ML19262C486
| ML19262C486 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 11/09/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19262C478 | List: |
| References | |
| 70-1100-79-07, 70-1100-79-7, NUDOCS 8002140074 | |
| Download: ML19262C486 (4) | |
Text
APPENDIX A NOTICE OF VIOLATION Combustion Engineering, Inc.
Docket No. 70-1100 Based on the results of an NRC inspection conducted on September 18-21, 1979, it appe'rs that certain of your activities were not conducted in full compli-ance wit. NRC regulations and the conditions of your license as indicated below.
Icems A, B, C, D and E are Infractions.
Items F, G, H and I are Deficiencies.
A.
Condition 17 of Special Nuclear Material License No. SNM-1067 requires the licensee to comply with the specifications of Regulatory Guide 8.11,
" Applications of Bioassay for Uranium."
Regulatory Guide 8.11 permits, as a minimum, annual urine bioassay for insoluble uranium.
Contrary to the above, one employee employed on April 24, 1978 and another employee employed on May 22, 1978, were not included in the June 1978 urine bioassay program, and the 1979 urine bioassay program had not been
)et conducted at the time of this inspection.
B.
Section 15.14 of Special Nuclear Material License No. SNM-1067 is con-cerned with equipment released from restricted areas for unrestricted use.
Section 15.14 states.
" Radioactivity levels on all surfaces shall be at the lowest level practicable after cleaning, and in no case shall exceed a removable level of 1000 dpm/100 cm2 and a fixed level of 500 dpm/100 cm2 average, and 25,000 dpm/100 cm2 maximum alpha for any equipment to be released from Health Physics Restricted Areas.
No surfaces will be painted, plated, or covered by any other means prior to release under this criteria.
The radioactivity on the interior surfaces of any piece of equipment shall be determined by making measurements at all appropriate points where the contamination levels are likely to be representative of contamination on interior surfaces.
Any surfaces which are likely to be contaminated, but are of such size, construction or location as to make the surface inaccessible for purposes of measurement shall be presumed to be contaminated in excess of the above limits.
Records will be maintained to indicate contamination levels of all equipment which has been released in accordance with the above.
These records will provide contamination levels and the identity of the recipient of the equipment."
8002140'D)
APPENDIX A 2
Contrary to the above, during 1979, on at least fifty different occasions, equipment was released from the Pellet Shop of the Manufacturing Facility, a restricted area, for unrestricted use and items were not monitored for fixed contamination, radioactivity on the interior surfaces of equipment was not determined, and records were not maintained showing the identity of the recipient of the equipment released.
C.
Section 8.2 of Special Nuclear Material License No. SNM-1067 requires written procedures.
Section 13.1 of the Nuclear Licensing and Safety Procedures Manual, developed pursuant to the above states,
"...In addi-tion to a continual program of in plant training, formal sessions shall be scheduled for all hot shop personnel on a semi-annual basis..."
Contrary to the above, as of this inspection, ten employees were last trained in December 1978, one employee was last trained in June 1978, six employees were last trained in December 1977, and one employee has not received training since June 1977.
All of the employees cited above have worked in the hot shop of the manufacturing area.
In addition, one employee did not receive training during 1978 and 1979 in the Nuclear Laboratories.
D.
Section 15.10 of Special Nuclear Material License No. SNM-1067 states,
" Persons whose work requires entering the unclad Fuel Handling Areas for a short period of time...must put on a laboratory coat and shoe covers.
Upon completion of their work...an alpha monitor is available for persons to check themselves for contamination.
Any person having any contamina-tion on any part of his clothing or body must remove the clothing..."
Contrary to the above, on September 18, 1979, an employee left the Pellet Shop of the manufacturing area, an unclad Fuel Handling area, and he did not monitor his clothing for the presence of radioactive contamination.
On September 20, 1979, an employee left the Ceramics Laboratory in Build-ing 5, an unclad Fuel Handling area, and he did n)t monitor his clothing for N.e presence of radioactive contamination.
E.
Section 8.2 of Special Nuclear Material Licensa h 3.
SNM-1067 requires written procedures.
Section 8.2 of the Nuclear Licensing and Safety Pro-cedures Manual, developed pursuant to the above states, "Any person whose 7 day running total exceeds 2.5 Maximum Permissible Concentration Days (MPDC) must work under a radiation work permit (RWP) which specifies that his breathing zone (BZ) sample be counted and calculated after each 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period.
Contrary to the above, on July 6, 1979, an employee's BZ sample was not counted and calculated after each 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> period, and this employee's 7 day running total exceeded 2.5 MPCD.
APPENDIX A 3
F.
10 CFR 20.408(b) states, "When an individual terminates employment with a licensee describe in paragraph (a) of this section, or an individual assigned to work in such a licensee's facility but not employed by the licensee, completes the work assignment in the licensee's facility, the licensee shall furnish to the Director of Management and Program Analysis, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, a repFt of the individual's exposures to radiation and radioactive mater F, incurred during the period of employment or work assignment in the li' asee's facility, containing information recorded by the licensee pursuant to SS20.401(a) and 20.108.
Such report shall be furnished within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assign-ment, whichever is earlier."
10 CFR 20.409(b) states, "When a licensee is required pursuant to 6620.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual.
Such notice shall be transmitted at a time not later than the transmittal to the Commission, and shall comply with the provisions of S19.13(a) of this chapter."
Contrary to the above, an employee terminated his employment with the licensee on January 31, 1979, and the required reports were not submitted until August 1, 1979.
G.
10 CFR 20.203(f) states, "(1) Except as provided in paragraph (f)(3) of this section, each container of licensed material shall bear a durable clearly visible label identifying the radioactive conterats.
(2) A label required pursuant to paragraph (f)(1) of this section shall bear the radiation caution symbol and the words ' CAUTION, RADI0 ACTIVE MATERIAL' or ' DANGER RADI0 ACTIVE MATERIAL. '
It. shall also provide suf-ficent information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or mini-mize exposures."
Contrary to the above, on September 20, 1979, a cabinet in the Building 18 High Bay Annex containing approximately 425 kilograms of Uranium was not conspicuously posted inasmuch as a sign stating Caution-Radioactive Material was completely covered.
Contrary to the above, on September 20, 1979, a safe located in Building 5 was posted with a ' Caution - Radioactive Material' label but the label did not identify the contents, and neither did it contain sufficient information to permit individuals working in the vicinity to take precautions to avoid or minimize exposures.
APPENDIX A 4
H.
10 CFR 20.401(a) requires each licensee maintain the radiation exposure of all individuals on Form NRC-5, or on clear and legible records containing all the information required by Form NRC-5.
Contrary to the above, records that are maintained as equivalent to Form NRC-5 do not contain the following information as required by Form NRC-5:
Emplojees social security number Name of licensee Method of monitoring I.
Section 8.2 of Special Nuclear Material License No. SNM-1067 states,
"...all procedures shall provide for the labeling of all mass limited containers to indicate the enrichment, and the uranium content and shall provide for maintaining the identity of enrichments of all SNM in the facility."
Contrary to the above, on September 20, 1979, several closed containers containing SNM bearing waste materials were not lebeled to indicate the enrichment and the uranium content.
These items were located in the Pellet Shop Annex.