ML20009B504
| ML20009B504 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 05/08/1981 |
| From: | Clemons P, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20009B501 | List: |
| References | |
| 70-1100-81-03, 70-1100-81-3, NUDOCS 8107160170 | |
| Download: ML20009B504 (7) | |
Text
n U. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT REGION I Report No.
70-1100/81-03 Docket No.
70-1100 License No. _SNM-1067 Priority 1
Category UR Licensee:
Combustion Engir.aering, Inc.
P. O. Box 500 Windsor, Connecticut 06095 Facility Name:
Nuclear Manufacturing Facility Inspection At:
Windsor, Connecticut Inspection Conducted:
February 25-27, 1981 M/
Inspector:
~P riemere, Radiatio. Specialist
'date5 NM. A. 8 0
f/
Approve sfM~
/ date P. J. Knapp, Chief, Facility Ra(iological Protection Section, Technical Inspection Branch Inspection Summary:
Inspection on February 25-27, 1981 (Report No. 70-1100/81-03)
Areas Inspected:
Routine, unannounced insp?ction by a regional based inspector of the Radiation Protection Program including:
outstanding items, environmental monitoring, procedures for opening packages, source inventory and leak test, dosimetry, bioassay, drills, terminations, monthly and annual audits, liquid waste, air samples, ventilation, smears, and training.
Shortly after arrival, areas where work was being conducted were examined to review radiation control procedures and practices.
The inspection involved 19 inspecto--hours onsite by one regional based inspector.
Results: Of the 13 areas inspected, no items of noncompliance were identified in 11 areas. Two apparent items of noncompliance were identified in two areas (Failure to conduct. environmental monitoring program as required, Paragraph 3; Failure to have procedures for opening packrges of licensed material, Paragraph 4).
Region I Form 12 (Rev. April 1977) 8107160170 810515 PDR ADOCK 07001100 C
PDR i
OETAILS 1.
Persons Contacted
- Mr. G. Johnstone, Health Physics and Safety Supervisor
- Mr. H. Lichtenberger, Vice President Mr. J. Limbert, Laboratory Radiation Engineer
- Mr. F. Pianki, General Manager, Fuel Fabrication Mr. P. Rosenthal, Manager, Health Physics The inspector interviewed several other licensee employees during the course of the inspection.
- Denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Event Report (1100/80-ER-01):
Exceeded quarterly reporting level.
The inspector revies.ed the licensee's corrective action as reported in the July 10, 1980 communication.
The prncedures have been developed and apparently are being followed as noted by the inspector.
(0 pen) Noncompliance (1100/80-05-01):
Radiation Control Committee not formed and functioning.
In a letter dated September 30, 1980 the licensee stated "...the Committee has been organized and intends to complete its annual audit function by October 31, 1980." The inspector reviewed docu-mentation that indicated that the Committee had been organized, and that the audit had been conducted before October 31, 1980, but the inspector also noted that the audit report had not been issued at the time of this inspection.
3.
Environmental Monitoring Condition No. 9 of Spacial Nuclear Material License No. SNM-1067 states:
"For use in accordance with the specifications ir, Sections 7, 8, 10, 12, 13, 14, 15, 19...of the licensee's application.. dated April 16, 1973...".
Section 15.12 of the licensee's application reqLires that various types of environmental samples be collected and analyzed at the frequencies cited in Table 15.1 as noted below:
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u.
3 Table 15.1 CE Environmental Monitoring Program
. Sample Frequency Analyses 1.
Farmington River Quarterly in M'rch Gross Alpha and Beta, Surface Water, May, August and Nitrate, Fluoride, Industrial Stream November pH, Total Uranium and Site Ponds 2.
Well Water Quarterly in March, Gross Alpha and Beta, May, August and Total Uranium, Nitrate, November Fluoride and pH 3.
Sediment from Quarterly in March, Gross Alpha and Beta, Farmington River, May, Augu.t and Total Uranium Site Ponds and November and Industrial Stream 4.
Vegetaticn Semi-Annually in Gross Alpha and Beta, On-Site May and September Total Uranium Vegetation Semi-Annually in Gross Alpha and Beta, Off-Site May and September Total Uranium 5.
Soil Semi-Annually in May Gross Alpha and Beta, and September Total Uranium 6.
Fallout Quarterly in March, Gross Alpha and Beta, May, August and Total Uranium November On February 26, 1981 the inspector asked the Radio-Chemist to demonstrate that the environmental monitoring program had been conducted as required.
The Radio-Chemist provided the inspector with documentation that indicated that the environmental monitoring program had not been conducted as required because various types of samples had been collected but the required analyses had rot been performed.
Specifically:
First Quarter - 1980 a)
Well Water samples - collected but not analyzed for nitrates and fluorides.
J
k w
^4 Second-Quarter - 1980 Farmii. Don River Surface Water, Industrial Stream and Site Pond samples -
collected but not analyzed for nitrates.
Third Quacter - 1980 a)-
Farmington River Surface Water, Indust. rial Stream and Site Ponds samples - collected but not analyzed for nitrates and fluorides.
b)
Well Water samples --collected but not analyzed for nitrates and fluorides.
c)
Sediment samples - collected but not analyzed for total uranium, d)
Vegetation samples - collected but not analyzed for any components.
Fourth Quarter - 1980 All samples coliected as required but none have been analyzed for any components.
The inspector noted that failure to analyze the environmental samples as required represents noncompliance with Condition 9 of SNM License No.
(81-03-01) 4.
Procedures For Opening Packages On February 25, 1981, during review of records of receipt of radioactive material, the inspector observed that the licensee received shipments of licensed material on December 17, 1980 (about 3 curies) and February 12, 1981 (about 3 millicuries).
This material is possessed under NRC Materials License No. 06-00217-06.
The inspector asked if the packages had been opened. He was told that the packages had been opened, and the contents
" distributed" as required.
The inspector asked the Laboratory Radiation Engineer if CE had procedures for opening packages containing licensed radioactive material, and was tolc' that procedures had not been developed.
10 CFR 20.205(d), " Procedures for picking up, receiving, and opening packages," states: "Each licensee shall establish and ma'itain procedures for safely opening packages in which licensed material is received, and shall assure that such procedures are followed and that due consideration is given to special instructicns for the type of package being opened."
The inspector noted that failure to have procedures for opening packages containing licensed radioactive material represents noncompliance with 10 CFR 20.205(d).
(81-03-02)
s 5
5.
Dosimetry The inspector reviewed dosimetry records for the period July-December 1980 for approximately 150 individuals monitored at the Nuclear Fuel Manufacturing Facility and the Laboratories.
The data indicated that all exposures were well within the 10 CFR 20.101 limits.
No items of noncompliance were identified.
6.
Drills Amendment No. 20 to SNM-1067-incorporates the licensee's emergency plan dated July 30, 1979.
Section 8.1.2 of the emergency plan states:
" Semi-annual... drills are conducted...".
The inspector reviewed documentation that indicated that emergency drills were conducted, and critiqued, in June and October 1980.
No items of noncompliance were identified.
7.
Bioassay Condition No. 17 of SNM-1067 requires the licensee to develop and maintain a bioassay program which meets the specifications of Regulatory Guide 8.11, " Application of Bioassay for Uranium".
Regulatory Guide 8.11 suggests an annual sampling frequency for minimum programs.
The inspector reviewed urine bioassay data for about 25 employees for 1980 to determine that the employees were participating in the program as required. The employees are participating in the program, and the data did not indicate any problems with exposure control.
No items of noncompliance were identified.
8.
Smears Section 15.6.1 of the licenn
, application requires that smear surveys be taken and analyzed for alphi. >ctivity to verify compliance with internal limits. The inspector reviewed smear survey records for the period July-December 1980 to assure that the licensee was in compliance with this license requirement.
No items of noncompliance were identified.
9.
Source Leak Test License Condition 15 of SNM-1067 requires "Each encapsulated plutonium source...shall be tested for leakage at intervals not to exceed six l
months." The licensee has five plutonium sources that must be tested.
t l
t
6 The inspector reviewed leak test data for the period January-December 1980.
The data indicated that all sources had been leak tested at the specified intervals.
License Condition 13(c) of NRC Materials License No. 06-00217-06 also requires sealed sources be leak tested at intervals not to exceed six months. The inspector reviewed leak test data for the sources held under this license for the same period stated above.
The data indicated that the sources had been tested at the required frequency.
No items of noncompliance were identified.
10.
Internal Audits - SNM-1067 Section 8.3 of the licensee's application, which is incorporated by License Condition 9 of SNM-1067, requires that monthly audits for radio-logical considerations be performed by a qualified individual.
The inspector questioned licensee representatives regarding the conduct of the monthly internal audits as required by Section 8.3.
The inspector reviewed audit reports for the period July-December 1980 for the monthly radiological safety audits.
The Nuclear Safety Committee is aIso required to perform an annual audit of the radiological aspects of SNM-1067. The inspector reviewed the report of an audit conducted by the Nuclear Safety Committee on December 12, 1980.
No items of noncompliance were identified.
11.
Ventilation Section 15.7 of Special Nuclear Material License No. SNM-1067 requires face velocities at hood openings to be at least 100 feet per minute. The licensee performed weekly ventilation surveys in the Pellet Shop, and monthly ventilation surveys in the laboratories, to determine that the face velocities were as required.
The inspector reviewed ventilation data for the Pellet Shop for the period July-December 1980 to confirm tt.at the required flow rate was maintained.
The data indicated that in every in:tance the face velocities were in excess of 100 feet per minute.
No items of noncompliance were identified.
- 12. ~ Air Samples The inspector reviewed general air sample data for the period July-December 1980 to determine if the licensee was in compliance with regulatory requirements.
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The inspector also reviewed breathing zone air sample data for approxi-mately 15 employees for the same period.
No items of noncompliance were identified.
- 13. Training Section 15.13 of SNM-1067 requires all personnel who are to handle radio-active materials-in the Manufacturing Facility receive training in the health and safety requirements.
The inspector reviewed training-related documentation which indicated approximately fifteen new employees had received appropriate-training during 1980.
Two females were included in this group, and the documentation indicated that they had also received pre-natal exposure training.
ihe documents also indicated that established employees, professional as well as technicians, had received retraining during 1980.
No items of noncompliance were identified.
14.
Liquid Waste The inspector reviewed liquid waste discharge data for the period October-December 1980 for the Manufacturing Facility to determine if the licensee
' adhered to requirements of 10 CFR 20.
The licensee made sixty discharges, totalling 120,000 gallons, during the period. All discharges were within the regulatory limits.
No items of noncomplince were idtatified.
15.
Termination Reports 10 CFR 20.408 requires a licensee to submit to the Director of Management and Program Analysis a report of an individual's exposure to radiation and radioactive material, incurred during the period of employment in the licensee's facility, when the individual terminates employment with the licensee.
The inspector reviewed approximately 10 exposure reports for 1980 of employees that had terminated employment with the licensee.
These reports had been submitted as required.
No items of noncompliance were identified.
16.
Exit Interview The inspector met with the licensee representative (denoted in paragraph
- 1) at the conclusion of the inspection on February 27, 1981.
The inspector summarized the purpose and scope of the inspection, and the findings as presented in this report.