ML20202F842

Safety Insp Rept 70-1100/86-03 on 860310-14.No Violations Noted.Major Areas Inspected:Radiation Protection Program, Including Status of Previously Identified Items & Implementation of Radiation Protection Program

ML20202F842
Person / Time
Site:	07001100
Issue date:	04/04/1986
From:	Cioffi J, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202F821	List: ML20202F816 ML20202F842
References
70-1100-86-03, 70-1100-86-3, NUDOCS 8604140231
Download: ML20202F842 (9)

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U.S. NUCLEAR REGULATORY COMMISSION-REGION I Report No. 70-1100/86-03 Docket No. 70-1100 License No. SNM-1067 Priority Category Licensee: Combustion Engineering, Inc.

P. O. Box 500 Windsor, Connecticut 06095

' Facility Name: Combustion Engineering Inspection At: Windsor, Connecticut 06095 Inspection Conducted: March 10-14, 1986 Inspector:

Y fd Jegn A. Cioffi, Radiat//c[n Specialist /dat'e F#cilities Radiation Protection Section

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Approved by: M. b bd M.' Shanbaky, Chief 4[t/[f([

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f date Facilities Radiation Wotection Section Inspection Summary: Inspection on March 10-14, 1986 (Report No. 70-1100/86-03)

Areas Inspected: Routine, unannounced safety inspection of the radiation protection program, including: the status of previously identified items; implementation of the radiation protection program; internal and external exposure controls; instru:r.entation and calibration; training and retraining of personnel; and implementation of the environmental monitoring program.

Results: Of the areas inspected, no violations were identified.

6609190FJ1 860407 PDR C

ADOCK 07001100 PDR

DETAILS 1.0 Personnel Contacted P. Bouchard, Supervisor, Electrical & Instrument Development C. Chesky, Electronics Technical Group Leader J. Helems, Chemist, Radiochemistry Laboratory A. Joseph, Senior Health Physics Technician, Nuclear Manufacturing

• H. Lichtenberger, Vice President, Nuclear Fuel Manufacturing J. Limbert, Radiation Safety Engineer, Nuclear Laboratories

• P. Rosenthal, Manager, Radiological Protection Services

• R. Sheeran, Manager, Nuclear Licensing, Safety, Accountability & Security

'J. Vollaro, Supervisor, Health Physics & Safety, Nuclear Manufacturing Other licensee personnel were also contacted or interviewed during the course of this inspection.

• Attended the Exit Meeting on March 14, 1986.

2.0 Purpose The purpose of this routine, unannounced, safety inspection was to review the licensee's program with respect to the following elements:

• Status of Previously Identified Items Implementation of the Radiation Protection Program a Internal and External Exposure Controls Instrumentation and Calibration Training and Retraining of Personnel Implementation of the Environmental Monitoring Program 3.0 Status of Previously Identified Items Open (85-01-01). Review new radiation protection procedures. The status and quality of the radiation protection procedures was reviewed. Although still in draft form, the procedures were generally found to be concisely written, and thorough. Several procedures had not been completed. This item will remain open pending completion of the procedures in an approved final form.

Closed (85-01-02). Calibrate magnehelic gauges used to indicate pressure drop across filter banks of ventilation system. The inspector verified through tours of the Nuclear Manufacturing Building, and the Nuclear Laboratories that the magnehelic gauges used to measure differential pressure across the effluent filter banks were all calibrated and on a routine calibration schedule. This item is closed.

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3 Open (85-01-03). Calibrate rotameters on effluent sampling pumps in the Nuclear Laboratories and review effluent data. The licensee has made arrangements with the ED&S Instrument laboratory to complete the calibra-tion of the rotameters by April 7, 1986. This item remains open pending review of the calibrations and changes to the effluent data.

Closed (85-01-04). Respiratory Protection Program. The licensee submit-ted a letter to the Regional Administrator, Region I, on February 18, 1985 in order to take credit for protection factors afforded by their respirators. Additional details on the respiratory protection program appear in section 5.1.3 of this report. This item is closed.

Closed (30-3754/85-03-09). Failure to leak test an Am-241 source. The inspector reviewed the leak test records for the Am-241 button source (CE-5) and found that all leak tests were performed and recorded in accord-ance with the conditions of the license. This item is closed.

4.0 Implementation of the Radiation Protection Program The licensee's program for controlling radioactive materials and contam-ination, providing surveillance and monitoring and establishing and maintaining administrative radiological work controls was reviewed relative to criteria in:

10 CFR 19.11, 19.12, 20.201, 20.203 and 20.401; SNM-1067, Part I, License Conditions, section 3.0, " Radiation Protection."

The licensee's performance relative to these criteria was determined by:

interviews and discussions with licensee personnel; review of selected RWPs governing work in the Nuclear laboratories; review of the results of routine and special contamination surveys performed in the Nuclear Manufacturing facility and the Nuclear laboratories; review of records of leak tests of sealed sources; direct observation and measurements made during tours of the pellet shop in the Nuclear Manufacturing facility and in laboratories in the Nuclear laboratory building.

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

The licensee performs alpha and beta smear surveys using a paper filter, however, there is no correction made for self-absorption by the filter paper. The inspector stated that self-absorption factors should be determined and applied to the counting results if they

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4 prove to alter the contamination results. The licensee stated that they will determine what the self-absorption factors are for the paper filters, and apply them to the results of contamination surveys, if necessary. This item will be reviewed in a future inspection. (86-03-01)

There are no minimum detectable activities (MDAs) established for the alpha counting equipment in the Nuclear Manufacturing facility. The SNM-1067 license requires an MDA be established of .005 microcuries for leak tests. However, a review of the leak test record data did indicate that the instrumentation is capable of meeting this license requirement. Licensee representatives stated that MDAs will be established for the alpha counting equipment to ensure that an MDA of 0.005 microcuries is being met for leak tests. This item will be reviewed in a future inspection. (86-03-02)

The licensee has initiated an Unusual Occurrence Report tracking system to track, trend, and identify the root causes of radiological, criti-cality, and safety violations. Operation of the system was initiated January 1,1986, and appears to be a good tool for the licensee to identify and correct problems associated with the daily operation of the manufacturing facility.

There were no violations or deviations identified during this review.

5.0 Internal and External Exposure Controls 5.1 Internal Exposure Controls The licensee's program for control of airborne radioactive contam-ination, internal exposure to radioactive materials and respiratory protection was reviewed relative to criteria provided in:

10 CFR 20.103 and 20.401; SNM-1067, Part I, License Conditions, section 3.0, " Radiation Protection."

5.1.1 Airborne Exposure Control The licensee's air sampling and engineering controls for airborne radioactive contamination were reviewed relative to the criteria above.

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

observation of air sampling during the pellet shop tour;

5 review of air sample analyses and other records; and discussions with health physics personnel.

Within the scope of this review, no violations cr devia-tions were observed. The licensee appeared to be implementing an air sampling program in accordance with established procedures and consistent with the regulatory I requirements'of 10 CFR 20.103.

5.1.2 Internal Exposure Assessment The licensee's implementation of in vivo bioassay assessment of possible internal exposures to workers was reviewed relative to the criteria referenced in section 5.1 of this l report.

l The licensee's performance relative to these criteria was l determined by:

discussions with health physics personnel in the Nuclear Laboratories and Nuclear Manufacturing facility; and l

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review of bioassay, contamination survey and other records and reports for selected radiation workers.

Within the scope of this review, no violations or devi-ations were noted.

5.1.3 Respiratory Protection Program The licensee's respiratory protection program was reviewed relative to the criteria in section 5.1 and Regulatory Guide 8.15, " Acceptable Programs for Respiratory Protection."

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

discussions with health physics personnel; review of equipment, storage, and supplies for respiratory protection; and review of the procedure established to implement the respiratory protection program.

6 Within the scope of this review, no violations or devi-ations were identified. However, the inspector observed that respirators were improperly stored. Licensee repre-sentatives stated that appropriate storage of respirators would be immediately provided.

5.2 External Exposure Control The licensee's external exposure control program was reviewed against criteria provided in:

10 CFR 20.101, 20.102, 20.104, 20.105, 20.201, 20.202, 20.203 and 20.401; SNM-1067, Part I, License Conditions, section 3.0, " Radiation Protection."

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

interviews and discussions with licensee and contractor health .

physics personnel; observations and measurements during tours of the Nuclear Manufacturing facility and the Nuclear laboratories; review of logs and other records; and examination of exposure reports and other records related to twenty radiation workers.

Within the scope of this review, no violations or deviations were noted. The licensee appeared to be implementing a generally effec-tive external exposure control program in the areas reviewed.

6.0 Instrumentation and Calibration The licensee's program for instrumentation and calibration was reviewed against criteria contained in:

- 10 CFR 20.201, 20,202, 20.401; SNM-1067, Part I, License Conditions, section 3.0, " Radiation Protection";

Regulatory Guide 8.24, " Health Physics Surveys during Enriched Uranium-235 Processing and Fuel Fabrication."

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i The licensee's performance relative to these criteria was determined by:

discussions with health physics personnel, and instrument laboratory personnel; review of the calibration set-up, records, and instrument inventories;

! and review of " Procedure for Control and Calibration of Radiation Detection Devices," number 00000-NLE-054. j Within the scope of this review, the following was identified:

A review of the calibration sheets maintained for each instrument

! indicated that.the acceptance criteria of 10*s for the Victoreen 498 i (Rad 102) was not achieved for the high range (X100) of the instru-j ment for the past year. The instrument was returned to use despite this deficiency.

A review of the calibration procedure 00000-NLE-054 indicated that acceptance criteria was established for only a few instruments. Many instruments calibrated by the ED&S Instrumentation group have no acceptance criteria specified.

The Instrumentation calibration facility is very small. Conse-l quently, the set-up for radiation instrumentation calibration is of I marginal quality, and consists of using a button source and orienting the detector a maximum of 150 centimeters away to obtain the correct l instrument readings for calibration. The minimum range for the l highest instrument scale is 10 centimeters. This calibration set-up may cause coasiderable error in the calibration because of the source-to-detector distance, and may be the reason for the Victoreen 498 failing to pass the acceptance criteria established in Regulatory Guide 8.24 and procedure 00000-NLE-054.

There were no procedures written at the time of the inspection to implement the appropriate calibration methods for rotameter cali-brations and magnehelic gauge calibrations.

The inspector discussed these findings with licensee management. Licensee management stated that the Electrical and Instrument Development group recently obtained a new supervisor, who will be responsible for upgrading the entire calibration program. Also, the Manager, Radiological Protec-tion Services, had independently identified some limitations in the calibration facility, and began the purchase of a Shepherd Calibrator for instrument and dosimetry calibrations.

The area of instrument calibrations will remain unresolved pending cor-rective actions taken by the licensee and reviewed by the NRC. (86-03-03)

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7.0 Training and Retraining of Personnel The licensee's program for training and retraining of personnel working with special nuclear material was reviewed against:

10 CFR 19.12 SNM-1067, Part I, License Conditions, section 2.6, " Training."

The licensee's performance relative to these criteria was determined by:

i discussions with the Health Physics Supervisor, Nuclear Manufactur-Ing, the Radiation Safety Engineer; review of lesson plans; and review of personnel training records.

f Management personnel in the Nuclear Manufacturing facility upgraded the training and retraining of personnel since the previous inspection (Inspection Report number 85-01). Improvements to the program included revised and detailed lesson plans for classroom presentations and the development and publishing of ar. Employee Training Handbook for all employees. The inspector discussed the improved program with licensee management. The inspector stated that the following additions would enhance the training program effectiveness and provide additional docu-mentation certifying the quality of the training and retraining program:

establish a policy for incoming personnel who fail the written exam more than two times, establish a written exam for annual retraining, f -

add a training session on practical factors (donning and removing protective clothing, proper frisking techniques, the use of respiratory equipment).

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

8.0 Implementation of the Environmental Monitoring Program The licensee's program for implementing the environmental monitoring program was reviewed relative to criteria in:

10 CFR 20.106; SNM-1067, Part I, License Conditions, section 5.0, " Environmental Safety."

Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Program. "

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The licensee's performance relative to these criteria was determined by:

interviews and discussions with licensee personnel; review of records of environmental analyses, liquid effluent analyses, daily background and source checks; and review of the applicable environmental and effluent monitoring procedures.

Within the scope of this review, no violations or dev'ations were identi fied. The licensee was performing the environmental and effluent analyses required in the special nuclear materials license. However, the inspector noted that there was an absence of any quality control program or procedures in place to verify the results of the environmental sample analyses. The inspector discussed the necessity of establishing a program to ensure the reliability of data through a program in which split samples, spiked samples, and blanks are exchanged with other facilities which perform similar environmental monitoring or with a vendor. Licensee representatives stated that they will review the feasibil'ty of establish-ing a quality control program for environmental analyses. This item will be reviewed in a future inspection. (86-03-04) 9.0 Exit Interview The inspector met with the licensee's representatives (denoted in Para-graph 1) at the conclusion of the inspection on March 14, 1986. The inspector summarized the purpose and scope of the inspection and findings as described in this report.

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