ML20133L556
| ML20133L556 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/07/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20132C968 | List: |
| References | |
| FOIA-85-208 70-1113-84-15, NUDOCS 8508120652 | |
| Download: ML20133L556 (9) | |
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- ENCLOSURE 1 h NOTICE OF VIOLATION ,
General Electric Company Docket No. 70-1113 Nuclear Fuel Manufacturing Department License No. SNM-1097 The following violation was iden~tified during an inspection . conducted on November 13 through 16 and December 3 through 7,1984. The Sev'erity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).
License Condition 9 requ. ires that licensed material be used in accordance with the statements, representations, and conditions of Part I of the .'
licensee's application. part 1, Section 2.2.1.1 of the licensee's application requires that the Area Manager establish and approve written ,
operating procedures incorporating radiation safety controls.
Contrary to the abovp, the requirements of the license condition were not l met, in that on December 3, 1984, visible uranium contamin tion was observed in the LEA measurement room which had not been cleaned up immediately as required by plant procedure Nuclear Safety Re'1 ease 6.1.0. !
4 This is a Severity Level IV 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.
Security .or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.7S0(d) or 10 CFR 73.21. .
I Date:
i 8500120652 050702 PDR FOIA PDR POLSON05-200
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Each measurement device is comprised of an Aston Company Analyzer, al T1 detector and an automated sample changer that is ~s'upported by a computer sy' stem .<hich analyzes the measurement data and reports the results At the time of this inspection, three LEA systems were performing enrichment analyses. Approximately 40,000 samples per year are analyzed by these LEA systems.
The efforts of this inspection were focused upon measurement performance evaluations of the Chemet Laboratory's LEA measurements systems.
- a. Standards Fabrication, Traceability, Analytical Evaluations and Controls The licensee LEA standards techniques utilized for fabrication, traceability and analytical evaluations of standard SNM were performed c '
in accordance with approved operating procedures. The licensee period-ically changes calibration and verification standards and may or may not change the isotopic content of these standards. A listing of the isotopic va_1ues of standards currently used for calibration and verification purposes is shown in Table I.
The licensee is using and maintaining LEA standards under controlled conditions and in accordance with the_ fac.111ty FNMC plan and approved standard operating procedures 50P . Calibration and Operating Instructions COI indicate that after a standard is removed from a sealed container it is designated as a " standard in use" and must be assigned to an individual responsible for the work area in which the standard is located. The licensee is preparing a revision to these operating instructions that will expand on the use and control of LEA NDA standarcs. These revised instructions will be in the status of review for approval by December 31, 1984.
No violation or deviations were observed in this area.
- b. System Calibrations -
Utilizing the five LEA NDA standards shown in Table-I, recalibrations of each LEA were performed at the required frequencies and in accord-ante with approved procedures. The recalibrations for each LEA system was performed by an on-line computer HP-9825 programmed to measure specified standards and to perform standards recalibration calcula-tions. Recalibrations were performed from the data obtained from two simultaneous measurements of the U-235 and U-238 isotope contained in each standard.
The inspector verified the computer calculated values for the calibra-tion curve currently used by Unit 1, and found no significant differ-ence between the licensee's currently used calibration curve measure-ments and the Ril verification measurements.
. No violation or deviations were observed in this area.
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. c. Measurement Techniques ' '
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Isotepic enrichment measurements performed by the licensee's LEA measurements systems were being performed in accordance with currently approved operatino procedures and instructions. Each LEA system utilizes analyzer iardware noted in paragraph 4 above, to provide measurements data for each sample analyzed and is supported by three computer systems to analyze the measurements data and to report the measurement results. The following :omputer systems are utilized for isotopic measurements by the LEAS in the Chemet Laboratory.
(1) The WP-9525 computer system is programmed to control the measure-ments of each LEA system and calculate an apparent isotopic value that is uncorrected for known measurement bias. One HP-9825 computer handles the analytical output from two LEA systems and -
automatically transmits) measurement results to the facility HP-87 computer system.
(2) The iP-57 computer system is ccmprised of several strategically located teNninals which control sample identification and corrects '
LEA measurement data for bias in weighing errors associated with sample preparations. The bias corrected data is transmitted to the facility Laboratory Measur.e. ment _ Computer System LMC5 via menu instructions The measurement technician selects the proper menu and the bias corrected measurement data is automatically
, transmitted to the LMC5 computer system (3) The LMC5 is the primary computer system for controlling all measurement data flow throughout the Chemet Laboratory. The LMC5 performs bias corrections for sampling errors associated with LEA measurement data, reports the final corrected isotopic results and assures that: a measurement technicians are properly qualified; b calibration and control stanaards have been analyzed in proper sequence; and c the analyzer system is operating within acceptable control limits, before issuing a final analytical report. -
Access to these computer systems is controlled by individual ' payroll numbers and aTunicue password for each qualified measurement tech-nician. Individual passwords are changed, at the discretion of the individual technician, by a single employee who is not associated with the wet chemistry laboratory analytical measurements. Each individual measurement technician has been instructed to protect his password from unauthorized users and the passwords used by qualified Chemet Labora-tory technicians are not documented.
The following technicues were used to control, prepare, analyze and report the isetopic analysis of each sample measured by the LEAS in the Chemet Laboratory.
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(1)kSamples are received from the production areas accompanied by an
-analytical request form containing a preprinted sample number. l
-" Sample numbers are manually input to the three LEA computer systems. - *
. (2) Samples are man.ually transported to a work station where the samples are queued in groups of twelve on a tray and the sample numbers and tray numbers are input to tne HP-87 computer system.
(3) Each of the samples is prepared for analysis by weighing,
. oxidation and dissolution of appropriate sample quantities.
Approximately 8.5 ml of dissolution liquor is placed in prenumbered counting tubes The counting tubes are stoppered and the tube numbers entered into the HP-87 computer system. .
(4) The counting tube numbers is entered into the HP-9825 computer -
system and the tubes are inserted into pr'oper sample changer,
. locations. After assuring that measurement parameters are correctly input to the LEA, the technician starts the automatic analytical sequence that is performed in the following manner; (a) Measures calibration verification standards if it has been more than four hours since the last verification was performed.
. (b) Measures the twelve prepared process samples for(gamma counts emitted from the U-235 and U-238 isotopic.
(c) Measures verification standards to assure th'e system is still in control after measuring process samples.
(d) Analyzes data and prints results an , paper tape. f. Auto-matically transmit calculation values to the HP-87'for each of the 12 process samples measured.
(5) The HP-87 automatically cenerates an isotopic measurement report.
This report contains the HP-9S25 calculated isotopic values that have been corrected for bias generated during sample preparation.
(6) A qualified analytical technician transmits the .HP-87 data for process samples and standards, to the LMCS system via _a menu selection technique. The corrected data from the HP-87 are auto:n.tically transferred to the LMCS computer system by this procedure and generates a transmission report of a'll pertinent measurements data.
(7) The LMCS. corrects the HP-87 data for sampling bias and issues a final corrected isotopic report for each process sample analyzed.
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- (8) A qualified LEA measurement technician checks the LMCS repo9t dai.a
,and r.ransmits'.the data to the requestor of the sample results.
No violations or deviations were observed in this area.
' d. Standard Operating Pr,ocedures 50P The licensee uses the following types of approved procedures to perform routine laboratory measurement and control functions.
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(1) The Chemical, Metailurgical and Spectrochemical CM&S procefures
. are detailed operating instructions for each type of measurement performed in the Chemet Laboratory. l (2) Calibration and Operating Instructions COI contain information - I and instructions relative to system calibrations, data analysis
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and reporting criteria.
(3) Station Corgrol Plans SCP provide operating instructions and ,
additional performance steps for the technician. .
A review of several SOPS associated with the Chemet Laboratory LEA rneasurements was conducted during this inspection. The licensee was judged to be following the requirements of the following procedures.
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. ('1) CK&S - 5.2 9 5, Revision 10 T , Determination of Weight Percent '
U-235 In An , Acid Media by Gamma Spectrometry dated August 6, 1982.
(2) SCP-400, Revision 4, Isotopic and 0/V Gravimetric Techniques, dated June 14, 1984.
(3) COI-010, Revision 1, Standard Preparation, Certification, Storage and Usage, dated September 30, 1982. I Quality Notice No. F-0-1075, Revision 0, Certification of (4) QN Standards RIP 001 - RIP 007, dated October 3,1979. ,
(5) CFAS - 5.2.9.6. Revision 3, Determination of U-235 in Solution of j Variable Uranium Concentrate dated August 24, 1982. l No violations or deviations were observed in this area. ,
- e. Replicate Measurements and Control Charts ,
The licensee is meeting the requirements of 10 CFR 70.57(b)(11), for '
the LEA systems, by maintaining a ,ccmputer based control chart system. '
Data f rom weekly measurements e.f standards are placed in the computer
l 6 , r data bank for use in calculating measurement bias associatpd with each NDA enrichment analyzer system. These computer calculations of control Hmits 'are based upon minimum of two measurements per week and at least chirty measurements of ' each standard on each measurement system.
Normal'ly these calculations encompass two to three hundred measurements of each standard on each NDA system.
The inspectors review of 1,197 control chart data measurements of control standards indicated that 104 (9%) items exceeded the 0.05 alarm control limits. and only one measurement exceeded the 0.001 control limits. All measurements exceeding the 0.05 and 0.001 control limits were investigated as required. Documented results of these investi-gation are being maintained.
No violations or deviation were noted in this area.
- f. Training Training of coerators for LEA operations is based upon criteria -
specified in . ANSI /ASME 45.2.6-197( Oualification of Inspection, Examination, and Testing Personnel for Nuclear Power Plants In addition, the Laboratory Enrichment Analyzer operators are trained by specific isotopic procedures, including FAS - 5.2.9.5, Revision 10, i Determination Of Weight Percent U-235 In An Acid by Gamma Media by Gar.ma Spectrometry Each analyzer operator is required to analyze }
- standards to within specified tolerances. The results of test data is ,
' evaluated by a . computer system for certification. Each operator is .
certified for three years, but must rerun the test standards every six months. Four operators are now certified to perform all operations of enrichment analysis by LEA technique in the facility Chemet Laboratory.
Training tests, results and operator certifications are documented as required.
No violations or deviations were observed in this area. ...
- 4. Physical Inventory - Independent Measurements 85211 Limited site time expended during this phase of the inspection prevented a thorough analytical evaluation of each LEA system in the facility Chemet Laboratory. A tentative check on the quality of measurement performance was achieved by submitting, four samples of production containers which had previously been measured for isotopic content by the LEA systems for measurement. The results of this data, shown in Table II, indicate no significant deviations between the original isotopic measurement and the remeasurement isotopic values.
No violations or deviations were noted in this area.
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. 5. Worker Concerns Relative to Laboratory LEA Enrichment Measurements' 93700' This part.of this inspection was conducted during the week of December 3-7, !
1984 Worker concerns in the following areas were examined during this inspection. ;
- a. Concern thet the low enrichment analyzer LEA Computer HP-9825 was .
programmed to accept out-of parameter cata vnd thereby produce !
erroneous analytical results of samples analyzed. '
This concern was examined by physical examination of required input, data to the system, discussions of operational procedures and tech-niques with laboratory technicians and supervisors, discussions of software program controls with the system , programmer and a physical ,
examination of portions of the software program associated with .
operating parameters that are used by the computer to analyze the raw -
analytical data. As a result of these examinations the following information, relative to system measurement controls, was revealed.
(1) Based upon' reviews and evaluations of operating criteria, measure-ment control limits are routinely changed and inserted into the computers data bank for use in routine evaluations of measurement data. __ _
(2) Control limit data are stored in a . data file that is ,secessible. by passwords which are controlled by one incividual. Individual
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passwords are assigned to those who work in the wet chemistry part of the Chemet Laboratory.
(3) The system is programmed to reinitialize. the measurement para-meters and requires a recalibration and verification measurem'ent each time a verification standard exceeds its accepted control limit value. [ach set of recalibration and verification measure-ment data performed is automatically documented by , printing on paper tape and transferring the measurement data to another laboratory computer system for further processing of the data.
(4) All changes to the measurement parameters are. automatically printed on paper tape and transferred to other computer systems to
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become archive recores.
. As a result of these examinations, the inspector determined that the LEA computer sof tware program,' is not programmed 'to accept out-of- -
parameter data. The program is reasonably protected from unauthorized changes and is designed to permit changes of operating parameters, including standards control limits that do influence the values of analytical measurements, to be input'to the system.
Werker concerns in this area were not substantiated.
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- b. Concern that laboratory personnel were violating procedures by not recording required isotopic data on worksheets and that GE management had shisled NRC inspectors by saying the LEA: calibration. log book,was not an official record required by procedure.
This worker concern was examined by discussions and interviews with all levels of laboratory personnel and a physical examination of historical procedures and archive measurement control data.
. This examinatio.n revealed that Station Control Plan, SCP-401 specified that LEA calibration logs .were to be used to record calibration measurement data during the period from April 25, 1979 to September 15, 1983 and that LEA calibration measurement data were not always docu-mented on these calibration log sheets The inspector's review .
indicated that the Station Control Plan, SCp-401 was not a procedure -
which was used to implement NRC requirements. Rather, the Jog 'was used to provide GE with a rapid indication of the status of equipment and thus precluded the need to periodically examine the :omputer tapes As a result, the irlspector concluded that GE management had not provided incorrect information to NRC inspectors concerning whether this record was required during the inspection documented in report 70-1113/84-05 in that the inspector's questions were directed to those procedures required by NRC. - -
The inspector concluded that statements made by the concerned worker
. were partially correct in that for a period of time the calibration' log was not maintained. However, this was not a violation cf NRC require-ments, since the Station Control Plan, which specified the maintenance of this log, was not required by NRC.
- c. Concern that the floor of the room in which the LEA measurement syst'em is located in contaminated with SNM and that the contamination is embedded in the floor tile and the cracks between floor tiles.
This concern was examined by physically testing the levels of'contami-nation in the room,. reviewino current and historical procedures to
- determine the level of acceptability of contamination for the site, the facility responsibilities for detecting and responding to levels of contamination, reviewing historical documentation of the contamination levels within the Chemet Laboratory and observing the licensees actions for coping with contaminated areas determined to exceed Plant Action Limits PAL for SNM contamination. As a result of these examinations the following information was revealed.
(1) Of the eighteen measurements performed, six rneasurements exceeded PAL for fixed contamination level and three measurements exceeded PAL for smearable contamination levels.
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(2) .7he licensee procedures do not provide clear and concise 3uide-
,_ lines for prevention of contamination within the LEA measurement
. . , room.
(3) The fact that contamination within the room was visible, indicated that the licensee had failed to follow approved procedures which require: (a) activities which produce contamination that exceeds PAL shall not be undertaken; (b) spills must be cleaned up immediately; and ',(c) equipment must be wiped clean of visible contamination. ,
(4) Wee kly radiation monitoring measurements as employed by the facility rad safety program exhibited weakness in the system, in that: ,
(a) A minimum of five rad safety measurements in the Chemet
. Laboratory are required and the locations of these measure-ments are left to the discretion of the measuring technician.
(b) There-is no rad safety program employed for measuring fixed -
levels of contamination in the Chemet Laboratory.
(5) In order to reduce the levels of contamination to acceptable Pals, during the inspection the licenfee removed and replaceo several floor tiles, cleaned equipment and some room walls with caustic .
cleaner and repainted some wall surfaces and cleaned equipment '
cabinets.
The failure to follow procedures to cleanup visable contamination is a violation 84-15-01 . .
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