ML20005G613
| ML20005G613 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/03/1990 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20005G608 | List: |
| References | |
| 70-1113-89-05, 70-1113-89-5, NUDOCS 9001190411 | |
| Download: ML20005G613 (19) | |
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~ ENCLOSURE 1 NCTICE OF VIOLATION General Electric Company Docket No.: 70-1113 Wilmington, NC License No.: SNM-1097 L During the Nuclear Regulatory Commission (NRC) onsite inspection conducted on May-22-26 and June 12-15, 1989, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC e ~ Enforcement' Actions," 10 CFR Part 2, Appendix C (1989), the violations are listed below: A. 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for~ the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent of-radiation hazards that may be present. 10 CFR 20.201(a)' defines a survey to mean an evaluation of the radiation protection hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a 4 physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive materials present. l 10 CFR~ 20.103(a)(3) requires the licensee, for purposes of determining compliance with the requirements of this section, to use suitable measurements: of concentrations of radioactive materials in air for detecting.and evaluating airborne radioactivity in restricted areas and in i l addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes-of radioactivity by exposed individuals. l' Contrary to the above, licensee surveys were inadequate in that on October L 18, 1988, for two contract personnel installing Heating Ventilation Air L Conditioning (HVAC) Management and Control System equipment in the overhead and on the recirculation fan platforms located above the Slugger areas, the licensee did not conduct physical surveys of the work location, materials, equipment, nor did the licensee make adequate measurements of concentrations of radioactive material in the air for detecting and evaluating airborne radioactivity hazards present. l B. Part I, Section 3.2.4.2.1 of the licensee's Application for License No. SNM-1097 requires the radiation safety function to evaluate annually, and following process and equipment changes, fixed filter sampling points for representativeness of personnel exposures. 9001190411 900103 ADOCK0700g3 PDR C l --a -e m-r-w,
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W,: 4(. + C i't . General-Electric Company Docket No. 70-1113-l< Wilmington,-NC-2- License No. SNM-1097 e ' Contrary to the above, from '1986-1989, the= licensee' failed to conduct adequate--evaluations. to demonstrate fixed filter sampling point representativeness, annually and following process or equipment changes. s This is a Severity Level IV violation (Supplement IV). + C. License Condition Nc. 9 of SNM License No.1097 requires that licensed material be used in accordance' with statements, representations, and conditions of Part I of the License Application dated October 23, 1987.
- Part I, Section. 2.7.1 of the licensee's Application for License
- No. SNM-1097 requires - that radiation protection function activities be conducted in'accordance with written procedures. 1. Nuclear Safety Release / Requirements (NSR/R) No. 85.04, General Controlled Area Rules, Revision (Rev.) 7, ' dated April 26, 1988, requires the use of a (1) yellow and magenta rope or tape, and yellow - .and magenta signs displaying various warnings or protection 4 requirements - (Example: full face mask required) and/or a (2) flashing yellow light to alert personnel to conditions causing a high airborne contamination area. Contrary to the above, the licensee failed to follow procedures for alerting personnel to conditions causing high airborne contamination areas on May 2S, I?89, in that: (1) a location in the Slab Blender area was barriered off with yellow and magenta tape but was not posted with the yellow and magenta signs displaying warnings or protection requirements; and (2) a location between the Number (No.) 3 and No. 4 Chemical Area Calciners, posted on one side as an airborne radioactivity area and containing contaminated No. 3 Slugger parts with highest smearable contamination levels of 50,887 disintegrations per-minute per 100 square centimeters (dpm/100 cm ) was not barriered e off properly with the barrier rope suspended completely around the designated areas. 2. NSR/R No. ' 85.05, Protective Clothing Rules, Rev. 4, dated August 13, 1987, requires that only authorized personnel wearing appropriate protective clothing / equipment are permitted within a marked-off contaminated area and also that head coverings are worn and cover all hair possible. Posted instructions at the entrance to the Controlled Area stipulate that working and observation personnel wear a cap covering all hair. Contrary to the above, the licensee failed to follow procedures for use of protective clothing in that: (1) on May 23-25,1989, an estimated ten (10) of 100 personnel observed in the Controlled Area wore their caps in a manner that did not cover all the hair possible; (2) on June 13-14, 1989, nine of 100 personnel observed in the Controlled Area wore their caps in a manner that did not cover all hair possible; and (3) on June 14, 1989, an individual entered beneath
~ y 3. c y.s. a v... W 0 b, - General Electric Companye -Docket No. 70-1113 Wilmington, NCL 3 License No. SNM-1097 i the V106 tank, posted: as a Controlled-Surface Contamination Area, without wearing any protective clothing. 3.. Practices and Procedures (P/P) No. 22. Respiratory Protection L Program, Rev. 5, dated March 23, 1988, Appendix B. Step A.2 and Step 5 1 h'_ requires: (l'). that individuals return respirators to designated storage areas or Controlled Area laundry when the immediate use/need is fulfilled and (2) that used respirators are not to be left in the Controlled Area from one shift to another but should be placed in the " dirty mask" receptacles or returned to the laundry. Nuclear Safety' Instruction (NSI) No. 0-1.0, Respiratory Protection - Training :and - Fitting, Rev. 15 dated March 8, 1989, requires individuals to return respirators to designated storage areas when the immediate use/need is fulfilled. ~ ' NSR/R No. 85.06, Face Mask Rules, Rev. 5, dated April 20. 1988, 3'. requires that respirators not be left on equipment and/or tool boxes l when no longer needed. L L Contrary to the above, the licensee failed to follow procedures for respiratori storage in that respirators were noted in the following unauthorized locations: (1) on May 23,1989, an unwrapped (used) c respirator: placed on a bucket in the Slab Blender area, and two poly-wrapped (unused) respirators placed inside a fire hose station cabinet in the Uranium Recovery Unit (URU) area; (2) on May 25, 1989, one used respirator placed. on the work stand opposite the control panel in the. Slab Blender area, and -one unused respirator placed inside an area barriered off and posted as requiring a full face respirator near the partially. disassembled No. 3 Slugger; (3) on June 13 '1989, a used respirator placed inside a cardboard box underneath rags and-other pieces of cardboard behind Hammermill No. 6, a used respirator placed on top of an electrical control panel in front of Hammermill No. 3, two unused half-face respirators placed in the drawer of a work station desk beside Slugger / Granulator No. 5; (4) on June 14, 1989, a used respirator placed on a can in the Slab Blender area, and a used respirator placed on a control panel near Hannermill No. 3; and (5) on--May 23, and June 14, 1989, used respirators in the Slab Blender area ~ not returned to the " dirty mask" receptacles or returned-to the laundry between shift changes. 4. NSR/R No. 85.08. Personnel Survey Leaving Controlled Area Rev. 7, dated December 8, 1986, requires that personal surveys be conducted by placing the scanner probe on an area to be surveyed, holding the probe in place for one to two seconds and monitoring the hands, wrists, chest TLD badge, neck, face, hair, ankles, and shoes at a minimum. Contrary to the above, the licensee failed to follow required personal survey procedures resulting in inadequate surveys in that: (1) on May 23, 1989, of two people observed exiting the UO2 Conversion Controlled Area and one person observed exiting the URU Controlled
g3 ,{ p ei. -,, General Electric Company'- Docket No. 70-1113 [ Wilmington _NC - 4. License No. SNM-1097 Area. all three persons moved the probe too rapidly and did not hold the-probe in place for the required one to two seconds; and (2) on - May 25,1989, of 22 people - observed - exiting the UO2 Conversion Contolled Area, six moved the probe too rapidly ~and/or did not survey. L all designated areas; (3) on June 13, 1989, three of nine individuals-1 observed exiting the UO2 Conversion Controlled Area moved the probe too rapidly or did not survey all designated areas;. and (4) on d June 14,1989, an individual-observed exiting the controlled area ~ established beneath the V106 Tank - did not perform : a - personal . contamination survey subsequent to leaving the area. ,5.- Practices-and Procedures (P/P), 40-22, Respiratory Protection Program, Rev. 5, dated March 22, 1988, details cognizant managers as responsible for scheduling respiratory protection-training and REMTRAC data entry, and the Nuclear Safety Engineering Section as-responsible for issuing REMTRAC Status Reports for Fitting / Training status and providing periodic respiratory protection training. Contrary to the above, as of May 26, 1989, thirteen (13) individuals were overdue their annually scheduled' Self-Contained Breathing Apparatus (SCBA) training, as noted by.the REMTRAC Status Report dated March 24. 1989. j 6. NSR/R Control No. 4.1.16, Respiratory Testing, Rev. O, dated January 21, 1982, requires that full-face masks not used after thirty (30) days be returned to the laundry for. reinspection. Contrary to the above, the licensee failed to follow procedures in that unused respirators placed in a storage cabinet in the URU-area on April 24,1989, had not been returned to the laundry after 30 days for reinspection. 17. NSR/R Control No.1.1.26. Empty Can Storage - FM0, Rev. 2, dated June 3,1987, requires that empty cans must have a lid and lock ring in' place and that empty cans.must be free of visible contamination. Contrary to the above, the licensee failed to follow procedures for empty can storage in that: (1) on June 13, 1989, nine cans placed in four separate locations of the B&W Blender Area did not have lids and/or lock rings-in place and one had visible powder in the bottom, one can -located behind Slugger No. 5 had no lock ring in place, approximately ten cans in the Radwaste hallway leading to the Old . Decontamination area had no lock ring in place, and one can located in 1 the Stacker Warehouse had no lid or lock ring in place; and (2) on June 14, 1989, two cans located in the B&W Hammermill area had no lock rings in place, s. 8. P/P No. 40-22, Respiratory Protection Program, Rev. 5, dated March 23, 1988, requires Plant Medical personnel to determine that an individual is medically capable to wear a respirator and annually reevaluate this determination. 2
l, r, L I p;-,..,.s .c 4" General Electric Company. Docket No. 70-1113 Wilmington. NC 5 License No. SNM-1097 'The criteria listed in Appendix D of the Cotton Dust Standard as found
- in the Federal Register, Volume 43, Number 122, dated June 23, 1978, is used by ine licensee to determine if a person is medically capable
- of wearing a respirator. Appendix D requ. ires that at least three forced expirations be carried out by ;the personnel being tested to demonstrate acceptability to wear a respirator. Appendix D also lists the criteria used to determine when a person is not allowed to wear a .t respirator! or when the person should be retested to verify acceptability. One of the criteria is an excessive variability, greater'than 10 percent, between the two largest forced vital capacity-(FVC) measurements and forced expiration volume in one second (FEV1) measurements. Contrary to the above, the licensee failed to follow procedures for determining if a person is medically capable to use a respirator in that. for medical records reviewed on June 14,1989, one individual completed only two forced expirations and for another individual a h variation greater than 10 percent was recorded between the two largest FCV's'and FEV1's -9. P/P 40-18, Regulatory Compliance Administrative Action Guidelines, Rev. 7 dated June 9,1987, establishes the action guidelines for exposure coutrol including the resubmittal of a urine sample subsequent to initial daily or weekly sample results exceeding 35 or 15 micrograms uranium per liter (ug U/1), respectively. Contrary to the above, the procedural guidance for reviewing bioassay results for non-routine samples, which exceeded established guidelines was inadequate in that details regarding the incident, including other personnel potentially involved and requiring the review of, and/or collection of supplemental survey data were not required. This-is a Severity Level IV violation (Supplement IV). 1 D. License Condition No. 9 of SNM License No.1097 requires that licensed material be used in accordance with statements, representations, and . conditions of Part I of the License Application dated October 23, 1987. Part I, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures. .NSI - No. 0-6.0, Contamination Measurement and Control. Rev. 19. dated June 7,1988, Appendix C, requires that smearable contamination in excess of 10,000 dpm/100 cm2 alpha or visible contamination on floors and 25,000 dpm/100 cm2 alpha on controlled area equipment, be cleaned immediately. Contrary to the above, radiation protection activities were not conducted in accordance with written procedures in that: (1) during June 13-14, 1989, visible contamination was observed on FMO Powder Warehouse railings and J -e
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License No. SNM-1097 floor areas and a NRC requested contamination survey indicated maximum contamination levels of 30,000 dpm/100 cmr on railings and selected equipnent'.in the area; and (2) on May 25,1989 NRC requested contamination surveys of the No. 3. Slugger equipment parts, which had been maintained'in the Controlled Area for several days, indicated maximum smearable e contamination levels of 60,000 dpm/100 cm, This is a Severity Level IV violation (Supplement IV).. Pursuant to the provisions of 10 CFR 2.201, General Electric Company is hereby 1 required to ' submit a' written statement or= explanation to the Nuclear Regulatory Commission ATTN:- Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a l Notice of Violation: and should include for each violation: -(1) admission or j denial of! the. violation. (2) the reason for the violation if admitted. -(3) the corrective steps which will; be taken to avoid further-violations, and (5) the date 'when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the repsonse time. If an adequate i reply is not received within the time specified in this Notice, an order may be . issued to show cause* why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. FOR THE NUCLEAR REGULATORY COMMISSION a 1p o , Director i ision Radiation Safety 4 and Safeguards Dated at. Atlanta, Georgia I this arctiay of Januar)1990 l i
c c. b ENCLOSURE 2 EVALUATIONS AND CONCLUSIONS I .On July 27.-1989, a Notice-of Violation (Notice) was issued for four violations identified during-a special NRC inspection. The General Electric Company responded to the Notice on October 10, 1989. -The licensee requested that Violation A be classified as licensee-identified, denied Violation 8 and, in addition.. requested that Violations C & D should be classified as a single ~ ' issue. The~NRC's evaluations and conclusions regarding the licensee's arguments are as follows: Restatement of Violation A 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys ~ as -(1)- may be necessary for the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent- 'of radiation hazards that may be present. 10 CFR'20.201(a)f defines a survey to mean an evaluation of the radiation protection hazards--incident to the production, use, release, disposal, or presence'of' radioactive materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey .of the location of materials and equipment, and. measurements. of levels of radiation or concentrations of radioactive materials present. 10 CFR 20.103(a)(3) requires the licensee, for purposes of determining compliance with the requirements of this section, to use suitable measurements of. concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary 'for timely detection and assessment of individual intakes of radioactivity by exposed individuals. Contrary to the above, licensee surveys were inadequate in that on October 18, 1988, for-two contract personnel installing Heating Ventilation Air Conditioning (HVAC) Management and Control System equipment in the overhead and on the recirculation fan platforms located above the Sluqqer areas, the licensee did
- not conduct physical surveys of the work location, materials, equipment, nor did the -licensee make adequate measurements of concentrations of radioactive material in the air for detecting and evaluating airborne radioactivity hazards present.
This is a Scyerity Level IV violation (Supplement IV). Summary of Licensee's Response to Violation A The licensee concurred that the violation occurred as stated; however, they requested that the event be categorized as a Licensee-Identified Violation (LIV)
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Enclosure ' 2 - 2 m pursuant to.~ 10 CFR Part 2, Appendix C. Section V(G). The basis for their
- request'was'as follows
a. The event was identified by General Electric (GE) and' was classified.
- investigated, documented, and corrected per internal procedures.
+ ' b. The' violation was classified.as a Severity Level'IV (SL4)' violation, - c. ~The.. violation was not reportable, y d. . Prompt, immediate, and thorough corrective actions were taken including the identification of root causes. Until corrective actions were completed, all: similar work in normally unaccessed areas was suspended pending a case-by-case review and, authorization by the radiation safety function. 4 Corrective actions included the following. Development and implementation of a checklist for selected work areas zthat? includes air sampling and bioassay requirements. Modifications' to radiation work ' permit (RWP) issuance and control measures. Modifications to RWP worker training requirements. The addition of radiation protection personnel focused on day-to-day coverage of RWP activities. e. 'There were no previous violations of a similar nature for which corrective I actions were taken that would have been expected to preclude this incident. The ' licensee's response agreed with the Report Details in that previous intakes i of_ soluble uranium were reported for the contractors on September 1 and October 6,,1988. However, for these intakes procedures were followed which required resamples. The resamples were analyzed and no additional action was required. ~ Furthermore, the response detailed that no investigation was performed because there was no indication during the September 1 - October 6,1988 period that a special investigation was warranted nor were there additional procedural requirements for action. The September 1 and October 6,1988 bioassay urinalyses results were characterized as small, reasonable and normal and thus - the' October 18th incident "was not a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous - violation because no previous condition would have in any way constituted a violation." Furthermore, the licensee's response indicated that the October 18, 1988 urine samples were not collected by chance. The licensee states that urinalysis program samples come from formally prescribed routines and also from worker self-initiatives stressed during training. For the events in question they believe that adequate training resulted in the appropriate samples being collected. = -
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+ The response also justified ' the scope of the 'investige tion, involving the evaluation of only 2 contract workers..This justification was determined from their June-1989 review of selected bioassay data for the additional personnel i potentially exposed during similar work conditions. During this review of . selected bioassay data, no positive uptakes of uranium material were reported, thus indicating that their initial decision to evaluate only 2 contractor workers was not in error. Finally,'the response details additional. corrective actions they are evaluating I to. address the licensee identified situation. These actions _ include (1) an
- improved capability to assure compliance to the 7 consecutive day 40 Maximum Permissible Concentration hour (MPC-hr) limit for soluble uranium, (2)'a restructuring of action guides / action levels and (3) ways to better highlight i
unexpected / unusual exposure results for followup. These evaluations and decisions on any additional changes are to be completed by December 1989. j NRC Evaluation i The NRC staff has reviewed carefully the licensee's response-and has concluded j that the licensee did not provide any, additional information that was not j already considered in determining that the violation should not be classified as a LIV. The NRC does agree that the violation was identified by GE personnel and that >several of the corrective actions were considered prompt and contributed, in -part, to evaluating the possible causes and to developing subsequent corrective l actions regarding the event, j However, the NRC considered-the promptness and thoroughness of the licensee j l evaluation-to be inadequate. The regulations specifically address requirements for all = personnel exposed to radioactive materials. The regulations state the following: 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as (1) may be necessary for the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to l evaluate the extent of radiation hazards that may be present. 10 CFR 20.201(a) defines a survey to mean an evaluation of the radiation l protection hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and l measurements of levels of radiation or concentrations of radioactive materials present. l 10 CFR 20.103(a)(3) requires the licensee, for purposes of determining compliance with the requirements of this section, to use suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body,
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m 4 m measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals. -The NRC Region II' staff views the use of air sampling as required by 10 CFR 20.103(a)(3), without exception, to be an "a priori" survey mechanism used to ' evaluate airborne. radiation hazards-present. The regulations require timely surveys to be conducted for all personnel expcsed to radioactive materials. Your initial evaluation did identify that air sampling surveys were not adequate for.the contractors working-on the selected _ areas of the HVAC; that evaluation of the intake of uranium material for the two' contract personnel was required; and that additional corrective actions, including improved training and the use of radiological-controls for contract workers was necessary. However, at no time -prior to, or during. the NRC inspections conducted May 22-26, and June 12-15, 1989, were GE radiation protection function personnel knowledgeable of-other, contract workers who potentially could have been exposed to soluble uranium material while' working on the HVAC system. In fact, during the onsite inspections,: radiation protection function personnel indicated that they were not aware of how many contractors were involved with HVAC work areas where air sampling was known to have been inadequate prior to, or during the time of the October 18. 1988 uptake event. Furthermore, selected radiation protection function personnel informed the inspector that determining the' potentially exposed personnel would be difficult. Not until June 23, 1989, approximately 8 months after the event and following NRC requests for the information during the second week of onsite inspection, did' licensee personnel provide to the NRC an accounting of contractor personnel potentially exposed to soluble uranium g l compounds during HVAC work. Information provided at that time indicated a total L of 13 individuals potentially exposed to uranium compounds in association with L the work on the HVAC system. For these '13 individuals, 5 were included in a L high potential exposure group, 3 in a intermediate exposure group, and 5 in a low exposure group. The NRC does not agree that the failure to find bioassay results indicating l-positive uptakes of uranium compounds for the contractors involved in the HVAC L upgrade construction, justified the limited scope of the licensee's initial evaluation. This information was provided "a posteriori" fc11owing several NRC requests and. indicates a lack of completeness and thoroughness regarding your corrective actions. Your evaluation did not determine when the contractors worked in areas containing soluble uranium compounds and, if appropriate urine samples had been submitted, analyzed and the results reviewed. For example, one contractor, included in the high potential exposure group, had not submitted a urinalysis sample on or around October 24, 1988, when the other 4 individuals in the group provided samples. An adequate investigation would include, immediately following the identification of radiological control problems with contract workers on, or around October 18, 1988, interviews with all personnel working on the HVAC system to determine the individuals involved and the extent of potential exposure. Such an evaluation may have permitted the collection of special urine samples from all contractors which would have strengthened your conclusions. As stated by licensee representatives during a June 23, 1989 teleconference, as a result of the short retention time for soluble uranium in the body and the absence of adequate air samples, definite conclusions regarding .D:
^ ,y a w 5 potential exposure to soluble-uranium compounds would not be possible for these personnel. The NRC staff-believes your evaluations of additional corrective actions and their subsequent implementation' would be ' a significant improvement to the
- A current radiation protection program.
Additional coments regarding these issues are discussed further in our review of your response to Violation C. NRC Conclusion For the above reasons, the NRC staff concludes that the violation can not be Lregarded as licensee-identified. . Restatement of Violation B Part I, Section 3.2.4.2.1.of the licensee's Application for License No. SNM-1097 requires the radiation safety function to evaluate annually, and following process ~ and equipment changes, fixed filter sampling points for representativeness of personnel exposures. Contrary.to-the above, from 1986-1989, the licensee failed to conduct adequate evaluations to demonstrate fixed filter sampling point representativeness, annually and following process or equipment changes. This is a Severity Level IV violation (Supplement IV). Sumary of Licensee's Response The licensee argues that documentation for demonstrating the representativeness of fixed air samples for 1986, 1987, and 1988 was not adequate to demonstrate compliance with the license requirements. However, the licensee's position is that they complied with the requirements for representative air sampling based on two methods which include detailed air flow studies for each sampling point - and comparisons of derived worker lung burdens based on air sample data to actual measured lung burdens for workers. The licensee stated that since 1985 additional air sample representativeness studies have been performed which resulted in selected changes in fixed air sampler location and airborne assignment calculational methods. The licensee concluded - that the air sampling program was functional and air sampling representativeness studies were being managed effectively. The response indicated that improvements to the fixed air sampling program are in progress including improvements in air flow study documentation; worker area assignment listings; additional air studies; and recomendations for improvements to the air sampling program. These improvements were to be completed by November 30, 1989. In addition, the response indicated that improvements to the methods used in the assigned versus measured lung burden corrparison study would be made, including
j 3 w ~ ;.. J e 6 inclusion of the calculational approach'into the REMTRAC computer recordkeeping . system and documentation of the modeling assumptions. 'NRC Evaluation The._ licensee response agreed that the documentation for evaluations was inadequate, but stated that air samples were representative based on air flow - studies and bioassay versus air sample comparisons. While these two methods. might-be effective in determining representativeness, the information provided during the inspection indicated such studies had not been done for each work station. Additionally, those few studies comparing. lung burden to air sample results provided to the inspectors during the inspection did not show clear correlation. If your review of data subsequent to the inspection has located records that demonstrate the license condition was met for annual studies and - studies after equipment changes we request you provide this additional information for our review. Finally. the-NRC staff does not agree that your program to demonstrate air sampling representativeness was managed effectively. - An effectively managed ~ program requires written procedures for conducting ' the specified - required activities. Furthermore, the procedures should delineate the responsible personnel / departments; scope of the studies; methods of conducting the study; a acceptace criteria; followup actions and reviews. 'The license conditions state ,the following:- 'Part I, Section 2.7.1 of the licensee's Application for -License No. SNM-1097 requires that radiation protection function activities be c conductednin accordance with written procedures. i Although not stated in the Inspection Report Details, the inspectors noted that there were no written procedures outlining the methods for both the fixed air l . sampling ~ representativeness and for assigned versus - measured lung burden comparison studier.. Your response did not provide any information which l procedures were-followed and the actual assumptions and criteria utilized to verify representativeness.. Based on this lack of procedures and criteria the ' NRC staff cannot determine whether the fixed air sampler and comparison study of - assigned versus measured lung burdens adequately verifys air sampling representativeness. NRC Conclusion For the above reasons, the NRC staff needs additional information if your l_ ' position is to be evaluated further. This information should include: A statement as to whether the evaluations were done for each work station L to determine representativeness and the records not maintained, or whether L they were not performed for each work station. The reason for the lack of data for the air flow studies. ( l L L
7' 1 j a r,*,, s-o f-i ~* ~ ' 7-A Procedures, previous or new, utilized to implement and verify your air sampling representativeness program, and to convert bioassay data to ) regulatory action points and limits, i The individual worker results used in the comparison studies of derived I versus measured lung burden analyses and the statistical criteria employed. The details should include assumptions utilized, and the numbers of personnel involved and their work areas for 1985, 1986, 1987, and 1988. j Restatenent of Violations C and D C. License Condition No. 9 of SNM License No.1097 recuires that licensed material.be used in accordance with statements, representations, and conditions of Part I of the License Application dated October E3,1987. Part I. Section 2.7.1 of the licensee's Application for License i No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures. 1. ' Nuclear Safety Release / Requirements (NSR/R) No. 85.04, General Controlled Area Rules Revision (Rev.) 7. dated April 26, 1988, requires the use of a (1) yellow and magenta rope or tape, and yellow and magenta signs displaying various warnings or protection requirements (Example: full face mask required) and/or a (2) flashing yellow light to alert personnel to conditions causing a high airborne contamination area. Contrary to the above, the licensee failed to follow procedures for alerting personnel to conditions causing high airborne contamination areas on May 25, 1989, in that: (1) a location in the Slab Blender area was.barriered off with yellow and magenta tape but was not posted with the yellow and magenta signs displaying warnings or protection requirenents; and (2) a location between the Number (No.) 3 and No. 4 Chemical Area Calciners, posted on one side as an airborne radioactivity area and containing contaminated No. 3 Slugger parts l with highest smearable contamination levels of 50,887 disintegrations per minute per 100 square centimeters (dpm/100 cm2) was not barriered off properly with the barrier rope suspended completely around the designated areas. P. NSR/R No. 85.05, Protective Clothing Rules, Rev. 4 dated Aegiat 13, 1987, requires that only authorized personnel wearing appropriate protective clothing / equipment are permitted within a marked-off contaminated area and also that head coverings are worn and cover all hair possible. Posted instructions at the entrance to the Controlled Area stipulate that working and observation personnel wear a cap covering all heir.
g l .; 4. f i[ t - i 8 E f t i Contrary to the above, the licensee failed to follow procedures for use of protective clothing in that: (1) on May 23-25,1989, an estimated ten (10) of 100 personnel observed in the Controlled Area 3 L wore their caps in a manner that did not cover all the hair possible; (2) on June 13-14, 1989, nine of 100 personnel observed in the p Controlled Area wore their caps in a manner that did not cover all hair possible; and (3) on June 14, 1989, an individual entered beneath the V106 tank, posted as a Controlled Surface Contamination Area, without wearing ary protective clothing. 3. Practices and Procedures (P/P) No. 40-22. Respiratory Protection i Program Rev. 5, dated March 23, 1988, Appendix D, Step A.2 and Step 5 requires: (1) that individuait return respirators to designated storage areas or Controlled Area laundry when the immediate use/need is fulfilled and (2) that used respirators are not to be left in the Controlled Area from one shift to another but should be placed in the " dirty mask" receptacles or returned to the laundry. Nuclear. Safety Instruction (NSI) No. 0-1.0, Respiratory Protection - 4 Training and Fitting, Rev. 15 dated March 8,1989, requires individuals to return respirators to designated storage areas when the i l immediate use/need is fulfilled. NSR/R No. 85.06, Face Mask Rules, Rev. 5. dated April 20, 1988, requires that respirators not be left on equipment and/or tool boxes when no longer needed. 1 Cnntrary to the above, the licensee failed to follow procedures for ' respirator storage in that respirators were noted in the following unauthorized locations: (1) on May 23,1989, an unwrapped (used) respirator placed on a bucket in the Slab Blender area, and two poly-wrapped (unused) respirators placed inside a fire hose station cabinet in the Uranium Recovery Unit (URU) area; (2) on May 25,1989, one used respirator placed on the work stand opposite the control pancl in the Slab Blender area, and one unused respirator placed inside an area barriered off and posted as requiring a full face l respirator near the partially disassembled No. 3 Slugger; (3) on June 13,1989, a used respirator placed inside a cardboard box underneath rags and other pieces of cardboard behind Hammermill No. 6, a used respirator placed on top of an electrical control panel in front of Hammermill No. 3, two unused half-face respirators placed in the drawer of a' work station desk beside Slugger / Granulator No. 5; (4) on June 14, 1989, a used respirator placed on a can in the Slab i: Blender area, and a used respirator placed on a control panel near Hammermill No. 3; and (5) on May 23. and June 14, 1989, used respirators in the Slab Blender area not returned to the " dirty mask" receptacles or returned to the laundry between shif t changes. 4. NSR/R No. 85.08, Personnel Survey leaving Controlled Area Rev. 7 dated December 8, 1986, requires that personal surveys be conducted by placing the scanner probe on an area to be surveyed, holding the probe I .~
7, .a l ' d.4 l L I " '. l 9 + r, in place for one to two seconds and monitoring the hands, wrists, chest. TLD badge, neck, face, hair, ankles, and shoes at a minimum. Contrary to the above, the licensee failed to follow required personal survey procedures resulting in inadequate surveys in that: (1) on i May 23,1989, of 'two people observed exiting the UO2 Conversion Controlled Area and one person observed exiting the URU Controlled Area, all three persons moved the probe too rapidly. and did not' hold the probe in place for the required one to two seconds: and(2)onMay 25,1989, of 22 people observed exiting the UO2 Conversion Controlled Area six moved the probe too repidly and/or did not survey all designated areast (3)' on June 13, 1989, three of nine individuals observed-exiting the UO2 Conversion-Controlled Area moved the probe i too rapidly or did not survey all designated areas; and (4) on June 14, 1989, an individual observed exiting the controlled area established beneath the V106 Tank did not perform a personal contamination survey subsequent to leaving the area. 5. Practices and Procedures (P/P), 40-22, Respiratory Protection Program, Rev.
- 5. dated March 22, 1988, details cognizant managers as responsible for scheduling respiratory protection training and REMTRAC data entry, and the Nuclear Safety Engineering Section as responsible for issuing REMTRAC Status Reports for Fitting / Training status and providing periodic respiratory protection training.
^ Contrary to the above, as of May 26, 1989, thirteen (13) individuals were overdue their annually scheduled Self-Contained Breathing p Apparatus (SCBA) training, as noted by the REMTRAC Status Report dated March 24, 1989. 6. NSR/R Control No. 4.1.16 Respiratory Testing, Rev. O, dated January 21, 1982, requires that full-face masks not used after thirty (30) days be returned to the laundry for reinspection. Contrary to the above, the licensee failed to follow procedures in L that unused respirators placed in a storage cabinet in the URU area on L April 24,1989, had not been returned to the laundry after 30 days for L reinspection. 7. NSR/R Control No.1.1.26 Empty Can Storage - FMO, Rev. 2. dated June 3,1987, requires that empty cans must have a lid and lock ring in place and that empty cans must be free of visible contamination. l . Contrary to the above, the licensee failed to follow procedures for empty can storage in that: (1) on June 13, 1989, nine cans placed in four separate locations of the B&W Blender Area did not have lids and/or lock rings in place and one had visible powder in the bottom, one can located behind Slugger No. 5 had no lock ring in place, approximately ten cans in the Radwaste hallway leading to the Old Decontamination area had no lock ring in place, and one can located in the Stacker Warehouse had no lid or lock ring in place; and (2) on
r. 6. 9 ; y.;, l r l-10 e June 14, 1989, two cans located in the B&W Hamermill area had no lock rings in place. 8. P/P No. 40-22. Respiratory Protection Program, Rev. 5, dated March 23, 1988, requires Plant Medical personnel to determine that an individual is medically capable to wear a respirator and annually reevaluate this determination. The criteria listed in Appendix D of the Cotton Dust Standard as found in the Federal Register Volume 43, Number 122, dated June 23, 1978, is used by-the licensee to determine if a person is medically capable of wearing a respirator. Appendix D requires that at least three forced expirations be carried out by the personnel being tested to demonstrate acceptability to wear a respirator. - Appendix D also lists r the criteria used to determine when a person is not allowed to wear a respirator or when the person should be retested to verify acceptability. One of the criteria' is an excessive variability. greater than 10 percent, between the two laroest forced vital capacity (FVC) measurements and forced expiration volume in one second (FEV1) measurements. Contrary to the above, the -licensee failed to follow procedures for determining if a person is medically capable to use a respirator in that, for medical records reviewed on June 14, 1989, one individual completed only two forced expirations and for another individual a variation greater than 10 percent was recorded between the two largest FCV's and FEV1's 9. P/P 40-18 Regulatory Compliance Administrative Action Guidelines, Rev. 7 dated June 9,1987, establishes the action guidelines for exposure control including the resubmittal of a urine sample l subsequent to initial daily or weekly sample results exceeding 35 or -15 micrograms uranium per liter (ug U/1), respectively. Contrary *.o the above, the procedural guidance for reviewing bioassay results exceeding established guidelines was inadequate in that details regarding the incident, including other personnel and requiring the review of, or collection of supplemental survey data were not required. This is a Severity Level IV violation (Supplement IV). I: l-D. License Condition No. 9 of SNM License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the License Application dated October 23, 1987. Part I, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.
-{ n F_ = y y.. 11 l i NSI No. 0-6.0, Contamination Measurement and Control. Rev.19, dated June 7,1988. Appendix C. requires that smearable contamination in excess of 10,000 dpm/100 cm2 alpha or visible contamination on floors and 25,000 dpm/100 cm2 alpha on controlled area equipment, be cleaned imediately. J 4 Contrary to the above, radiation protection activities were not conducted in accordance with written procedures in that: (1)duringJune 13-14, 1989, visible contamination was observed on FMO Powder Warehouse railings and L floor areas and a NRC requested contamination survey indicated maximum L contamination levels of 30,000 dpm/100 cme on railings and selected equipment in the area; and (2) on May 25,1989, NRC requested contamination surveys of the No. 3 Slugger equipment parts, which had been maintained in the-Controlled Area for several days, indicated maximum smearable contamination levels of 60,000 dpm/100 cmt, This is a Severity Level IV violation (Supplenent IV). Sunmary of Licensee's Response The licensee's response stated that GE had determined that Violations C and D 'are, in substance, the san.e violation to which the sane root causes and most elements of-corrective action apply. Additionally, the response noted that the NRC improperly referenced _"Part I. Secetion 2.2.1.4 of licensee's Application for License No. SNM-1097 instead of Section 2.7.1 for both Violations C and D. The response concurred with Violation -C for the examples of personnel not following internal procedures. With respect to violation D, the licensee concurred that a violation did occur for the June 13 -14, 1989 example of the failure to clean up spills and L accumulation of powder as soon as practical, and no later than the end of the L , shift-in the FM0 Warehouse. For the example involving the failure to cleanup L' the No. 3 Slugger Press. the response indicated that the procedure either -requires cleanup or the establishment of a contamination control area by barricading and posting the area. Further, because the Slugger Press was to be l . reassembled within a short time, decontamination to less than contamination l action limits was not warranted. With respect to Violations C and D, the response to the violations only addressed 3 of 8 examples of Violation C specifically. In the response, you indicated that; a) the new Manager, Nuclear Fuel and Compact Manufacturing (NF&CM) Department issued a personal letter to all employees stressing the importance of following procedures, b) the Manager, NF&CM, conducted all-employee meetings in workable size groups to outline his operating philosophy and making it very clear that he expects procedures to be followed, c).roundtable neetings were held with GE and contractor employees covering the procedural violation findings and stressing the necessity for following established procedures, and d) the initiation of shop management self-audits to be continued as long as they are effective. l
.L, 1.. 12 l f NRC Evaluation The NRC staff agrees th'at both Violations C and D involve the failure to follow procedures. However, the procedural issues were grouped into common areas one area dealing with the failure of workers to follow procedures for general radiation protection activities and a second area for radiation protection personnel failing to follow procedures regarding required surveys conducted in the controlled area. The first group of violations indicated an apparent lack of knowledge regarding worker responsibility. However, the second category of procedure violations indicated an apparent lack of understanding of responsibilities and a failure of appropriate interaction among the general employees conducting maintenance activities and the radiation protection staff who are required to perform the appropriate radiological surveys. NRC agrees with the response to Violation D which stated that Nuclear Safety Instruction (NSI) 0-6.0 was followed correctly on June 14, 1989, in that managenent was notified of contamination found in the FM0 Powder Warehouse and cleanup actions initiated promptly. However, as stated in the response, the visual contamination observed on June 13, 1989, was not cleaned up as required. Also, based on our observations during the inspection we agree that the No.3 Slugger work was handled correctly except that the required barrier was not adequate to maintain control of the area throughout the job. While these general corrective actions will contribute to long-term program i improvements, we cannot detemine if they are adequate to correct the wide range l-of individual issues noted in the NRC Inspection Report. For example, the response only addressed immediate corrective actions to verify and maintain program compliance for only 3 of the 8 orginally referrenced examples. l L HRC Conclusion L For the above reasons, the NRC staff has reached the following conclusions and l requires the supplemental actions outlined below: 1 Violations C and D will be considered separate. The second example of Violation D will be withdrawn. The suggested program improvement actions detailed in your reponse to Violation A would also address the additional example of procedural inadequacies outlined in example 9 of Violation C (Enclosure 1). Based on your response which indicated that an evaluation of these improvement actions will be completed and decisions regarding thair implementation will be made by December 1989, we request that you provide your evalution findings and a listing of implementing dates as part of a supplemental response, within 30 days of receipt of this letter, transmitting this Enclosure. We will address the adequacy of your actions following receipt of this information. l l
e-9.' ^ '.f i 9 ,,s, f 13 As a result of the limited nature of the response regarding your immediate corrective actions, you are requested to submit a supplemental response for the examples of Violation C and Violation D not previously addressed in l your response. This response should include the immediate and long-term corrective actions you propose for each example of the applicable violation, and should be provided within 30 days of receipt of the letter, transmitting this Enclosure, n I l i. L i l-l l l l u m _,}}