ML19309B724

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IE Insp Rept 70-1100/79-12,on 791212-14.No Noncompliance Noted.Major Areas Inspected:Emergency Planning,Environ Monitoring & Confirmatory Measurements,Including Equipment Insp & Maint,Training,Fire Protection & Radwaste Mgt
ML19309B724
Person / Time
Site: 07001100
Issue date: 02/01/1980
From: Bores R, Donaldson D, Terc N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19309B718 List:
References
70-1100-79-12, NUDOCS 8004070112
Download: ML19309B724 (8)


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

70-1100/79-12 Docket No.

70-1100 License No.

SNM-1067 Priority 1

Category A(11 Licensee:

Combustion Enaineerina. Inc.

Nuclear Power Systems P.O. Box 500 Windsor. Connecticut 06096 Facility Name: Fuel Fabrication Inspection at:

Windsor, Con ecticut Inspection cond t<d:

Dece er 12-14, 1979 Inspectors:

e 88 N. M. Terc, Radiation Specialist date signed ha b ( bon d &

2h/so D. E. Donaldson, Radiation Specialist date signed Approved by:

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R. J. BWes, Chief, Environmental and date signed Special Projects Section, FF&MS Branch Inspection Summary:

December ~ 12-14, 1979 (Report 70-1100/79-12)

Areas Inspected: Emergency planning, environmental monitoring and confirmatory mea-surements, including: coordination with offsite agencies; facilities and equipment; inspection and maintenance of emergency equipment; training; emergency drills; emer-gency procedures; management control of emergency planning; fire protection; radio-active waste management including the collection of samples for subsequent comparative analyses and programs for control of quality in laboratory radioanalysis; and, followup of items identified in a previous NRC inspection of the same areas.

The inspection involved 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 inspectors.

Results: Of the areas inspected no apparent items of noncompliance were identified.

Region I Form 12 (Rev. April -77) 800.40702.12

DETAILS 1.

Persons Contacted

  • J. Pianki, Vice President Nuclear Fuel
  • G. Bakevich, Nuclear Licensing and Safety Supervisor J. Limbert, Radiological Engineer P. Rosenthal, Manager Health Physics
  • G. Johnstone, Radiation Specialist R. Spaulding, H. P. Technician J. Helems, Development Engineer (Radiochemistry Lab)

M. Cleary, Supervisor of Maintena,nce Services Other Personnel

Silliman, J., Chief, Poquonock Volunteer Fire Department The inspector also interviewed other licensee employees, including members of the production and health physics staffs.
  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings a.

(Closed) Non-compliance (77-07-02):

Failure to develop procedures for determining the magnitude of release of radioactive materials, includ-ing guidelines for evaluating the need for notification and participa-tion of state agencies.

The inspector reviewed the contents of licensee corrective action as stated in letter dated January 6, 1978 according to which a procedure was prepared for estimating the magnitude of an off-site release result-ing from a criticality accident.

The inspector had no fJrther questions in this area at this time.

b.

(Closed) Unresolved item (77-07-03):

Agreements with Department of Energy Radiological Assistance Program (DOE-RAP) and the State of Connecticut.

The inspector noted that the licensee had obtained writ-ten agreements with the State of Connecticut, Department of Public Safety's Office of Civil Preparedness on July 16, 1979, and with (DOE-RAP) by' letter dated December 9, 1977.

The inspector had no fur-ther questions in this area.

c.

(Closed) Unresolved item (78-10-01):

Verification that airborne par-ticulate vent sampling is isokinetic-representative.

The inspector reviewed the information and data provided by the licensee, and deter-mined that sampling is isokinetic-representative.

The inspector had no further questions in this area.

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3 d..

(0 pen) Unresolved item (78-10-02) Training Program:

The inspector reviewed training related documentation and interviewed selected persons assigned to the emergency organization to verify that required training had been conducted.

(See Paragraph 6 below) e.

(Closed) Unresolved item (78-10-03) Management Control of Emergency Planning activities The licensee incorporated a centralized management hierarchy to coor-dinate and control actions during emergency conditions, into his new Emergency Plan / Procedures.

The inspector had no further questions in i

this area.

3.

Emergency Plan and Implementing Procedures The inspector reviewed the licensee's revised procedures for Emergency a.

Planning and discussed several aspects of them with the licensee, including the need for more specificity regarding the training of emergency personnel in their individual emergency duties and in defin-

~ing each participant's lines of action during emergency situations.

In the light of the above considerations, the licensee stated that all emergency procedures would be reviewed and rewritten in an attempt to incorporate the requirements of license conditions, such as amendment No. 20 as well as pertinent NRC Regulatory Guides and the inspector's comments.

The licensee stated the above revisions will be completed within 90 days of receipt of this report.

The inspector stated that pending the completion of the new procedures and review by the NRC, this item is considered unresolved.

(79-12-01) b.

The licensee's Emergency Procedures for implementing the new Emergency Plan do not contain provisions for determining the magnitude of release, if any, which may result from events other than criticality; i.e., fires, explosions, tornadoes, etc.

The inspector noted that the licensee had not conducted an evaluation to substantitate his claim that there was no need for evaluating the magnitude of such a release.

As discussed during the exit interview, the licensee will conduct such a study, and will document the results.

The inspector stated that until this study is completed and is subsequently reviewed by the NRC, this area is considered unresolved (79-12-02).

4.

Coordination with Offsite Agencies The inspector reviewed records, procedures and written agreements relating i

to the licensee's coordination of emergency planning activities with agen-cies listed in the Emergency Plan and Implementing Procedures and verified l

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~that written agreements existed between the licensee and the following j

offsite agencies Poquonock Volunteer Fire Department Connecticut Office of Civil Preparedness Connecticut Department of Environmental Protection Department of Energy Radiological Assistance Program (DOE-RAP)

The inspector determined through discussions with the Chief of the Poquonock Volunteer Fire Department that licensee's contact and coordination were adequate for this agency to maintain an-effective response capability.

The inspector further determined that firemen participated in emergency drills conducted by Combustion Engineering.

The inspector had no further questions in this area.

5.

Facilities and Equipment The inspector examined equipment and instrumentation to verify that the items specified in the licensee's emergency plan and implementing proce-dures wera available for use and maintained in an operable state.

The inspection included the examination emergency equipment kits and criti-cality monitors.

No items of noncompliance were identified.

l 6.

Training The inspector reviewed training related documentation and interviewed per-sons to verify that required training had been conducted.

Training conducted since December 1978 included sessions for new employees, as well as, retraining of licensee's radiation workers.

Discussions, with radiation workers and review of records indicated that training received was of a brief and general nature and did not specify radiological controls for specific operations.

The licensee agreed to retrain personnel including detailed step-by-step instructions, when required, for the performance of the worker's duties.

The inspector also noted that the radiological training program for the aforementioned persons was not documented in the form of schedules and lessons plans.

Further review indicated that the licensee's current emergency procedures

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did not clearly address the scope and nature of the training to be provided to individuals assigned to specific duties and/or responsibilities in

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response to the spectrum of emergencies discussed in the emergency plan.

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Discussions, with selected individuals assigned to the licensee's emergency organization indicated that specific training for emergency functions was

. not conducted.

The inspector also noted that the training program for

-emergency functions was not documented in the form of schedules and lesson plans.

Discussions with licensee management personnel indicated that the emergency procedures would be revised to include the specifics of the training pro-gram, pertaining emergency response functions for all participants, includ-ing management, decontamination and handling of injured personnel, etc.

The inspector stated that the adequacy of the radiological and emergency

. training programs would be considered unresolved, pending the completion l

and implementation of the planned procedural revisions and the subsequent review by the NRC-(79-12-03).

7.

Emergency Drills The inspector reviewed records of three emergency drills conducted on all shifts.

These were as follows:

9/29/78 Radiation evacuation drill 5/21/79 Semi-annual radiation evacuation drill (Participation of Windsor Police Dept.)

10/31/79 Radiation Evacuation exercise The inspector determined that the licensee used personnel to evaluate the organization's response; critiques were held, during which discussions highlighi.ed improvement possibilities; and, actions had been initiated or completed to correct areas needing improvement.

No items of noncompliance were identified.

8.

Management Control-Emergency Planning The inspector reviewed the licensee's Emergency Plan and held discussions with responsible licensee personnel relative to the control of emergency planning activities.

The inspector noted that a program of management con-trols existed, directed by the Vice-President, Nuclear Fuel who will act as Emergency Director.

During the day shift, in his absence, he has delegated this responsibility to the General Manager-Fuel Fabrication for emergencies occurring in the fuel manufacturing facility and to the Manager, Health Physics for emergencies occurring in the Development Department Labs.

The inspector noted that the plan was unified in approach.

The inspector had no further questions in this area.

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6 9.

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 fire extin-guishers were located throughout the facility and emergency exits were marked and clear of obstructions.

Within the scope of this tour no problem areas were identified.

b.

Fire Fighting The inspector noted that specific site and licensed activity person-nel 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 fight-ing.

Discussions with the licensee and representatives 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.

10.

Radioactive Waste Management - Confirmatory Measurements The licensee's radioactive waste management was reviewed in the following areas.

a.

Liquid Releases Liquid waste which originates from various sources throughout the facility is collected in retention tanks, analyzed, diluted as neces-sary and discharged to the Farmington River.

The inspector reviewed the licensee's liquid effluent data for 1979 and noted that no liquid effluent release limits were exceeded.

b.

Airborne Particulate Releases The inspector reviewed exhaust ventilation sample results for 1979, in particular whenever the criterion of compliance with Amendment 18 (2/13/79) to the license was involved.

This requires that corrective action be taken whenever the total gaseous release rate exceeds 2 pCi/

week.

For present exhaust flow rates, this action level has been set by the licensee at 1 x 10-12 pCi/ml.

The inspector reviewed all exhaust air records for the year 1979 and noted that throughout the year, on each occasion, when action levels required, the licensee had taken appropriate remedial action (i.e., changed absolute filters).

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The inspector also physically examined the sampling equipment.

He found that filter media were properly placed, and that air pumps were operational.

In addition, the differential pressure across absolute filters was found to be less than 4 inches of water, as required.

The inspector had no further questions in this area, c.

Split Samples Four effluent airborne particulate filter media and two water samples of 500 m1 each were taken by the licensee and split between the licens-ee and the NRC to verify his analytical procedures.

The results of these analyses were not available at the time this report was writtan and will be included in a subsequent report.

d.

Laboratory Quality Control (QC) Program The inspector noted that licensee's internal laboratory QC program consisted of daily backgrounds and daily standard-source checks.

The licensee stated that the source was traceable to NBS standards, but was not able to produce certification papers when requested.

The inspector noted the licensee has no specific regulatory. requirements in this area and therefore had no'further questions at this time.

11.

Environmental Monitoring The inspector reviewed the licensee's radiological environmental program in the following areas.

a.

Program Management The environmental program is administered by the Radiation Safety Officer in Building 5.

The environmental samples were analyzed by the licensee.

The inspector noted that licensee had written analy-tical procedures, but had not yet developed procedures covering the specifics of sample collection.

The inspector discussed the advantages of standard procedures for sampling but noted there were no specific regulatory requirements on this area.

b.

Implementation of Monitoring Program The inspector reviewed the licensee's environmental analyses for the first three quarters of-1979, and noted that the licensee had met all environmental sampling and analytical requirements.

c.

Quality Control QC The inspector noted that the licensee's internal laboratory QC program consisted of daily backgrounds and sources checks using NBS traceable

8 standards (Am-241 source, NBS-4904-E and Sr-90, NE-S-267 (CE-63)).

The licensee was asked to produce Certificates of Calibration which were reviewed by the inspector and found to be satisfactory.

The licensee also conducted computational checks of the raw data, checking calculations on a semi-annual basis.

The licensee was asked if he performed alpha absorption corrections

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on the analytical results.

He stated that they had performed a study showing the effects of alpha absorption were negligible, and thus did not correct for it.

The inspector requested a copy of this study but was unable to obtain it at the time of inspection.

The inspector stated that this would be reexamined during a~ subsequent inspection.

'(79-12-04) 13.

Unresolved Items Unresolved items are matters about which more information is required to ascertain whether they are acceptable items, items of noncompliance or deviations.

Unresolved items are disclosed during this inspections in Paragraph 3a, 3b and 6.

14.

Exit Interview The inspector met with the licensee representative denoted in Paragraph 1, at the conclusion of the inspection on December 14, 1979.

During the exit interview the inspector summarized the scope and purpose of the inspection and discussed the inspection findings.

Licensee management acknowledged the need to review the Emergency Plan Implementing Procedures and provided a commitment date of 90 days from receipt of this report for completion of a second generation of procedures.

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