ML20237J189

Ack Receipt of Informing NRC of Actions Taken to Correct Violations Noted in Insp 70-1100/87-01.Review of Two Audits Does Not Substantiate Response Re Item E.Item Will Remain Unresolved Until Review Complete

ML20237J189
Person / Time
Site:	07001100
Issue date:	08/11/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lichtenberger ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8708180021
Download: ML20237J189 (2)

Text

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I Docket No: 70-1100 i Combustion Engineering, Inc.

ATTN: Mr. H. V. Lichtenberger Vice President - Nuclear Fuel Nuclear Power Systems - Manufacturing P. O. Box 500 Windsor, Connecticut 06095 l

l Gentlemen:

Subject:

Inspection No. 70-1100/87-01 This refers to your letter dated June 17, 1987, in response to our letter dated May 26, 1987.

l Thank you for informing us of the corrective and preventive actions for items A through D documer.ted in your letter. These actions will be examined during a future inspection of your licensed program.

With respect to your response to item E, our initial assessment was based upon reviews of documentation provided by you to our inspector and interviews conducted at your facility at the time of the inspection. Further, a review of the two audits does not substantiate your response. However, our inspector will re-examine this area for additional information in a future inspection.

Therefore this item will remain unresolved until such a review is completed.

Your cooperation with us is appreciated.

Sincerely, Original Signea Iiy:

Ronald R. Bellamy Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:  !

Public Document Room (PDR) {

Local Public Document Room (LPDR) l Nuclear Safety Information Center (NSIC)

State of Connecticut 0FFICIAL RECORD COPY RL COMBUSTION ENG - 0001.0.0 08/05/87 B708180021 B70811 0 ADOCK 0700  ; y -

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l Region I Docket Room (with concurrences) l Management Assistant, ORMA (w/o encl) )

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ColHBUSTION ENGINEERING License SNM-1067 j

! Docket 70-1100- j June 17, 1987 l

U.S. Nuclear Regulatory Commission  !

l Region I  !

l G31 Park Avenue  ;

l King of Prussia, PA 19406 l l

Attention: Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards 1

Reference:

Letter from Thomas T. Martin, NRC, to H. V. Lichtenberger, CE, j dsted May 26, 1987; Inspection No. 70-1100/87-01. j

, 1

Dear Mr. Martin:

l Our response to the notice of violation, Appendix A, contained within the )

referenced letter is as follows:

Appendix A, Item A 10 CFR 20.203 (e) states that "each area or room in which licensed, material is used or stored and which contains any radioactive material (other than natural  !

Uranium or Thorium) in an amount exceeding 10 times the quantity of such materials 'j

< specified in Appendix C of this part shall be conspicuously posted with a sign or signs bearing the radiation caution symbol and the words: ' CAUTION - RADI0 ACTIVE MATERIALS'."

Contrary to the above, on April 13-16, 1987, the Pellet Shop area, in which licensed material in amounts greater than ten times Appendix C quantities were used and stored, was not conspicuously posted with the required " CAUTION -

RADI0 ACTIVE MATERIALS" sign, in that, neither one of the primary access points to the Pellet Shop nor inside the Pellet Shop were posted as required.

Response

We have posted " CAUTION - RADI0 ACTIVE MATERIAL" signs on (1) the primary access point to the pellet shop (the double doors) and (2) the womens' change room door leading to the pellet shop. The mens' change room door leading to the pellet shop and personnel / vehicle gates in the building 17/21 security fence were already posted with " CAUTION - RADI0 ACTIVE MATERIAL"' signs.

1000 Prospect Hill Road (203) 688-1911

\ Combustion Engineenng Inc. Post Office Box 500 Telex: 9-9297

\

y Windsor, Connecticut 06095

- s

Dicense SNM-1067 l l

. Docket 70-1100 l Page 2 of 4 '

Appendix A, Item B 10 CFR 20.203 (f)(1),(2), and (3)(1) states "each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents...(and) shall bear the radiation caution symbol and the words ' CAUTION RADI0 ACTIVE MATERIAL.' It shall also provide sufficient information to permit individuals handling or using the containers, or working in the vicinity thereof, to take precautions to avoid or minimize exposures." Labeling is required for containers that contain greater than the applicable quantities listed in Appendix i C of this part. J l

Contrary to the above, on April 13-16, 1987 several containers, boxes, bags, and a i tray containing greater than the applicable quantities listed in Appendix C of Part 20 for Uranium-235, were neither labeled with the radiation caution symbol I and the words " CAUTION - RADI0 ACTIVE MATERIAL," nor were labeled with information l identifying the radioactive contents.

Response

Shere applicable, containers in the pellet shop have been posted with signs that read " CAUTION - RADI0 ACTIVE MATERIALS."

In addition, we will submit a change to our license requesting that in lieu of 10 CFR 20.203 (f)(1),(2), and (3) (1) we be allowed to post signs at all entrance doors to the pellet shop that read "EVERY CONTAINER OR VESSEL IN T611S AREA, UNLESS OTHERWISE IDENTIFIED, MAY CONTAIN RADI0 ACTIVE MATERIAL." When this license change request is approved we will eliminate the requirement for posting individual containers in the pellet shop (of the type described in Item B) with " CAUTION -

RADI0 ACTIVE MATERIAL" signs.

I

.ppendix A, Item C License SNM-1067, Part I, License Conditions, Section 3.2.4, " Instrumentation,"

states "the calibration of the survey instruments shall meet the specifications described in Section 1.11 of Regulatory Guide 8.24, ' Health Physics Surveys During Enriched U-235 Processing and Fabrication.'" Section 1.11 of Regulatory Guide 8.24 states, in part, that " daily or other frequent checks of survey instruments should be supplemented every six months with a calibration of each instrument at two points separated by at least 50 percent of each linear scale that is used routinely..."

Contrary to the above, all E-520s, tha survey instrument used routinely to conduct radiation surveys in the Nuclear Fuel Manufacturing facility, were not calibrated in accordance with the license conditions on three out of four scales used. In addition, no daily or frequent checks were performed to ensure instrument operability. The inspector noted that these inadequately calibrated instruments were used to perfonn radiological surveys including those performed during April 13-16, 1987.

Response

Use of CE's Calibration Laboratory has been discontinued and all calibration /

repair of Nuclear Fuel Manufacturing and Product Development's survey instruments-tion has been taken over by Radiation Management Consultants (RMC) of a

~

License SNM-1067 Docket 70-1100 ,

Page 3 of 4 l- Philadelphia, PA. We have audited the facilities of this organization, its l

procedures, and its personnel. RMC has commenced calibration of all survey instrumentation and the required calibration / repair records and the initial audit report of RMC are on file for NRC review. 3 Appendix A, Item D SNM-1067, Section 2.7.2, " Operating Procedures for Nuclear Fuel Manufacturing" states, in part, that "all operations involving radioactive materials have written  !

procedures which include the appropriate safety requirements and are followed." l Section 3.1.1, " Radiation Work Permit Procedures" states " written operating g procedures for the Health and Safety group are provided and followed..." and 3 Section 4.1 states, "a manual entitled, ' Nuclear Licensing & Safety Procedures' l

... necessary to implement the radiation protection program ... is maintained by 1 the NLSA&S group." f j

Contrary to the above, certain procedures for the Health and Safety group  ;

necessary to implement the radiation protection program were not provided. No i written procedures were provided for several radiological safety activities including the requirements for surveys per 10 CFR 20.201; for posting, labeling, and controls, as required by 10 CFR 20.203; for storage and control of licensed i materials in unrestricted areas, as required in 10 CFR 20.207; for transfer for aisposal and manifests , as required in 10CFR 20.311; nor for checking criticality ,

monitors, as required by 10 CFR 70.24. ]

i

Response

All procedures required for the Health Physics operation including those noted by the inspector in the referenced letter that deal with area surveys, sign posting, '

storage / control / movement of radioactive material, tracking of Radioactive Waste and periodic checking of criticality monitors will be completed by August 31, 1987. All completed procedures will be approved by the Manager NLSA&S and j l

, released to our Central Document Control Center (CDC). l 1

Appendix A, Item E SNM-1067, Section 2.5.10. " Nuclear Safety Committee Membership" states " the Committee member or the Consultant to the Committee who performs the independent criticality safety review ... shall not be the person who is authorized to conduct the monthly criticality audit and shall not be the initial reviewer. The Committee member or the Consultant to the Committee who performs the independent radiological safety review ... shall not be the person who is authorized to conduct the monthly radiological safety audit and shall not be the initial reviewer."

Contrary to the above, for the 1985 and the 1986 Annual Audits, the Consultant to l the Committee who performed the independent criticality safety review was also the person who performed the initial reviews. For the 1985 Annual Audit, the Consultant to the committee who performed the independent radiological safety review was also the individual that conducted the monthly radiological safety Audit.

l

L'icense SNM-1067

. Docket 70-1100

. Page 4 of 4 i .

! Response 1

This is not a violation because (1) the initial review in the first part of 1985  !

tas performed by R. Klotz and the consultant to the comittee, R. Harding, performed the independent review. During the latter part of 1985 and during 1986

the initial reviewer duties were assumed by M. Elmagarabi and the independent 1 reviewer duties for the comittee were assumed by R. Koltz. ^+ no time during I 1985 or 1986 did the person who performed the initial review do the independent 1 review for the Nuclear Safety Comittee, and (2) the manager NLSA&S provided j radiological information on facility activities to the Nuclear Safety Comittee at the request of the committee chairman but did not act as a consultant to the comittee on radiological matters during the 1985 Audit.

Please note that, with the exception of Item D, we are now in full compliance with all violatuns noted in Appendix A, notice of violation and, as previously stated, te will be in full compliance with this item by August 31, 1987.

q dith regari to your concern "----- with the lack of management attention and action in .'asolving these previously identified Radiological controlled weaknesses" it should be noted that we were working with our Instrument ,

Calibration Labore tory to clear up the questions raised by your inspector in her j March 1986 visit to cur facility. During your inspectors' April 1987 visit, when '

additional unresolved questions regarding the Calibration Laboratory were raised, we took imediate action to subcontract all calibration of our radiation protection instrumentation to Radiation Management Consultants (RMC). In addition, we had written additional radiation protection procedures since your inspector's visit in March 1986. During your inspectors' visit in April 1987 they voiced concern regarding the progress that had been made in the writing of procedures. Again, we took direct action by assigning additional personnel to the writing of procedures and have comitted ourselves to a completion date for all Radiation Protection Procedures of August 31, 1987.

We wish to assure you that we have given, and will continue to give, all matters  !

involving our Radiological Control Program our full attention and we will take immediate action to resolve any program weaknesses when they have been identified.

i Very truly yours, l

.h H. V. Lichtenberger Vice President-Nuclear Fuel RES/laf