ML20059N822
| ML20059N822 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 10/01/1990 |
| From: | Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Waterman C ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| References | |
| NUDOCS 9010170328 | |
| Download: ML20059N822 (2) | |
Text
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l'i, OCI0.11999' K
-Docket No. 70-1100
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o 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:
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Subject:
Inspection No. 70-1100/90-06
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This refers to your letter dated September 14,1990, in response to our letter
<a dated August 1, 1990.
Thank you.for informing us of the. corrective and: preventive. actions documented i
in your letter. These-actions will be examined during a' future inspection of your. licensed program.
Your cooperation with us is appreciated.
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Sincerely, Original Signed 96 Wittiam J. Lazarus ~
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-James H. Joyner, Chief Facilities Radiological Safety-and' Safeguards Branch.
Division of Radiation Safety-and Safeguards-r i
cc:
A. E. Scherer, Director,-Nuclear Licensing C. B. Brinkman, Manager, Washington Nuclear Operations Public Document Room (PDR)'
Local Public Document Room:(LPDR) i.
Nuclear Safety Information' Center (NSIC)'
l State'of Connecticut-
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Region I Docket Room (with concurrences)-
Management Assistant,:DRMA (w/o enc 1)
- J.-Roth, DRSS J
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-9 f SEA BROWN BOVERI -
- September 14,- 1990:
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Docket No.
70-1100' License No.cSNM-1067 6
i Dr.-Malcolm R. Knapp, Director 4
Facilities Radiological Safety 1
and Safeguards Branch Division of Radiation Safety:
~
and. Safeguards U. S. Nuclear Regulatory Commission i
Region'I-475 Allendale Road King of-Prussia, Pennsylvania 19406-j
Subject:
Response to Noticeiof: Violation-t (Inspection Report No.170-1100/90-06):
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Reference:
Letter,- M.. R. ' Knapp - (NRC),to' C.'
R. = Watermani-l (C-E), dated' August 1,_1990
Dear Dr. :
Knapp:
The Reference requested Combustion: Engineering's' response:
i to: Items.A and:C of NRC Inspection.: Report No.
70-1100/90-06.
This: report-documented:the results of'a.
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special inspection that was:-conducted to: evaluate additional information we provided;in response to NRC:
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. Inspection Report:No.'-70-1100/90-03. ' Discussion with the l:
Region I Division Project' Manager confirmedEthat ouri 1-responseLby: September 14',
1990.wouldrbe: timely.
~Accordingly,~our response to ItemsEA!and C of NRC.:
InspectioncReport No.-70-1100/90-0611s.providedoin
. Enclosure I.
.i If I can be of further'assistanceiin'thisimatter,~please do not hesitate to-contact me or Mr. J.
F.1Conant at:
(203)285-5002.
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- Very>trulys yours,l.-
COMBUSTION /- ENGINEERING,n INC.,
'/ R. E._Vaughan Plant' Manager-REV:plm cc:
J..Roth (NRC Region I)
S. Soong-(NRC) r ABB Combustion Engineering Nuclear Power-Combusbon Engineenng inc_
1000 Prospect HA Rosa -
Tefephone (203) 688-1911
. Post Oftce Box 500
, Fan (203) 285-9512.
.o W:rcscr, Connectcut 06095-0500
- Te'ez 99297 COMBEN WSOR 30 OM
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ENCIDSURE.I' 2
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' RESPONSE-TO' NOTICE OF. VIOLATION I
(NRC INSPECTION REPORT NO.:70-1100/90-06)'
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l Response to Notice of-Violation 1 l,
-(Inspection Report No. 70-1100/90-06)
Violation A Violation A of NRC Inspection No.o70-1100/90-03 involved the.
licensee's. alleged failure'to complete evaluations to:
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Show that' adequate surveys;were-conducted'in the Pellet Shop.
i stack and load. area to prove compliance with the-dose. limits' i
-ofilo CFR 20.101(a) and (b);
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Determine the adequacy of beta l dose. measurements to the skin of the whole body, in this case,,the face, and;-
q Determine the adequacyLof' beta: shielding of safety glasses N
.used in.the Pellet Shop to ensure compliance with whole-body dose limits specified in~10{CFR 20'.101(a) ore (b).
1 In response to this violation,Lthetlicenseefcontended that the violation was unwarranted basedton an: evaluation conducted by the i
licensee from February 1985 through June 1985.
The evaluation-I results were: reviewed by-'the. NRC11n ; Inspection No. 87-01.
The i
inspector concluded that extremity-exposures were within regulatory j
limits.
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The inspectors reviewed the licensee's 1985 evaluationfand.found: '
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- it did not include the group of workers who,. historically,-
L-have the highest radiation exposures (the stack and load-3
' workers),:on whom:the violation was based;l it did'not correlate.the exposure of the' workers studied to' a
t the stack and' load. workers;:
L it'did not clearly describe the conditions (i'.e..,sthe status-of4 equipment, shielding, etc.) under which:the? evaluation was-l performed, thus preventing correlation with. 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 1 practice)..
Accordingly,- the inspectors concluded that the 1985 study did not-constitute;an ade @ ate 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 1
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shielded.from radiation from the pellets on top of the table.
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During the exit meeting on June 14, 1990, the inspectors stated that the licensee needs to evaluate the adequacy ofLthe positioning of personnel dosimetry..This item will be reviewed during a future inspection (1100/90-06-01). -
RESPONSE
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As stated in our letter of May 11, 1990, Combustion Engineering -
initiated additional surveys and a beta radiation study at the fuel pellet stacking table on April 13, 1990.
The study,.using Thermoluminescent Dosimeters (TLD) in a fixed position from the fuel pellet stacking surface, was designed to gather information about the attenuation of beta radiation by protective clothing garments and safety eye glasses worn by workers.
Results of the study indicate that exposure to the worker's face may be 10% higher than indicated-by the personal TLD worn by the workers under their protective clothing garments.
The resultant skin dose including dose to the skin of the face is well within NRC limits specified by 10CRF20.101.
With respect to the use of safety: glasses in meeting whole body dose limits as specified by 10CFR20.101, results of the study
' indicate that the use of standard safety glasses designed to ANSI specification Z87.1, 1989 is essentially 100%. effective in shielding beta radiation when worn by the average worker at the stacking table.
A report on this study is-presently-under preparation.
In parallel with this study, we conducted some tests using an air ionization chamber and polycarbonate plastics to evaluate-the benefits and practicality of a permanently: installed beta shield, In the interest of maintaining exposures As. Low As Reasonably i
L Achievable, ALARA, it was decided to install a " salad bar" type L
polycarbonate beta shield at'the pellet stacking table.-
Evaluations performed after' installation indicate that the beta o
shield is essentially 100% effective.
Based upon the above and results of routine radiation surveys, we-believe we are in full compliance with 10CFR20.101~.'
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Violation C
-l Violation C of NRC Inspection No. 70-1100/90-03 involved the licensee's alleged failure to issue "special" dosimeters to Radiation Protection Technicians (RPTs) in accordance with Radiation Protection-Instruction (RPI)-205.
In its response, the licensee contends that 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 I
dosimeters.. The licensee notes that these exposure results.
prompted a proposal to delete the requirements from RPI-205 as well as-from RPI-206, which contained a similar requirement for-certain other workers to wear neutron dosimeters.
In December 1989, the licensee initiated Procedure Change Requests (PCR) for both RPI-205 and RPI-206.
The PCR for RPI-206 subsequently-was approved and the l
requirement deleted from that procedure.
However, as a result of-l administrative oversight, the PCR for RPI-205 apparently was lost',
so the change was never approved and implemented.
The PCR has now l
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 Safety, issued Program Control Document l
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 does not address what. types of workers are required.to wear neutron dosimeters.
At the time of the inspection (February 26-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 theDconfiguration Management System and various tracking systems that a PCR could so L
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 inspection contained a clear requirement that-was not.being I
met.
The violation stands as cited.
RESPONSE
i Although caused by an administr v'ersight, special neutron dosimetry was-indeed not issuet stion Protection Technicians-as required by the version of I
. al Protection Instruction (RPI)-205 in-effect at the tin e the special neutron dosimetry was not required, RI us since been modified to-delete the special dosimetry re nt so that it is now consistent with other related fac.A. y documentation.
That is, Radiological Protection Technicians are no longer required to wear special neutron dosimetry.
Combustion Engineering'is now in compliance with facility procedural requirements concerning dosimetry for Radiological Protection Technicians.
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i As previously pointed'out, the root cause of this violation was r
i a failure to follow the established procedure revision process.
To correct this situation, the NFM Plant Manager has established a temporary. Procedure Review Committee to review. comments and changes-i to NFM Program documents.
As a minimum, documents within the scope:
6 of Committee review include Radiological Protection Instructions, Criticality Safety Instructions, EmergencyLPlan Implementing-
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Procedures, Industrial Safety Instructions,1and selected Administrative Procedures and Guidelines.
The committee consists of the NFM Plant-Manager, Operations consultant,' Program Manager of Radiological Protection and I
Industrial Safety, and the Cognizant Document " Owner" (as established by Administrative Guideline AG-1, Organization and Responsibilities).
t The Committee will meet as necessary to. address document review comments until the Plant Manager determines.that the established procedure revision process is working as intended.
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