ML20058F897
| ML20058F897 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/14/1982 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20058F885 | List: |
| References | |
| NUDOCS 8208030135 | |
| Download: ML20058F897 (3) | |
Text
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e G E N E R A.L$" ~ E-LE.CT R I C NUCLEAR ENERGY PRODUCTS DIVISION WILMINGTON MANUFACTURING DEPAR W ENT IL 1 0,
. C. 28402 (919) 343-5000 CASTLE HAYNE ROAD. P.
. OX July 14, 1982 Mr. A.
F. Gibson, Chief Technical Inspection Branch Division of Engineering & Technical Programs U. S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. Gibson:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/82-10 dated 6/15/82, received 6/22/82 Thank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr. C. M.
Hosey of your office on May 17-21, 1982.
Pertaining to the item of apparent noncompliance with NRC requirements in your letter, the reply to this item is given in the attachment to this letter.
We appreciate your inspector's comments and suggestions related to our employee safety and environmental protection programs.
These comments and suggestions are helpful to us in our constant efforts to improve these programs, ensure the continued health and safety of plant personnel, and ensure our compliance with NRC regulations and license condition.
We also welcome further discussion with your staff on the items in your letter and in our related reply, if necessary, for further clarification of these items.
Your inspection report referred to above does not contain information which we believe to.be proprietary.
GENERAL ELECTRIC COMPANY f' f$f.
dMc' Charles M. Vaugha,n, Manager Licensing & Nuclear Materials Management M/C J26 CMV:bsd NSD-I 8208030135 820726 PDR ADOCK 07001 C
GENER AL $ ELECTRIC Mr. A.
F. Gibson July 14, 1982 ATTACHMENT The information given below refers to the item in Appendix A,
" Notice of Violation," in the NRC Inspection Report 70-1113/82-10, dated June 15, 1982.
License Condition 9 of the license requires that licensed material be used in accordance with statements, representations and conditions of Appendix A, as contained in the licensee's application.
Appendix A,
Section 4.1 requires that operations and activities shall be directed by the designated area manager who shall establish written operating procedures.
Procedure PROD No.
- 1CR08, Personal Survey -
Leaving Controlled Area, requires that individuals hold the scanner probe approximately 1/4 inch away and slowly pass it over the hair,
- face, chest, hands, waists, ankles, shoes and TLD badge.
Contrary to the above, the requirements of the license condition were not met in that on May 20 and 21,
- 1982, individuals exited the controlled area without performing personnel contamination monitoring in accordance with the plant procedure.
The workers moved the probe at much greater distance that 1/4 inch and at a rapid rate.
General Electric concurs with the audit finding that on May 20 and 21, 1982, individuals leaving the controlled area were observed surveying themselves in a manner inconsistent with the applicable procedure.
This violation appears to be the result of employees not taking the time required to perform the proper self-monitoring when leaving the area as opposed to a lack of training or adequate equipment.
It is our belief that all effected employees have received the necessary training, retraining, and are periodically reminded of the proper techniques to be used.
Adequate survey equipment is conveniently available for their use.
GEN ER AL O stsciaic Mr. A.
F. Gibson July 14, 1982 l
Attachment - Page 2 GE has continued to conduct daily audits of personnel monitoring in the change rooms as defined in our letter of November 24, 1981, (reference 70-1113/81-11-04), but has not' found inadequacies to the degree reported by Mr. Hosey.
However, based on Mr.
Hosey's findings, it appears that the audits as currently structured may i
not be sensitive enough to detect deficiencies of speed and distance requirements for surveys.
In order to correct this suspected deficiency, all auditors assigned to these special audits will be reinstructed in proper survey techniques with emphasis placed on speed and distance considerations for a
proper survey as specified in the WMD procedure PROD 1CR08, " Personal Survey - Leaving Controlled Area."
This instruction will be completed by September 1, 1982.
Additionally, the requirements for proper self-monitoring techniques will be re-emphasized to employees by shop supervision during regularly scheduled "round table" meetings.
A survey instrument study has already been initiated at Wilmington to determine whether better instrumentation is available for this type of survey.
Completion of this study is anticpated by year end.
We have also embarked on a study to review what facility changes could be made to improve the situation.
This initial study is currently receiving management review.
Based on the audit results obtained after the above training and depending on the degree of non-conformity identified, we believe full compliance is obtainable by December 31, 1982.
As required in Appendix A of the inspection report, information contained in the response is provided under oath as follows:
The foregoing is true to the best of my knowledge and belief b sed on the information available to me at t I time.
Signed:
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