ML20033H136
| ML20033H136 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/03/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Waterman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| NUDOCS 9004180267 | |
| Download: ML20033H136 (2) | |
Text
-
m APR 0 31990 Docket No. 70-1100 Combustion Engineering, Inc.
ATTN: Mr. C. R. Waterman Acting Vice President - Nuclear Fuel Nuclear Power Systems 1000 Prospect Hill' Road Windsor, Connecticut 06095-0500-
. Gentlemen:
Subject:
Inspection No.'70-1100/89-03 This refers to_your letter dated March 15, 1990, in response to our letter-dated February 14, 1990.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
]
Original Signed Byi Rccrt J. Sores Ronald R. Bellamy, Chief Facilities Radiological Safety 4
and Safeguards Branch Division of Radiation Safety a
and Safeguards cc:
A. E. Scherer, Director, Nuclear Licensing C. B. Brinkman, Manager, Washington Nuclear Operations Public Document Room (PDR) j Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of Connecticut
(
II.i 5
0FFICIAL RECORD COPY RL CE 89 0001.0.0 ~
04/02/90 9004180267 900403 i
[.'DR ADOCK 07001100 PDC
' ' e
- j --- -
.. i[?
_t
-j
+
c-a
" Combustion Engirieering,.Inc.
2
. APa p 3 yg 1
bec w/ enc 1:
Region I Docket Room (with concurrences)-
ji Management Assistant, DRMA (w/o enc 1)
.. g
~J..Roth, DRSS
. i G. B1dinger, NMSS a
g
- ?
7:
j
..y
'?
'f j.
?';;
7
- .J
,r i
- (
.t v
u u
,l 1
3 l.
1 i
j
.g 9
j l
4 lil I
1 b
]
RI:DRSS RI:DRSS RI:DRSS-Ro
-l J
y 4/ /0 04/p3/90 04/(6/90 I
OFFICIAL RECORD COPY RL CE 89 0002.0.0-04/02/90 Y
iI t
I
- i
. i. a.~..
'I
.r e
L March lb, 1990 l-LD-90-024 nm i
i 1
Docket No. 70-1100 License'No. SNM-1067 i
Dr. Malcolm R.,
Knapp, Director' Division of Radiation. Safety and Safeguards i
U.S.. Nuclear. Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
'I subject:
Response to Notice of Violatic.n (Inspection Report No. 70-1100/89-03)
"deferences:
(A)
Letter LD-89-083, A. E. Scherer (C-E), to R. R. Bellamy (NRC), dated July 28, 1989 (B)
Letter, R. R. Bellamy (NRC), to P. L. McGill (C-E), dated-June 30, 1989 7
(C)
Letter, M. R. Knapp (NRC) to j
C.. R. Waterman (C-E), dated, February 14, 1990 1
Dear Dr. Knapp:
In Combustion Engineering's' letter of July'28, 1989, Reference (A), we responded to a Nuclear Regulatory Commission Notice of Violation transmitted via Reference (B).
Your letter of February 14,~1990,
?
Reference (C), responded to Combustion Engineeriny's contention that we had acted appropriately regarding the bioassay evaluations conducted and believed..that we-were t
4 not in violation of 10 CFR 20.103 (a) (3) requirements.
Further, you requested that combustion Engineerin provide additional information concerning.the.sub ect i
violation and the action'we had taken.
The Enclosure responds to your request.
In essence, while Combustion Engineering continues to believe that we acted prudently and in a conservative manner concerning the evaluation of biuassay results, we have, nevertheless instituted a procedure to address the concerns expressed by the Nuclear Regulatory Commission.
t Nuclear Power Businesses 1000 Prospect Hill Road (203) 285 5200 Combustion Engineenng, Inc.
Post Office Box 500 Windsor, Connecticut 06095 0500
!Y h
F.
- b.,.,
Dr. Malcolm R. Knapp LD-90-024
]
March 15, 1990 Page 2 i
If I can be of further assistance on this. matter, please.do not hesitate to call me or Mr. J.
F. Conant of my staff at (203) 285-5002.
Very truly yours, COMBUSTION ENGINEERING,.INC.
A A.
-scherer Director Nuclear Licensing
(
AES:jeb cc:
G. Bidinger (NRC)
J. Roth (NRC - Region I) i
~
I Y
t
t:...
4 ii r-Enclosure to LD-90-024 i
I 4
i l
i l
D'RPN8tE TO NOTICE OF VIDIATION
l l
l i
?
4 I
l g
'I i
I l
l J
l 1
i 1
l 4
l
\\
l
SUPPTFMPMTAT DRRPnueE TO NCrilCE OF VIOLaPION A complete statement of the violation and Combustion ~
Engineering's original response is attached for your information.'
Combustion Engineering ~hereby supplements its 1
, response with the following:
-The two individuals involved in the subject violation were in-vivo counted in June, 1989.
The specific results were -
-43 1 43 and 54 1 37 micrograms U-235-as compared to 0 1 43
?
and 0 45 micrograms.U-235, res prior-in-vivo counting (December,pectively, from their
.1988).
These results indicate.that neither individual exhibited any evidence of' an acute intake of radioactive material.
1989 in-vivo counts are well below facility action levelsBoth of the June, and Regulatory limits.
We believe'that the in-vivo results confirm the conclusions drawn by combustion Engineering.
based on the bioassay data evaluation performed at the time the incident occurred.
In your letter you also indicated.that combustion Engineering had exceeded its go/no-go action level for determining the need ior further bioassay evaluations since we had not accounted for alpha activity' contributed by i
other significant uranium isotopes in our enrichment mixture.
While it.is correct to state-that combustion Engineering did not use alpha activity contributed by other significant isotopes of uranium the go/no-go criterion used at the time was based on ac, tion levels specified in.
the facility license which were based solely on'U-235.
such, not measuring the contribution of other significantAs isotopes of uranium was not material to the decision process.
Because the decision regarding.the need for further bioassay evaluation was, in' fact, made:on a i
consistent uranium isotope basis, we believe that our evaluation of bioassay results was both prudent and conservative.
l Nevertheless, the ambiguity resulting from this incident has pointed to a need to clarify our Radiological Protection Instructions.
To this end, combustion documents to ensure that fecal analysis takes intoEngineering has I
consideration other.cignificant isotopes of uranium when used for making an assignment of intake from acute exposure.
We believe that this action should resolve the Nuclear Regulatory Commission's concern in this matter.
l i
.a Response to Noti'e of Violation c
(NRC inspection Report No. 70-1100/89-03)
Statement of Violation 10 CFR 20.201 " Surveys" states in part replations in this part, "surv,ey* means, that (a) As used in the raaintion hazards incident to the production, use release an evaluation of the disposal, or presance.of radioactive materials or,other sou,rces of radiation under a specific set of conditions.
appropriate, such evaluation includes a physical survey of the When location of materials and equipment, and measuraments of levels of radiation or concentration's of radioactive material present.
(1) may be necessary for'the licenses to comply with the(b) as regulations in this part.
i contrary to the above, between February 19896 27, 1989 and May 28, an adequate evaluation of bionssay results required by 10 CFR 20.103 regulations (a)(3) was not conducted to assure compliance with the in this part.
samples from two individuals agosed to radioactive materials onSpec February 27 1989.during removal cf a contaminated sheet of plastic from, the FA-1 ventilation system mezzanine floor were not adequately evaluated to determine compliance with 10 CFR 20.103 (a) (3).
'a Rennense Combustion Engineering has reviewed the records and acti with respect to two workers who had abnormally high lapel air ons taken sampler activities.
Combustion Engineering believes that the actions taken and the evaluations performed were in full g
', compliance with the requirements specified'i 20.103 (a) (3).
n 10 CFR 20 201 and combustion Engineering balisves that adequate surveys of the work i
area were conducted and that, based on these surveys, both individuals were assigned lapel air samplers while working i curveyed area.
n the combustion Engineering further be'lieves that ossigning intakes to both of these individuals based on the lapel air sampler activities complies with the requirements of 10 CFR 20.103 (a) (3).
Both our air sampling and bionssay programs 4
uso guidanna provid 6 in NASN-1281, APPLICATIONS OF BIDASSAY FOR t
17RANIUM, dated June 1974.
^
WASH-1251, Section IV-1.1, states in j
part, "if an air sampler is located such that airborne l
contamination, enroute from the source to the workers breathing zone, must pass by the sample head, the probs.bility of missing an**
intake is considerind to be too low to justify the additional bionssays.
The additional bioassays are not performed for a specific individual if the licensee can demonstrate that the air i
sampling system used to protect the individual is adequate to detect any significant intake."
Combustion Engineering believes that when a 3apel air sampler is use$. for determining the intake of radioactivity that all of the above conditions are met.
l Eased on the circumstances surrounding the higher than normal 4
lapel air sampler activities, combustion Engineering feels that using the activity readings from the lapel air samplers for calculating MPC hours and using that value in the seven day running total for intake was conservative and meets all regulatory requir'inents.
Based on the seven day running total i
MPC hours, the Manager of Radiological Protection and Industrial i
safety removed both individuals from the Pellet shop until l
further evaluations could be completed.
Our procedure, RPI-204, Bionssay Program, requires special bionssays when 40 MPC hours is
- cxceeded, since both individuals were involved in whatever occurred causing the above normal air samplar readings, both i
( individuals were requested to give urine and focal samples based caly on one individual's seven consecutive day total intake exceeding 40 MPC hours.
The purpose for taking the bioassay samples was based on guidance provided by an outside consultant.
This consultant provided the fc11 ewing guidance in determining the need for considerirg a change in work assignments:
a.
In-vivo lung counting greater than 175 micrograms' l
U235.
i
\\
s.
+
---ege-g-
w-w
-y wsm--
vw-my
- suie, mae-w a*
-w-e-
- we1+-8-*--
_)
-)
4
_b.
Urine bioassays greater than 141' dpa U/1 (sum of U234, U235 and U238).
o.
Faces bioassays s
greater than 55 dpa U235 excreted per day, this being obtained by multiplying the dpa U235 per gram wet weight by the total vet weight per sasiple.
This assumes the total sanple represents one days focal
- loss, sewever. avan if the laval er as d a nass j
exerated nar dav la~aveanded.
~
j Y den t rac- ---- =na a e
censideration af channa in werk maalaw-ant untaan thm l
-in-vive luna and urinary l
binassaw resulta avened the Invals in a and b mheva.
)
The Manager of Radiological Protection and Industrial Safety provided the bicassay results to the Program Manager, Radiological and Industrial Safety for his' evaluation
[
determination as to whethar or not these two individua
, to make a allowed to go back to work in an area with airborne I
contamination.
INe Program Manager, based on the urinalysis results for both individuals being 0'and focal U235 levels being considerably less than 55 dpa for.both individuals, made a deter-j mination that both individuals could be' returned to noraal, i
unrestricted duty.
)
TheactionlevelsrecommNndedbyourconsultantandusedin kbicassayprogramandRPI'sarebasedonchronicintakesan r
our i;
therefore, are consideied conservative when used for acute Artakas.
~
Dased on the conservatism of these action levels a simple 92/no-go decision was deemed appropriate.
Combustion Engineering believes that the actions of re individuals within our organisation were appropriate and were sponsible 3
based on guidance provided in WASH-1251, Regulatory Guide 8 n JfDREG/CR-4884, and ICRP-30.
Nevertheless, as part of ongoing 4
j e
T ?
~1 2
~
4 efforts and to further assure that in the future proper action concerning bioassays are conducted i.n an officiant manner s
individuals responsible for taking and/or evaluating bioas information will have their individual responsibilites cl say We believe that this action will preclude any confusioarified.
have axisted and which could potentially result in delays in n which saf properly processing bionssays.
(
h r
eo.
s 4
i 4
.....,,