ML19208B399

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IE Insp Rept 70-1100/79-03 on 790328-30.Noncompliance Noted:Failure to Perform Beta Surveys,Failure to Get Radiation Work Permit & Failure to Monitor Existing Unclad Fuel Handling Area
ML19208B399
Person / Time
Site: 07001100
Issue date: 06/14/1979
From: Clemons P, Crocker H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19208B391 List:
References
70-1100-79-03, 70-1100-79-3, NUDOCS 7909200170
Download: ML19208B399 (8)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.:

70-1100/79-03 4

Docket No.:

70-1100 License No.:

SNM-1067, Priority 1, Category UR Licensee: Combustion Engineering, Inc.

P. O. Box 501 Windsor, Connecticut 06095 Facility Name:

Nucl, ear Manufacturing Facility Inspection at Windsor, Connecticut Inspection conducted: March 28-30,1979 Inspector: (( U%

z P. E. Clemons, Radiation Specialist d'atd siljne I

Approved by: g f.

(//(hD H. W. Crocker, Acting Chief, Radiation darfe sign ~ d' '

e Support Sectit n, FF&MS Branch 6

Inspection Summary Inspection on March 28-30, 1979 (Report No. 70-1100/79-03).

Areas Inspected:

Routine unannounced inspection by a regional based inspector of the Radiation Protection Program including:

10 CFR 71.51, dosimetry audits, external radiation surveys, ventilation, radiation work permits, general air samples, stack samples, smears, organization, decomissioning plan, bioassay, termination reports and receipts of radioactive material. Shortly after arrival, areas where work was being conducted were examined to review radiation control procedures and practices. The inspection involved 23 inspector-hours onsite by one regional based NRC inspector.

Results:

Of the 14 areas inspected, no items of noncompliance were identified in 11 areas.

Three apparent items of noncompliance were observed in three areas (infraction - failure to perform beta surveys, Paragraph 4; infraction - failure to monitor, Paragraph 5; infraction -

failure to get a radiation work permit, Paragraph 3).

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DETAILS 1.

Persons Contacted F. Pianki, General Manager, Fuel Fabrication G. Bakevich, Nuclear Licensing and Safety Supervisor P. Rosenthal, Manager of Health Physics The insroctor interviewed several other licenesee employees durir.g the course of the inspection.

2.

Intarnal Audits Section 8.3 of the licensee's application, which is incorporated by License Condition No. 9, requires that monthly audits for radiological considerations be performed by qualified individuals and that an annual audit be performed by the Nuclear Safety Committee.

The Committee is required to review all aspects of the criticality and radiological safety programs.

The inspector questioned licensee representatives regarding the conduct of periodic internal audits as required by Section 8.3 of Special Nuclear Material License No. SNM-1067.

The inspector reviewed audit reports for the period July - December 1978 for the monthly radiological safety audits.

The inspector also reviewed the report c:

.e annual audit that was performed by the Nuclear Safety Committee on December 20, 1978.

No items of noncompliance were identified.

3.

Radiation Work Permit Section 8.2 of the licensee's application states " written operating procedures are provided..."

Section 4.6 of the Nuclear Licensing and Safety Procedures Manual, developed pursuant to the above, states "A Radiation Work Permit should be secured for any operation in which the normal containment and/or ventilation is made less effective."

With the assistance of a licensee representative, the inspector perfonned linear face velocity measurements on several pieces of equipment in the Manufacturing Facility of Building No.17 on March 30,1979. As they approached the Centerless Grinder in the Pellet Shop, the inspector noted that containment (Plexi-Glass) h o[6

. surrounding the Centerless Grinder had been removed on three sides.

The inspector was informed that the Centerless Grinder wheel was being realigned.

The inspector asked the licensee representative to make a measurement to determine the face i

velocity. With the Plexi-Glass removed there was no air flow into the Cer.terless Grinder.

Face velocities at hood openings y

must exceed 100 linear feet per minute.

The inspector asked the licensee representative if a Radiation Work Permit (RWP) was required to perform the operation.

The licensee representative, a new employee, did not know.

The inspector asked if a RWP had been issued for the specific operation, and he was told that a RWP had not been issued.

The inspector then referred to the Nuclear Licensing and Safety Procedures Manual which states that a RWP should be secured for an operation in which normal containment or ventilation is made less effective.

The inspector stated that failure to secure a Radiation Work Permit when the containment and/or ventilation is made less effective represents noncompliance with a condition of the license.

(79-03-01) 4.

Beta Surveys On March 28, 1979, as the inspector reviewed smear survey records for the period July - December 1978, he noted that all of the data was concerned with alpha contamination.

He asked the licensee for survey records for beta evaluations.

He was informed by a licensee representative that. hey did not make beta surveys.

Condition 9 of Special Nuclear Material License No. $NM-1067 incorporates Section 15 of the licensee's application.

Section 15.3.4 of the licensee's application states that a removable beta level of 5,000 dpm/100 cm2 requires cleanup within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in Health Physics restricted areas.

Section 15.3.5 of the licensee's application states that a maximum removable beta level of 200 dpm/100 cm2 is permitted.in clean areas.

The inspector asked a licensee representative how they could comply with Sections 15.3.4 and 15.3.5 if beta surveys were not performed.

There was no response.

Failure to perform surveys to evaluate the presence of beta contamination represents noncompliance with a condition of the license.

(79-03-02) fl Ak

. 5.

Monitoring On March 29, 1979, the inspector toured the Nuclear Laboratories of Building No. 5, acctmpained by a licensee representative, to observe ongoing activities.

The inspector and the licensee representative entered an area designated as the Ceramics Lab, an unclad fuel handling area, acccrding to the licensee repre-sentative.

They put on lab coats and shoe covers in the clean

' area of the Ceramics Lab before entering the potentially con-taminated areas of the lab.

They tcured the potentially con-taminated areas of the Ceramics Lab and then returned to the

" change line" where they removed the protective clothing prior to entering the " clean area" of the lab.

At this time, the inspector and the licensee representative exited the Ceramics Lab without monitoring with the available instrument, at which time the inspector inquired of the monitoring requirement upon exiting a potentially contaminated area.

The licensee representative stated that he was required to monitor prior to leaving the Ceramics Lab, an unclad fuel handlir.g area.

The licensee representative and the inspector returned to the Ceramics Lab and monitored as required.

Section 15.10 of the licensee's application requires personnel to monitor upon exiting an unclad fuel handling area.

The inspector informed a licensee representative that failure to monitor upon exiting an unclad fuel handling area represents noncompliance with the license conditions.

(79-03-03) 6.

Quality Assurance Program for Shipping Containers 10 CFR 71.51 states:

"(a) The licensee shall establish, maintain and execute a quality assurance program satisfying each of the applicable criteria specified in Appendix E, " Quality Assurance Criteria for Shipping Packages of Radioactive Material," and satisfying dny specific p~rovisions of which are applicable to the licensee's activities including procurement of packaging.

The description of the quality assurance program shall include a discussion of which requirements of Appendix E are applicable and how they will be satisfied.

A description of that program shall be filed, in accordance with this section, by January 1,1979, with the Director, Office of Nuclear Material Safety and Safeguards, Nuclear Regulatory Conmission, Washington, D.C.

20555.

If a person has filed such a description, the continued use of his existing quality assurance program is authorized until the acceptability of the program has been finally determined by the Commission."

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. The inspector asked a licensee representative if they had submitted a copy of the description of the program to the Director, Office of Nuclear Material Safety and Safeguards, as required by 10 CFR 71.51(a).

The licensee showed the inspector a copy of the program that was submitted on June 28, 1978.

No items of noncompliance were identified.

7.

Organization There has been a recent change in the licensee's Health and Safety

~ staff.

The licensee has hired a Radiation Specialist, a recent graduate of Rutgers University, to replace an experienced Radiation Specialist who resigned on March 2,1979.

The licensee also plans to add a third Health Physics technician to the staff within the immediate future.

No items of noncompliance were identified.

8.

Dosimetry The inspector reviewed dosimetry records for the period July -

December 1978 for personnel monitored at the Nuclear Fuel Manufacturing Facility.

Approximately 250 people were monitored during the year of 1978 and the maximum whole body dose reported for one employee was 1990 millirem.

No items of noncompliance were identified.

9.

External Radiation Surveys Part 20.201 " Surveys" states:

(a) As used in the regulations in this part, " survey" means an evaluation of the radiation hazards incident to the production, use, release, disposal, or presence of radio-active materials or other sources of radiation under a specific set of conditions.

When appropriate,.such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or con-centrations of radioactive material present.

(b) Each licensee shall made or cause to be made such surveys as may be necessary for him to comply with the regulations in this part.

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. The inspector reviewed radiation survey data for Plutonium-Beryllium neutron sources located in the Fluoroscope unit and the Drum and Filter Assay unit.

The surveys were performed on February 16, 1979 and the maximum dose rate observed was 0.5 millirem per hour at the surface of each unit.

The inspector also reviewed beta-gama survey data for surveys performed i

during the period of October - November 1978.

No items of noncompliance were identified.

10.

Ventilation Section 15.7 of the licensee's application requires face velocities at hood openings to be at least 100 feet per minute.

As stated in Item No. 3 of this report, the inspector performed linear face velocity measurements, with the assistance of a licensee representative on March 30, 1979. With one exception, all of the hoods had a linear flow exceeding 100 linear feet per minute.

No items of noncompliance were identified.

11. Air Samples The inspector reviewed general air sample data fcr the period July - December 1978 to determine if the licensee was in compliance with regulatory requirements.

No items of noncompliance were identified.

12. Stack Samples The inspector reviewed stack sample data for the period July -

December 1978 to determine if the licensee was in compliance with regulatory requirements.

No items of noncompliance were identified.

13. Smears Section 15.6.1 requires that smear samples be taken and analyzed.

for alpha activity to verify compliance with internal limits.

The inspector reviewed smear survey records for the period July -

December 1978 to assure that the licensee was in compliance with this license condition.

No items of noncompliance were identified.

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. 14. Decommissioning Condition No. 20 of Amendment No.17 to SNM-1067, dated May 25, 1978, required the licensee to submit a plan for the future decontamination of the places of use and sites authorized by the license.

The licensee was to submit the plan within six months of the issuance of the amendment.

The inspector asked a licensee representative if the decommissioning plan had been submitted as required.

The licensee representative showed the inspector a copy of the plan that had been submitted on January 12, 1979.

15. Biosaasy Condition 17 of SNM-1067 requires the licensee to develop and maintain a bioassay program which meets the specifications of Regulatory Guide 8.11, " Application of Bioassay for Uranium."

Regulatory Guide 8.11 has an annual sampling frequency for minimum programs.

The inspector reviewed urine bicassay data for 1978 for approximately 250 employees.

The inspector also reviewed whole body counting data for selected personnel juring 1978.

The data did not indicate any problem with exposure control or any condition exceeding any regulatory limit.

No items of noncompliance were identified.

16. Termination Reports 10 CFR 20.408 requires a licensee to submit to the Director of Inspection and Enforcement a report of an individual's exposure to radiation and radioactive material, incurred during the period of employment in the licensee's facility when the individual terminates employment with the licensee.

The inspector reviewed ten exposure reports during 1978 of employees that had terminated employment with the licensee.

These reports had been submitted to the Director of Inspection and Enforcement.

No items of noncompliance were identified.

17.

Receipt of Radioactive Material 10 CFR 20.205(b)(1)' requires that each licensee upon receipt of a package of radioactive material must monitor the external surface TI)b OIL i~

, of the package for contamination.

The inspector reviewed the incoming shipment records for two shipments received by the licensee in November 1978 to determine compliance with the i

regulations.

No items of noncompliance were identified.

18.

Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 30, 1979. The inspector summarized the purpose and the scope of the inspection and the findings as presented in this report.

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