ML20058M398
| ML20058M398 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 07/31/1990 |
| From: | Austin M, Bores R, Oconnell P, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058M396 | List: |
| References | |
| 70-1100-90-06, 70-1100-90-6, NUDOCS 9008100099 | |
| Download: ML20058M398 (7) | |
Text
f;
+
Q o;,
~
U. S. NUCLEAR REGULATORY COMMISSION REGION I h,
Report No.
70-1100/90-06 Docket No. 70-1100 h,.
n License No.. $NM-1067 Priority 1 Category ULFF n:
Licensee:. Combustion Engineering, Incorporated 1000 Prospect Hill Road 7
W.indsor, Connecticut 06095 g
. Facility Name:. Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor, Connecticut Y
Inspection Conducted: June 13-14, 1990 Inspectors-k _/
7-t/- h p
dr'M.A. Austin,RadiationSpecialist, Effluents date L
- Jiation Protection Section (ERPS), Facilities Radiological Safety and Safeguards (FRSSB),
Division of Radiation Safety and Safeguards R
(DRSS)
N h ()L) 7-p fu P. V. O'Connell, Radiation Specialist date Facilities Radiation Protection Section (FRPS), FRSSB, DRSS
.-)
m g
Approvedby:/
((
b
[O
. J. Bores, [ tion, FRSSB, DRSS hief, Effluents Radiation date rotection Sec SLN h
~1 3 [ %
W. J. Pasciak, Chief, Facflities Radiation -
date 3
p Protection Section, FRSSB, DRSS Inspection Summan :
Inspection on June 13-14, 1990 (Report No. 70-1100/90-06)
Areas Inspected:
Special, unannounced inspection to review the information described in the licensee's response, dated'May 11, 1990,'to the Notice of Violation, NRC Region I Inspection Report No.-70-1100/90-03.
The response letter I
stated that additional information was found subsequent to the exit meeting-for NRC' Inspection No.'70-1100/90-03, that demonstrated compliance with requirements
' for'five of the six violations cited.
I Results:' Due tp additional information provided by the licensee, two of'the violations were: withdrawn.
Four'of the violations remained as cited.
900810G099 900801 PDR ADOCK 07001100 C.
~
w-
+
- ^
- 'd
,1 L.
a
.e.
3 i
DETAILS n
1.0 Individuals' Contacted-1 I
- G.: Hess, Nuclear Material Licensing f
C. Molnar, Nuclear Material Licensing i
)
- P. Rosenthal, Program Manager, Radiological and Industrial Safety i
- R. Vaughan, Plant-Manager i
'J. Vo11aro,= Supervisor, Radiological and Industrial Safety i
- C, Waterman, Acting Vice-President, Nuclear Fuel
'+
- Denotes those'present at the exit interview._ The inspectors also interviewed'other licensee employees during the. inspection.
\\
2.0 R_eview of Previous Violations i
-i This was a special, unannounced inspection to review the information-described in the licensee's response, dated May 11, 1990, to_the Notice of Violation enclosed with NRC Region I Inspection Report No. 70-1100/90-03.
The response letter stated that, subsequent to the exit meeting for NRC Inspection No. 70-1100/90 additional information was found which
-demonstrated compliance with requirements for five of the six violations cited.
The violations described below are identified in the same manner as in the aforementioned Notice of Violation.
2.1. Violation A Violation A of NRC Inspection No. 70-1100/90-03 involved the licensee's alleged failure to complete evaluations to:
l Show t_ hat adequate surveys were conducted in the Pellet ShopL stack and load area to prove compliance with the dose. limits of J
10.CFR 20.101(a) and (b);
l L
+ -Determine the adequacy of beta dose measurements to the skin of L
the whole body, in this case, the' face, and; Determine the. adequacy af beta shielding of safety glasses used in the Pellet Shop.to ensure compliance with whole body dose limits.
specified in 10 CFR 20.101(a) em (b).
i
'In response to this violation, the licensee contended that the violation was unwarranted based on an evaluation c.onducted by the:
licensee-from February 1985 through June 1985.
The evaluation results were reviewed by the NRC in Inspection No. 87-01.
The-inspector concluded that extremity exposures were within regulatory limits.
,y
~
v.;
3 The. inspectors reviewed the licensee's 1985 evaluation and'found:-
[
it did not= include the group of workers who,. historically, have
?p the highest rediation exposures'(the stack and load workers), on whom the violation was based;-
L it did not correlate the exposure of the workers studied to the stack and load workers; p
- . it did not clearly describe the conditions (i.e., the status of '
equipment, shielding, etc.) under which th'e evaluation was performed, thus preventing correlation wi.th current conditions; it did not contain sufficient information to determine the correction factors that result from wearing safety glasses or from wearing dosimeters beneath protective clothing (the current practice).-
Accordingly,'the inspectors concluded that the:1985 study did not constitute an adequate evaluation of the conditions stated in the violation.
The violation stands as cited.
Relevant.to this violation, the inspectors observed stack and load workers improperly wearing their personnel dosimeter by hanging it from their waist. When worn in this manner, the dosimeter was shielded;from radiation from the pellets on top of the table.
During the exit meeting on June 14, 1990,.the inspectors stated that
.the licensee needs to evaluate the adequacy of the positioning of
-personnel dosimetry.
This item will be' reviewed during a future 1
inspection (1100/90-06-01).
2.2 Violation B i
Violation B of NRC Inspection No. 70-1100/90-03 involved the licensee's-alleged failure to furnish, within the time period ' allowed-by 10 CFR 20.408, exposure records for seven former licensee employees to the NRC Director of Nuclear Regulatory Research or to former employees following termination of employment.
In its response to this violation, the licensee accepted the citation and provided a discussion of the corrective actions being taken to resolve the item. The inspectors held general discussions with the licensee regarding this item and observed that the corrective actions
'had been initiated, but not yet completed, at the time of the current inspection, Therefore, the licensee's corrective action for this item will be reviewed again in a future inspection.
2.3 Violation C Violation C of NRC Inspection No. 70-1100/90-03 involved the licensee's alleged failure to issue "special" dosimeters to Radiation q
l
~
o
+
4 Protection Technicians (RPTs) in accordance with Radiation Protection Instruction (RPI)-205.
In its' response, the licensee contends that I
the violation is unwarranted because, until December 1989, "special" (i.e., neutron) dosimeters had been issued to the RPTs monthly for almost eleven years, and that no neutron exposure was ever assigned to any individual'who wore the neutron dosimeters.
The licensee 1
notes that these exposure results prompted a proposal to delete the i
requirerrents from RPI-205 as well as from RPI-206, which contained a-j similar requirement for certain other workers to wear neutron 4
dosimeters.
In December 1989, the licensee initiated Procedure Change Requests (PCR) for both RPI-205 and RPI-206.
The PCR for RPI-206 subsr.iuently was approved and the requirement deleted from that procedure.
However, as a result of administrative oversight,.
the PCR for RPI-205 apparently was lost, so the change was never approved and implemented.
The PCR has now been approved and RPI-205 has.now been so modified.
Further, the licensee notes that, on December 12, 1989, the Program Manager, Radiological and Industrial J
Safety, issued Program Control Document PR-6, External Exposure Control Program, that sets the requirements for that program.
However, "special" neutron dosimeters are not discussed in this document.
In Inspection Report No. 70-1100/90-03, the NRC staff noted that PR-6 i
does not address what types of workers are r3 quired to wear neutron dosimeters. At the time of the inspection (February 26-l March 2, 1990), RPI-205 required that they be issued to RPTs, and the inspector observed that this was not being done. At that time, the RP Supervisor informed the inspector that this was an oversight caused by the incorrect type of dosimeter being ordered for the RPTs from the dosimeter contractor. The NRC staff is concerned that, after.the licensee's-efforts to establish the Configuration
.~
Management System and various tracking systems that a PCR could so easily be misplaced and its loss not recognized over two months later.
Despite the licensee's intentions, or the explanation for the oversight, the implementing procedure in place-at the time of the 1
inspection contained a clear requirement that was not being met. The t
-violation stands as cited.
2.4 Violation D Violation D of NRC Inspection No. 70-1100/90-03 involved the licensee's alleged failure to verify the adequacy of the stack air sampling-techniques on a quarterly. basis, as required by Section 3.2.3 of NRC License No SNM-1067.
f Based on information contained in the licensee's letter dated May 11, 1990, questioning this and other violations during the current inspection, the inspector reviewed a report, dated June 7,1988, of an engineering evaluation performed by an inde-pendent consultant firm that documented an investigation of the adequacy of the Building 17 exhaust systems.
This engineering evaluation concluded that the construction and location of the s
+
y b
i I
5 sampling probes for the operating exhaust systems conformed with ANSI L
N13.1-1969 requirements, and that the installation of the sampling lines was satisfactory. 'The engineering consultant also developed sampling rate curves for each, exhaust system and recommended that i
these new curves be used.
The inspector accompanied a licensee radiation protection (RP) technician on a tour of all operating exhaust systems j
4 in Building 17, including an examination of the exhaust and samoling equipment in the mezzanine levels and on the rooftop areas. The inspector r,
r
[(
observed that the new curves, which correlated sampling rate and duct-air velocity, were posted at each sampling station for the operating
[
exhaust' systems.
The inspector observed an RP technician record the
-sampling flow rate, collect the sample filter paper, take a fixed
[p manometer measurement to determine the current duct air velocity, refer to the posted curve to determine what sampling flow rate cor-responded to the currently measured duct air velocity, and then adjust the sample pump flow rate, as necessary.
Stack air samples are collected
!?
on a daily basis, and sampling flow rate adjustments are made, as needed, at the time of sample collection.
The inspector reviewed records of these daily verification checks which were main-tained wi_th the sample result records.
Licensee representatives from Manufacturing Engineering informed the inspector that the manometers used to determine duct air velocity are calibrated yearly.
In addition, j
the inspector, observed that the operating exhaust systems _ have been
~
['
included in the licensee's Plant Equipment' Periodic Service & Inventory System (PEPSIS), which is part of the licensee's upgraded preventive U.
maintenance program.
The PEPSIS will be used to ensure-that the installed airflow manometer readings will be compared to portable instrument i
readings in the exhaust ducts on a quarterly basis. This is consistent' with the licensee's commitment made in its resporse to this violation,
[
. dated May 11, 1990.
The inspector determined that the licensee's use of the sampling-rate curves based on the independent engineering evaluation satisfied tM Section 3.2.3 requirement for periodic verification of-stack sampling adequacy, and the licensee's commitment to perform quarterly comparison measurements with a portable instrument provides L
further assurance of.an adequate sampling system.
During Inspection No. 70-1100/90-03, when asked by the inspector the status of.the quarterly sampling program, a licensee representative had stated that the required quarterly verification was no longer being done.
However, the information eceived during the current inspection provided sufficient basis to r
reconsider and withdraw the violation.
Relevant to this item, in a discussion with licensee representatives r
during the current inspection,.the inspector stated that the cited requirement in Section 3.2.3 of License No. SNM-1067 was now virtually 7
meaningless because it did not reflect the changes made in the stack sampling practices, and so an appropriate amendment was needed. The licensee representatives agreed and stated this item would be addressed as part-of the current license renewal proceedings.
i m._-
a
m
,m-y h
6 2.5 Violation E t
Violation E of Inspection No. 70-1100/90-03 involved the licensee's alleged failure to evaluste the'.representativeness of fixed air sampling. station data used by the licensee to determine breathing zone air concentration levels and to assign exposures to specific 1
' individuals.
In its May 11, 1990, response to this violation, the s
licensee acknowledged that it had been unnecessarily assigning.
l calculated intakes to r,pecific individuals based on fixed air sample i
data, but still felt the violation was unwarranted because the assigned intakes were not required to be done.
However, the violation.was based on the licensee's failure to evaluate the representativeness of-the fixed air sampling equipment. The licensee's response did not' address.this basis for the violation. Accordingly, the violation i
remained as cited.
i The inspector observed that the licensee discontinued the poor practice of a: signing unrealistic internal exposures to specific individuals based on non-representative fixed air sample data.
The inspector reviewed the new approach used by the licensee to address the monitoring-w of individuals who do not wear lapel air samplers in the Pellet Shop.
The inspector reviewed-records which showed that the RP Supervisor performed a daily review of the Pellet Shop personnel entry log sheet along with a review of the corresponding air sample data for that
.same day.
The RP Supervisor considers the various residence times of.
the individual visitors in the Pellet Shop in conjunction with-the
-apparent air concentrations measured that day, and then he determines if any individual could have received an internal exposure greater
}
than or equal to 2 MPC-hrs.
If so, the exposure is assigned to the 3
appropriate individual and is tracked during the calendar quarter.
If not, the RP supervisor documents the evaluation and maintains this daily record in the RP office files.
The licensee informed the inspector that the procedures will be updated to reflect this new approach, but this approach was being implemented first to determine
?-
if additional refinements could be made.
The inspector stated that the new approach was an improvement over the past practice because it presented a more real'stic accounting of the possible internal. exposures incurred by infrequent or short-term visitors to the Pellet Shop.
Based upon these inspector observations, this item is closed.
2.6' Violation F m
Violation F of NRC Inspection No. 70-1100/90-03 involved the licensee's
'I alleged failure-to train radiation protection (RP) technicians in.
accordance with the requirements of Section 2.1.1 of License No. SNM-1067.
The licensee, in its response to the Notice of Violation, stated that such a program was in place.
The inspectors reviewed the subject training records of the radiation protection and industrial safety 4
{t y',
w;,
.a. g sn,
. g
,c;
- c. ?s :
- s
- z.
'3:
3 '. $ --
^ '
T 1
.g -
}-
- ,+
"! M' Z technicians and determined that those, individuals.had received the L
minima.11y.specified training.
Based'on this additional information,-
1 W,
c
- the NRC stafficoncludes thatithe violation was' inappropriately cited
+
and is' withdrawn..
~
'~
'd
's 3.0- Exit Meetino:
r, L
Th'e inspectors: met'with: licensee' personnel denoted:in.Section 1.0Lat the
' conclusion of.the: inspection _on' June:14,.1990. JThel scope and findings of.
's
,.the. inspection.were_ discussed at that-time.
=
1 s
y i
2 -.
5
+
'}
i i k
y f
v
- h. c. -
'I i
1
.. g 4
~
-+
r,
i
'I q
k4
.c s,
f; c
- }
jl
- i
-j s
'i y
.I
~
N E
,-n
- w. w.
n,,,,.