ML20033F042
| ML20033F042 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 02/26/1990 |
| From: | Bores R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20033F038 | List: |
| References | |
| 70-1100-89-07, 70-1100-89-7, NUDOCS 9003150299 | |
| Download: ML20033F042 (10) | |
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L U; S. NUCLEAR REGULATORY COMMISSION REGION I Report'No=,
70-1100/89-07 Docket'No.
70-1100 l
License No.
SNM-1067 Priority _1_
Category ULFF Licensee: Combustion Engineering Incorporated 1000 Prospect. Hill Road Windsor Connecticut 06095 Facility Name:
Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor Connecticut
. Inspection Conducted: November 27-30, 1989 n
i Inspectors:
2_d B
q J. $pth', Pr~oject Engineer, Effluents Radiation
' dats Prot'ection Section, FRSSB, DRSS r
Approved by hW { L 2 /2f/fo d
4 R. J. Bores, Chief, Efj4uents Radiation d6te Protection Section, FRSSB, DRSS Insp'ection Summary:
Inspection'on November 27-30, 1989 (Report No. 70-1100/89-07)
. Areas Inspected:
Routine, unannounced inspection by a region-based inspector of the licensed program including management controls, reviews of operations, nuclear criticality safety, transportation and decontamination of onsite areas.
' I Results: One violation, one noncited violation and one unresolved item were identified.
Violation - failure to maintain the spacing between two arrays of' containers at 20 feet or greater (Paragraph 2.2); Noncited Violation posting-of a containe'r of radioactive material as required by 10 CFR 20.203(e)(2) 1(Paragraph:2.1); Unresolved Item - Conduct of nuclear safety evaluations with regard' to the-spacing between fuel rod transfer carts and other work stations
- or,other fuel rod transfer carts (paragraph 2.3).
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.9003150299 900305
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OETAILS 1.0 Individuals Contacted
- C. R. Waterman, Acting Vice President - Nuclear Fuel
- R. Vaughn, Manager, Operations
- D. L. Parks, Manager, Nuclear Materials
- P. R. Rosenthal, Program Manager, Radiological and Industrial Safety
- J. Conant,- Manager, Nuclear Material Licensing
- J. Ballard, Operations Consultant J. Vollaro,-Supervisor, Radiological and Industrial Safety S. Kucavich, Lead Radiation Protection Technician
- Denotes those present at the exit interview.
The inspector also interviewed other licensee employees during the inspection.
6 2.0 Review of Operations j
The inspector examined selected 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 f
protection rules.
2.1 Postings I
I The inspector observed that a "seatainer" was located in the i
Building 17 North Yard and contained natural uranium in excess of j
100 times the 10 CFR 20 Appendix C limit (10 millicuries).
- However, i
this seatainer was posted with Caution Radioactive Material sign on j
three rather than four sides.
The inspector noted that this "seatainer" had been moved from a location immediately adjacent and
.i to the north of another "seatainer" to a position on top of the other
" sea tai n e r"_.
It had previously been posted on the three accessible l
sides. However, the licensee neglected to post the fourth (south side) after the container had been moved.
The licensee immediately i
posted the fourth side of the "seatainer" as required by 10 CFR 20.203(e)(2) upon identification of this deficiency by the inspector.
This was identified as an apparent noncited violation (1100-/89-07-01), in that the criteria specified in 10 CFR 2 Appendix C.V.A were met. These criteria included; 1) corrective actions-were immediately taken and completed by the licensee, 2) this was-a Severity Level IV violation, and 3) this violation was not willful. Adequate corrective actions were completed by the licensee prior to the end of this inspection.
In accordance with the criteria of 10 CFR 2, Appendix C.V.A, no Notice of Violation will be issued for this apparent violation.
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-2.2 Criticality Safety Array Spacing During examination of the yard area located to the north and west of Building 17, the inspector noted that the distance between an array of 48 Model 927 shipping containers filled with fuel assemblies and an array of Model CE-250-2 shipping containers filled with
. Uranium-235 containing " residuals" located in a storage trailer appeared to be less than 20 feet. Actual measurement by the licensee' indicated that the separation distance was 18.5 feet. One of the criticality safety controls posted on the storage trailer required a 20 foot spacing between the trailer and any other fuel bearing containers.
Section 4.3.19 of the NRC-approved license application states, in part, that shipping container arrays of different types shall be separated from one another by at least 20 feet. This was identified as an apparent violation of Section 4.3.19 of the NRC-approved license application (1100/89-07-02).
Prior to the end of this inspection the licensee increased the spacing between the two-arrays to about 22.5 feet by moving three Model 927 containers from the south west corner of the array. Although this deficiency was corrected during the inspection, the licensee had not established long term corrective actions to assure that there would be no repeat item in the future.
1 2.3 Nuclear Criticality Safety Evaluations on Rod Transfer Carts During examination of the " cold side" of Building 17, the inspector observed several fuel rod turret transfer carts which were parked adjacent to but perpendicular with each other.- In this configuration there was less than a 12 inch edge to edge spacing (as little as 8 inches) between uranium bearing components on the
.ca rt s.
In addition, the-inspector noted that there could be as little as two inches between uranium bearing _ components on these carts _with the uranium containing-zone'on a granite surface table
' located immediately to the west of the double doors to the pellet shop when the cart was perpendicular to the surface table. The inspector requested copies of the nuclear safety evaluations conducted to determine the safety of these configurations.
Licensee representatives stated that the individual. responsible for conducting and maintaining.this type of nuclear safety evaluations was unavailable during this inspection.
The inspector, therefore, identified this issue as an Unresolved Item (1100/89-07-03) pending return of this individual to the site and the determination of the existence of the required evaluations.
Licensee representatives stated that the fuel rod turret carts would not be stored closer than 12 inches edge-to-edge when perpendicular to each other'and that the surface table would not be used for the examination of fuel bearing components without maintaining a 12 inch edge-to edge spacing until the proper evaluations were either found or performed. This Unresolved Item will be reexamined during a subsequent inspection.
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4 3.0 Nuclear Criticality Safety Alarm Siren During an annual training session attended by the inspector, a licensee representative played a tape of the Building 17 nuclear criticality.
safety alarm siren. This siren consisted of a single frequency high 2
pitched sound which was different from the sound eminated from the Building 5 siren. The Building 5 siren consisted of a multi-frequency oscillating pitch warbling sound.
The two different sounds were verified during a test of the sirens in Buildings 5 and 17 conducted by the licensee at the request of the inspector.
The inspector questioned the licensee's use of two different sounds to designate evacuation from the similar onsite facilities for the sama type of incident.
In addition, it was noted that onsite emergency siren training provided to_ personnel assigned to both facilities consisted of providing only the Building 17 siren. As a result, the licensee was requested to reevaluate the use of two different sirens in the two facilities.
In the meantime, the licensee 1
should consider providing both siren sounds during training so that j
employees working in both buildings would be conversant with both sounds.
Followup of licensee actions on this issue was identified as an Inspector Followup Item (1100/89-07-04).
4.0 Transportation Activities The inspector reviewed licensee actions taken when a shipment of Combustion Engineering owned power reactor facility inspection equipment was received _at the Windsor site under Byproduct License No. 06-00217-06.
The shipment, from the Commonwealth Edison Zion plant was received on 1
~ Friday, November 3,1989 af ter the receiving facility was shutdown for the l
weekend.
A' cursory radiation survey conducted at the time of receipt did not indicate the presence of excessive radiation levels on the vehicle.
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During a detailed radiation survey conducted on Monday, November 6, 1989, it'was noted that the radiation _ level in the cab of a short-based yard tractor was three millirem / hour.
Since this was in excess of the two millirem / hour limit required by DOT regulations, the licensee informed the carrier, the shipper and the NRC Region 1 office.
Subsequent investi-gation by the licensee revealed that the licensee had performed the survey with a short-based yard tractor instead of the longer-based over-the-road tractor actually used to bring the shipment to the site. The licensee requested the carrier to return the over-the-road tractor to the site for i
measurements.
This was accomplished on November 15, 1989.
It was determined _at that time that there was a 16 inch differential in the wheel j
base of the two tractors.
Calculations performed by the licensee and by Commonwealth Edison personnel indicated that, on the basis of the longer wheel base, the actual radiation level in the cab of the over-the-road i
tractor should have been about 1.5 millirem / hour which is below the maximum limit and compared favorably with the 1.0 millirem / hour measured i
by Commonwealth Edison prior to the shipment leaving their site on November 2, 1989. The inspector had no further questions on this issue.
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5.0 Residual High Enriched Uranium e
During this inspection, the inspector reviewed the licensee's actions taken to characterize and cleanup uranium contamination found around the former waste storage pad located to the west of Building 2.
According to licensee representatives, cleanup activities in this area continue to be aimed at complete characterization of the area prior to the discontinu-ation of activities for the winter. Preliminary surveys indicate that the contaminated area may cover up to about 150,000 square feet located on both sides of the roadway. This area includes the paved waste storage pad and is shown in Attachment No. 1.
Radiation readings were taken by the inspector with a Ludium Model 16 Analyzer equipped.with a one inch NaI crystal.
Radiation levels in the area were noted to be up to 100 times
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. background (approximately 3000 counts per minute).
The status of this project was discussed at the exit interview with licensee representatives present. The inspector requested the licensee to provide the NRC with a status report after the project was discontinued for the winter.
This status report should contain information on.the results of the characterization study, decontamination plans and procedures, and a projected completion date. The licensee indicated that this report would be provided to the Region I office upon competion of the characterization study.
This was identified as an Inspector Followup Item (1100/89-07-05).
6.0 Review of Allegations During this inspection, the inspector examined licensee actions with regard to several allegations and concerns received by the NRC Regional l
Office.
t 6.1 Allegation ~ File Number 121-89-A-0098 6.1.1 Concern Number 1 Respiratory protection program: The licensee does not assure that personnel have received the required training and a medical physical prior to being fit-tested. Also, personnel are not retrained annually, nor do they get the annual physical required for respiratory protection requalification.
During this inspection, the inspector examined Radiation Protection Instruction RPI-216 " Respiratory Protection",
-Revision 0, dated September 20, 1989.
Although the previous revision (Revision A) did not specifically require training and a medical examination prior to fit-testing, these inadequacies were corrected in the current revision.
Personnel are currently also required to be retrained and obtain a medical
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b examination annually for requalification for the respiratory protection program.
The inspector substantiated the concerns about the licensee's respiratory protection program but F
. verified that these inadequacies had been corrected by the licensee prior to this inspection.
1 6.1.2 Concern Number 2 The General Employee Training (GET) no longer has training in respiratory protection.
The Respiratory Protection Supervisor
_i did not confirm an individual's training prior to fit-testing h
the individual. He assumed that the GET training still contained a section on respiratory protection.
The inspector determined through examination of licensee records that the GET program does not provide training in respiratory prote: tion except to provide information to employees concerning the air concentration threshold levels where respiratory protection would be required. With regard to confirmation of~an
-individual's training prior to fit-testing, licensee repre-sentatives indicated that verbal confirmation of training had been obtained since the respiratory protection procedure, RPI-216, was originally implemented in February, -1989.
- However, the revised procedure issued in September, 1989 required documentation of this confirmation prior to the fit test. The
-inspector partially substantiated these additional ~ concerns about the licensee's respiratory protection program.
- However, these inadequacies were corrected by.the licensee prior to this inspection.
6.1.3 Concern Number 3 Pellet Shop workers and supervisors still try to bypass HP procedures, RWPs and controls whenever possible. One shift supervisor continually tries-to bypass HP procedures.
This concern was substantiated during Inspection 70-1100/89-80 conducted during September, 1989.
Since that inspection, the licensee initiated work place meetings with supervisors to retrain them on_ radiation protection requirements.
In addition, the licensee has established a system to give radiation protection technicians a mechanism to escalate actions taken in order to resolve observed deficiencies. Actions taken to L-resolve those deficiencies are escalated to upper management
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t-positions and are no longer addressed at the supervisor level as was previously the case. Actions have been completed by the licensee to resolve this concern.
However, the inspector will continue to follow this issue.
6.1.4 Concern Numbers 4 and 5 Bloassay urinalysis should be performed on all Pellet. Shop Workers, but not all Pellet Shop workers are tested.- There is-i no mechanism'in place to assure that all personnel who frequent-the Pellet Shop are tested.
i Whole body counting represents a situation similar to urinalysis bioassay. A maintenance person was never whole body counted, and he is in the Pellet Shop constantly.
He asked why he wasn't whole body counted.
The inspector determined through discussions with licensee representatives that the techniques used by the licensee-to assure that personnel have had urinalysis and whole body testing were not written.
In practice, the licensee uses records of prior history (urinalysis and/or whole body counting), pellet shop entry records and discussions with the manufacturing supervisor to develop a list of personnel who must be tested.
Since there is no formal method established to determine which employees required testing, any one individual can be L
overlooked. This was discussed with licensee representatives at the exit interview.
The current method for determining which individuals must be tested will txt reviewed and revised as nece ssary.
This was identified as an Inspector Followup Item
-(1100/89-07-06).
These two concerns were substantiated, The individual who was identified during Inspection 70-1100/89-80 as not having been whole body counted was scheduled to be counted subsequent to this inspection on December 4, 1989.
Subsequent to that date, the licensee notified the inspector that this individual had been whole body counted.
6.1.5 Concern Number 6 l-Personnel do not frisk out properly from the Pellet Shop.
Hands are not washed prior to frisking, yet the friskers do not pick up the contamination.
This concern was not substantiated during Inspection 70-1100/89-80 conducted during September 1989. This concern was also examined during this inspection and, once again, the inspector did not observe any individuals who did not frisk out properly from the Pellet Shop.
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6.1.'6 Concern Number 7
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A Production Manager has never received any radiation safety training. Also, some supervisors have not attended the radiation safety training.
This item was substantiated during Inspection 70-1100/89-80 conducted in September, 1989. A Notice of Violation was issued-with-that inspection report. During this inspection, the
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inspector reviewed licensee training records and determined that each previously identified individual manager and/or supervisor had received the required radiation safety training or retraining.
This concern has been corrected.
6.1.7 Concern Number 8 v
At.the NRC's insistence, the licensee had an independent audit s
performed by Bechtel. The audit identified problems in respiratory protection, air sampling and bioassay programs.
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corrective actions were taken-in response to the findings.
Through discussions with licensee representatives, the inspector determined that the licensee had not addressed the specific
- t problems or recommendations made as a result of the independent i
audit performed by the Bechtel Corporation.
However, licensee representatives _ indicated that the generic issues raised dering this audit had been addressed. During this inspec; ion, the chairman of the independent internal audit team indicated that-a review of each specific recommendation and the actions taksn oto correct each recommendation would be completed by December 31, 1989.
This was identified as an Inspector Followup Item (1100/89-07-07).. This corcern was substantiated.
6.1.8 Concern Number 9 Combustion Engineering also performs-quarterly audits that identify problems.
But nothing is done to correct them.
This concern was substantiated.auring Inspection 70-1100/89-80.
l Since thatL time, the. licensee established a mechanism in Administrative Procedure AD-07' issued on October 28, 1989, to assure that items identified during internal monthly or quarterly audits are acted upon. This concern has been corrected. However, this concern will be reexamined during subsequent inspections to monitor the effectiveness of the i
audits.
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7.0 Exit Interview u
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-The inspector met with the licensee representatives denoted in Paragraph' 1.0 at the conclusion of-the inspection on November 30, 1989.
The
' inspector summarized the-scope and findings of the inspection.
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