ML20214S485

Insp Rept 70-1100/87-01 on 870413-17.Violations Noted: Failure to Conduct Independent Criticality & Radiological Safety Audits & Failure to Establish Radiation Protection Procedures

ML20214S485
Person / Time
Site:	07001100
Issue date:	05/22/1987
From:	Cioffi J, Loesch R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214S455	List: ML20214S452 ML20214S456 ML20214S485
References
70-1100-87-01, 70-1100-87-1, NUDOCS 8706090285
Download: ML20214S485 (15)

Text

.

U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-1100/87-01 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, Inc.

Inspection At: Windscr, Connecticut Inspection Conducted: April 13-17, 1987 Inspectors: NM M 6/z//Pf M_eanA.C~ioffi,RadiationSpecialist,

~

date I FRPS s btf Y)f. S/2ll27 Robert Loesch, Radfation Specialist, date FRPS

/

Approved by: -:77/ 5 LM//

M. M. Shanbaky, Chief, Fa6/Tities s-/2. ~ //7 date~

Radiation Protection Section, EP&RPB Inspection Summary:

Inspection Conducted April 13-17,1987 (Inspection Report No. 70-1100/87-01)

Areas Inspected: Routine, unannounced safety inspection of the radiation protection program, including: the status of previously identified items; management organization and controls; training and retraining of personnel; implementation of the radiation protection program; instrumentation and calibration; radioactive waste management; environmental monitoring; and transportation activities.

Results

Five violations were identified during this review. Failure to conduct independent criticality and radiological safety audits, paragraph 4.2; failure to establish Radiation Protection Procedures, paragraph 6.1; failure to post an area " Caution - Radioactive Materials," paragraph 6.2; failure to post containers " Caution - Radioactive Materials," paragraph 6.2; failure to cali-brate radiation detection instrumentation, paragraph 7.0.

7 070609 PDR A  % [ oNPDR oo C

9 DETAILS 1.0 Personnel Contacted 1.1 Licer ;ee Personnel P. Bouchard, Supervisor, Electronics Laboratory )

• G. Chalder, Plant Manager, Nuclear Fuel Manufacturing J. Helems, Radiochemist, Nuclear Laboratories A. Joseph, Health Physics Technician, NFM

• H. Lichtenberger, Vice President - Nuclear Fuel D. Parks, Manager, Nuclear Materials & Security P. Rosenthal, Manager, Health Physics

• R. Sheeran, Manager, Nuclear Licensing, Safety, Account &

Security, NFM R. Veilleux, Health Physics Technician-in-Training, Nuclear Laboratories

• J. Vollaro, Supervisor, Health Physics and Safety

• R. Walker, Manager, Electrical Technology 1.2 NRC Personnel

• A. Della Ratta, Security Specialist, RI

• Denotes attendance at the exit meeting on April 16, 1987.

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

Management Organization and Controls Training and Retraining of Persor.nel Implementation of the Radiation Protection Program, including:

Procedures Surveys, Posting, Labeling, and Controls External Exposure Controls Internal Exposure Controls Instrumentation and Calibration Radioactive Waste Management Environmental Monitoring Transportation Activities 3.0 Status of Previously Identified Items 3.1 (Closed) 82-06-09 (Inspector Follow-up). Licensee to sample and analyze water and sediment in ponds along industrial stream.

l

. 3

- The licensee sampled the brook and pond outflow water and soil in November of 1982. The sample analyses were completed March 15, 1983.

The licensee's analyses indicated that natural uranium was present in these samples in the range of 0.8 to 6.0 ppm. The normal range of natural uranium found during environmental analyses of the areas surrounding the facility runs from 0.5 to 22 ppm. The licensee concluded that there was no indication of effluent contamination in this stream.

The licensee normally samples downstream from this industrial stream at the banks of the Farmington River. This item is considered closed.

3.2 (Closed) 85-01-01 (Inspector Follow-up). Review new radiation protection procedures.

This item is being closed for administrative purposes. Details of the status of the licensee's radiation protection procedures appear in paragraph 6.1.

3.3 (Closed) 85-01-03 (Unresolved). Calibrate rotameters on effluent sampling pumps in Nuclear Laboratories and review effluent data.

The inspector determined from a tour of the Nuclear Laboratories, and review of rotameter calibration records that rotameters used for sampling the Nuclear Laboratories stacks were calibrated on a routine calibration schadule. Further, the inspector reviewed effluent sample analyses for the Nuclear Laboratories stacks from July 1, 1986 to December 31, 1986, and determined that no signif-icant changes in effluent results were seen as a result of the rotameter calibrations. Further details of gaseous radioactive waste are discussed in paragraph 8.0. This item is closed.

3.4 (Closed) 86-03-01 (Inspector Follow-up). Self-absorption for alpha and beta smear surveys.

On September 15, 1986, the licensee completed a study on self-absorption of alpha contamination on smear papers. The licensee's I

analyses concluded that the largest self-absorption correction

[ required for smears of very high activity (i.e., 2700 disintegrations per minute to 7400 disintegrations per minute) would be 1.1. There-fore, the licensee concluded that an alpha self-absorption correction factor was not necessary. This item is closed.

I 3.5 (Closed) 86-03-02 (Inspection Follow-up). Establish an MDA for alpha counting equipment.

I The licensee determined the MDA for their counting equipment for leak tests of sealed sources. The MDA was approximately 1.5 disintegra-

tions per minute which is far below the license requirement for an l MDA of 0.005 microcuries. This item is closed.

I i

4

.3.6 (Closed) 86-03-03 (Unresolved). Instrumentation and calibration program.

This item is closed for administrative purposes. Details on the status of instrumentation and calibration appear in paragraph 7.0.

3.7 (0 pen)'86-03-04 (Inspector Follow-up). QA program for environmental monitoring program.

The licensee arranged to participate in the EPA Intercomparison Program for. Environmental Measurements. At the time of the inspec-tion, the licensee had just received some air and water samples to analyze. However, no analyses had been performed. Further, no procedure had been written to conduct a program.for environmental split samples with the EPA or any other environmental measurements facility for assuring'the adequacy of their measurement techniques.

The licerssee stated that a procedure for the conduct of the quality assurance program would be written as soon as they received more information from EPA and other laboratories on the testing protocols.

This item will remain open pending further action by the licensee.

4.0 Management Organization and Controls The licensee's management organization and controls were reviewed with respect to criteria contained in:

SNM License No. 1067, Conditions 11, 12, and Part 1, Section 2.0,

General Organization and Administrative Requirements.

i l- The licensee's performance related to the above criteria was determined

by:

. review of the radiation protection staff; review of monthly and annual audits for 1985 and 1986; review of selected records; and discussions with licensee representatives.

l 4.1 Staffing and Qualifications The licensee maintains a Supervisor of Health Physics and Safety with three Health Physics technicians reporting to him. One technician is

! used for each operating shift. The licensee operates the fuel manu-facturing facility around-the-clock for three shifts.

i

. 5 The licensee plans to employ a fourth Health Physics technician and place him at the Nuclear Laboratories for the control of radiation protection activities. The individual had no applicable previous experience in Health Physics, but was being provided with on-the-job training.and some theoretical training at the nuclear fuel manufac-turing facility. Currently, the individual is working with a full-time Health Physics technician, who monitors activities under the special nuclear materials license and the by product license.

4.2 Audits The licensee is required by the special nuclear materials license to conduct audits of the Nuclear Laboratories on a quarterly and annual basis by an individual, independent of the Nuclear Laboratories, who meets the minimum qualifications of the Health Physics & Safety Supervisor. The inspector verified that the quarterly and the annual audits were conducted as required by the license for 1986 and the first quarter of 1987. The licensee is additionally required to con-duct a daily audit of the Nuclear Fuel Manufacturing facility, by a Health Physics Technician, a monthly audit by an individual iho meets the minimum qualifications of the Radiation Specialist, and an annual audit by the Nuclear Safety Committee. The inspector verified that the audits were performed as required by the license for 1986 and the first quarter of 1987. However, the license states that "all audits shall be performed in accordance with a written plan." The inspector requested a copy of the written plan for review. Licensee represent-atives stated that no written plan, in the form of a formal procedure, existed for conducting the audits. The only written documentation that was available for the performance of the audits were daily and monthly check sheets, and a schedule of audit participants and audit dates by the Nuclear Safety Committee. The inspector stated that this appeared to be a program weakness in that there was no compre-hensive instructions for the annual audits to provide appropriate guidance to the audit team for the scope and depth of the audit.

Licensee management stated that if- the license specified that audits be conducted in accordance with a written plan, then a plan would be

, written. This item will be reviewed in a future inspection.

(70-1100/87-01-01) i The inspector reviewed the 1985 and 1986 Annual Audits performed by the Nuclear Safety Committee. The inspector determined from dis-cussions with licensee personnel and review of the audits that the Consultant to the Nuclear Safety Committee who performed the inde-pendent criticality safety review was also the initial reviewer of I criticality safety activities at the plant. Moreover, there was no independent review of the radiological safety program performed for

, 1985. The radiological safety information for 1985 was provided l by the Manager of Nuclear Licensing, Safety, Accountability, and l

Security, who is the same individual that conducts the monthly radi-i ological safety audits. These findings are an apparent violation of SNM-1067, Section 2.5.10, " Nuclear Safety Committee Membership" which l

t

. 6 states, in part, that "the Committee member or the Consultant to the Committee who performs the independent criticality safety review shall meet the minimum qualifications for a Nuclear Criticality Specialist and shall not be the person who is authorized to conduct the monthly criticality audits and shall not be the initial reviewer.

The Committee member or the Consultant to the Committee who performs the independent radiological safety review shall meet the minimum qualifications for the Manager - Health Physics and shall not be the person who is authorized to conduct the monthly radiological safety audit and shall not be the initial reviewer." (70-1100/87-01-02) 5.0 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; and SNM-1067, Part I, License Conditions, Section 2.6, " Training."

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

discussions with the Health Physics Supervisor, Nuclear Manufacturing; review of lesson plans; and review of personnel training records.

5.1 Radiation Worker Training / Retraining The inspector reviewed annual retraining lesson plans and records for all personnel. All retraining had been thoroughly documented, with all individuals accounted for to meet the annual retraining requirements.

Training of new personnel was conducted on a one-to-one basis with the Supervisor, Health Physics and Safety. The Supervisor, Health Physics and Safety, orally examines newly hired individuals to test l their understanding of working at the manufacturing facility.

l 5.2 Health Physics Technician Training l

l The inspector reviewed training records for several of the Health l

Physics technicians. It was noted that not only was each major topic signed off, but also each specific subtopic. The scope of the training was comprehensive and thorough, giving the technicians i the necessary information for supporting the Radiological Protection l Program.

i No violations were identified during this review.

l t

i

, 7-6.0 Implementation of the Radiation Protection Program 4

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 against criteria contained in:

l 10 CFR 19.11, 19.12, 20.101, 102, 103, 104, 105, 201, 202, 203, and 401;:and SNM-1067, Part I, License Conditions, Section 3.0, " Radiation i ,

Protection."

N:,

>- sThe licensee's performance related to the above criteria was determined by:

interviews and discussions with licensee personnel; 4

review of the results of routine and special contamination surveys performed in the Nuclear Manufacturing facility; review of records of leak tests of sealed sources; review of air sample analyses and verification studies for the fixed shop air samplers; and

' direct observations and measurements made during tours of the pellet shop in the Nuclear Manufacturing facility and in the laboratories in the nuclear laboratory building.

I 6.1 Procedures NRC Inspection Report No. 85-01, performed January 14-18, 1985, identified a lack of detailed procedures for Radiation Protection.

,, The licensee stated, at the time of the inspection, that a dedicated individual would be appointed to rewrite all procedures and ensure that they were processed through the central document control system.

NRC Inspection Report No. 86-03, performed March 10-14, 1986, reviewed the status of the Radiation Protection Procedures. The inspector found the new procedures to be in draft form and some procedures not yet written.

During the' current inspection, the inspector found the status of the procedures to be still incomplete, with handwritten procedures that had not been reviewed nor approved. In addition, certain radiation protection activities were not covered under the existing radiation manual nor under the handwritten procedure drafts. The inspector identified that there were no procedures for the following raciolog-ical controls activities:

f o 8 f

i There were no written procedures for the conduct of surveys, including type of survey, locations, and survey frequencies (10 CFR 20.201);

There were no written procedures for establishing and posting areas and containers within areas of the Nuclear Fuel Manu-facturing facility (10 CFR 20.203);

There were no written procedures for storage, control, and movement of radioactive materials into and out of unrestricted areas of the site (10 CFR 20.207);

There were no written procedures or established methods for tracking of waste manifests and transfer of waste (10 CFR 20.311); and There was no written procedure for periodic check of criticality monitors, including method of checking and frequency of checking the criticality monitors (10 CFR 70.24).

The inspector stated that failure to establish radiation protection procedures was an apparent violation of SNM License No. 1067, Sec-tions 2.7.2, which states that "all operations involving radioactive materials have written procedures which include the appropriate safety requirements and are followed", 3.1.1, which states that

" written operating procedures for the Health and Safety group are provided and followed", and 4.1 which described the maintenance of a

" Nuclear Licensing and Safety Procedures" manual, which is "necessary to implement the radiation protection program." (70-1100/87-01-03) 6.2 Surveys, Posting, Labeling, and Controls During a tour of the Nuclear Manufacturing facility, the inspector observed that one of the primary access points to the Pellet Shop was not posted " Caution - Radioactive Materials." Moreover, the area inside the access point was also not conspicuously posted

" Caution - Radioactive Materials." Since the Pellet Shop is an area which contains greater than ten times the quantity of Uranium-235 specified in Appendix C of Part 20, the inspector stated that this constituted an apparent violation of 10 CFR 20.203(e). (70-1100/87-01-04)

The inspector also noted that there were bins of bagged material, used HEPA filter units, and a flat tray of mop heads and other fibrous material on the FA-4 mezzanine which were not labeled. The licensee stated that all the material was contaminated with Uranium powder, and was being stored until their final disposition (reuse or sent to the Hematite plant for Uranium reclamation). The inspector also noted that throughout the Pellet Shop were placed various containers that were not labeled as to their contents. Licensee representatives pointed to various types of containers and indicated

9 that some were used for rags that wiped down the inside of hoods which contained Uranium powder. The inspector discussed these obser-vations with licensee management and asked if these containers could contain greater than the quantity of U-235 specified in Appendix C of Part 20. When licensee management stated that these containers did contain quantities of U-235 greater than the quantities specified in Appendix C of Part 20 (0.01 microcuries), the inspectcr stated that this was an apparent violation of 10 CFR 20.203(f)(1), (2), and (3)(1). (70-1100/87-01-05) 6.3 External Exposure Controls The inspector reviewed the placement of whole body dosimetry and TLD results for 1986. All exposures were below 500 millirems per year.

During a tour, the inspector noted individuals in the pellet stacking area handling large numbers of pellets in preparation for insertion into individual fuel rods. None of.the individuals were observed to be wearing extremity monitors. In discussions with the Supervisor, Health Physics and Safety, it was determined that the licensee had previously monitored several individuals working in the area over a period of months. Numerous TLDs were worn at various locations.

Inspector review of the data indicated that it was appropriate for the licensee to assume that the individuals would not exceed 25 percent of the regulatory limits for extremity exposures.

No violations were identified in this review.

6.4 Internal Exposure Controls 6.4.1 Air Sampling Program The licensee's data for the verification of representative sampling of the fixed area air samplers was reviewed during this inspection. The inspector noted that the quarterly verifications using teathering, and multiple height sampling indicated no variation from the fixed air samplers. The licensee verifies all stations on a quarterly basis. The license requires an annual verification of the fixed air samplers.

6.4.2 MPC - Hour Determination The inspector reviewed the licensee's data for fixed air sampling and the licensee's method for assigning MPC-hrs based on the results of the air sampling. The licensee changes air sample paper once each shift, counts the sam-ples, and records the results of the appropriate air sample on each worker's MPC log sheet. Each worker's log sheet is updated daily. The inspector noted that air activity is

• 10 generally in the E-13 to E-14 microcuries per cubic centi-meter range.

6.4.3 Bioassay Measurements The licensee conducts urinalysis measurements and whole body counting annually to verify the adequacy of their air sampling program. Inspector review of the urinalysis results indicated that all urinalysis results were less than 1 microgram of detectable Uranium.

The inspector noted that five individuals were identified as requiring special breathing zone air sampling if they entered the Pellet Shop. The inspector asked why these five individuals were restricted. The licensee stated that these five individuals refused to be whole body counted because of the type of whole body counter used

("a coffin"), and this was the only other way that assur-ances could be made for internal exposure control of these individuals. These workers are not employed in the Pellet l Shop and seldom enter it.

6.4.4 Respiratory Protection The inspector reviewed the Respiratory Protection Program that the licensee uses at this facility, and the procedure for conducting the Respiratory Protection Program. The inspector found that although the essential elements of an approved Respiratory Protection Program were incorporated in their procedure, the procedure lacked detailed instruc-tions on such activities as qualitative fit testing and training respirator users on the equipment. The licensee stated that the respiratory protection procedure will be revised and improved by incorporating additional details into the procedures to make them more comprehensive. The status of this procedure will be reviewed in a future inspection. (70-1100/87-01-03)

No violations were identified during the review of the licensee's 4 internal exposure controls program.

7.0 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";

l

. 11 Regulatory Guide 8.24, " Health Physics Surveys during Enriched Uranium-235 Processing and Fuel Fabrication"; and ANSI N323-1978, "American National Standard Radiation Protection Instrumentation Test and Calibration."

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

discussions with cognizant health physics and instrument calibration personnel; tour of the calibration facility; review of calibration records and selected instrumentation; review of work station survey sheets; review of daily efficiency and background check records; and review of " Procedure for Control and Calibration of Radiation Detection Devices," No. 00000-EID-012, dated September 19, 1986.

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

The inspector identified significant deficiencies in the calibra-tion laboratory during NRC Inspection Report No. 86-03, conducted

~

March 10-14, 1986. During the current inspection, the inspector found that no improvements or corrective actions had been taken.

The setup for radiation instrumentation calibration remained the same as identified in the previous inspection.

A review of work station survey results and discussions with health physics technicians revealed that the majority of radiation surveys are routinely performed with an Eberline E-520. The E-520 is cali-brated in-house by the licensee with the exception of the 0-2000 mr/hr scale which is appropriately tagged so as not to be used.

A review of the calibration procedure 00000-EID-012, which addresses the calibration of all radiation detection instruments, indicated that the procedure does not ensure compliance with license conditions.

Section 3.2.4 of the license conditions requires that all instrumen-i tation, other than the criticality alarms, be calibrated twice per year. In addition, it requires that all calibrations "shall meet the specifications described in Section 1.11 of Regulatory Guide 8.24." Regulatory Guide 8.24 stated in paragraph 1.11 that a proper calibration shall include "two points separated by at least 50 per-cent of each linear scale that is used routinely" and that "a survey instrument may be considered properly calibrated when the instrument readings are within 10 percent of the known value."

i

l i

, 12 Inspector review of the calibration history records revealed that the 0.2 mr/hr scale of the E-520 was never calibrated. The 0-20 mr/hr

.and 0-200 mr/hr scales, which were occasionally used, were only cali-brated at one point on the linear scale. Additionally, procedure 00000-EID-012 states that the acceptance criteria for a valid cali-bration point is 15 percent of full scale rather than the required 10 percent of the known value. This constitutes an apparent vio-lation of SNM license condition 3.2.4. (70-1100/87-01-06)

The inspector noted that although the Eberline PNR-4 neutron survey instrument is electronically calibrated with a pulser according to the manufacturer's recommended response value of 50 cpm per mrem /hr, the high voltage is not checked to verify compliance with original detector requirements. Variations in detector high voltage will affect detector sensitivity. The inspector discussed this finding

-with licensee representatives. The inspector also discussed the apparent unfamiliarity of the electronics technicians, in the calibration laboratory, with the requirements of radiation survey instrumentation calibration, in addition to the above-mentioned violation of license conditions.

8.0 Radioactive Waste Management The licensee's program for the control of liquid, gaseous, and solid radioactive waste was reviewed with respect to criteria contained in 10 CFR 20.106, 20.301, 20.311; and SNM License No.1067, Sections 6.1, " Liquid Effluent Discharges;"

6.2, " Airborne Radioactivity Discharge; and 5.1, " Effluent Control Systems Commitments."

The licersee's performance related to the above criteria was determined by:

discussions with licensee personnel; review of procedures related to these areas; and review of data generated from monthly composite samples of gaseous and liquid effluent.

8.1 Liquid Effluents All liquid waste from the Nuclear Fuel Manufacturing Facility (Bldg. 17) is diverted to the waste water processing facility (Bldg. 6) which is comprised of six holding tanks of 2000 gallons each (only one is in use at a time) and two dilution tanks of 10,000 gallons each. The licensee stated that the method of level indica-tion had been changed. Level actuation relays have been installed that signal when the tank is , and full. No other level indica-tion information is available other than direct inspection. The maintenance department cleans and verifies operability of the relays monthly. The licensee also stated that since only full tanks are processed, dilution factors and final release concentrations can be L _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _

, 13 accurately calculated to ensure compliance with 10 CFR 20, Appendix B, without the need for continuous level indication.

8.2 Gaseous Effluents The licensee's ability to monitor gaseous vent effluents was evalu-ated. Each vent is monitored by a sample pump operating at a fixed flow rate located downstream of the filter systems. Air sample filters are collected daily and the calculated activities averaged weekly and monthly.

The inspector reviewed the semi-annual effluent reports for the second half of 1985 and for 1986. The inspector noted that the licensee combines the gaseous effluent numbers from two quarters for the semi-annual effluent reports. However, the license condi-tion states that the licensee shall not exceed an amount of activity (18 microcuries) per quarter. The inspector discussed this with the licensee, and stated that gaseous activity should be reported for each quarter, because reporting of the gaseous effluents for a six-month period may not ensure compliance with the license limit of 18 microcuries per quarter. The licensee stated they will report quarterly effluent numbers in future semi-annual effluent reports.

This item will be reviewed in a future inspection.

(70-1100/87-01-07)

During a review of the ventilation monitoring activities, the inspector noted that the necessary pump flow to establish isokinetic sampling is determined from the vent flow, as indicated by a mano-meter and a licensee generated curve. The inspector also noted that the manometer is located at a different point in the ventilation duct as is the sampling probe. The licensee stated that the system was engineered to take a representative sample. Through discussions with cognizant personnel, the inspector determined that isokinetic sampling had not been verified for some time. The licensee stated that a contractor would be hired to evaluate the effluent monitoring system. This area will be reviewed in a future inspection.

(70-1100/87-01-08) 8.3 Solid Radioactive Waste The inspector reviewed procedures for assaying and packaging radio-active waste that was shipped to burial sites for disposal. The inspector found a limited and generalized procedure in the Health and Safety manual for sorting, assaying, compacting, and packaging material for shipment to disposal sites. Through discussions with licensee personnel, the inspector was able to determine that solid waste was sorted in a hood, packaged, and compacted before packaging for shipment. The licensee only disposes of general shop trash, consisting of gloves and paper towels. Any material that contains quantities of Uranium oxide powder that could be reclaimed is shipped to Hematite for reprocessing.

. 14 No violations were identified in the licensee's radioactive waste management program during this inspection.

-9.0 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"; and Regulatory Guide 4.15, " Quality Assurance for Radiological Monitoring Program."

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

interviews and discussions with licensee personnel; and review of the 1986 Environmental Monitoring Report.

Within the scope of this review, no violations were identified. The licensee was performing the environmental analyse. required in the special nuclear materials license. As stated in paragraph 3.7, the licensee had not yet formally established their quality assurance program for environ-l mental samples, with respect to an implementing procedure.

10.0' Transportation Activities The licensee's program for transportation of radioactive materials was reviewed against criteria contained in:

10 CFR 71, " Packaging and Transportation of Radioactive Materials."

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

discussions with licensee personnel; I

l -

determination of the status of the QA program for compliance with Subpart H of 10 CFR 71; and review of selected transportation documentation logs and paper work.

l i- Within the scope of this, no violations were identified. The licensee has a current and approved QA program to assure compliance with Subpart H of 10 CFR 71. The QA program was approved June 11, 1984.

. 15 The licensee transports four types of radioactive' materials. The primary shipments are fuel shipments from the manufacturing facility. The inspec-tor reviewed the logs for these shipments and noted that a copy of Form 741 was sent with the shipment, 2 copies of Form 741 were sent to the receiver through Express Mail, the appropriate shipping notices were filed with the states as needed, and the appropriate package Certificates of Compliance were maintained.

The licensee also ships samples of fuel pellets in exempt quantities for analysis to two laboratories. Residue shipments are made to Hematite, and radioactive waste is shipped to Barnwell,. South Carolina. Certificates of Compliance are maintained on file for all packages used.

Health Physics personnel are responsible to ensure that the appropriate radiation surveys are performed on all outgoing packages. During the inspection, the inspector found a shipping paper which had dose rate information that did not appear to comply with the package labeling requirements. Licensee representatives stated that an error was made on the decimal point placement for the-dose rate, and that the package was well below package labeling requirements. The inspector stated that there should be some management oversight to ensure that the shipping papers for packages are properly documented, or verified prior to release. This area will be further reviewed in a future inspection.

(70-1100/87-01-09) 11.0 Exit Interview The inspector met with the licensee's representatives (denoted in para-graph 1) at the conclusion of the inspection on April 16, 1986. The inspector summarized the purpose and scope of the inspection and findings as described in this report.