ML20148R538

Forwards Summary of 871201 Enforcement Conference in Region I Ofc Re Violations & Programmatic Breakdowns in Area of Radiological Controls as Noted in Insp Rept 70-1100/87-05. Notice of Meeting,Briefing Agenda & Handout Also Encl

ML20148R538
Person / Time
Site:	07001100
Issue date:	01/19/1988
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8802020215
Download: ML20148R538 (28)

Text

'i JAN 191988 Docket No. 70-1300 b b M ~ l O [g 7 Combustion Engineering, Inc.

ATTN: Dr. Paul ricGill Vice President - Nuclear Fuel P. O. Box 500 Windsor, Connecticut 06095 Gentlemen:

Subject:

NRC/ Licensee Enforcement Conference An Enforcement Conference was held at the NRC Region I office on December 1, 1987 with NRC and licensee representatives to discuss apparent violations and programmatic breakdowns in the area of Radiological Controls at the Combustion Engineering Nuclear Fuel Manufacturing - Windsor plant. These violations and programmatic weaknesses were discussed in NRC Inspection Report No. 70-1100/

87-05, dated November 17, 1987. A Notice of Significant Licensee Meeting issued on November 17, 1987, is attached as Enclosure 1.

Topics discussed during the meeting and the meeting attendees are listed in the attached Meeting Summary report, Enclosure 2. Your briefing agenda and handout material are attached as Enclosure 3. The four hour enforcement conference was held to give you the opportunity to refute any discrepant inspectioc findings and discuss short and long-term corrective actions for the apparent violations and programmatic weaknesses.

Further actions to be taken by the NRC, with respect to the apoarent violatior.s and programmatic weaknesses, will be the subject of separate correspondence. Your cooperation with us is appreciated.

Sincerely, Otinal Signed By:

Rxald R. Geilamy 8902020215 880319 Q1.gd70 PDR Thomas T. Martin, Director Divisior of Radiation Safety and Safeguards

Enclosures:

1. Notice of Significant Licensee Meeting No.87-138

2. Meeting Summary Report

3. Licensee Handout Material cc w/ encl: i l

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

State of Connecticut IEilR N 01G NA "0?RCIE REC 02 COPP IE 07 0 RIG 0 s 1 ,i

9 Combustion Engineering, Inc. 2 JANIg 1933.

bec w/ encl:

Region 1 Docket Room (with concurrences)

Management Assistant. DRMA (w/o encl)

Robert J. Bores, DRSS J. Roth, DRSS N. Ketzlach, NMSS RI:DRSS RI:DRSS Wh4M RI:DRSS RI D SS Ci fi ShanbafyS Bellamy Mar in 1/ /88 1/5/88 1/)3 /88 1/ 8 C ce enf conf 0FFICIAL RECORD COPY 12/16/87 l

E ENCLOSURE 1 U.S. NUCLE'AR REGULATORY C0mlSS10M No.87-138 REGION I NOTICE OF SIGNIFICANT LICENSEE MEETING Combustion Engineering Inc.

Name of Licensee: Windsor, Connecticut Location of Licensee: ,

Docket No.: 70-1100 Time and Date of Meeting: December 1,1987;f(:00a.m.

Location of Meeting: USNRC Region I 1008 8th Avenue, King of Prussia, PA Purpose of Meeting: Enforcement Conference to discuss the licensee's difficiencies in Radiation Protection and Management Controls identified during Inspection No. 70-1100/87-05.

William T. Russell, Regional Ad. m inistrator NRC Attendees: James M. Allan, Deputy Regional Administrator Jchn W. Hickey, Acting Director, Division of Radiation Safety and Safeguards Jay M. Gutierrez, Regional Counsel Daniel J. Holody, Enforcement Officer Ronald R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch Walter J. Pasciak, Chief. Effluents Radiation Protection Section Mohamed M. Shanbaky, Chief, Facilities Radiation Protection Section .

Mary Jean A. Cioffi, Radiation Specialist

. George H. Bidinger, Project Licensing Manager, NMSS Ramon L. Cilimberg, Metallurgical Engineer Jerome Roth, Project Engineer Dr. P. L. McGill, Vice President - Nuclear Fuel Licensee Attendees: Manufacturing G. H. Chalder, Plant Manager, Nuclear Fuel Fabrication R. Sheeran, Nuclear Licensing Safety, Accountability and Security.

F. Stern, Vice President and Chairman, Nuclear Safety Committee E. Scherer, Director, licensing Nuclear Fuel Manufacturing ;

Note: Attendance by NRC personnel at this meeting should be made known by 4:45 p.m., i November 30, 1987, via telephone call to Region I, at FTS 488-1205.

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Prepared by: If N//7/M oth, Project Enginee'r l

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Enclosure 1 2 Di s tributior,:

Victor Stello, Jr., Executive Director for Operations James M. Taylor, Deputy Executive Director for Operations James Lieberman, Director, Office of Enforcement Richard Cunningham, Director, Division of Fuel Cycle, Medical and Academic and Commercial Use Safety, NMSS Hugh L. Thompson, Director, Office of Nuclear Materials and Safeguards Leland C. Rouse, Chief, Fuel Cycle Safety Branch, NMSS Jack Goldberg, Office of General Council PublicDocumentRoom(POR) local Public Document Room (LPOR) bec:

Regional Administrator Deputy Regional Administrator Division Directors Branch Chiefs Public Affairs Officer Region 1 Receptionist J. Gutierrez, RC J. McGrath, SAO D. Holody, ES R. Bellamy, DRSS W. Pasciak, DRSS M. Shanbaky, DRSS  ;

M. J. Cioffi, DRSS J. Roth, DRSS i

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t ENCLOSURE 2 U. S. NUCLEAR REGULATORY COMMISSION REGION I MEETING

SUMMARY

Docket No. 70-1100 License No. SNM-1067 Licensee: Combustion Engineering, Inc.

P. 0.' Box 500 Windsor, Connecticut 06095 Facility Name: Combustion Engineering - Nuclear Fuel Manufacturing.

Purpose of Meeting: Enforcement Conference to' discuss apparent violations

< identified in NRC Inspection ~ Report No.70-1100/87-05.

Introduction An Enforcement Conference was held at the NRC Region I office on December 1, 1987 at 11:30 A.M. The meeting was requested by the NRC Region I Staff to discuss 10 apparent violations in radiological controls and the degraded-radiological conditions identified in NRC Inspection Report No. 70-1100/87-05.

i NRC Attendees J. Allan, Deputy Regional Administrator, RI J. Gutierrez, Regional Counsel, RI J. Hickey, Acting Director, DRSS, RI 3

R. Bellamy, Branch Chief. EP&RPB, RI M. Shanbaky, Chief, Facilities Radiation Protection Section, RI W. Pasciak, Chief, Effluents Radiation Protection Section, RI D. Holody, Enforcement Officer, RI J. Swift, Uranium Fuel Section Leader, NMSS J. Roth, Project Engineer, RI J. Gresick-Cioffi, Radiation Specialist, RI R. Cilimberg, Metallurgical Engineer, NRR Combustion Engineering Attendees t

P. McGill, V.P. Nuclear Fuel, CE, Iac.

A. Scherer, Director, Nuclear Licensing, CE, Inc.

G. Chalder, Plant Manager, NFM-Windsor R. Sheeran, Manager, N.L.S.A.S S., NFM-Windsor ,

P. Steinmeyer, President, Radiation Safety Associates, Inc.

State of Connecticut t C. Price, Senior Radiological Control Physicist, CT-DEP

Enclosure 2 2 f

Summary

1. The licensee acknowledged the apparent violationsfidentified in the subject inspection report, and presented their plan to correct.these 4

violations and prevent their reoccurrence.

2. - .The licensee discussed their perception of the. root causes which led to the breakdown in radiological controls and degraded plant conditions identified in the NRC Inspection report and the subsequent actions which would correct these root causes and prevent their reoccurrence. ,

3. The licensee presented long-term actions planned to upgrade the manufacturing operation and the radiation protection program.

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t Details of the licensee's presentation appear as Enclosure 3.

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e APPARENT VIOLATION 1 FAILURE TO MAINTAIN THE PELLET SHOP CONTAMINATION LEVELS BELOW THE LICENSE LIMITS, AS SPECIFIED IN SNM-1067, SECTION 3.2.8.1 (PARAGRAPH 5.2).

RESPONSE

- 6 dedicated decon personnel in place

- Dedicated HP Tech in charge of program

- Procedures for contamination control completed 84 point tracking board in use I

ENCLOSURE 3 Page 1 of 24

F APPARENT VIOLATION 2 FAILURE TO INSTRUCT WORKERS, 10CFR19.12.(PARAGRAPHS 4.1, 5.5, 7.1)

RESPONSE

- Training sessions completed for all pellet shop personnel in:

Contamination Control

- Use of 84 point tracking board Use of BZs

- Use of protective clothing / friskers

- 10CFR19, rights and responsibilities

- Prepared written procedure for RWP

- Trained pellet shop personnel in upgraded respiratory / bioassay program

- Posted violation notices and responses ENCLOSURE 3 l ' Page 2 of 24 i

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APPARENT VIOLATION 3 FAILURE TO PERFORM RADIOLOGICAL SURVEYS,10CFR20,201(b), (PARAGRAPHS 4.1, 4.6, 5.2).

RESPONSE

- Sectioned pellet shop into 84 survey areas

- Conduct daily surveys on the areas and post on tracking board

- Report survey results to management, supervisory and HP personnel

- Continuously update tracking board on all shifts

. ENCLOSURE 3 P' age 3 of 24 a

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.C APPARENT VIOLATION 4 FAILURE TO MAINTAIN A RESPIRATORY PROTECTION PROGRAM,10CFR20.103(c), (PARAGRAPH 5.5).

RESPONSE

We Have:

- Issued a management policy statement

- All new NIOSH/MSHA approved equipment

- Selected a program adiilinistrator

- Implemented written procedures

- Fit tested and trained all personnel who will use respirators

- Trained HP Techs in daily administration of the program .

- Upgraded the bloassay program ENCLOSURE 3

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APPARENT VIOLATION 5 FAILURE TO TAKE SUITABLE MEASUREMENTS OF CONCENTRATIONS OF RADI0 ACTIVE MATERIALS IN AIR, 10CFR20.103(a)(3), (PARAGRAPH 5.4).

RESPONSE

- 40 new BZs purchased

- Integrating BZs into existing fixed air sampling program ,

- Two continuous air monitors purchased .%

ENCLOSURE 3 ,

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APPARENT VIOLATION 6 FAILURE TO PERFORM B10 ASSAY MEASUREMENTS 10 ASSESS INTAKE BY WORKERS, 10CFR20.103(a)(3), (PARAGRAPHS 3.0, 4.1, 5.4).

RESPONSE .

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- Review of bloassay program by certified health physicist (CHP)

- CHP recommended progra,T,has been implemented

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- Whole body count'all pellet shop personnel twice a year

- Select 25% of personnel for fecal / urine sampling twice a year Personnel who receive an accidental intake will be fecal / urine tested immediately and WBC within 2-4 weeks I

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APPARENT VIOLATION 7 FAILURE TO USE PROCESS OR ENGINEERING CONTROLS TO LIMIT CONC RADI0 ACTIVE MATERI ALS IN AIR (10CFR20.103(b)(1), (PARAGRAPH 5.3).

RESPONSE

We are refurbishing existing equipment / ventilation systems by:

- Rebuilding hoods and glove boxes around powder handling eaulpment/ presses

- Covering roller conveyor / storage areas

- Placing skirts around equipment ENCLOSURE 3 Page 7 of 24 u

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APPARENT VIOLATION 8 l

l FAILURE TO ESTABLISH, MAINTAIN, AND IMPLEMENT RADIATION PROTECTION PROCEDURES AS REQUIRED BY SNM-1067, SECTION 2.7.2, 3.1.1, 4.1 (PARAGRAPHS 5.1, 5.3, 5.4, 5.5, 8.1).

RESPONSE

- Prepare a complete manual of Radiation Protection Procedures l

ENCLOSURE 3 i

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APPARENT VIOLATION 9 FAILURE TO MAINTAIN RECORDS OF SURVEYS,10CFR20.401(b), (PARAGRAPH 5.2).

RESPONSE

- Immediate HP Tech training

- Continuous review of records by HP supervisor

- Developing HF Tech training program i

. ENCLOSURE 3 Page 9 of 24 s

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-3 APPARENT VIOLATION 10 FAILURE TO POST NOTICES TO WORKERS,10CFR19.11, (PARAGRAPH 7.1).

RESPONSE

In conformance with 10CFR19.11

- Developing upgraded general employee training program

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. ENCLOSURE 3 Page 10 of 24

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C-E RESPONSES IMMEDIATELY ELIMINATE ALL APPARENT VIOLATIONS AND PREVENT THEIR RE0CCURRENCE SHORT/ MEDIUM-TERM

- EVALUATE PROBLEM AREAS ,

- DETERMINE THEIR ROOT-CAUSE

- IMPLEMENT CORRECTIVE ACTION PROGRAMS LONG-TERM  ;

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- ESTABLISH AND MAINTAIN A PROGRAM WHICH MEETS -- OR EXCEEDS -- All. REG'ULATORY STANDARDS i l l

!1 ENCLOSURE 3 Page 11 of 24 l j  !

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PRINCIPAL ROOT CAUSES POLICIES AND PRIORITIES UNDEFINED INADEQUATE RESOURCES PRODUCTION REQUIREMENTS INADEQUATE PROCEDURES AND TRAINING i

EMPLOYEE ATTITUDES MANAGEMENT COMPLACENCY i

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ENCLOSURE 3 Page 12 of 24

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l POLICIES AND PRIORITIES PROBLEMS NOT IN WRITING PRIORITIES COULD BE MISUNDERSTOOD CORRECTIVE ACTION .

1 NPS AND FUEL DEPT. POLICIES ISSUED PRIORITIES EMPHASIZED: SAFETY-QUALITY-SCHEDULE-COST I

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ENCLOSURE 3

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RESOURCES PROBLEMS AGING EQUIPMENT i

- INSUFFICIENT MANPOWER; SOME EXPERTISE MISSING i

CORRECTIVE ACTION INCREASED STAFF HIRED QUALIFIED CONSULTANTS EXISTING EQUIPMENT AND FACILITIES IMPROVED PLANNING MAJOR SHOP UPGRADE l'

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i PRODUCTION REQUIREMENTS PROBLEMS EQUIPMENT MAINTENANCE Hall TO BE MINIMIZED HP COVERAGE DIFFICULT t j

CORRECTIVE ACTION INCREASING HP STAFF l I

l PREVENTATIVE MAINTENANCE PROGRAM BEING DEVELOPED l

SUBCONTRACTED PELLET PRODUCTION o .

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ENC'.05URE 3 Page 15 of 24

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l PROCEDURES AND TRAINING PROBLEMS INADEQUATE PROCEDURES AND TRAINING IN RADIATION PROTECTION AREAS CORRECTIVE ACTION EXTENSIVE PROCEDURE IMPROVEMENT PROGRAM UNDERWAY ADDITIONAL TRAINING PROGRAMS STARTED l

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EMPLOYEE ATTITUDES PROBLEMS i

RESISTANCE TO CHANGE "WE VS. THEM" ATTITUDE I

CORRECTIVE ACTION l

C-E CULTURE CHANGE PROGRAM WILL BE CONDUCTED t

CONSULTANT ENGAGED FOR QUALITY IMPROVEMENT PROGRAM  ;

BETTER COMMUNICATION AMONG ALL EllPLOYEES ENCLOSURE 3 Page 17 of 24

e MANAGEMENT COMPLACENCY PROBLEMS EXISTING PRACTICES THOUGHT TO BE ADEQUATE INSUFFICIENT INDEPENDENT INPUT CORRECTIVE ACTIONS l

INCREASED SCOPE AND FREQUENCY OF INDEPENDENT REVIEWS HIGHER LEVEL MONITORING 0F OBJECTIVE DATA l

INCREASED PERSONAL ATTENTION j

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CORRECTIVE ACTIONS - LONGER TERM Root Cause Analysis: Preliminary Observations Management Inattention: Failu."e to Recognize:

- deficiencies in existing Radiation Protection Program l

deterioration of process equipment / containment

- deficient work practices

- inadequate resource allocation Corrective Actions Address:

l l Procedures and Practices

- Training Human Resources I

- Process and Equipment ENCLOSURE 3 Page 19 of 24

PROCEDURES AND PRACTICES .

OBJECTIVE To ensure that all plant operations and personnel protection programs are performed consistently and in accordance with regulatory and other reautrements.

RADIATION PROTECTION

- We have retained a consultant (Radiation Safety Associates Inc'.) to work with us to:

- review the adequacy of our existing written procedures .

- upgrade existing procedures where necessary

- develop new procedures where reautred

- provide a complete Radiation Protection Manual

- This process has been completed for Respiratory Protection and Radiation Work Permit (RWP) procedures.

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- Remaining procedures will be completed by June 30, 1988.

- The Radiation Protection Manual will form the basis for training Health Physics and shop personnel.

ENCLOSURE 3 Page 20 of 24 1

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PROCEDURES AND PRACTICES (CONT'D)

SHOP OPERATIONS

- Written procedures (instructions) have been issued to shop personnel for contamin_ tion control.

- Additional procedures (instructions) to shop personnel will be developed to address remaining radiation protection requirements.

- Shop procedures will be used to prepare lesson plans for personnel training.

INTERNAL AUDITS

- A procedure has been implemcated to provide for independent quarterly audits of of the Radiation Protection Procram and practice.

ENCLOSURE 3 Page 21 of 24

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TRAINING _

0BJECTIVE To ensure that personnel at all levels know and understand the duties and responsibilities of their jobs and the needs and purposes of protective procedures.

TRAINING 0F HP STAFF

- Respiratory Protection Course (October 1987)

Radiation Work Permit (December 1987)

- Radiation Safety Officer Course (December 1987)

- Training in remaining Radiation Protection procedures (complete by Septemeber 30, 1988).

TRAINING 0F SHOP PERSONNEL  ;

- Training in Respiratory Protection completed November 1987.

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- Training in Contamination Control completed November 1987.

- Up9raded employee training program complete by September 30, 1988 - 1 1

annually thereafter.

ENCLOSURE 3 Page 22 of 24

HUMAN RESOURCES

t OBJECTIVE To provide an adequate level of qualified personnel to maintain all plant operations in compliance with regulatory and other requirements.

RADIATION PROTECTION

- Provide full time Health Physics coverage at all times in the pellet shop (November 1987).

- Retain a qualified consultant to assist with preparation of Radiation Protection Procedures and training programs (October 1987).

- Provide a qualified individual to perform internal audits of compliance with Radiation Protection requirements (Quarterly beginning in 1988).

SHOP OPERATIONS

- Provide additional supervision in the pellet shop to assure operator compliance with contamination control and other procedures. (DecemJer 1987).

PROCESS ENGINEERING

- Provide additional engineering support in the pellet shop to improve contamination control of process equipment (December 1987).

PLANT / EQUIPMENT MAINTENANCE

- ' Provide personnel to implement an ongoing preventative maintenance program for equipment and containment / ventilation systems (April 1988).

ENCLOSURE 3 Page 23 of 24

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] i PROCESS AND EQUIPMENT OBJECTIVE To provide reliable engineered systems which maintain manufacturing operations in compliance with regulatory and other requirements.

IMMEDIATE ACTIONS

- Upgrade containment / ventilation systems on existing equipment (October 1987 -

June 1988).

- Modify material handling systems outside containment (October 1987 - June 1988).

- Implement preventative maintenance program ( April 1988).

LONGER TERM ACTIONS A major shop upgrading project is planned over the next three years.

ENCLOSURE 3 Page 24 of 24

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