ML20155F107

Notice of Violation from Insp on 880229-0304 & 28-31. Violation Noted:Lids of Seven Mass Limited Containers Containing Unmeasured Quantities of U-235 Not Labeled w/U-235 Content & Enrichment

ML20155F107
Person / Time
Site:	07001100
Issue date:	06/06/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20155F095	List: ML20155F091 ML20155F107
References
70-1100-88-03, 70-1100-88-3, EA-88-127, NUDOCS 8806160289
Download: ML20155F107 (3)

Text

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NOTICE OF VIOLATION Combustion Engineering, Inc. Docket No. 70-1100 Windsor, C)nnecticut License No.

EA88-127 During an inspectior conducted on February 29 - March 4, and March 28-31, 1988, violations c,f NRC requirements were identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy, 1986), the violations set forth below.

A. Amendment No. 9 to License No. SNM-1067 dated April 3, 1987 incorporates Section 4.1.6, "Marking and Labeling of SNM," dated October 22, 1986 into the NRC-approved license application (Part 1-Criteria) which states, in part, that all mass-limited containers shall be labeled as to enrichment and content.

Contrary to the above, on February 29-March 1,1988, the lids on seven mass limited containers (drums labeled as No. 5121, 4565, "contaminated oil", 4564, 4570, 4586, and 4611), containing unmeasured quantities of uranium-235, had been secured between December 20, 1987 and February 2,1988, and the containers were not labeled with the actual uranium-235 content and enrichment.

This is Severity Level IV violation (Supplement VI).

B. Amendment No. 9 to License No. SNM-1067, dated April 8,1987 incorporates Section 2.7.2, dated October 22, 1986 into the NRC-approved license application (Part 1-Criteria) which states, in part, that it is the responsibility of the Plant Manager to assure that all operations involving radiodctive materials have written procedures which include the appropriate safety requirements. Those procedures must be approved by the Manager, Nvelear Licensing, Safety, Accountability and Security (NLSA&S), The Nuclear Criticality Safety Specialist, or the Supervisor, Health physics and Safety prior to the start of any operation.

Contrary to the above, as of February 29, 1988, the plant Manager did not assure that all operations involving radioactive materials had properly approved written procedures in that the Quality Control procedures did not contain safety precautions now were they properly approved. For example, Operations Sheet No. 945, Revision 39, dated December 10, 1987, did not include any safety precautions, and there was no written approval by the Manager, NLSA&S, the Nuclear Criticality Safety Specialist or the Supervisor, Health Physics and Safety.

This is a Severity Level IV violation (Supplement VI).

C. Amendment No. 7 to License No. SNM-1067 dated August 4,1986 incorporates Section 4.3.9, dated December 16, 1985 into the NRC-approved license application (Part 1-Criteria) which states that the uranium oxide thickness on each of the Pellet Storage Shelves shall be less than four (4) inches.

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Contrary to the above, on February 29, 1988, the uranium oxide thickness, at five locations on the Pellet Storage Shelves, exceeded four inches by an amount of 1/8 to 3/4 of an inch.

This is a Severity Level IV violation (Supplement VI).

D. Amendment No. 3 to License No. SNM-1067 dated October 1,1984 incorporates Section 4.1.3 "Requests for Changes and Criticality Analysis" dated June 15, 1984 into the NRC-approved license application (Part 1-Criteria) which states that all proposed changes in process, equipment, and/or facilities that could affect nuclear criticality, radiological or industrial safety shall be approved in accordance with the requirements set forth in Section 2.2.2 of this part. Amendment 3 also incorporates Section 4.1.5 "Internal Review Requirements" which states, in part, that all process / equipment / facility changes which could affect nuclear critic-ality safety shall be reviewed and approved in writing by the Nuclear Criticality Specialist. Section 2.2.2 states that the General Manager delegated to the Production and Material Control Managers and to the Engineering Manager responsibility to assure that all operations involving nuclear materials have been analyzed to establish the required safety limits and controls. The Manager, NLSA&S or Nuclear Criticality Specialist shall assist the Engineering Manager and the Production and Material Control Manager by performing the analysis required and establishing the appropriate controls.

Contrary to the above, at some time prior to March 1,1988, a change was made at the facility, namely, covering the Batch Makeup Hood Conveyor, resulting in the potential accumulation of urantam oxide powder under the conveyor, and an analysis was not performed prior to the change to establish the required safety limits and controls. Further, this change in equipment, which could affect nuclear criticality safety, was not reviewed and approved in writing by the Nuclear Criticality Specialist.

This is a Severity Level IV violation (Supplement VI).

4 E. Amendment No. 3 to License No. SNM-1067 dated October 1, 1984 l incorporates Section 4.1.4 "Posting of Limits", dated June 15, 1984, into i the NRC-approved license application (Part 1-Criteric) which states, in I part, that all work stations shall be posted with a nuclear safety sign approved by the Manager, Nuclear Licensing, Safety, Accountability and  ;

Security (NLSA&S) or the Nuclear Criticaiity Safety Specialist. Section  !

4.1.2 states, in part, that it shall be the responsibility of the supervisor to assure that each work station is properly posted and that operations are performed in compliance with posted limits.

Contrary to the above, on February 27, 1988, a work station was not properly posted in that the posted nuclear safety limit of 24.0 kilograms uranium oxide appeared to be exceeded by about 1.1 kilograms as the result of a weighing error.

This is a Severity Level IV violation (Supplement VI),

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Notice of Violation 3

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F.

10 CFR 70,51(b)(1) states that each licensee shall keep records showing the receipt, inventory (including location), disposal, acquisition and transfer of all special nuclear material in his possession regardless of its origin or method of acquisition.

Contrary to the above, on March 2,1988, the inspector determined that the l'censee did not maintain inventory records, including location, of between 70 to 300 grams of uranium-235 in enriched uranium oxide that was found in liquid waste tanks and pipes during 1985.

y This is a Severity Level IV violation (Supplement III).

G.

Amendment No. 9 to License No. SNM-1067 dated April 8, 1987 incorporates Section 2.6.1 " Initial Training", dated October 22, 1986 into the NRC-approved license application (Part 1-Criteria) which states, in part, that all new employees shall attend a formal training session prior to working in restricted areas. Specialized training for radiation protection and nuclear criticality s fety shall be commensurate with the extent of the employees contact with radioactive materials. All personnel who will be working with radioactive materials must satisfactorily complete a test to ascertain tha effectiveness of the training.

Contrary to the above, as of March 28, 1988, personnel working with radioactive material, who required specialized training in nuclear criticality safety, were iot required to satisfactorily complete a test to ascertain the effectiveness of that training.

This is a Severity Level IV violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, Combustion Engineering, Incorporated is hereby required to submit to this office within thirty days of the date of the letter which transmitted this Notice, a written statement or explanation in reply, including: (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Where good cause is shown, consideration will be given to extending this response time.