semiannually, whichever occurs first.
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The inspector selectively reviewed the calibration schedule and records for portable health physics survey instruments and concluded that instruments were being calibrated at the specified frequency.
During tours of the facility, the inspector verified that survey instruments in use were within current calibration as evidenced by calibration labels.
No violations or deviations were identified, b.
Internal Exposure Control and Assessment The licensee was required by 10 CFR 20.103, 20.201(b), 20.401, 20.403 and 20.405 to control uptakes of radioactive material, assess such uptakes and keep records of and make reports of such uptakes. The Application for License No. SNM-1107, Sections 2 and 3 also include commitments regarding internal exposure control and assessment.
(1) Air Sampling Section 3.2.3.4 of the Application for License SNM-1107 states that all areas where exposed radioactive materials are handled shall be sampled for airborne radioactive particulate matter by using appropriate samplers to obtain reasonably representative samples during operations, or a schedule established by the Radiation Protection Component, and when indicated by a particular operation.
The inspector determined by review of air sample results that the f acility's air is sampled by approximately 250 fixed air samplers and the air sampling media is changed each shift. The licensee health physics section performs a preliminary analysis of each sample collected to locate potential airborne areas and notifies the responsible supervisor of airborne activity requiring exposure investigations or worker protection.
The inspector determined by review of air sampling procedures that the licensee's administrative procedures limit exposures of individuals to airborne radioactive material by controlling employee access to potential airborne radioactivity areas based upon daily exposures.
The daily exposures are determined through investigations that are initiated whenever air survey results indicate concentrations of airborne radioactive material in excess of maximum permissible concentration (MPC) values, The inspector reviewed the sampling, analysis and investigation procedures associated with the airborne radioactivity monitoring program.
The inspector selectively reviewed airborne survey results fur the period of January to April 1988 and concluded that the licensee was performing appropriate air samples and evaluations in accordance with their procedures and license application.
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No viulations or deviations were identified.
(2) Bioassay Program 10 CFR 20.103(a)(3) requires the licensee to use measurements.of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
(a) Bioassay Frequency The inspector determined by review of the bioassay program that in-vivo routine bioassays depend on the nature of the duties individuals performed.
Personnel involved in manufacturing ard waste recovery and disposal were required to have four in vivo bioassays per year. Personnel in most maintenanca activities, conversion, pellet processing, and health physics are in-vivo counted three times per year.
Personnel in - Quality Control and rod preparation were counted twice per year and selected personnel in management and engineering were counted once per year.
Urinalysis are performed monthly for personnel in conversion, manufacturing, health physics and waste recovery and disposal.
Everyone else's urinalysis is performed once per year. Fecal analyses are only performed under special circumstances as part of followup investigations.
The inspector concluded after review of selected bioassay results for the period of January to April 1988 that the licensee met their required frequencies for individual bioassays.
No violations or deviations were identified (b) Action Levels The inspector discussed actior, levels for bioassay results with licensee representatives and determined that a confirmed in-vivo lung burden assessment of 150 micrograms (ug) of uranium-225 (U-235) would result in an investigatior, as to the cause of the uptake. A confirmed in-vivo lung burden assessment of 200 ug of U-235 would l
result in a restriction from the radiation control area (RCA) until two consecutive counts reflect less than or equal to 100 ug of U-235, or several counts average less than or equal to 100 ug of U-235, or as per the discretion of health physics management. It was indicated that action levels were relative to the maximum permissible organ
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burden of 260 ug of U-235 which correspond to a dose rate to the lungs of 30 rems per year.
Action levels based on urinalysis results are based on chemical damage of elemental uranium to the kidneys as long as the U-235 enrichment is less than 5%.
The licensee's l
initial action level occurs at urinalysis results indicating elemental uranium concentrations in urine of 16 micrograms per liter (ug/1).
Personnel with uranium I
concentrations between 16 and 35 ug/l in urine are closely monitored by the health physics staff and are required to continue to submit samples. When uranium concentrations in urine exceed 35 ug/1, personnel are restricted from tne RCA.
It was indicated that confirmed concentrations exceeding 1,000 ug/l would result in immediate work restriction and handling of situation by the facility's medical staff.
l The investigation / restriction action levels based on i
in-vivo counts are license-required and the release criteria are based on administrative procedures.
Sample /resample action levels based on urinalyses are license-required.
Licensee representatives indicated that in the event a person gets involved in a release of gaseous (soluble) i uranium, there would be an automatic one week restriction j
since it takes one week to obtain urinalysis results from i
their vendor.
The inspector concluded after review of selected bioassay I
results for the period of January to April 1988, that the licensee's controls based on action levels were adequate.
i No violations or deviations were identified.
(c) Methodologies and Techniques The inspector determined that the licensee performs 3
internal dose assessments based directly on the methodology presented in the International Commission on Radiological Protection Report No. 30 (ICRP-30).
1 Urine and fecal anlayses are performed offsite by contractors; the respective minimum detectable amounts are 2 ug/l and.01 dpm/ gram.
In-vivo counts are performed onsite by the licensee and the minimum detectable activity is 70 ug of uranium.
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Techniques used for detecting uranium in-vivo are sodium iodide scintillation, and in urine and feces fluo *ometry.
The inspector concluded after review of selected bioassay results for the period of January to April 1988, that the licensee's methodologies and techniques were adequate.
No violations or deviations were identified.
(3) Controls 10 CFR 20.103(b) requires the licensee to use process or other engineering
- controls, to extent practicable, to limit concentrations of radioactive material in air in levels below that specified in Part 20, Appendix B, Table 1, Column 1, or limit concentrations, when averaged ovar the number of hours in any week during which individuals are in the area, to less than 25 percent of the specific concentrations.
The inspector determined by observation that the licensee utilizes ventilation and containment gloveboxes for control of airborne radioactive material.
The use of process and engineering controls to limit airborne radioactivity concentrations in the plant was discussed with licensee representatives and the use of such controls were observed during tours of the plant.
During a tour of the facility, the inspector observed the use of laminar flow units used to provide additional control of air concentrations around work hoods. These units produce a slight down draf t into the hood inlet which helps reduce airborne concentrations around the workers breathing zone.
No violations or deviations were identified.
(4) MPC-hour Tracking i
The inspector determined that individual exposures to concentrations of radioactivity in air are calculated by the licensee by utilizing air sample data for a specific area and records listing stay times of employees in the specific areas.
The inspector selectively reviewed the internal exposere records for the calendar year 1987.
The records reviewed did not show i
individual exposures in excess of regulatory requirements, i
Lince last inspection, there was one exposure in excess of the 43 MPC-hours per week control measure established in 10 CFR 20.103(b)(2).
On November 2,1987, a waste recovery and di3posal operator had been disposing pre-filters of a dust collectien system at the drum baler station.
Enclosures and
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ventilation units had been used during the removal of the l
pre-filters and at the drum baler station.
Frequent entrances l
and exits to/from the drum baler station created an airborne area just outside the staticn. Air samplers in the general area l
indicated an average airborne concentration of approximately 3 MPC.
The worker, unaware of newly created airborne area, removed his respirator several times to seek relief.
As the result of the unexpected high air sample results, the operator was placed on diagnostic fecal restriction, i
Evaluations of the fecal bioassay data resulted in a calculated exposure of 76 MPC-hours.
Since the operator had received an exposure of 2 MPC-hours the previous six days, the total assigned exposure for the seven-day period in question was 78 MPC-hours.
As the result of this incident, operators were instructed to j
perform the work in an enclosed sorting hood and to wear air line respirators when performing this type of work.
In addition, an engineering evaluation was perforrned regarding ventilation requirements for the affected localized area.
Recommendations were incorporated into the airborne reduction project.
The inspector concluded after review that the l
licensee's evaluations, assessments and immediate corrective actions were adequate to preclude future occurrences and l
complied with regulatory requirements.
l No violations or deviations were identified.
(5) Respiratory Protection Equipment 1
(a)
Personnel Qualifications The inspector discussed with licensee representatives the personnel qualification program for the use of respirators.
The respirator training program is part of the general employee training program required for new personnel.
Thereafter. respirator retraining is required every two years.
Physical exams and respirator fit tests are required upon entry on duty and yearly thereafter.
Licensee representatives indicated that, as per procedure, the ability to attain a minimum degree of respiratory l
protection was a prerequisite for employment in all plant l
areas requiring the use of respiratory protection equipment.
The inspector reviewed the qualification records of selected personnel who wore respirators during the week of March 21, 1983, and verified that the l
qualification records were current.
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7 (b)
Respiratory Storage During tours of the facility, the inspector noticed that in storage areas available for respirator issuance, the respirators were stacked on too of each other w a manner which could distort the respirators located at the bottom of the group.
The inspector indicated that this practice of storing respirators for issuance could affect their ability to provide an adequate face-to-mask seal af ter being determined to be in good working condition. Licensee representatives acknowledged the inspector's comments and I
indicated that they would consider ways to improve the storage of respirators in issuance areas.
The inspector indicated that the licensee's actions regarding this matter would be considered an Inspector Followup Item (IFI) and would be reviewed upon a
future inspection (IFI 70-1151/88-03-01).
No violations or deviations were identified.
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(c) Caution Signs, Labels and Controls 10 CFR 20.203 specifies the posting, labeling and control i
requirements for radiation areas, high radiation areas, j
airborne radioactivity areas and radioactive material.
License No. SNM-1107 provides an exception from the requirements of 10 CFR 20.203(f).
Section 3.2.2.4 of the Application for License SNM-1107 states that each entrance l
or access point to the controlled access area shall be i
I posted in accordance with 10 CFR 20.203 except for l
In lieu thereof, a sign bearing the I
legend, "Every container or vessel in this area may contain radioactive material," shall be posted at entrances to each l
area in which radioactive materials are processed, used, or l
- stored, i
l During tours of the f acility, the inspector reviewed the licensee's posting and control of radiation areas, airborne l
radioactivity areas, contaminated areas, and radioactive I
material areas.
The inspector found posting and labeling adequate to meet license conditions and 10 CFR 20 requirements.
No violations or deviations were identified.
(d) Surveys The licensee was required by 10 CFR 20.201(b) and 20.401 to perform surveys and to maintain records of such surveys to show compliance with regulatory requirements.
The
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Application for License No. $NM-1107 Condition 9, required that licensed material be used in accordance with statements, representations, and conditions contained in Sections 2, 3, and 4 of the Application dated March 26, 1984, and supplements thereto.
Paragraph 3.2.1.1 of the i
Application for License SNM-1107 stated that written procedures describing general radiation protection i
requirements shall be maintained and followed.
(1) Facility Surveys The inspector reviewed selected contamination surveys covering the period March 25-30, 1988.
The surveys reviewed contained sufficient information to adequately assess radiological conditions in the different work areas and were performed at the specified frequencies.
L No violations or deviations were ident.ified.
(ii) Personnel Frisking t
During tours of the plant the inspector observed workers leaving the radiation control area (RCA).
Frisking instructions were clearly posted at all exit i
points from the RCA and a recording at the train exit point continually reminded personnel about the frisking instructions.
In addition, there were four closed-circuit cameras monitoring four different exit points which were used to randomly verify employee compliance with the frisking instructions.
All workers whom the inspector observed frisking out performed an adequate frisk.
No violations or deviations were identified.
(e) ALARA Review 1
Section 3.1.2.5.1 of the Application for License SNM-1107
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states that a formal report shall be made by the Regulatory j
Compliance Committee to the Plant Manager every six nonths reviewing personnel exposure data to determine:
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if there are any upward trends developing in personnel exposures for identifiable categories of workers or J
types of operations, 11.
if exposures might be lowered in accordance with the ALARA concept, and i
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4 111. if equipment for exposure control is being properly f
used maintained and inspected.
The report shall include review of other required audits l
and inspections performed during the reporting period and review of the data from the following areas:
personnel exposures, bicassay results, unusual occurrences and inplant airborne radioactivity.
l The inspector reviewed the most recently issued ALARA report covering the period January 1 - June 30,1987.
As of the time of the inspection, the ALARA Report for the second half of 1987 was still in draft form. The following are highlights of the report.
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Manufacturing experienced the only statistically significant trend in airborne concentrations.
It was up at the rate of 2% MPC per quarter over one and one-half years.
L There were no statistically significant trends in MPC-hours.
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Manufacturing experienced the only statistically
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significant trend in invivo resuits; up 7 ug U-235 per i
quarter over one and a half yeart;
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l Conversion had the only statistically significant i
urine trend; down 0.4 uGU/1 per quarter over two years.
Manufacturing had a statistically significant trend in
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whole body dose equivalence; up 33 mrem /qtr over one t
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and a half years.
As a result of the Airborne Reduction Committee's work, a laminar flow module was installed on Pellet i
Line 3 oxidation hood. This unit has significantly reduced measured atrborne concentrations.
This unit j
or similar devices have applicability at a number of other hoods, i
All quarterly averages remain well below regulatory limits.
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Licensee representatives indicated that due to higher uranium enrichment and increased production in the facility, many of the trends being analyzed in the report j
could be adversely impacted.
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The inspector concluded af ter review of the ALARA Repurt for the first six months of 1987 that the licensee addressed relevant issues required oy their license application, j
No violations or deviations were identified.
(f) Technician Training e
The inspector discussed the technician training program with licensee representatives and was in f o~rred that currently there are three levels of technicians (C, B, and A or lead techs). C techs are in a learning mode and upon qualification, are promoted to B level.
B techs are normally assigned to handle routine assignments. A techs, or lead techs, are assigned to handle programs such as the bioassay program, external dosimetry program, etc.
The current training consists of:
on-the-job training with experienced technicians, procedure reviews, engineering work requests which inform the technician of work to be done and work place meetings.
The licensee informed the inspectors that they are evaluating a four tiered technician progression channel (C, i
B, A, and specialist).
It e'uld allow technicians to i
progress through the ranks without hinderance provided they l
pass a written test, an oral test and a practical
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demonstration.
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No violations or deviations were identified.
t (g) External Exposure Control l
10 CFR 20.101(a) specifies the applicable radiattor, dose i
y limits. The inspector reviewed personnel external exposurt
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records for the calendar year 1987 and verified that all individual exposures recorded were less than 1250 millirem I
per calander quarter.
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No violations or deviations were identified.
i (h)
Radiation Work Permits (RWPs)
J The inspector reviewed RWPs for selected activities in progress such as Forklif t Maintenance (RWP #88-13) and J
Respirator Cleaning (RWP #88-10). The inspector determined that the precautions and controls specified in the RWP were j
adequate to inform workers of the hazards that may be j
experienced in order to perform these tasks.
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No violations or deviations were identified.
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Transportation Activities (86740) a.
Quality Assurance Program 10 CFR 71.12 provides a general license to transport, or to deliver j
to a carrier for transport, licensed materials in packages for which i
a license or certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR 71, Part H.
t The inspector determined that the licensee had an NRC approved quality assurance program for packaging, apprcved under Docket 71-0251, with an expiration date of January 31, 1990.
No violations or deviations were identified.
b.
Selection of Packagings The inspector discussed the use of packages which require an NRC Certificate of Compliance (C0C) with cognizant licensee i
j representatives.
The inspector reviewed a C0C for fuel shipping containers, Model RCC-1, USA /5450/AF, and determined that the i
i licensee was a registered user for this container.
A C0C had been issued for the licensee to ship UF cylinders, Model 30A and 30B; L
6 heels in cylinders were shipped in accordance with 49 CFR 173.417.
Licensee representatives stated that no packages were used which were foreign-approved packaging that would require 00T revalidation i
(49 CFR 173 or 10 CFR 71.16).
i The inspector determined through discussions that 00T Spec 55 containers were not used and the licensee was aware of the l
prohibition of use (49 CFR 173.415(b)), that no plutonium shipments had been made nor were planned to be made by air (10 CFR 71.88), and j
the licensee did not rely on special form determinations to qualify shipments (49 CFR 173.469).
No violations or deviations were identified.
c.
Preparation of Packages and Delivery to Carrier i
The inspector determined from review of applicable procedures, review of shipping checklists and review of shipping papers from October 1987 to March 1988, as well as discussions with licensee representatives, that the following requirements were being met.
1 Routine use of container (10 CFR 71.01)
Liquid package requirement (49 CFR 173.412(n))
l Package weight (49 CFR 173.all)
P&ckage marking (49 CFR 172.300 et. seq.)
Radiation surveys (49 CFR 173.442)
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Bracing of packages (49 CFR 173.442)
Shipping paper documentation (49 CFR 172, Sub Part C)
Notification of Consignee (10 CFR 20.311)
No violations or deviations were identified.
6.
Radioactive Waste Management (84850) a.
Waste Manifests 10 CFR 20.311(b) and (c) require that a manifest system be used for i
all shipments of waste to a licensed burial facility. The inspector l
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determined that the manifest had been completed and forwarded as required for the two waste shipments reviewed.
No violations or deviations were identified.
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Waste Classification, Characterization, and Labeling b.
a 10 CFR 61.55 requires that waste be classified and identified as Class A, B,
and C.
The inspector reviewed the isotopic survey i
results for containers in two waste shipments and determined that the classifications shown on the manifests were in agreement with j
i 10 CFR 61.55.
No violations or deviations were identified.
1 c.
Tracking of Shipments, i
The radioactive material shipment procedures and checklists included l
provisions for determining the estimated date of arrival of the shipment, and written and telephone notification of the receiver.
The inspector verified that the two waste shipments had been verified as having been received at the disposal site.
The licensee's procedures included a seven day receipt requirement by the receiver and provisions for tracing the shipment if notification of receipt is j
not received.
No violations or deviations were identified.
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7 Radioactive Solid Waste (88035)
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The inspector reviewed the procedures, shipping records, and license j
requirements for shipments of radioactive waste to the disposal site.
j Regulatory requirements in 10 CFR 20.301 and 10 CFR 20.401 for tne disposal of waste were also reviewed. 10 CFR 20.301 specified the general i
requirements for disposal of waste.
The inspector discussed the radwaste volume reduction program with l
licensee representatives and was informed that the volume of waste shipped in 1986 and 1937 was 12,500 ft3 and 10.900 ft3 respectively.
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j 8.
NRC Information Notices (IN) (92717)
The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or i
- planned, I
IN 87-03 Segregation of Hazardous and low-level Radioactive Wastes I
j IN 87-07 Quality Control of Onsite Dewatering / Solidification Operations by Outside Contractors i
IN 87-26 Cracks in Stiffening Rings on 48-inch Otameter UF6 Cylinders IN 87-31 Blocking, Bracing, and Securing of Radioactive Materials t
Packages in Transportation IN 88-08 Chemical Reactions with Radioactive Waste Solidification Agents j
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