ML20044C000
| ML20044C000 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/03/1993 |
| From: | Pharr E, Rankin W, Shortridge R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20044B999 | List: |
| References | |
| 70-1113-93-02, 70-1113-93-2, NUDOCS 9303160090 | |
| Download: ML20044C000 (12) | |
Text
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'g UMITED STATES A.
NUCLEAR REGULATORY COMMISSION
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REGION ll
~F 101 MARIETTA STREET.N.W.
's ATLANTA, GEORGI A 30323 f
pag 3 1993
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Report No.:
70-1113/93-02 Licensee:
General Electric Company Nuclear Fuel and Components Manufacturing l
P. O. Box 780 Wilmington, NC 28402 i
Docket No.:
70-1113 License No.:
SNM-1097 Facility Name: Nuclear Fuel and Components Manufacturing Plant Inspection Conducted:
Febru y 1-5, 1993 i
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Inspectors:
ortridgb Da'te Signed R. B.
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2C,f'\\'5 f' 'j '
"L i E. B.
arr Date Signed Approved by cd 3/2[93 W. H. Rankin, Chief Date Signed Facilities Radiation Protection Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
f Scope:
This routine, unannounced inspection of the licensee's radiati n proi.ection (RP) program involved review of health physics (HP) activitie, including program organization and staffing; training and qualifications; external and internal exposure monitoring and assessment; management and administrative controls; and radioactive material control.
In addition, followup actions related to previously identified inspection findings were reviewed.
Results:
The licensee's radiological protection program activities were adequate to protect the health and safety of plant workers. Organizational changes were i
noted in both the Nuclear Safety Engineering and Radiation Protection groups which in general were expected to enhance the licensee's capabilities. A 9303160090 930303
.PDR ADOCK 07001113 C
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i Compliance Auditing group had recently been formed and appeared to be i
.successfully identifying issues for licensee followup. These identified i
issues and successful resolution of the findings were_ expected to prove beneficial in improving the overall effectiveness of the licensee's RP.
-program. Routine internal and external exposure programs were implemented appropriately with all personnel exposures less than 10 CFR
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Part 20 limits. -The nuclear safety training program continued to be implemented in accordance with license requirements, and the refresher training recently provided to RP Monitors was noted as a good initiative. An-l issue for followup was identified during the last inspection regarding i'
continued air sampler plugging in.certain areas of the Uranium Recycle Unit (URV). This item will remain open until area modifications are completed and effectiveness of the modifications are verified. The licensee estimated a modification completion date of May 1993.
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.l REPORT DETAILS 1.
Persons Contacted
- G. Bowman, Senior Program Manger, Compliance Improvement
- T. Brechtlein, Manager, Powder Production
- S. Babb, Manager, Lagoon Elimination l
- D. Brown, Manager, Reclaim and Support
- M. Chilton, Manager, Technical Resources, Fuel Chemical Manufacturing
- R. Foleck, Senior Specialist, Licensing Engineering
- L. Gutermuth, Specialist, Industrial Safety T. Hauser, Manager, Environmental Health and Safety and Nuclear Quality Assurance
- R. Keenan, Senior Program Manager, Compliance Auditing i'
- S. Laufer, Manager, Fuel' Quality R. Lennon, Senior Compliance Auditor
- R. Lewis, Senior Compliance Auditor
- A. Mabry, Nuclear Safety Engineering D. McLemore, Manager, Fuel Chemical ~ Manufacturing
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- W. McMahon, Acting Manager, Manufacturing Engineering
- S. Murray, Manager, Radiation Safety Engineering i
- E. Palmer, Manager, FM0 Maintenance i
- R. Patterson, Manager, Fuel Fabrication Production j
- R. Robinson,-Principle Nuclear Safety Engineer
- H. Shaver, Engineer, Nuclear Safety i
- R. Torres, Manager, Radiation Protection C. Vaughan, Manager, Regulatory Compliance
- P. Winslow, Manager, Licensing and Nuclear Material Management P
Other licensee employees contacted included engineers, technicians, and office personnel.
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Nuclear Regulatory Commission f
i W. Rankin, Chief, Facilities Radiation Protection Section
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- Denotes those present at the exit interview conducted on February 5, 1993.
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Radiation Protection Organization and Staffing (83822)
I Chapter 2, Sections 2.2.1. 4 and 2.2.1.5 of the License Application i
establish the responsibilities and general organization for the radiation safety and radiation protection functions.
l The inspector reviewed and discussed with licensee representatives changes made..to the_ organization since the last inspection of this area conducted August 24-28, 1992, and documented in Inspection Report (IR)
.70-1113/92-10. The inspector was informed that the Nuclear Safety i
Engineering (NSE)-group and_ Criticality Safety Engineering' group was j
still divided in order to split the criticality safety and radiation l
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safety functions. Under the new organization, the Manager, Radiation Safety Engineering and the Manager, Criticality Safety Engineering reported to the Manager, Regulatory Compliance.
The inspector also i
noted that the Regulatory Compliance Manager now reported directly to
-t the newly established Manager, Environmental Health and Safety and i
Nuclear Quality Assurance. This manager reported t'o the Vice President l
of General Electric Nuclear Energy. This change was intended to provide an increased focus for health aad safety and quality assurance programs.
Also, the inspector noted that a compliance auditing group had been j
formed since the previous inspection.
The audit group consisted of a criticality safety engineer, a RP supervisor, and a quality assurance i
staff member.
In addition, the inspector was informed that a new Nuclear Safety Engineer position had been filled with the engineer's primary focus being to assist with implementation of the new 10 CFR Part 20 regulations. The inspector reviewed the engineer's qualifications regarding education and experience and found that the engineer more than met the position qualification requirements of Section 2.5.3.2 of the License Application.
As noted in IR 70-1113/92-10, the licensee had filled five Radiation Monitor technician positions within the Radiation Protection (RP) organization with the individuals being in " trainee" status..At the time of the onsite inspection one of the " trainees" had successfully completed the qualification process and was functioning as a fully qualified radiation monitor.
The four remaining individuals were still in " trainee" status.
1 Overall, the inspector did not note any concerns regarding the recent organizational and staf fing changes.
The increased staffing in both the NSE and RP areas appeared to be a program enhancement.
However, the inspector informed licensee management that although the addition of the' compliance auditing group'should prove beneficial in improving the-overall effectiveness of the RP program, the loss of the two staff 7
members appeared to be resulting in increased workload on the remaining
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staff.
The inspector also discussed replacement of the vacated positions if the auditing group became permanent.
No violations or deviations were identified.
3.
Training and Qualifications (83822) 10 CFR 19.12 requires, in part, that the licensee instruct all f
individuals working in or frequenting any portion of a restricted area
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in the health protection aspects associated with exposure to radioactive material or radiation; in precautions or procedures to minimize exposure; in the purpose and function of protection devices employed; in
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the applicable provisions of the Commission regulations; in_ the j
individuals' responsibilities; and in the availability of radiation
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exposure data'.
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To maintain RP Monitor knowledge and skills current with industry standards the licensee provided approximately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> of training in Health Physics at Uranium f acilities.
The training was provided by an instructor that is nationally recognized for his knowledge of uranium r
processing and manufacturing. Subjects included Uranium Processing Experience, Relative Hazards of Uranium, Contamination Control and Monitoring, Personnel Exposure Control and Monitoring, Decontamination f
Techniques, Nuclear Criticality Safety Overview, and New 10 CFR Part 20
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Requirements.
The inspector observed portions of the course and noted that class interest and participation in discussions were good.
The inspector received site specific training provided to NRC inspectors
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and noted that the course content was appropriate. The practical t
4 factors training focused on how to enter and exit radiologically i
controlled areas and how to perform personal monitoring.
Based on the review, the inspector concluded that the licensee maintained a structured and comprehensive program for RP Monitor training which was considered a strength to the overall RP program and that plant management was committed to maintaining high RP program t
standards through updated training for the RP technicians.
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No violations or deviations were identified.
4.
External Exposure Controls (83822)
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l 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 I
trunk, active blood forming organs, lens of the eyes, or gonads;
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18.75 rems to the hands, forearms, feet and ankles; and 7.5 rems to the skin of the whole body.
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10 CFR 20.202(a) requires each licensee to supply appropriate personnel l.
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 4
l The inspector reviewed and discussed with licensee representatives the licensee's 1992 annual study to determine whether extremity monitoring was necessary for workers routinely handling unclad uranium fuel pellets.
The annual review was performed using workers who routinely handled unclad pellets.
For those workers monitored the highest average i
extremity exposure evaluated at 7 milligrams per square centimeter (mg/cm'), and projected to a quarterly total, was approximately l
3400 millirem (mrem), approximately 18 percent of the NRC quarterly limit.
Based on these studies the licensee verified that extremity
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exposures were less than 25 percent of the NRC extremity exposure limit, j
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and concluded that extremity monitoring was not routinely required.
The inspector was informed that although the licensee had an approved i
license amendment which allowed evaluation of extremity exposures at a 2
2 tissue equivalent skin thickness of 38 mg/cm. rather than 7 mg/cm,
based on International Committee on Radiation Protection (ICRP)
Publication 23 recommendations, the licensee would not evaluate 2
extremity doses at 38 mg/cm until needed, based on the revised 10 CFR Part 20 requirements. The inspector did not note any concerns regarding the licensee's extremity monitoring evaluation.
The inspector reviewed exposure records for selected individuals involved with Fuel Manufacturing Operation (FMO) activities during the period from July 1 through September 30, 1992..The inspector verified that for those selected records reviewed all whole body exposures were less than NRC regulatory limits.
j No violations or deviations were identified.
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Internal Exposure Controls (83822) l 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 j
in a restricted area to inhale a quantity of 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.
a.
Bioassay Program 10 CFR 20.103(a)(3) requires, in part, that the licensee, as appropriate, use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
Nuclear Safety Instruction (NSI) 0-2.0, Bioassay Program, Revision (Rev.) 23, dated June 24, 1992, requires operators assigned to 1
work in vaporization. and hydrolysis, where the potential exposure is UF., to submit urine samples on the first and seventh, or last, l
day of their work week. Maintenance personnel working on anLas needed basis in these areas are to subrait samples daily.
Operators routinely working in areas where the potential exposure' is uranium nitrate (UNH) are required to submit a urine sample on the last or seventh day of the work week. The procedure also defines action limits of 15 micrograms per liter (ug/1) and 20 ug/l for urinalysis results from UF, and UNH, respectively. If these action limits are exceeded RP will determine the time of the.
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5 intake in order to calculate the actual intake.
For calculated intakes equal to or, exceeding an administrative limit of 7.5 mg l
the individual will be restricted from airborne controlled areas until released by RP.
The inspector reviewed sample submittal records and urinalysis i
results to verify that workers were submitting samples as required and that appropriate actions were taken based on sample results.
l The inspector reviewed selected records _ of workers routinely assigned to vaporization, hydrolysis, and URV during the period-from September 1 to December 31, 1992.
For those records reviewed, the inspector verified that samples were being submitted at least at the frequency required by procedure.
The inspector noted that for those records reviewed the maximum urinalysis result was 19 ug/1.
Based on an exposure to UF an intae of 0.33 mg was calculated for the individual.
Additionally, the inspector reviewed lung burden analyses for selected workers and contractor personnel.
During discussions l'
with licensee representatives the inspector was informed that since September 1, 1992 there had been no instances of_ workers being restricted from the controlled area due to measured lung burdens greater than the licensee's action limit of 250 ug uranium-235 (U-235).
For the selected records reviewed, the inspector noted that most counts were less than licensee's minimum detectable level of 50-55 ug U-235.
i No violations or deviations were identified.
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Air Sampling Program Chapter 3, Section 3.2.4.2.1 of the License Application requires that the radiation safety function annually evaluate fixed air sampling points for representativeness of personnel exposures.
The inspector reviewed the most recent air sampler
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representativeness study conducted in November and December 1992, and documented in a report dated December 21, 1992. The study included air flow studies in each work area, a comparison of measured lung burden data to lung burden estimates from assigned airborne results, and an evaluation of urinalysis results. Review-l of the flow studies noted that they included smoke tube tests as j
well as smoke bomb tests to determine the adequacy of air sampler placement.
Based on the air flow studies, approximately 12
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recommendations were made for sampler changes. The recommendations were implemented through issuance of.a Facility Change Request. The inspector was informed that'the changes would be implemented and-verified by March or April 1993. Other aspects 1
of the study including the comparison of lung burden data to 1991
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air sample results demonstrated representativeness in accordance with license requirements.
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j The inspector reviewed and discussed with licensee representatives I
airborne concentration trending. The inspector noted that during.
i 1992 airborne perturbations and MPC-hrs had continued to decrease, l
as compared to 1990 and prior years averages. 'The inspector noted i
that many Radiation Protection Committee projects over the year appeared to have successfully reduced airborne perturbations and contamination events.
Licensee representatives informed the inspector that evaluations were ongoing to determine the effectiveness of laminar flow efforts, particularly in the Pellet Press area, to reduce airborne levels in the workers' breathing zones. The inspector was also informed that future laminar flow upgrades would be dependent on the results of these evaluations.
The inspector discussed with licensee representatives that their continued progress in this area would be evaluated during future inspections.
No violations or deviations were identified.
c.
Respiratory Protection Program 10 CFR 20.103(c)(2) permits the licensee to maintain and to implement a respiratory protection program that-includes, at a i'
minimum: air sampling to identify the hazard; surveys and bioassays to evaluate the actual exposures; written procedures to -
select, fit and maintain respirators; written procedures regarding the supervision and training of personnel and issuance of records; and determination by a physician prior to the use of respirators, that the individual is physically able to use respiratory protective equipment.
10 CFR-20 Appendix A, Footnote (d), requires adequate respirable t
air of the quality and quantity in accordance with NIOSH/MSHA certification described in 30 CFR Part 11 to be provided for the atmosphere-supplying respirators.
30 CFR 11.121 requires that compressed, gaseous breathing air meets the applicable minimum grade requirements for Type 1 gaseous air set forth in the Compressed Gas Association (CGA) Commodity Specification for Air, G-7.1 (Grade D or higher quality).
The inspector discussed with licensee representatives final.
actions to fulfill a commitment, as documented in IR 70-1113/92-02, to change Carbon Monoxide (CO) limits for Grade D breathing.
air from 20 parts per million (ppm) to 10 ppm.
During the previous NRC inspection the-inspector noted that the licensee's.
breathing air. procedures and instrumentation used 1966 Compressed j
Gas Association C0 criteria, 20 ppm,.to demonstrate Grade D compliance. However, the 1989 revision of the standard changed 00 acceptance criteria from 20 ppm to 10 ppm.
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The inspector was informed that since the previous inspection, j
during which the inspector was informed that the licensee had r
experienced problems with the in-line, instantaneous C0 monitors alarming at the 20 ppm set points due to truck exhausts, the vendor had performed an inspection of the system to ensure its proper operation. Subsequent to that inspection the licensee had i
performed maintenance on a compressor which appeared to be causing filter clogging due to an oil leak. Additionally, the licensee was primarily using two compressors for supplying breathing air which were less likely to be exposed to truck exhausts. The inspector was also informed that the licensee was prepared to move l-the intakes for those two compressors to the roof where there would be an even lesser chance of exposure to exhausts.
Since these changes the inspector was informed that problems had not
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been experienced with meeting the 10 ppm CO acceptance criteria.
The inspector verified that the licensee had upgraded their six inline C0 monitors, and were calibrated, to alarm at 10 ppm._ The inspector also reviewed records for the vendor's 1992 annual testing which certified the system's capability to supply Grade D breathing air.
Additionally, the inspector reviewed records for selected workers i
associated with routine FM0 activities. The' inspector verified that each worker was trained to use respiratory protective equipment, fit-tested, and medically qualified in accordance with appropriate requirements.
No violations or deviations were identified, i
6.
Management and Administrative Controls (83822)
Chapter 2, Section 2.8 of the License Application to SNM-1097 details l
guidance for performing nuclear safety inspections and radiation safety audits by selected site and outside groups.
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Wilmington Safety Review Committee The inspector noted that the Wilmington Safety Review Committee (WSRC) conducted an annual review of the ALARA program during December 1992. The inspector reviewed meeting minutes of the i
Annual Review of the ALARA Program performed by the WSRC on December 1, 1992. The inspector noted that since 1987 the licensee continued to note a favorable trend in airborne perturbations and MPC-hrs. The licensee did however note a slight increase in external and internal doses during 1992, as compared.
l to 1991 value.s. The licensee stated that these increases were a-result of factory loading.
The inspector was informed that although the doses for 1992 were slightly higher than 1991, the.
projected average whole body exposure and skin exposure during i
1992 was less than 1 percent of the NRC quarterly limit, air -
sample results, as confirmed by lung counting, indicated average i
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internal exposures were less than 5 percent of the quarterly l
limit, and urinalysis results indicated that approximately 95 percent were below the licensee's minimum reportable limit.
Additionally, the committee recognized the successful completion of Radiation Protection Committee projects during 1992 to reduce visible contamination, system perturbations, and overall airborne level s.
The inspector informed licensee representatives, that in t
accordance with the committee's assessment, a continued
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improvement in the material condition of the facility was noted and appeared to have positively influenced the licensee's exposure control programs. The inspector noted the WSRC was meeting as required and was providing overview of the safety of operations.
j No violations or deviations were identified.
b.
Compliance Audit Group The inspector discussed with licensee representatives new initiatives to improve the self-identification of problems. As a result of an NRC inspection late in 1992 that identified violations for failure to comply with procedure requirements, the licensee reassigned knowledgeable, key personnel' to perform audits of all aspects of plant operations at the. facility. The special i
audit group is comprised of three people and has averaged two audits a week since November 1992.
A review of the audits show the findings are substantive and address problems with' procedure adequacy, operator performance, operator knowledge and skills, equipment labeling, radiological controls, and criticality controls. Upon completion of each audit and subsequent review by licensing / compliance, the audit is forwarded to the cognizant building manager for review and resolution. The inspector reviewed audit findings with the audit group and attempted to determine the status of audit items resolved.
The audit status was maintained by the Manager of Licensing and Nuclear Materials by audit rather than by audit item. A complete, up to date, status of all assessment items identified and resolved was not obtained by the inspector due to the still preliminary state of licensee assessment activities and the need to do an indepth evaluation of assessment findings during future inspection activity. The inspector considered the new audit initiative to be indicative of managements' support to improve plant performance through their program of self assessment.
i No violations or deviations were identified.
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c.
Termination Reports 10 CFR 20.408(b) and 10 CFR 20.409(b) require that licensees make a report to the Commission, and notify the individual involved or designee, of the radiation exposure of each individual within 30 days after the exposure of the individual has been determined by the licensee or 90 days after the date of termination of employment or work assignment, whichever is earlier.
The inspector reviewed records for selected GE employees and contractor personnel who had been monitored for exposure and had recently terminated employment with the licensee to determine whether exposure notices had been issued to the NRC and employees as required. The inspector verified that in response to a previously issued non-cited violation for failure to issue j
terminations reports to the NRC and the individual within the required time limits, the licensee had incorporated modifications into their computer system which would prompt the operator to the appropriate query sequence for issuance of termination reports so j
as to provide all names requiring such reports.
For those records reviewed the inspector noted that the licensee was appropriately issuing termination reports to individuals and the NRC as required by the regulations.
No violations or deviations were identified.
7.
Radioactive Material Control (83822) a.
Sealed Sources i
The inspector reviewed and discussed with licensee representatives j
1992 sealed source leak tests records for certain inline system-
'i detectors and check sources for detection instrumentation. The inspector verified that sealed ' sources kept onsite were leak tested as prescribed by the license application. The inspector
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also noted that for those records reviewed no high test results j
were identified.
l No violations or deviations were identified.
b.
Facility Tours During tours and walkdowns of the process areas, the inspector i
observed personnel performing routine operations, as well as cleanup activities, which required respiratory protection. The i
inspector noted personnel were knowledgeable of the radiation hazards associated with their activities, and noted that protection devices including radiological postings, respiratory.
protective equipment, protective clothing, and personal dosimetry
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and material storage locations, the inspector noted that
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radioactive materials were posted / labeled and safeguarded in
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10 accordance with license conditions. The inspector observed that
.i survey instruments in use at the FM0 and URU change rooms were operational and displayed current calibration stickers. Review of j
the accompanying logbook for each of the instruments, indicated that the licensee was performing periodic performance checks as L
required by procedures.
No violations or deviations were identified.
8.
Previously Identified Inspector Followup Items (92701)
(0 pen) Inspector Followup Item (IFI) 70-1113/92-02-01: During a i
t previous inspection the inspector noted numerous documented cases of air sampler plugging problems in URU, particularly the Cross Flow Filter-
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Room. Discussions with licensee representatives indicated that the i
plugging was attributed to the interaction of chemical fumes in the area resulting in the deposition of ammonium nitrate on the filters. During the current inspection the inspector was informed that the licensee's continued actions in response to the plugging included:
tracking of l
sampler clogging; increased filter surveillances;. application of a correction factor to sampler results to account for the reduced flow when samplers were found clogged. To date the licensee had also implemented a " dry floor policy" throughout URU and had initiated replacement of PVC piping with stainless steel. Additionally, the
.l licensee had proposed a plan for corrective action which would include L;
further upgrades and modifications throughout the system. The inspector was informed that funding for the proposed corrective plan was anticipated and that if such funding was indeed granted the i
modifications _ should be completed by May,1993.
The inspector informed v
licensee representatives that the effectiveness of the actions to
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correct the plugging problems would continue to be tracked as an IFI (IFI 70-1113/92-02-01) pending fin ~al resolution of the problem.
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Exit Meeting (83822, 92701) l The inspector met with licensee representatives indicated in Paragraph 1 i
at the conclusion of the inspection on February 5,1993. The inspector-i summarized the scope and findings of the inspection.
Although proprietary documents and processes were reviewed during the inspection,_
l the proprietary nature of these documents.are not reflected in this j
report. Dissenting comments were not received from the licensee.
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