ML20153B967
| ML20153B967 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/26/1988 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8808310168 | |
| Download: ML20153B967 (7) | |
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?s. l*02 August 26, 1988 US Nuclear Regulatory Commission Document Control Desk Washington, DC 20555
Subject:
REPLY TO NOTICE OF VIOLATION
Reference:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/88-08 dated 7/27/88, received 8/1/88 Thank you for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr.
G. B.
Kuzo of you-office on May 23-27, 1988.
Pertaining to che two items of apparent noncompliance with NRC requirements in your letter, the reply to theFO items is given in the attachment to this letter.
We appreciate your inspector's comments and suggestions related to our employee safer; and radiation protection programs.
These comments and suggestic's are helpful to us in our constant ef forts to improve these progrens, ensure the continued health and safety of plant personnel, and r,sure our compliance with NRC regulations and license condition.
We also welcome further discussion with your staff on the items in your letter and in our related reply, if necessary.
Your inspection report referred to above does not contain information which we believe to be proprietary.
Sincerely, GE NUCLEAR ENERGY YW T.
Preston Winslow, Manager Licensing & Nuclear Materials Management
/sbm cc:
J. Nelson Grace NSD-I 8808310168 880826 PDR ADOCK 07001113 PDC go7 C
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4 US NRC Document Control Desk August 26, 1988 Page 1 of 6 ATTACHMENT 1 i
The information given below refers to the two items in Enclosure 1,
"Notice of Violation", from NRC Inspection Report 70-1113/88-08 dated July 27, 1988.
j i
A.
License Condition 9 of Special Nuclear Material 1
(SNM) License No. 1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part 1 of the i
License Application dated October 23 1987.
Part I, Section 2.2.1.4 of tio licensee's application for li onse No. SNM-1097 requires that radiation protection function activities be i
conducted in accordance with written procedures.
Nuclear Safety Instruction (NSI) 0-4.0, Rev. 24, j
dated August 24, 1987, requires all change room instrumentation to be inspected as prescribed by l
schedule.
Appendix A of NSI O-4.0 requires performance checks to be performed each shift and the results entered into the instrument log.
Nuclear Safety Release / Requirement (NSR/R) Control No. 1.1.23, Old Decon Room, Rev.
1, dated November 13, 1985, requires the roll up door in the Old Decon Room to remain closed except during transfer of material to and from the Old Decon Room.
Contrary to the above, the licensee failed to follow procedures in that:
1.
For the period reviewed from May 16, 1988 through May 24, 1988, performance checks of survey meters located in the men's main change room were not routinely conducted each shift.
2.
On May 23, 1988, the roll up door between the radiation controlled Old Decon Room and an adjacent uncontrolled area was not closed and materials were not being transferred to or from the room.
This is a Severity Level IV violation (Supplement IV).
i
US'NRC Document Control Desk August 26, 1988 Page 2 of 6 General Electric concurs with violation A in that internal procedures were not followed in the two examples on the dates specified.
With regard to Example 1, at the time of the inspection, the Radiation Protection function responsible for change room survey meter performance checks had recently shifted this work assignment from the individual assigned to work that shift inside the controlled area to one of several individuals assigned to work that shift outside the controlled area.
Radiation Protection work assignment sheets did not specifically include this activity.
Each individual believed the other was performing the required performance checks.
As a result, the performance checks were not consistently performed three times per day (each shift) as required.
When the violation was identified during the inspection, the appropriate NF&CM personnel were immediately notified.
On 5/24, a memo was distributed to Radiation Protection personnel clearly identifying the responsibility of these performance overchecks to a single individual on each shift.
The Radiation Protection work assignment sheets were also updated.
The most recent management overchecks have indicated there have been no further problems and full compliance has now been achieved by the above described corrective actions.
With regard to Example 2, the Old Decon Room roll up door had been opened to facilitate removal of waste boxes from the controlled area just prior to shift change.
It was apparently left open by the off-going shift.
The door was subsequently closed by the on-coming shift after the NRC inspector left the area and the appropriate NF&CM Area Manager was immediately notified, A variety of positive door controls and corrective actions have since been investigated to minimize recurrences of this situation.
On August 15, a timer and audible alarm were connected to the roll up door in addition to the existing flashing light.
If the door remains in the up position longer than a pre-established time, an audible alarm will sound.
In addition, shop operations management has initiated a series of round table discussion meetings with affected personnel to re-emphasize the requirement to keep the door closed in accordance with internal procedures.
These meetings are scheduled to be completed September 1, 1988.
Full compliance will be achieved with the completion of the above described corrective actions.
1
US' NRC Document Control Desk August 26, 1988 Page 3 of 6 B.
10 CFR 20.103 (a) (3) states that for purposes of determining compliance with the requirements of this section, the licensee shall use measurements of radioactivity in the body, measurement of radioactivity excreted from the body, or any combination of such measurements as may be necessary for the timely detection and assessment of individual intakes of radioactivity by exposea individuals.
Contrary to the.above, the licensee failed to adequately assess individual intakes of radioactivity by exposed individuals in that:
1.
For records reviewed from January 1,
- 1988, through May 27, 1988, numerous positive urinalysis results were identified for which no investigations nor uptake calculations were performed.
2.
For a February 10, 1988, incident, the investigation and subsequent uptake calculations were based on an urinalysis sample collected at an improper time interval following the exposure event.
This is a Severity Level IV violation (Supplement IV).
Before responding to this violation, it may be useful to reiterate the purpose and implementation of NF&CM's internal exposure control programs ts authorized by 10 CFR 20 and license conditions.
In accordance with the full wording of paragraph 10 CFR 20.103 (a) (3) and SNM-1097, paragraph 3.2.4.3.1, "Individual airborne exposure assignments are made based on airborne concentrations in the areas in which the individual worked and the time the individual spent in each area."
Air sample results, both soluble and insoluble, are evaluated with the insoluble MPC of 1 x 10-1' pC1/ml.
The MPC for soluble mixtu.es of uranium isotopes typical of fuel manufacturing (i.e.,
2% enrichment or greater) exceeds 2.3 x 10-20 pCi/ml, and is a function of isotopic mix.
Uniformly using the insoluble MPC simplifies implementation.
This simplification and GE's action guideline of 30 MPC-hrs /wk control worker exposure to soluble uranium with a restriction level of about 13 MPC-hours per week.
US'NRC Document Control Desk August 26, 1988 Page 4 of 6 GE's urinalysis program is implemented cs an additional precaution to minimize the chance of chemical health effects.
We believe GE is leading the low-enrichment fuel fabrication, industry with our routine daily sampling program for individuals exposed to UF, and related compounds.
For operational simplicity, to enhance the program's effectiveness, action levels are expressed in chemical units (i.e., pg/l and mg.
of intake) as directly specified in SNM-1097.
Because the urinalysis results are used to control chemical toxicity, a health effect with a known threshold, and because the uranium clears the body rapidly (i.e. a six hour half time for UF.), urinalysis intakes are not accumulated in the same manner as radiological exposure assigned by air sampling.
It is theoretically possible to derive an estimate of intake based on a urinalysis result and convert it to a number of MPC hours for soluble uranium adjusted for enrichment.
This number could then be added to the individual's exposure record, but should simultaneously be subtracted from the assigned exposure based on air sampling (which assesses the sum of soluble plus insoluble) to avoid double recording.
For these reasons, GE does not use the urinalysis program to derive intake equivalents in MPC-hours.
There are further reasons why not all positive urinalysis results are investigated.
The action levels specified in SNM-1097 do not require investigation and calculation of intake for each positive sample.
The rationale for the action levels is that they will screen out potential intakes less than GE's restriction level of 2.5 mg uranium.
Resamples (or routine samples) submitted after an intake would also be expected to be positive but not require an additional intake calculation.
In addition, if samples are spaced close enough together, an intervening intake in excess of the restriction level can be ruled out.
Therefore, in an "automated investigation", to accommodate both cases above, tne radiation exposure records system software (REMTRAC) does not flag for investigation samples with results less than 95 pg/l if there has been a previous urinalysis sample submitted within 24.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />.
The inspector's observation of a 53 pg/l sample submitted on April 28, 1988 is an example of such automated assessment of potential intake.
GE's combination of air sampling and urinalysis to control the radiological and chemical hazards of uranium 1s an appropriate and effective system which keeps workers' exposures below the limits given in 10 CFR 20 and Reg. Guide 8.11, With respect to violation B, examples 1 & 2, GE concurs that its internal procedures were violated in that:
(1)
An individual who was ending a work assignment with GE submitted a final urinalysis sample on 4/28/88; the enalytical result for which was not processed properly, and
US' NRC Document Control Desk August 26',
1988 Page 5 of 6 (2)
Calculations for two individuals known to be involved in an event involving exposure to soluble uranium were based on urinalysis samples submitted _three hours after the event.
Item one was caused by an oversight.
The contractor employee submitting the sample had terminated employment the same day.
Because the urinalysis result was entered into the computerized record keeping system after the individual's status in the system had been changed to "inactive", it was not processed in the usual manner.
Instead the result was listed on an exceptions ~ report and passed to the Radiation Protection supervisor who oversees the urinalysis program.
The report was mislaid and found after inquiries during the May.23-27, 1988, inspection.
)
The individual's airborne exposure h'istory was reviewed, the intake was assessed to be a 0.25 mg of uranium, and this result has been entered into the individual's history.
The urinalysis results for a year (July 1, 1987 to June 30, 1988) for all construction and maintenance contractors were reviewed and no 1
similar oversights were found.
Even though the Radiation Protection personnel responsible for the urinalysis program were alerted immediately, to prevent recurrence, all Radiation Protection personnel will have the facts and nature of this oversight brought to their attention.
Item two, above, was caused by a lack of clarity and specificity in the procedure used by Radiation Protection personnel, i.e., NSI 0-2.0.
The four-hour minimum time is specified in a footnote to the Appendix giving the formulas to be used for manual 1
calculations and not in the body of the procedure.
However, both individuals had submitted follow-up samples the next morning before entering the Airborne Controlled Area.
It is these sample results which should have been used to compute the intakes.
Performing such calculations yielded intakes of 0.12 mg for both individuals.
To guard against recurrence of a calculation of intake with improper time interval the following steps will be taken:
l A.
NSI O-2.0 will be revised to delineate and emphasize the required four-hour minimum interval between event and sample collection.
B.
REMTRAC software will be modified to prevent inputting a time interval between event and sample collection less than four hours.
Also modifications will be made to allow intake calculations to be based on a subsequent resample when appropriate.
Us NRC Document Control Desk' August 26,:1988 i
Page 6 of-6 C.
All Radiation Protection personnel will be trained on the revised'procadure and software, j
i Full compliance will be achieved by October 14, 1988.
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