ML20034B952
| ML20034B952 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/18/1990 |
| From: | Austin M, Bores R, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20034B945 | List: |
| References | |
| 70-1100-90-03, 70-1100-90-3, NUDOCS 9005010209 | |
| Download: ML20034B952 (10) | |
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V. S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
70-1100/90-03 Docket No.
70-1100 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:
February 26 - March 2, 1990 Inspectors:
/d 90 M. A. Austin, Ra'diation Specialist, Effluents
/ date/
Radiation Protection Section (ERPS), Facilities Radiological Safety and Safeguards (FRSSB),
Division of Radiation Safety and Safeguards (DRSS) 5 AX:
W 2
P. V. O'Connell,~ Radiation Specialist, date
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Facilities Radiation Protection Section (FRPS), FRSSB, DRSS
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(ot(&h Y-/f-7O Approved by e
7 R. J. Bores, Chief, Ef fluents Radiation date
^ Protection Section, FRSSB, DRSS W
YI 90 i
W. J. PasciakT Chief, Facilities Radiation date G70v Protection Section, FRSSB, DRSS l
0005010209 900420 DR ADOCK 0700 0
Inspection Summary:
Inspection on February 26-March 2,1990 (Report _ No.
70-1100/90-03)
Areas Inspected:
Routine, unannounced inspection by two region-based inspectors of the licensed program including reviews of external dosimetry, training, internal audits, ventilation requirements, facility air and stack sampling, and contamination surveys.
Results: Six violations and one unresolved item were identified. Violations:
three instances of failure to evaluate radiation hazards (Section 2.1.2); failure to issue termination exposure reports to the NRC and individuals (Section 2.2);
failure to issue the proper d0simeter to certain individuals in accordtnce with internal procedures (Section 2.3); failure to train radiatio" protection technicians (Section 3.0); failure to perform quarterly verification of stick air sampling techniques (Section 5.0); and, failure to perform yearly evaluation of the representativeness of fixed position air sampling stations (Section 6.0).
The unresolved item involves the determination of an appropriate beta radiation correction factor to apply to exposure records for exposures prior to December 1989 (Section 2.1.2).
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DETAILS 1.0 Individuals Contacted
- C Waterman, Acting Vice President - Nuclear Fuel
- P. Hubert, Manager, Manufacturing Engineering
- P. Rosenthal, Program Manager, Radiological and Industrial Safety
- W. Bennett, Manager, Training
- C. Molnar, Nuclear Material Licensing Specialist
- E. Scherer, Director, Nuclear Licensing J. Vo11aro, Supervisor, Radiological and Industrial Safety S. Kucavich, Lead Radiation Protection Technician K. Hayes, Industrial Safety Specialist
- Denotes those present at the exit interview.
The inspectors also interviewed other licensee employees during the inspection.
2.0 External Dosimetry 2.1 Previously Identified Concerns During a previous NRC Inspection two concerns were identified regarding the manner in which the licensee was monitoring exposures to workers' extremities and skin (70-1100/89-80-03).
These two concerns were as follows:
2.1.1 The first concern addressed the need for the licensee to conduct a study to determine whether extremity monitoring was required for workers. The licensee has completed the study to determine whether extremity monitoring should be required for certain workers, specifically, those workers involved in the stacking and loading of fuel pellets.
The results of this study indicated that these workers were not likely to receive an exposure to the extremities in excess of 25% of the limit specified in 10 CFR 20.101 (4.7 rem per quarter) and, therefore, extremity monitoring was'not required.
2.1.2 The second concern involved licensee's practice of accepting the dosimetry vendor's reported shallow dose exposure values without applying a correction for beta energy and without applying a correction factor to account for the potentially higher dose rate received by the skin of the face compared to that of the Thermoluminescent Dosimeter (TLD) which is worn under protective clothing (PCs).
In September 1989, the dosimetry vendor (Teledyne Isotopes, Incorporated) completed a study to determine the correction factor to be used in conjunction with the TLD reported exposures of
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4 shallow dose, i.e., dose to the ~ skin. Base'd-partially on tha results of this study the licensee determined that the con ection factor should be 2.12 and issued PR-6,_" External Exposure Control l
Program", dated December 14,-1989.. That document requires that a beta correction factor of 2.12 be applied to the vendor's reported shallow dose exposure values resulting from analysis of the TLDs1 used at the Nuclear Fuel Manufacturing (NFM) facility. As a' result, the-licensee started to apply this beta correction factor _
to the vendor supplied data beginning with the December 1989:
i exposure reports. However, at the time of this inspection, the licensee had not evaluated previous-exposures:which had not-included this correction factor.in the determination.
The licensee stated that they did not know if the dosimetry vendor had changed-the specifications for the TLDs and if they had,'.whether that' would change the correction-factor.
The licensee's determination 1
of an appropriate correction factor, based on the_ energy response of the TLD, to apply to personnel exposures prior to December 1989
-remains unresolved (70-1100/90-03.-01).
In addition, at the time of the inspection, the licensee had. not determined whether an additional correction: factor was needed to account for a potentially higher' dose rate received by the skin of the face compared to that measured by the TLD which was routinely worn unJer the PCs.
Shortly after Inspection' 70-1100/89_-80, 7
conducted during September 1989,1the licensen took four reedings with an open window ion chamber.
Two of the readings were taken' with the window of.the ion chamber covered with a single set of PCs. The beta readings _of the' ion chamber covered with the PCs
- i were from 23% to 43%' lower than the
- uncovered ion chamber readings.
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The licensee stated that, although this preliminary study indicated that personnel exposures to the exposed skin of the. face could-be 23 percent to 43 percen_t' higher then that. recorded by the.
TLD, which.is worn beneath.the PCs, they did not have the time-t i
or the resources to evaluate the adequacy,of their monitoring technique to assess the potentially higher dose'toLthe skin of the face.
In addition, the inspector reviewed survey-records of-various areas of the nuclear fuel manufacturing-(NFM) facility, including the stack and load area, and noted that radiation surveys did not routinely include beta dose rates.
The inspector discussed
,i this with several Radiation Protection Technicians (RPTs) and j
the Radiation Protection Supervisor, The RPTs and the RP~Suoervisor i
stated that, as part of their routine surveys, they take'open Q
window ton chamber. dose rate measurements..However, they do not
'i apply the beta correction factor for the survey instrument to determine the beta dose rates in the. areas-where. individuals' 7
work. However, the inspector determined that when each survey instrument is calibrated, a beta correction factor typically ranging from 3.7 to 4.0 is determined for each instrument.
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5 Based on that beta correction factor it appeared that the methods used by the licensee to conduct radiation surveys have underestimated beta dose rates by up to a factor of four.
As a result, the inspector noted that survey results which included open and closed window ion chamber readings, for a survey conducted by the licensee during September, 1989, indicated that the average generai area beta dose rate may be such that a worker in tM r>
area could receive occupational exposures in excess of 10 CFR 20.101 limits.
Failure of the licensee to evaluate the adequacy of the measuremerts of the beta dose to the skin of the face as determined from TLDs worn beneath the PCs and failure of the 1fcensee to conduct beta surveys of the stack and load area of the Pellet Shop are examples of an apparent violation of 10 CFR 20.201(b) wi,4ch requires, in part, that each licensee shall make or cause to be sade such surveys as may be necessary for the licensee to compl3 vith the regulations in this part (70-1100/90-03-02).
In addition to the above deficiencies, the inspector also noted that the licensee's dosimetry processor records whole body exposures as measured through 1000 mg/cm2 of ab3orber, 10 CFR 20.401, requires that each licensee maintain records of the radiation exposures in accordance with the instructions contained on Form NRC-5.
The instructions on Form NRC-5 require that when whole body exposures are measured through 1000 mg/cm2, the lenses of the eyes are to be shielded with an absorber at least 700 mg/cm2 thick. The inspector observed that the workers in the Pellet St.op were wearing ANSI Z87 approved safety glasses.
Th7se glasses typically provide only from 300 to 350 mg/cm2 of absorber.
In addition, a licensee representative stated that the adequacy the safety glasses to ensure compliance with the whole body exposure (in this case exposure to the lenses of the eyes) limits of 10 CFR 20.101 had not been evaluated.
This is another example of an apparent violation of 10 CFR 20.201(b) which requires, in part, that each licensee shall.make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in this part.(70-1100/90-03-02).
2.2 Dosimetry Records The inspector reviewed the licensee's records of cersonnel exposures, During this review, the inspector noted that as of March 1,1990, exposure records for seven individuals who terminated employment between November 17 and 20, 1989, had not been furnished to the Director, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555.
This is an apparent violation of 10 CFR 20.408(b) which requires that when an individual terminates employment with a licensee, the licensee shall furnish to the Director, Office of Nuclear w
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6' 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 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 assignuent, whichever is earlier (70-1100/90-03-03).
In addition, the inspector noted that' termination. reports had not been-sent to the individuals; who terminated employment-between November 17 and 20, 1989. This is an apparent violation of 10 CFR 20.409(b) which requires,Jin 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.
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Such notice shall be transmitted at a time no later than the transmittal.
to the Commission.(70-1100/90-03-03).
The inspector noted at the time of the inspection 'that one RPT was-
-I assigned the task of maintaining these-records and compiling termination report data whenever time was available. The inspector also noted that 30 individuals had terminated employment in December 1989.
Based on discussions with cognizant personnel and review of exposure records,'
it appeared that, unless the licensee devotes' additional resources to the task of compiling and maintaining exposure-records, the licensee will have difficulty in issuing termination reports to these individuals within the required time frame, a maximum of 90 days. As of the end of this inspection, 60 days had already lepsed and work on most of these termination reports had not been initiated.
Lj 2.3 Issuance of Dosimetry The licensee uses a contractor to process the thermoluminescent dosimeters (TLDs) used for personnel monitoring. The' inspector.. verified that the licensee utilized a contractor that maintains. current' National Voluntary Laboratory Accreditation Program (NVLAP) accreditation for the types of TLDs used. The licensee issues two different types of.
TLDs to individuals: " normal" dosimeters which monitor. beta and gamma exposures; and "special" dosimeters which monitor beta, gamma and neutron exposures.
The Program Document PR-6, " External Exposure control Program" establishes the criteria for the licensee's program to assure appropriate monitoring of external exposures. _ The inspector determined -that the RPTs working in the Pellet. Shop had been issued
" normal" dosimeters. However, Radiological Protection Instruction i
(RPI) 205, " Dosimetry Program", dated December 12, 1988, which is the.
implementing procedure for the " External Exposure Control Program" requires, in Section 7.1.2 that RPTs be issued "special" dosimeters L
containing beta, gamma,.and neutron monitoring TLD chips.
The inspector H
discussed this matter with both the Radiological Protection Supervisor and the Program Manager, Radiological and Industrial Safety.
The i
Radiological Protection Supervisor stated that the discrepancy was-
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caused by the' incorrect type of TLDs being ordered for the RPTs.
Thef Program Manager, Radiological and _ Industrial Safety stated th' t the.
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't Program Document, PR-6, does not require the RPT to wear the special dosimetry.
The inspector reviewed Program Document,.PR-6, and notedm that the Program Document does not address what type of workers are_
required to wear "special" dosimetry.
Failure to issue "special" l
dosimetry to the RPTs was identified as an apparent vi61ation of Section -
2.6 of the NRC-approved license appl.ication which requires routine Nuclear Fuel Manufacturing Facility and Product Development Laboratory operations be conducted'in accordance with written p,rocedures.. In this case, the implementing written procedure for the dosimetry' program war found.to be RPI-205 as indicated above-(70-1100/90-03-04)..
1 3.0 Traiaing 2
In NRC Inspection Report 70-1100/89-80 the-licensee's three part formal training program for the radiological protection staff was described. ;At-a the time-of that inspection the RPTs were working to complete the first part of the training program, which was ~a self study course.
The status of training of the RP Technicians was determined through discussions with RPTs and cognizant supervisors'and by:reviewin_q RPT training records during this inspection. The inspector noted that the training program discussed above had been terminated approx 1:mately two months after it began, therefore, the licensee no longer has a training program in place for the RPTs.
Discussions with several RPTs regarding various aspects of i
the RP duties indicated that additional training was needed.
For example,
.some of the RPTs did not know bcw to conduct beta surveys, how to properly.
document survey results, or how-to calculate MPC-hour exposures.
Section 2.1.1 " Plant Manager" of the NRC-approved-license-application states, in part, that the Plant Manager, Windsor Nuclear Fuel Manufacturing, has the overall responsibility for the safe operation of Combustion Engineering's o
nuclear fuel manufacturing facility located in ~ Windsor, Connecticut -(SNM-1067).
His or her responsibilities encompass the training function.as specified in Section 2.1.10 of the license application, " Radiological Protection and Industrial Safety Technicians," which states that the technicians are responsible for the day-to-day monitoring of operations at the fuel manufacturing facility and'the product development laboratories Monitoring
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is accomplished through the. collection of-data which allows the effectiveness 4
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.
The~ plant manager
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did not assure that the Radiation Protection and Industrial Safety 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 since the Radiation Protection and Industrial Safety technician training program was terminated approximately two months after the program began.
Failure to maintain a training program for~the RPTs was identified as an apparent violation of license conditions (70-1100/90-03-05).
8 4.0 Mdits The inspector reviewed the " Health Physics Program Appraisal Report",
which was completed for the licensee in December.1988 by a contractor (Bechtel Corporation). During the contractor's audit, many of the same weaknesses ~which are described-in-this inspection. report were identified.
Examples included failure of:the licensee to identify portions of the-faci 1Yty where special monitoring may be required, failure to determine radiation exposure to the skin, failure of the licensee to conduct: adequate-dose rate surveys, failure to assess the need for measuring _ the radiation exposure to lenses of the of workers' eyes, and failure to make needed upgrades in the doe etry recordkeeping system.- In general, the inspector-m determined that the licensee was not responsive to the contractor's audit findings.
5.0 Ventilation and Stack Sampling fnspector reviewed the ventilation systems used by the licensee to' provide a negative pressure differential between the Pellet Shop and all
-i surrounding work areas.
The inspector observed that the licensee performed weekly checks of the air flow direction, which was more frequent than the monthly chect ~ qui ed by the facility license. The inspector verified j
that the pre drop for-.all of the separate exhaust-systems in Building a:
- 17 was chec. > mekly and documented.
The inspector. reviewed records of the weekly chcas of face velocit'ies at ventilated hoods, and determined that a minimum velocity of 100 linear feet per minute was being maintained, a
'The inspector reviewed the method used by the licensee to' assess and. record-l the amount of gross alpha uranium activity in plant gaseous' effluents.-
l The licensee imposed a quarterly -limit of 10 microcuries which is less l
than 60% of the quarterly limit (18 microcuries) imposed by the facility; i
license.
Records show that the gaseous effluents were far below this limit, and the inspector observed that the system was well maintained by the l
licensee.
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The inspector asked how the licensee' tested-the adequacy of the stack sampling j
techniques.
Licensee-representatives. stated that this. test was not routinely performed, and that it was last accomplished on June 7, 1988. 'Section 3.2.3 of the NRC-approved license. application: states that the adequacy of-the sampling techniques to obtain representative samples will be verified quarterly.
Failure to perform a quarterly verification of the adequacy of' l
stack sampling was identified as an apparent violation of a license requirement (70-1100/90-03-06).
6.0 Air Sampling The inspector reviewed the methods used by the licensee to sample airborne, l
contamination for the evaluation of internal exposure. The inspector observed licensee practices and compared them to the license requirements and to
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.e 9-l the procedural requirements of the pertinent Radiation. Protection Instructions (RPIs).- The inspector noted that the-terminology for air l samplers', as used in 2he facility license, in the RPIs and by the technicians, was not consistent. This could cause confusion over air sampling requirements.:
The inspector also noted that there were some minor inconsistencies between.
RPI requirements and actual practice.
For example, RPI-207 states that workers are kept out-of the contaminated work area when their_ lapel air sampler unit malfunctions until their exposure is evaluated by the Supervisor of Radiological and Industrial Safety, whereas _in practice, the workers-are simply given a replacement unit and sent back to the work area.
Licensee representatives acknowledged the inspector's comments and indicated that actions would be taken to reevaluate and revise the procedure, as appropriate.
The inspector observed that.the license'e uses permanently mounted air-samplers, which it labelsias " station pumps", to collect data used to calculate internal ~ exposures for persons who enter the~ Pellet' Shop but who do not work directly with the unclad fuel. The inspector reviewed RPI-214. " Monitoring for Airborne-Contamination", which describes'the licensee's method for' collecting data from the " station pumps" and l
assigning internal exposures to individuals.
The inspector examined i
licensee records of " station pumps" air sampling data and the data entry forms used to calculate and assign internal exposures to' individuals who 3
enter the Pellet Shop without personal lapel air sampling ' devices. The i
inspector noted that, at the time of' the. inspection, the number of " station
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pumps" had been decreased from 24 to 21 because of the current project of equipment removal and deployment to Hematite.. The inspector.found that-the recordkeeping system maintained by the licensee was consistent with the method described in RPI-214 to assign individual internal exposure calculated from " station pumps" data. As described in RPI-214, these_
" station pumps" are intended to " monitor the airborne radioactive material concentration associated-with a specific task at a specific location".
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 l
concentration levels, the licensee shall evaluate its representativeness, at least once every 12 months and whenever any licensed process equipment change is made." The inspector requested the records of_the evaluations done to demonstrate the representativeness of the' data collected _from the
" station pumps" that were being used for individual internal exposure 1
assignments. The licensee representative stated that such evaluations Were not routinely done and could not determine when the most recent evaluation was done but indicated that it had been done more than 12 months ago.
Failure to conduct this evaluation at least once every 12 months was identified as an apparent violation of a license condition (70-1100/90-03-07).
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4 10 7.0 Centamination Surveys 1
The inspector reviewed the licensee's procedures and practices implemented for the control of clean area surface alpha contamination. The inspector.
1 reviewed selected records and determined that the' lunch room was. surveyed daily, as required by the-license, and that it was promptly cleaned when l-contamination levels exceeded 10 disintegrations per minute _(dpm)/100 cm2-
- l The records also showed that other " clean areas" of the plant were surveyed monthly for removable and' fixed alpha contamination.- The licensee utilized personnel' assigned to "decon crews" to clean up any_ contamination in excess 1
of action levels. The inspector observed the licensee had implemented an effective program for facility clean area contamination control.
No; violations or deviations were noted.
8.0 Exit Interview 4
The inspectors met with the licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection on March 2, 1990. The inspectors summarized the scope and findings of the inspection.
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