ML19269C465
| ML19269C465 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 12/01/1978 |
| From: | Donaldson D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19269C459 | List: |
| References | |
| 70-1100-78-10, NUDOCS 7902030007 | |
| Download: ML19269C465 (11) | |
Text
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O.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
78-10 Docket No.
70-1100 License No.
SNM-1067 Priority 1
Category A(1)
Licensee:
Combustion Encineerino. Incorocrated Nuclear Power Systems P. O. Box 500 Windsor. Connecticut 06096 Facility iiame:
Fuel Fabrication Inspection at:
Windsor, Connecticut Inspection conducted:
Nov mber 1-3, 1978 Inspectors:
8 L [. A f im -
/ p /-77 Donaldson, Radi tion Specialist cate signed D
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f 3 ~/ - f f J. P. Stohr, Chief, E&SP Section date signed
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date signed
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Approved b' AW#
- 2 J. P. Stohr, Chief, Invi:onmental and cate signed
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Spe a1 Projects Secti)n, FF&MS Branch Inspection Su:rgpg:
Inspection on Novew.ber 1-3,1978 (Report No. 70-1]00/78-10)
Areas Inspected:
Emergency planning, environment:1 monitoring and confirmatory including: coordination with offsite agencies; facilities and measurements;libration, inspection and maintenance of emergency equipment; training; equipment; ca emergency drills; emergency procedures; management control of emergency planning; fire protection; radioactive waste management including the collection of samples for subsequent comparative analyses and programs for control of quality in labora-tory radioanalysis; and, followup of items identified in a previous NRC inspection of the same areas.
The inspection iivolved 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> on site by two regionally based NRC inspectort.
Results:
Of the ten areas inspecteo, one apparent item of noncompliance was identi-fied in one area (Infraction - failure to verify that ventilation sampling is re-presentative).
Region I Form 12 (Rev. April 77) 7902030007 (
DETAILS 1.
Persons Contacted Principal Licensee Employees H. Lichtenberger, Vice President - Manufacturing
- G. Ba kevich, Nuclear Licensing and Safety Supervisor J. Limbert, Radiological Safety Engineer P. Rosenthal, Supervisor, QC and Health Physics M. Cleary, Supervisor of Maintenance Services H. Brosman, Manager, Group Records and Security E. Murphy, M. D., Corporate Medical Director Other Personnel J. Silliman, Chief, Poquonock Fire Company A. Heubner, Connecticut Department of Environmental Protection A. Hekking, Connecticut Office of Civil Preparedness The inspector also talked with and interviewed 5 other licensee employees including members of the production, health physics, radiochemistry and medical staffs.
denotes those present at the exit interview 2.
Licensee Action on Previous Insoection Findings a.
(Closed) Noncompliance (77-07-01):
Formation of a Review Committee and Committee review of initial training ac.d retraining of persons having responsibility in connection with the Site Emergency Plan.
The inspector held discussions with licensee individuals and reviewed available records and verified that a Review Committee had been established as specified ir paragraph 1.4.3 of the Site Emergency Plan.
The inspector noted that the Committee had conducted a review of training records relative to the emergency plan.
The inspector determined that the licensee's implemented corrective actions were in conformance with those detailed in two letters from the licensee to the NRC, dated October 28, 1977 and January 6, 1978.
b.
(0 pen) Noncompliance (77-07-02):
Failure to develop procedures for determining the magnitude of release of radioactive materials, including guidelines for evaluating the need for notification and participation of state agencies.
The inspector held discussions with responsible licensee individuals and persons of the Connecticut Department of Environmental Protection and Office of Civil Preparedness, and reviewed procedures developed for determining the magnitude of release of radioactive materials.
3 The inspector noted that while the licensee's corrective actions were implemented as outlined in a letter to the NRC dated January 6,1978, adequacy of the instituted corrective actions could not be verified.
In particular, the licensee had only developed a release evaluation methodology relative to a criticality.
In reviewing this methodology, the inspector noted that the licensee had selected a 0.3 radiciodine to noble gas ratio to be applied to releases which may result from a criticality without reveiwing or substantiating the applicability of this ratio to a criticality event.
The inspectors further noted that the licensee's implemented corrective actions did not contain provisions for determining the magnitude of release of radioactive materials, if any, which may result from events other than a criticality, i.e., fires, explosions, etc. Finally the procedure did not relate the results of the release determinations to action levels adopted by the State af Connecticut.
The licensee stated that refinements to the procedures, including an evaluation and expansion of the scope of the technical approach selected, would be reflected in an upcoming revision to the emergency plan and implementing procedures.
c.
(0 pen) Unresolved Item (77-07-03):
Agreements with Department of Energy Radiological Assistance Program (DOE-PAP) and the State of Connecticut.
The inspector noted that the licensee had obtained a written agreement with DOE-RAP.
The licensee had not, however, reached agreement with appropriate State agencies who would have responsibility for directing and implementing actions in the facility environs should a radiation emergency affect offsite areas.
The inspector stated that this item would remain open pending further action by the licensee.
d.
(Closed) Unresolved Item (77-07-04):
Assessment of alpha self-absorption correction.
The inspector he discussions with responsible licensee individuals and reviewed documented results of a study performed by the licensee to evaluate the effect of alpha self-absorption on counting data.
The inspector noted that alpha self-absorptionwasshowntobenegligibleforplanchetdepositsof<1 ug/cm. Analysis of typical liquid e# fluent demonstrated that, after <!vaporapion of a liquid sample, the residue was consistently below 1 ug/cm. The licensee has, however, modified the sample counting procedure to apply appropriate correction ctors to samples showing post-evaporation deposits > 1 ug/cm e.
(Closed) Unresolved Item (77-07-05):
Verification that airborne particulate vent sampling is isokinetic / representative.
The inspector held discussions with responsible individuals and determined that, since the previous inspection of this area, in September,1977, the licensee had installed a number of sampling probes (designed in accordance with ANSI N13.1-1969).
All vents in building 17 (4 release paths) were equipped with the new probes and 3 of 7 release paths in building 5 were so equipped.
The inspector requested information concerning any analyses conducted on the old and new sampling probes that would demonstrate that sampling of the vented airborne particulate effluent was isokinetic / representative.
The
4 licensee was unable to produce any evidence concerning this matter.
The inspector stated that the unresolved items wcald be closed via conversion to noncompliance due to the licensees failure to comply with the requirements of Paragraph 14.7 of the license application regarding verification that ventilation sampling techniques result in the collection of representative samples. (78-10-01) 3.
Emergency Plan and Implementing Procedures The inspector noted that the licensee was in the process of preparing a major revision to the emergency plan and implementing procedures.
Licensee management stated that the revision was a re! ult of a letter from the NRC, dated January 30, 1978, and that the purpose of the revision was to incor:3 crate the results of past NRC inspections, drills, reviews by licensee :3ersonnel and current guidance in the area. The inspector reviewed the draft revised plan and procedures, at the licensee's request, and discussed various aspects of the documents with licensee management.
Licensee management stated that the inspector's comments would be incorporated into the draft revision of the plan and precedures, as appropriate.
The inspector stated that the revised plan and implementing procedures would be reviewed during a subsequent inspection to verify that ap-plicable regulatory requirements are adequately covered in the plan and implemented by the procedures.
4.
Coordination with Offsite Acencies The inspector reviewed records, procedures and written agreements relating to the licensee's coordination of emergency planning activities with agencies listed in the Emergency Plan and Implementing Procedures.
The inspector discussed this subject with licensee representatives and persons of the following offsite agencies:
Poquonock Volunteer Fire Department Connecticut Office of Civil Preparedness Connecticut Department of Environmental Protection Discussion with the Chief of the Poquonock Volunteer Fire Company verified that the existing agreement with the licensee remains in effect, and that the licensee's contact and coordination were ade-quate for this agency to maintain an effective response capability.
Discussions with officials of the Connecticut Office of Civil Pre-paredness and the Connecticut Department of Environmental Protection indicated that coordination activities have not been as complete as desired. The licensee had been provided with copy of the State Radiation Emergency Response Plan _(RERP).with acconpanying guidance to prepare a draft local plan for the Windsor Locks Site modeled after other local plans already incorporated into the Connecticut RERP.
5 Discussion with resonsible licensee personnel indicated that no action had been taken to prepare this plan. The inspector informed the licensee of the need to establish a more comprehensive approach to coordination with Connecticut planning officials, particularly guidelines for notification and participation of the State.
Licensee management stated that this area would be addressed in the next revision to the emergency plan and procedures.
(See related discussion in paragraph 2.b and 2.c.)
5.
Facilities and Eauipmentt The inspector examined facilities, equipment and instrumentation to verify that the items specified in the licensee's Emergency Plan and Implementing Procedures were available for use and maintained in an operable state.
The inspection included examination of:
em-ergency equipment kits; criticality monitors and onsite medical treatment facilities.
No items of noncompliance were identified.
6.
Calibration, Inspection and Maintenance of Emergency Eauipment The inspector reviewed and evaluated the licensee's provisions for calibrating, maintaining and inspecting emergency response equipment.
The inspector selected a sample of emergency equipment and inventory records covering the period October 1977 through October 1978.
The inspector noted that the licensee's emergency equipment had been maintained.
No items of noncompliance were identified.
7.
Training The inspector reviewed training related documentation and interviewed selected persons assigned to the emergency Organization to verify that required training had been conducted.
Training conducted since September,1977 included sessions for new employees, as well as, retraining for the licensee's radiation workers.
Discussions with selected individuals assigned to the licensee's emergency organization indicated that their training was informal in nature and not performed with regularity.
Further review indicated that the licensee's current emergency plan did not clearly add ass the scope and nature of the training to be provided to indivi6als (licensee and non-licensee) who are assigned or have agreed to provide specific duties, services and/or responsibilities in response to the spectrum of emergencies discussed in the emergency plan.
The inspector also noted that the training program for the aforementioned persons was not documented ir. the form of schedules and lesson plans.
Discussions with licensee management personnel indicated that the emergency plan training program would be more clearly defined in the next revision of the emergency plan and implementing
6 procedures.
The inspector stated that the documented program would be reviewed during a subsequent inspection in order to verify its adequacy.
(78-10-2) 8.
Emergency Drills The inspector reviewed records of four emergency drills conducted since the previous emergency planning inspection in September, 1977. Evacuation drills were held in October,1977, November,1977, May,1978, and September,1978.
The inspector determined that the licensee used personnel to evaluate the organization's response; critiques were held, during which dis-cussion highlighted improvement possibilities; and, actions had been initiated or completed to correct any areas needing improvement.
No items of noncompliance were identified.
9.
Management Control - Emeraency Planning The inspector reviewed the licensee's emergency plan and held discussions with responsible licensee personnel relative to the management control of emergency planning activities.
The inspector noted that, while a program of management control existed, it was not unified in approach.
Within the NRC licensed activities covered by Facility License SNM-1067, two Area Coordinators have been appointed.
Each Area Coordinator is responsible for developing an " emergency plan of action" designed to cover his assigned building area.
These area plans of action are, in turn, submitted to a Director of Emergency Services for incorporation in and coordination with an overall Site Emergency Plan designed to cope with emergencies anywhere in the Windsor Locks site.
Detailed discussions with the Area Coordinators indicated that each coordinator exerts essentially of individual autonomy in the planning, organizing, directing, coordinating and controlling of response and response planning activities concerning the NRC licensed portion of the Windsor Locks site.
For example, each Area Coordinator is responsible for the conduct of training, drills, review and update of plans and procedures.
There is no centralized focal point of managment control within the licensed activity itself.
Licensee management stated that this situation would be reviewed from the standpoint of ensuring that plans and procedures developed for the NRC licensed activity are coordinated and controlled by a centralized individual assigned to the licensed activity prior to being forwarded to the Director of Emergency Services.
Licensee representatives also stated that a similar review would be performed to ensure that the planning and performance of preparedness functions,
7 1.e., drills, training and equipment maintenance / checks are also coordinated with centralized management control at the licensed activity management level.
The inspector stated that this would be reviewed during a subse-quent inspection (78-10-03).
10.
Fire Protection a.
Facility Tour The inspector, in the company of a licensee representative, conducted a tour of the facility.
Items such as housekeeping, maintenance and fire protection were observed.
The inspector noted that the fire extinguishers were located throughout the facility and emergency exits were marked and clear of obstruc-tions. Within the scope of this tour no problem areas were identified.
b.
Fire Inspections The inspector noted that fire inspections of the facility were perfonned under the Nuclear Energy Liability Property Insurance Association (NELPIA).
The inspector discussed the results of fire inspection conducted on September 7,1978 and reviewet the report of an inspection conducted February 3 and 16, 1978.
The inspector noted the insurance inspection indicated adeccate fire protection.
c.
Fire Fighting The inspector noted that specific site and licensed activity personnel are trained in fire fighting and would form a fire brigade which is responsible for fire fighting anywhere on the Windsor sites.
The local fire department may be called upon if necessary for fire fighting.
Discussions with the licensee and a representative of the Poquonock Volunteer Fire Department indicated that the local fire department personnel had been on the site for familiarization training.
No items of noncompliance were identified.
11.
Radioactive Waste Management - Confirmatory Measurements The licensee's radioactive waste management was reviewed in the following areas.
a.
Liqui 6 <eleases Liquid waste which originates from various sources throughout the facility is collected in retention tanks, analyzed, diluted as necessary and discharged to the Farmington River.
The
8 inspector reviewed the licensee's liquid effluent data for 1978 to date and not d that no liquid effluent release limits were exceeded.
b.
Airborne Particulate Releases Airborne particulate releases consist of particulates vented through four release paths from Building 17 after passing through high efficiency particulate (HEPA) filters, and seven release paths from Building 5 with six of these release paths having(high efficiency particulate (HEPA) filters and two paths environmental laboratory and hydrogen furnace) having no filters.
All the release paths from Buildings 5 and 17 are sampled during discharges to the atmosphere.
The inspector reviewed vent sample results and, based upon the licensee's results, determined that no airborne release limits were exceeded.
c.
Split Samples Split airborne particulate ef:luent sample's and liquid ef-fluent samples were taken by tr.2 licensee and the inspector for the comparison of analysis results.
Gross alpha analysis will be performed by the licensee using his normal routine methods of analysis and by NRC:I.
Joint analysis of actual effluent samples and subsequent comparison of the results determines the licensee's capability to measure radioactivity in effluent samples.
The results of these analysis will be reported in a subsequent inspection report.
d.
Counting Equipment The inspector noted that gas flow proportional counters are used for counting evaporated liquid and airborne particulate effluent samples.
The inspector noted that alpha self-absorption correction factors were used, as appropriate, in calculating the acitivty of liquid effluent samples.
e.
Laboratory Quality Control (OC) Program The inspector noted that the licensee's internal laboratory QC program consisted of daily backgrounds an standard checks with plateaus being determined periodically.
The inspector discussed various other aspects of an internal laboratory QC program with the licensee.
The inspector noted the licensee has no specific regulatory requirements in this area and therefore had no further questions at this time.
9 f.
Confirmatory Measurements A comparison of the licensee's measurements with those of the NRC for effluent samples split during a previous inspection on September 12-14,1977 (Inspection Report No. 70-1100/77-07) indicated that four measurements were in agreement or possible agreement under the test criteria used by the Office of Inspection and Enforcement (Attachment 1) and one measurement (gross beta of a liquid effluent) was in disagreement.
The licensee's gross beta measurement was higher than that of the NRC and hence was conservative.
This would not have resulted in the licensee exceeding any liquid release limits. The results of the L.easurements comparisons are listed in table 1.
In order te resolve the disagreement, the inspeci.or and licensee split another sample for the comparisen of analysis results.
Results of the analysis will be reported in a subsequent report.
No items of noncompliance wen identified.
12.
Environmental Monitoring The inspector rev.ewed the licensee's environmental monitoring pro-gram in the following areas.
a.
Program Management The inspector reviewed the licensee's radiological environ-mental monitoring pi ogram as described in license SNM-1067.
The environmental program is administered by the Radiation Safety Officer in Building 5.
The environmental samples are analyzed by the licensee.
The inspector noted the licensee has written procedures for environmental sample analyses.
b.
Implementation of Monitoring Program The inspector reviewed all the licensee's environmental an-alyses results for 1977 and January - September,1978, and noted the licensee was meeting all of the environmental sampling and analysis requirements.
c.
Quality Control The inspector noted the licensee had a limited environmental laboratory QC program consistina of daily background and standard checks with periodic plateau determinations.
The inspector noted the licensee has no specific regulatory require-ments in this area.
The inspector had no further questions in this area.
10 14.
Exit Interview The inspector :aet with the licensee representi.tive denoted in Para-graph 1, at 'ne ennclusion of the inspection on November 3,1978.
In addition, i inspector contacted Mr. H. I.ichtenberger, Vice President Manufacturing, by telephone on November 8,1978.
During boi.h the November 3 meeting and November 8 celephone conversation, the inspector summarized the purpose and t'ie scope of the inspection and the inspection findings.
Licensee management acknowledged the item of noncompliance and stated that additional changes to the draft revised emergency plan and implementing procedures would be pursued as had been discussed.
TABLE 1 CE - VERIFICATION TEST RESULTS SAMPLE IS0 TOPE NRC VALUE LICENSEE VALUE COMPARISON Stack Nos.
RESULTS IN mci /ml September 12 1977 F-1 gross alpha 2.66 1 0.03 E-12 3.51 1 ? E-12 Possible Agreement F-2A gross alpha 8.84 1 0.24 E-13 9.53 i ? E-13 Agreement F-2 gross alpha 2.57 1 0.06 E-12 2.49 i ? E-12 Agreement Waste Tank No.
Senteriiuer 13, 1977 A-1 gross alpha 1.4 1 0.3 E-7 2.40 1 0.2 E-7 Agreement gross beta
- 1. 710.1 E-7 8.40 1 0.4 E-7 Disagreement
s e
With regard to corrective actions taken to resolve an item of noncompliance reported previously in your letter of October 4,1977; the information which you have requested is hereby submitted:
a) The applicability of using a 0.3 radiciodine to noble gas ratio was a conservatism on our part in estimating the release of radioactive materials in the event of a criticality accident.
The actual ratio which was calculated was 0.024.
The PAG guidelines provide a correc-
~
tion factor to be applied to dose estimates where the radiciodine to noble gas ratio is less than 0.3.
The correction factor (0.16) will be incorporated in a revised procedure for determining the magnitude of release of radioactive materials following a criticality accident.
The off-site dose estimates will then be close to an order of magni-tude less than if calculated using the present procedure.
This pro-cedure will be revised within 90 days of the date of this letter.
K b) Our Environmental Impact Information which was submitted in October 1974 includes evaluation of all accidents which may have off-site impact.
The only accident which could result in release of radioac:ive material off-site (the nearest site boundary is 130 meters from the plant) is a nuclear criticality accident.
A fire or explosion, though extremely remote, would release UO2 particulates outside the plant and would require a large decontamination effort.
However, an off-site release of significant amounts of radioactivity from this type of accident, affecting the public health and safety, is not considered credible.
c) The need for notification of state and local response agencies and the nature and scope of assistance to be provided is presently being re-viewed.
Specific agreements with these agencies will be detailed in the revised submittal
.f our Emergency Plan.
This submittal is now scheduled for February 15, 1979.
The agreements reached with these agencies will then be a basis for including specific limits in our
" magnitude of release" procPdJre.
This information will be added to our procedure within 60 days of our Emergency Plan submittal.
Very truly yours, H. V. Lichtenberger Vice President-Nuclear Fuel Nuc! ear Power Systems-Manufacturing HVL/GJB/ssb
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