ML20214S456

Notice of Violation from Insp on 870413-17

ML20214S456
Person / Time
Site:	07001100
Issue date:	05/26/1987
From:	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 8706090276
Download: ML20214S456 (3)

Text

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APPENDIX A NOTICE Of VIOLATION Combustion Engineering, Inc. Docket No. 70-1100 C-E Power Systems - Nuclear Fuel Manufacturing License No. SNM-1067 Windsor, Connecticut 06095 As a result of the inspection conducted on April 13-17, 1987, and in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement Policy) (1986), the following violations were identified:

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 specified in Appendix C of this part shall be conspicu-ously 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 - RADIOACTIVE MATERIALS" sign, in that, neither one of the primary access points to the Pellet Shop nor inside the Pellet Shop were posted as required.

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

B. 10 CFR 20.203(f)(1),(2), and (3)(i) states "each container of licensed material shall bear a durable, clearly visible label identifying the radioactive contents...(and) shall bear the radiation caution symbol l and the words ' CAUTION - RADI0 ACTIVE MATERIAL.' It shall also provide sufficient information to permit individuals handling or using the con-tainers, 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 C of this part.

Contrary to the above, on April 13-16, 1987, several containers, boxes, bags, and a 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 and the words " CAUTION - RADI0 ACTIVE MATERIAL,"

nor were labeled with information identifying the radioactive contents.

This is a Severity Level IV violation. (Supplement IV) l 8706090276 070526 0 PDR ADOCK 07001 C

OFFICIAL RECORD COPY IR CE 87 0003.0.0 05/16/87

. Appendix A 2 C. License SNM-1067, Part I, License Conditions, Section 3.2.4, "Instrumen-tation," 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.'" Sec-l tion 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, the 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 inade-quately calibrated instruments were used to perform radiological surveys including those performed during April 13-16, 1987.

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

D. SNM-1067, Section 2.7.2, " Operating Procedures for Nuclear Fuel Manufac-turing" states, in part, that "all operations involving radioactive materials have written procedures which include the appropriate safety requirements and are followed." Section 3.1.1, " Radiation Work Permit Procedures" states " written operating procedures for the Health and Safety group are provided and followed..." and Section 4.1 states, "a manual entitled, ' Nuclear Licensing & Safety Procedures' ... necessary to implement the radiation protection program ... is maintained by the NLSA&S group."

Contrary to the above, certain procedures for the Health and Safety group necessary to implement the radiation protection program were not provided. No 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 materials in unrestricted areas, as required in 10 CFR 20.207; for transfer for disposal and manifests, as required in 10 CFR 20.311; nor for checking criticality monitors, as required by 10 CFR 70.24.

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

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."

0FFICIAL RECORD COPY IR CE 87 0004.0.0 05/21/87 /

I Appendix A 3 Contrary to the above, for the 1985 and the 1986 Annual Audits, the Con-sultant to 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.

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

Pursuant to the provisions of 10 CFR 2.201, Combustion Engineering, Inc. 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.

0FFICIAL RECORD COPY IR CE 87 0005.0.0 05/16/87 i

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