LD-90-024, Responds to NRC Re Violations Noted in Insp Rept 70-1100/89-03.Corrective Action:Responsibility for Individuals Taking &/Or Evaluating Bioassay Will Be Clarified in Future
| ML20012D103 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 03/15/1990 |
| From: | Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| LD-90-024, LD-90-24, NUDOCS 9003260466 | |
| Download: ML20012D103 (9) | |
Text
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March _15, 1990 LD-90-024 l;
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l Docket No.- 70-1100 License No. SNM-1067 Dr. Malcolm R. Knapp, Director Division of Radiation Safety and Safeguards i
U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Subject:
Response to Notice of Violation (Inspection Report No. 70-1100/89-03)
References:
(A)- Letter LD-89 ')83, A. E. Scherer (C-E), to L
R. R.
Bellamy (NRC), dated July 28, 1989 l
(B)
Letter, R. R. Bellamy (NRC), to P.
L. McGill (C-E), dated June 30, 1989 (C)
Letter, M. R. Knapp (NRC) to q
C. R. Waterman (C-E), dated, February 14, 1990 i
Dear Dr. Knapp:
In Combustion Engineering's letter of July 28, 1989, Reference (A), we responded to a Nuclear Regulatory Commission Notice of Violation transmitted via Reference (B).
Your letter of February 14, 1990, Reference (C), responded to Combustion Engineering's C_,3 contention that we had acted appropriately regarding the bioassay evaluations conducted and believed that we were not in violation of 10 CFR 20.103 (a) (3) requirements.
oo0 Further, you requested that Combustion Engineering C @ provide additional information concerning the subject l
gg violation and the action we had taken.
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The Enclosure responds to your request.
In essence, while
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ex Combustion Engineering continues to believe that we acted
- $8 prudently and in a conservative manner concerning the op evaluation of bioassay results, we have, nevertheless f
instituted a procedure to address the concerns expressed by gg the Nuclear Regulatory Commission.
kko Nuclear Power Businesses 1000 Prospect Hill Road (203) 285-5200 Combustion Engineenno, Inc.
Post Office Box 500
- J Windsor, Connecteut 06095-0500
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Dr. Malcolm.R. Knapp LD-90-024
.c March-'15,11990'-
Page 2 If I can be-of further assistance on this matter, please do not hesitate to call me or Mr. J.
F.
Conant of my_ staff at (203).285-5002.
Very truly yours, j-COMBUSTION-ENGINEERING, INC.
I::
l A.
Scherer.
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Director L
Nuclear Licensing AES:jeb cc: G.
Bidinger (NRC) t J. Roth_(NRC - Region I) l l:
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SUPPLEMENTAL RESPONSE TO NOTICE OF VIOIATION l'
A complete statement of the violation and Combustion Engineering's original response is attached for your information.
Combustion Engineering hereby supplements its response with the following:
The two individuals involved in the subject violation were in-vivo counted in June, 1989.
The specific results were
.43 i 43 and 54 i 37 micrograms U-235 as compared to 0 i 43 and 0 i 45 micrograms U-235, respectively, from their prior in-vivo counting (December, 1988).
These results indicate that neither individual exhibited any evidence of l
an acute intake of radioactive material.
Both of the June, 1989 in-vivo counts are well below facility action levels and Regulatory limits.
We believe that the in-vivo results confirm the conclusions drawn by Combustion Engineering based on the bionssay data evaluation performed at the time the incident occurred.
In your letter you also indicated that Combustion Engineering had exceeded its go/no-go action level for determining the need for further bioassay evaluations since we.had not accounted for alpha activity contributed by-other significant uranium isotopes in our enrichment mixture.
While it is correct to state that combustion Engineering did not use alpha activity contributed by other significant isotopes of uranium, the go/no-go criterion used at the time was based on action levels specified in the facility license which were based solely on U-235.
As such, not-measuring the contribution of other significant isotopes of uranium was not material to the decision s
process.
Because the decision re further bioassay evaluation was, garding the need for in fact, made on a consistent uranium isotope basis, we believe that our evaluation of bioassay results was both prudent and conservative.
Nevertheless, the ambiguity resulting from this incident has pointed to a need to clarify our Radiological Protection Instructions.
To this end, Combustion Engineering has amended its Bioassay Program implementing documents to ensure that fecal analysis takes into consideration other significant isotopes of uranium when used for making an assignment of intake from acute exposure.
We believe that this action should resolve the Nuclear Regulatory Commission's concern in this matter.
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Ii-Response to Noti's of violation o
(
.(NRC Inspection Report No. 70-1100/89-03) 4 statament af vialatlan 19 CFR 20.201
- surveys" states in part m - regulations' in this parti, "surv,ey" means, that (a). As used in the r:41stion hasards'inci an evaluation of the-
-Cicposal,.or presence. dent to the productionofradiosiativematerialsor,othersou use release cf radiation under' a specific set of conditions.
When typropriate, such evaluation includes a physical' survey of the location of~ materials'and' equipment and measurements of levels F
- cf radiation or concentration's of ra,dioactive material present.
6 k f(1) may be necessary for'the licensee to comply.with the.(b) Each licens y
r:gulations in this part.
' Contrary to the above, between February 27, 1989 and May 26,
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19896 an adequate' evaluation of bioassay results required by 10
.. lCFR 20.103(a)(3) was not. conducted to assure compliance with the r:gulations'in this part.
1
- camples from two individuals exposed to radioactive materials onSpecifically, the February 27 1989.during removal of a contaminated sheet of
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plcstic from, the'FA-1 ventilation system messanine floor were not h
cd:quately evaluated to' determine compliance with 10 CFR J
20.103 (a) (3).
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Response
combustion Engineering has reviewed the records and actions taken with respect to two workers who had abnormally high lapel air campler' activities.
Combustion Engineering believes that the 5'ostionstakenandtheevaluationsperformedwereinfull
,$compliancewiththerequirementsspecifladin10CFR20.201and 30.103 (a) (3).
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Combustion Engineering believes that adequate surveys of the work cr03,were conducted and that, based on these surveys, both individuals were assigned lapel air samplers while working in the curveyed' area.
Combustion Engineering further believes that occigning intakes to both of these individuals based on the lapel
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cir sampler activities complies with the requirements of 10 CFR 20.103 (a) (3).
Both our air sampling and bioassay programs l_
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[usd,guidanceprovidedinWASN-1251,APPI.ZCATIONSOFBICASSAYFOR W
15tANION =, dated June 1974.
WASN-1251, Section IV-1.1, states in part,1*if an air sampler is located such that airborne
. contamination,1enroute from the source to the workers breathing u
tone,, must pass by the sangple head, the probability of missing arf
- Antake-is considered to be too low to justify the additional
'bicassays.
The additional bionssays are not performed for a cpecific individual if the licensee can demonstrate that the air-campling~ system used to protect the individual is adequate to CGtect any significant intake."
Combustion Engineering believes that when a lapel air sampler is used for determining the intake sf-radioactivity that all of the above conditions are set.
'I Saced on the circumstances surrounding the higher than normal
.Itpel air sampler activities, combuntion Engineering feels that using the activity readings from the lapel air samplers for calculating MPC hours and using that value in the seven day running total-for intake was' conservative and meets all
- r:gulatory requir'daants.
Based on the seven day running total MPC hours, the Manager of Radic, logical Protection and-Industrial 00foty removed both individuals from the Pellet Shop until further evaluations could be completed.. Our procedure, RPI-208,
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Dic2ssay Program, requires special bioassays when 40 MPC hours is cx2 ceded.
Since both individuals were involved in whatever i occurred causing the above normal air sampler raadings, both
[kindividualswererequestedtogiveurineandfocalsamplesbased
'enly on one~ individual's seven consecutive day total intake
', exsceding 40 MFC h'ours.
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Th9 purpose for taking the bioassay samples was based on gu'idance,
provided by an outside consultant.
This consultant provided the following guidance in determining the need for considering a L chtrigs-in work assignments:
a.
In-vivo lung counting greater than 175 alcrograms' U235.
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Urine bionssays greater than 141 dpa U/1 (sua of U234, t
U235 and U238).
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Faces bioassays. greater than 55 dpa U235 excreted per
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day,.this being obtained by multiplying the opa U235 i
per gram, wet weight by the total wet weight per sample.
This assumes the total sample represents one days feoal j
loss.
Novaver. avan if the inval of as asw trnss avereted nar dav la sweeadad. Y den t racs. =nd a e
cenalderation of chansa in work analshment unlaan tha
-in-vive luna and urinary blemanav ranults avened the levels in a and b abava.
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Th3 Manager of Radiological Protection and Industrial Safety provided the bionssay sesults_ to the Program Manager,
, 3tadiological and Industrial saf.ety for his evaluation, to make a G;tcraination as to whether or not these two individuals could be t
c11 owed to go back to work in an area with airborne i
f,ccntamination.
Tife Program Manager, based on the urinalysis rccults for both individuals being 0 and focal U235 levels being c noiderably less than 55 dpa for both individuals, made a deter-
-ainttion that both individuals could be returned to normal, unr stricted duty.
ThoactionlevelsrecommNndedbyourconsultantandusedinour hbiocesayprogramandRPI'sarebasedonchronicintakesand, l
th3refore, are considered conservative when used for acute i' intakes.
i-L Baced on the conservatism of these action levels a simple
' 02/no-go decision was deemed appropriate.
Combustion Engineering believes that the actions of responsible individuals within our organization were appropriate and were bacco on guidance provided in WASH-1251, Regulatory Guide 3.1'1, 3fDREG/CR-4884, and ICRP-30.
Nevertheless, as part of ongoing I
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f.9 Cf$ orts and-to further assure that in the future proper actions
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individuals responsible for.taking and/or evaluating' bioassay information will have their individual responsibilites clarified.
. W3 believe that this action will preclude any confusion which saf i
have-existed and which could potentially result:in delays in-properly processing bioassays.
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