ML20151Y844

From kanterella
Jump to navigation Jump to search
Notification of 880803 Meeting W/Licensee in King of Prussia,Pa to Discuss Deficiencies in Facility Radiation Protection,Transportation & Matl Controls from Insp Repts 70-1100/88-05 & 70-1100/88-06
ML20151Y844
Person / Time
Site: 07001100
Issue date: 07/26/1988
From: Roth J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20151Y837 List:
References
NUDOCS 8808290059
Download: ML20151Y844 (44)


Text

n

, jq p U ul 5

l

. ENCLOSURE 1 No.88-118 .

U.S. NUCLEAR REGULATORY COMMISSION I REGION I l NOTICE OF LICENSEE MEETING l Name of Licensee: Combustion Engineering, Inc.

Windsor, Connecticut Docket No.: 70-1100 Time and Date of Meeting: August 3, 1988; 11:00 a.m.

Location of Meeting: USNRC, Region I 475 Allendale Road, King of Prussia, Pennsylvania Purpose of Meeting: Enforcement Conference to discuss the licensee's deficiencies in the facility Radiation Protection, Transportation, and Material Control and Accountability Programs and Management Controls identified during Inspection Nos.

70-1100/88-05 and 70-1100/88-06. In addition, the status of the licensee's actions to correct deficiencies identified during Inspection Nos.

70-1100/87-05 and 70-1100/88-03 will also be discussed.

NRC Attendees: William T. Russell, Regional Administrator Stuart D. Ebneter, Director, Division of Radiation Safety and Safeguards Jay M. Gutierrez, Regional Counsel Daniel J. Holody, Enforcement Officer Ronald R. Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch Walter J. Pasciak, Chief, Effluents Radiation Protection Section Mohamed M. Shanbaky, Chief, Facilities Radiation Protection Section Mary Jean A. Gresick, Radiation Specialist George H. Bidinger, Licensing Project Manager, NMSS Leland C. Rouse, Chief, Fuel Cycle Safety Branch, NMSS I Jerome Roth, Project Engineer l

l l

l 8808290059 880S18 PDR ADOCK 07001100 C PDC l

O i 1

Licensee Attendees: Dr. P. L. McGill, Vice President - Nuclear Fuel i F. Stern, Vice President - Nuclear Fuel l Manufacturing '

A. E. Scherer, Director, Nuclear Licensing C. R. Waterman, Plant Manager, Nuclear Fuel  ;

Manufacturing - Windsor P. R. Rosenthal, Manager, Radiological and Industrial Safety J. F. Conant, Manager, Nuclear Material Licensing G. H. Chalder, Senior Staff Consultant Note: Attendance by NRC personnel at this meeting should be know by 3:45 p.m..

August 2, 1988, via telephone call to Region I at FTS 346-5205.

Prepared by: 3 J th, Project Engineer' Victor Stello, Jr., Executive Director for Operations James M. Taylor, Deputy Executive Director for Operations James Lieberman, Director, Office of Enforcement Hugh L. Thompson, Director, Office of Nuclear Material Safety and Safeguards Richard Cunningham, Director, Division of Fuel Cycle, Medical and Academic and Commercial Use Safety, NMSS Glen Sjoblom, Deputy Director, Division of Fuel Cycle, Medical and Academic and Coninercial Use Safety, IMSS Leland C. Rouse, Chief, Fuel Cycle Safety Branch, NMSS Jack Goldberg, Office of General Counsel Public Document Room (PDR) local Public Document Room (LPDR) i

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

SUMMARY

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

P. O. 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 Nos. 70-1100/88-05 and 70-1100/88-06 Introduction An Enforcement Conference was held at the NRC Region I office on August 3, 1988 at 11:00 A.M. The meeting was requested by the NRC Region I Staff to discuss 8 apparent violations in radiological controls, transportation and material control (measurements) and the status of actions taken to correct the items identified in Inspection Report Nos. 70-1100/87-05 and 70-1100/88-03.

NRC Attendees S. D. Ebneter, Director , DRSS, RI J. Gutierrez, Regional Counsel, RI R. Bellamy, Branch Chief, EP&RDB, RI M. Shanbaky, Chief, Facilities Radiation Protection Section, RI W. Pasciak, Chief, Effluents Radiation Protection Section, RI D. Holody, Enforcement Officer, RI J. Roth, Project Engineer, RI J. Gresick-Cioffi, Radiation Specialist, RI L. C. Rouse, Chief, Fuel Cycle Safety Branch, NMSS G. H. B1dinger, Licensing Project Manager, NMSS Combustion Engineering Attendees P. McGill, V.P. Nuclear Fuel, C.E., Inc.

A. E. Scherer, Director, Nuclear Licensing, C.E., Inc.

P. Rosenthal, Manager, Radiological and Industrial Safety, C.E. , Inc.

R. Bell, Council, C.E., Inc.

T' O

8 Enclosure 2 i Summary

1. The licensee acknowl. edged the apparent violations identified in the subject inspection reports, and presented their plan to correct these violations and prevent their reoccurrence.
2. The licensee presented a status report on their actions to correct the violations identified during Inspection Nos. 70-1100/87-05 and 70-1100/88-03. In addition, the licensee presented information concerning plans to conduct an internal assessment of the status of compliance with federal regulations (NRC, EPA, OSHA and DOT).
3. The licensee presented long-term actions planned to upgrade the manufacturing operation and the radiation protection program.

Details of the licensee's presentation appear as Enclosure 3.

I 5

1 ENCLOSURE 3 WINDSOR NUCLEAR FUELS MANUFACTURING FACILITY ENFORCEMENT CONFERENCE REGION I 0FFICE AUGUST 3, 1988

, 3-COMBUSTION ENGINEERING, INC.

WINDSOR, C0fitlECTICUT

AGENDA AUGUST 3, t988 ENFORCEMENT CONFERENCE

l. INTRODUCTION A.E. SCHERER ll. OVERVIEW P.L McGill INDEPENDENT ASSESSMENT FACIUTIES MODERNIZATION 111. C-E RESPONSE TO NRC FINDINGS C.R. WATERMAN IV. COMMITMENT STATUS P.R. ROSENTHAL l

V. - ORGANIZATION OVERVIEW & F.M. STERN QUAUTY IMPROVEMENT PROGRAM i

l l

l


4----.._-.,..-- _-,- _ m _--,---._____---w-,,---,-m--,e,-e----usp

I APPARENI VIOLATION 1 FAILURE 10 FOLLOW THE REQUIREMErJTS OF RADIATION WORK PERMIT (ITEM 2-B)-

BACKGROUND UPGRADING OF A POTENTIALLY COf4T AMI f4ATED SYSTEM WAS BEING ACCOMPLISHED BY Ari Ot T S I DE CONTRACTOR-A RADIAT10tJ WORK PERMIT WAS ISSUED COVERItJG THIS WORK AS REQUIRED BY SECTION 3-1-1 0F LICENSE SNM-1067 lHE RADIATION WORK PERMIT REQUIRED Tile USE OF RUBBER GLOVES-lHE WORKERS WERE OBSERVED HAtJDLING THE POTEtJTIALLY C0f4TAMINATED PARTS WITHOUT RUBBER GLOVES-

=_ ~ . -

^

o APPARENT VIOLATION 1 FAILURE TO FOLLOW THE REQUIREMENTS OF RADIATION WORK PERMIT (ITEM 2 B).

RESPONSE

CE ACCEPTS THE VIOLATION.

CORRECTIVE ACTION IHE WORY, WAS IMMEDIATELY STOPPED AND THE CONTRACT WORKERS WERE DIRECTED TO LEAVE THE PELLET SHOP.

IHE CONTRACT WORKERS WERF SURVEYED BY A IIEALTH PHYSICS TECHNICIAN AND HAD NO DETECTABLE C0hTAMINAT10N ON THEIR BODIES-IHE CONTRACT WORKERS WERE REINSTRUCTED ON THE ABSOLUTE NECESSITY TO FOLLOW IHE INSTRUCTIONS OF RWPS AND ALL OTHER PROCEDURES.

lHE PRESIDENT OF THE CONTRACTING COMPANY WAS TELEPHONEG AND INFORMED OF THE INCIDENT AND OF THE IMPORTANCE OF PROPERLY INSTRUCTING HIS PEOPLE ON THE ABSOLUTE NECESSITY TO FOLLOW OUR PROCEDURES-INSTRUCTED ALL HEALTH PHYSICS TECHNICIANS TO INSURE THAT ALL WORKERS UNDERSTAND AND COMPLY WITH THE REQUIREMENTS OF A RWP PRIOR T0' ALLOW-ING THE WORKERS TO START WORK-REVIEWED THE MODIFIED GENERAL EMPLOYEE TRAINING PROGRAM AND DETERMINED THAT MORE EMPHASIS WAS PLACED ON THE USE AND COMPLIANCE WITH RWPS.

APPARENI VIOLATION 2 FAILURE 10 POST ALL DOCUMENTS, TJOTICES OR FORMS P U R S U A t4 T TO 10CFR19-11 Ita A SufflCIErJT T4 UMBER OF PLACES TO PERMIT 1 tJ D I V I DU A L S E tJ G A G E D IN LICENSED ACT-IvillEs to OBSERVE THEM Ori THE WAY TO OR FROM THE LICENSED ACTIVITY LOCATION (ITEM /-C).

BACKGROUND WokK COVERED BY LICEriSE SNM-1067 IS CONDUCTED IN TiiE NUCLEAR LABORATORY FACILITIES I t1 Bu l L D i rJ G S WHICH IS SEPARATE FROM THE Malta MANUFACTURING FACILITIES AT hu l L D i rig 17-IliE POSTING REQUIREMENTS OF 10CFR19 ll WERE MET BY POSTING REQUIRED t r4 F O RM Al l otJ I f4 TWO LOCAT10t4S IN bulLDING 5, THE MAIN (EAST) ENTRANCE A fiD l ti Tile T10 R T ii E R t1 MOST EAST / WEST CORRIDOR-

APPARENT VIOLATION 2 FAILUHE 10 POST ALL DOCUMENTS, tJOTICES OR FORMS PURSUANT TO 10CFR19-ll IN A SUFFICIENI NUMBER OF PLACES TO PERMIT INDIVIDUALS ENGAGED I fl LICENSED ACT-IvlTILS 10 OBSERVE THEM ON THE WAY TO OR FROM THE LICENSED ACTIVITY LOCATION (ITEM 7-C)-

RESPONSE

Cl ACCEPTS THE VIOLATION-CORRECIIVE ACTION A REVIEW OF BUILDING 5 ACCESS POINTS WAS CONDUCTED AND FIVE ADD 1IIONAL AREAS WERE IDdNTIF1ED FOR POSTING DOCUMENTS PURSUANT 10 10CFR19

  • IHE DOCUMENTS AND NOTICES REQUIRED TO BE POSTED PURSUANT TO 10CFR19 ll HAVE BEEN POS1ED AT ALL LOCATIONS IDENTIF1ED ABOVE-All i f1 D I V I D U A L HAS BEEF 4 APPolNTED TO BE RESPONSIBLE FOR MAINTAINING IHE5E P O S T I (4 G S Irl BUILDING S-AN If1DIVIDUAL HAS BEEN APPOINTED TO BE RESPONSIBLE FOR MAINTAINING ALL POSTINGS PURSUANT TO 10CFR19-ll IN ButtDING 17/21

. .~

APPARENT VIOLATION 3 & 4 FAILURE 10 PROPERLY LABEL WASTE CONTAINERS IN ACCORDANCE WITH 49CFR172 403 Af4D FAILURE TO PROVIDE THE APPROPRIATE INFORMATION C0f4CERNING THE PROPER S ti l P P l f4 G NAME ATJD HAZARD CLASS Oft THE WASTE MAfilFEST FORMS (ITEM 3-C-2).

BACKGR0llND A WASIL PACKAGE MUST C 0 fi T A I N LE3S Til AN 5 GRAMS OF SNM IN ANY 10 LITER votuME 10 BE LABELED LSA-litL (( PROCEDURES UllLIZED FOR DETERMINING THE SPECIFIC C0f4 CENTRATION of 51'ECIAL fiUCLEAR MATERIAL IN AfiY 10 LITER VOLUME UTILIZED Af4 AVER- .

A G i r1G t'ROCESS OVER TiiE E f4 T I R E VOLUME OF THE B25 SHIPPlf4G CONTAINER.

Nii 3 G L l81 E FILIER BOXES I fl TliE B25 SHIPPING CONTAINERS CONTAlf4ED GREATER l il A fd ') GRAMS OF SNM PER 10 LITER VOLUME-litt li25 Sill PP i tlG CONTAINERS WERE IMPROPERLY LABELED LSA.

liu WASlE M A fi l F L S I FORMS l ii E R E F O R E DID fl0T LIST THE PROPER SHIPPING T4AME Af4D itAZARD CLASS.

s

APPARENI V10LAl10N 3 & 4 ,

FAILURE TO PROPERLY LABEL WASTE CONTAINERS IN ACCORDANCE WITH 49CFR172 403 AND FAILURE TO PROVIDE THE APPROPRIATE INFORMATION CONCERNING THE PROPER SHIPPING NAME AND liAZARD CLASS ON THE WASTE MANIFEST FORMS (ITEM 3-C-2). .

. RESPONSE CE ACCEPIS THE VIOLATION-CORRECTIVE ACrioN IHE PROCEDURE FOR LSA SHIPMENTS HAS BEEN CHANGED AND REQUIRES ALL l'ACK AGES WI TH !N A CONTAINER NOT EXCEED-5 GRAMS OF U235 IN A 10 LITER VOLUME ALONG WITH ALL OT*iER REQUIREMENTS FOR LSA SHIPMENTS-CHANGED THE PROCEDURE FOR MEASURING THE U235 CONTENT OF ABSOLUTE FILTERS TO REQUIRE RECLEANING OF THE FILTERS TO GET THE U235 CONTENT LESS THAN 56 GRAMS AND IF THIS CONDITION IS NOT SATISFIED THE FILTER WILL BE LABELED WITH THE PROPER RADIOACTIVE NATERIAL f!SSILE CLASS.

APPARENI VIOLATION 5 FAILURE TO MEASURE URANIUM Ar4D U235 Of4 ALL WASTE DISCARDS AS SPECIFIED IN SEClion 4-2 1 0F lHE NRC APPROVED FNMCP (! TEM 4).

HACKGR0tlND IHE 1:UNDAMENTAL NUCLEAR MATERIAL CONTROL PLAf1 (FNMCP) REQUIRES MEASURE-M E f41' S Of ALL WASTE SHIPMEtiTS POTENTIALLY CONTAIN!f4G SNM-COMPACllBLE SHOP TRASH AND USED FILTERS ARE MEASURED 10 DETERMINE THE UU Af411 T Y OF U235 PRESEf1T PRIOR TO SHIPMEf4T-Nord COMPACl l blE MATERIALS SUCH AS SPRINGS, TUBING, BRICKS, DUCTWORK, EIC- WERE f401 MEASURED-

APPARENT VIOLATION 5 FAILURE TO MEASURE URAfJIUM Af1D U235 Of1 ALL WASTE DISCARDS AS SPECIFIED IN SECTiofJ fi-2-1 0F THE NRC APPROVED FNMCP (ITEM 4)-

RESPuNSE

_ CL ACCEPTS THE V10LAT10fd-CORRECTIVE ACTIOfJ llE L D LH' Sil l PM E fJ T OF ALL C 0f1 T A l fJ E R S THAT C 0 f: T A l f1 fl0fJ COMPACTED WASTE-MEASUREMEflT MEIHODS FOR NGtJ COMPACIED WASTE ARE B E I fig DEVELOPED AfJD THESE MEASUREMEllT METHODS WILL BE USED TO DETERMifJE THE AMOUNT or U255 IN THL NON COMPACTED WASTE PRIOR TO THEIR B E l f4G SHIPPED OFF S!fE-IHE f fjMCP WILL BE REVISED 10 !f4CLUDE THESE MEASUREMEfJT METHODS-

APPARENT VIOLAT10N 6 MEASUREMEt4fs GF U235 WERE USED THAT WERE OUTSIDE THE CALIBRATED RANGE OF THE ME ASUREME rd i SYSTEM CONIRARY TO THE REQUIREMENTS SPECIFIED IN THE FNMCP A rJrd E x , S E C T l o tJ ll-1-3 (ITEM II )-

BACKGRullNI) lHE IUMll' REQUIRES TH/ " MEASURED VALUES OUTSIDE THE CAllBRATION RANGE of A DEVICE tJ O I BE USED-lHE C AL I BR AT I ori RAfJGE OF THE IJ 0 f4 DE S T RU C T I V E ASSAY DEVICE FOR MEASURING U 2 5 5 C ofJI ErJT OF ABSOLUTE FILTERS WAS 0 To 90 GRAMS-R E A D I tJ GS OF GREATER THAfJ 90 GRAMS WERE USED-

APPRAfNI VIOLATION 6 M E A s u l< E M E f4 T S OF U235 WERE ijsED THAT WERE OUTSIDE THE CAllBRATED RAfdGE OF THE MEASUREMErJT Afaf4E X , SECTION 11 SYSTEM C of41 1 3 (lTEM 11 ) R- A RY TO THE REQUIREMENTS SPECIFIED IN THE FNMCP

RESPONSE

(( ACCLPIS T ilE VIOLAl10N-CORRf.C11VE ACI!Of4 NElfibTRUCTED ALL P E R S 0 !Jf4E L Wilo ASSAY FILTERS Off THE REQUIREMEf4TS OF THE FNMCP.

l'il Af4GE D T HE PROCE!)GRE FOR ASSAY OF FILTERS CGNTAMINATED WITH U235 10 NOI USE MEASlJREMEf4TS OUTSIDE THE RANGE OF IllE CALIBRAT10ft STANDARDS USED-

APPARENI VIOLATION 7 FAlt:Jkt IG LVALUATE THE P'lESENCE OF RADIOACTIVE MATERIAL ON MATERIAL BEING COMPACILD A flD SAMPLE ThE r. l i< DG ri l N G lilE COMPACTING OPERATIOtt (ITEM 5-5).

BACKGROUND l ttE OPE RA T I Of4 OF THE TRASH COMPACTOR HAD BEEF 4 E VA L LI A T E D I f4 THE PAST U S i rJ G A tilGH VOLUME AIR SAMPLER Af4D A DETERMINATION WAS MADE THAT f40 A D D I l l O rJ AL VEfillLATION C O f4 T R O L S WERE REQUIRED FOR OPERATION OF THE U f41 I - NO DOCUMENTATION OF THESE EVALUATIONS HAS BEEN FOUND-

O APPARENI VIOLATION 7 FAILukE TO EVALUATE TliE PRESEfJCE OF RADIOACTIVE MATERIAL Of4 MATERIAL BEING COMPACTED AIJD SAMPLE T ilE AIR DU R l rJ G T iiE COMPACTIrJG OPERATIOrd (lTEM 5.5).

RESPONSE

_ [L ACCEPIS Tale V I OL Al 10f4 -

CORRECTIVE ACTION IMMEDIATELY REQU: RED 1HE COMPACT!!JG OPERAT10f4 BE COVERED BY AN RWP Will Cit I !J C L U D L S Tite REQUIREMEf4T Ilf AT Tile OPERATOR WEAR A LAPEL AIR SAMPLER.

I tt E OPERAllON OF THIS UNII IS BE l rJG EVALUATED TO DETERMitJE IF VENTIL-A l l OfJ M0DI F li AT IOf4 WiLL IMPitOVE THE OPERATION W I Til RESPECT TO ALARA C o f4 5 I D E R A T I O fA S -

m

APPARENT VIOLATION 8 FAILURE IO 's u P I'L Y I f4D I UM Folt BADGES TO ALL VISITORS TO THE PELLET SHOP AS REQUIRED BY S UI'l L I C E fJS E 1067, Pt.RT 11, SECT 10f4 4 9 (ITEM 5-7).

IIACKGROUND

1. i C L f 4 5 E 1007 REQUIRES ALL VISITORS TO HAVE I flD I U M FOIL Of4 THEIR BADGES-Uf4 DER CERTAlfd COf4DI T I ONS VISITORS COULD GAlf4 ACCESS TO THE SITE WITHOUT I f4 D I U M FO!L Of4 IHEIR BADGES-

APPARENT V101.A110tl 8 FAILURL 10 SUPPLY IfdDIUM F0ll HADGES TO ALL VISITORS TO THE PELLET SHOP AS REOUIRED !!Y ShM LICEf4SE 1067, PART ll, SECTIOf4 14-9 (ITEM 5-7)-

RESPONSE

CE ACCLPIS Tile V 1 0 L A T 1 0 fJ -

CORRECTIVE ACT10f4 I llE GUARD FORCE WAS If4STRUCTED TO NOT ALLOW AflY Of4 E INTO THE FACILITY W I Til0 U T Ali INDIUM F0ll O f4 EllHER TiiEIR IDEf4TIFICATION BADGE OR ll0-If4DIUM F0ll HAS BEErd ADD.D TO ALL I D E f4 T I F I C A T I O f4 BADGES-

i

  • e l

I i

I n

N E

w

>=

me

% mar N

e Z

4 Cll1 2

J C

+

2 O

U LJ J J

U CC C

=

?

I

)

t

4

  • I

(

l A

N E

w

>=

.-.=

V C

2 W

33 J

W 2

2 O

U I

t i

l I

r l

  • a a -

I

. 4 1

1 I

e, l

i V

e N

E uJ H

V 2

L.J E

c.

Go J

LM

l3 LL.

.I 6

f 4

_ . _ _ . , . _ , , _ , _ _ _ . . _ , c. .__.. , _ ,__-.. ., _ _ _ ,,,. _,, .. , ,_m , .,_ ,.--,, , .m ,, ..- , _ , .._,_. ,, _ ,

)

a 3

M E

T I

(

S R

E N

I A

T N

O C

G N

I P

P l

l i

S G

N I

M O

C N

I N

O S

L E

V E

L N

O I

T A

N I

M A

I N

O C

D E

S A

E R

C N

I

l

! llIll l

)

5 5

M E

T I

(

M A

R G

O R

P L

O R

T N

O C

N O

I T

A N

I M

A T

N O

C F

O S

S E

N E

V I

T C

E F

F E

I 9

i CORRECTIVE ACTIONS

- PROCEDURES AND PRACTICES

- TRAINING

- HUMAN RESOURCES

- PROCESS AND EQUIPMENT i

l l

1 J

't 4

i 4

l L

_, __ _. .__ _ _ . . _ . . . _ _ . _ _ _ _ . _ . _ _ . _ _ . _ _ _ , , _ _ _ . , _.__ _ __,_, _ ,_ _ _ _____ _ _ _ ,...r __ _ _ _ ., . _ _ . , _ _ _ , _ _ . .

PROCEDURES AND PRACTICES 01UECTIVE TO ENSURE THAT ALL PLANT OPERATIONS AND PERSONNEL PROTECTION PROGRAMS ARE PERFORMED CONSISTENTLY AND IN ACCORDANCE WITH REGULATORY AND OTHER REQUIREMENTS.

RADIATI0i1 PROTECTION

- WE-HAVE-RETAf NEB-A-86NSubTANY-(RABtAVf 0N-SAFEYY-AsseetATEs-INea-ve-NeR,(-wiTH US-Y8:

22 REVIEW THE ADEQUACY OF OUR EXISTING WRITTEN PROCEDURES p Procedures 7.dentified to be written or rewritten UPGRADE EXISTING PROCEDURES WHERE NECESSARY 22 g Now in Draft DEVELOP NEW PROCEDURES WHERE REQUIRED PROVIDE A COMPLETE RADIATION PROTECTION MANUAL

- THIS PRQQgg@)

PERMIT HAS BEEN COMPLETED FOR RESPIRATORY PROTECTION AND RADIATION WORK (KWr PROCEDURES.

- REMAINING PROCEDURES WILL BE COMPLETED BY JUNE 30, 1988. 4th Quarter 1988 THE RADIATION PROTECTION MANUAL WILL FORM THE BASIS FOR TRAINING HEALTH PHYSICS AND SHOP PERSONNEL.

COMBUSTION ENGINEERING, INC.

WINDSOR, CONNECTICUT NUCLEAR FUEL MANUFACTURING - WINDSOR RADIO 14GICAL PRMBCTION INSTRUCTIONS

-RPI Title Number 1 Whole Body Exposure 2 Monitoring for Skin Exposure 3 Extremity Monitoring 4 Radiation Work Permits 5- Dosimetry Program-Windsor 6 Radiological Control Areas 7 Internal Exposure Control 8 Bioassay Program 9 Monitoring for Radiation & Contamination 10 Protective Clothing 11 Ventilation System Monitoring 12 Monitoring Visitor Exposure 13 Transportation of Radioactive Material 14 Monitoring for Airborne Contamination 15 Stop Work Order 16 Respiratory Protection Program 17 Criticality Control IS Packaging and Shipping of Dry Activated Waste 19 Environmental Monitoring Program 20 Radiation Workers Training Program 21 On Site Transfer of Radioactive Materials 22 Instrument Calibration

~

PROCEDURES AND PRACTICES nRIFETIVE TO ENSURE THAT ALL PLANT OPERATIONS AND PERSONNEL PROTECTION PROGRAMS ARE PERFORMED CONSISTENTLY AND IN ACCORDANCE WITH REGULATORY AND OTHER REQUIREMENTS.

_BADIATI0d PROTECTION

- WE-HAVE-REYAtNEB-A-88NsubfANT-(RADtAVf8N-8AFETY-Ass 8etATes-INe d-T8-W8RK-WtTH US-Y8:

22

! REVIEW THE ADEQUACY OF OUR EXISTING WRITTEN PROCEDURES A Procedures identified to be written or rewritten UPGRADE EXISTING PROCEDURES WHERE NECESSARY) 22 l g Now in Draft i

DEVELOP NEW PROCEDURES WHERE REQUIRED l

PROVIDE A COMPLETE RADIATION PROTECTION MANUAL l

- THIS PRQQQp HAS BEEN COMPLETED FOR RESPIRATORY PROTECTION AND RADIATION WORK PERMIT (KWF) PROCEDURES.

- REMAINING PROCEDURES WILL BE COMPLETED BY JUNE 30, 1988. 4th Quarter 1988

- THE RADIATION PROTECTION MANUAL WILL FORM THE BASIS FOR TRAINING HEALTH PHYSICS AND SHOP PERSONNEL.

4

~

PROCEDURES NtB PRACTICES (CONT'D)

SHOP OPERATIONS

- WRITTEN PROCEDURES (INSTRUCTIONS) HAVE BEEN ISSUED TO SHOP PERSONNEL FOR CONTAMINATION CONTROL.

Completed 12/87

- ADDITIONAL PROCEDURES (INSTRUCTIONS) TO SHOP PERSONNEL WILL BE DEVELOPED TO ADDRESS REMAINING RADIATION PROTECTION REQUIREMENTS.

22

Will be completed concurrently with X procedures about 4th Quarter 1988

- SHOP PROCEDURES WILL BE USED TO PREPARE LESSON PLANS FOR PERSONNEL TRAINING.

INTERNAL AUDITS I

- A PROCEDURE HAS BEEN IMPLEMENTED TO PROVIDE FOR INDEPENDENT QUARTERLY AUDITS OF THE RADIATION PROTECTION PROGRAM AND PRACTICE.

Implemented 12/87 s

TRAlllING OBJECTIVE TO ENSURE THAT PERSONNEL AT ALL LEVELS KNOW AND UNDERSTAND THE DUTIES AND RESPONSIBILITIES CF THEIR JOBS AND THE NEEDS AND PURPOSES OF PROTECTIVE PROCEDURES.

TRAINIiiG OF HP STAFF RESPIRATORY PROTECTION COURSE (0CTOBER 1987) co.plete and ongoing RADIATION WORK PERMIT (DECEMBER 1987) complete and ongoing RADIATION SAFETY OFFICER COURSE (DECEMBER 1987) co.plete TRAINING IN REMAINING RADIATION PROTECTION PROCEDURES (COMPLETE IN SEPTEMBER 30,1988).

4th Quarter 1988 IIP staff has been trained in old .anual will be retrained in new m nual.

i

. t TRAINING L'

TRAINING OF SHOP PERSONNEL

- IRAINING IN RESPIRATORY PROTECTION COMPLETED NOVEMBER 1987. co.plete and Ongoing

- TRAINING IN CONTAMINATION CONTROL COMPLETED NOVEMBER 1987. co prete ana ongoing

- UPGRADED EMPLOYEE TRAINING PROGRAM COMPLETE BY SEPTEMBER 30, 1988 -

4th Quarter 10 X TRAINING MODULES IDENTIFIED 3 X MODULES WRITTEN 2 MODULES GIVEN

TRAINING COORDINATOR NUCLEAR TRAINING DEPARTMENT

0, TRAINING GENERAL EMPLOYEE TRAINING - INTERIM GENERAL EMPLOYEE TRAINING - flNAL HEALTH PHYSICS IECHNICIAN IRAINING "FITNESS FOR DUTY" IRAINING (SHOP SUPERVISGRY PERSONNEL)

. \

GENERAL EMPLOYEE TRAINING - INTERIM OBJECTIVE: litiEDIATELY DEVELOP AND IMPLEMENT AN ItE)DCBINATION PROGRAM FOR NEW PERSONNEL WHICH, AS A MINIMLN, SATISFIES EXISTING REGULATORY GUIDANCE AND LICENSE REQUIREMENTS FOR GENERAL E?PLOYEE TRAINING STATUS: -

PROGRAMIMPLEMENTEDFORNEWPERSONNELEFFECTIVEJULY 13,1988 REQUIREDTRAININGFORACCESSTOALLBLDG.17/21AREASEXCEPTPELLET SHOP INCLUDES:

1. SAFETY, SECURITY & EMERGENCIES
2. RADIATION WORKER RIGHTS & RESPONSIBILITIES
3. RADIATION PROTECTION FUt0AMDiTALS
4. CRITICALITY SAFETY ADDITI0tML TRAINING FOR PELLET SH3P ACCESS INCLUDES:
1. RADIATION WORK PERMITS
2. PERSONAL CONTAMINATION MONITORING 8 CONEOL
3. BREATHING 20f4E AIR SAMPLERS
4. RESPIRATORY PROTECTION i

SATISFACTORY COMPLETION OF ALL TRAINING AREAS IS ASSURED At0 DOClfEiTED BY WRITTEN EXA'ilNATIONS e

GENERAL EMPLOYEE TRAINING - FINAL OBJECTIVE: DEVELOP AND IMPLEMENT A PERMANENT GD4ERAL EMPLOYEE TRAINING AND RETRAINING PROGRM FOR ALL NFM PERSONNEL WHICH SATISFIES ALL FACILITY NEEDS INCLUDING, BUT NOT LIMITED TO, REGULATORY GUIDANCE AND FACILITY LICENSE REQUIREMENTS STATUS: DETAILED CONTENT OUTLINES DEVELOPED AND VALIDATED FOR ALL AREAS:

1. ORGANIZATION 8 ADilNISTRATION
2. FACILITY / PROCESS O'ERVIEW
3. QUALITY CQ4 TROL
4. PLANT SECURITY
5. If0VSTRIAL SAFETY
6. RADIOLOGICAL FUt044ENTALS
7. CRITICALITY SAFETY
8. EMERGENCY PLNiNING 8 PREPAREDNESS
9. RADIATION PROTECTION FOR RADWORKERS
10. RESPIRATORY PROTECTION LESSON DEVELOPMENT IN PROGRESS) CURRENTLY SCHEDULED FOR CCt4PLETION BY8EPTEMBER 30,1988 CURRENT TARGET DATE FOR IMPLEMENTATION FOR NEW PERSONNEL: 10/1/88 EXISTING PERSONNEL TO BE RETRAINED IN ACCORDANCE WITH NEW PROGRAM INTHEFOURTHQUARTER1988 l

l l

l

. HEALTH PHYSICS TECHNICIAN TRAINING OBJECTIVE: PROVIDE UPGRADED TRAINING FOR ALL FACILITY HP PERSONNEL, TO INCLUDE BOTH ACADEMIC FUNDAMENTALS AND PLANT SPECIFIC RADIOLOGICAL CONTROLS PROCEDURES STATUS: -

FACILITY HP&S SUPERVISOR HAS COMPLETED RADIATION SAFETY OFFICER COURSE CONDUCTED BY CONSULTANT (RSA)

IN-HOUSE HP TECHNICIANS HAVE COMPLETED:

o TRAINING COURSE IN RADIATION SCIENCE ACADEMIC FUNDAMENTALS CONDUCTED BY CONSULTANT (RSA) o ADDITIONAL TRAINING IN APPLIED HEALTH PHYSICS CONDUCTED BY CE RADIATION PROTECTION SERVICES GROUP OTHER PERSONNEL (PSES1) QUALIFIED TO SENIOR HP TECHNICIAN LEVEL PER ANSI /ANS 3.1 GUIDELINES ALL HP TECHNICIANS HAVE COMPLETED RETRAINING IN CURRENT SH0r HP PROCEDURES AND PRACTICES CONDUCTED BY HP&S SUPERVISOR

- LONG TERM PLANS INCLUDE DEVELOPMENT /lMPLEMENTATION OF FORMAL, STANDARD 12ED INITIAL TRAINING AND RETRAINING PROGRAMS FOR ALL HP PERSONNEL

"FITNESS FOR DUTY' TRAINING FOR 5 HOP SUPERVISORY PERSONNEL OBJECTIVE: CONDUCT TRAINING FOR ALL SHOP SUPERVISORY PERSONNEL WHICH WILL ENABLE THEM TO MORE EFFECTIVELY RECOGN!ZE AND DEAL WITH POTENTIAL DRUG /ALC0HOL RELATED PROBLEMS AMONG SHOP PERSONNEL STATUS: -

TRAINING BY CE NUCLEAR SECURITY SERVICES COMPLETED MAY,1988 FOR EXISTING SUPERVISORY PERSONNEL TRAINING FOR NEWLY HIRED / PROMOTED SUPERVISORY PERSONNEL WILL OCCUR WITHIN 90 DAYS OF SUCH ASSIGNMENT

---m- .

I O

~

HUMN RESOURCES E

i To PROVIDE AN ADEQUATE LEVEL OF QUALIFIED PERSONNEL TO MAINTAIN ALL PLANT OPERATIONS IN  :'

, COMPLIANCE WITH REGULATORY AND OTHER REQUIREMENTS.

I RADIATION PROTECTION PROVIDE FULL TIME HEALTH PHYSICS COVERAGE AT ALL TIMES IN THE PELLET SHOP (NOVEMBER 1987). Increased HP sta U RETAIN A QUALIFIED CONSULTANT TO ASSIST WITH P5tEPARATION OF RADIATION PROTECTION PROCEDURES AMD TRAINING PROGRAMS (OCTOBER 1987). Impie.ented

PROVIDE A 9UALIFIED INDIVIDUAL TO P{RFORM INTERNAL AUDITS OF COMPLIANCE WITH l RADIATION PROTECTION REQUIREMENTS (WUARTERLY BEGINNING IN 1988). Implemented l

3IEP QPERAT10NS l  ;

. 1 PROVIDE ADDITIONAL SUPERVISION IN THE PELLET SHOP TO ASSURE OPERATOR COMPLIANCE WITH CONTAMINATION CONTROL AND OTHER PROCEDURES. (DECEMBER 1987). Implemented ESQESS EEINEERING l i Paov!DE ADDITIONAL ENGINEERING SUPPORT IN THE PELLET SHOP TO IMPROVE  !

CONTAMINATION CONTROL OF PROCESS EQUIPMENT (DECEMBER 1987). Implementeo 1

l P1.AMI1 EQUIPMENT MAINTENANE PROVIDE PERSONNEL TO IMPLEMENT AN ONGOING PREVENTIVE MAINTENANCE PROGRAM FOR EQUIPMENT AND CONTAINMENT / VENTILATION SYSTEMS (APRIL 1988). Imp 1 ented

.-. _- - _ _ - . - . . - - - _ . - = . _ . . - - . - - _ - - . . . - ___ .=

PROCESS AND EQUIPMENT DBJECTIVE TO PROVIDE RELIABLE ENGINEERED SYSTEMS WHICH MAINTAIN MANUFACTURING OPERATIONS IN COMPLIANCE WITH REGULATORY AND OTHER REQUIREMENTS.

i i

i IMMEDIATE ACTIONS 1

UPGRAQE ONTAINMENT/ VENTILATION SYSTEMS ON EXISTING EQUIPMENT (OCTOBER 1987 -

JUNE 1986'). 90I complete will be complete by June completed MODIFY MATERIAL HANDLING SYSTEMS OUTSIDE CONTAINMENT (OCTOBER 1987 - JUNE 1988).

90% complete with complete by June Completed i -

IMPLEMENT PREVENTIVE MAINTENANCE PROGRAM (APRIL 1988).

Initiated January 1988 will be fully operational December 1988 i

LONGER TERM ACIl0RS A MAJOR SHOP UPGRADING PROJECT IS PLANNED OVER THE NEXT THREE YEARS.

. OTHER COMMITMENTS REVIEW PLANT OPERATING PROCED@ES FOR C0ffATIBILITY WITH APPROVED LICENSE APP,,1 CATION. "MKING NO LABELING OF f%SS-LIMITED CONTAINERS" I;m OUARTER LCM 8 WILL BE COMPLETED IN THE IITH :U MTER

. FERFORM AN EVALUATION TO DETERMINU IF ALTERNATE METHODS EXIST TMT WCtJLD ENSURE SAFE CRITICALITY LIMITS ARE NOT EXCEEDED FOR THE Mf4ERMILL HOOD ISTQUARTER1989 WILLBECOMPLETEDINISTQUARTER1989 INSTAU. CCtRINU0uS AIR l'bNITOR. AFTER RECEIPT OF ADDITIOfML B/Z SAMPLERS, INCORPORATE C@l No B/Z SATLERS IfRO INTERGRATED SYSTEM 3RDOUARTER1988 WILL BE CCt4PLETED IN 3RD QUARTEP 1988 u;%\DE B10 ASSAY PROGRAM:

- IN-VIVO CCOUlfG TWICE PER YEAR

- [1 GAL NO UR!fMLYSIS SATLING TWICE PER YEAR FOR THE HIGHEST 4 % OF PELLET SHOP WORKERS BASED ON IN-VIVO COUNTING FECAL NO (filfMLYSIS SATLING IFt4EDI ATELY FOR PERSONNEL JUSPECTED TO MVE RECEIVED AN INTAKE ABOVE QUARTERLY LIMITS.

r0LL0b+-UP WITH IN-VIVO COUNTING WITHIN FOUR WEEKS

!1THQUARTER1933-IMPLEMFJ4TED

PEVIOUS MJCLFAR RHS .

ORGANIZATION EXECUTIVE viCE PRESIDENT NUCLEAR POWER SYSTEMS S.T. BREWER ._.

CHAIRMAN NUCLEAR SAFETY COMMITTEE F.M. STERN VICE PRESIDENT NUCLEAR FUEL P.L. McGILL MANAGER QUALITY CONTROL M. CLCTZER I l l DIRECTOR DIRECTOR DIRECTOR FUEL ENGINEERING PROD. DEVELOPMENT NUC. FUEL PROJ.

J.R. PARRETTE R. DUNCAN W.C. COPPERSMITH PLANT MANAGER PLANT MANAGER HEMATITE FUEL WINDSOR FUEL MANAGER MANUFACTURING MANUFACTURING NUC. MATERIALS J.A. RODE G.H. CHALDER D.L PARKS 7_____________________

l i

MANAGER MANAGER NUCLEAR CRITICALITY MANAGER MANAGER NUCLEAR LICENSING

  • CONSULTANT MANUFACTURING ENC. PRODUCTION SAFETY, SECURITY FACILITIES R. G. KLOTZ P. HUB'iRT G. KERSTEEN AND ACCOUNTABILITY AND EQUIPMENT l R.E. SHEERAN 1. SKINNER SUPERVISOR HEALTH PHYSICS AND SAFETY J. VOLLARO

OEM OEANIZATION EXECUTIVE vlCE PRESIDENT NUCLEAR POWER '

SYSTEMS S.T.GREWER CHAIRMAN '

NUCLEAR SAFETY COMMITTEE W.D. MAWHINNEY VICE PRESIDENT NUCLEAR FUEL P.L. McGILL MANAGER DIRECTOR QUALITY CONTROL NUCLEAR LICENSING M. GLOTZER A.E. SCHERER I I I I vlCE PRESIDENT DIRECTOR DIRECTOR MANAGER DIRECTOR NUCLEAR FUEL PRODUCT N U RW. NUC. MATERIALS FUEL ENGINEERING MANUFACTURING DEVELOPMENT J.R. PARRETTE W.C. COPPERSMITH D.L. PARKS l F.M. STERN R.DUNCAN

< .t EW MX1 EAR RES MtFACRRING ORGANIZATION VICE PRESIDENT NUCLEAR FUEL MANUFACTURING F. M . STERN PLANT MANAGER PLANT MANAGER DIRECTOR SENIOR MANAGER STAFF CONSULTANT RADIOLOG: CAL AND HEMATITE FUEL WINDSOR FUEL MANUPACTURING NUCsR NEL INDUSTRIAL SAFETY MANUFACTURING MANU FACTURING TECHNOLOGY P.R. ROSENTHAL J.A. RODE C.R. WATERMAN L.14 GROSSMAN C C LD R l _ _ _ _ _ _ __ _ __ _ __ q _

l I ._

SU PERVISOft MANAGER MANAGER

^ MANAGER

" ' ' HEALTH PHYSICSENG. MANUF/^TURING FACILITIES ACCOUNTABILITY C NSULT PRO CTI N AND SAFETY ENGil'GRING AND EQUIPMENT G. KEF VEEN AND SECURITY R. G.. KLOTZ J. VOLLARO P. HuthEPT l. SKINNER R.E. SHEERAN 1 ,

.-