ML20029C077
| ML20029C077 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/07/1991 |
| From: | Kuzo G, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20029C067 | List: |
| References | |
| 70-1113-91-01, 70-1113-91-1, NUDOCS 9103250236 | |
| Download: ML20029C077 (30) | |
Text
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Report No.: 70-1113/91-01 Licensee: General Electric Company Wilmington, NC 28401 Docket No.:
70-1113 License No.:
SNM-1097 Facility Name: General Electric Company Inspection Condtcted:
February 4-8, 1991 Inspector:
Mjib W
b Newb hl
___Y(uzo{
Date signed G.
Accompanied by:
E' B /Pydr i
Approved by:
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3I J24. Potter [C,n R DfteSigned Facilities Radiation Protection Section
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Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection involved review of licensee radiation protection (RP) program activities including program staffing and organization, training, radioactive contamination control, audits, internal and external exposure controls and evaluations; receipt of applicable Information Notices; and review of licensee actions regarding previously identified inspector followup items and enforcement issues.
Results:
Continued facility cleanliness and upgraded housekeeping activities were noted.
Training and medical qualifications for personnel were conducted in accordance with established RP program schedulec.
Changes to the extremity monitoring
. program met 10 CFR Part 20 requirements.
External.-and internal personnel exposure results were within the applicable license and/or 10 CFR Part 20 limits.
Routine reports, audits, notices to workers, and postings were in accordance with 10 CFR Parts 19 and 20, and License Conditions.
Concerns were identified for continued procedural non-compliance by workers as identified by violations regarding personnel monitoring and criticality controls.
In addition, a procedural inadequacy regarding Facility Change Request (FCR) guidance was identified as a non-cited violation (NCV).
Licensee responses to identified issues were considered timely and appropriate.
9103250236 910311
{DR ADOCA 07001113 PDR
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l Within the areas inspected, the following apparent violations were identifiet.
Failure to follow ' personal radiation protection prc
+es (1) for (URU) and Vaporizatlor.
- ea urinalysis submitting Uranium Recovery) Unit samples as required and (2 for wearing personal dosiretry in the Bundle Assembly area.
Multiple examples of a violation of License Condition No. 9.
Failure to have adequate procedures to ensure proper air flow from areas of lower to higher potential radioactive contamination following facility modifications.
NCV of License Condition No. 9.
Licensee corrective actions initiated prior to completion of onsite inspection activities.
Failure to follow criticality procedures for maintaining unattended fissile material only in approved storage areas.
Violation of License Condition No. 9.
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REPORT DETAILS 1
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1.
Persons Contacted Licensee Employees
- B. Bentley, Manager, Fuel Manufacturing Operations (FM0)
- G. Bowman, Senior Program Manager, Compliance Improvement
- B. Brinkley, Area Coordinator, FM0
- R. Foleck, Senior Specialist, Licensing Engineering
- D. Hassler, Supervisor, Heating Ventilation Air Conditioning (HVAC)
Maintenance
- P. Jasinski, Specialist Process Control, ChemMet Lab
- R. Keenan, Senior Engineer, Nuclear Safety Engineering (NSE)
- S. Laufer, Manager, Fuel Quality
- J. Lewis, Area Coordinator, FM0
- W. Lewis, Manager,-Nuclear Fuel and Components Manufacturing
- S. Murray, Manager, NSE
- W. - Ogden, Manager, Manufacturing Systems and Site Services
- R. Pace, Pr(3 ram Manager, FM0
- R. Patterson, Manager, Technical Resources-FM0
- B. Robinson, Senior Engineer, NSE
- H. Shaver, Nuclear Safety Engineer
- P. Sick, Manager, Quality Assurance
- H. Strickler, Manager, Industrial Safety and Environmental Protection
- J. Summey, Manager, Production Maintenance
- R. Torres, Program Manager, Radiation Protection
- C, Vaughan, Manager, Regulatory Compliance
- F.' Welfare,-Nuclear Safety Engineer
- T. Winslow, Manager, Licensing and Nuclear Material Management Other licensee employees contacted included engineers, analysts, technicians, operators, and office personnel.
- Attended exit interview conducted February 8, 1991 1
2.
External Exposure (83822) 10 CFR 20.101(a) requires that no licensee possess, use or transfer licensed material in such a manner as to cause any individual. in a restricted area to receive in any period of one calendar quarter a total occupational dose in excess of 1.25 rems to the whole body, head and trunk, active blood forming organs, lens of the eyes, or gonads; and 18.75 rem to the hands and forearms, feet and ankles.
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2 10 CFR ?0.202(a) requires each licensee to supply appropriate personnel monitoring equipment and requires the use of such equipment by each individual entering a restricted area under such circumstances that he receives or is likely to receive, a dose in any calendar quarter in excess of 25 percent-of the applicable value specified in 10 CFR 20.101(a).
10 CFR 20.202(b) defines personnel monitoring equipment as devices designed to be worn or carried by an individual for the purpose of neasuring the dose received.
10 CFR 20.401(a) requires each licensee to maintain records in accordance with the instructions contained in Form NRC-5, showing the radiation exposures of all individuals for whom personnel monitoring is required under 10 CFR 20.202(a).
Form NRC-5 requires dose to the skin to be monitored through a density absorber thickness of 7 milligrams per square centimeter (mg/cm ),
e The inspector reviewed and discussed specific changes and initial monitoring results relating to the extremity monitoring program.
The changes were in response to enforcement issues Hantified during a previous inspection conducted June 18-22, and August 1-3, 1990, and documented in Inspection Report - (IR) 70-1113/90-07, dated August 20, 1990; and a supplemental inspection conducted September 4-6, 1990, and documented in a subsequent Notice of Violation and Supplemental Report dated November 2, 1990.
~1dentified issues included concerns regarding extremity monitoring guidance, monitoring accuracy, and dose evaluation adequacy, a.
Implementing Guidance Part 1, Section 2.7.1 of the licensee's Applicatien for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with vritten procedures.
Nuclear Safety Instruction (NSI) 0-7.0, Radiation TLD Badge Issuance and Control, - Revision (Rev.) 13, dated September 28, 1990, details guidance for implementation of extremity monitoring at the facility.
The current procecare required, in part, that the Nuclear Safety Engineering _(NSE) group periodically assess extremity exposure using finger-mounted thermoluminescent dosimeters (TLDs).
The procedure specifies approximately eight Jcb functional areas (JFAs) where extremity dosimetry is to be iscued _to personnel unless evaluations determine that monitoring is not required to meet 10 CFR Part 20 requirements.
For work activities where extremity exposure is not routinely monitored but the potential exists to excced 4.68 rems per quarter which requires direct monitoring (25 percent of the 10 CFR Part 20 limit), an evaluation is required to be conducted-annually.
Discussions with licensee representatives and direct observations of work activities confirmed that maximum employee handling of unciad uranium materials occurred in the specified JFAs.
Further, to evaluate the extremity dose accurately, the procedure referenced the need to assess the potential for a differential TLD
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3 response between beta energies from the unciad uranium material and calibration source.
If necessary as a result of a differential response, correction factors are to be utilized for the final dose assessment.
The inspector noted the current guidance was appropriate to properly evaluate extremity monitoring requirements for personnel handling unciad uranium materials at the facility.
No violations or deviations were identified.
b.
Extremity Dose Evaluations The inspector reviewed and discussed with cognizant licensee representatives the current status of, and the evaluations conducted for the extremity monitoring program for personnel handling unclad uranium materials in selected facility process areas. A new vendor was selected.to provide extremity dosimetry and evaluate the results on a weekly basis during December 3-16, 1990, and on a monthly basis for January 1991.
Characteristics of the new TLD systec Eddressed the following concerns reviewed during the previous inspection conducted June 18-22, and August 1-3, 1990, and documented in IR 70-1113/90-07 dated August 20, 1990; an Enforcement Conference conducted August 27, 1990,; and documented in an Enforcement Conference Summary dated November 2,1990;- and a supplemental inspection conducted September 4-6, 1990, and documented in a Notice of Violation / Report Supplement dated November 2, 1990.
Dose to the skin now is assessed through a density absorber thickness of 7 mg/cm,r Characteristics of the TLD holder now allows the dosimeter to be -
positioned at the distal end of a worker's finger, that is, the area expected to receive maximum exposure during handling of the unciad uranium materials.
No extrapolation of dose from the separate TLD location to the area of maximum exposed skin is required.
At the time of the ensite inspection, the vendor was developing a beta correction factor to evaluate the potential for a differential TLD response to the uranium and calibration source beta energies.
Preliminary vendor data regarding the system response to varying b6ta energies indicated a 90. percent TLD response to the uranium beta energy.
Further, licensee representatives outlined current extremity monitoring program initiatives including the evaluation of areas of the hand receiving maximum dose from handling unclad uranium material, verification of TLD system measurement accuracy, and determination of pellet dose rates.
The initiativec resulted from the following observations and included tha following activities.
s.
4 NSE personnel observations of work habits by employees handling unciad uranium indicated that for certain tasks, the distal area of the thumb may receive the maximum extremity dost To assess extremity doses to areas of both the thumb and the iwex finger, the licensee conducted multiple extremity badging for six individuals selected from separate JFAs including grinder. rod loading, press, and quality control (QC) operations.
During January 1991, the individuals were fitted with _ extremity TLDs mounted on both the thumb and index finger at areas expected to receive the maximum exposure. Results of the comparisons were not available during the onsite inspection.
Extremity monitoring systems are not included in the NVLAP accreditation program.
To evaluate extremity TLD accuracy, licensee _ representatives quantitatively irradiated TLD badges t
using an uranium slab source and sent the dosimeters to the vendor for= processing.
At the time of the onsite inspection, rctults from the irradiation studies were not available.
Determination of pellet dose rates could be utilized to corroborate preliminary assessments of extremity exposures for personnel handling unshielded uranium materials.
- However, accurate dose rates from unciad pellets were not known.
A study to determine the dose rates associated with unshielded pellets of Known fabrication process age was initiated..Results were not available at the time of the onsite inspection.
The inspector noted that the current extremity monitoring system and licensee ~ initiatives were appropriate to evaluate exposure and to verify compliance with applicable license and 10 CFR Part 20 extremity monitoring _ requirements.
No violations or. deviations were identified.
c.
Dose Assessments The-inspector reviewed and discussed the December 3-16, 1990 weekly extremity monitoring results for_ personnel handling unclad uranium materials.
Monitoring' was provided for approximately 90 to 100 workers.
From review of records and discussion of the employee tasks, the inspector noted that only five-individuals were assessed more than 100 millirem-(mrem) during either of the two weeks in the monitoring period.
The majority of individuals assessed a weekly extremity exposure exceed _ing 100 mrem were associated with grinding and QCfoperations.
For the initial two week monitoring-period, a maximum accumulated exposure of -222 mrem was reported.
Based on a maximum average exposure of-111 mrem per week and assuming a 90 percent TLD response to the uranium beta energy, the inspector calculated-a maximum quarterly exposure of 1603 mrem.
Besed on these initial calculations, the quarterly extremity exposures would be less than 10 CFR Part 20.202(a) limits requiring direct monitoring.
Licensee representatives
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stated that additional evaluation of the need for continued direct monitoring of extremity exposures would be conducted following receipt of the January 1991 monitoring results.
No violations or deviations were identified.
d.-
Whole Body Exposure The inspector discussed the June 1,1990 through January 31, 1991 cumulative whole body exposures for Fuel Manufacturing Operations (FM0) hourly employees.
Licensee representatives stated that whole body monitoring was' conducted by a NVLAP approved vendor.
Discussion with licensee representatives indicated that all whole body exposures were within 10 CFR 20 limits.
No violations or deviations were identified.
l 3._
Internal Exposure (83822) 10 CFR 20.103(a)(1) states that no licensee shall possess, use, or transfer licensed -material in such a manner as to permit any individual in a restricted area to inhale a quantity cf radioactive material in any period of one calendar quarter greater than the quantity which would result from inhalation for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week for 13 weeks at uniform concentrations of radioactive material in air specified in Appendix B, Table 1, Column 1.
10 CFR 20.103(a)(3) requires for purposes of determining compliance with the requirements of this section, the licensee 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' l
radioactivity excreted from the body, or; any combination of such j
measurements as may be necessary for the: timely detection and assessment of 4
-individual intakes of radioactivity by expoked individuals.
10 CFR 20.103(b)(2) states that whenever the intake of radioactive material within any period of seven consecutive days by any individual exceeds that which would - result from inhalation-' for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentrations specified in Appendix B, Table 1, Column 1, the licensee shall make evaluations and take such actions as are necessary to assure against recurrence.
The licensee shall-maintain records of such occurrences, evaluations, and actions taken in a clear and readily identifiable form suitable for summary review and evaluation.
The inspector reviewed implementation of selected ' areas of the licensee's air sampling, urinalysis, and lung burden analysis programs.
In addition, a detailed review of the licensee's ChemMet Lab urinalysis processing activities was conducted.
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a.
Air Sampling Representativeness Part 1. Section 3.2.4.2.1 of the License Application requires that the radiation safety function annually evaluate the fixed sampling points for representativeness of personnel exposures.
The inspector discussed and reviewed with cognizant licensee representatives RP program changes for air sampling representativeness studies conducted to evaluate workers' potential internal exposures.
Previously, concerns regarding the adequacy of the methods employed and the lack of documented results were identified during an inspection conducted May 22-26 and June 12-15, 1989, and detailed in IR 70-1113/89-05.
Licensee representatives stated that in response to the NRC concerns procedure NSI E-11, Air Sampling Representativesness, Rev. O, dated August 31, 1990, was developed to provide guidance for conducting the annual air sampling representativeness study.
The procedure details implementing methods, result evaluations, corrective actions for
-identified deficiencies, and documentation requirements.
The inspector verified that the annual study was conducted and documented in a report dated December 28, 1990.
The licensee demonstrated sampling representativness by conducting air flow studies and also, by evaluating graphs of expected lung burden results derived from stationary air sampler (SAS) radioactive material air concentration data applied in-an accepted intake model plotted against actual measured-lung burdens.
The inspector noted that evaluation of the plotted data did not require a statistical analysis regarding the fit lof. the data but that as a result et the lack of published guidance regarding methods to demonstrate air sampling representativeness, the current licensee's program was considered adequate to meet the License Application requirements.
The inspector reviewed and discussed.the accuracy of the licensee's SAS system.
During facility tours, the inspector noted a flow rate of.
approximately 120 cubic feet per meter (cfm) for the majority of SASS.
4 Cognizant RP staff-informed the inspector that an attempt was made to maintain SAS. flow rates at 120 cfm, During change-out of the SAS filters at the end of each shif t the flow rates were verified, and any flow rates differing from 120 cfm were recorded in the RP technician's logs.
Subsequent computerized calculations of the total air volume sampled utilize either the 120 cfm default value, or where flow rates differ the average flow rate of before and after the filter changeout.
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During tours of URV facility areas, the inspector noted several SASS L
l with flow rates of 50-80 cfm.
The inspector verified that for these p
SASS, applicable flow rates were utilized for computations of total sample volume and resultant airborne concentrations.
The licensee's Air Sampler Concentration Reports for June 1990 through January 1991, were reviewed.
The inspector reviewed and discussed with cognizant licensee personnel the JFAs with the highest average airborne
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7 concentrations per shif t.
Those JFAs reviewed and discussed included the B&W Slab Blender, the URV furnace, and the New Decon Room.
The highest single shift insoluble airborne uranium concentration, 22.25 times the maximum permissible airborne concentration (MPCa) of 1.0 E-10 microcuries per cubic centimeter (uCi/cc), was noted for the B&W Slab Blender area on January 22, 1991.
Licensee representatives characterized the issue as an isolated event which occurred during construction activities.
The issue is discussed further in Paragraph 3.d.
From discussions with licensee representatives, the inspector noted that high airborne concentrations identified in the blender, URU furnace, and New Decon areas were being evaluated routinely and that planned activities to reduce airborne concentrations were initiated or planned, as necessary.
No violations or deviations were identified, b.
Lung Burden Analysis Practices and Procedures (P/P) 40-19, Bioassay Program, Rev. 8, dated September 20, 1989, requires the licensee to implement a bioassay program in order to comply with the conditions of NRC license SNM-1097.
Section 4.2 of the procedure requires the licensee to schedule individual lung counts based on each worker's assigned airborne exposure and previous lung burden results.
The procedure establishes the limits for worker rediiction from selected JFAs and the frequencies for reanalysis.
Lung burden results collected from June 1,1990 to January 31, 1991, for selected individuals working in the Slab Blender, URO furnace, and Slugger areas were reviewed.
The inspector verified that for selected workers assigned airborne exposure values greater than 520 E-11 microcurie-hours per cubic centimeter (uCi-hrs /cc), that is, 52 MPCa-hrs per quarter, the required lung burden analysis frequencies were increased from an annual to a quarterly basis in accordance with P/P 40-19.
The inrpector also noted a contractor assigned an airborne exposure greater than 520 E-11 uCi-brs/cc per quarter whose previous -
lung burden result of 155 micrograms (ug) uranium-235 (U-235) exceeoed
-the licensee action limit (150 ug U-235) requiring lung burden analyses to be increased from a quarterly to a monthly frequency.
Records-reviewed indicated that the licensee performed the lung count for the worker as required with the result being less than the minimum detectablelimit(MOL).
The inspector discussed and reviewed lung burden analysis records-with l
licensee representatives for an individual assigned a first quarter j
1990 airborne exposure exceeding-the 520 E-11 uCi-hrs /cc limit but who did not undergo a second quarter lung burden analysis as required by procedure.
The inspector was informed by cognizant licensee representatives that the individual was scheduled for the lung count as required, but that on March 31, 1990, the individual transf(. ed f rom FM0 to Fuel Components Operations (FCO), a non-nuclear fuel processing
8 site facility.
The licensee stated that the individual's potential exposure was evaluated from review of airborne concentrations in his work areas and previous-lung burden analyses.
The previous lung burden analysis conducted on February 6. '1990, indicated a-lung burden of approximately 40 ug U-235.
Because the individual had not approached MPCa limits while in FM0 and had since transferred to an area without uranium materials, licensee -representatives believed that the lung count was not, required.
Results of an October 17, 1990 exit lung count were less than the MOL, Following a discussion of actitivies regarding the issue, licensee representatives stated that detailed reviews of an individual's missed lung burden analysis would be documented and included in an individual's personal file.
No violations or deviations were identified, c.
Urinalysis-NSI 0-2.0, Bioassay - Urinalysis Program Rev.18, dated March 7,1990,-
requires the licensee to perform urinalysis nmasurements on individuals assigned to work in areas where soluble uranium compounds (e.g. uranium
-hexafluoride, uranyl nitrate, uranyl fluoride, and related compounds) are processed.
Appendix A of NSI 0-2.0 requires workers in the URU, the CheMmet and URU labs to submit urine samples for testing at the end of shift on the last day of the work week and also on Sunday of the work week.
Workers in the Vaporization and Hydrolysis areas are required to submit urine samples at the end of shift each work day.
The inspector reviewed REMTRAC's Urinalysis History program records for selected employees who worked in.the URU and Vaporization areas from June 1, 1990 through January 31, 1991.
The inspector observed several instances of the workers apparently not submitting _ urine samples at the end of shift.
Additional detailed review of applicable _ workers' bioassays and tire-in-area data were conducted for January, 1991.
The records reviewed included five URU1 area workers (requiring sample submittal at the end of shift on the last work day and also on Sunday anytime during the shift) and three Vaporization area workers (requiring sample submittal at the end of each work shift).
Of the five URV workers the inspector noted three individuals who submitted urine stmples at least two hours prior to the _ end of _ sh1f t work.
Two URU workers did not submit the end of the work week samples while one did not submit the required-Sunday sample.
Additionally, one Vaporization area worker was noted to be submitting urine samples at least two hours before the.end of the shift. -Review of time-in-area-data indicated that samples were submitted and the workers then returned to-- the respective process areas.
For the eight Lworkers reviewed, the inspector identified ten such occurences in which the workers failed to follow NSI 0-2.0.
The inspector informed licensee representatives that the failure to follow radiation monitoring procedures-to submit urine samples as required was an example of an apparent violation of License Condition No. 9(70-1113/91-01-01).
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9 Cogniz a_nt licensee representatives stated that the three URU individuals who missed submitting samples were contacted by RP prior to their next entry into the Airborne Controlled Area (ACA).
At that time a urine sample was submitted prior to entering into the ACA.
The inspector noted that all results were below licensee action limits.
The inspector reviewed June 1,1990 to January 31, 1991 positive urinalysis results for individuals working in the Vaporization and URV areas.
Required uptake calculations were conducted for all urinalysis results which exceeded 15 micrograms per liter lug /1) UNH or 35 ug/l UF6.
The inspector noted three incidences of one URV worker exceeding the seven day cumulative intake limit of 1.4 mgU which requires initiation of follow-up activities, including documentation of an Unusual incident Report (UIR) and submittal of a resample, as well as specific JFA wcrk restrictions.
Subsequent to each incident the worker was restricted from further work with soluble uranium until a repeat urinalysis was conducted and a UIR was written. Licensee's evaluations included appropriate review of air sample results in-the the areas and subsequent discussions with the employee.
All reanalysis and air sample results were less than licensee action levels.
Following discussions with the individual the licensee was evaluating a potential bias in the bioassay analyses from prescribed medical treatment as causing the elevated urinalysis results identified.
Licensee follow-up actions included the submittal of the individual's urinalysts samples to a vendor laboratory for further review.
The inspector had no further questions regarding this issue.
One example of a violation for failure to follow personnel radiation
_ protection procedures for submitting bioassay samples was identified.
d.
January 21, 1991, Elevated Airborne Concentration Event The inspector reviewed and - discussed licensee actions regarding the.
January 22, 1991, elevated -airborne concentrations approximately.
22.25 times MPCa for insoluble uranium in the B&W Slab Blender area.
The incident occurred as two contractors performed disassembly work on the -B&W Slab Blender.- Jarring of the blender collection hood during
'its - placement on the floor released a previously inaccessible contamination buildup and resulted in the elevated airborne concentrations identified.
The inspector verified that this uranium powder buildup was inaccessible during initial decontamination activities.
Licensee radiological controls for the task were reviewed in detail.
Radiological controls included a pre-job survey, posting of the entire room as requiring respirators for entry, and use of proper-protective clothes.
Discussion with cognizant licensee and contractor personnel indicated that-the workers wore appropriate protective clothing (RWP) and full-face respirators as required by. the Radiation Work Permit (project task number 693.91).
Subsequent to identification of the
9 10 incident by the RP personnel, contamination surveys and bioassays were conducted for the workers involved.
Neither individual's bioassay results exceeded the _ procedural action limits.
Urinalysis results were less than 7 micrograms total uranium per liter (ug U/1) and lung burden analyses were less than the minimum detectable limit of approximately 40-50 ug U-235 for both workers.
Neither individual exceeded a limit of 40 MPCa-hrs per week requiring an evaluation.
In accordance with applicable procedures an VIR was written.
The licensee's internal exposure assessment for the two contractors involved in the incident was reviewed in detail. The inspector noted that a final assessment of approximately 10 MPCa-hrs was assigned to each individual.
However, no detailed documentation of preliminary evaluations which resulted in issuance of the URI and subsequent methods used to assign the final MPCa-hr exposures were available for review.
From discussion with cognizant licensee representatives the inspector noted that the event started at approximately 0930 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.53865e-4 months <br /> i
(hrs).
Subsequently, during selected periods of the contractors' stay-times in the area (0930-1130 hrs and 1300-1500 hrs), air concentrations based on the SAS in closest proximity to the blender work area were used to assign internal exposure.
For the period prior to the event (0730-0930 hrs) when the workers were in the area without respiratory protective equipment, MPCa-brs were assessed using the average area SAS results for the shif t, excluding air concentration results from tha proximate sampler.
The inspector stated that the final assigned MPCa-hrs were appropriate but requested that the licensee review documentation requirements associated with MPCa-br calculations. The licensee made no commitment to improve documentation in this area.
Licensee representatives stated that practices which may have contributed to the incident were to be included in the " Lessons Learned Manual."
The inspector noted that licensee radiation protection actions prior to, during, and subsequent to the Slab' Blender disassembly activities were appropriate.
No violations or deviations were identified, e.
ChemMet Lab Urinalysis Processing The licensee's-processing of urinalysis samples was reviewed in-detail-during the onsite inspection.
The review incluhd training and qualifications of employees, procedural guidance c.d implementation, QC activities, and tracking of submitted samples.
Procedure C01-028, Certification of ChemMet Lab Personnel, Rev. 2, dated March 8,1990, details, in part, methods for certification for laboratory personnel to perform select tasks.
All laboratory personnel are provided initially with an general laboratory orientation.
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Supervisory review of each _ individual's qualification to perform l
specific laboratory function and qualification tests to ensure 1
11 measurements of standard specimens to within allowable limits is required prior to allowing a laboratory worker to conduct c quantitative analysis independently.
Laboratory employees are required to be recertified at intervals not greater than three years and are required to perform a specific analysis each year, at a minimum, to maintain qualifications for that task as current, Procedure, NEDE-11373, Measurement of Trace Uranium in Urine Using the Scintrex UA-3 Analyzer, Rev. 2, dated September 30, 1988, details the
- procedures for chemical determination _of uranium in urine, The procedure details sample preparation and the required analytical equipment and its operation.
In addition, measurement and reliability controls required for the analyses are outlined.
From dis Tsion with licensee representatives, the inspector was informed " at currently three individuals were involved in processing all urinai sis samples.
Review of licensee training ar' yualification records inoicated that those individuals processing urinalysis samples were trained and qualified to perform the task in accordance with the approved procedure.
Further, discussions with selected laboratory personnel indicated that the laboratory workers were aware of the procedural methods, and the specified measurement and reliability controls.
The ' inspector reviewed and discussed with the cognizant ChemMet laboratory personnel urinalysis sample processing capabilities.
Licensee representatives stated that approximately 30 samples or less were analyzed during an eight hour shift.
However, during review of July 1,1990 through February 7,1991 Bioassay Sample Log worksheets, the inspector noted several occasions where more than 35 samples were analyzed.
In particular, the inspector noted two occurrences where almost twice the routine number of samples, 60 and 49 samples, respectively, were analyzed.
Licensee representatives stated that multiple processing (boil down and chemical preparation of the sample) for more than 30 samples cnuld be conducted readily thus allowing additional samples to be analyzed.
Furthermore, from review of selected time cards, the inspector determined that analyses of the sample batches of 60 and 49 samples were completed during 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts.
For all the worksheets reviewed, sample analyses were conducted in accordance with approved procedures and laboratory quality controls.
In addition, the inspector verified that selected bioassay _ samples originally collected and documented. in RP group records were processed and analyzed at required.
All samples registered in RP logs wue processed as verified by review of ChemNet Bioassay Sample Log worksheets.
l No violations or deviations were identified, i
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Radiation-Controls (83872) a.
Contamination Surveys Chapter 3, Section 3.2.4.6 details removable surface contamination i
action levels requiring decontamination for controlled and uncontrolled areas.
The inspector reviewed genert1 area and equipment contamination surveys conducted within selected process radiologically controlled areas (RCAs). All values were less than values requiring decontamination.
No violations or-deviations were identified.
b.
Personnel Survey Instrumentation i
NSI 0-4.0, Nuclear Safety Instrumentation, Rev. 27, dated September 14 1990,_ provides the frequency for conducting calibrations and/or performance checks of personnel survey equipment at selected RCA access points.
l The _ inspector reviewed June 1,1990 through January 31, 1991 logs of daily performance checks for survey instruments maintained at the men's and/or women's change-room facilities associated with access to the-incinerator, URU, and FM0 airborne controlled area (ACA) facilities.
All performance checks were conducted in accordance with the established schedule.
No violations or deviations were identified, c.
Personnel Surveys
--10 CFR 20,201(b) requires each licensee to make or cause to be made such surveys as may be necessary for_ the-licensee to comply with the regulations ~ in 10 CFR Part 20 and are reasonable 'under.the =
circumstances to evaluate the extent of radiation hazards' that may be present.-
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Process Requirements and Operator's Documents (PROD) No. 85.08 Change Room PROD,_ Personal--Survey Leaving Controlled Area, Rev. 9, dated January 29, 1991, requires personal surveys.for possible contamination on clothing and body, -to be conducted by all personnel when leaving the Controlled Area.
The survey requires that surveys be conducted by.
-placing'the scanner probeion an area to be surveyed, holding the probe in place for 1-2 seconds, and monitoring _ the hands, wrists, chest, TLD badge, neck, face, hair, ankles, and shoes at a minimum.
During. the onsite inspection, upgraded licensee activities to improve worker compliance for conducting personal monitoring were reviewed and discussed by the inspector.
Proposed activities for this area were documented previously in a letter dated December 21, 1990, transmitting
v 13 the licensee's response to a repeat violation documented in IR 70-1113/90-07, dated August 20, 1990.
Licensee activities included using specially trained employees (security personnel) to observe monitoring practices of workers exiting radiologically controlled facility areas during peak use time, for example shif t change.
Monitoring concerns and/or non-compliances identified are documented and reported to cognizant management for followup actions.
The' inspector noted that training of the monitoring personnel was completed and the program upgrade currently was being initiated.
During the onsite inspection selected observations of monitoring program implementation at the Fh0, URU, and ChemMet lab areas was conducted by the inspector. All monitoring was conducted in accordance with the licensee's commitments.
No violations or deviations were identified.
d.
Radiation Work Permit (RWP) Implementation Chapter 3, Section 3.3.1 of the License Application requires RWPs to be issued for nonroutine operations which are not covered by operating procedures. The RWP specifies the necessary radiation safety controls, as - appropriate, including personnel nionitoring devices, _ protective clothing, respiratory protective equipment, special air sampling, and i
additional precautionary measures to be taken.
NSI _0-9.0, Radiation - Work Permit, Rev.19, dated April 17, 1990, documents the licensee RWP program and requires documentation of any problems.
The inspector discussed the-current RWP program with cognizant licensee personnel.
A full-tin.c RP technician is assigned to implement and review contractor RWP activities. - All. contractors are required to document that they have read the RWP details.
Copies of the~ active RWPs are maintained in the main RP office and, in addition, are_ posted for' easy reference in the Radiation Safety Offices for the process areas.
The " Lessons Learned Manual" continued to be maintained and is regarded _ as a. RP program enhancement.
A new requirement being implemented requires thet a facility Change Request (FCR) be' drafted and signed by-a cognizant merber of the NSE group prior to issuance of-a'particular RWP.
Cognizant licensee representatives stated that NSE' group and management support for the RWP program was a program c
strength.
During the onsite inspection, selected RWPs associated with contractor-activities were reviewed.
In particular, radiological controls associated with the B&W Slab Blender disassembly were reviewed and '
discussed in detail (Paragraph 3.d).
For the RWPs reviewed, radiation control activities were considered appropriate.
No violations or deviations were identified.
l 1
k
~
i.
L.
14 i
5.
AdministrativeControls(83822) a.
Notices to Employees 10 CFR 19.11(a) and (b) require, in part, that the licensee post current copies of Part 19 -Part 20, the license, license conditions, documents incorporated into the license, license amendments and operation procedures, or that a licensee post a notice describing these documents and where they may be examined.
10 CFR 19.11(d) requires that a licensee post Form NRC-3, Notice to Employees. $,fficient copies of the required forms are to be posted to permit licensee workers to observe them on the way to or from licensed activity locations.
During the onsite inspe: tion, the inspector verified that Fonn NRC-3 and notices referencint the appropriate 10 CFR Part 19 and Part 20 and licensee documents were posted in accordance with the applicable regulations.
The applicable forms or reference to where the documents may be viewed were posted at the Controlled Access Are, entrance.
No violations or deviations were identified.
b.
Audits and Inspections (83822) i Chapter 2, Section 2.8 of the License Application to SNM-1097 details guidance for performing nuclear safety inspections and radiation safety audits by selected site and cutside groups.
Section 2.8.1 of the License - Application, provides guidance for -
conducting quarterly (not to exceed 100 days) safety audits and weekly tispections of nuclear manufacturing and support areas to determine
- that actual operations conform to criticality and radiation safety-requirements.
-The inspector selectively reviewed safety audits conducted during the third and fourth quarter for 1990.
During-the onsite inspection,
. licensee representatives were conducting the 1991 first quarter safety audit.
The inspector verified that the audits were conducted in a timely manner and within the 100 day limit as required.
Selective inspector review of the 1990 third and fourth quarter audits indinted that no radiation monitoring or criticality issues similar.to the issues identified during this inspecticn (Paragraphs 3.c, 8.a-b, and 8.d)were-identified.
No violations or deviations were identified.
6.
Training (83822) 10 CFR 19.12 requires the licensee to instruct all individuals working in or frequenting any portions of the restricted areas in the health protection 1
1
4 d
15 aspects associated with exposure to radioactive material or radiation, in precautions or procedures to minimize exposure, and in the purpose and function of protection devices employed, applicable provisions of Commission regulations, individual's responsibilities and the availability of radiation exposure data.
Chapter 2, Section 2.6 of the License Application requires that employees complete formal nuclear safety training prior to unescorted access in the controlled area and with retraining to be conducted biennially.
During the current inspection, the inspector verified that nuclear sefety and respiratory protection training-was provided to selected operators working in facility New Decon and FM0 Bundle Assembly areas.
Records indicated that for those individuals reviewed, training or retraining was conducted at the scheduled frequency.
No violations or deviations were identified.
7.
Respiratory Protection Program (83822) 10 CFR 20.103(c)(2) permits the licensee to maintain and to -implement a respiratory protection-program that includes, at a minimum: air samplingJto identify the hazard; surveys, and _ bioassays to evaluate the actual exposures; written procedures to select, fit, and maintain respirators; written procedures regarding supervision and training of personnel and issuance of _ records; and determination by a physician prior to use of respirators, that the individual user is physically able to use respiratory
_ protective equipment.-
a.
Program Changes During the onsite inspection, procedural changes regarding the use and storage of respiratory protection equipment were reviewed and discussed with cognizant licensee representatives.
These changes resulted from similar violations and concerns involving-licensee corrective actions identified during inspections conducted May 22-26, and June 12-15, 1989, and documented -in IR 70-1113/89-05, dated July 17, 1989; an inspection conducted February 5-9, 1990,- and documented in-IR 70-1113/90-03, dated March 27, 1990; and an-inspection conducted June 18-22, and August 3-7, 1990, and documented in IR 70-1113/90-07, dated Auge.t 20, 1990; and in a Notice of Violation / Supplemental Report, dated hovember 2, 1990.
Furthermore, licensee actions and NRC concerns involving this issue were reviewed and discussed.during an Enforcement Conference conducted August 27, 1990, and documented in an l
Enforcement Conference Summary dated November 2, 1990.
L The violations involved the failure to properly store / maintain unused respirators within selected process areas.
NRC concerns included the potential for an operator to use/re-use a respirator having been contaminated through improper storage.
16 The inspector reviewed the licensee's most recently proposed corrective actions for-these issues documented in a letter dated December 21, 1990, transmitting a response to the similar violation documented in IR 70-1113/90-07, dated August 20, 1990.
Licensee representatives outlined changes implemented in PROD 85.06, Controlled Area Face Mask Rules, dated December 21, 1990, and P/P 40-22, Respiratory Protection Program, Rev. 6, dated December 20, 1990.
Changes to the program included revised guidance that respirators must be maintained in appropriate storage areas or be begged appropriately to be acceptable for re-use and that the-equipment does not have to be returned to the laundry at the end of the shift.
The inspector discussed concerns regarding the licensee's ability to conduct audits of worker compliance with the new guidance.
Licensee representatives stated that no concerns for conducting audits in this area were noted during initial reviews conducted.
Further, licensee representatives stated that manager walk-throughs of the area have notea compliance with the new procedures.
The inspector informed licensee representatives that no immediate concerns were identified with their program changes; however, the increased effort currently in place regarding this program area should be continued.
No violations or deviations were identified.
b.
Training and Qualifications P/P 40-22, Respiratory Protection Program, Rev. 6, dated June 20, 1990, requires that a respiratory protection program be established to complement the ongoing radiation exposure control program.
This program requires an initial medical evaluation as well as an annual reevaluation for airborne controlled area workers An initial respiratory protection training. and respirator fitting also is required. _ Periodic retraining and a-qualitative fit-test are to be reevaluated annually.
Training records for selected individuals _ in the New Decon area were reviewed.-
The inspector verified that the workers' respiratory protection -training and annual riedical evaluations - were conducted-in accordance with the applicable procedures.
No violations or deviations were identified, c.
Respirator Usage The licensee's -implementation of respiratory protection program activities at the facili" As reviewed.
Through observations ot
.d operations in progress, the inspector determined that persona.
a wearing respirators when required in RCAs and that there was a sufficient quantity of respirators available for use.
During tours of the facility, the inspector did not find
6 17 abandoned respirators and all unused respirators were bagged r.nd/or stored in appropriate locations for use/re-use as necessary.
No violations or deviations were identified.
8.
FacilityTours(83822)
License Condition 9 of SNM License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part 1 of the License Application dated October 23, 1987.
Part 1, 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.
Part 1, Section 4.1.3 of the licensee's Application for License No. SNM-1097 requires,- in part,- that criticality control procedures incorporating limitations established by the criticality safety function are developed and maintained and that concerned _ personnel are made aware of these procedures through posting, training programs or other appropriate written notification.
During the onsite inspection, the inspector selectively. toured the licensee's facility and storage areas, observed facility crerations, and obscrved work being performed in various JFAs to evaluate the implementation and effectiveness of the licensee's radiation prctection program.
The following specific radiation protection or nuclear criticality conditions, practices, and issues were noted and/or discussed with licensee representatives, a.
Criticality Controls-Nuclear Safety Release / Requirement (NSR/R), 2.01.01 UPMP General, General, Rev. 2, dated March 19, 1990, requires that fissile material may only be left unattended in approved storage locations.
On February 5,1991, at approximately 1930 hrs while touring the'second floor of the URU solvent extraction process area, the inspector noted a five gallon container hanging from'aLvalve located on a process drain line.
Subsequent examination indicated that the container held approximately one ' pint of liquid.
. Licensee representatives accompanying the.. inspector stated that the use of the container most likely was to contain a leak associated with operation of the valve.
At-that time, the accompanying licensee representatives identified the material only as solvent -and stated -that the operator utilizing the bucket may have stepped away from the area for a short period of time while awaiting the leakage to subside.
During and subsequent to tours of - the URV area, the licensee representatives accompanying thc inspector did not attempt te contact any operators / supervisors familiar with processes in the area.
Thus, the inspector believed that there was no immediate potential concerns with use of the container to
18 collect the liquid material.
At approximately 0730 hrs on February 6, 1991, the inspector discussed the issue with additional NSE and URV personnel.
The inspector was informed that the container remained as found the previous evening and that the solvent did contain fissile material.
The inspector informed licensee representatives that the failure to follow criticality procedures for storage of fissile material only in an approved storage location was an apparent violation of License Condition No. 9 (70-1113/91-01-02).
Licensee short-and long-term corrective actions subsequent to the incident included the following.
The container, approved for use in the process areas, was removed from the area -and stored properly imediately following discussion between the inspector and cognizant licensee representatives at approximately 0730 hrs on February 6, 1991 Prior to the end of the onsite inspection, a facility change to pipe the potential process operation leakage directly from the valve _to an approved storage container was approved and initiated.
The issue was scheduled to be reviewed by appropriate personnel through the use of roundtable discussions.
An evaluation of leaks which resulted in-use of containers within selected process areas was to be developed.
The evaluation was to include both the location ar/ frequency of the leaks.
Alternative solutions were to be evaluated and specific actions defined and then implemented in accordance with an established schedule.
The inspector noted that licensee actions regarding this issue appeated thorough and timely.
One violation of License Condition No. 9 for the failure to follow criticality procedures was identified, b.
Facility 'clodifications (83822)
Part 1, License Application section 3.2.2.1 states that ventilation equipment is designed to provide air flow from areas of lesser potential._ contamination to areas of higher potential-contamination.
During tours of the facility areas on February 4, 1991, at approximately 1700 hrs, the inspector noted air flow from a FM0 radiologically controlled area to a non-radiologically controlled area.
The slight air flow was detected moving through minor penetrations in
.the temporary barrier wall of double plastic sheets erected betwe e the FM0 rod loading and the B&W Pack and Shipping areas.
Licensee representatives stated that in January 1991 the B&W Pack and-Shipping area was isolated from the radiologically controlled areas and-deccntaminated.
At the time of the onsite inspection, the area was being controlled temporarily as a clean area for the current ongoing development and setup of process equipment.
Licensee representatives stated that proper air flow was verified during the initial facility modificatiot and during routine monthly surveillances.
The Facility Change Request (FCR) associated with construction activities for the B&W Pack and Shipping area was
T 19 reviewed.
The inspector verified that FCR-90-284 Demolition and Site Preparation Work of the Pack & Shipping Area Equipment Areas, dated November 10, 1990, was prepared and reviewed in accordance with applicable procedures.-
Review of air flow verification studies conducted on January 9,1991, indicated appropriate air flow patterns for the area.
Cognizant licensee representatives stated that the initial air balance / flow deterninations were conducted with the rollup door closed and with specific ventilation system conditions. From initial reviews of the air flow concern, licensee representatives determined that the partial opening of a large rollup door combined with a reduction in ventilation supply in the B&W Pack and Shipping area resulted in the improper balance between the controlled and non-controlled areas.
Proper air-flow was restored upon closure of the rollup door without any changes in the ventilation supply system.
From discussion with licensee representatives, the inspector determined that the rollup door was opened for a period of _ approximately two to three hours.
Contamination surveys were conducted and no significant contamination was identified in the uncontrolled area.
- Additional followup of the issue by cognizant NSE personnel, identified sele::ted procedural weaknesses regarding the notification of HVAC personnel of facility changes which potentially may affect area ventilation.
Prior to the end of the onsite inspection, procedural modifications requiring notification of HVAC system personnel of facility changes potentially ffecting air flow and balance were incorporated into NSI-E-7.0, F diological Safety Review for Process and Equipment Change Results, Res. 13, dated Fehi nary 7, 1991, and NSI 0-9.0, Radiation Work Permit, Rev. 20, dated February 7,1991.
In addition, the inspector requested licensee representatius to review the adequacy of HVAC procedural guidance regarding air flow requirements.
This information was not available at the end of the onsite inspection.
The inspector informed licensee representatives that the pending a review of the adequacy of HVAC procedures to meet License Application Section 3.3.2.1, the identified air flow procedural concerns would be corsidered an unresolved item (URI).
During a February 19, 1991 teleconference, licensee representatives
_ informed the inspector that procedure 310-19, Controlled Area _ Air Balance and Certification, Rev.1, dated January 26, 1991, requires building air flow to be in a direction from areas of lesser concentrations to areas of greater concentrations. During a subsequent teleconference on February 20, 1991, the inspector inforned licensee representatives that based on the corrective actions initiated and on adequacy of the supplemental HVAC procedures reviewed, the URI regarding procedural adequacy to ensure air flow in accordance with License Application requirements met the requirements of 10 CFR 2, C.V.G and would be considered a non-cited violation (NCV)
(70-1113/91-01-03).
f 4
20 One NCV regarding procedural adequacy to ensure air flow in accordance with License Application requirements sas identified.
c.
Use of Protective Clothing (PCs)
During tours of the facility on February 4-8, 1991, the inspector observed licensee persennel wearing PCs in the RCA.
All persons observed. were wearing their PCs in the n;anner prescribed by the applicable PROD.
No problems were noted in this area.
No violations or deviations were identified.
d.
Personal TLD Use PROD No. 87.01, Rev. C, dated September 14, 1990, requires personnel to wear TLD badges et all times while working in the bundle assembly area.
PROD 87.01 is posted at the entrance to the controlled area so as to be seen by anyone entering the controlled area.
During tours of the FM0 and bundle assembly areas, the inspector observed worker practices pertaining to personnel dosimetry usage.
On February 5,1991, the inspector observed a QC employee working in the Bundle Assembly area and not wearing a TLD.
Upon questioning by the inspector, the employee stated that the TLD was required for work in the area.
The employee indicated that the TLD was removed shortly before the inspector's observation, but was unaware where the dosimeter was placed.
The inspector informed licensee representatives that the failure to wear the TLD in the Bundle Assembly area was considered an additional example of an apparent violation of License Condition No. 9
-(70-1113/91-01-01). Review of training records indicated that the employee had received the appropriate training regarding external exposure controls.
Subsequent licensee corrective actions included review and discussion of the incident with appropriate personnel. The inspector informed licensee representatives that. this was a repeat example _ of a violation identified during an inspection conducted June 18-22-and-August 1-3, 1990, and documented in IR 70-1113/90-07 and Notice of Violation / Report Supplement dated August 20, 1990, and November: 2,.1990, respectively.
One example of-a violation of License Condition No. 9 for failure to follow radiation monitoring procedures was identified, e.
Personnel Contamination Surveys During tours of the facility on February 4-7, 1991, the inspector-observed various individuals perform personal surveys at RCA exit locations.
The inspector verified that personnel were surveying properly prior to leaving the controlled area.
No violations or deviations were identified.
r.
21.
f.
Posting and Labeli?g it Details of the licensee posting surveillance program upgrades were
-reviewed and. discussed with cognizant licensee representatives.
The upgrades were initiated as corrective actions for similar violatior,s identified during previous inspections conducted November 29 -
December 2,1986, documenten in IR 70-1113/988-18; May 22 - June 23,
'989, documented in IR 70-1113/89-05; and June 18-22, and August 3-7,
.990, documented in IR 70-1113/90-07.
Licensee corrective actions as detailed in General Electric's Nuclear Fuel and Component Manufacturing (GE's - NF&CM) response dated December 21, 1990, were reviewed and discussed in detail.
The concerns involved the adequacy of maintaining appropriate postings
-i associated with selected facility storage areas.
Licensee actions l
regarding this issue involved the development and implementation of
-^
routine program guidance to evaluate facility postings.
At the time of the onsite ' inspection the following corrective actions were completed or in progress.
Radiation Control personnel had devehped and appropriately coded site maps with facility location / area postings and their required informational content.
J Detailed audits of postings by radiation control personnel were completed and appropriate changes made to the site maps.
Audit guidance-for reviewing postings was developed. The guidance included correct location, quality of information, general condition, and need for changes.
The coded site maps and audit guidance were to be utilized by radiation - control, NSE, and management personnel conducting audits or walk-throughs of selected facility areas.
During February 4-8, 1991 facility tours, no concerns regara ng area postings were noted.
The inspector had no further questions regarding this issue.
No violations or deviations were' identified, g.
SNM Sealed Source. Radiological Controis License Cri.uition-9 requires the licensee to use licensed material in
.accordaNe with statements, representations, and conditions contained in the License Application dated October 23, 1987.
Part 1 Section 3.2.4.10 of the License Application requires the licensee to perform a-leak test on all plutonium sealed sources every three months.
l
22 Licensee representativts detailed SNM source procedure changes iniplemented since the previous NRC inspection documented in IR 70-1113/90-07.
Licensee representatives stated that NSI 0-3.0, Sealed Source Control, Rev.14, dated October 1,1990, was changed to include the three month leak test License Application tequirement only for the plutonium sealed sources. In addition the procedure required inventory to be conducted on either a quarterly or semiannual basis for cther sealed sources.
The procedure requires all incoming sources must 4
bc entered into a source control program prior to reltase to the owner for tracking and at.ccuntability.
As an additional backup control when a source initially is received from shipping, the source is surveyed and a control number is assigned by RP personnel for manual tracking 4
i purposes.
The inspector reviewed records of sealed source physical inventories and leak tests conducted from June 1,1990 to January 31, 1991. The inspector verified that all licensee SNM sealed-source controls were conducted in accordance with the revised procedure.
l No violations or deviations were identified, h.
General Observations During February 4 0, 1991 facility tours conducted in se',ected FM0 production and storage areas, the inspector reviewed general housekeeping and contaminaticn controls.
The following.ssues were reviewed by the inspector and discussed with cognizant licensee representetives.
On February 5,191, the inspector noted an employee in the RCA machine shop taping components of a process area pump in preparation for painting.
The employee condt.cting the taping was not wearing gloves and was unaware of the contamination levels on the pump.
The employee indicated that detailed manipulation cf the tape required that his glove; be removed.
Surveys of the pump indicated contamination levels less that 500 disintegrations per minute per 100 centimeters square-(dpm/100 cmt) and-that in the past radiation control personnel permitted removal of the gloves to complete similar taping tasks. Licensee representatives stated that the pump was surveyed prior to its refurbishment and final preparation for painting.
However, licensee representatives stated that policies regarding handling of potentially contaminated equipment would be reviewed.
On three occasions, the inspector noted operators holding open doors between the Gadolinis radiologically controlled process area and the cdjacent non-centrolled south hallway area.
Controlled area operators propped the doors partially opened for ~ 10 to 4
15 minute periods while conducting conversations with individuals in the hallway.
Licensee representatives stated that doors were util1 zed for transferring material into and out of the-process area -in accordance with the appropriate radiation monitoring controls.
The inspector noted that during his observations no
23 materials were moved into or out of the identified process area but that the opening of the doors for discussion increased the Wtential for spreading contamination to uncontrolico creas.
Licensee representatives stated that the controlled area was inaintained at a negative pressure with respect to thc non-controlled hallway and that routine containination surveys were negative.
Licensee representativts stated that directivt s would be issued to climinate the otserved practice.
During a tour of the powder and pellet > reduction arcas on february 6,1991, the inspector observed a slab blunder baghouse filter change-out.
The change-out wcs conducted in accordance with the applicable procedures and all contarnination control guidance was followed.
No concerns were identified regarding on.pty can storage.
General housekeeping and contamination control continued to be maintained and was considered a continued prograin strength.
No violations or deviations were identified.
9.
Nuclecr Safety Engineering end Radiation Control Organization and Staffing (83822) a.
Orgarization O
Chapter 2, Sections 2.2.1.3 and 2.2.1.4 of the License Application define the f unctions and 9tneral organizetion for the Nucleer (Radiation) Safety and Radiation Protection sections, respectively.
The inspector reW ewed and discussed the licensee's current organizationel structure.
Licensee representatives stated that no organizational changes were implemented since the last NRC inspection of RP program activities conducted in June and August 1990 and docurrented in IR 70-1113/90-07, dated August 20, 1990.
No violations or deviatieris were identified.
b.
Staffing
~
Changes to NSE and RP staff since the previous NRC radiation protection inspection (1R 70-1113/90-07) were reviewed and discussed with cognizant licensee representatives.
The radiation protection NSE and RP technician staff levels were not changed since the previous hkC inspection of RP program activities.
No violations or deviations were identified.
4 24 10.
FollowupItems(92701) j The following inspector followup items (Ifis) and hRC Infonnation Notices (ins) were reviewed and were discussed with cognizant licensee representatives.
1 a.
Inspector Followup Items (Closed)IFl 70-1113/89 05-02:
Review licensee actions regarding lack r
of " root cause" analysis associated with quarterly audit reviews.
This issue involved the inspector's observation of a high frequency of similar " potential non-coropliance" (PNC) issues among both licensee quarterly safety audits and also, violations identified during NRC inspections.
The inspector noted that implemented corrective actions addressing each non-compliance did not reduce significantly, the licensee's performance regarding the identified items.
In addition, the licensee's audit procedure lacked guioance regarding " root cause" J
analyses regarding PNCs identified.
The inspector reviewed and verified initiation of actions stated regarding this-issue as identified in GE's NF&CM response dated December 21, 1990.
Licensee representatives stated that FNCs and findings from quarterly audits now are trended and grouped to facilitate the prioritization and evaluation of the issues, fognizant licensee representatives stated that the PCNs then are reviewed by "Special Focus Ernployee involvement Teams" composed of hooriy and professional staff.
The team is used to evaluate and to propose potential solutions regarding similar PNCs or NRC-ident!fied violations.
For each issue a root cause list is generated and potential solutions developed.
The solutions are reviewed for timeliness in implementation, cost / benefits, regulatory significance, i
and potential for developing new concerns.- Licensee representatives stated that full implementation and appropriate guidance for licensee actions _regarding root cause analysis would be available by the end of the first quarter in 1991.
The inspector informed licensee representatives that based on their initial actions, this item would be considered closed, b.
Information Notices The inspector verified that the following ins were received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.
IN 90-44 Dose Rate Instruments Underresponaing to the True Radiation Fields IN 90-48 Enforcement Policy for Hot-Particle Exposures
- z
t 25 IN 90-56 Inadvertant Shipment of a Radioactive Source in a Container Thought to be Empty 1N 90-66 Incomplete Draining and Drying of Shipping Casks IN 90-75 Denial of Access to Current Low-level Radioactive Waste Disposal facilities IN 90-71 Fitness for Duty 13.
LicenseeActiononpreviousEnforcementAction(92702) a.
SAS Representativeness (Closed)VIO 70 1113/89-05-05:
Failure to demonstrate representativeness of SAS locations relative to air breathed by workers.
- The issues regarding the demonstratation of SAS representativeness were identified during an inspection conducted May 22-26, and June 12-15
-1989, and documented in IR 70-1113/09-05, dated July 17, 1989.
The
' inspector reviewed implementation of corrective actions stated in GE's NF&CM responses dated October 10, 1989,-and June 1, 1990.
Results of this review are documented in Paragraph 3.a of this report.
The inspector informed licensee representatives that this item would be considered closed, b.
Procedural Compliance Enforcement issues The fo11cwing enforcement issues regarding procedural compliance concerns were identified during inspections conducted May 22-26, and June 12-15, 1989, and documented in IR 70-1113/89-05, dated July 17, 1989; an inspection conducted February 5-9, 1990, and documented in IR 70-1113/ % 03, dated March 27, 1990; and an inspection conducted June 18-22, and August 3-7, 1990, and documented-in IR 70-1113/90-07 dated August 20, 1990, and in a Notice of Violation / Supplemental Report dated November 2, 1990, furthermore, licensee actions and NRC concerns involving these issues were reviewed and discussed during an Enforcement Conference conducted August 27, 1990, and documented in an Enforcement Conference Summary dated November 2,1990.
The ' inspector reviewed and verified implementation of corrective actions stated in GE's NF&CM response dated December 21, 1990.
(Closed).VIO 70-1113/89-05-06:
failure to follow procedures and/or inadequate procedures for radiation protection activities:
MuP :ple examples of a violation of License Condition No. 9.
~_
k 26 (Closed)Unresolveditem(URI) 70-1113/90-03-02: Review adequacy of licensee proposed corrective actions to prevent rotorrence of improper respirator storage.
(Closed)-VIO 70-1113/90-07-06:
Failure to follow procedures for (1) Respirator use, (2) TLD use, (3) postings (4) combustible material-storage, (5) bagging contaminated filters, (6) can storage, (7) ShM leak testing:
Multiple examples of a violation of License Condition No. 9.
The inspector informed licensee representativcs that these items would be considered closed bec)d on review of selected program areas as detailed in paragraphs 4, 7, and 8 of this report.
c.
Contamination Control (Closed) V10 70-1113/89-05-08:
Failure to adhere to contamination control procedures for (1) the powder warehouse area and (2) process (slugger) parts.-
This item was reviewed during a previous inspection conducted June 18-22, 1990 and documented in IR 70-1113/90-07.
Based on the previous review conducted this item is considered closed.
d.
Extremity Exposure Related Enforcement Activities The following enforcement issues regarding extremity monitoring activities were identified during an inspection conducted June 18-22 and August 3-7, 1990, and documented in IR 70-1113/90-07 and Notice of Violation / Supplemental Report, dated August 20, 1990, and November 2,
- 1990, rt spectively, 4
The inspector reviewed and verified implementation of corrective e
actions stated GE's NF&CM response dated December 21, 1990.
Results of the inspector's review are documented in Paragraphs 2.a-c of this report.
Based on the current licensee extremity monitoring program and previous corrective actions outlined during an Enforcement Conference conducted August 27, 1990, and documented in an Enforcenent Conference Meeting Sunnary, dated November 2,1990, the inspector informed licensee representatives that the following items would be considered closed.
(Closed)VIO 70-1113/90-07-01:
Failure to have written procedures for-conducting an extremity. monitoring progran for personnel routinely handling unciad uranium materials:
Violation of License Condition No.-9.
g n -. - -- -
l' nF )
I 27 e
(Closed) VIO 70-1113/90-07-02:
Failure to monitor and record exposure to extremities in accordance with instructions provided in NRC Form-5.
(Closed) VIO
/0-1113/90-07-03: Failure to supply and to require the use of appropriate extremity monitoring equipment by individuals potentially exceeding 25 percent of 10 CFR 20.101 limits.
Violation of 20.202 requirements.
c.
Personnel Monitoring Compliance (Closed) VIO 70-1113/90-07-05: Failure to conduct adequate surveys / evaluations of the hazards present to detect contamination on the skin of the foot 'by a URV worker exiting the RCA:
Violation of 10 CFR 20.201(b) requirements.
The -inspector reviewed and verified implementation of corrective actions stated in GE's NF&CM response dated December 21, 1990.
Based on review of licensee corrective actions as detailed in Paragraph 4.c and general observations, the inspector informed licensee representatives that this issue would be considered closed.
12.
ExitInterview(83822)
The inspection scope and results were sumarized on February 8,1991, with those individuals indicated in Paragraph 1.
The general program areas reviewed and the potential noncoroliances identified during this inspection and listed below w9re reviewed in detail.
At that time examples of violations of Licerise Condition No. 9 for the failure to follow radiation monitoring and criticality procedure requirements were discussed in detail.
In addition, one issue regardin9 the adequacy of licensee procedures to ensure proper air flow was identified as an unresolved item pending licensee review of-HVAC procedures.
The ' licensee was informed it t pending NRC management review, previous violations and followup items discussed in Paragraphs 10 and 11 were closed during this inspection.
Licensee representatives acknowledged the inspector's comments..
The licensee did identify proprietary material reviewed by the inspector during this inspection, however, the inspector noted that no proprietary information wobid be used in the report.
During a February 20, 1991 teleconference, the inspector informed licensee representatives that the failure to have adequate procedures - to ensure proper. air flow from areas of -lower to higher potential radioactive contamination following facility modifications was considered a non-cited violation.
Licensee representatives had no additional questions regarding this issue.
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s 28 Item Number Desyjptjen_and Reference t
n VIO - Failure to follow p)ersonal radiation 70-1113/91-01-01 protection procedures (1 for submitting URV and Vaporization area urinalysis sanples as required. (Paragraph 3.c). and (2) for wesring personal dosimetry in the Bundle Assembly area (Paragraph 8.d)
Multiple examples of a violation of License Condition No. 9.
70-1113/91-01-02 VIO - Failure to follow criticality prt edures for maintaining unattended fissile material in an approved storage area (Paragraph 8.a).
' Violation of License Condition No. 9.
70-1113/91-01-03 NCY - Feilure to have adequate procedures to ensure proper air flow from areas of lower to higher potential radioactive contamination following facility modifications (Paragraph 8.b).
NCV of License Condition No. 9.
Licensee corrective actions initiated prior to completion of onsite inspection I
activities.
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