ML20005G895
| ML20005G895 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 01/05/1990 |
| From: | Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20005G892 | List: |
| References | |
| 70-1100-89-01MM, 70-1100-89-1MM, NUDOCS 9001230261 | |
| Download: ML20005G895 (13) | |
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- j U.S. NUCLEAR REGULATORY COMMISSION.
REGION I Docket No.
70-1100 License No.
SNM-1067 Licensee:
Combustion Engineering, Incorporated 100 Prospect Hill Road Windsor. Connecticut 06095-0500 Facility Name: Windsor Nuclear Fuel Fabrication Facility Type of Meeting: Management Meeting Meeting Date: October 5. 1989 f
Prepared by:
JT I
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th,' Profect Engineer, ERPS
" date' Approved by:
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R. Bores,
'ef,' Effluents Radiation
- date 1
Protectio ection, Facilities Radiological Safety and Safeguards Branch Meeting Summary: A management meeting was held at Region I, King of Prussia, Pennsylvania, on October 5,1989, to. discuss the licensee's updated schedule for completion of corrective actions with regard to the Nuclear Fue1' Integrated Improvement-Program (NFIIP) and the violations and comment's made during the recent Mid-SALP Team Inspection. The meeting was attended by NRC and licensee-L management. Two main issues were discussed:
(1) NRC representatives provided the: licensee with the results of the recent Mid-SALP Team Inspection and I
licensee representatives provided the NRC with the planned actions to respond.
to the violations and comments made during the Team Inspection and (2) the.
licensee provided an updated report on the status of actions taken to complete
-the Nuclear Fuel Integrated Improvement Program. The NRC requested the Itcensee to conduct an internal. assessment of the~ improved safety program upon completion of the NFIIP and to make available for NRC review the results of that assessment, and the licensee agreed.
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1 DETAILS 1.0 Meeting Attendees a.
Combustion Engineering, Incorporated S. Brewer, President, Nuclear Power' Businesses P. McGill, Vice President, Nuclear Fuel' C. Waterman,-Vice President and General Manager, Nuclear Fuel-1 Manufacturing A. Scherer, Director, Nuclear Licensing P. Rosenthal, Program Manager, Radiological and Industrial Safety b.
Nuclear Regulatory Commission-W. Russell, Regional' Administrator M. Knapp, Director, Division of Radiation Safety and Safeguards (DRSS)
J. Joyner, Division Project Manager, DRSS R. Bores, Chi-f, Effluents Radiation Protection Section, DRSS l
M. Austin, Radiation Specialist, DRSS i
l F. Costello, Sr. Health Physicist, DRSS P. O'Connell, Radiation Specialist, DRSS
)
. C. Gordon, Emergency Preparedness.Specialj st, DRSS l
J. Roth, Project Engineer, DRSS I
J.-Jang, Sr. Radiation Specialist, DRSS l
G. Bidinger, Section Leader, NMSS D. McCaughey, Nuclear Process Engineer, Licensing Project Manager, NMSS r
2.0 Summary of Discussion Mr. Russell opened the meeting, welcomed the licensee representatives and turned the meeting over to Dr. Knapp.
Dr. Knapp introduced the meeting participants and -turned the meeting over to Mr. Joyner.
Mr. Joyner provided the licensee representatives with the results of the Mid-SALP Team Inspection conducted on' September 5-8, 1989.
l Mr. Waterman provided information on the actions: (1) taken to correct the violations identified
'.n the mid-SALP report; (2) initiated to address the request for additional information on the internal' audit program and i
conduct of an emergency drill; and (3) taken to address deficiencies identified in the Radiation Deficiency Report Program.
Mr. Waterman also discussed the status of completion of the Nuclear Fue1' Integrated Improvement Program.
Mr. Rosenthal described the status of efforts to more accurately determine skin and extremity doses to personnel from beta radiation in the Pellet Shop.
(Copies of slides of the information presented by Messers. Waterman and Rosenthal are attached.)
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3.0 Conclusions Mr. Russell suggested that the licensee consider conducting a compre-hensive, internal assessment of the licensed program to determine how r
successful the Nuclear Fuel Integrated Improvement Program (NFIIP) was in J
correcting the safety program deficiencies originally identified by-the NRC. This assessment should be conducted following completion of all
~ 1 elements of the NFIIP.
Completion of the NFIIP is expected to occur during the first quarter of 1990. The licensee committed to perform-the self assessment.
Mr. Russell also requested the licensee to provide the Region I office
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with a schedule for completion of the NFIIP, conduct of the suggested assessment and completion of the assessment report. He also stated that the NRC would conduct a confirmatory assessment following completion of these actions.. Dr. Brewer stated that the requested schedule would be provided to the NRC Region I Office within ten (10) days of this meeting.
4.0 NRC Region I Inspection Repo-t No. 70-1100/89-80 (IR 89-80)
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1 Subsequent to the meeting, Mr. John Conant, Manger, Nuclear Material Licensing, contacted Mr. Joyner to provide supplemental information for and to identify possible misinformation in the report of the Mid-SALP l'eam Inspection.
Mr. Conant's comments and the NRC staff's response are indicated in the sections below.
4.1 In the first paragraph of Section 4.1 of IR 89-80, it is noted that the policy statement contained-in Program Requirements-3 (PR-3),
" Criticality Safety Program," is silent on employee responsibilities to follow procedures and on employee obligations to halt an operation-if it is not covered by procedure or if safety is in doubt. The licensee's position is that the Program Requirements document is not the right place for the type of policy information cited above, but that it will be contained in a new employee handbook that is under development.
The licensee should promptly incorporate the policy statements in an existing document until they can be issued in the employee handbook.
4.2 In the. first paragraph of Section 6.1 of IR 89-80, it is noted that-
"there have been no independent audits of the radiation protection program." The licensee's position is that there have been indeperdent reviews of the radiation protection program. Mr. Conant cited the review performed by the Bechtel Corporation s
representatives from Oak Ridge, Tennessee; and the assignment of Mr. Jim Limbert, who Mr. Conant described as knowledgeable in health physics and from outside the Fuel Division, to the Task Force that assessed compliance with all regulatory requirements in 1988. The NRC staff acknowledges that these constitute independent audits, but notes that these audits were performed in mid-1988 or earlier.
Independent audits should be performed on a continuing basis.
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4 4.3 In Section 7.2 of IR 89-80 it is noted that "the -licensee should submit implementing procedures to NRC for approval." Mr. Conant stated that the licensee's position is that they don't believe they are required to submit implementing procedures to NRC for approval,
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that they may be implemented 2fter the licensee's inttrnal approval i
process. 'The NRC staff agrees with the licensee's' position.
4.4-In Section 7.8 of IR 89-80 Mr. Conant noted that the NPl appears to.
f suggest that emergency procedures are being written by the licensee in order to implement the Radiological Contingency Plan (RCP). ~If' that is the NRC staff's belief, it is incorrect.
The precedures in J
preparation are needed to implement the Emergency Plan-(EP), which has not yet been approved by NRC.
Thus, while the EP procedures are not yet complete, they are not required prior to 90 days after NRC' approval of the.EP.
The procedures required to implement the RCP have long been in place and have been implemented in past exercises and in response to actual emergencies involving the. site.. The NRC staff agrees with the licensee's position.
4.5 In Section 8.2 of IR 89-80, it is noted that "there is no independent assessme..t of the nuclear criticality-safety and radiological protection areas by technically qualified individuals." Mr. Conant noted that he had previously. addressed the.
issue relative to radiological protection (See Section 4.2 abovt),
and that, similarly, there have been independent audits of the criticality safety area. He noted that Mr. Dave Smith, of Los Alamos Scientific Laboratory, has reviewed criticality-safety as 4
part of the 1988 Task Force on regulatory compliance, as has Mr. Bob Harding, who performed audits after-he had-retired from the licensee's Fuel Division. The NRC staff comment at the conclusion l
of Section 4.2 above applies'to Mr. Smith's' audits.. However, the staff questions the independence of Mr. Harding's audits, since he continues to perform secondary reviews of. criticality safety changes in the facility.
4.6 In Section 9.1 of IR 89-80, it is noted' that the licensee's licensing l-staff includes "a dedicated staff of four people and a temporary staff equivalent to 6-7 staff years of support." Mr. Conant l
corrected this information. He said that the four-full-time. people are part of the 6-7 staff years equivalent. The NRC staff acknowledges the correction.
4.7 In Section 9.4 of IR 89-80, it is noted that the ~" procedure whereby Radiological and Industrial Safety _ requests Nuclear Licensing 1to initiate a licensing action has not been written." Mr. Conant acknowledged that the procedure has.not been written, but noted that i
any line manager can request a licensing action, not just Radiological and Industrial Safety.
The NRC staff acknowledges the additional information.
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VIOLATION 70-1100/89-80-02 j
Failure to retrain salaried personnel within 13 months.
Corrective Action 0
. Salaried personnel. requiring retraining have been-trained.-
0 Training Program Document will clarify requirements.
O Written response will be provided within 30 days.
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RADIATION DEFICIENCY REPORT DEFICIENCY U
New system used by Radiation Technicians to report finciings of thsic routine inspections.
Old system was' Abnormal' Event Occurrences (AEO). This system has been elevated up to the Operations Department (Shift Supervisors and Operations Manager).
PLAN FOR RADIATION TECHNICIANS INSPECTION FfNDING SYSTEM 0
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Define what' is a finding for this program.
O Make system require corrective action at lowest level for operation type non-compliance findings:
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If workers are not wearing proper protective clothing stop operation until they comply.
Elevate longer term corrective' action items or higher sevsrity level findings to other programs:
0 Equipment items to Equipment Status Report (ESR) system 0 AEO's to AEO system.
O Document all findings and forward to Managcment for trending and aid in root cauce cacIycie.
This system will be implemented by an RPI.
O RPI is in draft form and being revised consictent with above.
O RPt will be put into our scheduling system.
O When RPI is issued its requirements will be communicated to all workers, supervisors sad managers in NFM.
O instructions on the use and purpose of the existing Radiation Deficiency Reports have been provided to RP Technicians, Production Supervisors and Operations Shift Suparvisorc.
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INDEPENDENT AUDITS OF RADIOLOGICAL SAFETY AND CRITICALITY Audit Audit Responsibility Frequency Program Manager, Quarterly Radiological And Industrial Safety i
' Nuclear Safety Committee Annual i
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Independent Task Force Assessment (CAL 88-23)
(Completed 12/31/88)
Outside Radiological And Criticality Consultants-(Completed 12/3188) 1 Subcommittee Followup Quarterly During 1989
PLANS FOR EMERGENCY PREPAREDNESS EXERCISE 1989
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The existing Radiological Contingency Plan and implementing procedures will be modified to incressel:)
O their response effectiveness.
O Appropriate training will be conducted.
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An exercise will be conducted before December 31,1989 to test the promptness of response, adequacy of procedures, emergency equipment and the overall effectiveness of the picn.
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The exercise will involve off-site agencies to test as a minimum the communication links and i
notification procedures and site. security,-survey and re-entry teams to assure familiarity and efficiency in performing their emergency functions.
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PLANS FOR'MORE ACCURATELY' DETERMINING EXTREMITY AND SKIN PERSONNEL DOSE-EXTREMITY-DOSE 1985 STUDY l
1989 STUDY-
- FINGER RINGS
- WRIST BADGES
- WHOLE BODY TLD
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- BOTH SHORT & LONG TERM STUDIES IN PROCESS i