ML20151E705

Insp Rept 70-1100/88-06 on 880614-17.Violations Noted.Major Areas Inspected:Licensee Radiation Protection Program

ML20151E705
Person / Time
Site:	07001100
Issue date:	07/08/1988
From:	Gresick J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20151E684	List: ML20151E683 ML20151E702 ML20151E705
References
70-1100-88-06, 70-1100-88-6, NUDOCS 8807260177
Download: ML20151E705 (13)

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-1100/88-06 Docket No. 70-1100 License No. SNM-1067 Priority 1 Category ULFF Licensee: Combustion Fngineering, Incorporated P.O. Box 500 Windsor, Connecticut 06095 Facility Name: Nuclear Fuel Manufacturing and Nuclear Laboratories Inspection At: Windsor, Connecticut Inspection Conducted: June 14-17, 1988 Inspectors: .

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Jeaf A. Gresick, Radiation Specialist, date FRPS j

Approved by: 97f .C'A /d -7/g'/f'[ ~

M.M.~5hanbaky, Chief, Facikfties Radiation '

date Protection Section Inspection Summary: Inspection conducted on June 14-17, 1988. (Report No.

70-1100/88-06).

Areas Inspected: Routine, unannounced inspection of the licensee's radiation protection program, including: management and organizational changes, training and retraining of personnel, radiation protection program upgrades effluent and environmental monitoring, and criticality safety. Theinspectoralsoreviewed concerns brought to NRC attention regarding radiation protection practices at the Nuclear Fuel Manufacturing facility.

Results: Within the scope of this review, two apparent violations were identified: failure to survey radioactive material durin trash compacting to assure compliance with the requirements of 10 CFR 20.201 b), (paragraph 5.4);

failure to provide indium foil dosimeters to visitors in he Pellet Shop, SNM-1067, Part II, section 4.9 (paragraph 5.7),

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N-DETAILS 1.0 Personnel Contacted 1.1 Licensee Personnel

• P. McGill, Vice President, Nuclear Fuel

• F. Stern, Vice President, Nuclear Fuel Manufacturing

• C. Waterman, Plant Manager, Nuclear Fuel Manufacturing, Windsor

• E. Scherer, Director, Nuclear Licensin CE

• P. Rosenthal, Manager, Radiological & In g,dustrial Safety, NFM J. Vollaro, Health & Safety Supervisor, NFM-Windsor Radiochemist, CE Power Systems J.

S. Helems,h, Kucavic Radiation Specialist, NFM-Windsor J. Althouse, Consultant, Radiation Safety Associates, Inc I. Skinner, Manager, Facilities & Equipment, NFM-Windsor S. Sorenson, RSO, Radiological Protection Services, CE Power Systems Other licensee and contractor personnel were contacted and interviewed during this inspection.

1.2 NRC Personnel

• G. Sjoblom, Acting Division Director, Division of Radiation Safety &

Safeguards, Region I

• denotes attendance during the exit interview on June 17, 1988.

2.0 Purpose The purpose of this routine, unannounced inspection was to review the Radiation Protection program with respect to the following elements: ,

- Management and Organizational Changes

- Training and Retraining of Personnel

- Status of the Radiation Protection program upgrades, including:

- Engineering Controls Upgrades in the Pellet Shop

- Air Sampling Program

- Respiratory Protection Program

- Surveys and Contamination Controls

- Radiation Werk Permits

- Personnel Monitoring

- Effluent and Environmental Monitoring

- Hot Particle Controls in Building 2 (Reactor Services facility)

- Criticality Safety Controls l Ihe inspector also met with a Pellet Shop worker, who expressed concerns l regarding radiation safety at this facility.

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2 3.0 Management and Organizational Changes As a result of additional violations found in the area of criticality

, safety (NRC Inspection Report No. 70-1100/88-03), the lack of progress in rogram upgrades the radiation safety p/88-03), and due(NRC Inspection Report No.to the planned expansio 70-1100/88-01,70-1100 modernization of the pellet manufacturing operations, the licensee reorganized the Nuclear Fuels Manufacturing organization and replaced personnel in two key plant positions. The new organizational structure is included as Attachment 1 to this report. Effective June 2, 1988, the licensee appointed a new individual to the position of Plant Manager, Nuclear Fuel Manufacturing, Windsor. The qualifications of this individual, with respect to license requirements for this position, will be reviewed in a future inspection.

The licensee eliminated the position of Manager, Nuclear Licensing, Safety, Accountability & Security. The new position is titled Manager, x Radiological and Industrial Safety. A new individual was appointed to this position effective June 2, 1988. The Manager, Radiclogical and Industrial Safety, reports directly to the Vice President, Nuclear Fuels Manufacturing. This reporting chain alleviates previous NRC concerns regarding the potential conflict of interest between production needs, and nuclear and industrial safety.

The ins ector reviewed the qualifications of the newly appointed Manager Radiolo ical and Industrial Safety and found that the individual was well qualifi d by experience in health physics practices and radiation safety at nuclear fuels manufacturing plants as well as in a broad range of other nuclear facilities. However,theInspectoralsonotedthatthenewly created position is not reflected in the current special nuclear materials license. The licensee stated that since the license is in the process of renewal, these organizational changes will be incorporated into the license renewal. The effectiveness of these organizational changes will continue to be evaluated in future inspections.

4.0 Training and Retraining of Personnel The licensee's program for training and retraining radiation workers and Health Physics technicians was reviewed with respect to criteria contained in 10 CFR 19.12 and the special nuclear materials license.

The adequacy and effectiveness of the licensee's training and retraining program was determined by:

- review of lesson plans for the new General Employee Training (GET), HP technician training, written examinations; and

- discussions with licensee and contractor personnel.

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Within the scope of this review, no violations were identified. The licensee developed and provided training to all of the Health Physics technicians to assure consistency in the implementation of the radiation protection policies and practices currently in effect. This basic training was provided as a temporary measure to upgrade technician performance.

After completion of the program upgrades in the area of policies and procedures, an expanded training program will be implemented.

The licensee had also conducted the radiation worker retraining to ecai, the license requirement for annual retraining. However, inspector review of the written examinations given to radiation workers identified that incorrect information was given to radiation workers in their retraining program. Also, inspector review of the GET lesson plans indicated that the specific type of radiation and radiation hazards present at the Nuclear were not Fuels Manufacturing addressed in the GETfacility (i.e.,This sessions. alpha wasradiation and uranium) verified during discuss ions with Pellet Shop workers.

Weaknesses in the GET training rogram regarding the hazards of working with uranium had been previousl brought to management's attention by Pellet Shop workers. As a resu t of this, the licensee established a training coordinator for the Nuclear Fuels Manufacturing, Windsor plant.

The training coordinator position was filled during the inspection on June 16, 1988. Prior to his actual appointment, the training coordinator had begun to evaluate the training needs of plant personnel. However, due to the recent appointment of the training coordinator, progress in this area will be reviewed during future inspections.

5.0 Status of the Radiation Protection Program Upgrades 5.1 Pellet Shop Engineering Controls Upgrades l The inspector reviewed the status of planned Pellet Shop improvements i to limit the potential for airborne radioactivity levels. During the l previous inspection (NRC Inspection Report No. 70-1100/88-03),the inspector noted that substantial improvements were made with additional hoods and ventilation over sources of loose powder. The licensee had also installed stainless steel sheet metal over conveyor belts and carts to facilitate decontamination. During this inspection, the inspector noted that the cuckets used for the

) reparation of the powder arior to pressing into pellets had not yet

)een replaced. This area lad previously been identified as requiring l upgrading and modifications, because of the continual failure of the cones (funnels) to remain fastened to the buckets while being inverted and fed into the blenders at the powder preparation station. The inspector also noted that there were at least three stations (hoods l

that were used to handle loose powder, and these stations continued)to j

be operated with the front faces open to the workers' breathing zone.

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The inspector discussed these areas with the licensee. The licensee provided the inspector with the following information:

- The modification for the buckets and cones will be completed in approximately one month. The delay was in obtaining all the necessary parts for the modified buckets.

The modification for the hood front faces had not been identified to the Facilities and Equipment personnel in charge of engineering modifications. At the exit interview, the licensee stated that the Manager, Radiological and Industrial Safety will identify all equipment that still needs improvements to reduce airborne radioactivity levels. The licensee stated that system upgrades or modifications will be performed as may be necessary to minimize airborne radioactivity.

This area will continue to be reviewed in future inspections.

5.2 Air Sampling Program The inspector reviewed the status of the upgrades to the licensee's air sampling program during this inspection. Previously, the licensee stated that they had decided to use a 100% breathing zone air sampling program. During this inspection, the new Manager, Radiological &

Industrial Safety stated that he would expedit5 the acquisition of the breathing zone air samplers to establish a 100% breathing zone air sampling capability. The fixed air sampling stations will continue to be maintained as a back-up to the breathing zone air samplers.

The licensee stated that the breathing zone air sampling program should be estatlished and in place by the end of July or the beginning of August.

This area will continue to be reviewed in future inspections.

5.3 Respiratory Protection Program The inspector reviewed the status of the licensee's newly instituted respiratory protection program. The licensee recently completed revision 1 of the procedures for the respiratory protection program.

The licensee also plans to continue the independent audits of their respiratory protection program on a periodic basis. This area will be reviewed in detail in a future inspection.

5.4 Bioassay Program The inspector reviewed the status of the bioassay program procedures, and the results of some evaluations made of Pellet Shop workers' lung counts and in vitrc bioassay results. The inspector noted that, at

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the time of the ins ection only one individual's lung ceunt results had been evaluated hor comp,liance with 10 CFR 20.103 requirements.

Preliminary results indicated that this individual had been exposed to an avera employns.ge nt withofthis 107licensee.

MPC-hours per quarter for the past 17 years ofHowever licensee personnel, the inspector determined that this individual may have sustained these intakes during special maintenance activities, performed parsodically over the past 17 years, and may be indicative of discrete and acute intakes of radioactive material. The licensee had no air sampling data to indicate that the individual's intake did not exceed 40 MPC-hours per week or 520 MPC-hours per quarter. In addition, the licensee did not have timely bioassay measurements to verify the adequacy of the air sampling program. Therefore, no evaluations of individual incidents was performed, and the exact events cannot be reconstructed.

NRC Inspection Report No. 70-1100/87-05 identified five violations in this area. The licensee had received citations at that time for failure to comply with the requirements of 10 CFR 20.103 (a)(1),

(a)(3), (b)(1), and (c).

The licensee's additional evaluations of the bioassay data of the Pellet Shop workers, including any individual with evidence of intake of uranium oxide powder will be reviewed in a future inspection. This area will remain unresolved (70-1100/88-06-01).

Further progress in establishing a suitable bioassay program to comply with the requirements of the regulations will continue to be reviewed in future inspections.

5.5 Surveys and Contamination Control The licensee's program for surveys and contamination control was reviewed with respect to criteria contained in regulatory requirements and the special nuclear materials license conditions.

The licensee's performance related to the above criteria was determined by:

- observations and measurements made during tours of the Pellet Shop;

- review of selected records; and

- discussions with licensee and contractor personnel.

Within the scope of this review, the following was identified:

During a tour of the Pellet Shop, the inspector observed a radiation worker using a trash compactor, without a breathing

6 zone air sampler. There was also no air sampler in the general vicinity of the trash compactor. The inspector also noted that there was no ventilation controls for the trash compactor. Any potential airborne release would be directed out of the seams of the door toward the worker's breathing zone. The worker stated that occasionally, a bag would break or open up, and dust would come out of the seams of the door. The licensee compacts material contaminated with uranium powder in this compactor. The j inspector determined that no radiological surveys had been

! performed to determine the extent or amount of radioactive material present in the trash being compacted.

The inspector discussed this activity with health physics personnel who stated that they had made reasurements previously and had not measured any elevated airborne activity. They had not established any requirements for Radiation Work Permits nor other controls (i.e., procedures) for this activity. Workers operated the trash compactor whenever they felt it was necessary.

The inspector stated that failure to evaluate the presence of radioactive material on the material being compacted, and sample the air during the compacting operation was an apparent violation of 10 CFR 20.201 (b). This requires that surveys be made to assure compliance with the requirements of the regulations, and to evaluate the extent of radiation hazards that may be present (70-1100/88-06-02).

The licensee stated that effectively immediately, they would establish the compacting operation as an activity requiring an RWP, and provide breathing zone air samplers for all compacting activities. The new Manager, Radiological & Industrial Safety that this equipment would be also stated, reviewed and at the exitfor evaluated interview,ility acceptab as a radioactive waste compactor.

The inspector conducted independent measurements of the contamination levels in the Pellet Shop. Results of the smears in the area of batch make-up and the elevator indicated that the effectiveness of the licensee's contamination control program was declining. Areas previously known to have low contamination levels were found to accumulate contamination approaching the license limit 10,000 dpm per 100 square centimeters). This was brought to the(licensee s attention during the inspection and at the exit interview. The new Manager, Radiological & Industrial Safety stated that he would be making changes to improve contamination control immediately. This area will continue to be reviewed in future inspections.

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5.6 Radiation Work Permit Program 3

The inspector reviewed a draft copy of the Radiation Work Permit procedure. The new procedure only documented the elements of the Radiation Work Permit program as it currently is practiced at this facility. This RWP procedure remains weak in providing adequate guidance as to what activities should be performed under RWP controls.

The new Manager, Radiological & Industrial Safety stated that he would establish a procedure to meet the needed controls at thii site. This area will be reviewed in a future inspection.

5.7 Personnel Monitoring During this inspection, tho inspector noted that there were no administrative controls for the issuance of indium foils as an accident criticality dosimeter at this facility. The licensee provides an indium foil for visitors on the visitor's identification badge. Regular plant personnel who enter the Pellet Shop have indium foils affixed to the outside of their TLO. However, the inspector found that the licensee did not affix the indium foil to the picture badges of the contractor personnel and occasional visitors to the Pellet Shop. Failure to supply indium foil badges to all visitors to the Pellet Shop is an apparent violation of SNM license no.1067, Part II, section 4.9 (70-1100/88-06-03).

6.0 Effluent and Environmental Monitoring The licensee's program for effluent and environmental monitoring was reviewed with respect to criteria contained in regulatory requirements and the special nuclear license conditions.

The licensee's performance related to the above criteria was determined by:

l - review of environmental analyses of surface waters, river sediment, well water, fallout, and soil for 1987 and 1988;

! - review of an incident with the FA-1 filter system and the licensee's l

subsequent corrective action; and

- discussions with licensee personnel.

Within the scope of this review, no violations were identified.

Environmental analyses of the surrounding waters and land indicated that there were no releases to the environment. No anomalous data was noted.

l 1988, the Health Physics department identified that the air On Juneon9,t he FA-1 filter bank had exceeded the established CE action limit sample (IE-12 microcuries per cubic centimeter mandates immediate shutdown of the

8 The elevated airborne activity was caused by affected ' intilation system)hanism which holds the absolute filters in a failure of the tension mec pl ace. The licensee immediately shut down the system and any process equipment associated with the ventilation system, and made the necessary repairs. Inspector review of the licensee's response to the failure of the FA-1 filter system, and the new Manager, Radiological & Industrial Safety's subsequent corrective action indicated that appropriate and timely corrective actions were taken. New administrative limits were also established, as a result of this incident, for all ventilation systems to prevent the release of licensed material in excess of the licensee's quarterly license limit of 18 microcuries of uranium.

7.0 Hot Particle Controls in Building 2 During this inspection, the inspector was informed by site personnel that the reactor services personnel in Buildina 2 had identified numerous hot particles coming back to the storage facility on the reactor services equipment. The inspector reviewed the licensee's controls for hot particle detection and the potential spread of the particles to personnel and uncontrolled areas of the facility.

The licensee established the following controls for hot particle contamination:

All shipping boxes containing equipment used at the reactor sites are now smeared thoroughly with maislin wipes to remove any hot particles on the outside of the shipping boxes. This is done prior to removing the shipping boxes from the trailer. Personnel performing this activity are required to wear full anti-C's.

- When the licensee is certain that the shipping boxes are free of hot particles, the boxes are removed from the trailers and stored in the licensee's storage facility.

Any refurbishment work on the equipment or decontamination of the equipment is performed in a ventilated tent, with decontamination personnel in full anti-C's.

The inspector noted the following weaknesses in the licensee's hot particle control program:

- The licensee uses GM pancake probe friskers to detect hot particles on personnel when they leave the controlled area. This equi have the appropriate sensitivity to detect hot particles.pment may not

- A review of the licensee's methodology for hot particle dose assessment indicated that the licensee was unaware of the current NRC position regarding averaging the dose to 1 square centimeter of skin

9 area. Also, the licensee was unaware of the large correction factor needed to convert meter response to hot particles to total dose equivalent.

The inspector discussed these weaknesses with the licensee. The licensee stated that they would contact radiation protection personnel at nuclear power plants for information on their hot particle control programs, and establish the necessary controls.

8.0 Criticality Safety Controls The inspector discussed the controls established by the licensee to assure that each process and equipment change which was considered in the Pellet Shop was evaluated with regard to nuclear criticality safety. As a result of this discussion the inspector determined that the licensee had not established the criteria or threshold levels to determine the type of changes that would be required to be evaluated. In addition, the inspector determined that the licensee had not established procedures to assure that each process and equipment change was properly reviewed, evaluated, fabricated, installed and initially operated in accordance with the criteria established as a result of the change evaluation. This concern was discussed with the cognizant licensee personnel and with licensee management at the exit interview on June 17, 1988. The licensee stated that the new Manager, Radiological & Industrial Safety will review this area and establish the appropriate administrative controls. This area will be reviewed in a future inspection.

9.0 Employee Concerns Discussed with NRC On June 14, 1988, the inspector was approached by a radiation worker, working in the Pellet Shop. The individual had some concerns about events that had occurred during the previous weekend.

9.1 Equipment Failure at the Milling Hood On Monday, June 13, 1988, the individual stated that he was concerned about his assigned MPCs for the shift. He stated that a vacuum hose fell off of the back of the milling hood. He immediately left the work station, and turned his breathing zone air sampler in for analysis. The HP technician immediately counted the filter. The filter showed that there was no unanticipated activity on the filter paper. Later that day, the individual was told by the HP technician that the filter was recounted. and the estimated MPC value was adjusted downward slightly. No reason was given for the adjustment.

The inspector reviewed the incident in the HP Unusual Occurrence log, reviewed a number of MPC-hour sheets, el conducted discussions with licensee personnel. All calculations lewed by the inspector were I

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accurate. Further, the licensee explained that all breathing zone air filters are counted after a 4 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> decay period to allow for the decay of radon and its daughter products. The initial count was not instead the filter was recounted after the 4 to 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> decay used;d,andtbeMPCassignmentwasbasedonthesecondcount.

perio The inspector met with the individual on June 17, 1988, and sample counting procedures were discussed with him. The individual had no more concerns at that time.

9.2 Lack of Filter Paper in Breathing Zone Air Sampler On June 12, 1988, the individual stated that he was working with a furnace, when it "popped". The individual stated that he immediately went to the HP technician on duty, to have his filter paper counted.

The HP technician found that the breathing zone air sampler head had not been equipped with a filter paper. The HP technician immediately performed a nasal smear on the individual and filled out an unusual occurrence report. On Tuesday, June 14,1988, the individual was sent for a lung count. The results of the nasal smear showed no detectable activity. The lung count was also negative. However, the individual was concerned about the failure to put the filter paper in the sampler head.

The inspector reviewed the unusual occurrence report, and conducted discussions with licensee personnel. The inspector concluded that although there was a failure to provide the sampling media, this appeared to be an isolated incident. The HP technician appeared to respond appropriately. There was no detectable intake of radioactive materials based upon the nasal smear. The lung count was timely, and indicated that there was no uptake of radioactive materials. Further, the licensee counseled the HP technician, and retrained him on the importance of ensuring that the breathing zone air sample head was properly prepared for use. The inspector had no further concerns in this area.

The inspector met with the individual on June 17, 1988 and informed him of the results of the review. The worker had no further concerns at that time.

9.3 Use of Respirator With Facial Hair The individual stated that work was performed on an electrical motor in the bottom of the milling hood. This job required an RWP and a respirator, but the individual performin wear the respirator without being cleanshaven. g the work was permitted to The inspector reviewed the RWP for this activity, the licensee's procedures for respiratory protection, and interviewed the HP

D 11 technician covering the job. The HP technician who covered the job stated that the individual who wore the respirator was clean-shaven in the sealin his neck. g surface of the respirator, but had not completely shaved The inspector could not substantiate the use of respirators without being clean-shaven in the facial sealing area. The inspector communicated this information to the individual who expressed the concern on June 17, 1988, prior to the exit interview.

10.0. Exit Interview The inspector met with licensee representatives (indicated in Paragraph 1) at the conclusion of the inspection on June 17, 1988. The inspector summarized the scope and findings of the inspection.

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. ATTACliMENT 1 Comaus': ion Encineerinc \uc ear r ue Vanu"ac':urinc i Orcaniza:iona. Overview l

Jr. 3. _. V cGi Vice 3resicent Nuc ear r ue A. E. Scherer Director Nuclear Ucensing F. M. Stern i Vice President Nuclear Fuel Manufacturing 1

P. R. Rosenthal C. R. Waterman J. A. Rode M n ger L. N. Grossman '

Plant Manager Plant Manager Director Rod. nd.

Windsor Facility Hematite Facility Man. Technology gd