ML20034B947
| ML20034B947 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/20/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034B945 | List: |
| References | |
| 70-1100-90-03, 70-1100-90-3, NUDOCS 9005010204 | |
| Download: ML20034B947 (4) | |
Text
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APPENDIX A NOTICE OF VIOLATION I
Combustion Engineering, Inc.
Docket No.
70-1100 Windsor, Connecticut License No. SNM-1067 During an inspection conducted on February 26-March 2, 1990, violations of NRC requirements were identified.
In accordance with'the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy, 1988), the violations are set forth below.
A.
10 CFR 20.201 (b) requires, in part, that each lictnsee #"
make or cause to be made such surveys as (1) may be necessary ter G e licensee to comply with the regulations in this part and (2) are reasonable under the i
circumstances to evaluate the extent of radiation hazards that may be present.
10 CFR 20.101(a) requires, in part, that no licensee shall possess, use or transfer licensed material in such a manner as to cause any individual in a restricted area to receive in any period of one calendar quarter from radioactive material and other sources of radiation i
a total occupational dose in excess of 1.25 rems per calendar quarter to the whole body which includes the lens of the eyes and/or 7.5 rems per calendar quarter to the skin of the whole body.
10 CFR 20.101(b)(1) allows the licensee to permit an individual in a restricted area to receive a total occupational dose to the whole body not to exceed 3.0 rems per calendar quarter.
l Contrary to the above, between September, 1989 and February, 1990, the licensee did not complete evaluations to:
^
1.
Show that adequate surveys were conducted in the Pellet Shop stack l
and load area to prove compliance with the dose limits _of 10_CFR 20.101(a) and (b);
2.
Determine the adequacy of beta dose measurements to the skin of the whole body, in this case, the face, and;-
3.
Determine the adequacy of beta shielding of safety glasses used in i
the Pellet Shop to ensure compliance with whole body dose limits specified in 10 CFR 20.101(a) or (b).
i This is a Severity Level IV Violation (Supplement IV.0).
B.
10 CFR 20.408 requires, in part, that "when an individual terminates i
employment with a licensee, the licensee shall furnish to the Director, t
l Office of Nuclear Regulatory Research, U. S. Nuclear Regulatory.
Commission, Washington, D. C. 20555, a report of the individual's exposures to radiation and radioactive material.
Such reports shall be OFFICIAL RECORD COPY IR CE 90 0004.0.0 04/04/90 dbbbk hhkfoo PDC
APPENDIX A 2
furnished within 30 days after the exposure of the individual has been determined by the licensee or 90 days after.the date of termination of employment or work assignment, whichever is earlier." In addition, 10 CFR 20.409(b) requires, in part, that "when a licensee is required pursuant to 20.405 or 20.408 to report to the Commission any exposure of an individual to radiation or radioactive material, the licensee shall also notify the individual. Such notice shall be transmitted at a time not later than the transmittal to the Commission."
Contrary to the above, as of March 1,1990, exposure records for seven individuals who had terminated employment between November 17 and 20, 1989 had not been furnished to the Director or the individuals as required.
This is a Severity Level IV Violation (Supplement IV.D).
C.
Section 2,13 of the NRC-approved License No SNM-1067 license application (Part 1 - Criteria) states, in part, that the Program Manager, Radiological and Industrial Safety, is responsible for defining the radiological protection program. This program addresses the safety criteria and procedurris necessary to ensure the protection of employees.
Section 2.1.5 states, in part, that the Manager, Radiological Protection and Industrial Safety, is responsible for implementing the program defined by the Program Manager and reviews and approves safety related operating procedures.
Section 2.6 states that Nuclear Fuel Manufacturing Facility and Product Development Laboratory operations which involve licensed materials shall be cunducted in accordance with written procedures. Section 7.1.2 of Radiological Protection Instruction RPI-205, " Dosimetry Program", which involves licensed materials, is a safety-related procedure and was written to implement Program Document PR-6 that requires "special" dosimeters capable of monitoring beta, gamma-and neutrons be issued to Radiation Protection Technicians.,
Contrary to the above, as of February 27,1990, "special" dosimeters capable of monitoring beta, gamma and neutrons had not been issued to the Radiation Protection Technicians working in the Nuclear Fuel Manufacturing facility.
This is a Severity Level IV Violation (Supplement IV.D).
D.
Section 3.2.3 of the NRC-approved License No. SNM-1067 license application (Part 1 - Criteria) states, in part, that the adequacy of the (stack exhaust air) sampling techniques to obtain representative sanples will be verified quarterly in the Manufacturing Facility.
I 0FFICIAL RECORD CCPY IR CE 90 0004.1.0 04/04/90
APPENDIX A 3
Contrary to the above, between June,1988 and February 27, 1990, the adequacy of the stack exhaust air sampling techniques to obtain representative samples was not verified quarterly in the Manufacturing Facility.
I This is a Severity Level IV Violation (Supplement VI.0).
E.
Condition 14 of NRC License No. SNM-1067 requires, in part:
"If permanently mounted air sampling equipment is used to determine the breathing zone air concentration levels, the itcensee shall evaluate.its representativeness at least once every 12 months and whenever any licensed process equipment change is made."
i Contrary to the above, permanently mounted air sampling equipment, which was used to determine breathing zone air concentration levels, had not been evaluated between January 1, 1989 and March 2, 1990.
In addition, many licensed process and equipment changes have been made since January.
1, 1990 when redeployment of processing equipment from the W'odsor Fuel i
Manufacturing facility to the Hematite Missouri. Fuel Manufacturing facility i
started and none of the fixed location breathing zone air sampling stations were reevaluated.
This is a Severity Level TV Violation (Supplement.VI.0).
I F.
Section 2.1.1 of the NRC-approved License No. SNM-1067 license application (Part 1 Criteria) states, in part, that the Plant Manager, Windsor Nuclear Fuel Manufacturing has the overall responsibility for the safe operation I
of Combustion.Enginearing's nuclear fuel manufacturing facility.
His or 1
her responsibilities include ensuring adequate training of the staff.
Section 2.1.20 states that the Technicians are responsible for the day-to-day monitoring of q.p+,Sns at the Fuel Manufacturing Facility and the Product l
Devt. +;.e.s Laboratories. Monitoring is accomplished through the collection of data ynich allows the effectiveness of radiological, criticality and industrial safety, environmental protection and emergency planning programs to be assessed. Technicians also monitor the proper implementation of Radiation Work Permits.
Section 2.2.10 states that the Technicians shall also complete a facility specific training program (s) in safety-related areas within their area (s) of cognizance.
Contrary.to the above, the Radiation Protection and Industrial Safety Technician training program that was developed to ensure proper training of these technicians was terminated approximately two months after the program began, the Technicians did not complete a facility specific training program, and the Plant Manager did not ensure that the technicians were adequately trained to fulfill their responsibilities to monitor operations at the fuel manufacturing facility and to monitor the proper implementation of Radiation Work Permits.
This is a Severity Level IV Violation (Supplement VI.D).
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APPENDIX A 4
Pursuant to the provisions of 10 CFR 2.201, Combustion Engineering, Incorporated is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending this response time.
OFFICIAL RECORD COPY IR CE 90 0006.0.0 04/04/90
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