ML20030B652
| ML20030B652 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/16/1981 |
| From: | Franklin L, Hosey C, Howell J, Kahle J, Millsap M, Jonathon Puckett NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20030B644 | List: |
| References | |
| 70-1113-80-7, 70-1113-81-07, 70-1113-81-7, NUDOCS 8108180399 | |
| Download: ML20030B652 (11) | |
Text
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'o UNITED STATES
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NUCLEAR REGULATORY COMMISSION n
nE REGION ll o,
'f 101 MARIETTA ST., N.t', SUITE 3100 P
ATLANTA, G EC '
.A 30303 o
Report No. 70-1113/81-07 Licensee:
General Electric Company Wilmington, NC 28401 facility Name: Wilmington Manufacturing Department Docket No. 70-1113 License No. SNM-1097 Inspection at Wilmington, North Carolina Inspectors:
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J. D Kahle Date Y
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. C. Howe F Da'te
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Date Approved by:
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M~. Hosdf,4cting Ch19f, TI Branch Da'te Division of Engineering and Technical Irispection
SUMMARY
Inspection on September 22-26, 1980 and June 8-12, 1981 Areas Inspected This routine, unannounced inspection involved 132.nspector-hours onsite in the areas of radiation protection covering radiation protection procedures, internal exposure control, external exposure control, contamination control, posting and labeling, notifications and reports, followup on outstanding open items and packaging and transporation of radioactive waste.
8108190399 810723
{DRADOCK 07001113 PDR.
i Results Of the eight areas inspected, one item of noncomplianco was found in c1e area (Failure to follow personal survey procedure whea exiting the control area).
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DETAILS 1.
Persons Contacted Licensee Employees
- E. Lees, Quality Assurance Manager
- J. Bergman, Fuel Manufacturing M' nager
- B. Bentley, Fuel Chemical Operation Manager
- R. Patterson, Fuel Fabrication Operation Manager
- W. Hendry, Regulatory Compliance Manager
- J. Mohrbacher, Nuclear Safety Engineering Manager
- R. Torres, Radiation Protection Supervisor R. Lewis, Radiation Protection Shift Supervisor
- D. Barbour, Radiation Protection Shift Supervisor
- G Powers, Senior Nuclear Safety Engineer
- G. Bowman, Senior Nuclear Safety Engineer C. Vaughan, Licensing and Compliance Manager
- R. Foleck, Senior Licensing Engineering Specie'ist
- S. Murray, Nuclear Safety Engineer
- W. Smalley, Seninr Environmental Protection En.neer u
- D. Brown, Powder Production Operation Manager J. Brown, Contracts Specialist C. Shipp, Industrial Safety Manager R. Pace, Fuel Support Operation Manager P. Zorich, Burns Security Agency Sergeant Other licensee employees contacted included four operators, three technicians and two clerks.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September 26, 1980 and June 12, 1981.
In the June 12, 1981 exit interview, management was informed that the September 22-26 inspection report had been lost and that the finding regarding a violation would be covered in report 70-1113/81-07. Management representatives objected to this procedure because the situation had been corrected and the present inspectors had no documentation that the licensee had ever been in violation of any regulatory requirements and if enforcemen'.
action was in order at this time, there should be two separate reports. Managemen+. representatives w ra informed that the viola-tion had been observed ty the inspectors in September 1930 and e/en though corrective action had been taken by the licensee the enforce-ment documentation would be contained in the forthcoming report.
2 3.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance 78-14-01 and 78-19-01:
Failure to survey to evaluate potential airborne hazard associated with welding contaminated equipment.
Job Hazard Analysis (JHA) No.
22 was examined by the inspector.
It relates to the radio-logical safety control associated with maintenance activities in the uranium manufacturing areas.
Documentation was reviewed which showed that the new JHA had been reviewed with maintenance personnel and that they had signed a document that they had read and understood the radiological safety control requirements.
An examination of procedures, P/P 40-9, " Service Work in Controlled Area" and NSI 0-9, " Radiation Work Permit" showed that procedures have been developed to provide proper instructions for the personnel to work with radioactive mater 1al and potentially contaminated equipment and materials, b.
(Closed) Open Item 78-19-02: Modification of Respiratory Protection Procedures to include standby rescue personnel for bubble suit users.
The licensee has issued a revised procedure (Prod. No. 80-20) which now includes this requirement.
c.
(Closes,. pen Item 78-19-03: Respirator de" ice approvals for UF Area. Bioassay records and air sample results were reviewed 6
during this inspection.
The information reviewed was consistent with the previous results.
It is apparent that the respiratory device is satisfactory for use in UF6 areas.
d.
(Closed) Open Item 78-19-04: Modification of computer program and associated timely notification of terminated employees.
Discussion with a licensee representative revealed that when individuals terminate cmployment, or their work assignment with the licensee, their names are removed from the active personnel data base in the computer files. Then a computer input of the TLD exposure results received from Landauer wi?1 flag individuals who have been removed from the active files and a notification of terminated individuals exposure report is prepared.
e.
(Closed) Open Item 79-06-01:
Revise procedures for action level in liquid effluents. The nuclear safety method sheet i
for PROD Document No. 80-69, "WMD Process Effluent Control",
was revised to control the process lagoon daily releases so as not to exceed 2 parts per million (PPM) uranium which is equivalent to 10 percent of the 10 CFR 20 Appendix B maximum
. concentration (MPC).
Plant procedure P/P 40-18, " Regulatory Compliance Administrative Action Guidelines"6 establishes the action level for liquid effluents at 3 x 10- uC1/ml, which is 10 percent of the MPC. The nuclear safety method sheet also requires the Shop Support personnel to contact the Environmental Engineer in the event the 2 PPM uranium value cannot be met.
3 f.
(Closed) Unresolved Item 79-06-02: Gross Beta Analysis of Nitrate-Bearing Liquid Shipments.
The licensee takes a grab rample from each truck load of nitrate-bearing liquid waste.
A daily composite is made of the grab samples at the end of each day, then a weekly composite is made of the daily com-posites.
The weekly composite samples are sent to Vallecitos for gross alpha and gross bett analyses. The areas for storage of empty and filled radioactive material containers are well controlled and posted.
g.
(Closed) Open Item 79-06-03:
Labeling of empty boxes in outside storage areas. Since the time that this item was identified the FM0/FM0X area Sas been enclosed within a security fence, consequently the labeling need has been negated as the secured area is properly posted. Also, the licensee now places a packet of " EMPTY" labels in with the packing list when containers are sent out with instructions for the receiver to place empty labels on the containers when returning in accordance with DOT regulations. Observation of containers showed proper marking and labels.
h.
(Closed) Noncompliance 79-17-01:
Release of material from the controlled area with contamination above the license limits.
The licensee has initiated a procedure (PROD 80-72) that requires that all sanitary (noncontaminated) trash generated within the emergency control center (ECC), except for the I
troth from the lunchroom and the computer room, will be visually inspected for suspect items and monitored with a sensitive radiation detector and released by the Radiation Protect'on Unit and the Shop Support Unit prior to removal from the site.
An examination of procedures and discu sfons l
with licensee representatives revealed that responsibilities and instructions have been assigned to the various units to assure that contaminated materials have not been placed in with the sanitary trash, that the sanitary trash is properly i
f monitored for radioactive contamination and that no radioactive or radiation warning or caution signs, stickers or labels are contained in the sanitary trash. Materials are removed from the trash if any positive readir.3 above background is detected.
An examination of the records showed that occasionally materials were removed because of a reading above background, the item was suspect or bore a radioactive material label.
i.
(Closed) Open Item 79-17-02:
Procedures for control of conta-minated materials in temporary work sites.
Discussions with licensee representatives revealed that all work at the plant is reviewed by the nuclear safety group. The procedures that assure that the work is reviewed by the nuclear safety group are P/P 40-9, " Service Work in Controlled Areas", P/P 40-5,
" Nuclear Safety Review System" and NSI 0-9, " Radiation Work
4 1
Permits".
An examination of these procedures showed that responsibilities are established for assessing the need for a nuclear safety review, that area management approved the work and that the nuclear safety. review requirements are incorporated into the applicable procedures.
l j.
(Closed) Noncompliance 80-10-01: Failure.to keep fuel rod 4
cabinet doors closed.
The inspector reviewed documentation that showed that management instructions had been issued which clarified the specific requirement and emphasized the 1:aportance of following the requirement and enforcement by supervision.
A nuclear safety review has been performed and a management decision made to replace the aluminua. trays with stainless steal. When the stainless steel trays are in place, it will l
no longer be necessary to keep the fuel rod cabinet doors closed to maintain nuclear criticality safety if water or foam l
are sprayed into the cabinet in the event of a fire.
4.
Unresolved Items dnresolved items were not identified during this inspection.
5.
Bulletins, Circulars and Notices a.
IE Circular Number 79-09. Occurrences of split or punctured regulator diaphragms in certain self contained breathing
)
apparatus. This circular was sent out by the Commission on June 22, 1979.
NIOSH had released a " Respirator Users Warning" on May 2, 1979.
This was responded to by the licensee on May 18, 1979.
The supplier was contacted by the licensee and all self-contained breathing (SCBA) units were promptly inspected.
By procedure this has further become a monthly inspection item.
This item is closed.
i b.
IE Circular Number 79-15. Bursting of high pressure hose and malfunction of relief valve and "0" ring in certain self-i contained breathing apparatus. The licensee does not use the type of SCBA covered by the circular. This item is closed,
[
c.
IE Information Notice Number 80-19.
NIOSH recall of recircula-ting mode (Closed Circuit) self-contained breathing apparatus (rebreather).
T S licensee does not use these SCBAs.
This item is closed.
l d.
IE Circular No. 79-21, Prevention of Unplanned Releases of Radioactivity.
This particular circular was not dispatched to fuel facility licensees. The circular convents and concerns regarding hydrostatically testing of underground piping which carry liquid radioactive material was discussed with licensee representatives.
It was determined that ti.e licensee has no process liquid waste lines that are underground.
The process liquid waste lines from the FM0/FM0X complex to tne waste 4
5 treatment facility are above ground.
The licensee does have some drain lines which are underground. The drain lines are gravity flow and carrying treated racioactive liquid wastes which have been batch released with a concentr ction below the regulatory limits.
The licensee rep msentative stated that the drain lines are vitrified clay pipe which is not amenable to hydrostatic testing and would be practically impossible with the cemented connections at the various manholes.
Licensee representatives acknowledged our concern and the importance of testing underground lines which carrying liquid radioactive material and provide the potential for releasing radioactivity to unrestricted areas in the event of leaks.
This item is closed.
e.
IE Circular No. 81-07, Control of Radioactively Contaminated Material.
Even though the circular is applicable only to nuclear powcr reactor fxilities, a licenses represcr,tative stated that the philosophy ar.d principles were essentially applicable to uranium fuel fabrication facilities.
The l vensee has determined that it is not necessary to change or revist any _/ their procedures regarding the control and release of materials for unrestricted use or removal of sanitary (noncon-taminated) trash from the plant.
This is discussed in paragraph 3b. above.
Licensee representatives stated that the alpha contamination measurement capability of detecting 100 dpm/100 cm2 fixed and 20 dpm/ 100 cm4 removable was not practical except under very special ideal conditions.
The systematic errorc associated with routine smeur surveying and measurements would exceed these levels.
The licensee representatives emphasized that their controls and release levels were as low asreasonablyachievablepdwithinthelicensecond{ tion limits of 5000 dpm/100 cm fixed and 1000 dpm/100 ce removable.
This item is closed.
?
6.
Allegations a.
An April 28, 1981, Region II NRC received a telephc < call from an alleger expressing concern of improper radioactive waste disposal on the licensee's property. The alleger stated that twelve 55-gallon drums were removed from the fuel manufactur-ing building and disposed of in a marshy area located on the licensee's property.
The individual alleger was contacted to pin-point the area where the drums were allegedly disposed.
The alleger expressed a desire to remain anonymous.
b.
Surveys with very sensitive micro-R/hr radiation detection instruments were made of the FM0/FM0X storage areas and along all the roads in the back part of the plant. The area, where the drums were allegedly disposed of was extensively monitored for radiation and visually observed for the presence of 55-gallon drums.
Radiation levels above background were not detected nor were any 55-gallon drums observed.
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1, 6
i 7.
External Radiation Control i
An examination of tM external radiation dosimetry records for 1980 and first quarter 1981 revealed that radiation exposures to individuals were well within limits.
Documentation was available to show that reviews were made of any unusual or suspect results and that investi-gations had been performed by the nuclear safety engineering staff to resolve concerns and take corrective action, if necessary, Verification was made that the licensee maintained records in i
i accordance with 10 CFR 20.401 and issued the annual report pursuant to 10 CFR 20.407.
I 8.
Intern;l Radiation Control a.
Air Sampling Program The inspector examined the sampling program extensively.
Samples are taken daily at most work locations and the program l
appears to be adequate.
Historical and current tracking of j
air sample results is being done and this has aided in upgrad-ing engineering controls.
One area of concern was noted in the area of assigning MPC-hours. The licensee may have several air sampling locations in a given work area. The licensee procedure calls for averaging of these air samples prior to assigning MPC-h urs.
The inspector informed the licensee that this was a questionable practice and recommended cht.nging this procedure to assignment of MPC-hours based on a specific air sample location. This item will be evaluated during a subse-ouent inspection (81-07-01).
3 i
j h.
Bioassay Program l
The inspector examined bioassa," procedures and records.
No discrepancies were noted in this brea and this program appears adequate.
c.
Respiratory Protection Program The inspector examined the overall respiratory protection i
program. The inspectors noted that the licensee was not following the recommendations noted in NUREG 0041, in that:
i (1) No formal mor.thly inspection is performed on full face j
req,irators.
Licensee representatives felt that re-spirator turn over time was such that the need for this formal inspection was not necessary. The inspector I
stated that there was no assurance that each full face respiratcr received a monthly inspection.and that a formal procedure should be implemented.
This item will l
be evaluated during a subsequent inspection (81-07-02).
E
7 (2) fio formal inventory procedure is used for respira. ors.
The inspector informed licensee representatives that this should be done on a routine basis to ensure that adequate supplies are available for routing a.id amergency use.
This item will be evaluated during a subsequent inspection (81-07-03).
l (3)
Improper storage of respirators.
The inspector noted that respirators were stored, ready for use, stacked on one shelf in several layers.
The inspector pointed out that this can lead to the respirator face pieca losing the set and making these respirators potentially defective.
The inspector recommended sinole layer storage to decrease the potential of damaging the respirators pursuant to fiUREG 0041. This item will be evaluated during a subse-quent inspection (81-07-04).
(4) Contarination surveys are not performed on each individual respirator.
During the respirator cicaning, as noted in licensee procedure-Prod. 80.83, smear surveys are performed on 5 respirators per batch.
By procedure a batch can con-sist of 35 respirators with no more than 10 full-face respirators.
The inspector informed lice 1see representatives that each respirator should be individually smeared to assure
+'M contamination levels are not in excess of the limits specified in fiUREG 0041.
' nis item will be evaluated during i
a subsequent inspection (81-07-06).
The inspector spoke to licensee representativt concerning regu-lator certification for self-contained breathing opparatus (SCBA).
The licensee was not aware of this requirement and had received no guidelines from the manufacturer.
The inspector stated that the manufacturer recommended that regulators be checked and recertified annually.
This item will be evaluated during a subsequent inspection (81-07-05).
9.
Packaging and Transportation of Radioactive Waste The inspector examined the following documentation associated with the packaging and transportation of radioactive waste:
a.
PROD 80.10 Old Decon Waste Box Loading b.
PROD 80.38 Packing Waste Boxes and Drums c.
PROD 80.60 Shipping Waste Boxes d.
Packaging Engineering Change flotice e.
Drawing flo.112 D 1585 Rev.1 (Shipping Container-Contaminated
[
Waste) of f.
Inspection Procedures QCII - Drawing 112 D 1585 Rev. 1 and f
QCOR - Operator Requirements g.
Burial Site Disposal Criteria
8 The program for packaging and shipping containers of radioactive waste and the associated quality assurance inspections performed by the licentee are discussed with licensee representatives.
Con-tainers (4' x 4' x 4' wooden boxes) were examined by the inspector.
Licensee procedures have been revised to provide, with quality assurance controls, adequate containers to meet the b. rial site and D01 shipping container specifications.
Procedures, both operating und quality assurance inspection, have been developed and/or revised to assure that only acceptable materials, (e.g., no liquids) are placed in the containers.
The procedures reflected that inspections are performed prior to shipping, pursuant to the burial site disposal criteria. The inspector noted that there has been a significant improvement in the construction and sealing of the boxes used for disposal of waste.
It appeared that the operating and quality assurance procedures were adequate to assure that acceptable con-tainers are used, that only acceptable materials are placed in the containers, that adequate inspections are performed and that the containers are properly sealed prior to shipment.
10.
Plant Tours a.
General During tours of the FM0/FM0X ccmplex, it appeared that licensed material was processed, handled and stored in accordance with license conditions and the licensee's nuclear safety and radiation protection practices and procedures.
Personnel were observed to be using protective clothing and equipment as prescribed in the licensee's procedures. General housekeeping was satisfa: tory and no industrial safety or fire hazards were observed.
b.
Change Rooms License Condition 9 of the license requires that licensed material be used ia accordance with statements, represerita-tions and conditions of Apper.:iix A, as contained in the licensee's application. Appandix A, Section 4.1 requires that operations and activities shall be directed by the designated area m: nager who shall establish written operating procedures.
Procedure PROD No. ICR08, Personal Survey-Leaving Controlled Areas, requires that individuals hold the scanner probe approximately h-inch away and slowly pass it over the hair, face, chest, hand, wrist, ankles, shoes and TLD badge.
(1) During the inspection in September 1980, the inspectors observed personnel leaving the controlled area through the change room without properly monitoring themselves.
Personnel failed to hold the inscrument scanner probe in close proximity (approximately binch) of the body and to pass
9 the probe slowlv over the required areas. Also, some er the in:truments were not functioning.
A contamination survey of the clean side of the change room showed conta-mination levels above the action levels.
(2) During the June 1981 inspection, personnel were observed leaving the controlled area through the change room.
Personnel surveys for possible contamination on clothing and body were canducted in accordance with the posted procedural requirements.
Documentation was examined whicn showed that personnel had been instructed in the required procedure for monitoring when leaving the con-trolled area and the proper use of the ins rumentation.
Records were reviewed which sho'.!cd that contamination was not being spread to the clean side of the change rooms.
(5) Licensee representatives were informed that their corrective actions appeared satisfactory to prevent recurrence of the violation.
fio response regarding the violation would be required.
c.
Posting and Labeling The inspector reviewed the licensee's posting of radiation, contamination and radioactive material area and the labeling of radioactive material.
fie violations or deviations were identified.
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