ML19320B776
| ML19320B776 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/13/1980 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19320B771 | List: |
| References | |
| NUDOCS 8007150031 | |
| Download: ML19320B776 (7) | |
Text
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GENER AL h ELECTRIC NUCLEAR ENERGY x
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PRODUCTS DIVISION
' 'I' WILMINGTON MANUF ACTURING DEPARWENT CASTLE HAYNE ROAD P. O. BOX 780 f
TON 2
. (919) 343-5000 June 13, 1980 Mr. James P.
O'Reilly, Director U.
S.
Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
Refercnces:
(1) NRC Inspection Report RII:PWS, 70-1113/80-3, 3/4/80 (2) Letter, AL Kaplan to JP O'Reilly, 4/9/80 (3) NRC License SNM-1097, Docket #70-1113 With reference to your inspection leport dated March 4, 1980, your staff has requested further information related to our answer to that report dated April 9, 1980.
This information is enclosed as an attachment to this letter.
General Electric personnel would be pleased to discuss this matter with you and your staff as you may deem necessary.
Very truly yours, GENERAL ELECTRIC COMPANY Arthur L. Kaplan, Manager Licensing & Compliance Audits M/C J26 ALK : hmw Attachment NSD-I cc:
Document Management Branch i
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goon 150
- ymcIAL COPY,
G E N E R AL j) E LE CTRIC Mr. J. P. O 'Reilly June 13, 1980 Attachment - Page 1 ADDITIONAL INFORMATION RELATED TO NRC INSPECTION REPORT RII:PWS, 70-1113/80-3, 3/4/80 The following is the additional information requested by the NRC Region II staff, related to our response to inspection report RII:PWS, 70-1113/80-3, 3/4/80.
1.
Does attyotte take cottttal of and track tite receipt of UF, cythtdets before t
titey are artloaded from ovetpacks?
Yes, in the following manner:
- 1) The trailer is logged in and out on a log sheet by the guards located at the Emergency Control Center.
Everyone going to or coming from the fuel manufacturing area must pass through this point.
- 2) In addition, these same guards will have a large board posted in their office at the Emergency Control Center, on which each trailer with UF6 overpacks are tracked by trailer number, as to whether or not they are in the controlled access area.
This will be Unplemented by July 14, 1980.
- 3) The fuel support foreman receives the UF6 cylinder trailer from the truck driver.
He verifies the trailer number and he verifies that the seals affixed to the cylinder overpacks by the enrichment facility are intact.
He then affixes a verification sticker to the short-form bill of lading which accompanies the shipment.
If one seal on an overpack were broken, he would receive the shipment.
If both seals on an overpack were broken, he would hold the driver _and call his unit manager (Manager-Fuel Support) for further instructions.
- 4) The fuel support foreman then notifies the radiation protection office that a shipment has been received and is awaiting monitoring.
Notification time is documented on the verification sticker.
GENER AL $ ELECTRIC Mr. J. P. O'Reilly June 13, 1980 Attachment - Page 2 2.
How does the above (i.e., answer t.o Question M1) fit ido your mderial conttot and accounting ptogram? !s a tog kept on their location in the yard?
- 1) Cylinders are stored on the trailers after their receipt.
The trailers are located in the roadway behind (on the west side of) the fuel manufacturing building, until they are removed from their overpacks, weighed, and their weights entered into MICS.
- 2) Our control over these cylinders prior to their removal from the overpacks and entry of their weights into MICS, with respect to our material contre.l. and accounting program, is exercised by the receipt procedure and the log sheet tracking procedure described in Item 1.
- 3) The presence or absence of a trailer by identification number, is noted in the guard log and will be tracked on the status board maintained by the guards as described above.
- 4) The guard log sheet and status board.and the receipt and verification procedure carried out by the fuel support foreman for trailers carrying full UF6 cylinders, provide the link in our material control and accounting program between shipment of the UF6 by the vendor and entry of the cylinder weights into MICS.
- 5) The log descriM d above only specifies whether or not a particular trailer is in the fuel manufacturing area, but not specifically where in t nat area.
We believe that this control, plus all of the other new controls implemented on t M handling of UF6 cylinders that are full or empty, or contain hec quantities, and also the relatively small size of area in which these trailers are stored, all preclude the necessity of another log specifying the exact location of a trailer in the fuel manufacturing area.
3.
Relative to the following paragraph (#1) on page 2 of inspection report 80:03:
"We are concerned abod.the imptemeMaticn of your management and nuclear material control systems that permitted this occurrence. In addition tn your response to the specific items of apparent noncompliance, please ptovide us a unitten description of.those actions taken or planned, inelwiing imple-menting schedules,.to improve.the effeetiveness of your manage-ment and nuclear material control systems."
More information is requeMed relative to management and nuclear material conttot systems, i.e., polic.ies, higher tevet procedures than Nuclear Safety Instructions, etc.
G E N E R AL llI E LECTRIC Mr. J. P. O'Reilly June 13, 1980 Attachment - Page 3 As a result of this incident, the Section Manager of Quality Assurance quickly called for a full-scale investigation to establish the cause and to determine corrective actions required to prevent recurrence.
The first step of this investigation was establish the cause.
From this investigation, we have concluded the cause for the occurrence of this incident was the lack of documentation in procedures, instructions, etc., concerning the handling of trailers with empty UF overpacks in our facility.
6 In order to prevent recurrence of this incident, we reviewed thorough-ly the actual practices and written procedures and instructions related to all handling of incoming and outgoing UF6 overpacks.
As a result of this review, we improved the handling practices, especially those related to outgoing empty overpacks.
We changed a number of existing procedures, including unit-level Traffic &
Material Distribution (T&MD) procedures and two department-level Practices & Procedures (P/Ps) dealing with receiving and shipping UF6 cylinder trailers.
We also issued new instructions to shipping, fuel support and production control personnel involved in this activity.
This investigation was continued to cover handling practices and procedures related to other nuclear fuel shipping packages.
- However, after reading preliminary conclusions about the adequacy of the mora frequently used packages, the team temporarily ceased its activities.
l The reason was that, in addition to the specific investigation re. lated to the handling of UF6 cylinders, the Section Manager of Quality Assurance also assembled a group of expert consultants not associated 1
with the Wilmington plant or with General Electric (except for one i
of the three consultants who is a corporate level consultant on transportation matters) to study all our shipping and receiving practices and procedures related to all hazardous materials.
The members of this group have completed their study and are in the i
process of submitting their findings to our management.
We expect their report to be completed by July 11, 1980.
The leader of this group is Mr. William A. Brobst, former Chief of the AEC and DOE transportation safety programs and former Deputy Director of the DOT's Office of Hazardous Materials.
After this incident occurred, a senior specialist in the Traffic &
Material Distribution unit, who has a great deal of practical experience in packaging and transportation of radioactive materials, as well as a thorough f amiliarity with NRC and DOT requirements
.concerning the same subject, was assigned the full-time responsibility for administration of the shipment and receipt of all hazardous materials to assure compliance with NRC and DOT requirements.
G E N E R A L j) E LECTRIC Mr. J.
P. O 'Reilly June 13, 1980 Attachment - Page 4 Management awareness of and concern for proper shipping and receiving of radioactive materials can be demonstrated by the above actions, as well as the upper-management policies, practices and procedures presently in place which require compliance with regulatory require-ments in general, and which implement safe shipping and receiving of radioactive materials in particular.
These include the following:
e NEBG OPGs (Nuclear Energy Business Group Organization & Policy Guides) 70- 4 Nuclear Safety in NEBG Operations 70- 6 Safeguards Systems for Control of Nuclear Material 70-17 Occupational Radiation Exposure 70-18 Nuclear Criticality Safety 70-32 Radiation Protection for Employees Working Offsite 70-42 Reporting Defects & Noncompliance 100- 2 Environmental Protection 100- 5 Emergency Planning e
WMD P/Ps (Wilmington Manufacturing Department Practices & Procedures) 30- 3 Custodial Responsibilities for Nuclear Materials 30- 7 Reporting Defects & Noncompliance 30-31 Disposal of Surplus or Obsolete Equipment or Tooling 30-41 Training for Low-Level Radioactive Waste Activities 40- 1 Wilmington Technological Safety Council 40- 2 Industrial Safety 40- 3 Limiting Non-Essential Material in Controlled Areas 40- 4 Nuclear Safety Design Criteria 40- 5 Nuclear Safety Review System 40- 6 Regulatory Compliance Audits 40- 7 Occupational Radiation Exposure Control 40- 8 Classification & Posting of Areas 40- 9 Service Work in Controlled Areas 40-10 Procurement, Use & Disposal of Radiation Sources &
X-Ray Machines 40-12 Nuclear & Environmental Incident Investigation 40-13 Environmental Protection 40-14 Final Process Effluent Control System 40-35 Safety Responsibilities - Radiation Emitting Equipment 40-16 Nuclear Safety 40-17 General Nuclear Safety Requirements & Training 40-18 Regulatory Compliance Aduinistrative Action Guidelines 40-19 Bioassay Program 40-21 Radiation Protection for Offsite Work 40-22 Respiratory Protection Program
- GENER AL $ ELECTRIC Mr. J. P. O'Reilly June 13, 1980 Attachment - Page 5 90- 1 Receiving & Shipping of Radioactive Materials 90- 3 Radioactive Material Shipping Containers 90- 5 Shipping Notices 140- 1 Uranium Physical Inventories 140- 2 Special Nuclear Material Scrap Control 140- 3 Preparation & Approval of NED 48 Documents 140- 4 Change Control of Safeguards System 140- 5 Special Nuclear Material Measurement Systems 140- 6 Measured Values of Metal Impurities in SNM 140- 7 SNM Replicate Sampling Program 140- 8 Measured Average "ranium & Isotopic Factors 140- 9 SNM Measurement Training & Qualification 140-10 Tampersafing Program 140-11 Application of Tampersafe Seals 140-14 Measurement of Process Liquid Waste Streams 140-21 Operation of the NRC ND Assay Van 140-43 Station Inventory Action Limit Controls 4.
With refetence to item of noncompliance C from inspection report 80-03:
"C. As requited by 10 CFR 20.205(b)(1), 'Each licensee, upon receipt of a package of radioactive materlat, shall monitor the extetnal surfaces of t.he package for nadioactive contamination caused by teakage of.the radioactive contents... The monitoring shall be perfarmed... no latet than three hours after the package is received at the licensee's facility if received during.the normal wo.tking hours... '
conttary to the above, the licensee fa.ited to monitor
~
the external surfaces of packages con.taining radio-active material (cylindet overpacks) on trailer number 340217 received on January 23, 1980, ptior to.the subsequent shipment offsite of.that traiter on January 24, 1980."
How do Radiation Protection personnel know when to perform swtveys? These surveys have to be done after receipt (as defined above); and receipt is
^
defined as when GE accepts responsibliity for the shipnent.
Please see Section 1 above, specifically Items 3 and 4.
- Also, NSI O 17.0, Shipment & Receipt of Radioactive Materials, the instruction to Radiation Protection personnel on monitoring of e
g.
GENER AL $ ELECTRIC Mr. J. P. O 'Reilly June 13, 1980 Attachment - Page 6 incoming and outgoing radioactive materials packages, was modified to refer specifically to the requirement referred to in Item of Noncompliance C above.
" Normal working hours" pertains to the working hours of the fuel support foreman, who has the responsibility for accepting incoming shipments of full UF6 cylinders.
At present, a fuel support foreman is on duty twenty-four hours per day, seven days per week.
If in the future, coverage by a fuel support foreman should be reducel for example to twenty-four hours per day, Monday through Friday, then an incoming shipment of full UF6 cylinders on a Saturday or Sunday would not be received by GE (i.e., the fuel support foreman), until a fuel support foreman were next on duty on the following Monday.
Under these conditions, the shipment would be logged in by guards at the Emergency Control Center as described above, and the trailers would be stored within the controlled access area until the fuel support foreman returns to work.
A. L. Kaplan
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