ML19309E333
| ML19309E333 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 11/09/1979 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19309E310 | List: |
| References | |
| 70-1100-79-09, 70-1100-79-9, NUDOCS 8004210145 | |
| Download: ML19309E333 (16) | |
Text
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k U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-1100/79-09 Docket No. 70-1100 License No. SNM-1067 Priority 1
Category UR Licensee:
Combustion Engineering, Incorporated P. O. Box 500 Windsor, Connecticut 06095 Facility Name:
Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection at:
Windsor, Connecticut Inspection conducted: October 9-12, 1979 t
Inspectors:
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JGoth,ProjectInspector datt! sign'ed date signed date signed Approved by:
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E Crocker7 Chief, Fuel Facility Projects
/ da'te 's1@ned Section, FF&MS Branch Inspection Summary:
Inspection on October 9-12,1979 (Report No. 70-1100/79-09)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the licensee's programs including: organization; facility changes and modifi-
- ations; internal review and audit; safety committees; training; maintenance; r? view of operations; nuclear criticality safety; initial use of packages; routine use of packages; licensee action on previously identified enforcement items; and, followup on regional office Bulletins.
The inspection was initiated on the 4:00 p.m. to midnight shift on October 9,1979, and involved 25 inspector-hours onsite by one'NRC' inspector.
Resuits: Of the 12 areas inspected, no items of noncompliance were identified in 10 areas.
Five items of noncompliance were identified in two areas (Deficiency -
four instances of failure to post, inadequate posting or improper posting of work station (79-09-01), Paragraph 3.a; Infraction - failure to keep a stored rod box covered when not attended (79-09-02), Paragraph 3.b; Infraction - four instances of inadequate procedures or failure. to supply procedures (79-09-03),
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s o o 4 210 M
2 Paragraphs 3.c, 4.a(3)(a), 4.b(2); Infraction - failure to evaluate the use of unsafe geometry containers in the process area and maintain a record of approval for the storage of closed waste drum anywhere in the process area (79-09-04),
Paragraphs 3.d, 5.b(4)(bl; Infraction - failure to maintain clean areas at or below the 100 dpm/100 cm2 smearable limit (79-09-05), Paragraph 4.a(b)(3)).
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DETAILS 1.
Persons Contacted Nuclear Manufacturing
- H. V. Lichtenberger, Vice President, Nuclear Power Systems - Manufacturing
- G. Bakevich, Supervisor, Nuclear Licensing and Safety T. B. Bowie, Manager, Nuclear Materials and Security Nuclear Laboratories P. R. Rosenthal, Manager, Health Physics J. Limbert, Radiological Engineer The inspector also interviewed 12 other licensee employees during the course of the inspection.
They included operations foremen and operators, health physics technicians, laboratory technicians, electronic technicians, and general office personnel.
- denotes those present at the exit interview.
2.
Licensee Actions on Previously Identified Enforcement Items (Closed) Infraction (1100/79-04-01): Two instances of failure to wear gloves when handling unclad uranium fuel.
The inspector verified that the licensee had conducted documented training sessions for each operating shift on July 10, 1979.
Included in this documentation training session was the topic "UO2 Handling Procedures," in which the license requirements for wearing gloves when handling unclad U02 was emphasized.
The inspector also observed that operators were wearing gloves as required in the fuel handling areas.
Corrective actions have been completed on this item of noncompliance.
(Closed) Infraction (1100/79-04-02): Three instances of failure to establish adequate radiological controls and/or instructions for operators.
During inspection 70-1100/79-07, the inspector noted that alpha survey instruments had been installed near the change line for the emission spectrograph unit in Building 5 and at the exit to the restricted area in Building 6.
During this inspection (70-1100/79-09) the inspector examined the procedure OS 1580, Revision 5, released September ll,1979, and determined that written instructions had been incorporated which specifies the "predry air flow" to be used by operators.
Corrective actions have been completed on this item of noncompliance.
4 (Closed) Infraction (1100/79-04-03):
Failure of the Nuclear Licensing and Safety Supervisor to review and approve 23 of 25 examined safety related procedures.
The inspector examined a random sampling of 5 procedures and determined that they had been reviewed and approved by the Nuclear Licensing and Safety Supervisor.
The licensee has also established a procedure which requires, in the future, that the Nuclear Licensing and Safety Supervisor would review and approve all new procedures on the master copy and that all procedure revisions would be signed-off on the Engineering Notice required for transmittal to operating groups.
Corrective actions have been completed on this item of noncompliance.
3.
Off-Shift Review of Operations The inspector initiated this inspection with an unannounced off-shift examination of the Manufacturing Plant at about 5:30 p.m. on October 9, 1979.
During this examination, the inspector observed operations and activities in progress; inspected the nuclear safety aspects of the plant; and, reviewed the safety aspects of operations sheets with operators.
a.
Work Station Postings During examination of the cold shop operations, the inspector noted that a transfer cart, constructed with rollers to facilitate the loading of a rod box and located in the Rod Box Storage Area near the Fluoroscope Area, was not posted with a criticality safety sign which indicated the criticality control limits for the transfer cart.
Failure to post this transfer cart with the appropriate criticality safety sign was identified as an instance of noncompliance.
This sign and several other torn but legible signs were replaced prior to the end of this inspection.
The inspector noted that the sintercbility test hood (WS-P-23) had not been reposted with the nuclear criticality limits and controls for the UO2 liner washing operation being conducted in the hood at the time of this inspection.
Each of four zones in the hood were posted for 37 kilograms of UO2 and no instructions were issued or posted to indicate the criticality control limits which were applicable to this operation.
This was identified as another instance of noncompliance.
The inspector noted that closed contaminated waste containing drums were being stored in the pellet shop and in the pellet shop annex.
The licensee had posted one nuclear safety sign in the pellet shop annex which states, " Waste drums may be stored anywhere in the pellet shop provided they are outside of all taped boundaries and separated from any other fissile material by one (1) foot." The inspector commented that the license required that signs, including criticality limits, are posted near the appropriate work station and that the posting of one sign in the process area was not an acceptable solution.
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Failure to post the other two rooms of the process area was identified as another instance of noncompliance with this requirement.
The inspector noted that the licensee had placed two signs in each of the three rooms in the process area to correct this item prior to the end of this inspection.
The inspector also noted that the permanent storage area for the nondestructive assay unit calibration drums was no longer posted with the required signs.
This sign was also replaced prior to the i
end of this inspection (79-09-01).
i b.
Rod Box Storage The inspector noted that a rod box stored in the top location of a storage rack located at the southwest corner of work station 129 was not fully covered as required when personnel were not in attendance.
There was approximately a one inch gap between the edge of the box wall and the outer edge of the box cover which could allow the box to fill with water in the event that the facility fire sprinkler system were activated.
Page C-108, dated January 20, 1978, states that each box is equipped with a tight fitting aluminum cover which overlaps the outside edge of the box by a minimum of one inch.
One box may remain uncovered for short periods of time to allow the addition or removal of rods for inspection purposes provided that personnel are in attendance.
t The licensee was notified of this item of noncompliance during a
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telephone call on October 22, 1979 (79-09-02).
c.
UO,, Liner Washing and Filter Knockdown The inspector observed an operator washing UO, liners at the work l
station in the'sinterability test hood.
It was noted that when the operator removed the washed liner from the hood to place it into an I
open waste drum which was located on the east side in front of the l
hood, potentially contaminated liquid dripped from the operators gloves onto the floor, the west side of the' drum and the operator's' protective clothing.
A subsequent contamination smear taken by a licensee representative at the request of the inspector, revealed a smearable contamination level of about 6000 dpm/100 square centimeters.
Discussions with the operator revealed that drippage did not appear to be a problem, i.e., protective clothing never got to the point of being wet.
The inspector examined the operations sheet OS No. 1462, dated December 20, 1976, " Filter and U0 Liner Handling Procedure,"
7 with operators and determined that the Operators were knowledgeable in the procedural requirements of the operations sheets for " Filter Knockdown," and "Prefilter and Virgin Powder Liner Washing".
- However, it was noted that the operations sheet did not address the radiological or criticality safety aspects 'of the operations conducted in that:
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6 (1) For Filter Knockdown The procedure does not address whether the filter pieces are placed into a plastic bag in the hood or passed through the hood i
opening and placed into a bag placed outside the hood.
Discussions with various operators indicated that both techniques are used by different operators.
(2)
For Prefilter and Virgin Powder Liner Washing The procedure does not address:
(a) Assuring that SNM has been removed from the criticality control zones in the sinterability test hood prior to initi-ating the liner washing operation.
(b) Radiological protection procedures to assure that contamination of personnel and the work area is minimized.
(c) Assuring that the sinterability test hood is reposted with criticality control signs for the operation being conducted.
(d) The frequency for changing wash and rinse water.
Failure to provide adequate instructions in a procedure was identi-fled as an instance of noncompliance (79-09-03).
d.
Open Unsafe Geometry Containers During examination of the process area the inspector noted that several open unsafe geometry containers, including 55 gallon drums, were located at the west end of the pellet stacking area and at the west end of the pellet shop.
These containers were normally used as conta-minated waste receptacles.
However, according to the licensee, the storage of open unsafe geometry containers, when not attended, had not been evaluated for nuclear criticality safety.
Failure to evaluate the use and/or storage of unsafe geometry containers in the process area was identified as an instance of noncompliance (79-09-04).
For additional information, see Paragraph 5.b(4)(b).
e.
Labeling of Mass Limited Containers Section 8.2 of the approved license application requires that all mass limited containers be labeled to indicate the enrichment and the uranium content.
The inspector observed at least 5 closed drums of contaminated waste which had been assayed for uranium content on September 21, 1979, which were not posted to show the enrichment or the uranium content.
Since this condition also existed during inspection i
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70-1100/79-07, and since an item of noncompliance was to be issued in connecticn with that inspection, the report of which has not yet been issued, further action on this item of noncompliance was not i
deemed appropriate during this inspection (70-1100/79-09),
f.
" Visitor" Contamination Surveys Upon exiting from'the unclad fuel handling area, the inspector observed a health and safety technician remove his laboratory coat, wash and survey his hands for contamination, and change shoes to i
street shoes.
The approved license application states that 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, " visitors" must remove their laboratory r
coats and shoe covers-and wash their hands before leaving the area.
An alpha personnel monitor is available for persons to check themselves for contamination.
Any person having contamination on any part of his clothing or body must remove the clothing and thoroughly wash the contaminated skin areas.
This individual made no attempt to survey his body or clothing for contamination to assure that he was not contaminated.
Since this condition also existed during inspection 70-1100/79-07, and since an item of noncompliance was to be issued in connection with that inspection, the report of which has not as yet been issued, further action on this item of noncompliance was not deemed appropriate during this inspection (70-1100/79-09).
4.
Review of Operations The inspector examined all areas of the plant and the nuclear laboratories to observe operations and activities in progress, to inspect the nuclear safety aspects of the facilities and to examine the general state of cleanliness, housekeeping and adherence to fire protection rules.
a.
Nuclear Manufacturing Facilities (1) Outside Waste Drum Storage The inspector examined the outside waste drum storage pad located south of Building 21.
Approximately 33 drums of waste were stored on the pad, each drum was properly labeled as to enrichment and contents, each drum was shown to contain less than 100 gram U-235 and the total quantity of U-235 stored on the pad was less than 500 grams.
(2) Micronizer Log Sheet The inspector examined the micronizer log sheet for the time period June 1, 1979 through September 30, 1979.
The records
8 showed that the appropriate posted nuclear safety limit had not been exceeded during the time period examined.
(3) Contamination Control During this inspection and a previous inspection (70-1100/79-07),
the inspector observed that operators (those personnel who work in the unclad fuel handling areas and are issued clean protective clothing), do not survey their bodies, other than their hands, for alpha contamination when leaving these areas of the plant.
A " Procedure for Entering and Leaving the Pellet Shop," posted at the change line in Paragraph 4, states, in part, that, "If conta-mination is suspected on shces or personnel clothing, the monitor provided at the change line for this purpose should be used."
Once again, there is no requirement to survey their bodies for contamination.
During inspection 70-1100/79-04, the inspector observed a situation where a " puff" of UO2 powder was seen coming out the top of the Station 1 blender hood.
At that time, the powder settled from the open 2nd level location of the hood to the floor level of the pellet shop where other operators were working and were not aware of what had occurred.
The operator working at this hood was also not aware of the contamination release until advised of it by the inspector and the accompanying licensee representative.
The operators were subsequently not found to be contaminated.
In order to determine if radioactive contamination was being carried over the change line, the inspector requested and observed direct and smear alpha contamination surveys of the cold side of the change room at selected locations at 8:00 p.m. on October 9, 1979.
The survey was conducted with an Eberline RM19 equipped with an alpha scintilation probe (RM19 identified as Rad 108 and the scintilation probe identified as Rad /P 25).
The instrument was last calibrated as a unit on October 5, 1979, and the counting efficiency was determined to be 34.5%.
The survey results indicated the following results:
At a location near the change line, 870 dpm/60 cm2 direct, 244 dpm/100 cm2 removable.
At a location in a corner against the farthest wall 580 dpm/60 cm2 direct, 21 dpm/100 cm2 removable.
At other locations away from the change line 290-360 dpm/60 2
cm direct.
This survey indicated that contamination was being transported across the change line in some manner.
However, it was determined through discussions with licensee representatives that fixed contamination surveys'of clean areas are not conducted by the
9 licensee.
In addition to " operators," other licensee personnel who enter the unclad fuel handling areas for short periods of time were also observed not surveying either their bodies or their clothes for' contamination as shown previously in Paragraph
- 3. f.
The inspector also observed that about 75 to 80 percent of the operators who are issued protective clothing (coveralls and shoes) do not remove their street clothes before donning the pro-tective clothes and in at least one instance, it was observed that the protective clothes did not cover the street clothes.
In this instance, on October 11, 1979, the individual involved was observed lying on the floor of the pellet shop working under a sintering furnace.
Subsequent surveys of the individual by licensee personnel indicated that his street clotnes had not become contaminated even though the average removable contamina-tion level of the floor in the unclad fuel handling area was determined by the licensee to be about 700 dpm/100 cm2 on that date.
The licensee records indicated that the removable contami-nation levels of various areas of the floor in the unclad fuel handling area ranged as high as about 12,500 dpm/100 cm during 2
the time period June 7, 1979 through October 10, 1979.
When the areas were identified, immediate cleanup was started as required.
As a result of this review by the inspector, the following items of noncompliance were identified.
(a) Management had not assured that radiological safety con-trols had been established as required by Section 8.2 of the approved license application in that personnel leaving the unclad fuel handling area were not required to survey for radioactive contamination on their bodies, clothes, and shoes and fixed contamination surveys are not conducted in clean areas (79-09-03).
(b) The maximum removable contamination level on the clean side of the men's change room was 244 dpm/100 cm2 which was in excess of the permitted 100 dpm/100 cm2 allowed by Section 15.3.5 of the approved license application (79-09-05).
b.
Nuclear Laboratories (1) Facility Examination It was noted by the inspector that the personnel contamination survey instrument for the emission spectroscopy and enemistry laboratories had been relocated inside the exit doors to the respective laboratories from a position just outside these doors in the hallway.
It was also noted that source material was no
10 longer being stored in the mens change room and that the Caution-Radioactive Materials sign previously posted on a cabinet at this location had been removed.
(2) Ceramics Laboratory Vacuum System The inspector observed that a vacuum cleaning system was available for use in the ceramics laboratory.
According to licensee repre-sentatives, this system was used to clean the laboratory floor and clean up the external portions of equipment used in the laboratory.
It is not to be used to clean up fuel spills.
The inspector requested a copy of the written instructions for the use of this vacuum system and was informed that no written instructions were available.
Section 8.1 of the approved license application requires that written health and safety restrictions be provided for all operations on radioactive materials.
Since written instructions were not available for this equipment, the licensee was notified that this constituted an instance of noncompliance (79-09-03).
5.
Nuclear Criticality Safety a.
Nuclear Laboratory (1) Nuclear Safety Postings Inspection of the laboratories disclosed no inst r.ir of lack of nuclear safety postings or failure to follow the posted.; its.
It was noted that the posted limits had been increased frca 350 grams to 740 grams U-235 in criticality areas 19, 22, and 25.
Licensee documentation, dated August 30, 1979, approved the changes with the stipulatict that these areas could no longer receive U02 enriched to greater than 5 w/o U-T35.
Verification of enrichments at less than 5 w/o U-235 was completed prior to the limit changes.
The continuous logs for several of the criti-cality areas were examined, Each log showed :he amount of uranium and U-235 present in the area and the enrichmant of the uranium as required.
(2)
Labeling of Closed Waste Drums The inspector noted that a closed waste drum located in the ceramics laboratory was not labeled with U-2?5 content and enrich-ment as required.
Licensee records for the urum contents indicated that the drum contained a negligible quantity of U-235, however, the drum, No. NL865, was immediately labelef.
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11 (3) Monthly Audits of the Nuclear Laboratories The inspector examined the records of four monthly audits of the nuclear laboratories conducted by the Nuclear Licensing and Safety Supervisor for the time period May 31, 1979 through September 27, 1979.
The inspector noted that no problem areas were identified during the conduct of the monthly audits.
b.
Nuclear Fuel Manufacturing (1) Nuclear Safety Postings Instances of inadequate posting of nuclear safety specification in Building 17 were previously discussed in Paragraph 3.a.
(2)
Internal Review and Audit (a) Daily Audits Records of daily audits conducted by health physics technicians for the time period June 7, 1979 through October 10, 1979, were examined by the inspector.
These audits examined signs, logs, radiation alarms, and criticality safety compli-ance.
Items requiring corre: tion were corrected immediately.
(b) Monthly Audits Documentation of monthly audits conducted by the Nuclear Licensing and Safety Supervisor, as required by Amendment 17, during the time period June 25, 1979 through September 27, 1979, were examined by the inspector.
A total of 6 items were identified which require correction in the four reports.
The inspector verified that appropriate corrective actions were taken or had been initiated by the licensee.
(3) Nuclear Safety Evaluations (a) Facility and Equipment Changes and Modifications The inspector noted that the licensee was constructing an enclosed equipment storage crib cage at the northwest corner of the machine shop area.
This crib was previously located in the center of the shop area just southeast of the new location.
Licensee representatives indicated that this equipment storage crib was not to be an authorized storage location for SNM bearing fuel components.
The licensee has started installation of dual criticality monitors in Building 17.
Presently, two units have been
12 installed side-by-side in the southwest corner of Building 17 and at one location in the unclad fuel handling area of Building 17.
Licensee representatives indicated that the installed units are no+. operational and that it would be some time before the remaining units are authorized for installation.
It was noted that the original criticality monitors located throughout the facility appear to be operating properly.
The licensee is in the process of rearranging equipment in the pellet stacking area of the unclad fuel handling area.
A new pellet storage rack and rod storage rack have been installed to the north of the down draft tables against the north wall and a new final end cap welder was being installed into the southeast corner of the pellet stacking area.
None of this equipment was authorized for use with a 9M at the time of this inspection.
Two exclusion zones for the temporary storage of U0 hoppershadbeendelineatedonthefloorofthepelfet shop just north of the exclusion zone for the UO7 powder and pellet storage bunkers and south of the powder blending stations.
These temporary storage zones were not posted as required with nuclear safety signs.
However, since they were not in use at any time during this inspection, the inspector indicated that these zones would have to be evaluated for nuclear safety and posted prior to use.
The licensee removed the tape delineating the zones and indicated that the evaluation and posting requirements would be met prior to replacing the tape for use of the zones.
(b) Review of Nuclear Safety Evaluations The inspector reviewed the records of the review and approval of process equipment or facility changes performed by the Nuclear Licensing and Safety (NL&S) Supervisor for criticality and radiological safety.
From May 16, 1979 through October 4, 1979, 12 requests for review and approval of facility and equipment changes were made by Engineering.
The requests were reviewed and approved by the NL&S Supervisor and conditions were imposed, as needed, for criticality and radiological safety considerations.
Seven of the requests involved criticality safety considerations and these requests were independently reviewed by a qualified person designated by the Nuclear Safety Committee.
These evaluations were then countersigned by this qualified person after review as required.
13 The inspector requested the licensee to supply copies of approved and reviewed evaluations concerning the use of open unsafe geometry containers for contaminated waste in the unciad fuel handling areas previously discussed in Paragraph 3.d, and for the storage of assayed and/or unassayed closed contaminated waste drums anywhere in the unciad fuel handling areas.
Discussions held with a licensee representative indicated that the use of open unsafe geometry containers in the unclad fuel handling areas had not been evaluated and that the storage of closed contaminated waste drums which had been demonstrated to contain as much as 150 gram of U-235 anywhere in the unciad fuel handling areas had been evaluated but copies of the evaluation could not be supplied i
to the inspector prior to the end of this inspection.
Telephone discussions held with the Nuclear Licensing and Safety Supervisor subsequent to the inspection on October 22, 1979, indicated that this evaluation could not be located.
Failure to analyze or evaluate the use of open unsafe geometry containers and maintain records of approval of the evaluation of the storage of closed waste drums anywhere in the unciad fuel handling area was identified as an item of noncompliance (79-09-04).
6.
Safety Committees The inspector examined records of the minutes of meetings held by the Nuclear Laboratories Development Department Safety Committee between December 6, 1978 and August 8, 1979.
During this period of time, nine meetings'were held on a monthly basis.
Topics covered during these meetings included discussions on emergency training, criticality incident reentry team training, storage of hazardous liquid waste, use of hazardous chemicals, general safety, industrial safety, and radiation protection.
7.
Organization The inspector determined through examination of licensee records and discus-sion with licensee representatives that no changes in the organizatio' of the Nuclear Laboratories or the Manufacturing Facility occurred since the last inspection.
8.
Training a.
Salaried Employee Trairdng During inspection 70-1100/79-07, all aspects of employee training were examined in detail with the exception of the training of Supervisory /
Salaried employees.
This group of personnel includes management, engineering and scientific personnel who have occasion to work in or
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14 inspect the SNM handling areas unescorted.
Examination of salaried employee training records available for the years 1977 and 1978 (no training had been conducted in 1979 through August, 1979), revealed that 8 salaried employees were trained in 1978 but not in 1977, seven additional salaried employees were trained in 1977 but not in 1978, and at least 5 salaried employees had not been trained during 1977, 1978, or 1979, the only years for which records were available.
Since an item of noncompliance was to be issued with respect to employee training in connection with inspection 70-1100/79-07, the report of which has not been issued as yet, and since the licensee has started retraining all employees including salaried personnel in anticipation of this item of noncompliance, further action on this item of noncompli-ance was not deemed appropriate during this inspection (70-1100/79-09).
b.
Emergency Response Training The inspector noted that occasional workers and visitors to the Nuclear Fuel Manufacturing facilities were not instructed in the appropriate response to warnings or alarms sounded in the event of any unusual occurence or malfunction that may involve exposure to radiation or radioactive material.
The licensee indicated that procedures have been established in order to enhance the security of the facility which require that all " occasional" workers and/or visitors who enter the facility will be required to be escorted.
It is this escort's responsibility to assure that the occasional worker and visitor responds properly to all warnings and alarms.
9.
Maintenance The inspector reviewed maintenance practices in the Nuclear Laboratories through a review of records and discussions with licensee personnel.
Maintenance personnel do not report to the Nuclear Laboratory management.
When maintenance personnel perform work on equipment where the potential for exposure to radioactive contamination or radiation exists, health physics procedures are involved to assure safety.
Radiation Work Permits (RWP's) are issued by health and safety personnel.
These permits establish the protective clothing and respiratory protection requirments for the jobs to be done.
These maintenance personnel are escorted in restricted (poten-tially contaminated) areas at all times by appropriate laboratory personnel.
Preventative maintenance is conducted on systems important to safety on an established frequency, i.e., ventilation systems, emergency generator startup tests, etc.
In addition, the change in pressure across filters is checked weekly, hood flow and laboratory air flow direction are checked monthly.
Magnihelic gau0es have been installed into the ventilation ducts for all ventilation systems associated with potentially contaminated equipment and these gauges are checked by health physics personnel at least weekly.
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15 10.
Followup on Regional Office Bulletins The inspector held discussions and examined a response letter to the NRC dated September 24, 1979, concerning the applicability of IE Bulletin No. 79-19, dated August 10, 1979, " Packaging of Low-Level Radioactive Waste for Transport and Burial," to operations at this site.
The licensee had deter-mined that this Bulletin was applicable to the site as indicated in the response letter.
Item 9 of the Bulletin requested a report, in writing, (giving) the plan of action and schedule (for completion) with respect to the previous 8 items.
The licensee's response did not comply with this report in that the plan of action and schedule of completion was not indicated in the September 24, 1979 response letter for items 3, 4, 5, 6, 7, and 8.
In addition, the availability of the documents specified in item 1 was not indicated.
This was discussed with the licensee at the exit interview and the licensee indicated that a supplemental letter would be submitted to the NRC:I office supplying the required information (79-BU-19).
11.
Shipping a.
Initial Use of Packaging The inspector determined through discussions with licensee representa-tives that no new shipping packages had been purchased for use in shipping special nuclear material.
It was also determined that qua-lity assurance personnel, in the past, did not routinely follow the manufacture and inspection of new shipping packages, although this had been done on a sporadic basis.
Procedures are currently being revised to assure that quality assurance personnel will follow the fabrication of new packages in detail in the future.
b.
Routine Use of Shipping Packages Procedures for the packaging of SNM containing components were reviewed by the inspector.
Licensee records relating to the shipping of fuel bundles in 927Al and 927C1 shipping containers were examined for packages shipped between June 12, 1979 and September 26, 1979.
A shop traveler " Fuel Shipment" is used to specify the steps and procedures to be followed in packaging fuel bun-dies.
A procedure, MFG-03-02, Revision 8, dated August 27, 1976, " Pack-aging of Fuel Bundles," covers the procedural requires for package inspection before, during, and after loading, bundle loading into the package, final closure, and securing of the shipping container, and loading of the shipping container onto the transport vehicle.
It also covers container and vehicle labeling requirements.
The shipping records documented the results of radiation surveys, container inspec-tion results, labeling, marking and placarding of vehicles and con-tainers as required by license conditions, internal procedures, or federal regulations.
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1 16 Through discussions with licensee representatives, it was determined that Specification 17H, shipping containers used for the packaging and shipping of contaminated waste had not, in the past, been routinely checked as required by 10 CFR 71.54, " Routine Determinations." However, this weakness had been identified in a recent audit of shipping practices and procedures are currently being rewritten to include this requirement.
12.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection at 11:00 a.m. on October 12, 1979.
The inspector summarized the scope and findings of the inspection.
The licens-ee was notified by phone on October 22, 1979, that the items concerning improper rod box storage (Paragraph 3.b) and contamination control (Para-graph 4.a.(3)(a))iously identified during the exit interview.would be cited as to the items prev
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