ML20127K038
| ML20127K038 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/05/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127J983 | List: |
| References | |
| NUDOCS 8505220020 | |
| Download: ML20127K038 (9) | |
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.S GENERAL $ ELECTRIC
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v WILMINGTON MANUFACTUMNG DEPARTMENT GENERAL ELECTRIC COMIMNY + P.O. POX 780
- WILMINGTON, NORTH CAROUNA 28402 35 APa 12: n 9: 3 7
'y April 5,.198F Mr. _ J. - Philip ' Stchr,: Di' 'ector r
Division of Radiation Safety &-Safeguards
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U.S. Ndclear Regulatory Commission, RII-
-101;Marietta Street, NW --Suite 2900
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. Atlanta, Georgia-30303
Dear.Mr. Stohr:
Reference': ' (l)' NRC License SNM-1097, Docket #70-1113 (2) NRC Inspection Report 70-1113/84-17 dated.1/31/85,-receized 2/5/85 (3) Letter, CM Vaughan to JP Stohr, 3/1/85 On March.1, 1985; in the General Electric Company response to.the report of-. an ' inspection _ conducted at our licensed. fuel-fabrication plant by Mr. C. M. Hosey of your. office on November. 27-30,.1984, GE-NFMD requested ' thatithe first. item' of apparent noncompliance be
- held.in / abeyance pending a management. meeting on' 3/13/85 with the NRC in. Atlanta.. As committed during that meeting, GE hereby responds to the subject; item.as an-attachment to this letter.
Inyour letter'of January 31, 1985, you also indicated a concern
- regarding the -implementation of our-radiation protection program.
Generalz)lectric.does not concur'with~your' assessment and, in fact,:the Severity Level IV and Severity Level V violations also do not support any concernLfor the implementation.of these programs.
-General-Electric does~ agree that a perception.has been created
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that our Chemet Laboratory radiation protection program is not as soundLas it actually is.- This is the result of the extensive amount' of inspection effort applied in the _ Chemet Laboratory, the
' fact:that. allegations regarding our, operations have received
-extensive'public attention, and ' the manner in which these allegations have been investigated.
General Electric.has; however, applied considerable attention to the radiation protection' program as it relates to the Chemet
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. Laboratory and,-in fact,-taken a number _of steps to make changes
.and improvements in that program.
We are also continuing to look at other necessary-upgrades-to our radiation safety practices as SW"*AB82M3dA C
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GENERAL $ ELECTRIC Mr. J. Philip Stohr April 5, 1985 Page 2 we have consistently done during our years of operation.
Most recently the actions that we have taken related to the Chemet Laboratory are as follows:
o An all laboratory employee meeting-were conducted to discuss
_ Company and employee obligations in the_ radiation safety to review the radiation exposure history for those
- program, workers and to answer questions.
o Routine contamination surveys have been temporarily increased in the Chemet Laboratory to three times per week to provide an additional experience base for decision making.
The number of locations tested for fixed and removable o
radiation during routine surveys have been temporarily increased.
Selected procedures have been reworded to provide clarity in o.the requirements of the radiation protection program as applied to the Chemet Laboratory.
Increased emphasis has been placed on minimizing external o
contamination of sample containers submitted to the laboratory.
Laboratory personnel have been supplied with a go/no-go survey o -meter to augment their ability in cleaning spills immediately.
The titration hood has been installed _andfis operational as o
was committed'in the closecut meeting.
The lighting improvement for the bulletin board has been o
installed as was committed in the closecut meeting.
' Signs have been posted at the exits specifying the survey o
requirement of personal articles removed from the controlled area.
General Electric appreciates 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
GENERAL h ELECTRIC-Mr. J.-Philip Stohr April 5, 1985 Page 3 the NRC regulations and license conditions.
We also welcome
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further discussion with.your staff on our reply, as neccessary,-
for further clarification.
Very truly yours, GENERAL ELECTRIC COMPANY flaAu4W.
auyL Charles M. Vaughan, Manager l-Regulatory Compliance M/C J26 l
CMV:bsd Attachment-NSD-I I
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l GENER AL $ ELECTRIC Mr..J.. Philip Stohr April 5,.1985 Attachment - Page 1 ATTACHMENT
-The information given below is in response the first item of apparent. noncompliance listed in 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).
General Electric Company' denies this alleged violation in that
" suitable" raeasurements of concentrations of radioactive materials in air were and are being taken in the Chemet Lab per 10 CFR 20.103.
Section 20.103(a)(3) states, in part:
"For purposes of determining compliance with the
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requirements of this section, (i.e., 40 MPC-hrs /wk and
'520 MPC-hrs /qtr), the licensee shall use suitable
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GENERAL $ ELECTRIC
. Mr. J. Philip Stohr April'5, 1985:
Attachment Page 2 measurements of concentrations of radioactive materials in' air for-detecting and evaluating airborne radioactivity in restricted areas and in addition, as
. appropriate, shall use measurements of radioactivity in the body or any combination of such measurements as may be necessary...".
Two stationary air samplers are located in the Chemet Lab, one in the-Wet Lab near the isotopic balance and one in the Spectrometer Lab near the metal impurities hood.
Both are general work area
. samplers and are changed on an eight hour frequency per standard practice.
Weekly averages of the Wet Lab results for 1979-1984 are shown in the attached figure.
Slightly increasing trends _can be noticed in the years.1980 and 1981 with concentrations rising to 5%.of the MPC for insoluble uranium.
An investigation indicated that improvements to the Wet Lab air handling and distribution system were warranted.
Such improvements were made in-late 1981.
Since that time, air concentrations in the Lab have averaged about 2% of the MPC for insoluble uranium.
Routine urinalysis and lung counting of Chemet Lab employees demonstrate that the workers are not continuously exposed to 3 unmeasured concentrations of uranium.
Only 2% (~20'out of 1000) of the' routine urinalysis esults submitted by Chemet personnel in 1983 and 1984 were greater than 10 pg/ liter.
The minimum reported sensitivity-for the laser fluorimetric assay is 5 pg of uranium per liter.
During 1983 and 1984 approximately 104 of the urine samples had results above the minimum sensitivity.
If these results.were caused by events generating significant airborne contamination, one would expect positive results for different individuals to be correlated in time.
Samples by Chemet personnel are submitted at the end of the work week.
However, since tne Chemet Lab is a four-shift operation, the end of the week is not always Friday.
Therefore, to perform temporel analyses, any positive results for different individuals that. occurred within two days of each other (i.e., a~3-day window) were considered as a group.
The results of such group analysis are presented below:
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s GENERAt $ ELEM Mr. J. Philip Stohr April 5,.1985 Attachment - Page 3 Random Occurrences of Occurrence Positive Results Prediction
- Singularly 24 38 Paired 20 19 Three Together 7
6.4 Four Together 1
1.5 Five~Together 1
0.3
-*Using a Poisson distribution with a mean of 1.0 since 104 positive results occurred in 104 weeks.
'Thus,the pairing ~or grouping of results is less than or equal to-Lthe-pairing or grouping that would be expected if the positive results were created by chance forces alone.
There is a distinct lack of indication that employees are being exposed to large
" puffs" of airborne 1 radiation which would be expected to affect the results of two or more workers at the same time.
In fact, the positive results have a statistical distribution very similar to the occurrence of " false positive" results that would be expected to show values just above the lower limit of detection of the laser fluorometric technique.
In the.past two years, only one individual has had a result greater than 15 pg/ liter, the NFMD action guide requiring assessment of intake.
This individual's calculated intake was 0.46 mg, far less than the 2.7 mg daily intake limit for soluble-uranium recommended in WASH-1251.
For the period of' January 1982 to January 1985, routine lung counts-(145 counts taken on 53 Chemet Lab workers) indicate that two individuals had results greater than MDL (75 pg U 235).
Both were recounted the following quarter and had results less than MDL.
An additional individual had a lung count greater than MDL.
~However, this exposure was received in an area other than the Wet Lab.
Lung counts are recognized as not being sensitive enough to confirm eight hour SAS measurements.
However, the collection of results does-show that workers are not being chronically exposed to unmeasured levels of insoluble airborne uranium which would build up in their lungs over time.
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sa GENERAL $ ELECTRIC ME. J. Philip Stohr
' April 5, 1985 Attachment - Page 4 After being' informed at the NRC exit interview on 11/30/84 that the inspector-intended to issue a notice of violation, General Electric initiated a special study as an overcheck of our air sampling program.
Two-additional air' samplers were installed'at strategic locations within the Wet Lab.: To date, approximately
'1000 eight-hour air samples have been: collected.
All of the weekly average _ air sample results have been i l'x 10-12 pCi/cc.
-A comparison'of results of the additional samplers.(SAS 404 and
.SASf405) withithe existing sampler-(SAS 400)-is shown below.
This comparison indicates that_previously reported concentrations are
-representative of those.to which workers may be exposed in the Lab and easily demonstrate _ compliance-to 10 CFR 20.103.
WEEKLY AIR SAMPLE AVERAGES 21 Samples / Week.(3/ Day, 7 Days / Week) x 10-11 pCi/cc SAS 400 SAS 404 SAS 405 (Existing)
(New)
'(New)
FW 49-84 0.1 0.1 0.1 FW 50 0.1 0.1 0.1 FW 51 0.1 0.1
O.1 0.0 0.1 FW 03 0.0 0.0 0.1 FW 04 0.1 0.1 0.1 FW 05 0.1 0.1 10. 1 FW 06 0.1 0.0 0.1 FW 07 0.1 0.0 0.1 FW 08 0.1 0.0 0.1 FW 09 0.1 0.0 0.0 FW 10 0.1 0.0 0.0 FW 11 0.1 0.0 0.1 FW 12 0.1 0.0 0.0 FW 13 0.1 0.0 0.0 t
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GENERAL $ ELECTRIC Mr._J. Philip Stohr-April.5, 1985 Attachment - Page 5 In addition,Jan engineering evaluation of Chemet Lab air flow
- patterns was-performed on December 3, 1984.
Beside demonstrating
' that the two special samplers used for the study were properly located, these tests showed that significant horizontal dispersion occurs above the seven foot level as the air handling system rapidly cleared the-_ test smoke from the area.
Clearly, air concentration measurements taken in the Lab have been
~ " suitable" for determining compliance for exposure of individuals
- t<o concentrations of radioactive materials in air in the restricted area per 10.CFR 20.103.
Therefore, following review of
. the preceding.information, General-Electric requests that the NRC withdraw the alleged violation.
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. 4 4-o GENERAL $ ELECTRIC Mr. J. Philip ~Stohr April 5, 1985 Attachment - Page 6 WEEKLY AVERAGES - WET LAB (21 SHIFTS)
Weekly Rverages for th'e ' Wet Lab' (21 shifts) 8 1.0 x
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.8 G
3
.7 m
8
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.5 e
0
.4 8"
.3 E
.2 E
.1 E_
0.0
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1979 1980 19R1 1982 1583 1984
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