ML20246E009

Insp Rept 70-1100/89-04 on 890717-21.Violation Noted.Major Areas Inspected:Mgt Controls,Criticality Safety,Radiological Controls & Emergency Preparedness

ML20246E009
Person / Time
Site:	07001100
Issue date:	08/15/1989
From:	Austin M, Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20246D990	List: ML20246D988 ML20246D997 ML20246E009
References
70-1100-89-04, 70-1100-89-4, NUDOCS 8908280365
Download: ML20246E009 (6)

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'. 'U.Si NUCLEAR' REGULATORY COMMISSIONS ,

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REGION:I.

,I Report No. 70-1100/89-04 Docket No. 1100:

License NoL >SNM-1067 Priority 1 Categ'ory ULFF' L'icensee: -Combustion Engineering, Incorporated

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1000 Prospect Hill Road

. Windsor. Connecticut 06095

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-Facility:Name: Nuclear Fuel- Manufacturing and Nuclear Laboratories-Inspection At:- Windsor, Connecticut

. Inspection Cor. ducted: July 17-21, 1989

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Inspectors: /

M .A. Austin,~Radietion Specialist, Effluents-

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Radiation Protection'Section, FRS&SB,.DRSS Approved by: # Y /$~ f

' R. /T/ Bdres*, Chief, ETf Tuents Radiation ' date /

Prd14ction Section,; FRS&SB, DRSS Inspection Summary: Inspection on July 17-21, 1989 (Report No. 70-1100/89-04)

Areas Inspecte'd: Routine, unannounced inspection by one region-based inspector of the licensed program including reviews of management controls, criticality safety, radiological controls, and emergency preparedness.

Results: One Severity Level IV violation was observed: failure to conduct an annual emergency exercise involving offsite agencies (paragraph 5.2). Progress

' toward completion of improvements in management controls, criticality safety and emergency preparedness was identified. The requirement for implementation of.a' technically qualified oversight function within the new radiological control. organization was identified. The need for additional clarification of individual responsibilities for the radiation protection program was observed.

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DETAILS 1.0- Individuals Contacted

• S. T.' Brewer, President, Nuclear Power Business Division

• P. L. McGill, Vice President, Nuclear Fuel

• P. R. Rosenthal, Program Manager, Radiological and Industrial Safety l- *C. R.' Waterman, Vice President and. General Manager, Nuclear Fuel Manufacturing

• D. G.' Stump, Manager, Radiological and Industrial Safety J. Vo11aro, Health Physics and Safety Supervisor

• R. E. Vaughan, Manager, Operations

• R. E. Sheeran, Manager, Account' ability and Security

• J. C. Ballard, Operations Consultant

• J. F. Conant, Manager, Nuclear Material Licensing

.R. Bennett, Consulting Engineer

• denotes those present at the exit interview. The inspector also interviewed other licensee employees during the inspection.

2.0 Management Controls 2.1 Internal Audit Program

'The inspector met with licensee management and reviewed Program Document No. PR22, entitled " Audits, Inspections and Surveys",

Revision 0, dated June 21, 1989. This document provides a comprehensive summary of the various types of internal audits to be performed by the licensee, including the required frequency and responsible individual for each audit. The inspector identified this document as an' initial,' positive step toward improved management control of an internal audit program. Compliance with this document and-the adequacy of the specific audits actually~ conducted will be reviewed in a future inspection.

-2.2 Safety Committees The inspector reviewed licensee records of the activities of the Nuclear Safety Committee (NSC). This documentation shows that the NSC involvement in facility operations has increased in calendar year 1989. The NSC conducted an audit of facility operations in January 1989, which included both pre- and post-audit meetings. The NSC convened on April 5,1989 and July 10, 1989 to review proposed license amendments before submittal to NRC. The inspector observed this increased NSC activity to be an improvement compared to that seen in recent years.

The inspector met with licensee management to question the relationship between the NSC that is described in the existing license and the Facility Review Group (FRG) that is proposed in the

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D' organizational amendment request dated June 23, 1989. The' licensee explained that.the FRG would. assume the functions of.the present NSC

.when the aforementioned: amendment request received final NRC

. approval. The licensee further explained that, after NRC approval of the FRG, the NSC would be retained as a higher level management oversight. group.

In. addition to the existing NSC and proposed-FRG,.the inspector learned of another safety-related committee already established by licensee management, which is described in Administrative Procedure No. API, entitled " Abnormal Event Occurrence (AEO). Reporting", dated April 17, 1989. The licensee utilizes an.AE0 Review Committee that convenes on an ad hoc basis to address a wide range _of non-routine events, such'as' contamination incidents. This newly-formed-committee provides a more formalized mechanism with regardLto management. involvement in the evaluation and resolution'of problems, and. represents a potential. improvement in management control.

3.0 Nuclear Criticality Safety 4

3.1 Evaluations The: inspector reviewed the status of the licensee's implementation of-a formal system to evaluate facility changes. The inspector

-reviewed' Program Do'cument No. PR-3, entitled " Criticality Safety Program",. dated July 13,'1989, which describes this formal system.

This document.also contains a written statement of the company's nuclear criticality ~ safety policy, which includes the personal.

-endorsement signatures of upper' level management. The formal system.

Dutilizes a Change / Modification Review (CMR) and approval process that relies. upon the. Program Manager, Radiological and Industrial Safety to ensure that any facility' changes receive the necessary criticality safety evaluation. At the time of the inspection, the licensee was testing a draft procedure. The inspector reviewed the pre printed forms already being used that provide documentation of the criticality safety evaluations being performed. The inspector noted that completion of the-implementing procedure was falling behind the schedule given in the licensee's June'30, 1989 status report submitted to NRC Region I. Licensee representatives stated that additional manpower will be assigned to this task to assure completion in a timely manner. Compliance with the final, approved implementing procedure will be determined in a future inspection.

3.2 Audits The inspector reviewed the records of the criticality safety-related audits performed by the radiological control technicians. The

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quarterly operational checks of the Virgin Powder' Roll Up' Door and

_ the monthly checks of the Criticality Alarms were performed as required for the January-June 1989 time' period.

t 4.0 Radiological Controls 4.1 Procedures The inspector reviewed Program Document No. PR1, entitled " Bioassay",.

dated June 30, 1989. The inspector identified. that this. program' presently evaluates bioassay data'to determine uptake (e.g., lung deposition) but does.'not estimate intake (e.g., MPC-hours). The.

, inspector indicated to licensee representatives that the program methodology should be expanded to include an estimation of: intake, because the exposure limits given~in 10 CFR 20.103 are presented in terms of intake. The licensee indicated this programmatic improve-ment would be reviewed and. implemented, if appropriate. The inspector also noted that the completion of this program document and its related implementing procedure was falling behind the schedule given in the licensee's June 30, 1989 Status Report to NRC Region I.

Licensee representatives stated that aaditional manpower will be

. assigned.to this task to assure completion in a timely manner.

Compliance.with the revised implementing procedure, when finally approved, will be reviewed in a future inspection.

4.2 Organization The' inspector interviewed licensee management and radiation protection staff personnel to evaluate the new radiological control organization described in their June 23, 1989 amendment application. In the' application letter, the licensee states: "In regard to the qualifications of key personnel important to safety, Nuclear Regulatory Commission staff have requested that an oversight function be provided for individuals that do not' fully satisfy the primary educational and experience requirements specified in Part I, Section 2.2 of the license application.

Combustion Engineering agrees to provide such an oversight function and will, in cases where it is utilized, inform the Nuclear Regulatory Commission of the affected individual and his or her qualifications for the position being filled, the person to provide oversight and his or her qualifications, and the nature of the oversight to be provided. Further, we will not terminate such oversight without f a ;t informing the Nuclear Regulatory Commission of our intent to do so."

In accordance with the above quoted agreement, licensee management informed the inspector that the present Program Manager of Radiological and Industrial Safety would be providing such an

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oversightIfor the present Manager of'R' radiological and Industrial

' Safety. At the_ time of the inspection,.the exact nature of this

. oversight was still being developed.

The. inspector met with licensee management personnel to discuss individual'. responsibilities for various elements of the overall-radiation protection program. These discussions indicated that

. additional explanation of specific duties may be needed for the new

positions of Program Manager, Manager, and Supervisor, within the Radiological and Industrial Safety function. Licensee management.

stated that appropriate action would be taken to assure that -

responsibilities within the new organization are clearly understood by the assigned. individuals.

5.0 Emergency Preparedness 5.1 Procedure Development The inspector examined the current status of.the Emergency Plan Implementing Procedures (EPIPs). In a meeting with the licensee engineer primarily. responsible for the EPIPs, .the inspector reviewed _ .

l: internal correspondence that showed the draft emergency procedures I had been completed and internally distributed to all " emergency-- 1 l: responders" on July 19, 1989 for review and comment. The licensee.

I plans to complete this iaternal review by August 11, 1989 and complete final approval by August 17, 1989.

5.2 Emergency Drills The inspector reviewed the status of licensee plans to implement the new drill / training requirements of the. proposed Emergency Plan. The-inspector reviewed detailed, computer generated flow charts that showed the various tasks that must be coordinated and completed before the upgraded emergency drill can be conducted. All tasks have been assigned to specific individuals and scheduled for completion such that an upgraded emergency drill could be conducted as early as October 4, ISS9. -

In addition to reviewing the status of licensee activities regarding the proposed Emergency Plan, the inspector a Wo determined licensee compliance with the applicable requirements for emergency drills given in the existing Radiological Contingency Plan (RCP). Condition No. 21 incorporates the RCP as a requirement of License No. SNM-1067..

The RCP requirements for the conduct of emergency drills states, in part: " Semi-annual site emergency evacuation drills are conducted to test promptness of response, adequacy of procedures, emergency equipment, and the overall effectiveness of the emergency plan. At least one of the two drills given annually will be part of an overall

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. exercise that involves participation by off-site' agencies-to test as a minimum the communication links and notification procedures."

Documentation provided-to the. inspector _for' review :,howed that.'at least two emergency evacuation drills had been conducted in '1988:

one'on September 22, 1988 and the other on November 16,1988. -In both ' drills, promptness of response to the tripped alarms was ' tested, .

. problems were. identified, and the. drill scenario was documented and..

' summarized. However, there was no parti:ipation by offsite agencies

.in' any of these drills. Failure to-' include offsite agencies in emergency drills conducted in 1988 was identified as an apparent violation of a license requirement in the Radiological Contingency Plan. (70-1100/89-04-01). Licensee' repro entatives acknowledged the fact that the requirements-of the Radiological Contingency Plan:must- ,

continue to be met until NRC approval of the proposed Emergency Plan- '

e is obtained.

6,0 Exit: Interview-The inspector metTwith the licensee representatives (denoted in paragraph

.1.0) at the conclusion of the inspection on July 21, 1989. The inspector.-

summarized the scope'and findings of the inspection.

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