ML20155F091

Discusses Enforcement Conference on 880510 Re Insp Rept 70-1100/88-03 & Forwards Meeting Summary & Notice of Violations.Violations Symptomatic of Same Underlying Deficiencies Noted in Late 1987 Re Radiation Protection

ML20155F091
Person / Time
Site:	07001100
Issue date:	06/06/1988
From:	Sjoblom G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
Shared Package
ML20155F095	List: ML20155F091 ML20155F107
References
EA-88-127, NUDOCS 8806160287
Download: ML20155F091 (29)

Text

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JUN 0 61988 Docket No. 70-1100 EA 88-127 Combustion Engineering, Inc.

ATTN: Dr. P. L. McGill Vice President - Nuclear Fuel Manufacturing l Nuclear Power Systems 1000 Prospect Hill Road Windsor, Connecticut 06095-0500 Gentlemen:

Subject:

NOTICE OF VIOLATION AND ENFORCEMENT CONFERENCE REPORT (NRC Inspection Report Number 70-1100/88-03 On May 10, 1988, an Enforcement Conference was held at the NRC Region I office with yot. and niembers of your staff to discuss apparent violations of nuclear criticality safety requirements at your Windsor Nuclear Fuel Manufacturing facility.

l The violations were identified during an inspection conducted on February 29 -

l March 4 and March 28-31, 1988. The inspection report was sent to you on April 21, 1988.

The enforcement conference was conducted to discuss (1) your position with respect to the inspection findings and apparent violations, the causes of the violations, and the short and loag-term corrective actions taken or planned in the criticality safety area; and (2) the status of corrective actions described in your letter dated February 23, 1988 concerning radiological safety controls at the Windsor facility. The Enforcement Conference Report is enclosed. During the conference, you contested some of the violations set forth in the inspection report. The NRC has reevaluated these violations based on the information pro-vided at the conference, and has determined that seven of the eight apparent violations described in the inspection report occurred as stated. These viola-tions are described in the enclosed Notice.

Although the vialations are each classified at Severity Level IV in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions",

10 CFR 2, Appendix C, Enforcement Policy (1988), the NRC is nonetheless con- ,

cerned that the violations are symptomatic of some of the same underlying de.fic-iencies that contributed to violations of radiation prote: tion requirements identified in late 1987 for which an $12,500 civil penalty was issued on January 25, 1988. These deficiencies include inadequate identification and correction of causes of violations; apparent conflicts between safety and production; ineffective internal audits; lack of independent audits; deficient safety procedures; and inadequate attention to qualification and training of personnel.

OFFICIAL RECORD COPY CE ENFORCEMENT CONF. 88 0001.0.0 06/03/88 8806160287 880606 \\

PDR ADOCK 07001100 4

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Combustion Engineering, Inc. 2

$ JUN 0 6 1988 The NRC acknowledges that in response to those violations of radiation protection requirements that contributed to the previous civil penalty, a significant upgrade of management controls at the Windsor facility is ongoing.

However, these recent violations demonstrate the need for (1) additional inde-pendent evaluation of your controls in all areas (including criticality control),

and (2) prompt completion of the facility upgrades. We emphasize that a'y recurrence of these violations in the future may result in' additional enforce-ment action, such as civil penalties or orders.

You are required to respond to the enclosed Notice, and you should follow the instructions specified thereia when preparing your response. In your response, you should describe plans for expanding the scope of the current assessment of the radiation protection program to all licensed programs (including nuclear criticality safety), and you <hould give consideration to retaining an indepen-dent party to aid in this assessment. After reviewing your response, the NRC will determine if further enforcement action is needed to ensure compliance with requirements. We will continue to review the actions you have taken to correct the underlying deficiencies identified in your radiation and criticality safety programs by means of frequent inspections of your facility.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC's Public Document Room.

The response directed by this letter is not subject to clearance by the Office of Management and Budget under the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, Orjeginal Signed By a len L. Sjoblom, Acting Director Division of Radiation Safety and Safeguards

Enclosures:

1. Meeting Summary Report

2. Licensee Handout Material

3. Notice of Violation cc w/ enc 1:

A. E. Scherer, Director, Nuclear Licensing C. B. Brinkman, Manager, Washington Nuclear Operations Public Document Room (POR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

State of Connecticut 0FFICIAL RECORD COPY CE ENFORCEMENT CONF. 88 0002.0.0 06/03/88

JUN 0 6' 1988 Combustion Engineering, Inc. 3-bec w/ enc 1:

Region I Docket Room (with concurrences)

Management: Assistant, ORMA (w/o enc 1)

Robert J. Bores, DRSS J. Roth, DRSS G. Bidinger, NMSS D. Holody, W. T. Russell E. Flack, OE J. Lieberman, OE

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6/ 7/88 R OFFICIAL RECORD COPY CE ENFORCEMENT CONF. 88 0003.0.0 06/03/88

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4 Enclosure 1 U.S. NUCLEAR REGULATORY COMMISSION REGION I MEETING.

SUMMARY

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

1000 Prospect Hill Road Windsor, Connecticut 06095 Facility Name: Combustion Engineering - Nuclear Fuel Manufacturing Purpose of Meeting: Enforcement Conference to-discuss apparent violatic identified in NRC Inspection Report No. 70-1100/87-05.

Intrcduction:

An Enforcement Conference was held at the NRC Region I-office on May 10, 1988 at 10:45 a.m. The meeting was requested by the NRC Region I Staff to discuss 8 apparent violations in Nuclear Criticality Safety and Management Controls identified in NRC Inspection Report No. 70-1100/88-03 and to discuss the status of actions to correct the deficiencies identified during Inspection No.

70-1100/87-05.

NRC Attendees:

J. Allan, Deputy Regional Administrator, RI G. Sjoblem, Deputy Director, Division of Industrial and Medical Nuclear l Safety, NMSS l

F. Congel, Acting Director, DRSS, RI  !

J. Joyner, Chief, Nuclear Materials Safety Branch, RI M. Shanbaky, Chief, Facilities Radiation Protection Section, RI W. Pasciak, Chief, Effluents Radiation Protection Section, RI D. Holody, Enforcement Officer, RI G. Bidinger, Senior Nuclear Process Engineer, NMSS J. Roth, Project Engineer, RI ,

R. Loesch, Radiation Specialist, RI l Combustion Engineering Attendees:

P. McGill, V.P. Nuclear Fuel, CE, Inc. l F. Stern, V.P. Nuclear Fuel Manufacturing, CE, Inc. '

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

G. Chalder, Plant Manager, NFM-Windsor R. Sherran Manager, Health and Safety, NFM-Windsor l J. Kingseed, Manager, Licensing, CE, Inc. l R. Bell, Counsel, CE, Inc.

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' Summary

1. The licensee acknowledged three, presented information to refute one, and contested four of the violations identified in the subject inspection.

report. Two of the four contested violations were characterized by the licensee as new examples of violations previously identified during In pection No. 70-1100/87-05.

2. The licensee presented a status report on their actions to correct the violations identified during Inspection No. 70-1100/87-05/

Details of the licensee's presentation appear as Enclosure 4.

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APPARENT VIOLATION 1 Fall.URE To PROPERLY MARK EACII MASS LIMITED CONTAINER WITH THE ACT

= IfRAN f UM CDNTF.NT AND ENRICHMENT (Item 3.a.) *

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3 - 55 gallon drumn tempornrily otored on concrete pad on south side of Building 21 I drum contained radioactive materin1 contaminated Zirconium tubing. Drum was covered, unnealed and labeled as I drum contained contaminated springs from fuel 1 the springs. Drum van rods with Zirconium chips trapped in covered, unnenled and labeled as radioactive material.

I drum cantained contaminated pellet press oil.

prenn oil, internni contamtnation. Drum vce covered, unsealed and marked as pellet Drumn were properly marked and placed on

, the approved storage pad.

Drums were not to be procenned in necordance vith 0.S. 1764.

contaminnted materful whic h can be nennyed. O.S. 1764 in used to process beenuse it contnined no detectable amount of uranium. The material in the drums could not be assayed Chem-Nuclent who would come on nite to do the work. These drums would be processed by 1

in concrete, in accordance with their own procedure. Chem-Fuclear would encapsulate all material 4 - 55 gallon drumn tempornrily stored in the of the Building 17 yard renidue trailer located in the north west corner i All 4 drumn contained contaminated nintering furnace. furnace brick and vacuum sweepings from the No. 2 De 4 drums also contained contaminated anbestos material frove the furnace insulation.

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To provide room in the pcIlet shop, the druma were d rumn were nenled (hernune temporarily stored in the residue trailer. The they contained aabenton remnants) and labeled radioactive materia.l n ene drumn were not to be processed under O.S. 1764 O.S.

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material which can be nnenyed. 1764 is used to process contaminated 5 no detectable amount of urnulum. The material in the drums could not be assayed because it contained

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accordance with O.S. back into the pellet shop where they were processed in Barnwell for burin 1. 7003 which deals with packaging material in B-25's for shipment to ro

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6 APPAltFNT VIOLATION 1 FAII,IIDE TO PROPEfti,Y MARK EACH MASS LIMITED CONTAINER WITH THE ACUAI, IIItAN ItIM CONTENT AND ENRICHMENT (Item 3.a.)

i RESPONSE ~

Drums were in temporary storage awaiting further processing Drums did not require markings which specified U-235 content and enrichment ~

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Drums were properly marked

. O.S. 1764 will be clarified 1

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C-E doen not helleve it had a violation i

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_.A._P_F_ANENT VIOLATION 2 Fall.t!RE 10 APPROVE OPERATION SHEETS AND FAII.URE TO INCL.tfDE APPROPRIATE CAFElY M.18:

AD1 IONS IN OPERATION SHEETS (Item 'l.h.) ' '

RACKGROUND This in one example of nn operation sheet that was selected for the type of problem noted in the apparent violation. There are other operation aheets with similar problems. We admit it.

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For the apparent requirementa. viointion noted, however, a traveler describes the helium leak test operation The shop traveler spect f t en that 7 operation sheets will be used. No. 945 describes the operational steps and No. 1242 includes the necennary safety precautione, including criticality.

The operation door closure switch. of the helium lenk tent unit was designed such that it took 2 hande to operate the door with one hand. This design feature was defeated by some operators who could operate the The door switch in being reden!gned to prevent the operator from operating it with one hand.

We will fix the equipment rather than incorporate the warning in the operation sheet.

Un had nirendy agreed te. upgraele our extating shop floor procedurea (operation aheets) to include the appropriate precautionn. afgnneuren, necenanry operat Ing inntructions and applicable safety and criticality 4

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APPAHENT VIOLATION 2 FAILURE TO APPHOVE OPERATIONS SHEETS AND FAILURE TO INCLUDE APPROPRItT .

SAFETY PRECAtlTIONS IN OPERATIONS SIIEETS (Item 3.b.)

I RESPONSE i O.S.

should have been approved by Manager NL&S.

sheets have been signed. These particular operation Neconnary sa fet y precautions were included in another O.S.

! located at station Safety precaut ion on ringers in i tube not included on O.S. because of system desige i

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CE had committed to an upgrade of the O.S.

violation "G" program as part of its response to as addressed in Dr. McGill's letter will he completed by the 4th Ouarter of 1988. of 2/23/88. This upgrade i

CE does not believe it had a repeat violation b

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_ APPARENT VIOLATION 3 Fall.IIRE To MAINTAIN PEI,I.ETS WITHIN THE REQ 1tIRF.D 4" SLAR THICKNESS ON 11IE Fl!El. l'El.l.ET STORAGE SHEINF.S (Item 3.c.)

RACKGROUND Criticality limit entahlinhed bnned on an infinite array of optimally moderated pellet trays 4" high Criticality limit la implemented by:

Limiting pellet trny 007 weight to a safe amount 2

Limiting pellet trny atack height to 2 - 2" high trays 1 .

Specifying 4" alab limit on nuclear criticality sign at station In January 1988, Production from 8500 grams to 9300 grnmn. requent ed they be allowed to increase tray maximum UO2 weight This requent was reviewed and approved.

j The operntore, than apreading nt timen.

them out over Ioaded t iie ailditional pelle:s into the center of the tray rather the tray opening.

l When the pellets are distributed uniformly, theThis tray caused cover sits theflush.

tray cover to sit at an angle.

Operators would stack 7 trays on top of one another.

the bar opening on the pellet tray storage shelves. At times, double tray height would be above and slide pellet trayn under har. To get under bar, operators would push bar up [

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APPA_ltENT VIOLATION 3 FAILURE TO MAINTAIN PEI,LETS WITilIN TIIE REQUIRED FOUR INCII SLAB THICKNESS ON TifE FUEL PEI.T.ET STORAGE SilELVES (Item 3.c.)

RESPONSE

The correct weight of pellets was put into each tray.

Trays were stacked a maximum of 2 high.

Trays with mounded pellets in center of tray have lower Keff.

Trays did oxceed the 4" limit.

CE admit.n to a procedural violation.

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1-2 Corrective action:

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Procedures were corrected to require leveling of pellets in trays Operators trained on the importance of leveling pellets a

In flexible bar installed on storage shelves s 1

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APPARENT VIO1ATION 4 ,

I Ai1.tllu. tn (:0Nittit:r DAIl.Y AllillT.9 F.ACll WORKING I)AY (Item 4.a.(I))

RACKGROUND The nucient fuel manu facturing facility is formally audited once each working day by a Ifealth Physten techntrian for ifealth Physics compliance and criticality compliance.

The license doen not npecify the degree of audit detail required. This is left to the discretion of the lien 1 th Physicn aupervisor.

.I Our procedure in to conduct a fully detailed audit each working day that the shop is in

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full operation and an nhbreviated audit when the shop is in partial operation.

Both the deta f leil anil nhbreviated audit are fully documented.

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APPAltENT VIOI.ATION 4 ' ~

PAILUHE TO CONDUCT DAILY AUDITS EACH WORKING DAY (Item 4.a. (1) )

RESPONSE

We are required to conduct an audit each working day we elo conduct an audit each working day

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All audits are documented '

CE does not believe it had a violation

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APPARENT VIOI.ATION 5 FAILURE 'IT) EVAI.UATE THE EFFECTS OF AN ACCUMUI.ATION OF URANIUM OXIDE POWDER UNDER 'n1E CONVEYOR ADJACENT TO THE BATCH MAKE-UP HOOD ON CRITICALITY SAFETT (It em 4.h. (2))

.B._ACKCROUND "Ihe batch make-tip hood / roller conveyor has been in place in the pellet shop s for the past If. yearn.

Ve evalunted the ponnib11ity of a gradual UO2 powder buildup and concluded, from 18 years of operntIng experience on thin equipment, that significant UO2 powder would not nerunu la t e under the conveyor and there was no cause for a

, e:ri t icali ty concern.

At 4.1% enrichment it would require 55 Kg's of UO2 optimally moderated and reficcted to form n crittent mann. We restrict hucket content in this hood to a maximum of V. Kg*n of I:02. We nIno require the bucket to be covered

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prior to removal from the hood onto the conveyor.

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APPA, RENT VIOLATION 5

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FAILURE TO EVALUATE TIIE EFFECTS OF AN ACCUMULATION OF URANIUM OXIDE POWDER j

UNDER Tile CONVEYOH ADJACENT TO TIIE HATCII MAKE-UP HOOD ON CRITICALITY SAFETY.

(Item 4.b. (2) )

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RESPONSE

l' Nuclear Criticality Specialist was consulted prior to enclosing the hood t

we believe that the precautions we took were responsible and acceptable i

CE doen not believe it had a violation i

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APPARENT VIOLATION 6

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r:WTHeil.1111~. AlslitTillN OF llHANillM OXII)E TO Tile IIAPWEHMil.l.

110 011 1 0 ASStiltIC TIIA1 Tile MASS 1,lMIT IS NOT EXCEEDED (Item 4.c.)

BACKGROUND UO2 powder, in a bucket, in put into the top of the 2 part hammermill hood.

ne operator records the weight of 1702 in the bucket (excluding tare weight of bucket) onto log sheet posted on hood.

he operator procensen the Ue2 powder through the hammermill where it accumuleten into a 5 gallon bucket (which han a tare weight of approximately 1 Kg) on the lower part of the hood.

he bucket in the lower part of the hood nits on a scale which han a digital readout that shows the combined weight of the bucket and powder.

h e operator removen the bucket from the lower part of the hood. He then weighs bucket. subtracts tare weight, nnd recorIn powder vetr.ht on log posted on hood.

he neiperv f =nr verfffen e len t c lie nin t ti cniculatinna are correct.

De NRC innpector found a 1.1 exceeded by 0.5 Kg of 107. l'a discrepancy which could have caused the 24 Kg hood limit to be g .

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APPARr:NT VIOLATION 6 '

l FAILURE TO CONTROL Tile ADDITION OF URANIUM OXIDE TO TIIE HAMMERMILL IIOOD TO ASSilRE TIIAT TIIE MASS LIMIT IS NOT EXCEEDED (Item 4.c.)

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RESPONSE

A 1.1 kg discrepancy does exist on the milling hood log The reason for the discrepancy is indeterminate

. Likely cause: operator did not subtract bucket tare weight of approximately 1 Kg ,

we do not believe we violated the posted criticality limit but we cannot prove it CE cannot contest the apparent violation Corrective action

. we have etianged the form to not only record 002 weight, but also tare weight and total weight

, we have instructed supervisory personnel on the changed form i

. we will redesign the hood weighing / recording system to eliminate the problem -

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APPARENT VIOLATION 7 "

4 FAllitM. 'In int'l.trl'E Tile IIRANIlfM-7% CONTAINF.D IN SEDIMENT REMOVED - -

FHitM WA:. l E TANF:. ANI) PIPF.S IN Millt. DING 6 ON INVFNTORY (Item 9.h.)

BACKCROUND In 1984 we discovered mnterial in an underground line that was adjacent to the old naval nuclear fuel fabrication facility.

The naval nuclear fuel f abrica tion facility stopped actively producing naval fuel in 1959 - 1960.

ne facilit r van decomminnioned and turned over to CE site personnel for other uses.

The material in the line van identified an high enriched uranium. The material had been in the line for approximately 24 years.

The NRC wan immed ia t + f y not i fi ed of the discovery.

The material (a mixture of nand, dirt, aluminum oxide, and uranium) was removed from the line, loaded into 5 gallon buckets, and stored in Building 6 for safeguarding purposes.

We voluntarily requented, in a high enriched material. ne NRC approved this request.

licenne change to the NRC, that we be allowed to possess the 1

We voluntarily nuhmitted a packaging and disposal procedure to the NRC for approval. The NRC approved thin request.

ne material waa analyred by an offaite laboratory.

' Baned on the Inbora tory ' n analynin, it was determined that there was about 70 grams of U-235 in all of the material found in the pipe. .

De materini was shipped to Barnwell for burial on May 4, 1988.

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APP,ARENT VIOLATION 7 FAILURE FROM TO INCLUDE Tile URANIUM-235 CONTAINED IN SEDIMENT REMOVED WASTE TANi(S AND PIPES IN BUILDING 6 ON INVENTORY (Item 9.b.)

RESPONSE

Material owned by Government NRC immediately and fully notified Material properly safeguarded by C-E when we received were obligated to license inventoryrevision to possess material, we material.

until May 2, 1988 We failed to do this CE admits to a procedural violation l

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APPARfWP VIG.ATION 9 #

FAIIUFF. 'IU ADFBIATELY ASSESS '11E RESUL'IS T ' LYE CRITICALITY SAFT/IY TTMINnt; PIOGRAM (Item 10.a.2.)

, BACl(GROUND

'Ihis is one exarrple of a.nther trainirq violation. 'Ihem are other similar violations nyanliry trainiry of IP 'Ibchs arwi facility personnel. We admit it.

W had previously agreed to upgrade our existing training for both Health Physics

'Ibchs arrt facility yersonnel.

2 General avployee Training modules have alrmdy been coupleted and given to facility personno).

3 additional General nrployee Training modules have been conpleted and training in them modules has been scheduled.

licalth Thysics 'Ibch Trainiry modules have been started and a training schedule established.

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m are workiry cn the entire trainirg progreen and are preparing.ccuplete training modules, lesson plans, and tests. -j

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APPARENT VIOLATION 8 '

FAILURE TO ADEOtfATELY ASSESS THE RESULTS OF THE CRITICALITY SAFETY TRAINING PROGRAM (Item 10.a.2.)

RESPONSE +

CE had committed to an upgrade of the training program as part of its response to violation "H" as addressed in Dr. McGill's letter of 2/23/ns we are on schedule for the completion of that commitment by the 4th Quarter of 1988 ,

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SUMMARY

CE admits to 2 procedural violations CE cannot contest I apparent violation CE believes that 5 of the apparent violations are incorrect

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CORRECTIVE ACTIONS - LONGER TERM ROOT CAUSE ANALYSIS:

MANAGEMENT INATTENTION: FAILURE TO RECOGNIZE:

DEFICIENCIES IN EXISTING RADIATION PROTECTION PROGRAM DETERIORATION OF PROCESS EQUIPMENT / CONTAINMENT DEFICIENT WORK PRACTICES INADEQUATE RESOURCE ALLOCATION CORRECTIVE ACTIONS ADDRESS:

PROCEDURES AND PRACTICES TRAINING HUMAN RESOURCES PROCESS AND EQUIPMENT 4

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l'ROCEDURES AND PRACTICES l

OBJECTIVE ,

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

RADIATION PROTECTION f

WE HAVE RETAINED A CONSULTANT (RADIATION SAFETY ASSOCIATES INC.) TO WORK WITH US TO:

REVIEW THE ADEQUACY OF OUR EXISTING WRITTEN PROCEDURES 56 Procedures identified

- to be written or rewritten UPGRADE EXISTING PROCEDURES WHERE NECESSARY 36 Now in Draft DEVELOP NEW PROCEDURES WHERE REQUIRED PROVIDE A COMPLETE RADIATION PROTECTION MANUAL Complete 4th Quarter 1988 THIS PERMITPROCESS HAS BEEN COMPLETED FOR RESPIRATORY PROTECTION AND RADIATION WORK (RWP) PROCEDURES.

REMAINING PROCEDURES WILL BE COMPLETED BY JUNE 30, 1988. de @ a ver 1988 j THESHOP AND RADIATION PROTECTION PERSONNEL. MANUAL WILL FORM THE BASIS FOR TRAINING HEALTH PHYSICS s

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t PROCEDURES AND PRACTICES (CONT'D) -

SHOP OPERAT_ IONS WRITTEN PROCEDURES CONTAMINATION CONTROL. (INSTRUCTIONS) HAVE BEEN ISSUED TO SHOP PERSONNEL FOR Completed 12/87 ,

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

Will be completed concurrently with 56 prt>cedures above 4th Quarter 1988 i -

SHOP PROCEDURES WILL BE USED TO PREPARE LESSON PLANS FOR PERSONNEL TRAI INTERNAL AUDITS A PROCEDURE HAS BEEN IMPLEMENTED TO PROVIDE FOR INDEPENDENT QUARTERLY AUDITS OF THE RADIATION PROTECTION PROGRAM AND PRACTICE.

Implemented 12/15/

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

TRAINING OF HP STAFF RESPIRATORY PROTECTION COURSE (OCTOBER 1987) Complete and Ongoing RADIATION WORK PERMIT (DECEMBER 1987) Complete and Ongoing RADIATION SAFETY OFFICER COURSE (DECEMBER 1987) Complete

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TRAINING IN SEPTLMblR 30,REMAlf3ING 1988). RADIATION PROTECTION PROCEDURES (COMPLETE BY 4 tit Qwtttet 1985 HP staff has beeri trairied in old manual will be retrained in new manual,

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lHAINING TRAINING OF SHOP PERSONNE_L TRAINING IN RESPIRATORY PROTECTION COMPLETED NOVEMBERComplete 1987. and ongoing TRAINING IN CONTAMINATION CONTROL COMPLETED NOVEMBER Complete 1987. and Ongoing UPGRADED EMPLOYEE TRAINING PROGRAM COMPLETE BY SEPTEMBER 30, 1988 -

l ANNUALLY THEREAFTER.

4 tin Quatttet 9 Training modules identified 8 modules written 2 modules given u

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!!UMAN RESOURCES o OBJECTIVE TO PROVIDE AN ADEQUATE LEVEL OF QUALIFIED PERSONNEL TO MAINTAIN ALL PLANT OPERATIONS IN COMPLIANCE WITH REGULATORY AND OTHER REQUIREMENTS.

RADIATION PROTEXTION PROVIDE FULL TIME HEALTH PHYSICS COVERAGE AT ALL TIMES IN THE PELLET SHOP (NOVEMBER 1987). Increased HP staff .

RETAIN A QUALIFIED CONSULTANT TO ASSIST WITH PREPARATION OF RADIATIOr4 PRO TECT I O",1 [

PROCEDURES AND TRAirJING PROGRAMS (OCTOBER 1987). Implemented PROVIDE A QUALIFIED INDIVIDUAL TO PERFORM INTERNAL AUDITS OF COMPLIANCE WITH RADIATION PROTECTION REQUIREMENTS (QUARTERLY BEGINNING IN 1988). Implemented SHOP OPERATIONS PROVIDE ADDITIONAL SUPERVISION IN THE PELLET SHOP TO ASSURE OPERATOR COMPLIANCE WITH CONTAMINATIOff CONTROL AND OTHER PROCEDURES. (DECEMBER 1987). Implemented PROCESS ENGINEERING i

PROVIDE ADDITIONAL ENGIf4EERING SUPPORT IN THE PELLET SHOP TO IMPROVE CONTAMINATION CONTROL OF PROCESS EQUIPMENT (DECEMBER 1987). Implemented PLANT / EQUIPMENT MAINTEfMNCE  :

PROVIDE PERSONNEL TO IMPLEMENT AN ONGOING PREVENTIVE MAINTENANCE PROGRAM FOR

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EQUIPMENT AND CorJTAINMErJT/ VENTILATION SYSTEMS (APRIL 1988). Implemented

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4 PROCESS _AND EQUIPMENT OBJECTIVE TO PROVIDE RFL I AllLE ENf lf41'ERI D SYSTEMS WillCH MAINTAIN MANUFACTURING OPERATIONS IN COMPLIANCL WITH HEGULATORY AND GTHER REQUIREMENTS.

Il1 MEDIATE ACTIONS UPGRADE JUfJE 1988). CONTAltJMEfJT/ VENTILATION 907 complete wi'l be complete by June SYSTEMS ON EXISTING EQUIPMENT (OCTO MODIFY MATERIAL 907, complete HAflDLING will complete by June SYSTEMS OUTSIDE CONTAINMENT (OCTOBER 1987 IMPLEMENT PREVEtJTIVE MAltJTENANCE PROGRAM (APRIL 1988).

Initiated January 1988 will te fully operational December 1988 LONGER TERM ACTIONS A MAJOR SHOP UPGRADIfJG PROJECT IS PLANNED OVER THE NEXT THREE YEARS. Ii i

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