ML20042D826
| ML20042D826 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/23/1990 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CWM:90:046, CWM:90:46, NUDOCS 9004100153 | |
| Download: ML20042D826 (3) | |
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ADM6NCED NUCLEARFUELS CORPORATD4 nravurony coeumut r,ta mm wu nau oclos v memma u w,1n,w (M'm 5766'IC titia sb n !9 i
March 23,1990 l
CWM:90:046 I
f U.S. Nuclear Regulatory Commission Attn: Document Control Desk l
Mall Stop P137 i
Washington, DC 20555 i
Ucense No, SNM 1277 Docket No. 70125r t
Gentlemen:
REPLY TO A NOTICE OF VIOLATION This is in reply to a Notice of Violation which accompanied Inspect Report No. 70-1257/90-01 transmitted from Region V by letter dated March 2,1990, The violation as listed in the notice is reproduced below:
6
- 10 CFR Part 20 states under
- Precautionary Procedures" in Section 20.201(b) r
- Each licensee shall make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in this part, and (2) are j
reasonable under the circumstances to evaluate the extent of radiation hazards that may be present".
j 10 CFR 20.103(a)3 requires, in part, the use of measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any l
combinations of such measurements to determine compliance with the requirements of 10 CFR 20.103,10 CFR 20,103(a)2 requires, in part, that no t
licensee shall possess, use, or transfer mixtures of U 234, U 235 and U 238 in i
soluble form in such a manor as to permit any individual in a restricted area to inhale a quantity of such material in excess of the intake limits specified in Appendix B, Table I, Column 1 and footnote 4 thereto. Footnote 4 to Appendix l
B, states, in part, that for soluble mixtures of U 238, U 234 and U 235 in air chemical toxicity may be the limiting factor, if the percent by weight of U 235 is less than 5, the concentration value for a 40-hour work week is 0.2 milligrams j
uranium per cubic meter (mg U/m') of air. Using a standard breathing rate of 20 liters per minute,0.2mg/m' corresponds to an intake limit of 9.6 mg uranium per 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> work week, i
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Document Controf Desk CWM:90.046 o
March 231990 Page 2 Contrary to the above, prior to February 9,1990, the licensee did not conduct adequate evaluations of positive bloassay sample results obtained from several individuals during the period of January 4,19B8, through January 3,1989 as required in 10 CFR 20.103(a)(2) to demonstrate compliance with the applicable reporting requirements in 10 CFR 20.405 This is a Severity Level IV violation (Supplement IV)'
Advanced Nuclear Fucis Corporation's (ANF) tesponse to the violation noted above is outlined below:
The ANF procedures, both in the License ar'd Standards, address investigstions for overexposure due to radiation but do not specifically address approach to chemical toxicity limits. Our review Indicates that these same procedures have been in effect for the past ten years and probably the life of the plant. Radiological Salcty personnel were aware of the potential for chemical toxicity levels to be exceeded with soluble uranium compounds but assumed that the License action levels were appropriate. Procedures did callforpositive urine samples to be rerun for confirmation and where confirmed, a discussion with the involved IndMdual was held in an attempt to discover the cause. Also, appropriate all samples were reviewed and additional urine samples were taken to assure the Individual was
' clean', The requirement for a detailed evaluat:on based upon urinalysis results was not understood.
The immediate corrective steps were to review the actMties of the four employees who had given urine samples over the last two years (19881989) with analysis above the License action level of 25 pg/t. Battelle Northwest Laboratory was contracted to conduct example intake calculations fct each of the four employees as an overcheck. Each of the four employees was determined not to have exceeded regulatory limits. The nine employees who had given urino samples which were positive but did not exceed the License limit (> 10<25 pgit) cver the same time period were investigated and were determined not 10 have exceeded regulatory limits.
In addition, program improvements were instigated.
The urinalysis sample schedule frequency was increased to semi monthly, tho lower detection level was reduced by a factor of 10, and the investigation level for determining Intake versus toxicity limits was reduced by a factor of 4. Pcrsonnel who are responsible for program conduct, including Investigative documentation, are in agreement with the program changes and are committed to satisfactory implementation.
The modified urinalysis program was in effect on March 1,1990, including a new contract with U.S. Testing which performs the analyses. As of that date, ANF was in compilance. The program as currently constituted, may be overly conservative; however, it is planned to continue as is until an experience data bank exists which will allow informod decisions to be made on any further modifications.
Document Controf Desk CWM:90:046 March 23,1990 Page 3 There is no plan to modify eRher Parts I or il of License No. $NM 1227 at this time, This will be done after an experience base has been established and the program is finalized At this time, it is believed that a lloonse amendment will not occur before July 1990, if clardication is required, please feel free to call me.
Very truly yours, M
C. W. Matody, Manager Regulatory Compliance jrs cc:
J. B. Martin, NRC RV