ML19262C490
| ML19262C490 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 11/09/1979 |
| From: | Clemons P, Roth J, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19262C478 | List: |
| References | |
| 70-1100-79-07, 70-1100-79-7, NUDOCS 8002140080 | |
| Download: ML19262C490 (11) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION I Report No.
70-1100/79-07 Docket No.
70-1100 License No.
SNM-1067 Priority 1
Category UR Licensee:
Combustion Engineering P.O. Box 501 Windsor, Ct.
06095 Facility Name:
Nuclear Manufacturing Facility Inspection At:
Windsor, Ct.
Inspection Conducted:
September 18-21, 1979 Inspectors:
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w P.g.'Clemons,RadiationSpecialist date 0l W iiNb9 Roth, Fuel Facilities inspector datg
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J. P..Stohr, Radiation Support Section, date
,FF&MS Branch Inspection Summary:
Inspection on September 18-21, 1979 (Report No. 70-1100/79-07)
Areas Inspected:
Routine unannounced inspection by regional based inspectors of the Radiation Protection Program including:
outstanding items, training, bioassays, release of equipment for unrestricted use, procedures, contamination control, dosi-metry, annual report, ventilation, termination report, posting and labeling, NRC Forms, leak test, air samples, breathing zone samples, smears, audits, neutron sur-vey and instrument calibration.
Shortly after arrival, areas where work, was being conducted were examined to review radiation control procedures and practices.
The inspection involved 47 inspector-hours onsite by two regional based NRC iiispectors.
8 c02140 b Region I Form 167 (August 1979)
Results:
Of the 19 areas inspected no items of noncompliance were identified in 9 areas.
Ten apparent items of noncompliance were observed in ten areas (infraction - failed to do urine bioassay paragraph 4; infraction - failed to do fixed alpha surveys paragraph 5; infraction - failed to train paragraph 6; infraction - failed to monitor paragraph 7; infraction - did not collect BZ samples each 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> paragraph 8; deficiency - failed to submit termination report paragraph 9; deficiency - failed to label container paragraph 10; deficiency - form did not comply with Form NRC-5 paragraph 11; deficiency -
failed to follow procedures paragraph 12).
DETAILS 1.
Persons Contacted Mr. G. Bakevich, Nuclear Licensing and Safety Supervisor
- Mr. H. Lichtenberger, Vice President Mr. F. Pianki, General Manager, Fuel Fabrication Mr. P. Rosenthal, Manager, Health Physics The inspector interviewed several other licensee employees during the course of the inspection.
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (0 pen) Noncompliance (79-03-02) Failed to survey for beta contamination.
The licensee is still not surveying to determine the presence of beta contamination.
According to the Nuclear Licensing and Safety Supervisor he was under the impression that inasmuch as he is going to request a license amendment to eliminate the requirement to do beta surveys he did not have to make the evaluation.
He was informed by the inspector that beta surveys must be performed until such time as the license is amended eliminating the requirement.
(0 pen) Noncompliance (79-03-02) Failed to Monitor.
This item was repeated during this inspection; therefore., it is recurrent and it will be addressed in a subsequent inspection.
(Closed) Noncompliance (79-04-02) Alpha survey meters were not available for use at the emission spectrograph lab in Building 5 and at the exit to Building 6.
The inspector observed that alpha survey meters were at both locations during this inspection.
3.
Internal Audits Section 8.3 of the licensee's application, which is incorporated by License Condition 9, requires that monthly audits for radiological con-siderations be performed by a qualified individual.
The inspector ques-tioned licensee representatives regarding the conduct of the monthly internal audits as required by Section 8.3.
The inspector reviewed audit reports for the period January-July 1979 for the monthly radiological safety audits.
No items of noncompliance were identified.
4 4.
Bioassay The inspector asked a licensee representative for urine bicassay data for 1979.
He was informed that the urine bioassay program had not begun for 1979.
He then requested the 1978 bioassay data, which was given him.
The 1978 program was done in June 1978.
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 annual urine bioassay for insoluble uranium.
The inspector selected the names of ten individuals who should have participated in the June 1978 annual urine bioassay program.
The inspector noted that one employee was employed on April 24, 1978 and another employee was employed on May 22, 1978 and he also noted that neither employee was included in the 1978 bioassay program.
The inspector was informed by a licensee representative that both employees should have been included in the annual urine bioassay program.
The inspector noted that failure to include appropriate employees in the annual urine bioassay program represents noncompliance with the license condition (79-07-01).
The inspector also noted that the annual bioassay program for 1979 had not begun at the time of this inspection.
5.
Alpha Surveys Section 15.14 of Special Nuclear Material License No. SNM-1067 is concerned with equipment released from restricted areas for unrestricted use.
Sec-tion 15.14 states, " Radioactivity levels on all surfaces shall be at the lowestlevelpracticableafterclegning,andinnocaseshallexceeda 2
removable level of 1000 dpm/100 cm and a fixed level of 500 dpm/100 cm average, and 25,000 dpm/100 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 con-tamination 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.
5 Records will be maintained to indicate contamination levels of al'. quip-ment which has been released in accordance with the above.
Tbc e records will provide contamination levels and the identity of recipient of the equipment."
The inspector asked the licensee representative for the records of all equipment released from the restricted area of the Manufacturing area for the period January-June 1979.
The records were given the inspector.
He noted that during the period, on at least fifty different occasions, equipment had been released from the Pellet Shop of the Manufacturing Area, a restricted area, for unrestricted use.
He also noted that the records indicated that only surveys for removable alpha contamination had been performed.
The inspector asked a licensee representative if surveys had been performed for fixed alpha contamination, he also asked if surveys had been performed to determine the contamination levels on the interior surfaces of the pieces of equipment released for unrestricted use.
He was told that these surveys were not performed.
The inspector also noted that the records did not identify the recipient of the equipment in any instance during the period of January-June 1979.
He was told that the recipients of the equipment were never identified.
The inspector stated that failure to comply with license requirements represents noncompliance (79-07-02).
6.
Training The licensee is required to provide a continual training program as required by the license.
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 addition to a continual program of in plant training, formal sessions shall be scheduled for all hot shop personnel on a semi-annual basis..."
To ascertain that appropriate personnel were being trained as required, the inspector requested a list of all personeel assigned to the hot shop.
The inspector also requested a list of personnel who are not assigned to the hot shop (Pellet Shop) but who are required to work in the hot shop on a frequent basis.
Both lists were given to the inspector.
The inspector then requested training records which would indicate when these employees were trained.
The recerds were given to the inspector.
The inspector noted the following facts as indicated by the training records and the list of employees:
6 a)
Ten employees were last trained in December 1978.
b)
One employee was last trained in June 1978.
c)
Six employees were last trained in December 1977.
d)
One employee has not received training since June 1977.
The inspector asked a licensee representative if these facts were accu-rate and he was informed that apparently the facts were accurate.
The inspector noted that failure to provide formal training, on a semi-annual basis, to appropriate personnel represents noncompliance with the license (79-07-03).
7.
Monitoring 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 contamination on any part of his clothing or body must remove the clothing..."
On September 18, 1979 as the inspector prepared to enter the Pellet Shop of the Manufacturing area he observed an employee exiting the potentially contaminated side of the Change Room.
The inspector heard a noise which indicated that the employee had monitored his hands on the hand monitor.
The inspector observed the employee approach the " step over" line where an alpha instrument was available to monitor the remainder of the body.
The employee proceeded to remove his shoe covers, step over the line to the clean side of the Change Room and leave the area without any additior.al monitoring.
On September 20, 1979, the inspector was in the Ceramics Laboratory of Building 5, an unclad Fuel Handling Area, discussing the program being performed by licensee personnel.
The inspector was in the Clean Area of the Ceramics Laooratory and Laboratory personnel were standing in the potentially contaminated area of the Ceramics Laboratory.
As the discus-sions were being conducted, the inspector observed an individual, approach the Change Line from within the unclad Fuel Handling Areas.
The employee proceeded to remove his Lab Coat and shoecovers and stepped over the
" Change Line" into the Clean Area and left the Ceramics Laboratory with-out monitoring with the alpha monitor that had been provided.
The inspector noted that failure to comply with license requirements represents noncompliance (79-07-04).
7 8.
Breathing Zone Samples Section 8.2 of Special Nuclean Material License No. 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 e,:ceeds 2.5 Maximum Permissible Concentration Days (MPCD) must work under u 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.
As the inspector reviewed records of the breathing zone samples he noted that on July 6, 1979 the employees breathing zone sample was not collected and counted and calculated after each four hour period as required inas-much as the employees 7 day running total exceeded 2.5 Maximum Permissible Concentration Days.
A licensee representative was asked by the inspector if there was an explanation as to why the sample was not counted and calculated every four hours as required inasmuch as the employees seven day running total exceeded 2.5 MPCD.
The inspector was told that this was a case where the health physics technician forgot to collect the sample.
The inspector noted that failure to observe the license requirements represents noncompliance (79-09-05).
The inspector also reviewed breathing zone air sample data for an alleged incident that occurred in the Annex Area of the Manufacturing Area on June 20, 1979.
The data indicated that the results were higher than normal, but the inspector noted that regulatory limits were not exceeded.
9.
Termination Report 10 CFR 20.408(b) states, "When an individual terminates employment with a licensee describe :n 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 report of the individual's exposures to radiation and radioactive material, incurred during the period of employment or work assignment in the licensee's facility, containing information recorded by the licensee pursuant to 6620.401(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."
8 10 CFR 20.409(b) states, "When a licensee is required pursuant to SS20.405 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 $19.13(a) of this chapter."
As the inspector reviewed termination reports for approximately ten individuals for the period January-July 1979 he observed that one individual terminated his employment with the licensee on January 31, 1979 and he also noted that the required report was not submitted to the Commission or the individual within 90 days as required by regulations.
The report was submitted to the Commissico and the terminated employee on August 1, 1979, approximately 190 days aitar the individual terminated his employ-ment with the licensee.
The inspector noted that failure to comply with the regulations represents noncompliance (79-07-06).
10.
Labeling 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 contents.
(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-ficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or mini-mize exposures."
As the inspector toured the Laboratories of Building 5 he asked if radio-active material was located in areas other than the Building 5 Laboratories.
He was informed that depleted uranium was contained in fuel bundles in the Building 18 High Bay Annex.
As the inspector approached the cabinet in which the fuel was stored, in Building 18, the inspector observed that the cabinet was not posted. Upon closer examination the inspector found that the cabinat was posted, but the appropriate sign was completely covered so that it could not be seen.
Appendix C permitted up to 15 millicuries of uranium to be stored in the cabinet, but the cabinet contained approximately 140 millicuries.
As the inspector toured tic Building 5 Laboratories on September 20, 1979, he observed a safe, located in a hallway, and the safe was labeled
" Caution-Radioactive Material".
The label did not contain any other
9 information.
The inspector informed a licensee representative that if a container was required to be labeled, the label must also identify the radioactive contents.
The inspector also stated that the label did not contain any information to permit individuals who may be in the area to take precautions to avoid or minimize exposures.
The safe contained several sources that were exempted by Appendix C of Part 20, but it also contained millicurie quantities of Cesium-137 and Cobalt-60 as stated by a licensee representative.
The inspector noted that failure to comply with regulatory requirements represents noncompliance (79-07-08).
11.
Form NRC-5 10 CFR 20.401(a) requires each licensee to maintain the radiation exposure of all individuals on Form NRC-5, or on clear and legible records con-taining all the information required by Form NRC-5.
The inspector requested the licensee representative provide him with the licensee's Form NRC-5 exposure data, or the licensee's equivalent records.
The licensee has developed records that are regarded as being equivalent to the Form NRC-5.
The inspecte reviewed the licensee's equivalent records and noted that the records aid not contain all of the information required by Form NRC-5.
Specifically the licensee's records did not contain the following information:
a)
Employees social security number b)
Name of licensee c)
Method of monitoring The inspector noted that failure to comply with the regulatory require-ments represents noncompliance (79-07-09).
12.
Procedures 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."
On September 18, 1979, as the inspector toured the Annex area of the Pellet Shop, he observed approximately ten closed fifty-five gallon drums containing SNM bearing waste materials.
The drums were labeled as con-taining radioactive material, but the labels did not indicate the uranium content and neither was the enrichment indicated.
10 The inspector noted that failure to comply with a license requirement represents noncompliance (79-07-10).
13.
Dosimetry The inspector reviewed dosimetry records for the period January-June 1979 for approximately 150 individuals monitored at the Nuclear Fuel Manufac-turing Facility and the Laboratories.
The data indicated that all expo-sures were well within the 10 CFR 20.101 limits.
No items of noncompliance were identified.
14.
Annual Report 10 CFR 20.407(b) requires licensee's to submit personnel exposure and monitoring reports to the Director of Management and Program Analysis within the first quarter of each calendar year.
The inspector reviewed the licensee's report submitted to the Director on February 14, 1979, indicating exposure information for 140 individuals monitored during the previous calendar year.
According to the data, no employee received a dose in excess of the limits specified in 10 CFR 20.
No items of noncompliance were identified.
15.
Source Leak Test License Condition 15 requires "Each encapsulated plutonium source...shall be tested for leakage at intervals not to exceed six (6) months." The licensee has five plutonium sources that must be tested.
The inspector reviewed leak test data for the period January-August 1979.
The data indicated that all sources had been leak tested at the specified intervals.
No items of noncompliance were identified.
16.
Air Samoles The inspector reviewed general air sample data for the period January-July 1979 to determine if the licensee was in compliance with regulatory requirements.
No items of noncomplance were identified.
11 17.
Ventilation Section 15.7 of Special Nuclear Material License No. SNM-1067 requires face velocities at hood openings to be at least 100 feet per minute.
The licensee performs weekly ventilation surveys in the Pellet Shop, and monthly ventilation surveys in the Laboratories, to determine that the face velocities were as required.
The inspector reviewed ventil: Lion survey data for the period January-July 1979.
The data for the Pellet Shop indicated that the desired flow rate was maintained throughout the period.
The data from the Laboratories surveys indicated that the flow rate was less than 100 feet per minute, but the data also indicated that corrective action was taken and the required flow rate was restored.
No items of noncompliance were identified.
18.
Smears Section 15.6.1 of the licensee's application requires that smear surveys be taken and analyzed for alpha activity to verify compliance with inter-nal limits.
The inspector reviewed smear survey records for the period January-June 1979 to assure that the licensee was in compliance with this license requirement.
No items of noncompliance were identified.
19.
Instruments Section 15.8 of the licensee's applicetion requires that all instruments be calibrated twice per year and following repair.
The inspector selected seven instruments at random, and reviewed calibra-tion records to determine if the licensee was complying with the require-ment.
The calibration records indicated that the instruments had been calibrated on a quarterly frequency.
No items of noncompliance were identified.
20.
Exit Interview The inspector cet with the licensee representative (denoted in paragraph 1) at the conclusion of the inspection on September 21, 1979.
The inspector summarized the purpose and the scope of the inspection, and the findings as presented in this report.