ML19309E324
| ML19309E324 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 12/05/1979 |
| From: | Lichtenberger H ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19309E310 | List: |
| References | |
| NUDOCS 8004210138 | |
| Download: ML19309E324 (3) | |
Text
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y C-E Power Systems Tel 203/688-1911
- Cornbustion Engineering, Inc.
Telsx: 99297 1000 Prospect Hill Road O
Windsor, Connecticut 06095 H SYSTEMS POWER License SNM-1067 December 5, 1979 Docket 70-1100 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention: Mr. George H. Smith, Chief Fuel Facility & Material Safety Branch
Reference:
Letter from Mr. G. H. Smith to Mr. H. V. Lichtenberger, dated November 13, 1979; Inspection 70-1100/79-09 o
Gentlemen:
This is in response to the above referenced letter in which you reported four infractions that were determined during your inspector's visit to our facility on October 9-12, 1979.
Appendix A, Item A
- 1) A formal procedure for the filter knockdown operation was not available at the time of the inspection.
Response
A formal procedure for this operation, including established safety limits and controls necessary to assure adequate protection of operators, has been written and is in effect at this time. We are in full compliance at this time.
2)
Personnel exiting the unclad fuel handling area of Building #17 did not survey their bodies, clothes and shoes for radioactive contamination.
Response
Those employees who wear laboratory coats and shoe covers and who enter unclad fuel handling areas are observing only and as such have only a remote possibility of becoming contaminated with UO. All production processes are 2
carried out in closed ventilated systems and hoods. All equipment is routinely l cleaned to levels which are as low as possible. Floors are cleaned once per shift and sometimes more frequently, but as an added precaution, all visitors and observers are required to wear a laboratory coat as well as shoe covers l
to provide a further margin of safety in contamination control. All persons l
leaving the unclad fuel handling area are required to monitor their hands.
l If contamination is suspected on any other part of the body or clothing, a portable alpha monitor is available to check for contamination. We consider l
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q Appendix A, Item A-Response (Cont'd)
'these precautions sufficient to provide an adequate contamination control pro-gram.
It appears that the intended monitoring requirements were not made clear in our original license application.
It was our intention that all regular pro-duction workers be required to wear a complete suit of protective clothing and t
be required to monitor their hands (as a minimum) when exiting contaminated i
areas. It was also our intention that all visitors and observers be required i
to wear a laboratory coat and shoe covers and also be required to monitor their i
hands (as a minimum) and to additionally check any other part of the body or personal clothing with the available alpha monitor if contamination is found i
on the hands or contamination is suspected on any other part of the body. It l
is our intent to amend License SNM-1067 at the time of our renewal next year to i
clear up the poor semantics in Section 15.10.
We believe we are in full com-pliance with the intent of License SNM-1067 and regret that the wording was not more carefully reviewed at the time our original application was submitted.
3)
Fixed alpha radioactive contamination surveys were not conducted in clean areas.
Response
j Fixed contamination surveys of clean areas are now performed on a monthly basis j
to provide continuing assurance that these areas are below license limits for
. fixed contamination. The frequency of these surveys may be changed on the basis of information gathered from the monthly surveys.
Survey results performed to l
l date indicate very low levels of fixed contamination in all clean areas. We are in full compliance with License SNM-1067 at this time.
i
- 4) Written operating procedures were not provided for the use of a vacuum cleaning j
system located in the Building #5 ceramics laboratory.
N N,
Response
The inspector was informed that this vacuum cleaner was never used to vacuum I
radioactive materials. It has been removed from the restricted area and is no
]
longer used.
F Appendix A, Item B l
- 1) Management did not assure that the use of open not-safe-by-geometry containers in the unclad fuel handling areas of Building #17 had been analyzed to establish l
required safety units and controls, and had been reviewed and approved by the
[
Nuclear Licensing and Safety Supervisor.
Response
i The containers referred to are Specification 17-H drums used for packaging low level radioactive waste. An analysis had previously been performed by the Nuclear Safety Consnittee which concluded that because of the small quantities of special I
nuclear material and lack of moderation,-these containers were safe in an in-finite array. This analysis could not be located at the time of the inspection.
A similar analysis has been performed and documented by the Manager, Nuclear Licensing, Safety & Accountability which includes the same basis conclusions.
l This analysis is available for review by your inspectors. To provide an additional I margin of nuclear criticality safety, all waste drums will be covered except at the time waste is being put into the drums.
i '
9.
o hppenihixA,ItemB-Response (Cont'd)
- 2) Approval for the storage of closed contaminated nste drums (containing up to 150 grams U23s) anywhere in the unclad fuel handling areas of Building #17 was not recorded in a log maintained under the direct supervision of the Nuclear Licensing & Safety Supervisor.
Response
Approval for the above storage was granted by the Nuclear Licensing & Safety Supervisor some time ago. This approval is now recorded in a log maintained under his direct supervision.
Appendix A, Item C A rod box, stored on one of the in-process rod storage racks in work station #M-129, was not fully covered as required and was not attended by personnel.
Response
This infraction was corrected at the time of the inspection. Personnel have been reminded of the requirement to keep all rod boxes covered when not attended by personnel. We are in full compliance at this time.
Appendix A, Item D 2
The maximum removable alpha contamination level of 100 dpm/100 cm was exceeded on the clean side of the men's change room; a clean area. A removable contamination level of 244 dpm/100 cm2 was observed.
Response
2 This area was decontaminated to a level below 100 dpm/100 cm. This area is rou-tinely cleaned at least once per day. Personnel have been reminded to remove shoe covers on the contaminated side of the change iine as required. We are in full com-pliance at this time.
Very truly yours, MA*
H. V. Lichtenberger Vice President-Nuclear Fuel Nuclear Power Systems-Manufacturing HVL/GJB/ssb