ML20135H581
| ML20135H581 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/18/1985 |
| From: | Felton J NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Ratner M RATNER, M.G. |
| References | |
| FOIA-85-598 NUDOCS 8509240033 | |
| Download: ML20135H581 (3) | |
Text
UNITED STATES 8
NUCLEAR REGULATORY COMMISSION l
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WASHINGTON, D. C. 20555 SEP 16125 b
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Mozart G. Ratner, P.C.
1900 M Street, NW Suite 610 IN RESPONSE REFER Washington, DC 20036 TO F01A-85-598
Dear Mr. Ratner:
/
This is in partial response to your letter dated August 23, 1985, in which you requested, pursuant to the Freedom of Information Act (FOIA), copies of six specified records regarding inspection repnrts.
The documents listed on the enclosed Appendix A and a portion of the record listed on the enclosed Appendix B are responsive to your request and are being placed in the Nuclear Regulatory Commission's (NRC) Public Document Room (PDR),
1717 H Street, NW, Washington, DC 20555. You may obtain access to these records by presenting a copy of this letter to the PDR staff or by requesting PDR folder F01A-85-598 under your name.
The two attachments to the record listed on Appendix B contain information which identifies procedures for safeguarding licensed special nuclear material at a licensed facility or plant. This infonnation is considered comercial or financial (proprietary) information pursuant to 10 CFR 2.790(d) and is being withheld from public disclosure pursuant to Exemption (4) of the F0IA (5 U.S.C. 552(b)(4)) and 10 CFR 9.5(a)(4) of the Commission's regulations.
Pursuant to 10 CFR 9.9 of the NRC's regulations, it has been detennined that the information withhel_d is exempt from production or disclosure, and that its production or. disclosure is contrary to the public interest. The persons responsible for this denial are the undersigned and Mr. John G. Davis, Director, Office of Nuclear Material Safety and Safeguards.
This denial may be appealed to the NRC's Executive Director for Operations within 30 days from the receipt of this letter. As provided in 10 CFR 9.11, any such appeal must be in writing, addressed to the Executive Director for l
Operations, U.S. Nuclear Regulatory Comission, Washington, DC 20555, and should clearly state on the envelope and in the letter that it is an " Appeal from an Initial FOIA Decision."
l The review of additional records subject to your request has not been completed. We will notify you upon completion of the review.
Sincerely,
>A.
. M. Felton, Director RATPER 85-598 PDR Division of Rules and Records Office of Administration
Enclosures:
As stated s.
Re: F01A-85-598 APPENDIX A RELEASED RECORDS 1.
05/13/85 Ltr from Barr to Lees, subject: Report No. 70-1113/85-07, (1 page) w/ enclosed:
1.
70-113/85-07 Inspection Report (6 pages) 2.
07/01/85 Ltr from Barr to Lees, subject: Report No. 70-1113/85-05, (2 pages) w/ enclosed:
1.
70-1113/85-05 Inspection Report (11 pages)
(Please Note regarding document 2, the correct date is 7/1/85.)
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i Re: F01A-85-598 APPENDIX B PORTIONS OF RECORD DENIED - FOIA EXEMPTION (4) 1.
06/24/85 Letter from Vaughan, GE to Grace, Sub,iect: Fundamental Nuclear Material Control Plan Revisions (1 page) - RELEASE
- a. : Listing of Changes (1 page)
(Withheld, Exemption (4))
- b. :
Procedures for Safeguarding Licensed Special Nuclear Material-(7 pages)
(Withheld, Exemption (4))
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I ATLANTA.SEDROI A 30123 Gene..l Electric Company MM iI ra ATTN: Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:
SUBJECT:
REPORT NO. 70-1113/85-07 On April 14-19, 1985, NRC inspected activities authtrized by NRC License No. SNM-1097 for your Wilmington facility. At the ccnclusion 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.
Sfithin the scope of the inspection, no violations or deviations were identified.
In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures will be placed in the NRC Public Document Roos unless you notify this office by telephone within 10 days of the date of this letter and submit written application to withhold information contained therein within 30 days of the date of this letter.
Such application must be consistent with the requirements of 2.790(b)(1).
Should you have any questions concerning this letter, please contact us.
Sincere
[
~ /g Kenneth P. Barr, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards
Enclosure:
Inspection Report No. 70-1113/85-07 cc w/ enc 1:
l C. M. Vaughan, Manager Regulatory Compliance m 'r '~
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$$ 13 N Report No.: 70-1113/85-07 Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.:
SNM-1097 Facility Name: Nuclear Fuel Manufacturing Inspection Conducted: April 14 - 19, 1985 Inspector:
'I M I!/ff J. B. Kahl
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Datie Signed Approved by:
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$/l/f6 E. J. McAlpile, Section Chief Date Signed Division of Radiation Safety and Safeguards SUMARY Scope: This routine, unannounced inspection entailed 38 inspector-hours on site in the areas of management organization and controls, operator training /
retraining, nuclear criticality safety and operations review.
Results:
Of the four areas inspected, no violations or deviations were identified.
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REPORT DETAILS I
I 1.
Licensee Employees Contacted
- ). E. Bergman, Manager, Manufacturing
- W. W. McMahon, Manager, Quality Assurance
- C. M. Vaughan, Manager, Regulatory Compliance
- W. C. Peters, Manager, Nuclear Safety Engineering R. L. Torres, Manager, Radiation Protection
- J. H. Bradberry, Manager, Security and Emergency Preparedness
- R. G. Lewis, Supervisor, Radiation Protection J. R. Watkins, Acting Manager, Powder Production
- E. A. Schaefer, Senior Engineer, Chemical Lab
- D. W. Brown, Manager, Uranium Recycle Operation
- T. P. Winslow, Manager, CHEMET Laboratory S. W. Dale, Manager, UPMP Program
- B. 5. Dunn, Licensing Administrator j
- R. H. D. Foleck, Senior Specialist, Licensing Engineering G. M. Bowman, Senior Nuclear Safety Engineer
- P. S. Stansbury, Senior Nuclear safety Engineer J. T. Taylor, Senior Nuclear safety Engineer F. G. Welfare, Senior Nuclear Safety Engineer H. W. Webb, Senior Nuclear Safety Engineer
- S. P. Murray, Senior Nuclear Safety Engineer R. J. Keenan, Nuclear Safety Engineer I
Other licensee employees contacted included two technicians, nineteen operators, four security force members, and two office personnel.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on April 19, 1985, with those persons indicated in paragraph 1 above.
The licensee stated that design, process and operational information associated with the Uranium Process Management Project (UPMP) would be considered company proprietary l
under the terms of 10 CFR 2.790. The inspector acknowledged their request.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Management Organization and Controls (88005) s.
Organizational Structure The inspector, verified that the licensee's key positions with safety related responsibilities (area manager, criticality safety function, radiation safety function, radiation protection function, environmental l
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- function, and regulatory compliance function) were established as described in the license application. h designated i
responsibilities of the key positions agreed with or exceeded those j
depicted in the license application. h inspector verified that the l
qualifications of the personnel filling the required key positions met or exceeded the specifications described in the license application.
No violations or deviations were identified.
l b.
Procedure Control i
The inspector verified that the licensee has established and is saintaining a system for issuing and controlling procedures. Verifica-i tion was made that procedures were reviewed and revised, if necessary, at least annually.
Document Control issues procedure changes to designated recipients and maintains a system to assure that only 1
current procedures are avaijable to operators.
A review of several j
operating procedures during tours of the operating areas showed that operating procedures were current and available to operating personnel.
No violations or deviations were identified.
1 c.
Reviews and Audits 1
The inspector verified that the licensee has implemented programs for I
inspecting and auditing facility operations on a daily and quarterly basis.
The radiation protection technicians inspect operations continuously on a shift basis.
The nuclear safety engineers (criticality safety and radiation safety) perform comprehensive audits of operations quarterly. The nuclear safety audits usually take one to two weeks.
Verification was made that inspection and audit findings are immediately brought to the attention of operating and nuclear safety management.
Items identified by the shift inspections are reviewed by the nuclear safety manager. Generic issues and corrective actions to prevent recurrence are reviewed, discussed and tracked by the operational radiation safety committee.
Items identified by the quarterly audits are communicated to operations for 1 mediate corrective action. A review of the audit findings by the regulatory compliance annager identifies potential regulatory noncompliance.
hse are transmitted to management requesting a response as to final corrective actions. A review of the records showed that investigations were performed to determine the cause of the potential noncompliance and actions were taken to prevent recurrence. A licensee representative l
stated that they have initiated a program through management and operator awareness of examples of potential noncompliance to reduce the number l
of items identified by their internal audit and inspection program.
I h inspector reviewed the annual external audit results performed by the licensee's corporate Nuclear Safety Assurance, Quality Assurance and Reliability Operation from San Jose, California. h licensee has implemented a tracking system to assign responsibility and complete remedial action for each findings until closure.
3 I
i No violations or deviations were identified.
d.
Safety Committees The inspector reviewed the meeting minutes of the Wilmington Safety Review Committee (W5RC) and the Operational Radiation Safety Committee.
The inspector verified that the activities of the WSRC net the require-ments of the license application. Action items were identified and tracked until their closure.
The Operational Radiation Safety Committee meeting minutes showed that manufacturing operational i
equipment upgrade items were identified with assigned responsibilities for actions, tracking, reporting and completion target dates. It was apparent that operational problems were identified with committee assistance for remedial action to reduce sources of airborne and surface contamination.
No violations or deviations were identified.
1 5.
Operator Training / Retraining (88010)
The inspector reviewed the licensee's program for providing site specific training for NRC inspectors and discussed the procedures for NRC inspectors to enter the plant and secure badging for unescorted access to the control area.
The inspector verified that control area operators were provided i
nuclear safety retraining as required by the license. The agenda or scope of the nuclear safety training was inspected during an inspection in January 1985 (Inspection Report 85-02).
During tours of the process areas discussions with individuals revealed that they had received nuclear safety training within the past year.
No violations or deviations were identified during this inspection.
6.
Nuclear Criticality Safety (88015) a.
Facility Modification and Changes The inspector reviewed the following licensee procedures for performing nuclear safety reviews:
P/P 40-5, Nuclear Safety Review System NSI E-1.0, Nuclear Safety Record NSI E-3.0, Nuclear Safety Review Requests NSI E-4.0, Criticality Safety Analysis Methods and Verification The inspector concluded the procedures were adequate. Several nuclear safety review packages were examined by the inspector.
Verification was made that the records contained all the documents required by the licensee's procedures. The inspector verified that acceptable methods i
were used in the analyses and that the analyses and results were verified by an independent reviewer. Supporting calculations and data were contained in the packages. The inspector verified that preopera-tional audits had been performed prior to issuance of a final approval by nuclear safety and that a Nuclear Safety Release / Requirement (NSR/R)
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was issued to operations.
During tours of the process area the inspector verified that NSR/Rs were available with the operating i
procedures. No violations or deviations were identified.
b.
Criticality Alare System The inspector reviewed the calibration procedure with a licensee representative and discussed the details of the weekly source check and the annual calibration. A technician demonstrated the technique used for establishing the source-to-detector distances when calibrating the t
criticality warning system detectors.
The inspector concluded the procedure was adequate. An examination of the records showed that the detectors were calibrated on an annual basis.
No violations or i
deviations were identified.
i' c.
Storage and Handling Special Nuclear Material (SW)
During tours of the process and storage areas the inspector verified that containers of SM were stored in accordance with the licensee's procedures that containers of material were not placed in unauthorized locations. The presence of unsafe geometry containers were authorized and properly controlled through administrative or mechanical controls.
No violations or deviations were identified.
I d.
Ventilation Ducts l
l Licensee representatives stated that a number of years ago a surveil-lance procedure was implemented to survey horizontal portions of ventilation ducts on a monthly basis for accumulations of SNM.
They i
stated that only small quantities of SNM has been detected at the elbows of some ducts and that accumulation of material has not been a 4
problem. As a result of an NRC notification that this may be a problem
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at uranium processing plants, an evaluation was performed to assess the j
potential at the plant and a special survey was conducted of the i
suspect areas.
Negative results were found.
No violations or deviations were identified.
7.
Operations Review (88020)
During tours of the control areas the inspector talked with operators 1
a.
to determine their awareness of the location of operating procedures and the basic nuclear criticality safety requirements. Operators knew where the procedures were located and were familiar with nuclear 1
criticality safety requirements. Operating personnel stated that they had received nuclear safety training within the past year. Observation i
of workers' activities showed that work was being performed in accordance with operating procedures.
The inspector verified that j
gafety equipment required tw licensee procedures and license conditions was present as required. No violations or deviations were identified.
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5 b.
Uranium Process Management Project (UPMP)
The inspector toured the UPMP area and discussed the operating status with licensee representatives.
Installation is essentially complete except for some process and nuclear safety control. systems.
Licensee representatives stated that all systems will be thoroughly checked out prior to introduction of licensed material into the system. Also, each process will be started up individually and debugged prior to startup of another process.
This was - confirmed by the individual in the nuclear safety function who is responsible for authorizing introduction of licensed material.
Licensee representatives e stirra ted four to five weeks before introduction of licensed material into the system.
No violations or deviations were identified.
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UNITED ST.^.TEs NUCLEAR REGULATORY COMMISSION O'
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ATL ANT A. GEORGI A 30323 s,...../
JUL 011985 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. 70-1113/85-05 On April 15 - 19, and May 24, 1985, NRC inspected activities authorized by NRC License No. SNM-1097 for your General Electric Wilmington Facility.
'At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.
The inspectior, was ar. examinatior. of activities conductec uncer your liter.se with respect to radiation safety and compliance with NR~ regulations and the conditions of your license.
It included selective examinations of procedures and representative records, interviews with personnel, and direct observations by the inspector.
Within the scope of the inspection, no violations or deviations were identified.
Your attention is invited to an unresolved item identified in the inspectier report.
This matter will be pursued during future inspe:tiens.
In accordance with 10 CFR 2.790(a), a copy of this lette-and the er.eiosces will be placed in NRC's Public Document Room unless you nctify this of fice by telephone within ten days of the date of this letter and submit writte-application to withhclc information contained therein wit *ir thirty cays of thE cate of the letter Such application must be consistert d
w th the recuire erts of 2.790(b)(1).
Should you have any questions concerning this letter, please contact us.
Sincerely, KennethP.Barr,Cnief.,fr Nuclear Materials Safety.
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and Safeguards Braa.ch Division of Radiation Safety andSafegu4rds
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Enclosure:
(See pa,ge 2)
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General Electric Company 2
Enclosure:
Inspection Report No. 70-1113/85-05 cc w/ enc 1:
C. M. Vaughan, Manager Regulatory Compliance
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a JUL 01805 Report No.: 70-1113/85-05 Licensee: General Electric Company Wilmington, NC 28401 Facility: General Electric Wilmington Facility Docket No.:
70-1113 License No.:
SNv.-1097 d
Inspection Conducted: April 15 - 19, and May 24, 1985 Inspectors:
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7 WV5' D. M. ~ Montgom'ery
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T2te Signed Accompanying Personnel:
D. M. Collins D. Sly 6 -/3 - 85 Approved by:
D. M. Collirs, Crief Dan S grec Emergency Prepareaness and Radiciogical Prctection Branch Division of Radiation Safety and Safeguarcs SUM.M.ARY Scope: This routine unannounced inspection involved 60 inspe:t:--houes or, site in the areas of radioactive waste management, environrnenu' protection, confirmatory measurements, bioassay, and independent inspectier ef fort.
Results:
No violations or deviations were identified.
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REPORT DETAILS 1.
Licensee Employees Contacted
- J. Ber(Pan, Manager, Fuel Manufacturing "W. McMahon, Manager, Quality Assurance "R. Hawk, Manager, Operational Planning
- C. Vaughan, Manager, Regulatory Compliance
- W. Smalley, Manager, Environmental Protection
- R. Pace, Manager, Fuel Support
- P. Winslow, Manager, CHEMET Laboratory R. Torres, Manager, Radiation Protection
- P. Stansbury, Senior Nuclear Safety Engineer
- S. Murray, Senior Nuclear Safety Engineer
- T. Crawford, Environmental Protection Engineer "B. Dunn, Licensing Administrator B. Beane, Senior Engineer, Fuels Fabrication A. Shaefer, Senior Engineer A. Cameron, Day Shift Foreman
- Attended exit interview 2.
Exit Interview The inspection scope and findings were sum.T.arized on April 19, 1985, with those persons indicated in Paragraph 1.
The inspectors described the areas inspected and discussed the inspection findings.
One unresolved item
- was identified in the area of operation and raictenance of sentilation systems (Paragrapn 10).
An inspector follo.up iter ir the area cf e;uent sample analysis comparisons between NRC and the licensee (Paragra:" 7) was identified.
Licensee representatives acknowledged the ir.spe::crs' findings.
3.
Procedores (88035, 88045)
Chapter 2.7 to Part I of the license application requires written procedures to be. established, implemented, and maintained covering various areas including Radiation Safety, Radiation Protection and Environmental
- Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations.
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2 Protection functions.
The inspector reviewed selected portions of the following Environmental Protection Instructions (EPIs), Nuclear Safety Instructions (NSIs), and other procedures:
EPI 0-1.0, Operation of Final Process Effluent control Stream, Rev. 2, June 1, 1984 EPI 0-2.0, Environmental Sampling of the Final Process Lagoon System and Site Dam, Rev. 4, January 7.,1985 EPI 0-4.0,' Sample Collection and Analysis of Aeration Basin Monitoring Wells, Rev. 1, June 1, 1984 EPI 0-6.0, Stack Sampling Program, Rev. 8, October 9, 1984 EPI 0-7.0, Soil and State Split Sampling Programs, Rev. 6, February 12, 1985 EPI 0-8.0, Sample Collection from Monitoring Wells, Rev. 9, i
February 12, 1985 EPI 0-9.0, Environmental Ambient Air Sampling Stations, Rev. 1 June 1, 1984 NSI 0-4.0, Nuclear Safety Engineering Radiation Protection Instru-mentation, Rev. 20, August 24, 1984 ATM 4.1.21.2, Detere'natior, of Uraniue ir. Wa:e-by X-ray Flue escen:e,
Rev. 7, March 4, 1955 ATM 1.2.21.10, Measurement of Uranium in U-ine using the Scintrex UA-3 Analyzer Method, October 6, 1982 The inspector noted that the procedures were tsing revie.ed, updated, and approved by appropriate staff and managemer.t as required by administrative requirements.
No violations or deviations were identified.
4.
Records (88035, 88045)
The inspector reviewed selected portions of the following records:
(1) Sampling and analysis results of the Environmental Radiological Monitoring Program described in Table 5.1 of Part I of the license application, June 1984 - March 1985.
l
3 (2) Stack sampler particulate-filter sampling and analysis results for the following stacks:
4 CHM 50546 - Exhaust for Main Chemical Area (FMO)
CHMSFOX - Exhaust for Main Chemical Area (FM0X)
UPSE000 - Uranium Processing System Exhaust INEXBURN - Incinerator Exhaust (3)
In-vivo Lung Counter Records, 1/3/84 - 4/17/85 i
' Daily Performance Checks Background Checks (4) Results of spiked analysis of urine samples 3/6/85 - 4/17/85 (5) Quality Notice - Qualification for the use of the Scintrex UA-3 Analyzer, June 29, 1982 (6) Calibration records and performance checks for the following instruments, July 1984 - March 1985:
Harsha. TASC-12 Alpha / Beta Counting Syster Liquid Uranium Monitor Fluorimeter No violations or deviations were identified.
5.
Licensee Audits The inspector reviewed the licensee's exterr.a1 anc internal audit program as related to the radioactive waste managerent ano environmental protection programs.
The external audits were conexted by the Quality Assurance and Reliability Operation (QA&RO) Group which was part of the licensee's corporate structure but independent of the Wilmington Manuf acturing Department.
External audit findings were documentec either as Corrective Action Requests (CARS) or Advisories.
CARS required a formal committed corrective action and committed prevention actions from the responsible area manager.
A ' tracking system was maintained to followup on CARS.
Advisories did not require a formal response to the QA&RO, however, they were normally re-examined during the next audit.
Environmental Protection Internal Audits were also referred to as " Regulatory Compliance Audits."
Personnel under the direction of the Manager of the Environmental Protection function performed the environmental protection audits, however, they did not report to the production organization and had no direct responsibility for the function and area being audited.
Audit findings were documented and communicated to the Area Manager who was responsible for corrective action commitments.
Corrective action items were tracked until their closure.
The inspector reviewed QA&R0 Audit Report No. 84-02 (dated 6/14/84) conducted May 7-31, 1984.
There were no corrective action requests identified in the areal of environmental protection or waste management.
1 4
Approximately five advisories were identified in the areas of records management, documentation, quality assurance, and sample analysis reporting.
Audit results were reviewed by management and appropriate followup actions were taken.
The inspector also reviewed Environmental Protection (EP) Audit 8405, EP Audit 8406, and EP Audit 8501.
The inspector noted that appropriate management initiated corrective action on the " areas of concern" identified in the audits.
No violations or deviations were identified.
6.
Environmental Protection (88045) a.
The inspector reviewed the licensee's environmental protection program with respect to the requirements of Chapter 5 to Part I of the licensee's application.
The environmental protection program had been changed since the last inspection due to the issuance of the renewed license dated June 29, 1984.
Basically, - the new program added additional sampling analysis, and other requirements.
The inspector determined that procedures were in place which established criteria for meeting requirements for sampling, data recording and storage, reporting of results, calibration, measurements and analysis, and actions to be taken in the event analysis results exceed or deviate from established limits.
The inspector examined and reviewed selected records of the environmental sampling and analysis program for the period July 1984 to March 1985.
The review included an examination of air monitoring, surface water, nitrate waste stream, groundwater, soil and vegetation sampling records.
The inspector noted that the licensee had identified an ite-ir t*'s prograft requiring corrective action which had been accomplished.
No violations or deviations were icentified.
b.
During the record review prc:ess, the inspector also observed that the groundwater WT-4 series wel' was dry throughout 1984.
The inspector noted that the licensee took the appropriate corrective actions as required by Section 5.2.4.2 of Chapter 5 to Part I of the license application (effective June 29, 1984) which requires the licensee to initiate an investigation within 14 working days after the end of three consecut we dry sampling periods and to initiate a corrective action program resulting in the renewal of sampling.
On December 12, 1984, a new Wi-4 well was installed.
The licensee experienced no problems with the new well from December 12, 1984, to March 1985.
All records of investigations and corrective action programs were in order.
No violations or deviations were identified.
c.
Section 5.2.1.2 of Chapter 5 to Part I of the license application requires installation and operation of ambient air sampling stations in the prevailing wind directions downwind of the principal point of ef fluent release, near the fenced property line.
The inspector and a licensee representative examined and observed the operation of the four
5 ambient air sampling stations located in the south, southwest, northeast, and southeast quadrants as described in Figure 5.3.
No violations or deviations were identified.
7.
Quality Control of Analytical Measurements (86045, 84844)
The inspector determined that no substantial changes had been made in the program for quality control of radioactivity measurements.
The licensee's program had the capability to identify deviations or deficiencies in the analysis of environmental and effluent samples by automatically checking each determination, running standard yield determinations between sample counts and checking counter background on each shif t.
Counter data was automatically entered into a computer logging system programed to identify deviations.
Analyses which either exceeded or deviated from established boundary values were repeated for serification.
The inspector determined that radioactivity counting standards used by the licensee were traceable to the National Bureau of Standards (NBS).
NBS traceable certificates for the standards were available on-site.
The licensee used several laboratories to perform the radiological analyses for the environmental radiological monitoring program.
Isotopic analyses on the particulate filters from the ambient air monitoring stations were performed by a vendor.
The gross alpha and gross beta analyses for the various liquid samples were performed by a laboratory that is part of the licensee's corporate structure.
Gross alpha ano beta analyses of stack samples of airborne discharges were performed on-site.
Other environmental samples weee analyzed in the CHEMET environmental labo-atory for uranium content.
Samples with trace levels of uranium were analyzed by fluorimetry.
j lhe inspector reviewed ~the fluorimeter calibration curve and QC data log for January-March 1985.
Samples with higher levels of uranium were analyzed by using a Liquid Uranium Monitor (LUM) which basically uses an X-ray fluorescence process for uranica content analysis.
Spiked samples with known amounts of uranium were run daily on the LUM and an average recovery of the spike was determined.
During this inspection samples were collected for confirmatory measurements to evaluate the licensee's capability for measuring radioactivity in the various e,ffluent streams as required by license conditions.
Three liquid samples f rom the waste treatment f acility were collected and split with the licensee on April 18, 1985 (V-108 in, V-108 out, V-104 out).
Additionally, two stack sampler particulate filters (CHM 50546 - 4/14-15/85, UPSE000 -
4/12-13/85) that had been analyzed recently by the licensee were collected These samples will be analyzed by the U.S. Department of Energy's Radio-logical and Environmental Sciences Laboratory (RESL) for the NRC.
The inspectors requested the licensee to provide the results of their analyses to the NRC.
The results will be reviewed during a subsequent inspection (70-1113/85-05-01).
6 8.
Bioassay Program (92706)
The inspector reviewed the quality assurance program for the lung counting system and analysis of uranium in urine (urinalysis program).
The inspector reviewed operating procedures for calibration and routine operations.
The inspector noted that the lung counter was calibrated annually by the company contracted to operate the system.
Periodical performance checks and background counts were made to ensure the operability and verify calibration status.
The inspector noted that the urinalysis program did not include the analysis of spiked, " blind" samples and/or replicate analyses as part of the quality control program.
Although the licensee periodically analyzed urine samples spiked with known quantities, the program had not been incorporated into plant procedures and no formal review of the data was apparent.
The inspector noted that there were no specific license requirements regarding quality control in this area.
A licensee representative stated that similar findings had been identified in QA&R0 Audit Report No. 84-02 and that this area.was being reviewed.
The inspector reviewed records associated with the testing of the Scintrex UA-3 Analyzer and discussed the operational history with CHEMET Laboratory staff including the manager.
Prior to procurement of the analyzer, a licensee representative visited a commercial laboratory that was using the Scintrex UA-3 for analysis of uranium in urine and determined that the instrument was acceptable.
Following procurement of the Scintrex UA-3 Analyzer, the instrument and chemical procedure for analysis of uranium in urine was tested.
Although initial testing at a General Electric Laboratory in Schenectady, NY was not successful, subsequent testing at the licensee's facility dem nstrate:' the instrument's capability to make accurate measurements in urine.
The licensee's testing of this method and instrument was consistent witt good labo-atory practice.
A Quality Notice,
" Qualification for the use of the Scintrex Analyzer" was issued on June 29, 1982, prior to its use for bioassay analyses.
This notice documented the testing and acceptatility of the instrument for measuring uranium in urine at an acceptable lowe-limit of detection.
The inspector provided three spiked, " blind" urine samples and a blank urine sample to the licensee for analysis.
These samples were prepared by the U.S.
Department of Energy's Radiological and Environmental Sciences Laboratory (RESL).
These samples were analyzed for uranium by the licensee using the licensee's approved procedure which utilized a Scintrex UA-3 Analyzer.
The results were erratic and, with the exception of sample #1, were higher than the known values by as such as a factor of 40.
The licensee reported a value of 56 pgm/L compared to a known value of 70 pgm/L for sample #1.
Since a review of licensee quality control data did not show similar problems, it appeared that the storage and/or preservation of the spiked samples may have resulted in interferences that were net normally present in fresh urine samples.
The spiked urine samples were approximately seven days old and preserved with hydrochloric acid while the licensee normally holds urine samples for less than one day prior to analysis with no preservative.
Additional unknown aqueous solutions spiked with uranium were sent to the licensee for analysis using the same techniques as used for the
7 analysis of urine samples.
The licensee results for these samples were as follows:
Concentration, pom/ liter Sample Known GE*
Ratio GE/Known Blank
<1
- 1 14 15 1.07
- 2 70 77 1.10
- 3 31 32 1.03
- 4 70 82 1.17
- Average of three determinations Alt 50 ugh there were no official NRC acceptance criteria for bioassay analysis, the results were considered acceptable for this type of analysis.
The results met the draf t American National Standards Institute (ANSI)
~ criteria for bicassay measurements.
The results appeared to show a systematic high bias.
This would be conservative with respect to worker protection.
No violations or deviations were identified.
9.
Liquid and Airtorne Effluent Monitoring Instrumentation (88035)
The inspector reviewed the radioactive liquid and airborne ef fluent monitoring programs established to meet the requirements of 10 CFR 20.106, 10 CFR 20.203, 40 CFR 190, and the sections of Chapter 5 to Part I of the license application.
The inspector reviewed the licensee's procedures and methods of sampling and analysis and the licensee's procedures and records for calibration of the following counting ir.struments (covering the period July 1984 - March 1985):
Harsha. TASC-12 Alpha / Beta Counting System Liquid Uraniurr Monitor Fluorimeter No violations or deviations were identified.
10.
CHEMET Laboratory Tour The inspector toured 'the CHEMET Laboratory area and observed various laboratory operations in progress.
The inspector noted that fume hood air velocities appeared to be lower than normally encountered.
At the inspector's request, a licensee representative arranged for the measurement of the air flow for several fume hoods in the CHEMET Laboratory.
The inspector observed a licensee representative perform the air flow t
8 measurements.
The average air flow for hood #5 was approximately 55 linear feet per minute (ifpe) compared to the licensee's action point of an air flow of 80 ifpe.
Although other fume hoods met the licensee's action point, the flow rates were lower than normal.
Subsequent to the inspector's observations, the licensee determined that the main ventilation system had been changed from the east bank to the west bank in order to calibrate the air flow monitors associated with the east bank.
Either the east or west banks can be used to provide ventilation for the fume hoods and process areas.
The air flow was normally controlled automatically by process instrumentation; however, the west bank was in the manual operation mode when the switchover was made.
The manual flow settings were not adequate to provide the normal flow requirements.
A licensee representative stated that this condition lasted for 20 to 30 minutes before normal air flow was achieved.
The inspector informed the licensee that this matter would be considered as an unresolved item pending NRC review of the procedures for operation and maintenance of the venti-lation systems and air monitoring data collected during this period.
(70-1113/85-05-02)
One unreso!ved item was identified.
11.
Radioactise Gaseous Effluents (88035) a.
The licensee was required by 10 CFR 20.106 to limit the amount of radioactivity in effluents to unrestricted areas.
Chapter 5 to Part I of the license application required the licensee to process, monitor, anc cortrol radioactive gaseous effluents to meet the applicable re;;J a: cry requirements.
Tne inspector reviewed sampling and analysis logs of the stack sampler paeticulate filters for each principal radioactive effluent release p; i r.:. representing an approximately two-month period since the last inspection.
The inspector noted that records were completed, and that the required sampling and analysis of stack filters had been performed in all cases that were analyzed.
All sample analysis results reviewed by the inspector were less than action guide limits.
No violations or deviations were identified.
i b.
The inspector reviewed the Semiannual Effluent Reports pertaining to gaseous effluents for January-June 1984 and for July-December 1984 which were submitted to meet the requirements of 10 CFR 70.57.
The inspector did not observe anomalous measurement results, trends, or missing data.
No violations or deviations were identified.
c.
The inspector reviewed the high efficiency particulate air (HEPA) filtration systems.
The licensee did not perform in place D0P leak testing of the HEPA filter systems since license conditions do not
1 9
specify in place leak testing requirements.
The manufacturer of the HEPA filters provides certified DOP testing documentation on each filter by serial number.
The licensee regularly monitored the differential pressure (AP) across the filter banks.
Filters are replaced with AP values exceeded the manufacturer's ratings for the filter.
Assurance of system integrity was based on quality control during filter procurement, training of plant personnel in correct methods of filter installation, and on effluent sampling and analysis.
This filtration system reduced the potential for exposure to airborne contamination to personnel changing the filter banks.
A number of conventional systems had been replaced with this system.
Gaseous effluents were sampled continuously downstream of the HEPA filter banks.
Samples were removed at daily or weekly intervals, depending on the potential for concentrations of particulate material in the effluents, and were analyzed on-site for gross alpha activity.
No violations or deviations were identified.
12.
Radioactive Liquid Effluents (88035) a.
The licensee was required by 10 CFR 20.106 to limit the amount of radioactivity in ef fluents to unrestricted areas.
Chapter 5 to Part I of the license application required the licensee to process, monitor, and control radioactive liquid ef fluents to meet the applicable regulatory requirements.
The insp ctor selectively reviewed the NPDES Liquid Waste Release Self-Monitoring Reports for the periou June 1984 to March 1985.
In addition, the inspector selectively reviewed the periodic sampling and analysis records of continuous releases from the holding lagoons and nitrate waste streams for the same period noted above representing approximately three months of operation.
On the basis of this selective records review, the inspector determined that the required samples and analyses had been performed.
Liquid waste release records reviewed by the inspector showed uranium concentrations less than the action levels for uranium in liquid effluents.
No violations or deviations were identified.
b.
The inspector reviewed the Semiannual Effluent Reports pertaining tu liquid effluents for January-June 1984 and July-December 1984 which were submitted to satisfy the requirements of 10 CFR 70.57.
The inspector did not observe anomolous measurement results, trends, or missing data.
No violations or deviations were identified, c.
The licensee monitored liquid effluents by periodically collecting and analyzing composite samples of continuous releases from the holding (final process) lagoons tu the Northeast Cape Fear River.
Control of
10 releases was afforded by pre-release sampling and analysis of batch inputs from the quarantine tank control system to the holding lagoons which provided a degree of control over the soluble uranium input to the lagoons.
No violations or deviations were identified.
13.
Radioactive Solid Waste (88035)
The licensee was required by 10 CFR 20.203, 10 CFR 20.301, and 10 CFR 20.401 to use caution signs and other controls to limit access to radiation areas (as related to solid wastes), to follow general requirements for waste disposal, and to maintain records of waste disposal, respectively.
Section 1.7.5 of Part I to the license application authorized the licensee to treat, store, and dispose of solid wastes pursuant to 10 CFR 20.302 and 10 CFR 20.304.
Section 5.1.3 of Part I to the license application required the licensee to monitor, assay, observe action limits and report activity data on each solid waste shipment.
The inspector examined the licensee's incineration facility used to oxidize combustible solids and liquids.
The ash product was processed for uranium recovery with the unusable portion of the ash being transported to a licensed burial ground.
At the time of this inspection, the incinerator was not operating.
Solid wastes generated in the fuel manufacturing operation (FMO) were. packaged in boxes.
These boxes were assigned to controlled access hg((ing areas where they awaiteJ processing through a decontamination facility.
The decontamination operation provided the licensee a means to receive uranium for recycle, to separate wastes into combustible and noncombustible categories, and to dtcontaminate material for reuse.
After separation in the decontamination facility, the combustible wastes were packaged into 4' X 4' X 4' plywood boxes for subsequent burning in the incineration facility.
The noncomaustible wastes were packaged into 4' X 4'x 3 ' metal boxes for shipment to the Barnwell facility for disposal.
The metal boxes were DOT-approved fer retrievable storage.
The boxes were labelled appropriately in accordance with 10 CFR 20.203 and each box was marked with an identification code and number.
All waste boxes, whether the combustible boxes for on-site incineration or the metal boxes for off-site-l shipment, were stored in on-site outdoor storage areas for not less than 60 days prior to incineration or of f-site shipment.
After that time, each box was taken to a special analytical facility where sensitive radiation spectrometry was used to determine the uranium-235 content.
The storage areas were appropriately fenced and marked with caution signs.
The inspector reviewed selective records of radioactive solid waste interim storage, incineration, and shipments off-site to the Barnwell facility representing approximately a two-month period since the last inspection.
No violations or deviations were identified.
L
U GENER AL Q ELECTRIC NUCLEAR FUEL MANUFACTURING DEPARTMENT GENER AL ELECTR6C COMP ANY - P. O. 80R 740 - WetutNetON. NORTM C AROL644 34402 0
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June 24, 1985 c
g :n
-O Dr. J. Nelson Grace, Regional Director t
[5 P
U. S. Nuclear Regulatory Commission, RII r
P. O. Box 2203 Atlanta, Georgia 30301
- y C1 Dear Dr. Grace
Reference:
NRC License SNM-1097, Docket 470-1113
Subject:
FUNDAMENTAL NUCLEAR MATERIAL CONTROL PLAN REVISIONS General Electric Company hereby submits revisions (dated 6/24/85) to the Fundamental Nuclear Material Control Plan (FNMC) for the fuel fabrication facility in Wilmington, North Carolina.
Attachment I contains a descriptive listing of the changes made which do not require NRC approval prior to implementation, and contains the revised pages and applicable index pages.
Pursuant to 10 CFR 2.790(d), General Electric reauests this information be withheld from public disclosure as this material identifies General Electric procedures for safeguarding licensed special nuclear material.
General Electric personnel would be pleased to discuss this matter further with you and your staff as you may deem necessary.
Very truly yours, GENERAL ELECTRIC COMPANY, 6W
/
M Charles M. Vaughan, Manager Regulatory Compliance M/C J26 CMV bad Attachments
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cc Director, ONMSS
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