Text

Supplemental Petition Under 10CFR2.206 for Withdrawal of Insp Repts 70-1113/84-17 & 70-1113/84-18,Chapter 2 Re Alleged Violations at GE Wilmington,Nc Nuclear Manufacturing Plant
	ML20132C972
Person / Time
Site:	07001113
Issue date:	03/12/1985
From:	Ratner M; RATNER, M.G.
To:	; NRC
Shared Package
ML20132C968	List: IA-85-208, Insp Rept 70-1113/84-16 on 841127-30 & 850114-16.Violation Noted:Failure to Investigate & Take Corrective Action When Control Stds Limits Exceeded; ML20132C963; ML20132C972; ML20133L544; ML20133L556; ML20133L563; ML20133L592; ML20133L633; ML20133L655;
References
	FOIA-85-208 NUDOCS 8505020153
	Download: ML20132C972 (44)
	v • d • e

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BEFORE THE NUCLEAR REGULATORY COMMISSION Vera M. English NRC Inspection Reports Nos.

and 70-1113/82-18 General Electric Company 70-1113/84-04 70-1113/84-05 70-1113/84-08 70-1113/84-13 70-1113/84-15 70-1113/84-16 70-1113/84-17 70-1113/84-18 SUPPLEMENTAL PETITION UNDER 10 CFR S 2.206 FOR WITHDRAWAL OF REPORTS 84-17 and 84-18, ISSUED JANUARY 18, 1985; 82-18, ISSUED SEPTEMBER 27, 1982; 84-04, ISSUED AUGUST 23, 1984; 84-05, ISSUED MAY 9, 1984; 84-08, ISSUED JULY 19, 1984; 85-10, ISSUED JULY 27, 1984; 84-13, ISSUED NOVEMBER 15, 1984; 84-15, ISSUED FEBRUARY 7, 1985; 84-16, ISSUED FEBRUARY 13, 1985; ISSUANCE OF NEW REPORTS CORRECTLY DOCUMENTING AND FINDING ALLEGED VIOLATIONS AT THE G.E. WILMINGTON, N.C.

NUCLEAR MANUFACTURING PLANT; ISSUANCE OF NOTICE OF VIOLATION ON ALL SUBSTANTIATED ALLEGATIONS, ASSIGNMENT OF APPROPRIATE SEVERITY LEVELS TO EACH FOUND VIOLATION, AND TO ALL VIOLATIONS COF3IDERED AS A WHOLE; AND COMMENCEMENT BY NRC OF APPROPRIATE ENFORCEMENT ACTION, INCLUDING THE ASSESSMENT OF CIVIL PENALTIES CHAPTER II J.

The Inspector's Findings In 84-17 (h),

p. 7, That " Marking Off Contaminated Areas Is Not Required By NRC Regulations, License Conditions or Licensee Procedures" Is Predicated Solely Upon G.E.'s Misrepre-sentation To The Inspector Since submission of Chapter I, G.E.

has filed in Case No. 85-ERA-2, a motion to dismiss or for summary judgment j

based up n the Inspector's finding quoted and refuted in Chapter,I, par. G, pp. 22-23.

G.E. Motion, filed March 5, 1985, p.

11, n.

18.

G.E.'s misrepresentation to the Inspector, i

fEhDN

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4 upon which he necessarily relied in making his finding, was made during the investigation on November 27-30, 1984.

General Manager Lees was first confronted with the documents quoted at pp. 22-23 of Chapter I on December 15, 1984.

He then admitted, under oath, that the " Criticality Safety Control Chemet Lab,"

(Exh. 3a in 85-ERA-2) is an authentic company instruction issued to employees (Lees' Dep

p. 24), but claimed that he had never seen it before!

(Id.)

Such instructions are required by G.E.'s license.

(Rept. No. 84-10, p.

3, par. 8(a) (last three lines), p.

4, par.

9, penultimate sentence).

Lees also claimed that he could not authenticate the

" Hourly Course Outline" (Exh. 3b, Lees' Dep., p.

25).

But nuclear safety training is required by 10 CFR Part 19 (Rept.

No. 84-13, p. 5, par. 7), and by G.E.'s license.

Rept. No.

84-10, p. 3, par. 7; p. 4, par. 9.

G.E.

has yet to produce a scintilla of evidence that Exh. 3(c) (temporarily rejected for want of adequate foundation) is not authentic.

Having been caught in the lie that G.E.'s instructions to employees do not provide for roping off or otherwise marking uranium spills and areas contaminated by others, G.E.

invokes the Inspector's finding to assert (Motion, p.

11, n.

18), that "the only proper action an employee must take if he or she observes a spill of radioactive material * *

is to immediately clean it up * * *."

Thus, G.E.

uses the Inspector's false finding, predicated on G.E.'s own misrepresentation to the Inspector, to disprove the truth! l l

a

s G.E.'s argument is not only falsely premised in fact, but utterly absurd in law, since it would require " whistle blowers" to destroy the hard evide'nce of management's violation of nuclear safety regulations which management constantly demanded that Mrs. English produce to substantiate her charges, and without which NRC inspectors would, as their reports amply show, make no finding in her favor.

If G.E.'s argument were valid, the whistle-blower would have a choice only between two intolerable alternatives -- (1) destroy the proof of management's violations, about which the law gives her the right, without discrimination or reprisal, to complain to NRC and to support her charges by producing evidence, or obtaining and preserving hard evidence, at the expense of losing her statutory protection.

If these were the only alternatives, G.E.

would have discovered a loophole which enables it to violace both the safety requirements of the law and the

" employee protection" provisions with impunity.

K.

The Inspector's Conclusion, 84-17 (d)

(pp. 4-5) That Th'ere Was No Violation In Requiring Lab Employees To Accept Visibly Contaminated Sample Vials and Paperwork Into The Lab Is Patently False Once again, the Inspector's report is fatally defective in that it fails to recognize G.E.'s ALARA obligation.

It is also defective'in that it fails to recognize that Condition 9, Appendix A, Sec. 4.1, of G.E.'s license, binds'GfE. by law to all " written operating procedures."

Rept.

No. 81-11, issued Oct. 26, 1981, p. 5, par. d(1) (first two

(.i e

s sentences); Rept. No. 84-04, " Notice of Violation," first two e

sentences, p. 5, par. 13.

G.E. 's written safety procedures and practices impose on all submitters of vials and paperwork to the lab the duty to clean " visible contamination" from vials and paperwork before leaving them to be picked up by lab employees.

(App. A hereto, Nuclear Safety Rules B, 14, issued 4/27/78).

Report No. 84-15,

p. 9, c.(3), finds that G.E.'s " approved procedures" require that "(c) equipment must be wiped clean of visiblar contamination."

Report No. 84-04, p. 7, second par., last sentence, finds that " Samples received from the production area for analysis were * *

found to have external contamination on the containers."

Had the Inspector in 84-17 not been blinded by G.E.'s misrepresentations, he might have recognized the distinction drawn by G.E.

in its operating procedures between "presumaoly contaminated" and " visibly contaminated."

The Inspector, however, bought G.E's purely diversionary argument that because precautionary measures were required of Chemet Lab employees, there was no violation in management's l

allowing submitters to leave " visibly contaminated" vials and paperwork for lab employees to pick up and handle, and in 1

requiring Chemet Lab employees to accept and handle such materials.

Of course, that is a complete non-sequitur.

l J,u,st how bad this Report is can be judged from the fact t

l that, 'tMb weeks af ter its exoneration of G.E.

from Mrs.

l English's charge, Chemet Lab Manager Winslow, on February 19, i

~~

1985, issued a notice to all "Submitters of U-Samples to Chemet Lab" stating that:

"To effectively meet radiation safety guidelines in the Chemet Lab," vials and paperwork which "show evidence of excessive or accumulated exterior contarination cannot be accepted."

(App.

B, infra).

L.

The Inspector's Finding, p. 5, That Allegation (e) "Could Not Be Substantiated" Results From The Inspector's Misrepresenta-tion Of The Allegation The Inspector was able to dismiss this J

j-allegation only by misrepresenting it.

Mrs. English had actually charged that her work table top and legs, and the floor of her work area, were repeatedly contaminated by Chemet test operators on the prior shift, either " deliberately," or "being sloppy" or "didn't care," and that " management was condoning this."

The Inspector misrepresented this charge by confining it to " deliberate" contamination, and addressed himself only to that.

Mrs. English herself had refused so to restrict the charge, recognizing that " deliberateness" could l

not be proved.

The Inspector's " discussion" of this incident is, therefore, entirely beside the point.

He asked the wrong questions and, not surprisingly, got answers unresponsive to I

the true allegation.

Under Mrs. English's actual charge, whether the work bench surface, legs and floor were contaminated by the prior shift, deliberately, or willfully, or accidentally, is utterly t

irrelevant.

The only relevant fact is that when Mrs. English !.

arrived at work she repeatedly found her work place contaminated.

The penultimate sentence in the " discussion,"

about an individual other than Mrs. English having used poor work practices which resulted in contamination of Mrs.

English's work area, is substantiated by at least three witnesses.

Yet, management did nothing about the workers on the prior shift who were doing the contaminating.

The statement of "two witnesses" referred to in the preceding sentence is patently incredible on its face, since, admittedly there were no eye witnesses to Mrs. English's alleged " spill."

Did the Inspector even ask these so-called

" witnesses" how they " knew"?

In short, the " specific cause" of the contamination of which Mrs. English complained could have been conclusively determined; indeed, employee witnesses identified the guilty individuals to the Inspector.

On the facts known to the Inspector, the violation alleged was proven beyond possibility of doubt.

M.

The Inspector's Finding (a), pp. 2-3, That Management Did Not Discourage Employees From Answering Questions of NRC Inspectors Is Erroneous The Inspector found (p. 2), that one employee (obviously Mrs. English) "did state that [her) supervisor once told [her] to refer NRC inspectors to the supervisor if they hadan.y[g'uestions."

That finding contrasts with the finding in Rept. No. 84-16, p. 4, 3a (3), that "Two of the twelve l

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technicians interviewed indicated that they were told to refer any questions asked of them by NRC inspectors to their supervisors * * *."

Both findings sustain the allegation of

" discouragement."

If instructions to refer NRC investigators' questions to supervision is not " discouragement" of free and full discussion by employees with inspectors, what is it?

Mrs.

English was known by every member of management and every worker in the Chemet Lab to be the person most concerned and most knowledgeable about uranium safety hazards and violations of safety practices and procedures.

Other Chemet Lab employees were neither as knowledgeable or as safety-concerned as she.

It is, therefore, not surprising that she (and one other potential " subversive," as management characterized Mrs. English, App. C, infra) were the only ones management may have felt compelled to " discourage."

The In=pectut chv== to overlook this obvious fact.

Yet he does not articulately discredit Mrs.

English or state any possible reason he might have for doing so.

The 84-17 Inspector states that he interviewed a total of twelve Chemet Lab technicians, test operators and first-line supervisors, in this connection.

How many were rank and file employees and how many supervisors he does not say.

The 84-16 Inspector interviewed " twelve laboratory technicians."

(p. 4, f.

par. (3)), and found two, not one.

Moreover, the 84-17 Inspector asked the wrong question, "whether or not they had been advised or told not to talk to l

'A NRC inspectors."

That was not what Mrs. English claimed she had been told.

The 84-16 Inspector asked the right question and got the answer that what Mrs. English and another technician were told was " discouragement."

84-16, p. 4, par (3).

Nevertheless, incredibly, even the 84-16 Inspector found "no violations."

N.

The 84-17 Inspector's Finding (b), p. 3),

That the Posting Allegation, Although

" Partially Substantiated," Is Not A Violation, Is Factually and Legally In Error The Inspector's assertion that "the documents required by 10 CFR S 19.11 were conspicuously posted," upon which his dismissal of this allegation was based, overlooks (1) that some of the items required to be posted by 5 19.11(a),

were never posted, e.g.,

Parts 19 and 20 of 10 CFR; "the license, license conditions, or documents incorporated into a liceu== Ly reference and amendments thereto," and "any response from the licensee to any notices of violation involving radiological working conditions."

What was " posted" was enclosed in a plexiglass covered bulletin board located at the gateway to the walk to the Chemet Lab, at least 500 yards away from the entrance to the Lab building, instead of at the entrance to each controlled area (84-17, pp. 10-11).

The single bulletin board was observable by Chemet Lab employees only on their way to and from work, at a time i

when hondes of employees congested at the gateway (id.), and everyone was in a hurry to punch in or get home.

Any employee who stopped to look at what was on that bulletin board rendered himself or herself conspicuous and subject to hostile surveillance by the ever present G.E.

uniformed guard.

The whole point of the $ 19.11(a) " conspicuous" posting requirement is that employees shall be able to " observe" the posted documents.

Webster's Third New International Dictionary, unabridged (1965), p.

1558, defines " observe" as "5: to see or sense, especially through directed, careful, analytic

~

attention."

Obviously, no employee could " observe," in this sense, the multi-page documents, which $ 19.11(a) and (c) requires the employer to " post," enclosed tightly as they were in the plexiglass-covered case.

If all that 5 19.11 required was that employers post " conspicuously" so as to permit employees to i

" observe" that the employer has complied with the posting requirement, and not to enable employees to read and study the posted documents, the requirement would be ludicrous and self-defeating.

Fortunately, that construction is foreclosed,by l

$ 19.11(b), which specifies that "(i]f posting of a document specified in (a)(1)(2) or (3) of this section is not practicable, the licensee may post a notice which describes the l

document and states where it may be examined."

(Emphasis i

added.)

In short, the object of posting is to enable employees to exam 6ne the specified documents, not merely to ascertain that the employer has " posted" them.

Since study and analysis s

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of multi-page documents " posted within a plexiglass covered bulletin board is not a " practical" means to accomplish the purpose of $ 19.11(a) and (d), G.E. was legally required at least to post a " conspicuous" notice in compliance with (b).

i This G.E.

did not do, and this is, in itself, a most serious l

violation.

j The details to which the Inspector confined himself exclusively simply compound this real basic violation.

The Inspector found the " postings [were] less accesstele than in f

the past."

Apparently, he did not even require what past practice was ano why it was changed, although the effect of the, 1

change was to diminish the employees' right to know, which the j

Act protects.

He treated minimal compliance with the literal i

text as fully satisfying the employer's legal obligation.

e This, as we have seen, he had no legal right to do.

Moreover, the Inspector by implication found that even j

the portions of the documents visible through the plexiglass l

were barely legible during the night hours (when Mrs. English j

worked) without improved lighting.

Instead of finding this a I

violation, the Inspector " advised" management to " install i

better lighting," as if that would wipe out management's current and past violations.

O.

The Inspector's Conclusion (c), pp. 3-4, l

That Dumping Uranium Powder Outside Hoods Is Not A Violation Is Utterly Untenble o.-

Whether or not some workers develop or aggravate a

l sinus conditions as a result of dumping uranium powder outside

! l

_ _-.__..._.._.__... _ _,_ ~._._,

hoods, the practice is a flagrant violation of G.E.

nuclear safety practices, by which G.E.

is legally bound, and, as such, should have been found unlawful by the Inspector.

Sources cited, Chapter I, pp. 24-26, and appended thereto.

We requote one.

Rad Safety, Lab Operating Procedures, App.

D, hereto, 3, H,

issued April 3, 1973, provides, p. 2:

"H.

All compounds of uranium that could become airborne shall be handled inside of hoods with air flow of 80-120 LFM through the apertures.

Examples of this is (1) Opening of powder sample containers (2) Crushing of pellets, weighing, etc., (3) Dumping and compositing samples for return to Shop Operations, (4) Dissolution and concentration of uranium samples by heating."

P.

The 84-17 Inspector's Conclusion That G.E.

Did Not Violate Procedures By Having

" Dichromate Titrations Done In The Open and Not Under A Vented Hood"

((i), pp. 8-9) Is False We showed in Chapter I, pp. 27-29, that the inspector's conclusion that G.E. did not violate procedure by having dichromate titrations performed outside vented hoods is legally untenable.

G.E. management guided the Inspector to one document which happens not to specify that such titrations must be done under a hood.

Cf. authorities cited in "O" above.

He then swallowed G.E.'s untenable thesis that without such precise specification there can be no violation, as if ALARA did not exist.

The 84-17 Inspector's finding (p. 9) that the fumes released by dichromate titrations outside the hood do not materially increase "the radiological hazards of working at 11

this station" relies entirely on " radiological contamination surveys performed by the licensee in 1984, [which] did not identify contamination above the action level at this station."

But elsewhere in his same Report, pp. 17-18, the Inspector finds correctly that G.E.'s radiological contamination surveys for this station during 1984 are utterly unreliable, because the single monitor was geographically far removed from the work station in question and was seven feet off the floor (at least four feet above the level of the work station), so that the surveys were literally worthless!

Moreover, the Inspector also found (id., p.

13, first par.) that G.E.

uses airborne exposure.

values derived "from the time spent in the work area" and " air concentration measured in the work area," to " calculate the internal dose assigned to the individual."

That system could not produce results relevant to contamination "at the [ work]

station."

Further, the Inspector ignored the findings of Rept. No.

81-11, p. 2, par. 4(a), that G.E.'s air sampling system "could

[ sic] result in underestimating radioactivity levels to which an employee was exposed," in violation of 10 C?R S 20.103.3 and S 20.401, G.

2.:

"a. The licensee has several work areas that contain multiple air samples individually placed at the different work locations.

Timekeeping for personnel at specific work locations is not maintained by the licensee and therefore for purposes of assigning MPC hours the multiple air sample activity is averaged.

The inspector stated that this was not a good health physics practice and in certain areas could result in underestimating radioactivity levels to which an

. e employee was exposed.

Failure of the licensee to accurately determine the MPC-HRS for an employee would be in violation of 10 CFR 20.103.3 and 10 CFR 20.401.G.2."

(Emphasis added.)

I'ndeed, misplacement of the single air filter must have rersulted in underestimating radioactivity levels to which Chemet test operators were exposed.

The finding of "no violation" is an incomprehensible as it is illegal.

Q.

The 84-17 Inspector's Finding That " General Airborne Radioactivity Levels In the Lab Have Been Minimal"-(o, pp. 15-16) Is Based On G.E. Surveys Which the Inspector Himself Found Worthless and Conflicts With the Findings in 84-04.

The 84-17 Inspector admitted that " Step 3.11 of -

COI 409 requires the tray of crucibles to be removed from the microwave oven and placed in a hood to cool."

(p. 15).

He also found that for an undetermined period of time prior to early 1984 (p. 11), last sentence in third par. from bottom),

and "until early 1984,"

i.e.,

after Mrs. English complained to NRC, "the cooling rack set outside the hood next to the microwave oven," not under a hood.

Instead of finding that this was a violation, the Inspector, swallowing G.E.'s hook, embarked on a frolic and detour minimizing the resulting hazard, as if this could justify the deliberate violation.

To exonerate G.E.

from this charge, the Inspector found 4

(pp. 15-16) that exposure to the fumes from the cooling crucibles;was not serious.

SUBJECT:

CONTROL OF CONTAMINATION Tu effectively mee't radiation safety guidelines in the Chemet Lab, sample containers, request forms or secondary containers (bags) which are associated with nuclear material sampling and show evidence of excessive or accumulated exterior contamination cannot be accepted by the Chemet Lab.

Samples determined not to be acceptable will remain at the sample window and the submitting unit notified to correct. the excessively contaminated submittal.

Additionally, to assure that lab paperwork contamination levels are maintained as low as practic'al, the current practice of placing the ich.aquast form in plastic bags with uranium containing samples must be discontinued.

The use of separate plastic bags should be used when mutiple samples / requests are delivered at the same time.

Your assi, stance is requested to instruct personnel responsible for sampling of this change by 03/11/85.

Af ter this date, request forms will not be accepted when received in bags along with uranium s ampl es.

The submitting unit will be notified to destroy the sub-mitted forms and initiate new request forms.

Your timely co-operation in this effort will be appreciated.

Thanks.

l i

W,*T ZI s

i j

T.P. Winslow, Manager Chemet Laboratories l

Mail Code:

H-92

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Dial Comm:

8*292-5461 T P W/ dvc Appendix B

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STRICIU PRIVA*lE e

C ENER AL h ELECTRIC l'

em sawm.

5461 esis. March 13, 1984 sonas.

ster.

WMD-QA-FO-Chemet Labs ansates.

M/C K-10 svesist.

VERA ENGLISH SAFETY CONCERNS L. A. Sheely, Manager Fuel Quality Mail Code K-10 During the morning shift on 03/08/84, Pete Jasinski, Acting supervisor for Paul Bann, was informed by Carl Rochelle of Vera English's concern that the microwave oven used for isotopic dissolutions was operating improperly due to salt accumulations being found on the inside of the oven door.

Mr. Jasinski completed a check-out including surveying the microwave oven with the microwave radiation detection instrument.

Mr. Jasinski found no indications of improper operating conditions -

a) Normal salt deposits within the oven which are cleaned during each shift and b) No measurable microwave radiation readings.

After complet-ing these checks, Mrs. English stated she still felt the oven was operating improperly as she could smell nitrous oxide fumes coming from the im H.

Mr. anninski reported that he and othera could not smell the fumes, but to be positive of the unit's proper ventilation to the 3' vent duct he decided to have Maintenance recheck the ventilation.

Just prior to'the erd of the shift, Mairtenance personnel, including 3entale seane, checked the system and confirmed the ventilation was working properly.

At this' point, it was the end of day shif t and Mrs. English had not pro-cessed any isotopic saeples through the microwave pending Mr. Jasinski's check-outs for each,of her concerns.

Additionally, C. F. Shipp, Plant safety specialist, advised that nitrous oxide at the OSHA air limit of $

ppm would be very nauseous with an obvious odor.

Since no problems were found, the microwave was used by other assigned operators on the follow-ing shifts with no unusual conditions being noted.

At 11 :00 p.m., March 09, 1984, when Mrs. English reported for her first night of graveyard shift, Mr. Coke McLamb reviewed with her the quick letter written by BVAC specialist, Bennie Beane, stating the ventilation principles add be basis of salt formation.

Mrs. English asked why the Maintenance review was not done on ihursday, March 06, when she was complaining.

Mr.

McLamb stated that the review was made on Thursday and Mr. Beane's letter was. based on his review of the oven on Thursday.

During' the weekend shif t very little isotopic work was available and Mrs. English perforced her assigned duties using the oven Friday and saturday nights (March 09 and 10) witrout incidence.

Appendix C

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(

j L. A. Sheely March 13,1984 J

sowever on sunday night (March 11) when Mr. Bill Lacewell, shif t super-l visor, reported to work, Mrs. English again raised concerns about the microwave.

Mrs. English removed the alpha monitor used for personnel contamination surveys at the exit of the Cheset Lab and reported that 4

she had found contamination on an exterior back panel of the sierowave.

Mr. Lacewell contacted Radiation safety; they reported no contamination l

vas found on the oven.

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i Mrs. English raised many concerns to Mr. Lacewell such est the microwave is creating radiation that is harmful to her, that the 6oor was loose i

and f umes escaped from the door, that f umes were affecting her sinuses l

and she was afraid of breathing radiation from the oven and that if a

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man was corplaining then the problem would get fixed.

Mr. Lacewell assured her that each of these concerns had :been investigated by con-tacts with Maintenance, Radiation safety and the safety specialist, l

etc., and that her discrimination accusagion was unfounded.

I In addition to these assertions, she told Mr. Lacewell that Radiation Jafety did not find the contamination on the oven since she knew that i

they do not do a thorough job on their routine checks.

She said 'tast i

week I smeared some sample on a table before their check and they could i

l not find it.

They had to come back to find it.*

Mr. Laeewell states i

Mrs. English's use of the word " smeared' was used in the context to in-I dicate she had contamina$ed a table surface with uranium sample material.

l It is extremely difficult for supervisors and other lab personnel to work ef fectively with Mrs. English's current continuous accusations, assertions, allegations, etc.

of extreme concern is her direct actions to promote her concern.

First, removal of the personnel monitor frc= an assigned survey station without specific supervision approval and second, purposely contaminating an area which could potentially create hazards for others.

i ker action may be bordering on being considered subversive and her rela-tionship with Supervision and certainly her ereditability for management is rapidly deteriorating.

Consequently, it is imperative that specific steps be taken to reassign Mrs. English from the Controlled Area of the i

Lab to preclude any potential purposeful action on her behalf to support j

her concerns.

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T. P. Winslow, Manager W.

Lacewell Date Chemet Labofatories i

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P. R.gasinski Date c.

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STANDARD OPERATING Clllt A A L IttCTAIC PR0CEDURE o

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' O.3.4 Radiation Safety - Lab Operating Procedure

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1.0 PURPOSE Th purpose of this procedure is to establish and outline the general radiation safety rules, practices, and precautions necessary to prevent airborne exposures, personal contamination, and spread of contamination within the Lab.

2.0 SCOPE The scope of this procedure is to cover the radiation safety rules and practices and precautions of a very general nature for the Wet Chemical

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'pecial requirements outlined in the General

, and Spectrography Labs.

S Radiation Safety Procedure #1.2.2-8.2.2 and SOP C-2.0-QA-201 shall be follo$ed.

3.0 TOLIC'l A. Eating, storing, or preparing food is not permitted in any areas where uraniu= is handled.

B. Smoking'and storing of Tobacco is not permitted in the controlled area.

C. The use of food containers (milk bottles, thermos, etc.) for handling or storing uranium is not permitted.

D. Employees working with uranium and all other personnel leaving the Lab must completely survey themselves for uranium contamination before leaving the work area.

A separate log is provided for individual clearance of small personal items such as clipboards and paperwork.

E. White labcoats, completely buttoned, and gloves, either rubber or disposable, plastic type, is required for working or handling uranium or touching potentially contaminated equipment, i

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G. Radiation Protection must be contacted to perform release surveys of all equipment leaving the controlled areas.

H. All compounds of uranium that could become airborne shall be handled inside of hoods with air flow of 80-120 LFM throuch the apertures.

Exa=ples of this is (1) Opening of powder sample containers (2) Crushing of pellets, weighing d e., (3) Dumping and compositing samples for return to Shop Operations, (4) Dissolution and concentration of uraum samnles by heating.

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GEN ER AL @ ELECThl0 esat comu. 8*292-5461 oats. Janu'ary 19, 1984 copits. C. G. McLamb, B-92 L.A. Sheely, K-10 orpr. WILMINGTON MANUFACTURING DEPARTMENT E.A. Lees, J-02 annitis. M/C H-92 ausner. ACTION PLANNED PER OUR 01/12/84 MEETING TO:

Vera M.

English M/C H-92 As indicated to you in our meeting of 01/12/84, actions have/will be taken in the following areas.

Flexibility for you to change your password has been e

limited due to the required interactions of twc computers, LMCS and HP9887, both of which require exact password matching.

Specifically, J. Garris, the only Lab LMCS authorized password accessor, will be set up by 01/25/84 to also be the enly authorized HP9887 password accessor.

At any time you are scheduled off for more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, your in-process work on the HP9887 should be cleared such that you may contact John to effect a password change for you.

Based on your 4-shif t rotation, you should be able to change your password upon reporting to either the 3:00 - 11:00 shif t or the 7:00 - 3:00 shift.

e LMCS 902/902 transaction password control, when initially set up, involved the ability to change values for standards results and, consequently, access was restricted to supervisor passwords only.

Sometime ago, these transactions were modified to eliminate access to changing standards results.

Use of the current 902/903 transac. tion by qualified lab personnel is appropriate for routine correction for input errors.

Bowever, if intentional falsification of results occurred, traceability to who/ shy changes were made would not be available.

Therefore, trans-actions 902/903 will not be made available to others until they are modified to record and print out on each changed result report to document the person,

/ reason and date of the changes.

In the interim, all supervisory passwords will be changed on a continuing basis to eliminate indiscrete use by others.

[-/6 N

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vera M. English January 19, 1984

-page 2-i When the HP9887 compu,ter was implemented in November e

1982, the pay number of the operator performing the sample solution weighing was used as. the pay number to be reported on the LMCS results report.

Since the possibility does exist that the shift operator who transacts the data on the HP9887 to LMCS may allow incorrect data to be transmitted, the LMCS results report will then show this incorrect results and the pay number of the non-transmitting operator.

Since it is not possible to enter one pay number which will represent the performance of the total' steps in completing a sample, I have decided to change the pay number reported to LMCS to be the pay number of the operator releasing the results.

This change was implemented effective 01/17/84.

With respect to samples which you have. identified on the rerun log as requiring rerun and subsequently being deleted by another operator, from the Lab viewpoint, I am confident that the deletions are being properly handled.

Per procedure, a sample outside the expected range is to be rerun if C&R personnel indicate it is from a source which was expected to meet the range.

Your. C&R conta.ct advises to rerun the sample-and a subsequent C&R contact advises not to rerun.

The l

problem lies with differing C&R decisions.

From a quality viewpoint, samples outside the expected range which are not rerun will not be released by CAR.

From a Lab viewpoint, we should not expend the retest labor to rerun samples not requiring reruns.

As an overview of the total isotopic measurement / quality release system, no specific problems are apparent due to samples not being rerun which should have been rerun.

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fpfWL T.P., Winslow, Manager Chemst, Laboratories, M/C H-92 TPW/dvc j& Y o

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..JCLE AR REGUL A10kY COMMisslON 4

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101 M ARiETT A STREE T. N R ATLANTA. GEORGIA 30303 e

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J g 3 1 1985 General Electric Company ATTN:

Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

REPORT NO. 70-1113/84-17 On November 27-30, 1984, NRC inspected activities authorized by NRC License No. SNM-1097 for your Nuclear Fuel Manufacturing Department. At the conclusion of the inspection, the findings were discussed with those rnembers of your staff icentified in the enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and

-er eseatative records. interviews with personnel, and observation of activities ir progress.

Tne inspecticn findings indicate that certain activities violated NRC require-ments. The violations, references to pertinent requirerrents, and elements to be included in your response are presented in the enclosed Notice of Violation.

In addition to the need for corrective action regarding the specific matters identified in the enclosed Notices, we are concerned about the implementation of your radiation protection program that permitted this situation to develop.

Consequently, your response should describe those particular actions taken or planned to improve the effectiveness of your program.

Your attention is invited to unresolved items identified in the inspection report.

These matters will be pursued during future inspections.

Please note that the enclosed report documents oral commitments (see page 1) made by a licensee representative and discussed in the exit interview.

If your understanding of these commitments differs fror the report statements, please inform this office promptly.

The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511.

i

$ 7CN

General Electric Company 2

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

Sincerely, C

1 g J. Philip Stohr, Director Division of Radiation Safety and Safeguards

Enclosures:

1.

Notice of Violation 2.

Inspection Report No. 70-1113/84-17 cc w/encis:

C. M. Vaughar. Manager

. :er.s'r; a: N.: ea-Mate ' tis Management Unit l

l l

ENCLOSURE 1 NOTICE OF VIOLATION General Electric Company Docket No. 70-1113 Nuclear Fuel Manufacturing Department License No. SNM-1097 The following violations were identified during an inspection conducted on November 27 - 30, 1984. The Severity Levels were assigned in accordance with the NRC Revised Enforcement Policy, (March 8, 1984, 49 CFR 8583).

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 te use suitable measurements of concer.;-a ic s cf eadiractise materia' ' r. ad- 'r

.a: air sa : 'ers ir tne CHEMET Laboratory were not located where the sample collected woulo be representative of airborne radioactivity concentrations breathed by the workers in the laboratory.

This condition existed on the cate 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).

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.

Contra ry to the above, the NRC was not furnished a termination exposure report within the 30 day limit in that a worker 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).

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including:

(1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

f :zLC4 %C 7

General Electric Company 2

Docket No. 70-1113 Nuclear Fuel Manufacturing Department License No. SNM-1097 Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as rec;uired by 10 CFR 2.790(d) or 10 CFR 73.21.

JAN 311985 Date:

1

p attu UNITED 51 ATEL

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g NUCLE AR REGULATORY COMMIS$10N

[

o REGION 11 2

l 101 M ARIETTA STR E E T. N.W.

ATLANTA. GEORGIA 30303

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f JAN 311985 Report No.:

70-1113/84-17 Licensee: General Electric Company Wilmington, NC 28401 Docket No.:

70-1113 License No.:

SNM-1097 Facility Name:

Nuclear Fuel Manufacturing Department Inspection Conducted: fovember 27 - 30, 1984 Inspector:

[ LP

'C. M. Hosty Date' Signed V

h

/[3 O D A ::reved by:

LL G. R. Jer.p.ms, Se;;1o A Cnt ef

'Date S1gre-Division of Radi1Ition Safety and Safeguards

SUMMARY

Scope:

This special, unannounced inspection entailed 38 inspector-hours on site in the areas of followup on worker concerns and an unresolved item.

Results: Two violations - Failure to make suitable measurements of concentra-tions of radioactive materials in air in the CHEMET Lab and failure to furnish the NRC a report of a terminated individual's radiation exposure within 30 days after the exposure.had been determined.

I l

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REPORT DETAILS 1.

Persons Contacted Licensee Employees

J. E. Bergman, Manager, Fuel Manufacturing "W. C. Peters, Manager, Nuclear Safety Engineering

C. M. Vaughan, Acting Manager, Regulatory Compli.ance

T. P. Winslow, Manager, CHEMET Lab

R. L. Torres, Manager, Radiation Protection D. T. Barbour, Radiation Protection Shif t Supervisor

S. P. Murray, Nuclear Safety Engineer

P. S. Stansbury, Nuclear Safety Engineer E. L. Jeffords, Nuclear Safety Engineer

B. J. Beane, Senior Engineer J. R. Swenson, Foreman, Special Material Order and Control J. Willia

5. Raciatier. Prote:tien Tecer.ician H. W. Ganious, CHEMET Lab Technician R. L. Brown, CHEMET Lab Test Operator-A G. M. Coronado, CHEMET Lab Technician G. W. Shiver, CHEMET Lab Test Operator-A H. W. Fields, CHEMET Lab Technician L. W. Brown, CHEMET Lab Test Operator-A W. A. Wells, CHEMET Lab Technician H. B. Pierce, CHEMET Lab Technician C. G. McLamb, CHEMET Lab Shift Supervisor W. Lacewell, CHEMET Lab Shift Supervisor J. R. Sutton, CHEMET Lab Test Operator-A

0. L. Swepson, CHEMET Lab Technician

Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on November 30, 1984, with those persons indicated in paragraph I above. The failure to make suitable measurements of concentrations of radioactive materials in air in the CHEMET Lab (paragraph 5) and failure to furnish the NRC a report of a terminated individual's radiation exposure within 30 days after the exposure of the individual had been determined (paragraph 4) were discussed in detail. The licensee acknowledged the inspection findings and took no exceptions.

The weaknesses in the contamination control program in the CHEMET Lab, were discussed.

Aspects of program discussed included frequency and scope of contamination surveys, survey requirements for removing paperwork, samples and personal items from the lab, and management attention and commitment to a radiologically clean working environment in the laboratory.

Licensee

2 management agreed to review this area and to take appropriate actions to improve the program.

Improved lighting for the bulletin board where the documents required by 10 CFR 19.11 are posted was discussed.

Licensee management agreed to take action to improve the lighting in the vicinity of this bulletin board.

The installation of local area exhaust systems to remove noxious fumes generated during various analyses was discussed.

The licensee agreed to perform dichromate titrations in a vented hood or to install an exhaust directly over the work station.

3.

Licensee Action on Previous Enforcement Matters (Closed) UNR (84-13-01) This item was determined to be a violation and is discussed in paragraph 5.

4.

Allecations. Discussions and Findings Note: The pronoun "he" is used throughout this report without regard to the sex of the individual to protect the identity of confidential sources to the maximum extent possible.

a.

Allegation Employees were told not to talk to or answer questions of NRC inspectors.

Discussion 10 CFR 19.15(b) states, in part, that during the course of an l

inspection any worker may bring privately to the attention of the inspectors,'either orally or in writing, any past or present condition which he has reason to believe may have contributed to or caused any violation of the Act, the regulations in this chapter, or license condition, or any unnecessary exposure of an individual to radiation from licensed radioactive material under the licensee's control.

In addition, Form NRC-3, Notice to Employees, states that an employee l

may talk with an NRC inspector. This form is required to be pcsted by l

10 CFR 19.11 in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to and from any particular licensed activity location to which the document applies.

A total of twelve CHEMET Lab technicians, test operators and first-line supervisors were asked whether or not they had been advised or told not to talk to NRC inspectors. Each individual stated that they had never been so advised.

One individual did state that his supervisor once told him to refer NRC inspectors to the supervisor if they had any cuestions.

3 During inspections at the licensee's facility between 1982 and 1984, the inspector has never encountered an individual who refused to talk with him. The inspector has on occasion been stopped by workers and asked questions.

Findings This allegation was not substantiated. The inspector found no evidence which would indicate that workers were prohibited or discouraged from talking with NRC inspectors.

No violations or deviations were identified.

b.

Allegation 10 CFR 19.11 required posting has become less accessible to employees than in the past. At the near guard house locatior, the bulletin board is poorly lighted.

Dust and dirt make posted material almost illegible.

Discussion 10 CFR 19.11(d) requires that documents, notices, or forms posted pursuant to this section appear in a sufficient number of places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed material activity location to which the document applies, shall be conspicuous, 'and shall be replaced if defaced or altered.

The inspector observed the posting of the dacuments required by 10 CFR 19.11 at the personnel entrance to the licensee's controlled access area during daylight and night hours.

Findings The allegation was partially substantiated. Although the postings may be less accessible than in the past, they met the requirement of 10 CFR 19.11 in that employees engaged in licensed activities could observe them on the way to and from any particular licensed activity.

The documents required by 10 CFR 19.11 were conspicuously posted and have been neither defaced nor altered. The postings were legible during the daylight hours. The postings were also legible during the night hours, although lighting in the area could be improved.

Licensee management agreed in the exit interview to. install better lighting in the vicinity of the bulletin boards.

c.

Allegation Dumping of uranium powder outside hoods and the release of gas fumes in the lab may be the cause of sinus problems and other nasal difficulties experienced by lab personnel.

4 1

Discussion Twelve laboratory personnel were asked if they had experienced sinus problems or other nasal difficulties while working in the lab.

One individual stated that he had a nasal rash from nitric acid fumes four or five years ago when performing isotopic analysis and has had a problem with hydrofluoric acid fumes at times in the lab.

The remaining eleven individuals interviewed stated they had not experienced sinus or nasal problems while working in the lab.

Findings The allegation was not substantiated. One. individual out of the twelve interviewed indicated he had any sinus or nasal problems while working in the lab.

It appears that nasal or sinus problems are not as pervasive in the lab as indicated in the allegation.

No association between dumping Uranium Powder and sinus problems was established.

Industrial exposure to concentrated acid is outside the purview of the NRC's responsibilities. However, this worker concern has been referred

OSHA.

No violations o cesiatiens were icer.tifie:.

d.

Allegation There was a violation of a laboratory procedure in accepting contami-nated sample vials and paperwork in the lab. -Supervisors were lax and condoned this.

Discussion Plant Procedure Calibration and Operation Instruction (COI) 6, Rev.1, Control of Samples in the CHEMET LAB, states in Paragraph 3.1.6 that

" samples received in the controlled lab are to be handled as contami-nated material."

In addition, Nuclear Safety Release 6.1.0, Radio-logical Safety Requirements for the CHEMET Lab, specifies that all personnel working in the CHEMET Lab must wear lab coats and safety glasses and that gloves will be worn when handling samples coming from the controlled area, working with visibly contaminated laboratory waste or equipment, working inside hoods,.and any time the individual feels gloves are required.

The inspector made several unannounced visits to the CHEMET Lab on different shifts and observed laboratory personnel's adherence to the requirements of the Nuclear Safety Release.

Findings The allegation was not substantiated.

The licensee recognizes that samples that come from the production area may be contaminated. Plant Procedures caution CHEMET Lab personnel that samples may be contaminated and require the use of appropriate protective clothing for lab personnel.

The inspector did not observe any violations of the

I i

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5 Nuclear Safety Release while he was in the laboratory. No violations or deviations were identified.

e.

Allegation Alleger's work area was deliberately contaminated by another person or persons on a previous shift.

Discussion A total of five CHEMET Lab personnel were asked if they knew of any cases where a lab worker's work station was deliberately contaminated by someone else. One individual states he was not aware of such an incident.

One individual stated he had no first hand knowledge, however, he had heard that it happened. Two individuals stated tnat they knew that the alleger contaminated his own work station to test whether or not radiation safety personnel could find the contamination during a routine survey.

Another individual stated that he and the alleger observed another worker using poor work practices which resultet ir. a spiii anc cien't teli any:ne.

Tney uset tne spill ic test radiation safety personnel's ability to find the contamination on a routine survey.

Findings l

This allegation could not be substantiated.

It is conceivable that either the work bench was accidentally contaminated on a previous shift j

rather than deliberately contaminated, or contaminated as indicated by the individuals interviewed, however, the specific cause could not be determined.

No violations or deviations were identified.

f.

Allegation Radiation Safety personnel were lax on monitoring for contamination and t

requiring cleanup.

Radiation safety people who. cover the analytical lab do not know what to look for.

Radiation Safety visits were rare and they never got-after people and told them to decontaminate.

Discussion License Condition 9 requires that licensed material be used in accordance with statements, representations and conditions of Part I of the licensee's application.

Part I, Section 3.2.4.6 discusses the minimum frequency, action limits for removable surface contamination, and maximum delay permitted in initiating decontamination action.

Plant Procedure Nyclear Safety Instruction 0-6.0, Rev.14, Contamina-tion Measurement and Control, provides the guidelines for the conduct of the contamination measurement program, evaluation and documentation

6 of the results and the required action based upon the contamination survey findings.

The inspector reviewed the weekly contamination survey results for 1984 and the licensee performed special surface contamination surveys, under the direct observation of the inspector. The inspector discussed the frequency, scope and time of day of the surveys with licensee representatives.

Twelve CHEMET Lab personnel were questioned concerning the frequency of surveys by the radiation safety staff and the timeliness of decontamination if contamination was identified during the survey. All twelve individuals indicated when radiation safety identified a contaminated area in the lab, the lab was notified and the area was promptly cleaned up, and then resurveyed by radiation safety.

Findings This allegation was partial'y sursta-tiated.

Cc+ta-ina:icn sueveys were performed at the minimum f requency required by tne license.

The inspector found no evidence which would indicate that radiation safety did not notify the laboratory of contamination and that decontamination was not initiated within the time limit imposed by the license.

Licensee representatives stated that the CHEMET lab surveys were performed weekly on the day shift.

If an individual was assigned to a back shift in the CHEMET Lab, he might conclude that radiation safety didn't perform frequent surveys in the Lab.

The review of the contamination survey results and observations by the inspector indicate that surveys performed by the radiation safety technicians are generally in the same locations which are often not the areas with the highest potential for becoming contaminated. The inspector stated that the licensee should familiarize the radiation safety technicians with the operations in the CHEMET Lab so that they can ensure that they survey those areas where the potential for spills exist (sample preparatirm area, weighing area, etc.). Random surveys for contamina-tion should be performed at least daily and detailed surveys of the entire lab should be performed weekly since the licensee utilizes the same administrative limits for contamination as are required for uncontrolled areas and there is a greater potential for a contaminating i

event. The licensee has no policy requiring notification of radiation safety in the event of a spill in the Lab. The inspector stated that the radiation safety group should be notified in the event of a spill so that a survey can be performed after decontamination to ensure the area is clean prior to resuming work in the area.

A licensee representative stated that this area would be reviewed and appropriate actions taken. The inspector stated that this area will be reviewed during a subsequent inspection (IFI 84-17-04).

No violations or deviations were identified.

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g.

Allegation The 1979 change of the analytical lab from a " controlled area" to

" semi-controlled area" was a violation of the employee relations manual.

Supervisor's putting the employee manual under lock and key was a violation of GE Policy.

Discussion In discussions with licensee representatives, the inspector determined that the change in the designation of the laboratory to " semi controlled" in the early 70's only involved a change in the types of protective clothing worn. Personnel in the lab were permitted to wear lab coats and surgical gloves rather than full protective clothing required in the production area.

The inspector reviewed the GE Employee Relations Manual.

Fincir.gs i

This allegation was not substantiated.

The change in the designation of the CHEMET, Lab is not discussed in the Employee Relations Manual.

i The clothing requirements for work in the CHEMET Lab are considered acceptable to the NRC'and are typical of what is used at similar NRC licensed facilities.

The accessibility of the Employee Relations-Manual is a matter reserved to the licensee and is outside the purview of NRC regulations.

No violations or deviations were identified.

A h.

Allegation Spill areas, and contamination areas, were not marked off to caution other: people in the analytical area.

Di sc'ussion 4

Plant Procedures Nuclear Safety Instruction 0-6.0, Contamination J4easurement and Control, requires that contamination surveys be reviewed with the foreman or supervisor of an area if contamination above the action level is found.

This action should apprise the supervisor / foreman of that part of his facility which is contaminated.

The licensee does not have a procedural requirement, nor do they rope off or otherwise mark contamination areas.

Findings This allegation was substantiated.

However, the marking off of contaminated areas is not required by NRC regulations, license conditions or licensee procedures.

No violations or deviations were identified.

8 1.

Allegation The practice of dumping heated Uranium pellets into open containers and allowing them to cool in uncovered containers outside a vented hood is unsafe.

Discussion This pertains to samples of scintered pellets removed from the LECO Hydrogen and Oxygen analyzers.

The inspector reviewed the technical manua'l for the LECO Model RR-IEN Automatic H2 Determinator and plant procedure CM&S 1.2.8.4, Rev.11, 12/16/83, Hydrogen Determination.

The analyzer is equipped with a purge system which is vented to an exhaust system. The analyzer raises the temperature of the pellet to approximately 1800C. During heat up the pellet fractures due to rapid therma-1 expansion.

The analyzer measu*es the hycreger. which evelves cu*ir.; this heatire cycle.

The inspector observec the analysis of samples usinc the LECO Hydrogen Analyzer. The pellet pieces are cooled substantially before the cycle ends and the analyzer is opened to remove the pieces.

Upon removal,

~

the pieces are placed in a stainless steel container for cooling.

. ~

Twelve CHEMET Lab personnel were questioned concerning the emission of fumes while the samples are cooling in the open container.

Seven of the twelve indicated that fumes were not given off during the cooling process, one individual thought fumes were a problem and four individuals had never performed the test and stated they didn't know.

Finding The allegation was not substantiated.

Based on observation by the inspector and interviews with laboratory personnel the cooling scintered pellets in the open is not a radiological or industrial safety problem.

No violations or deviations were identified.

j.

Allegation Dichromate titrations were done in the open and not in a vented hood and this was a safety hazard.

Discussion The licensee's Chemical, Metallurgical and Spectrochemical Laboratory Manual, Section 1.2.21.6, Rev. 5, 8/25/82, Determination of Uranium by Dichromate Titration, describe the procedure for preparing the samples and performing the dichromate titration.

In step 5.1 under special 4

precautions, the procedure states that " proper radiation protection should be taken to prevent inhalation or ingestion of solid or liquid samples centair.inc Urariue durir.g all handling operations." However, i

the procedures does not specify what speci'ic actions sbc lc be taker..

1.-x 9

The procedure contains no precautions concerning the inhalation of acid fumes that evolve from the titration.

Of the twelve CHEMET Lab personnel questioned concerning the evaluation of fumes from this titration, six of eight individual who have performed the titration stated that fumes are given off and most believed it should be performed in a hood.

The remaining four individuals had not performed the titration and had no comments.

The inspector observed a CHEMET Lab technician perform the dichromate titration and noted that fumes, although not visibly could be smelled during the addition of concentrated acids to the sample.

Findings The allegation was substantiated.

Based on observation by the inspector and interviews with laboratory personnel the performance of the cienrcmate titratien outside a h;cd does release ac'd furcs irtc the laboratory in the immediate vicinity of the work area.

The Uranium is in solution before the addition of concentrated acids thus minimizing the possible airborne radioact'ivity hazard.

Since weekly radiological contamination surveys per~ formed by the licensee in 1984, did not identify contamination above the action level at this work station, the radiological hazards of working at this station are minimal.

The only potential safety hazard is that resulting from the evolution of acid fumes during the titration.

In discussions with licensee management, the inspector stated that the titrations should be performed in a hood to eliminate the potential for inhaling noxious fumes.

During these discussions, licensee representatives stated that the licensee would consider relocating the work station to' a hood or installing a special exhaust system for this station.

Neither NRC regulations, nor license conditions address industrial safety in the laboratory.

This allegation was referred to OSHA.

No violations or deviations were identified.

k.

Allegation While working in an unt.ontrolled area of the plant, the alleger found a stores requisition with yellowed fingerprints on the lower right hand corner indicating contamination.

Discussion The inspector accompanied a licensee representative to the archives for stores requisitions and had the representative pull several requisi-

tions, including the one identified by the alleger.

The identified requisition did in fact have yellow marking on the lower right hand This requisition, along with several others were surveyed for corner.

radioactivity by the irspector and none was found.

10 Notices posted at the exits from the plant's controlled areas, including the CHEMET Lab, state that equipment and material must be surveyed by radiation protection prior to unconditioned release.

During tours of the plant, the inspector noted that the posted instructions at the exits from the controlled areas did not specify what survey requirements should be followed when removing paper, notebooks and personal items from the controlled area.

In discussions with the inspector, a licensee representative stated that small items such as paper, notebooks and personal items should be surveyed by the individual prior to exiting the controlled area and that at one time signs to this effect were posted at the exits. The licensee repre-sentative stated that signs specifying the survey requirements for all material and equipment would be reposted.

Findings The allegation was not substantiated. The inspector found no evidence which wecle indi: ate cer.ta-inated r.aterial is being removec f er

ne controlled area witnout proper controls.

No violations or deviations were identified.

1.

Allegation

~

Some laboratory personnel were not monitoring themselves for contamina-tion when leaving the job at the end of their workshifts.

Discussion Plant Procedure Nuclear Safety Release 6.1.0, Revision 4, Radiological Safety for the CHEMET Lab, specifies that all personnel exiting from the laboratory controlled area must monitor themselves for radioactive contamination.

The general cdnsensus of the individuals from the CHEMET Lab who were interviewed was that visitors to the lab are the ones.in the past who have failed to monitor themselves when they exited the laboratory. The interviewees indicated that the violators of the monitoring requirement were generally individuals who entered the laboratory to deliver or pickup paperwork or to discuss sample results with laboratory supervisors and who did not enter the potentially contaminated part of the lab.

Interviewees indicated that the number of individuals who were observed leaving the lab without monitoring has diminished and it is a rare occasion that individuals have to be stopped and asked to return to monitor properly.

The inspector, from an inconspicuous vantage point, observed the CHEMET Lab controlled area exit point, on several occasions during the inspection to determine if individuals were exiting the area without performing proper monitoring.

These observations were made on all shif ts and especially at tires wher. the number cf personnel e>it'n;

11 would be the highest (e.g., end of shift and at meal times).

The inspector did not observe anyone exiting from the CHEMET Lab without performing a proper survey.

In discussions with the inspector, a licensee representative stated that the radiation protection staff had performed more than 1000 special surveys of personnel after they had monitored themselves and t

have identified one individual with detectable contamination.

This individual had exited the production area. The surveys are unannounced and personnel are randomly selected.

The licensee has established disciplinary action for personnel who are observed not frisking or who frisk improperly as determined by the detection of contamination on personnel by the radiation protection staff during the special checks.

Finding t

The allegation was not substantiated. The inspector did not observe, re-dic he fird a y evicerce wnich would indicate i n di v ' c.J a ' s~ are exiting the controlled area without monitor.ing properly.

No violations or deviations were identified.

m.

Allegation Answers to radiation safety tests are available before the test is given.

Discussion A total of twelve CHEMET Lab personnel were questioned concerning the availability of answers to the radiation safety exam prior to taking the test, the instructor teaching the test or specifically identifying answers to test questions during the training or cheating during the exam. Ten of the twelve individuals indicated that they did not know of answers to the test being made available prior to the test, the instructor pointing out answers to specific test questions during training or cheating.during the test. One individual indicated he had observed cheating during a past test and another individual indicated that the answers to the test were available before the test a number of years ago. In discussion with licensee representatives, the inspector ascertained that the licensee administers a written exam only after the employee's initial radiation safety training.

No exam is required following the annual retraining.

Finding The allegation was not substantiated. The inspector found no evidence which would indicate answers to test questions are systematically provided to trainees prior to radiation safety training. While the NRC does not condone cheating on an examination neither NRC regulations nor license concitions recuire the lice +aee te administer a w-itter

12 1

examination following training.

The written examination is a self-imposed licensee requirement.

No violations or deviations were identified.

n.

Allegation

'The alleger has been furnished incomplete radiation exposure results.

The record is incomplete for film badge (or TLD), urinalysis, and whole body count results.

Discussion 10 CFR 19.13(b) requires that at the request of any worker, each licensee shall advise such worker annually of the worker's exposure to radiation or radioactive material as shown in records maintained by the licensee pursuant to paragraph 20.401(a).and (c).

10 CFR 19.13(c) requires at the request of a worker formerly engaged in licensed activities controlled by the licensee, that each licensee furnish to the worker a repe-: ef the werker's excesu-e to raciaticr or radie-active material.

Such reports shall be furnished within 30 days from the time the request is made, or within 30 ' days after the exposure of the individual has been determined by the licensee, whichever is later.

Plant Procedure Nuclear Safety Instruction E-6.0, Rev.11, Personnel Dose Reporting, requires that a worker be provided a report of his radiation exposure within 30 days of the request. Although how the request should be made is not specified in the procedure, discussions with licensee representatives indicate that the worker is asked to make i

the request in writing, so that compliance with 10 CFR 19.13 can be formally documented.

The. inspector reviewed the exposure records for the alleger and several other licensee employees who worked in licensed activities.

The inspector noted that radiation exposure data (film badge or TLD) for the period prior to 1976 was not available for personnel who worked in the CHEMET lab. In discussions with the inspector, a licensee repre-sentative stated that he believes CHEMET lab personnel were not issued film badges prior to 1976. However, the film badge issue records were at another licensee facility being microfiched and not available for review.

10 CFR 20.202(a) requires that each licensee supply appropriate personnel monitoring equipment to, and require the use of such equipment by each for individuals who enter a restricted area under such circumstances that he receive, or is likely to receive, a dose in a calendar quarter in excess of 25 percent of the applicable value specified in paragraph (a) of 20.101.

In reviewing the exposure data for CHEMET Lab personnel since 1976, it appears that personnel monitoring required by 10 CFR 20.202 probably would not have been required by CHEMET Lab personnel. However, if dosimetry was provided, then the licensee is required to include the results in any report to i

the individual or the NRC.

l

- - ~ - _ - -

13 The licensee uses an assigned airborne exposure value derived from the time spent in the work area and the air concentration measured in the work area to determine compliance with 10 CFR 20.103(b) and to calculate the internal dose assigned to the individual.

During the review of the exposure records for CHEMET Lab personnel, the inspector noted that the data for the period of February 1979 through May 1982 was omitted from the data available on some individuals. The licensee determined that the omission of the data was the result of a change over in computer programs, and that the data for the period was available.

A licensee representative stated that the assignment of airborne exposures of personnel in the CHEMET Lab began in late 1973.

However, during the inspection the licensee could not provide evidence that would establish the starting date for the assigned airborne program.

In addition to using suitable measurements of concentration of radio-active materials in air for detecting and evaluating airborne radio-a:tivity in rest-icted a eas.10 CR 20.103(a)(?) recaire s t e li:e see to use measurements of racioactivity in the bccy, 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. Paragraph 3.2.4.3.3 of Part 1, to the licensee's application for license renewal specifies that routine in vivo lung counting frequencies are established for individuals who normally work in areas where nontransportable uranium compounds are provided.

Individuals are scheduled for in vivo lung counting based upon their airborne exposure assignments and previous counting results. Plant Procedure and Practices 40-19, Bioassay Program, implements the license requirement.

The alleger received an annual whole body count from 1977 through 1984.

All were reported on the exposure report provided to the alleger.

Licensee representatives, in discussions with the inspector, stated that they believe that the licensee began using whole body counts for evaluating the uptake of insoluble radioactivity in 1977.

However, they could not provide any evidence to support this belief.

Nuclear Safety Release 0-2.0, Bioassay Urina'ysis Program implements the licensee's internal monitoring program for assessing the uptake of soluble radioactive material.

Appendix A,

Paragraph D of this procedure specifies the frequency of sampling for CHEMET Lab personnel.

The inspector reviewed the urinalysis data provided to the alleger in the termination report.

Daring this review, the inspector noted that the data for the exposure period prior to January 1983 was not included.

In discussions with licensee representatives the inspector was informed that the prior data was not included in the computer and therefore was not a part of the report.

However, the licensee representative stated that the results of urinalysis performed prior to 1983 for the CHEMET Lab personnel were available in hard copy and could be included in the report. Due to the low levels normally repeeted for CHEW.ET La perse-ne'. acting ine resalts p-etatly wocie net alte-the

i 14 final estimate of internal dose reported for the alleger. However, the inspector stated that a complete report of bioassay results should be provided to each individual who requests the report or who terminates.

The inspector stated that failure to provide a worker with a complete 4

report of exposure to radiation or radioactive material as shown in records maintained by the licensee pursuant to 20.401(a) and (c) would 3

be a violation of 10 CFR 19.13(a).

The inspector stated that this issue would be unresolved

pending establishment by the licensee of the dates when whole body counts, external monitoring, urinalysis and assigned airborne programs began and the preparation of revised dose reports for CHEMET Lab personnel and a review of the reports during a subsequent inspection (84-17-01).

10 CFR 20.408(b) requires that when an individual terminates employ-ment, the licensee furnish the NRC with a. report of the individual's exposure within 30 days after the exposure of the individual has been ce u rmi r.e c.

On July 26, 1984, a licensee employee terminated.

The individual's exposure had been determined on July 17, 1984. On this date, a report of exposure was provided to the individual at their request. The date i.

of last exposure was in March, 1984.

The report of the individual's exposure sent to the NRC was dated October 19, 1984, 94 days after the exposure of the individual was determined. The inspector stated that failure of the licensee to submit the exposure report of a terminated employee within 30 days after the exposure was determined is a viola-tion of 10 CFR 20.408(b) (84-17-02).

71nding This allegation was substantiated.

The licensee did not provide the alleger with complete urinalysis results, in that available data prior to 1983 was not included. Also, the assigned airborne exposure data for the period of March 1979 through May 1982 was erroneously omitted i

from the exposure report.

The extent to which data required to be provided the individual by NRC regulations was omitted is an unresolved issue until the licensee provides documentation establishing the starting dates for performing whole body counts, assigned airborne exposure determinations, TLD/ film badge issue and the performance of urinalysis and the information is reviewed by the inspector.

A violation of NRC requirements to submit termination reports to the NRC in a timely manner was identified during the review of this allegation, although timely reporting of information was not a part of this allegation.

Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.

I

15 o.

Allegation An airborne hazard was created when bubbly hot uranium material was removed frcm a microwave oven and allowed to cool in the open and not l

in a vented hood.

Discussion i

Licensee procedure Calibration and Operation Instruction (COI) 409, Revision 2, 7/25/84, Isotopic and U/0 Preparation Using Gravimetric Techniques, Steps 3.9 requires that the crucible be covered immediately after the addition of nitric acid.

Step 3.11 of COI 409 requires the tray of crucibles to be removed from the microwave oven and placed in a hood to cool.

Three of the twelve CHEMET Lab personnel interviewed commented on the location of the cooling rack for samples removed from the microwave.

The three individuals indicated that up until early 1984 the cooling rac6 set outsice tre hcod next te the microwave oven.

In early 1954 it was placec in tne nood.

A total of twelve CrtEMET Lab personn'el were asked if they had noted any problems with fumes coming from the microwave oven during heating or while samples were being cooled outside the hood. One individual indicated he had a nasal rash 4 or 5 j

years ago as a result of nitric acid fumes, however since they started covering the crucibles with a watch glass after the addition of nitric acid he has not had a problem. Another individual stated that he had

'noted a problem with acid fumes one time when the hood was not working.

However, the supervisor took prompt action.to get the hood ventilation system restored. The remaining 10 individuals stated that they had not i

noted any problems with fumes from cooling, samples.

I During the inspection, the inspector used a smoke tube to evaluate the air flow in the vicinity of the hood and microwave oven.

Smoke i

discharged in the immediate vicinity of the microwave oven door is drawn into the microwave by the exhaust system installed to remove any fumes generated during heating of samples. The flow in the work area around the microwave oven is toward the wall behind the microwave, up l

toward the ceiling and generally away from personnel who might be in the area of the microwave oven.

l The inspector reviewed the bioassay data for selected personnel assigned to the CHEMET Lab. During the review of results of the weekly l

urinalysis for personnel in the CHEMET Lab for 1984, the inspector noted that 20 out of 28 individuals checked had at least one positive l

urinalysis result (greater than the minimum detectable activity value i

of 5 micrograms per liter). The highest value noted was 19 micrograms per liter.

This value is well below NRC internal exposure limits and 3

the licensee's action level. There was not a significant difference in f

the number of positive results before and after the cooling rack was i

placed in the hood, which would indicate the small intake of radioactive material occurred as the result of other activities in the

.~.

\\

16 lab.

A review of whole body counts indicated that depositions of radioactivity by CHEMET Lab personnel have been less than the minimum detectable level of the whole body counter of approximately 75 micrograms of Uranium 235.

The general air flow from the area of the microwave oven is toward the intake of the recirculation system. A review of results of contamina-tion surveys performed while the cooling rack was outside the hood indicated that contamination has not been found along the path of the air toward the air recirculation system intake. At the request of the inspector and under the direct observation of the inspector, the licensee performed a surface contamination survey in the recirculation The highest system intake ducts prior to the'.high efficiency filters.

survey result was 300 dpm/300 cm These results indicate that general airborne radioactivity levels in the lab have been minimal.

Tne recirculation system has been in operation since the lab started up.

Licensee representatives stated that the duct work had never been decontaminated.

The contamination is probably the result of a cracual builcue eve-the yea *s sir.ce the systerr was placed ir service.

The contamination leveis were very low, in fact Licence Contmer.s would permit this duct work to be released for unrestricted use.

Findings

~

The allegation was not substantiated.

The inspector could find no evidence which would substantiate the allegation that an airborne hazard was created by cooling samples outside a hood. Bioassay data indicate that uptakes of radioactivity by CHEMET Lab personnel have been very small and in most cases not significantly greater than the minimum detectable level for the instrument used for the analysis. Interviews with laboratory personnel indicated that only one individual noted fumes evolving from cooling,

samples, particularly since the use of watch glass covers over the crucibles was initiated several years ago.

Interviews with lab personnel indicated that the cooling rack was located next to the microwave oven and outside a hood for an undetermined period of time

~

prior to early 1984.

The current revision of Procedure COI 409 (Revision 2) and previous revisions of the procedure required the samples to be removed from the microwave and placed in a hood for cooling. During unannounced tours of the laboratory, the inspector observed that the cooling rack was in the hood as required by procedure.

No violations or deviations were

. identified.

Air sampling in the CHEMET Lab was reviewed during an inspection performed September 17-21, 1984 (Inspection Report 70-1113/84-13). An unresolved item was identified.

Followup on this item is discuss in Paragraph 6 of this report.

17 5.

Air Sampling in the CHEMET Laboratory Air sampling in the CHEMET Lab was identified as an unresolved item in Region II Inspection Report 70-1113/84-13, pending a review of the documentation which the licensee indicated would furnish information on evaluations made to determine the air sampling program in the CHEMET Lab.

Followup on the allegations listed below resulted in the identification of the unresolved item:

a.

An airborne hazard was created when bubbly hot uranium material was removed from a microwave oven and allowed to cool in the open and not or c vented hood, b.

leaks around the microwave oven, used for dissolution of uranium samples in crucibles, created an airborne hazard from uranium gas vapors, and c.

uranium powers were cumpec from cru:ibies outsioe nocos causing airborne contamination and surface area contamination and supervision was reluctant to do anything about it.

10 CFR 20.103(a)(3) requir.ss the licensee to use suitable measurements of concentration of radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas.

The licensee's air sampling program in the main work area of the CHEMET Lab is a single air sampler located approximately seven feet off the floor in the north west corner of the lab. The filters are removed each shift and analyzed.

l The inspector reviewed the contamination surveys performed by the licensee in the CHEMET Lab in 1984, air sample results for 1984, and interviewed laboratory personnel concerning operations in the lab.

The inspector also used a smoke tube to evaluate the flow of a~ir around the work stations where uncontained Uranium was handled.

During. tours of the lab, and through interviews with lab personnel the inspector determined that operations such as sample preparation and powder weighing take place at locations far removed from the single air sampler.

During rrtiew of the contamination survey data for 1984, the inspector noted that sample preparation areas (work bench and floor) in the vicinity of hood number 1 and the weighing stations are areas where loose surface contamination has been identified above the licensee's administrative action level for' initiating cleanup.

s l

18 i

The air flow studies performed by the inspector showed that air flow in the lab is away from the air sampler, even at the work stations in the immediate vicinity of the air sampler.

The air flow studies also indicated that airborne radioactivity if it occurred would probably remain in the general area of the individual performing weighing operations at several places in the lab because of the partial enclosure around the balances. In discussion with licensee representatives, the inspector ascertained that the CHEMET Lab exhaust ventilation system had been modified witnin the past year. -This system exhausts through the various hoods in the lab and is the principal air exhaust system for the lab. In addition, the lab has an approximately 5000 cfm recirculation system for general room air, which has several air registers above the grated ceiling in the lab and a single air return located on the north east corner of the lab. The inscector stated that air samplers shoulc be locatec in tne areas of the iao where potential exists for the material handled to become airborne, such as sample preparation areas, areas.where samples are heated to high temperatures and weighing stations, and that the air samplers should be located where the sample co'lectec is red *esentative cf the airbcene ccace* teat' ors t'reat'ed by the worker. Since the ventilation system hac Deen mocifiec af ter tne previous evaluation of air sampling in the lab, that study was not consicered relevant. The' inspector statec that f ailure to make suitable measurements of concentrations of radioactive materials in air for detecting and evaluating airborne radioactivity in the CHEMET Lab was a violation of 10 CFR 20.103(a)(3).

(84-17-03).

UNITED STATES f,#paasco'o, NUCLEAR REGULATORY COMMISSION o

REGloN 18 3

3,,

3 101 M ARIETT A STRE ET, N.W.

e ATL ANTA. GEORGI A 30303 o

%.... /

jgg 311985 General Electric Company ATTN:

Mr. Eugene A. Lees, General Manager Wilmington Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

REPORT NO. 70-1113/84-18 On December 17 - 21, 1984 NRC inspected activities authorized by NRC License No. SNM-1097 for your General Electric Wilmington facility.

At the conclusion of the insDection, the findings were discussed with those members of your staff identified in the enclosed inspection report.

A-eas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

The inspection findings indicate that certain activities violated NRC require-ments.

The violations, references to pertinent requirements, and elements to be included in your response are presented in the enclosed Notice of Violation.

In accordance with 10 CFR 2.790(a), a copy of this letter, its enclosures, and your reply will be placed in NRC's Public Document Room upon completion of our evaluation of the reply.

If you wish to withhold information contained therein, please notify this of fice by telephone and include a written application to withhold information in your response. Such application must be consistent with the requirements of 2.790(b)(1).

The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511.

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

Sincerely, J. Philip St r,

ire r

Division of Radiation Safety and Safeguards

Enclosures:

(See page 2) dO53CO22.3 hh g 9e 1

General Electric Company 2

Enclosures:

1.

Notice of Violation 2.

Inspection Report No. 70-1113/84-18 cc w/encis:

C. M. Vaughan, Manager Licensing and Nuclear Materials Management Unit

ENCLOSURE 1 NOTICE OF VIOLATION General Electric Docket Nos. 70-1113 Wilmington License Nos. SNM-1097 The following violation was identified during an inspection conducted on December 17 - 21, 1984. The Severity Level was assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

10 CFR 70.22(h)(i) states, in part. that Emergency Plans shall contain the elements that are listed in Section IV, " Content of Emergency Plans," of Appendix E to 10 CFR 50.

10 CFR 50, Appendix E IV(D)(1) states, in part, that administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described.

Contrary to the above, though the Emergency Director is required by the Radiological Contingency and Emergency Plan to provide projected dose information and recommendations to off-site organizations for implementing effective emergency action, neither the Plan or Implementing Procedures were adequately prescriptive to assure prompt notification and protective action recommendations to off-site authorities.

This is a Severity Level IV violation (Supplement VIII).

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply, including:

(1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full comoliance will be achieved.

Security or safeguards information should be submitted as an enclosure to f acilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 CFR 73.21.

JAN 311985 Date:

o UNIT ED ST ATES

,[na macg*'o NUCLEAR REGULATORY COMMISSION y*

REGloN 11 g

j 101 MARIETTA STREET.N.W.

AT L ANT A. GEORGI A 30323 o,

b.,.. * 'g JAN 311985 Report No.:

70-1113/84-18 Licensee:

General Electric Company Wilmington, NC 28401 Docket No.:

70-1113 License No.:

SNM-1097 Facility Name: General Electric Company Inspection Conducted-Degember 17-21, 1984 y

InspectorxI WA

/

.5 S-T. R. {ecker e

' Date<'Sioned

(

'l' Approved by:

,6 W. T. Cline, Section Chief Date Signea Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 32 inspector-hours on site in the areas of emergency preparedness, fire protection and investigation of worker concerns.

Results:

Of the areas inspected one violation was identified in the area of protective action recommendations.

Op

.?

2 REPORT DETAILS 1.

Persons Contacted Licensee Employees Contacted

W. W. McMahon, Manager, Quality Assurance

J. H. Bradberry, Emergency Preparedness Coordinator

J. L. Harmon, Manager, Manufacturing Technology and Engineering Operations

B. F. Bentley, Acting Manager, Manufacturing

R. G. Patterson, Manager, Fuel Fabrication

F. G. Welfare, Acting Manager, Nuclear Safety Engineering "S. P. Murray, Senior Nuclear Safety Engineer R. Folek, Senior Specialist, Licensing Engineering A. Hobbs, Site Supervisor for Security R. Lennon Chief, Training P. Zorick, Fire Seargent/ Burns Security Other licensee employees contacted included operators, security force members, and office personnel.

Other Organizations M. Murray, Emergency Room, Supervisor New Hanover Memorial Hospital

' Attended exit interview 2.

Exit Interview The inspection scope and findings were summarized on December 21, 1984, with those persons indicated in paragraph 1 above. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3.

Offsite Support Agencies (88050)

The inspector held discussions with licensee representatives regarding the coordination of emergency planning with offsite agencies.

Written agreements with those offsite support organizations specified in the Radiological Contingency and Emergency Plan (RCEP) had been renewed as required and appropriate. The inspector determined through discussions with licensee representatives that the licensee was. periodically contacting local and State support organizations for purposes of offering training and maintaining mutual familiarization with emergency response roles and site orientation.

The inspector visited the New Hanover Memorial Hospital and ' interviewed cognizant staff there regarding plans to provide medical treatment for radioactively contaminated individuals as specified in the formal agreement between the hospital and the licensee.

Hospital staff appeared to have an

3 acceptable working knowledge of their emergency response role with respect to the licensee's facility. The inspector was given a tour of the emergency treatment facilities.

Hospital personnel used the f acilities during the period of the inspection tc treat a contaminatec worker who was injured during an accident at the plant.

No violations or deviations were identified.

4.

Emergency Plan, Procedures, Facilities, and Equipment (88050)

Based on discussions with a licensee representative and a review of documents, the inspector determined that there had been no significant changes in the RCEP other than the appointment of a new emergency director, since the last emergency preparedness inspection (March 1984).

The licensee's emergency call list was reviewed and found to be current (11/19/84).

Tne list is updated on approximately a six month frequency.

Emergency telephone numbers are conspicuously incorporated into the plant telephone book.

The inspector: selectively examined emergency supplies and found them to be properly maintained.

Inspection and inventory check lists were reviewed and an independent survey of the supplies listed for the emergency truck was performed. Survey meters were recently calibrated and operational and air tanks on respiratory equipment were full.

The inspector toured the Emergency Control Center and onsite medical facility and determined that the equipment was appropriate and in place.

The inspector reviewed the plant evacuation routes and assembly points, and found no unusual impediments.

The inspector discussed the types of sampling and other actions to be taken during emergencies involving effluent releases and accidental criticality with a licensee representative.

Several of the licensee's onsite air sampling stations were examined and found to be operating.

The RCEP requires that "the Emergency Director will provide projected dose information and recommendations to off-site organizations for implementing effective emergency action".

A review of the RCEP and procedures as well as discussions with licensee representatives disclosed that procecures for providing prompt protective action recommendations for the protection of the public were inadequate in that they were lacking in content and specificity.

As written the procedures were vague as to the actions to be taken and priority and responsibility for such action.

Licensee representatives were unable to provide implementing procedures describing appropriate licensee actions for promptly notifying offsite agencies and providing protective action recommendations. Any procedures which addressed notifying offsite agencies and providing the recommendations appeared to place those actions on a relatively low priority.

The issue was discussed with licensee representatives during which the inspector described the benefit of more prescriptive procedures in order to promptly assess the situation, determine appropriate protective

4

e g

I 4

l i

action recommendations, notify the cognizant authorities, and make i

appropriate protective action recommendations to of f site authorities.

The I

need for predeterminec commur.ications pathways wnich include a message

[

format agreed upon by appropriate resconcents was also discussed.

The f ailure to provide for appropriate procedures to iaentify anc communicate protective action recommendations to off site authorities is a violation of j

10 CFR 70.23(11) and 10 CFR 50, Appendix E.

4.

Test and Drills (88050)

The inspector reviewed a schedule for emergency preparedness training exercises.

Seven exercises included events such as bomb threat, confrontation, fire and explosion, radiological, severe weather, criticality I

and chemical hazards. Records of previously held drills were reviewed. The inspector noted that critique comments were evaluated and tracked.

No violations or ceviations were identified.

5.

Onsite Fire Protection Equipment and Procedures (88050) l i*

The inspector noted that the local fire department does not participate in onsite drills.

This non participation is at the request of the fire department due to its small, all volunteer nature.

Facility orientations are provided for the fire company and rescue squad annually.

Computer records for periodic surveillance testing of the diesel fire pump were reviewed and found acceptable.

The inspector had no further questions.

No violations or deviations were identified.

6.

Inspector Follow-up (92701) a.

(Cles.ed) Inspector Followup Item (IFI) 70-1113/81-11-03:

Wind speed and ni-ection recorder installation.

The equipment has been installed.

I b.

(Closed) IFI 70-1113/83-08-02:

Determine stability index from local meteorological data.

Same as (a) above.

c.

(Closed) IFI 70-1113/82-03-01:

Ne maintenance inspection and test procedure for fire pump.

Maintenance and test records were reviewed and found acceptable, d.

(Closed) IFI 70-1113/82-03-03:

Completion of fire brigade initial training and improved documentation of fire brigade training. Training records for the fire brigade were reviewed and found acceptable.

7.

Investigation of Worker Concerns An individual contacted the NRC Region II office expressing concern with regard to emergency preparedness related issues at the General Electric's Nuclear Fuel Manuf acturing Depar' ment, Wilmington, North Carolina. As a t

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result, a Region II inspector investigated the following worker concerns during a routine inspection:

a.

People on crutches and in casts were allowed to work in the FMO building, where at times, curing crills and criticality tests, they were required to evacuate quickly.

b.

In the case of criticality evacuation there might be a problem of workers getting out of the plant.

Reference was specifically made to one area of the plant where " Fat Albert" and the fuel bundles hang.

Here the corridors are blocked by bundle carriers.

The investigation took place during the December 17-21, 1984, inspection.

The investigation consisted of observations, review of procedures, and interviews.

The specific worker concerns were not discussed during the December 21, exit meeting with licensee management.

Conclusions Neither of the allegations was substantiated.

The first allegation stated that: people on crutches were allowed to work in the FM3 building where at times, during drills and criticality tests, they were required to evacuate quickly. A review of licensee documents indicated that it 4

is plant policy to require medical verification of a workers ability to run prior to allowing that worker to return to duty in the FMO facility following an illness or injury which may affect that ability.

Standing orders for the guard force state that no one using cane, crutches or wheel chair is allowed to enter the controlled access area unless they get a medical release from Dr. Schmidt in the medical unit. The inspector reviewed several medical orders, some of which allowed and some restricted access to.the controlled access area. The inspector i

ncticed no one in'the area with apparent disabilities which would hinder running.

Further, a guard was approached and asked to repeat his orders on the subject which he did appropriately. A licensee representative stated that there is a strong Company commitment to strict adherence to established requirements for evacuation capability.

The second allegation stated that:

in the case of criticality evacuation there i

might be a problem of workers getting out of the plant.

The alleger referred specifically to one area of the plant where " Fat Albert" and fuel bundles hang.

Here, the corridors are blocked by bundle carriers.

The inspector inspected the area noting the posted evacuation routes as well as the structures mentioned above.

It was determined that these structures were, in fact, impediments to a clear egress but not unreasonably or unusually so. Any l

machine, large tool, desk etc., in the path of flight could be considered as blocking the evacuation. It is generally not reasonable (or possible) to provide an absolutely clear path for evacuation in the work place.

Rapid egress could still be accomplished. Licensee representatives stated that evacuation routes in the area were designed to avoid routing workers through the most congested locations in the area and actions are taken at appropriate times to assure free egress.

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FEB 071995 j

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Genera) Electric Company ATTN: Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. 0. Box 780

.Wilmington, NC 28402 Gentlemen:

SUBJECT:

REPORT NO. 70-1113/84-15 On Novembe 3 through 16 and December 3 through 7, 1984, NRC inspected activities authorized by NRC License No. SNM-1097 for your Nuclear Fuel Manu-facturing Department.

At the conclusion of the inspection, the findings were discussed with those members of your staff. identified in the enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

The inspection findings indicate that certain_ activities violated NRC require-ments. The violation, references to pertinent requirements, and elements to be included in your response are presented in the enciesed Notice of Violation.

In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activities and security measur.es are exempt from public disclosure; therefore, the enclosures to this letter, with the exception of the report cover page which presents a nonexempt summary and the Notice of Violation, will not be placed in NRC's Public Document Room.

The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget issued under_ the Paperwork Reduction Act of 1980, PL 96-511.

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

Since ly,

{

s L. J. Philip Stohr, Director

.cg g g Division of Radiation Safety and Safeguards Enciosures:

1.

Notice of Violation (Not Exempt) 2.

Inspection Report No. 70-1113/84-15 (Exempt from Disclosure)

C. M. Vaughan, Manager l/

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TABLE I Current LEA Standards (I)

(70-1113/84-15)

Calibration Verification Standards Standards

% Enrichment

% Enrichment 0.715 0.715 1.454 2.223 2.238 2.999

.3.978 3.985 (1) These standsrds data are based on the mean of the Teledyne and Ledoux Laboratory analyses.

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TABLE 11 LEA Quality Test (70-1113/84-15)

Original Remeasured Isotopic Container Isotopic Measurement (*4)

Difference (%)

No.

Measurement (%)

2200AP'4087 2.165-2.190

-0.025 2200AP4070 2.211 2.212

-0.001 2200AP4105 2.216 2.211 0.005 2200AP4121 2.217 2.I'89 0.028 Net sum difference (%)

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REPORT DETAILS 1.

Licensee Employees Contacted

'J. E. Bergman, Manager, Fuel Manufacturing

W. W. McMahon, Manager, Quality Assurance

C. M. Vaughan, Acting Manager, Regulatory Compliance

T. P. Winslow, Acting Manager, Site Support Quality

R. M. McIver, Acting Manager, Site Operations and Materials Systems

'G. E. Green, Manager, Financial Operations

'H. Stern, Acting Manager, Microelectronics Technology and Equipment Operations D. Starr, Manager, Site Support Quality

B. F. Bently, Acting Manager, Fuel Manufacturing

G. R. Pearson, Acting Manger, Fuel Fabrication Operation

R. E. Parnell, Measurement Control Engineer, Chemet Laboratory

G. R. Hallett, Senior Engineer, Measurements and Statistics

R. H. Foleck, Senior-Specialist Licensing Engineer "C. Schlitz, Acting Manager, Microelectronics Technology and Equipment Operations

V. P. Moore, Acting Manager, Site Operations and Materials Systems

G. F. Finders, Shift Supervisor Radiation-Saft4y The inspector also interviewed several other licensee employees.

Denotes those present at the November 16, 1984 exit interview and/or the December 7, 1984 exit interview.

2.

Exit Interview The inspection scope and findings were summarized on Neverber 16, 1984 and December 7, 1984, with those persons indicated in paragraph I above.

The following issues were discussed in detail:

Measurement Systems - Laboratory Enrichment Analyzer para. 3 ; Physical Independent Measurements para. 4; and Worker Concerns Inventory para. 5 ; and one violation - failure tc follow procedures.for cleaning up visible contamination Para 5.

The licensee acknowledged the inspection findings and took no exceptions.

3.

Measurement Systems

.aboratory Enrichment Analyzer 85207 The General Electric Company GE, Wilmington Manufacturing Department, Wilmington, North Carolina facility's LEA systems are located in the Chemet Laboratory and are comprised of measurement devices capable of measuring the and scrap materials.

enrichment % U-235. of sample quantities of UO, U D33 2

UNITED ETATES p as?u

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FEB 071995 Report No.:

70-1113/84-15

. Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1213 License No.:

SNM-1097 Facility Name: General Electric Company Inspection Conducted:

November 13-16 and December 3-7, 1984 c QO du p.

2/6/t s Inspector:

Date Signed E. L. Clay, Safeguarch Enginebr' c R0,6_m 2/6/es-Approved by: E. J. McAlpine, Chief \\ Material Control and Date Signed Accountability Section, Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards SUPPARY Scope:

This routine, unannounced inspection entailed 77 inspector-hours (59 inspector-hours at the site during ncrmal working hours,18 inspector-hours on backshift at the site) in the areas of measurement systems, physical inventory, and worker concerns.

Results:

One violation was identified:

Failure to clean the LEA measurement room of visible contamination.

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FEB 131985 General Electric Company ATTN:

Mr. Eugene A. Lees, General Manager Wilmington Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

REPORT NO. 70-1113/84-16 On November 27-30, 1984 and January 14-16, 1985, NRC inspected activities authorized by NRC License No. $NM-1097 for your Wilmington Nuclear Fuels Manufacturin5 Department. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.

Areas examined during the" inspection are identified in the report. Within these

~

areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progr.ess.

The inspection findings. indicate that certain activities violated NRC require-ments..The violation, references to pertinent requirements, and elements to be included in your response are presented in the enclosed Notice of Violation.

~

In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activities and security measures are exemp*. from public disclosure; therefore, the enclosures to l

this letter, with the exception of the report cover page which presents a nonexempt summary, will not be placed in NRC's Public Document Room.

The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Office of Management and Budget issued under-the Paperwork Recuttien Act of 1980, PL 96-511.

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

Sincerely, 1.

s J.

hilip tohr, Director l

gq f Division of Radiation Safety and Safeguards gg

Enclosures:

1.

Notice of Violation l

(Exempt from Disclosure) 2.

Inspection Report No. 70-1113/84-16 (Exempt from Disclosure)

W i

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General Electric Company 2

FEB 131985

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C. M. Vaughan, Manager Regulatory Compliance 4

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March 20, 1985 3132 Camden Circle Wilmington, N.C.

28403 (919) 343-8328 FPEEDOM OF INFORMATK)N ACT REQUEST Vanessa Washington, k-N*206 NRC Public Document Room 1717'H St. NW, First Floor Lobby M'

03 N T Washington, D.C. 20555

Dear Ms. Washington:

This request is made under the f ederal Freedom of Information Act, 5 U.S.C.

552.

Please send me copies of the following NRC documents:

70-1113 - 81/11 70-1113 - 84/08 70-1113 - 82/10 70-1113 - 84/10 70-1113 - 82/16 70-1113 - 82/18 70-1113 - 84/13 70-1113 - 83/05 70-1113 - 84/15 70-1113 - 84/16 70-1113 - 84/04 70-1113 - 84/17 70-1113 - 84/05 70-1113 - 84/18 70-1113 - 84/07 4

Also from Docket No. 70-1113, I seek the following documents for which I lack an index number:

o Letter f rom James M. Taylor to Mozart G. Ratner dated 1/10/85, with attachment marked 7590-01, Petitions for Action under Act 10 CFR Sec. 2.20%

o Motion to Institute Proceedings for Imposition of Civil Penalties and to Vacate and Reverse Inspection Reports, etc., signed by Mozart G. Ratner, and Chapters 1 and 2 thereto.

As you know, the FOI Act provides that if portions of a document are exempt f rom release, the remainder must be segregated and disclosed. Therefore, I will expect you to send me all nonexempt portions of the records which I have requested and ask that you justify any deletions by reference to specific exemptions of the FOI Act. I reserve the right to appeal your decision to withold any materials.

The FOI Act provides f or waiver or reduction in f ees if disclo-sure could be considered as "primarily benefitting the general public." I am a f reelance journalist assigned by the The News and

+

Nd[f7 a

Observer, of Ra leigh, N.C. to cover a U.S. Department of Labor dispute styled Vera P. English V. General Electric Company and apparently some or all of the above-referenced documents are relevant to that case, in which there is an considerable public interest. Therefore, I ask that you waive all search and duplica-tion f ees. I am aware that several of the requested documents are voluminous and that copying costs may be substantial. In the alternative, I may be willing to view the documents at the public document room, if I know which documents would be made available.

If you deny these requests, please notify me of the estimated costs so that I may decide whether to pay the f ees or appeal your denial of my request for a waiver.

As I am making this request in the capacity of a journalist and this information is of timely value, I will appreciate your communicating with me by telephone, rather than by mail, if you have any questions regarding this request. Thank you for your assistance, and I vill look forward to receiving your reply within 10 business days as required by law.

Sin ' rely yours, mes R. Polson 2

ML20132C972

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Dear Ms. Washington:

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ML20132C972

Text

SUBJECT:

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Dear Ms. Washington:

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