ML20127K015
| ML20127K015 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/01/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127J983 | List: |
| References | |
| NUDOCS 8505220014 | |
| Download: ML20127K015 (4) | |
Text
F J: /,.5 To424 f.L/
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y GENERAL $ ELECTRIC WludNGTON QUFACTURING DEPARTMENT GENERAL C
j ltO2 KM 780.WILMINGTON, NORTH CAROUNA 28402 0
March 1, 1985 Mr. J.. Philip Stohr, Director Division of Radiation Safety & Safeguards U.S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia 30303
Dear Mr. Stohr:
Reference:
(1) NRC License SNM-1097, Docket #70-1113' (2) NRC Inspection Report 70-1113/84-17 dated 1/31/85, received 2/5/85 Thank you for your letter reporting the resulta of the inspection conductedHat our licensed fuel fabrication plan? by Mr. C. M. Hosey of your office on November 27-30, 1984.
With regard to the - first item of apparent noncompliance and the
. generally stated concern about the implementation of the NFMD radiation protection program, General Electric has requested a management meeting to discuss the issues prior to responding in writing.
This approach was determined to be acceptable via a telephone conversion with Mr. E. J. McAlpine on 3/1/85.
The meeting is currently scheduled for the morning of March 13, 1985, in Atlanta.
Pertaining to the second 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 public and employee health and safety.
These comments and suggestions are helpful to us in our constant efforts to improve these programs, and ensure our compliance with NRC regulations and license conditions.
We also welcome further discussion with your staff on the items in your letter and in our related reply, as necessary, for further clarification.
Your inspection report referred to above does not contain information which we believe to be proprietary.
Sincerely, GEMERAL ELECTRIC COMPANY W-O 13 PDR Charles M. Vaughan, Manager Regulatory Compliance M/C J26
/sbm hhhaphment
m GENERAL $ ELECTRIC I Mr. J. Philip Stbhr-
. March 1, 1985-
' Attachment'- Page 1
- e ATTACHMENT-The informatibn given belowlis in response to NRC Inspection Report-70-1113/84-17, " Notice of_ Violation - Enclosure 1",
dated 1/31/85 ~..
.1.-
10 CFR 20.103(a)(3) requires the licensee to use suitable measurements of.
concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.
Contrary to the above, the licensee failed to use suitable measurements of concentrations of radioactive material in air-in that-air samplers _in the Chemet Laboratory were not_ located where the sample collected would be representative of airborne radioactivity concentrations breathed by the workers in the laboratory.
This condition existed on the date of the
~ inspection and was believed to have existed from early 1984 to November 30, 1984. :The Chemet Laboratory is a restricted area.
This is a Severity Level IV violation (Supplement IV).
The General Electric Company written response to this-item is-being withheld pending the completion of a GE requested management meeting with the US-NRC Reaion II which is currently scheduled for March 13, 1985, in Atlanta.
2.
10 CFR 20.408(b) requires that when an individual terminates employment, the.
licensee shall furnish the NRC with a report of the individual's radiation exposure within 30 days after the exposure of the individual has been determined.
-contrary to the above, the NRC was not furnished a termination exposure report
l 4
l G EN ER Alll% ELECTRIC
" Mr. J. Philip Stohr
. March 1, 1985
]
Attachment - Page 2 within the 30 day limit in that a worker d
terminated employment on July 26, 1984, the individual's exposure was determined on July 17, 1984 and the exposure report was ' furnished to the NRC on October 19, 1984.
This is a Severity Level V violation (Supplement IV).
General Electric Company concurs with the violation as stated above.
Nine days prior to. termination,-the subject individual requested and received a copy of their exposure history within the 30-day reporting time limit required by 10 CFR 19.13(b).
When the individual terminated employment with General Electric on 7/26/84, the report furnished to the employee on 7/17/84 was not considered to be a final determination of exposure pursuant to 10 -
CFR 20.408(b) as the employee had the potential for further exposure / monitoring during the nine day time period between the
, requested report and termination.
It is a rare occurrence that a
~
person _will request an exposure _ history just prior to termination and.not have any additional exposure, an outstanding badge _ result,-
or a final-whole body count before termination.
However, this was
~
not the~ case-with the subject individual:
the employee had no additional exposure or monitoring.
- Since.the NRC deemed the 7/17/84 employee requested report as a
' final determination, pursuant to 10 CFR 20.408(b) the termination exposure report was required within 30 days of termination (i.e.,
30 days from 7/26/84).
However, as GE-NFMD did not consider the 7/17/84 report as a final determination, within 90 days of termination a final determination of exposure was compiled and a termination exposure report furnished pursuant to 10 CFR 20.408(b).
In an effort'to avoid future conflicts of this nature and as part of the on-going effort by GE-NFMD to upgrade ' compliance programs, GE-NFMD has fully implemented a computerized termination dose reporting program (as of year-end 1984) to provide termination reports as soon as the final monitoring information is available.
As a result, if an individual's exposure ends several months prior
c GENERAL $ ELECTRIC
- Mr. J. Philip Stohr March 1, 1985
' Attachment - Page 3
-to termination and all items necessary to make a final
. determination are available, a termination dose report will now be generated within 30 days of the termination date.
As-this was an isolated ^ incident and as a different termination reporting routine has.been implemented, General Electric is now in full compliance.:
r
- o.,
CM Vaughan
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