ML20058H451

Discusses Enforcement Conference Conducted on 900820 Re Activities at Facility & Insp Rept 70-1113/90-07.Info Discussed Re Radiation Protection Program

ML20058H451
Person / Time
Site:	07001113
Issue date:	11/02/1990
From:	Stohr P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Lewis W GENERAL ELECTRIC CO.
References
EA-90-139, NUDOCS 9011160110
Download: ML20058H451 (28)

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.4i NOV 0 21990 i

'i Docket No. 70-1113 License lio. SNM-1097 EA 90-139 l

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General Electric Company l

ATTN:, Mr. Wayne'P. Lewis, General Manager i

-Nuclear Fuel and Component

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Manufacturing Department P. O. Box 780 f

Wilmington, NC 28402 j

L Gentlemen:

l

SUBJECT:

ENFORCEMENT CONFERENCE

SUMMARY

1 This' letter refers to the Enforcement Conference held at our request on i

August _20, 1990.

This meeting concerned activities authorized for your Nuclear Fuel and Component Manufactv 'ng facility.

l The issues discussed at the _ Enforcement Conference related to concerns j

identified during the origi.nc1 inspection conducted June 18-22, 1990 and August 1-3,-1990, and documented in' Inspection Report' No. 70-1113/90-07.

In L

particular, these ' issues concerned your radiation protection program for-1 monitoring the extremities of workers handling unciad uranium, and also for l

repeat violations of procedural and transportation non-compliances.

A list of j

attendees and a copy of the viewgraphs_you presented are enclosed.

1 o

Based on.the..information provided. by your staff - and additional concerns-

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regarding your extremity monitoring program evaluation as discussed at the -

1 Enforcement. Conference, a. supplemental inspection was ' conducted September =6-7,1990.-

lResults. of the supplemental - review and our' final

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evaluation concerning the-apparent violations are_being forwarded to your under.

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separate cover.

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'In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures j

will be placed in the NRC Public Document Room.

1 1

- Should you have any questions concerning this matter, please contact us.

j Sincerely, j

~ ORIGINAL slGNgo gy J. PHILLIP S%

i J. Philip Stohr, Director Division of Radiation Safety and Safeguards a

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Enclosures:

(See page 2)

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. General Electric' Company 2

Enclosures:

1.

List of Attendees-2.

Meeting Sumary 3.

Visual Aids cc_w/encls:

T. Preston Winslow, Manager Licensing and Nuclear Materials Management.

General Electric Company P. O. Box 780, Mail Code J26 Wilmington, NC 28402 State of North ~ Carolina bec w/encis:

Document Control Desk bec w/o encis:

License Fee Management Branch-

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ENCLOSURE _1 List of Attendees General Electric Company W. Lewis, Manager, Nuclear Fuel and Component Manufacturing C. Vaughan, Manager, Regulatory Compliance S. Murray, Manager, Nuclear Safety NRC S. D. Ebneter, Regional Administrator, Region 11 (Rll)

J. L. Milhoan, Deputy Regional Administrator, Ril J.P._ftohr, Director,DivisionofRadiationSafetyandSafeguards(DRSS),Ril G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS),R11 D. M. Collins, Chief, Emergency Preparedness and Radiological Protection (EPRP)

Branch,:DRSS, RII W.E. Cline, Chief,-NuclearMaterialsSafetyandSafeguards(NMSS) Branch, DRSS, RII E. J.'McAlpine, Chief, Radiation Safety Projects (RSP) Section, NMSS, DRSS, Rll G.B.-Kuro,SeniorRadiationSpecialist,FacilitiesRadiationProtection(FRP)

-Section,-EPRP, DRSS, RII C. H. Bassett, Senior Radiation Specialist, RSP, NMSS, Ril B. Uryc, Senior Enforcement Specialist ~,' EICS, Rll

-E.. Flack Project Director, NMSS, NRC Headquarters s-

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, ENCL _0SURE 2 Enforcement Conference Summary The Regional Administrator (RA), NRC Region II' (RII) opened the meeting by stating that continued NRC identification of issues at the licensee's facility, i

both the. frequency of repeat violations and the identification of new i

regulatory issues, were of increasing concern.

Further, the RA stated that, in general, the Commission was placing increased emphasis on fuel facility j

radiation protection and criticality programs and that this emphasis would j

continue for their facility.

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The Manager, General Electric (GE/ Nuclear Fuel-and Component Manufacturing (NF8CM) Division stated that he and his staff were dedicated to meeting compliance requirements-and we:e continuing to follow their plan for i

improvements outlined and dis:.ussed in NRC-GE management meetings conducted

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July.11, 1990, and August 27, 1990.

j The Director, Division of Radiation Safety and Safeguards, reviewed two areas l

of concerns documented in Inspection Report 70-1113/90-07-which were being k

considered for escalated enforcement action by the NRC.

These areas included deficiencies identified for the extremity monitoring program for personnel handling ~ unclad uranium and several repeat violations.

An overview of the

-escalated enforcement process was presented by the Director, Enforcement and Investigation Coordination staff.

l The GE. Regulatory Compliance Manager presented an overview of the seven apparent violations identified in the subject inspection report.

The overview l

included the situation at the time of the inspection, the cause of the problem, and their corrective actions.

Information_ provided in the _ licensee's viewgraph presentation are' included in Attachment 2.

l 1

Additional discussion between thel NRC and cognizant licensee. representatives i

was conducted regarding specific aspects of the extremity monitoring program.

- The -issues discussed included the the appropriate placement of extremity

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dosimetry to meet regulatory requirements, the revised dose rates from unclad j

uranium pellets utilized to evaluate individual's exposure, and the licensee's

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final evaluation of potential overexposures. The following extremity monitoring j

issues were reviewed and discussed in detail:

' Skin dose monitoring for selected areas of the extremities areas.

Regarding this issue, licensee representatives stated that a study was in

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progress to; evaluate the extremity dose received at two index finger.

l locations, that is at the tip(and at the first joint of the finger, using a

thermoluminescent dosimeters TLDs).

The study was being conducted to 1

determine proper extremity monitoring techniques for evaluation purposes 1

and, if necessary,_ for routine monitoring purposes.

An agreement was

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reached for licensee, and NRC Nuclear Material Safety and Safeguards 1

(NMSS) and NRC Ril Facility Radiation Protection -(FRP) personnel to meet I

and review the results of the comparison study.

The meeting was expected 1

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'l to be scheduled in approximately four weeks when the cc.iparison results-l for approximately 32 individuals were expected to be available, j

Overall reduced pellet dose rates estimates.

Licensee representatives stated that the uranium pellet bete dose rate was reduced from j

161-191 millirem / hour (mrem /hr) originally detailed in a 1973 study as a j

result of limited ingrowth of the metastable state of Protactinium-234 (Pa-234m) from a more rapid throughput of uranium materials.

This increased throughput occurred in 1985.

Current pellet dose rates were l

reported to be approximately 40-60 millirem per hour (mrem /hr) relative to 1

161 mrem /hr. previously measured and utilized in dose calculation algorithms.

The licensee stated that dose rates measured on the side of,

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relative to the ends of the pellet, were reduced.

Furthermore, the j

licensee stated that another vendor study indicated that the measured dose rate of uranium. pellet material. was approximately 100 mrem /hr.

NRC i

representatives stated that data supporting the effect of increased rate material throughput, pellet surface geometry effects, and vendor results j

regarding revised dose rates would be reviewed.

J l

Extremity' exposure. reassessment.

Licensee representatives presented s

results of their re-evaluation of assigned extremity doses for personnel I

handling unclad uranium materials.

For the period of 1979 through June 1990, the licensee identified seven occurrences involving six individuals

.whose extremity dose assessed through 7 mg/cm2-exceeded the 1

10:CFR 20.101(a) limit of 18.75 ren per quarter.

Subsequent adjustments

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for identified material throughput record errors and decreased dose rates, s

reduced the original subject quarterly overexposure extremity dose values 1

to,6.66 rem per_ quarter or less.

NRC representatives stated that the-bases 'for. the adjustments :to the lkensee's assessments would be reviewed in detail.

1, Licensee evaluation of procedural non-conformance preented in the inspection report were' reviewed and. discussed.

The ongoing corrective actions were outlined. in detail'.

In addition, the' presentation. reviewed' improving trends regarding the occurrence of specific procedural non-compliances including empty-container storage /use, respiratory protection equipment storage, and posting

-adequacy.

The licensee. characterized their program for upgrading procedural 4

compliance ~ as a complex issue, but that-the plan was on schedule and was

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conducted with total commitment from management.

l The licensee addressed a transportation issue regarding'the failure to provide f

exclusive use vehicle instructions to drivers.

Their evaluation determined

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that required documents were provided.

Subsequent to the enforcement -

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]S conference, the licensee provided a copy of a letter from the transport company verifying that the required documentation was provided.

The licensee summarized their management dedication to immediate and long-term compliance for the identified issues.

Based on their evaluations, no individuals were assigned extremity exposures greater than the 10 CFR Part 20 quarterly limits.

However, additional evaluction was to be conducted to

' determine the need for the routine issuance of extremity dosimetry for l

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~;v personnel $and1_ing r unciad uranium.

In addition, improvement ' regarding-

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n,e (identified procedural compliance deficiencies was cc..inuing.-

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The Deputy Regional _-ddministrator closed the z. meeting. by -stating his f

' appreciation for the' presentation = and discussion 1of the additional. data and q

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-1nformation regarding the current-issues provided by the licensee staff.

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APPARENT VIOLATION 1

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3 VIOLATION i

70-1113/90-07-01 FAILURE TO HAVE WRITTEN PROCEDURES FOR l

CONDUCTING THE EXTREMITY MONITORING PROGRAM l

FOR PERSONNEL ROUTINELY HANDLING UNCLAD l

URANIUM MATERIAL-(PARAGRAPH 2 a).

VIOLATION l

OF LICENSE CONDITION NO. 9, j

l SITUATION g

a

' PRIOR TO THE CURRENT SYSTEM, EXTREMITY DOSE MONITORING PROGRAM 3

WAS PROCEDURALIZED 4

IN LATE 70s, ENGINEERING STUDIES WERE PERFORMED AND DOCUMENTED

. COMPUTER SYSTEM, FUNCTIONAL REQUIREMENTS DEVELOPED

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INCORPORATED.INTO REMTRAC DOSE ASSESSMENT AND TRACKING SYSTEM l

I EXTREMITY DOSE MONITORING PROCEDURE DELETED IN 1980 f

'CAUSE-WE DIDN'T RECOGNIZE FORMAL Pr.OCEDURES WERE REQUIRED l-COMPUTER SYSTEM SPECIFIJATIONS DOCUMENTED

-ENGINEERING STUDIES DOCUMENTED-CORRECTIVE ACTION l

PROCEDURAL REQUIREMENTS ON EXTREMITY MONITORING HAVE BEEN Li INCLUDED IN A NUCLEAR SAFETY INSTRUCTION (NSI) l i

IDENTIFIED AREAS REQUIRING EXTREMITY MONITORING i

- ' REQUIRES' MONITORING. DEVICES WHERE. EXPOSURE POTENTIALLY l

EXCEEDS-25% OF LIMIT i

ANNUAL RE-EVALUATION WHERE MONITORING'MAY BE REQUIRED PER 10 CFR'20 CMV 8/27/90

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t APPARENT VIOLATIONS 1-4 OVERVIEW EXTREMITY EXPOSURE A--PROGRAM WHICH~ DETERMINES EXPOSURES BASED ON CALCULATION RATHER THAN DISCRETE MEASUREMENTS

.3 DEVELOPED 1976-1979 e.

WE-THOUGHT THE' PROGRAM WAS APPROPRIATE NOW KNOWN THAT CERTAIN ASPECTS MUST BE CHANGED

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EXTREMITY MONITORING BACKGROUND

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EXTREMITY EXPOSURES ARE TO A SMALL AREA OF THE FINGER AND THUMB TIPS FROM CONTACT (THROUGH GLOVES) WITH LOW ENRICHED URANIUM FUEL PELLETS

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TECHNICALLY CHALLENGING PROBLEM FIRST USED AS DOSE ALSIGNMENT IN 1979

'i PROGRAM BASED ON:

- ' TIME / MOTION STUDIES.(PELLET CONTACT TIMES)

. THROUGHPUT AT A GIVEN WORK STATION (KG HANDLED)

SURFACE DOSE RATE,OF 195 MRADS/HR (PELLET ENDS)

PROTECTIVE GLOVE AND'ICRP 23 FINGERTIP SKIN THICKNESS CONSIDERED AS ABSORBERS RESULTED IN DOSE CONVERSION FACTORS.FOR APPLICABLE PROCESS AREAS-(REM /KG RANDLED PER SHIFT)

FINGER TLD BADGES ON. WORKERS INDICATED CONSERVATISMS IN-MODEL WAS ORIGINALLY DESIGNED TO DEMONSTRATE EXTREMITY EXPOSURES l

WERE LESS THAN 25% OF LIMIT (4. 68 REM PER QUARTER)

STUDY UPDATED AND MODIFIED SLIGHTLY IN 1983 1984 LICENSE UPDATE DOCUMENTS OUR SYSTEM, BUT DOES NOT PROVIDE AN EXCEPTION i

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APPARENT VIOLATION-2 P

VIOLATION-70-1113/90-07-02 FAILURE TO MONITOR AND RECORD EXPOSURE TO THE EXTREMITIES IN ACCORDANCE WITH-INSTRUCTIONS PROVIDED IN FORM NRC-5-(PARAGRAPH 2.a).

VIOLATION OF 10 CFR 20.-401(a) REQUIREMENTS.

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. SITUATION GE PROGRAM IN 1979 USED 58 MG/CM8 SKIN THICKNESS TAKEN FROM DATA LISTED IN ICRP.FvBLICATION 23 1

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.CAUSE' MISUNDERSTANDING THAT--7 MG/CM8 SKIN THICKNESS MUST BE USED TO DETERMINE COMPLIANCE WITH'THE LIMITS OF 10 CFR 20.101 l

CORRECTIVE ACTIONL WE NOW UNDERSTAND NRC POSITION.REGARDING 7 MG/CM8.(REFERENCE LETTER-TOLP. STOHR'FROM L. CUNNINGHAM DATED 7/20/90) i FACTORED REVISED SKIN THICKNESS INTO OUR REASSESSMENT OF THE IDENTIFIED INDIVIDt:ALS WITH APPARENT OVEREXPOSURES WILL USE 7 MG/Ch8 SKIN' DENSITY FOR DETERMINING COMPLIANCE y

USING TLDs l

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j APPARENT VIOLATION 3

L VIOLATION 70-1113/90-07-03 FAILURE TO SUPPLY AND TO REQUIRE THE USE OF APPROPRIATE EXTREMITY EXPOSURE MONITORING EQUIPMENT BY' INDIVIDUALS POTENTIALLY EXCEEDING l

25 PERCENT OF 10 CFR 20.101(a) LIMITS (PARAGRAPH 2.b).

VIOLATION OF 10 CFR. 20.~202 (a) (1). REQUIREMENTS.

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SITUATION 1

EXTREMITY EXPOSURE MODEL USED IN LIEU OF INDIVIDUAL MONITORING DEVICES

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CAUSE LTECHNICALLY DIFFICULT TO' UTILIZE MONITORING DEVICES ON FINGERTIPS - DEVELOPED.IN-HOUSE SYSTEM

=t OUR APPROACH TO COMPLIANCE WAS DOCUMENTED IN OUR 1984 LICENSE I

RENEWAL L

FAILURE TO HAVE A SPECIFIC EXEMPTION IN LICENSE l

4 C.ORRECTIVE ACTION FINGER RING:TLD MONITORING PROGRAM INITIATED 8/6/90 i

' EXTREMITY DOSES'WILL CONTINUE TO BE' MONITORED AND ASSIGNED USING TLDs' PURSUANT TO 10 CFR 20 L

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APPARENT VIOLATION 4

1 VIOLATION i

70-1113/90-07-04 FAILURE TO-MAINTAIN OCCUPATIONAL DOSEF TO THE SKIN OF THE RANDS BELOW 18. 7 5 REM PER Q'JAPTER FOR INDIVIDUALS HANDLING UNCLAD URANIUM-MATERIAL (PARAGRAPH 2.c).

VIOLATION OF 10 CFR 20.101(a) REQUIREMENTS.

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SITUATION t

USE OF 7 MG/CM8 SKIN THICKNESS IN GE MODEL CAUSED SEVERAL INDIVIDUAL EXPOSURES TO APPEAR GREATER THAN 18.75 REM /QTR '

CAUSE

~l GE MODEL CONSIDERED FINGERTIP THICKNESS OF 58 MG/CM8 p

ADDITIONAL CONSERVATISM IN APPLYING THE MODEL SWOWN TO EXIST

, UNABLE ~DURING INSPECTION TO SORT THROUGH CONSERVATISM IN OUR-

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MODEL

'RECORDKEEPING ERRORS i

CORRECTIVE ACTION INVESTIGATION ~ PERFORMED-ON SEVEN INSTANCES OF APPARENT OVEREXPOSURES MATERIAL HANDLING-RECORDKEEPING ERRORS IDENTIFIED AND CORRECTED.

SURFACE' PELLET DOSE RATE RE-ESTABLISHED MORE RAPID THROUGHPUT OF MATERIAL LESS INGROWTH OF'S-EMITTING DAUGHTERS CURRENT CONTACT DOSE RATE OF PELLETS IS 40-60 MR/HR VERSUS1 161 CONFIRMED BY RECENT TLD' STUDY 1985 BATTELLE STUDY INDICATED 100 MR/HR CMV 8/27/90

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ASSESSMENT OF e

APPARENT OVEREXPOSURES REMTRAC DATE EMPLOYEE-NO.

(58 mc/cm8) 7 mc/cm8*

CORRECTED **

84/04 A

15.07 rem 19,29 rem 6.66 rem 84/04 B

15.05 19.26 5 'i S 89/01 c

15'.47 19.80 5.53 89/02 D

14.87 19.25 6.59

'89/02 E

16,46 21.07 4.$1

-89/02 F

17.44 22,32 -

4.66 90/02-

-D-15.04 19.25 6.47

• REVISED BETA TRANSMISSION FACTOR USING 7 mg/cm8 SKIN THICKNESS.

ALL-OTHER ASSUMPTIONS REMAIN SAME,

• • CORRECTED EXPOSURES USING'7-mg/cma SKIN THICKNESS, MATERIAL-

HANDLING RECORDKEEPING - ERRORS CORRECTED, AND SURFACE PELLET DOSE

' RATE OF 75 mR/hr CMV 8/27/90 l

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TLD FINGER RING STUDIES 1983 STUDY 10 WEEKS 11 INDIVIDUALS / WEEK 7 DIFFERENT PROCESS AREAS REMTRAC DOSE FINGER RING' DOSE 1

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(mrem /wk)

HIGHEST-3:

(1) 1070 HIGHEST 3:

(1) 190 (2) =1060 (2)-170 (3) 130 (3).1030 1990 STUDIES INITIATED,8/6/90 -' WEEKLY EXCHANGE - ONGOING

,(21 WEEKS DATA) AVAILABLE

~N 100 INDIVIDUALS REMTRAC DOSE FINGER RING DOSE 8 (mrem /wk)

(mrem /wk)'-

' HIGHEST 3:

(1) 1720 HIGHEST 3:

(1) 140 (2)'1640 (2) 120 (3) 1460 (3) 110

• BASE OF FINGER 11 8 FINGER JOINT NEAR. NAIL CMV 8/27/90

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CONCLUSIONS e

i GE CONCURS THAT INDIVIDUALS WITH EXTREMITY EXPOSURES IN EXCESS

' OF 25% OF THE QUARTERLY LIMIT HAVE NOT BEEN SUBJECTED TO-MONITORING EQUIPMENT PER 10 CFR 20.202(a) (1)

GE UNDERSTANDS THE APPLICABILITY OF,7 MG/CM8 SKIN' THICKNESS AND'HAS READJUSTED EXPOSURE ASSIGNMENTS OF HIGHEST INDIVIDUALS ACCORDINGLY s

ERRORS AND SOME CONSERVATISMS IN THE PREVIOUSLY USED DOSE ASSESSMENT METHOD'HAVE BEEN. IDENTIFIED, QUANTIFIEDLAND-REMOVED-i f

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THERE HAVE BEEN NO OVEREXPOSURES TO PERSONNEL OUR~ COMPLIANCE PROGRAM.IS BACK ON TRACK CMV 8/27/90

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APPARENT VIOLATION 5

VIOLATION-70-1113/90-07-05 FAILURE TO CONDUCT ADEQUATE SURVEYS /

I EVALUATIONS OF THE HAZARDS PRESENT TO DETECT RADIOACTIVE CONTAMINATION ON THE SKIN OF THE FOOT BY A URU WORKER EXITING THE RCA.

VIOLATION OF 10-CFR 20.201(b) REQUIREMENTS.

SITUATION' CONTAMINATED. FOOTPRINTS FOUND ON CLEAN SIDE OF SOP

-TRACED TO, SPECIFIC-WORKER

' CONTAMINATION FOUND ON WORKER'S FOOT WORKER HAD SPECIAL EMPHASIS TRAINING ON SURVEYS POTENTIALLY LIV EXCEPT FOR 89-05 FRISK FINDINGS OVERALL - GOOD PERSONNEL SURVEY IMPROVEMENTS 16 PEOPLE 05-INSPECTION - MAY/ JUNE, 1989 D

90-03-INSPECTION - FEBRUARY, 1990

"... APPEARED TO BE AN IMPROVEMENT IN~ COMPLIANCE WITH THE REQUIREMENTS FOR PERSONNEL MONITORING" 90-07 INSPECTION -~ JUNE, 1990 -'"...NO PROBLEMS WERE NOTED WITH THOSE PERSONAL SURVEYS OBSERVED"'

-CAUSE

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CONTROLLED' AREA SHOES IN POOR CONDITION

' CORRECTIVE ACTION

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-RESTRICTED INDIVIDUAL FROM CONTROLLED AREA

' DECISION-HAKING-LEAVE HIGHEST-LEVEL POSITIVE-DISCIPLINE 1

EVALUATION / PURGE OF CONTROLLED AREA SHOES INCIDENT' COVERED IN ROUNDTABLES;WITH EMPLOYEES AS PART 0F EXIT

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CRITIQUE REVIEW SPECIAL>ROUNDTABLES ON " CLEAN SHOE PRACTICE AT SOP" EVALUATED EXTREMITY-EXPOSURE (LOW - 10 MREM)

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PROCEDURAL COMPLIANCE 1

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3 APPARENT VIOLATION 6

0 VIOLATIONE 70-1113/90-07-06 FAILURE TO FOLLOW PROCEDURES FOR THE FOLLOWING RADIATION PROTECTION PROGRAM AREAS / ACTIVITIES.

MULTIPLE EXAMPLES OF A VIOLATION OF LICENSE R,

CONDITION NO.

9..

PERSONAL RADIATION PROTECTION GUIDANCE FOR:

(1)--RESPIRATOR STORAGE (PARAGRAPH 7);

(2) THERMOLUMINESCENT DOSIMETER (TLD) USE i

ARE W H N E S OR GE PAD PAR GRAPH 8 PROCESS / RECOVERY OPERATIONS PROCEDURES FOR

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PROCESS EQUIPMENT FILTERS (PARAGRAPH 8.f); AND (1) STORING COMBUSTIBLE MATERIALS NEAR EMPTY UP CYLINDERS (PARAGRAPH.8.e); (2)-BAGGING (3)' MAINTAINING LIDS AND LOCKS FOR STORAGE CANS.

INVENTORY.ING AND LEAK TESTING OF SNM SEALED SOURCES (PARAGRAPH 9).

PERSONAL RADIATION PROTECTION GUIDANCE FOR:

(1)c-RESPIRATOR STORAGE' SITUATION-1

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'o TRAINING VIDEO WAS MORE RESTRICTIVE THAN PROCEDURE OR-AUDITING > GUIDANCE

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-TRAINING-VIDEO REQUIRED DISPOSAL-AT END OF WORK PERIOD

• NRC INSPECTOR'NOTED A RESPIRATOR STORED FOR > 24 HOURS

• : APPARENT VIOLATION BASED ON TRAINING VIDEO REQUIREMENTS-CAUSE e' ' INDIVIDUAL FAILED TO RETURN THE. RESPIRATOR -

CORRECTIVE ACTIONS T*

.MAKE TRAINING PROGRAM, PROCEDURES, AND AUDITING. GUIDELINES'

CONSISTENT.

• - RETRAIN USERS'TO. REINFORCE OWNERSHIP AND CONTROL i

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APPARENT VIOLATION 6

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(2) TLD USE j

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6-INDIVIDUAL WORKING IN BUNDLE ASSEMBLY' AREA WITHOUT REQUIRED l

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TLD REQUIREMENT TO WEAR TLD SPECIFIED IN TRAINING AND BY THE ISSUANCE OF A TLD i

3 CAUSE i

l OVERSIGHT ON THE PART OF THE INDIVIDUAL i

CORRECTIVE ACTION-Lj IMMEDIATE CORRECTION BY INDIVIDUAL

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DISCIPLINARY ACTION ENTERED AT THIRD STEP (WRITTEN

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REMINDER) i

• ' RE-EMPHASIZED REQUIREMENTS TO KORKERS IN THE AREA

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(3)-INCORRECT POSTING OF A RADIATION AREA i

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SITUATION l

• < STORAGE PAD-IMPROPERLY POSTED TO REQUIREMENTS' l

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POSTING REQUIRED TO STATE " RADIATION AREA" l

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• ' OF TWO-SIGNS, ONE SIGN DID NOTLINCLUDE " RADIATION AREA" q

WARNING-1

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• -UNABLE TO DETERMINE INITIAL FAILURE.

SURVEILLANCE PROGRAM WAS NOT EFFECTIVE.

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-* ' SIGN CORRECTED IMMEDI/^2LY

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• WORK INITIATED TO REPLACE THE ROPE AND SIGNS WITH PERMANENT POSTS'AND-SIGNS ON PERI. METER OF AFFECTED AREA

' UPGRADING SURVEILLANCE MONITORING ~ SYSTEM.AND METHODS TO USE LISTS / MAPS ON AN INCREASED FREQUENCY

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4 PROCESS / RECOVERY OPERATIONS PROCEDURES FOR:

I (1) COMBUSTIBLE MATERIAL STORED NEAR UF, CYLINDERS SITUATION NSR IN EFFECT FOR SUBJECT FENCED PAD REQUIRING COMBUSTIBLE MATERIAL BE GREATER THAN 15 FEET FROM CYLINDERS EMPTY UF, CYLINDERS STORED ON THE FENCED PAD SITE CONTRACTOR PLACED LUMBER ON OUTSIDE OF FENCE BUT I

CLOSER THAN 15 FEET TO CYLINDERS CAUSE NSR FOR PAD DID NOT ADEQUATELY ADDRESS EXTERNAL EFFECTS CORRECTIVE ACTION RESTATE NSR REQUIREMENT TO PROVIDE NECESSARY LEVEL OF j

POSITIVE CONTROL (2) OPERATIONAL PROCF. DURE ON CHANGING PROCESS BAG FILTER j

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l PROCESS EQUIPMENT BEING CHANGED USING SPECIAL CONTROLS -

AFFECTED AREA WAS ROPED OFF AND PERSONNEL ON FULL FACE I

MASKS CAUSE OPERATOR ERROR - BAG FILTER NOT IMMEDIATELY PLACED IN l

PLASTIC BAG AS REQUIRED f

CORRECTIVE ACTION i

ALL OPERATIONAL PERSONNEL THAT PERFORM THIS WORK WERE I

INSTRUCTED ON WHAT RAD HAPPENED AND DIRECTED TO FOLLOW ALL g

PROCEDURES - PRACTICING GOOD RADIATION CONTROL TECHNIQUES i

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APPARENT VIOLATION 6

(3) EMPTY CANS FOUND WITHOUT REQUIRED LIDS OR LOCK RINGS SITUATION CANS OBSERVED IN SEVERAL AREAS WITHOUT LID AND/OR LOCK RING AS REQUIRED BY PROCEDURE ACTIVE PROJECT IN PLACE TO ADDRESS THIS PROBLEM BUT WORK IS NOT COMPLETE CAUSE WORKERS NOT CONSISTENTLY FOLLOWING PROCEDURES CORRECTIVE ACTION EMPRASIZE FOLLOWING PROCEDURES ACCELERATE COMPLETION OF THE PROJECT REVISE PROCEDURES AND RETRAIN TO NEW REQUIREMENTS JNVENTORY AND LEAK TESTING OF SNM SEALED SOURCESt SITUATION INTERNAL PROCEDURES REQUIRED ENRICHED URANIUM SOURCES TO BE INVENTORIED AND LEAK CHECKED EVERY THREE MONTHS FOJR URANIUM SEALED SOURCES WERE NOT CHECKED PER PROCEDURE CAUSE SOURCES WERE NOT PROPERLY ENTERED IN THE " SOURCE INVENTORY TRACKING SYSTEM" IN A TIMELY MANNER NO METHOD FOR SPECIFICALLY TRACKING A 90-DAY REQUIREMENT CORRECTIVE ACTION ESTABLISHED 6-MONTH FREQUENCY AS APPROPRIATE FOR ENRICHED URANIUM DEVELOPING AND WILL IMPLEMENT A 90-DAY TRACKING ROUTINE FOR SLURCES REQUIRING 3-MONTH INTERVALS CMV 8/27/90

6

.C PROCEDURAL COMPLIANCE ACTIONS i

ORGANIZATION AREA COORDINATORS COMPLETE ADDED RC RESOURCES RWP EMPHASIS COMPLETE COMPLIANCE FOCUS IN RC COMPLETE j

TRAINING / RADIOLOGICAL COMPLETE REPLACE P. STANSBURY COMPLETE 3

ADDRESS NEW REQUIREMENTS IN-PROCESS / PLANNING TRAININr-SPECIALIST COMPLETE EMPLOYEE INVOLVEMENT COMPLETE TRAINING INITIAL SKILLS TRAINING FOR COMPLETE AREA COORDINATORS AREA COORDINATOR FACILITATOR IN-PROCESS TRAINING AREA COORDINATOR WORKSHOP PLANNED SPECIAL EMPHASIS VIDEO ON COMPLETE COMPLIANCE ISSUES ROUNDTABLES ON-GOING CONFIGURATION CONTROL REFRESHER COMPLETE HIGH PE'1FORMANCE TEAM DEVELOPMENT COMPLETE l

PROBLEM SOLVING-COMPLETE PROGRAM LEADERSHIP COMPLETE 11-MINUTE MEETING PLANNED STAFF PLANNING AND STRATEOY WORKSHOP PLANNED l

CMV 8/27/90 1

!r Y*

PROCEDURAL COMPLIANCE ACTIONS COMMUNICATION / EMPLOYEE MOTIVATION MANAGEMENT VISIBILITY IN TRAINING CONTINUING VIDEOS l

POSITIVE DISCIPLINE SYSTEM UPDATE COMPLETE ELECTRONIC MESSAGING CENTERS COMPLETE /ON-GOING EMPLOYEE RECOGNITION RESTRUCTURE PLANNED L

EXIT CRITIQUE RESULTS COVERED IN COMPLETE /ON-GOING ROUNDTABLES PROGRAMS / PROCEDURES NRC FINDINGS FACTORED INTO RAD COMPLETE /0N-GOING COMMITTEE COMPLIANCE ISSUES MEETINGS IMPLEMENTED TRENDING / MEASUREMENTS EMPHASIS IN-PROCESS

" BIG THREE" ASPROACH CONTINUING AREA COORDINATOR ASSIGNMENT TO COMPLETE SPECIFIC ISSUES CATEGORIES SHOP PROCEDURE REVIEW PLAN COMPLETE i

PROCEDURE SIMPLIFICATION IN-PROCESS SPECIAL EMPHASIS PROD TRAINING PLANNED IMPROVEMENTS TO DATE SOME AREAS MUCH IMPROVED PROTECTIVE CLOTHING INSPECTION 89-05:

20 INSTANCES OBSERVED INSPECTION 90-03:

"THE INSPECTOR NOTED THAT WORKER COMPLIANCE WITH THE NSR/Rs GOVERNING THE USE OF PROTECTIVE CLOTHING MAD IMPROVED" INSPECTION 90-07:

"ALL PERSONS OBSERVED WERE WEARING THEIR PCs IN THE MANNER PRESCRIBED BY THE PROD" CMV 8/27/90 1

~:

' i.

PROCEDURAL COMPLIANCE ACTIONS i

1 o

IMPROVEMENTS TO DATE - CONTINUED TIME CLOCK / BREAK AREA OVERCHECKS IMPROVEMENT OVER 1989 SHOP CLEANLINESS / VISIBLE CONTAMINATION INSPECTION 89-05:

VISIBLE CONTAMINATION IN MULTIPLE AREAS INSPECTION 90-03:

"THE INSPECTOR NOTED THAT THERE HAD BEEN A GREAT IMPROVEMENT IN THE PHYSICAL CLEANLINESS OF THE FACILITY AND IN GENERAL HOUSEKEEPING" INSPECTION 90-07:

" CONTIN 0ED MAINTENANCE OF FACILITY CLEANLINESS AND UPGRADED HOUSEKEEPING WERE NOTED" SOME AREAS IMPROVED BUT NEED CONTINUED EMPHASIS EMPTY CAN STORAGE INSPECTION 89-05:

24 CANS OBSERVED INSPECTION 90-07:

4 CANS OBSERVED OUR TRACKING SHOWS 85% REDUCTION IN OBSERVATIONS MASK STORAGE INSPECTION 89-05:

13 MASKS OBSERVED INSPECTION 90-03:

4 MASKS OBSERVED INSPECTION 90-07:

1 MASK OBSERVED

~

OUR TRACKING-SHOWS 50% REDUCTION IN OBSERVATIONS POSTING OF AREAS INSPECTION 89-05:

MULTIPLE AREAS INSPECTION 90-03/90-07:

1 SIGN EACH OUR SELF-AUDITS SHOW IMPROVEMENT ADDITIONAL EFFORT / CONTINUED EMPHASIS NECESSARY'TO MEET GOAL CMV 8/27/90 f

1 i/

[.,....

4

.q, e

l CONCLUSIONS t.

PROCEDURAL CONFORMANCE WAS IDENTIFIED AS A VERY COMPLEX ISSUE IN EARLIER DISCUSSIONS WITH NRC REinocNS I

OUR PROGRAM FOR UPGRADING CONFORMANCE @ ON SLHEDULE PER PREVIOUS NRC DISCUSSIONS MANAGEMENT IS COMMITTED TO HAVING PROCEDURAL CONFORMANCE THROUGHOUT OUR WORK FORCE AND WE HAVE BEEN DILIGENTLY WORKING l

TOWARD THAT END l

PROCEDURAL COMPLIANCE IS MEASURABLY BETTER THAN..* WAS AT THE

=BEGINNING OF THE YEAR j

i i

BOTH OUR PROGRAMS INDICATE INCREMENTAL IMPROVEMENT i

1 i

l CMV S/27/90 t

I c.c e

• APPARENT VIOLATION 8

VIOLATION 70-1113/90-07-08 FAILURE TO PROVIDE EXCLUSIVE USE VEHICLE INSTRUCTIONS TO DRIVERS IN ACCORDANCE WITH 49 CFR 173.425 (b) (9) REQUIREMENTS (PARAGRAPH 10).

VIOLATION OF 10 CFR 71.5 REQUIREMENTS.

SITUATION OUR PRACTICE CHANGED EARLIER IN YEAR PREVIOUSLY INSTRUCTIONS WERE ON BILL-OF-LADING BILL-OF-LADING IS SPECIFIED TO BE KEPT IN SHIPPING FILE CHANGE WAS TO HIGHLIGHT THE VISIBILITY OF THE INSTRUCTIONS INSTRUCTION SHEETS DID NOT REQUIRE RETENTION OF EXCLUSIVE USE INSTRUCTIONS IN OUR FILES

.e WE COULD NOT SATISFY THE INSPECTOR THAT WE HAD PROVIDED THE INSTRUCTIONS TO THE DRIVER CAUSE-1 UNABLE TO QUICKLY DEMONSTRATE COMPLIANCE.

DIDN'T INTERPRET THAT 49 CFR 17 3.425 (b) (9) APPLIED TO OUR FILES FAILED TO ADD THE ACTION ITEM TO OUR INSTRUCTIONS WHEN THE CHANGE WAS.MADE j

FAILED TO ADDRESS DEMONSTRATING COMPLIANCE WHEN THE CHANGE WAS 1

MADE j

i CORRECTIVE ACTION OBTAINED DEMONSTRATION WE' COMPLIED ON THE THREE SHIPMENTS IN QUESTION-D i

UPDATED-OUR INSTRUCTIONS TO INCLUDE THE REQUIREMENTS FOR l

RETAINING INFORMATION TO DEMONSTRATE COMPLIANCE l

. VERIFYING'AND' UPDATING FILES FOR ANY OTHER SHIPMENTS SINCE THE j

CHANGE e

REVIEWED WITH WORKERS THE CHANGE TO THE INSTRUCTION AND-FORMS l

CMV 8/27/90 I

J

.s 77 3

t' 4

1 b;

SUMMARY

APPRECIATE VERY MUCH THE OPPORTUNITY TO DISCUSS THESE APPARENT

[

VIOLATIONS BEFORE A NOTICE OF VIOLATION ISSUED i

L GE MANAGEMENT IS CONCERNED BY THE LFVEL AND NATURE OF THE APPARENT VIOLATIONS DISCUSSED HERE o

I I

AN EXTREMELY HIGH PRIORITY AND-LEVEL OF EFFORT HAS BEEN APPLIED TO INVESTIGATE AND CORRECT THEM i

WE ARE ALSO VERY CONCERNED ABOUT OUR LONG-TERM COMPLIANCE l

RECORD AND TAKE COMPLIANCE VERY SERIOUSLY UPON DETAILED INVESTIGATION, THE SIGNIFICANCE OF A NUMBER OF THE APPARENT VIOLATIONS DOES NOT APPEAR AS HIGH AS INITIALLY BELIEVED, BUT THERE IS WORK TO BE DONE' PROCEDURAL CONFORMANCE WAS THE SUBJECT OF PREVIOUS MANAGEMENT MEETINGS AND WAS TARGETED FOR IMPROVEMENT BY END 1990 WE ARE MOVING AHEAD AND MAKING INCREMENTAL IMPROVEMENT i

E CMV. 8/27/90