ML19208B392
| ML19208B392 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 07/09/1979 |
| From: | Lichtenberger H ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19208B391 | List: |
| References | |
| NUDOCS 7909200158 | |
| Download: ML19208B392 (2) | |
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C'-E Po r Systems Tel. 203/688-1911 Combustion Engineenng. Inc.
Telex: 99297 1000 Prospect Hill Road Windsor, Connecticut 06095 H POWER SYSTEMS License SNM-1067 Dociet 70-1100 July 9, 1979 U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406 Atter. tion:
Mr. George H. Smith, Chief Fuel Facility & Material Safety Branch
Reference:
Letter from Mr. G. H. Smi;h to Mr. H. V. Lichtenberger, dated June 15, 1979; Inspection 70-1100/7903
. Gentlemen:
This is in response to the above referenced letter in which you reported three infractions that were determined during your inspector's visit to our facility on March 28-30, 1979.
Appendix A, Item A Condition 9 of SNM-1067 incorporates Section 8 of our license application which requires " written operating procedures".
Section 4.6 of our Nuclear Licensing
& Safety Procedures states that "a Radiation Work Permit must be secured for any operation in which the normal containment and/or ventilation is made less ef fec-tive".
The inspector noted on March 30, 1979 that the containment and ventila-tion were made less effective on the Centerless Grinder in that the plexiglass shield had been removed on three sides and a Radiation Work Permit was not secured.
The grinder was not in operation at the time the plexiglass was removed. There was no fuel in the system except for small amounts of residual surface contamina-tion.
Reutine adjustments were being performed prior to introducing the next batch of fuel pellets.
Thus, no " operation" on fuel or non-routine maintenance was being performed and no Radiation Work Permit is required.
The operating sheet for the grinder has been revised however, to require that only one face of the plexiglass be removed when making adjustments in the interest of providing the greatest possible margin of safety against airborne contsnination. Accordingly, it is requested that this item of noncompliance be withdraun.
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4 Appendix A, Item B Condition 9 of SNM-1067 incorporates Section 15 of our license application which 2
states that a removable beta level of 5000 dpm/100 cm requires clean-up within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in restricted areas and that a maximum removable beta level of 200 dpm/
100 cm2 is permitted in clean areas. The inspector noted that surface contamina-tion surveys to determine the beta contamination levels in restricted areas or clean areas are not made in Buildings #5 and #17.
While it is recognized that removable uranium may be detected by surveying for either alpha or beta surface contamination, we believe that alpha surveys are biologically more restrictive and relate more directly to potential personnel hazards. An application to amend license SNM-1067 to reflect the fact that re-movable uranium will be surveyed by alpha detection only will be submitted within 90 days of the date of this letter.
Beta surveys will be used as a confirmatory method when considered necessary by health and safety personnel.
Appendix A, Item C Condition 9 of SNM-1067 incorporates Section 15 of our license application which requires personnel to monitor their hands prior to leaving unclad fuel handling areas. On March 29, 1979, the inspector observed an employee exit the Ceramics Lab of Building #5 without monitoring as required.
The Development Department will emphasize personnel monitoring requirements during all future training sessions.
The next radiation workers training session will be held prior to August 15, 1979.
In addition, each controlled area in Building #5 will be inspected for proper posting of personnel monitoring requirements.
Proper posting of the areas will be corrected as required.
This will be accomplished by July 31, 1979.
Very truly yours, H. V. Lichtenberger Vice President-Nuclear Fuel Nuclear Power Systems-Manufacturing HVL/GJB/ssb
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