ML20154J356
| ML20154J356 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/28/1980 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | Kenna W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20154J343 | List: |
| References | |
| FOIA-85-158 NUDOCS 8603100576 | |
| Download: ML20154J356 (4) | |
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GEN ER ALh ELECTRIC NUCUAR ENERGY PRODUC DIVISION WILMINGTON MANUF ACTURING DEPAR WEN CASTLE HAYNE ROAD e P. O. BOX 780 WILMINGTON, N. C. 28401. (919) 343-5000 April 2#
1980 en Mr. W.
B. Kenna, Chief Safeguards Branch U. S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. Kenna:
References:
(1) NRC Inspection Report RII/DWJ, 70-1113/80-04, dated 4/10/80 (2) NRC License SNM-1097, Docket #70-1113 Thank you for your letter referred to above which reported the results of the inspection of our fue1~ fabrication plant in Wilmington, N.
C.,
by Mr.
D. W.
Jones of your office on March 5-7, 1980.
A reply to the items of apparent noncompliance with NRC require-ments is given in the attachment to this letter.
We appreciate your inspector's comments and suggestions related to our safe-guards programs.
These comments and suggestions are helpful to us in our constant efforts to maintain and, where ne cessary, improve these programs and to ensure the continuation of a successful safe-guards effort at our plant.
We also welcome further discussion with your staf f on the items in your letter and in our related reply, if necessary for further clarification of these items.
Pursuant to 10 CFR 2.790(d), General Electric Company requests that the attachment to this letter be withheld from public disclosure since this attachment identifies details of General Electric's control and accounting procedures for safeguarding licensed special nuclear material.
Very truly yours, GENERAL ELECTRIC COMPANY 8603100576 860124
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PDR FOIA R ATNER 85-158 PDR Arthur L. Kap an, Manager Licensing & Comp:,iance Audits M/C J26 ALK:bmw SGD-I D-i At t ac hment a/
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Mr. W. B. Kenna April 28, 1980 ATTACHMENT The information given below refers to the two items in Appendix A,
" Notice of Violation," in the NRC Inspection Report RII:DWJ, 70-1113/80-04, dated April 10, 1980.
The corrective actions detailed below have already been implemented or will be implemented by the dates shown.
A.
10 CFR Patt 70.58 (i) (2) rega4'tcs.tlat the licotsce establish, maiuttain, and follow p'toccdurcs to finit the accumulation and the wicetta.btty of mcasarcmatt of scrap, such tlat no item of scrap generated in the ficot6ce's plant measured wLth an micettabt-ty of greater than
- 10 petcott remains on invattory longet than twelve months.
Contraty to the above, examination of the lico1sce's perpetwit htvattortj record for matethtl typc codes rep 1esenting matcrials with a measuremott w1cettahtty greater than t 10 percott inh *cated tlat apptoximatcLet 100 scrap contabschs rcptesentbtg more titan 5 kilograms of U-235 have remahted on h1vottory for a petiod exceeding tweluc montits.
TitL6 is a deficiency.
On August 2, 1979, we submitted a request for authorization to the NRC Material Control & Accounting Licensing Branch, for authorization to retain scrap of the type described above for more than one year.
The reasons for our need to retain this scrap for such a period of time in excess of one year are:
- 1) Inability of our present offsite vendor to serve our needs for recovery of uranium from these scrap materials.
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K nna GE ER-April 28, 1980 PR P ION Attachment - Page 2
- 2) Inability to find an alternate vendor for providing us with the required scrap recovery service.
- 3) Present lack of onsite capability to accomplish the required scrap recovery ourselves.
In December 1979, we held further discussions with the NRC licensing staff concerning this matter.
In addition, the situation with our vendor for scrap recovery services has clarified to the point where such services can be provided, but with timing that will still require us to retain some of this scrap for more than one year.
As a result of these discussions, this inspection, and the present situation relative to our vendor for scrap' recovery services, we submitted another request for authorization to retain the scrap in question for more than one year, on March 7, 1980.
This most recent request is still pending.
We are in the process of establishing a workable schedule for processing of our scrap materials with our present vendor.
This should alleviate our need to store these scrap materials for such long periods of time while waiting for the vendor to provide us with the scrap processing service.
After such a schedule has been established with the vendor, we do not expect to encounter further problems related to processing of this type of scrap material.
Thus, we do not expect to have to retain such materials for more than one year, af ter December 31, 1980.
In the meantime, our long-range planning includes consideration of acquiring our own onsite capability to recover uranium from this scrap material.
These plans would call for this onsite capability to be in place by mid-1984.
The relevant General Electric manage-ment' recognizes the seriousness of this problem and the need to provide for an onsite scrap recovery capability at the Wilmington plant.
i B.
SectAon 4.4.1 of the Fundamc>ttal Nuctcar FLtterial Control Plan spceifics.tlutt:
"The rept.icMe measuremetzt ptogram is scheduled to ptovide a minimum of 15 replicates or 100% replica. tion, whichevet is less, for cach measurementt typelmaterial ca.tegory during cach ma.tcrial balance period. The replications of sampling, sample analyses, bulk and NQA measatcments of ptocess matetials are conducted as uniformly as ptactical throughout.the mMetial balance period. Da.ta from these replications are used for the estimation of random etror variances, to i
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April 28, 1980 PRd NO Attachment - Page 3 monitor and control measwtement perfoonnce, and to provide input to catrent LEMUF calculations and to LE calculations for receipts and shipments."
Contrary to the above,.the replica.tc data gencrated during the material balance period August 13, 1978 through August 14, 1979 for theltitiamchtic.anatijtical method did not tjictd the random chror va.tiance used in the LEMUF cnicttlation.
This is a deficienci.
j The data referred to in Item B above represents one data point ou.t of several thousand.
The data had.been prepared and checked in accordance with the regulatory and license requirements.
The discrepancy identified by the inspector was caused by human error in the handling of large volumes of data in relatively short time periods allotted for such activities.
Since the last inventory, we have modified some4 computer based) reports to provide a format which lends itself to more reliable evaluation of data and more reliable identification and correction of such problems prior to the end of the material balance period.
We believe that these actions will prevent future recurrence of such noncompliances.
A. L. Kaplan
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U G E N E R A L'h E LECTRIC NUCMAR ENERGY PRODUCTS DIVISION WILMINGTON MANUF ACTURsNG
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CASTLE HAYNE ROAD e P. O. BOX 780 WILMINGTON.. C. 28402'+ 1919) 343 500b DEPARWENT August 11, 1981 Mr. R. C. Lewis, Acting Director Division of Resident &
Reactor Project Inspection U. S. Nuclear Regulatory Commission, Region II 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. Lewis:
References:
(1) NRC License SNM-1097, Docket #70-1113 (2) NRC Inspection Report 70-1113/81-07, dated 7/23/81, received 7/29/81 Thank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr. J. B. Kahle of your office on June 8-12, 1981.
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This inspection report does not contain any information which we believe to be proprietary.
Very truly yours, GENERAL ELECTRIC COMPANY
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Charles M. Vaughan, Acting Manager Licensing & Compliance Audits M/C J26 CMV:bmw NSD-I 5
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y.nu JUL 231981 General Electric Company ATTN: Mr. J. A. Long, General Manager Wilmington Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:
Subject:
Report No.613/81-D This refers to the routine safety inspection conducted by Mr. J. B. Kahle of this office on September 22 - 26, 1980 and June 8 - 12, 1981, of activities authorized by NRC License No. SNM-1097 for the Wilmington Manufacturing Department facility.
Our preliminary findings were discussed with Mr. E. A. Lees, Quality Assurance Manager, at the conclusion of the inspection.
Areas examined during the inspection and our findings are discussed in the enclosed inspection report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspectors.
During the inspection it was found that certain activities under your license appear to violate NRC requirements.
This item and references to pertinent requirements are listed in the Notice of Violation enclosed herewith as Appendix A.
Corrective actions to prevent recurrence were completed prior to the conclusion of this inspection; therefore,-s reply is not requested.
We have examined actions you have taken with regard to previously identified enforcement matters and unresolved items. The status of these items is discussed in the enclosed report.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosed report will be placed in the NRC's Public Document Room.
If the report contains any information that you believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you:
(a) notify this office by telephone within ten days from the date of this letter of your intention to t ile a request for withholding; and (b) submit within twenty-five days from the date of this letter a written application to this office to withhold such information.
If your receipt of this letter has been delayed such that less than seven days are available for your review, please notify this office promptly 50 that a new due date may be established.
Consistent with section 2.790(b)(1), such application must be accompanied by an affidavit executed by the owner of the information which identifies the document or part thereof sought to be withheld, and a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public disclosure. This section further requires the statement to address with e
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Jut. 231981 General Electric Company 2
specificity the considerations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld shall be incorporated as far as possible into a separate part of the affidavit.
If we do not hear from you in this regard within the specified periods noted above, the report will be placed in the Public Document Room.
Should you have any questions concerning this letter, we will be glad to discuss them with you.
Sincerely, N
R. C. Lewis, Acting Director Division of Resident and Reactor Project Inspection
Enclosures:
1.
Appendix A, Notice of Violation 2.
Inspection Report No. 70-1113/81-07 cc w/ encl:
C. M. Vaughan, Acting Manager Licensing and Compliance Audits G. R. Mallet, Acting Manager Nuclear Materials Management bec w/ encl:
License Fee Management Branch Central Files Local Public Document Room Washington Public Document Room Nuclear Safety Information Center Technical Information Center Document Management Branch State of North Carolina (t 0~ IN s!G1Th15 AfiV T' S'Il?FP (*~ "fIh)
RII:ETI RII:E RII:ETI, RII:RRPI, R" :RRPI AFbihs n GP 1
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t APPENDIX A NOTICE OF VIOLATION General Electric Company Docket No. 70-1113 Wilmington Manufacturing Department License No. SNM-1097 As a result of the inspection conducted on September 22 - 26, 1980 and June 8-12, 1981, and in accordance with the Interim Enforcement Policy,.45 FR 66754 (October 7,1980), the following violation was identified.
License Condition 9 of the license requires that licensed material be used in accordance with statements, representations and conditions of Appendix A, as contained in the licensee's application.
Appendix A, Section 4.1 iequires that operations and activities shall be directed by the designated area manager who shall establish written operating procedures.
Procedure PROD No. 1CR08, Personal Survey - Leaving Controlled Area, requires that individuals hold the scanner probe approximately inch away and slowly pass it over the hair, face, chest, hands, waists, ankles, shoes and TLD b' dge.
a Contrary to the above, individuals were observed holding the probe a much greater distance than inch and moving the scanner probe quickly over the body.
This is a Severity Level VI Violatierr-(6cpplement IV F).
JUL $ 8 ISOI Date:
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NUCLEAR REGULATORY COMMISSION
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Report No. 70-1113/81-07 Licensee:
General Electric Company Wilmington, NC 28401 Facility Name: Wilmington Manufacturing Department Docket No. 70-1113 License No. SfN-1097 Inspection at Wilmington, North Carolina Inspectors:
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Date Approved by:
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Division of Engineering and Technical Inspection
SUMMARY
Inspection on September 22-26, 1980 and June 8-12, 1981 Areas Inspected This routine, unannounced inspection involved 132 inspector-hours onsite in the areas of radiation protection covering radiation protection procedures, internal exposure control, external exposure control, contamination control, posting and labeling, notifications and reports, followup on outstanding open items and packaging and transporation of radioactive waste.
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f Results Of the eight areas inspected, one item of noncompliance was found in one area (Failure to follow personal survey procedure when exiting the l
control area).
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DETAILS 1.
Persons Contacted Licensee Employees
- E. Lees, Quality Assurance Manager
- J. Bergman, Fuel Manufacturing Manager
- B. Bentley, Fuel Chemical Operation Manager
- R. Patterson, Fuel Fabrication Operation Manager
- W. Hendry, Regulator.y Compliance Manager
- J. Mohrbacher, Nuclear Safety Engineering Manager
- R. Torres, Radiation Protection Supervisor R. Lewis, Radiation Protection Shift Supervisor
- D. Barbour, Radiation Protection Shift Supervisor
- G. Powers, Senior Nuclear Safety Engineer
- G. Bowman, Senior Nuclear Safety Engineer C. Vaughan, Licensing and Compliance Manager
- R. Foleck, Senior Licensing Engineering Specialist
- S. Murray, "' clear Safety Engineer
- W. Smalley, senior Environmental Protection Engineer
- D. Brown, Powder Production Operation Manager J. Brown, Contracts Specialist C. Shipp, Industrial Safety Manager R. Pace, Fuel Support Operation Manager P. Zorich, Burns Security Agency Sergeant Other licensee employees contact 6d included four operators, three technicians and two clerks.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September 26, 1980 and June 12, 1981.
In the June 12, 1981 exit interview, management was informed that the September 22-26 inspection report had been lost and that the finding regarding a violation would be covered in report 70-1113/81-07.
Management representatives objected to this procedure because the situation had been corrected and the present inspectors had no documentation that the licensee had ever been in violation of any regulatory requirements and if enforcement action was in order at this time, there should be two separate reports.
Management representatives were informed that the viola-tion had been observed by the inspectors in September 1980 and even though corrective action had been taken by the licensee the enforce-ment documentation would be contained in the forthcoming report.
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3.
Licensee Action on Previous Inspection Findings a.
(Closed) Noncompliance 78-14-01 and 78-19-01:
Failure to survey to evaluate potential airborne hazard associated with welding contaminated equipment. Job Hazard Analysis (JHA) No.
22 was examined by the inspector.
It relates to the radio-logical safety control associated with maintenance activities in the uranium manufacturing areas.
Documentation was reviewed which showed that the new JHA had been reviewed with maintenance personnel and that they had signed a document that they had read and understood the radiological safety control requirements.
An examination of procedures, P/P 40-9, " Service Work in Controlled Area" and NSI 0-9, " Radiation Work Permit" showed that procedures have been developed to provide proper instructions for the personnel to work with radioactive material and potentially contaminated equipment and materials.
b.
(Closed) Open Item 78-19-02: Modification of Respiratory Protection Procedures to include standby rescue personnel for bubble suit users.
The licensee has issued a revised procedure (Prod. No. 80-20) which now includes this requirement.
c.
(Closed) Open Item 78-19-03:
Respirator device approvals for UF Arei.
Bioassay records and air sample results were reviewed g
during this inspection.
The information reviewed was consistent with the previous results.
It is apparent that the respiratory device is satisfactory for use in UF6 areas.
d.
(Closed) Open Item 78-19-0*r-Modification of computer program and associated timely notification of terminated employees.
Discussion with a licensee representative revealed that when individuals terminate employment, or their work assignment with the licensee, their names are removed from the active personnel data base in the computer files.
Then a computer input of the TLD exposure results received from Landauer will flag individuals who have been removed from the active files and a notification of terminated individuals exposure report is prepared.
e.
(Closed) Open Item 79-06-01:
Revise procedures for action level in liquid effluents.
The nuclear safety method sheet for PROD. Document No. 80-69, "WMD Process Effluent Control",
was revised to control the process lagoon daily releases so as not to exceed 2 parts per million (PPM) uranium which is equivalent to 10 percent of the 10 CFR 20 Appendix B maximum concentration (MPC).
Plant procedure P/P 40-18, " Regulatory Compliance Administrative Action Guidelines"6 establishes the action level for liquid effluents at 3 x 10-uCi/ml, which is 10 percent of the MPC.
The nuclear safety method sheet also requires the Shop Support personnel to contact the Environmental Engineer in the event the 2 PPM uranium value cannot be met.
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(Closed) Unresolved Item 79-06-02: Gross Beta Analysis of Nitrate-Bearing Liquid Shipments.
The licensee takes a grab sample.from each truck load of nitrate-bearing liquid waste.
A daily composite is made of the grab samples at the end of each day, then a weekly composite is made of the daily com-posites.
The weekly composite samples are sent to Vallecitos for gross alpha and gross beta analyses.
The areas for storage of empty and filled radioactive material containers are well controlled and posted.
g.
(Closed) Open Item 79-06-03: Labeling of empty boxes in outside storage areas.
Since the time that this item was identified the FM0/FMOX area has been enclosed within a security fence, consequently the labeling need has been negated as the secured area is properly posted.
Also, the licensee now places a packet of " EMPTY" labels in with the packing list when containers are sent out with instructions for the receiver to place empty labels on the containers when returning in accordance with DOT regulations. Observation of containers showed proper marking and labels.
h.
(Closed) Noncompliance 79-17-01:
Release of material from the controlled area with contamination above the license limits.
The licensee has initiated a procedure (PROD 80-72) that requires that all sanitary (noncontaminated) trash generated within the emergency control center (ECC), except for the trash from the lunchroom antf'f.he computer room, will be visually inspected for suspect items and monitored with a sensitive radiation detector and released by the Radiation Protection Unit and the Shop Support Unit prior to removal from the site.
An examination of procedures and discussions with licensee representatives revealed that responsibilities and instructions have been assigned to the various units to assure that contaminated materials have not been placed in with the sanitary trash, that the sanitary trash is properly monitored for radioactive contamination and that no radioactive or radiation warning or caution signs, stickers or labels are contained in the sanitary trash.
Materials are removed from the trash if any positive' reading above background is detected.
An examination of the records showed that occasionally materials were removed because of a reading above background, the item was suspect or bore a radioactive material label.
i.
(Closed) Open Item 79-17-02:
Procedures for control of conta-minated materials in temporary work sites.
Discussions with licensee representatives revealed that all work at the plant l
is reviewed by the nuclear safety group.
The procedures that assure that the work is reviewed by the nuclear safety group are P/P 40-9, " Service Work in Controlled Areas", P/P 40-5,
" Nuclear Safety Review System" and NSI 0-9, " Radiation Work L
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4 Permits".
An examination of these procedures showed that responsibilities are established for assessing the need for a nuclear safety review, that area management approved the work and that the nuclear safety review requirements are incorporated into the applicable procedures.
J.
(Closed) Noncompliance 80-10-01:
Failure to keep fuel rod 3
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cabinet doors closed.
The inspector reviewed documentation that showed that management instructions had been issued which, clarified the specific requirement and emphasized the importance of following the requirement and enforcement by supervision.
A nuclear safety review has been performed and a management decision made to replace the aluminum trays with stainless steel.
When the stainless steel trays are in place, it will no longer be necessary to keep the fuel rod cabinet doors closed to maintain nuclear criticality safety if water or foam are sprayed into the cabinet in the event of a fire.
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Unresolved Items
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F Unresolved items were not identified during this inspection;
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5.
Bulletins, Circulars and Notices
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a.
IE Circular Number 79-09.
Occurrences of split or punctured regulator diaphragms in certain self. contained breathing g ThiscircularwassentoutbytheCommissionoy!pg" apparatus.
NIOSH had released a " Respirator Users Warn
- June 22, 1979.
on May 2, 1979 This was responded to by the licensee on l
May 18, 1979.
The supplier was contacted by the licensee and all self-contained breathing (SCBA) units were promptly inspected.
By procedure this has further become a monthly inspection item.
This item is closed.
6 b.
IE Circular Number 79-15.
Bursting of high pressure hose and malfunction of relief valve and "0" ring in certain self-contained breathing apparatus. The licensee does not use the type of SCBA covered by the circular.
This item is closed.
c.
IE Infonnation Notice Number 80-19.
NIOSH' recall of recircula-ting mode (Closed Circuit) self-contained breathing apparatus (rebreather).
The licensee does not use these SCBAs.
This item is closed.
t d.
IE Circufar No. 79-21, Prevention of Unplanned Releases of Radioactivity.
This particular circular was not dispatched to fuel facility licensees.
The circular contents and concerns
.regarding 4ydrostatically testing of underground piping which carry liquid radioactive material was discussed with licensee representatives.
.t was determined that the licensee has no process liquid waste lines that are underground.
The process 10cuid waste 1.ines from the FM0/FM0X complex to the waste s
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treatment facility'are above ground. The licensee does have some drain lines which are underground. The drain lines are gravity flow and carrying treated radioactive liquid wastes which have been batch released with a concentration below the l
regulatory limits.
The licensee representative stated that the drain lines are vitrified clay pipe which is not amenable to hydrostatic testing and would be practically impossible with the cemented connections at the various manholes.
Licensee representatives acknowledged our concern and the importance of testing underground lines which carrying liquid radioactive material and provide the potential for releasing radioactivity to unrestricted areas in,the event of leaks.
This item is closed.
IECirNularNo.81-07,ControlofRadioactivelyCentaminated e.
Ma teria l.
Even though the circular is applicable only to nuclear power reactor facilities, a licensee representative stated that the philosophy and principles were essentially applicable to uraniumj ftel fabrication facilities.
The licensee has determined that it is not necessary to change or revise any of their procedures regarding the control and release of materials for unrestnicted use or removal of sanitary (noncon-taminated) trash from the plant.
This is discussed in paragraph 3b. above.
Licensee rr.presentatives stated that the alpha contamination ' measurement capability of detecting 100 dpm/100
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cm2 fixed and 20 dpm/ 100 cmz removable was not practical except under.very special ideal conditions.
The systematic crrors associated with routine smear surveying and measurements
- .i would exceed these levels.'1 Tie lice'nsee representatives emphasized that their controls and release levels were as low asreasonablyachievablegndwithinthelicensecond{ tion limits of 5000 dpm/100 cm fixed and 1000 dpm/100 cm removable.
This, item is closed.
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6.
Allegations a.
An April 28, 1981, Region II NRC received a telephone call
' from an alleger expressing concern of improper radioactive waste disposal on the licensee's property.
The alleger stated i
that twelve J5-gallpn d ams were removed from the fuel manufactur-ing% uilding and disposed of in.3 marshy area located on the licensee'.s property.
The individual alleger was contacted to pin-point the area where the drums were allegedly disposed.
The a11eger expressed a desire to remain anonymous, b.
Surveys with very sensitive micro-R/hr radiation detection 4
instruments were made of the FM0/FM0X storage areas and along i
all'the roads in the back part of the plant.
The area, where the drums were allegedly disposed of was extensively monitored for radiation and visually observed for the presence of 55-gallon drums.
Radiation levels above background were not 4
detected nor were any 55-gallon drums observed.
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6 7.
External Radiation Control An examination of the external radiation dosimetry records for 1980 and first quarter 1981 revealed that radiation exposures to individuals were well within limits.
Documentation was available to show that reviews were made of any unusual or suspect results and that investi-gations had been performed by the nuclear safety engineering staff r
to resolve concerns and take corrective action, if necessary.
Verification was made that the licensee maintained records in accordance with 10 CFR 20.401 and issued the annual report pursuant to 10 CFR 20.407.
8.
Internal Radiation Control a.
Air Sampling Program The inspector examined the sampling program extensively.
Samples are taken daily at most work locations and the program appears to be adequate.
Historical and current tracking of air sample results is being done and this has aided in upgrad-m ing engineering controls.
One area of concern was noted in the area of assigning MPC-hours.
The licensee may have several air sampling locatio'ns in a given work area.
The licensee procedure calls for averaging of these air samples prior to assigning MPC-hours.
The inspector informed the licensee that this was a questionable practice and recomended changing this procedure to assignment of-MPC-hours based on a specific air sample location.
This item will be evaluated during a subse-quent inspection (81-07-01).
b.
Bioassay Program The inspector examined bioassay procedures and records.
No discrepancies were noted in this area and this program appears adequate.
c.
Respiratory Protection Program The inspector examined the overall respiratory protection program. The inspectors noted that the licensee was not following the recommendations noted in NUREG 0041, in that:
(1) No formal monthly inspection is performed on full face respirators.
Licensee representatives felt that re-spirator turn over time was such that the need for this formal inspection was not necessary.
The inspector stated that there was no assurance that each full face respirator received a monthly inspection and that a formal procedure should be implemented.
This item will be evaluated during a subsequent inspection (81-07-02).
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(2) No formal inventory procedure is used for respirators.
The inspector informed licensee representatives that this should be done on a routine basis to ensure that adequate supplies are available for routing and emergency use.
This item will be evaluated during a subsequent inspection I
1 (81-07-03).
(3)
Improper storage of respirators.
The inspector noted that respirators were stored, ready for use, stacked on one shelf in several layers.
The inspector pointed out that this can lead to the respirator face piece losing the set and making these respirators potentially defective.
The inspector recommended single layer storage to decrease the potential of damaging the respirators pursuant to-NUREG 0041. This item will be evaluated during a subse-quent inspection (81-07-04).
(4) Contamination survey' are not performed on each individual respirator.
During the respirator cleaning, as noted in licensee procedure-Prod. 80.83, smear surveys are performed on 5 respirators per batch.
By procedure a batch can con-sist of 35 respirators with no more than 10 full-face respirators.
The inspector informed licensee representatives that each respirator should be individually smeared to assure that contamination levels are not in excess of the limits specified in NUREG 0041. This item will be evaluated during a subsequent inspection (81-07-06).
The inspector spoke to licc}see representatives concerning regu-lator certification for self-contained breathing apparatus (SCBA).
- The licensee was not aware of this requirement and had received no guidelines from the manufacturer.
The inspector stated that the manufacturer recommended that regulators be checked and recertified annually.
This item will be evaluated during a subsequent inspection (81-07-05).
9.
Packaging and Transportation of Radioactive Waste The inspector examined the following documentation associated with the packaging and transportation of radioactive waste:
a.
PROD 80.10 Old Decon Waste Box Loading b.
PROD 80.38 Packing Waste Boxes and Drums c.
PROD 80.60 Shipping Waste Boxes d.
Packaging Engineering Change Notice e.
Drawing No. 112 0 1585 Rev. 1 (Shipping Container-Contaminated Waste) f.
Inspection Procedures QCII - Drawing 112 0 1585 Rev. I and QCOR - Operator Requirements 9
Burial Site Disposal Criteria
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The program for packaging and shipping containers of radioactive waste and the associated quality assurance inspections performed by the licensee were discussed with licensee representatives.
Con-tainers (4' x 4' x 4' wooden boxes) were examined by the inspector.
Licensee procedures have been revised to provide, with quality assurance controls, adequate containers to meet the burial site and 00T shipping container specifications.
Procedures, both operating and quality assurance inspection, have been developed and/or revised to assure that only acceptable materials, (e.g., no liquids) are placed in the containers. The procedures reflected that inspections are performed prior to shipping, pursuant to the burial site disposal criteria.
The inspector noted that there has been a significant improvement in the construction and sealing of the boxes used for disposal of waste.
It appeared that the operating and quality assurance procedures were adequate to assure that acceptable con-tainers are used, that only acceptable materials are placed in the containers, that adequate inspections are performed and that the containers are properly sealed prior to shipment.
10.
Plant Tours a.
General During tours of the FM0/FM0X complex, it appeared that licensed material was processed, handled and stored in accordance with license conditions and the licensee's nuclear safety and radiation protection practices and procedures.
Personnel were observed to be using protecffve clothing and equipment as prescribed in the licensee's procedures.
General housekeeping was satisfactory and no industrial safety or fire hazards were observed.
b.
Change Rooms License Condition 9 of the license requires that licensed material be used in accordance with statements, representa-tions and conditions of Appendix A, as contained in the licensee's application.
Appendix A, Section 4.1 requires that operations and activities shall be directed by the designated area manager who shall establish written operating procedures.
Procedure PROD No. 3CR08, Personal Survey-Leaving Controlled Areas, requires that individuals hold the scanner probe approximately 1-inch away and slowly pass it over the hair, 4
face, chest, hand, wrist, ankles, shoes and TLD badge.
(1)
During the inspection in September 1480, the inspectors observed personnel leaving the controlled area through the change room without properly monitoring themselves.
Personnel failed to hold the instrument scanner probe in close proximity (approximately 1-inch) of the body and to pass 4
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9 the probe slowly over the required areas.
Also, some of the instruments were not functioning.
A contamination survey of the clean side of the change room showed conta-mination levels above the action levels.
(2)
During the June 1981 inspection, personnel were observed leaving the controlled area through the change room.
Personnel surveys for possible contamination on clothing and body were conducted in accordance with the posted procedural requirements.
Documentation was examined which showed that personnel had been instructed in the required procedure for monitoring when leaving the con-trolled area and the proper use of the instrumentation.
Records were reviewed which showed that contamination was not being spread to the clean side of the change rooms.
(3)
Licensee representatives were informed that their corrective actions appeared satisfactory to prevent recurrence of the violation.
No response regarding the violation would be required, c.
Posting and Labeling The inspector reviewed the licensee's posting of radiation, contamination and radioactive material area and the labeling of radioactive material. No violations or deviations were identified.
GENERAL h ELECTRIC U $ P. 7 0 r.
.-e erxW1on h#ACTLt% DUMM*4T GENU.N ILFCM dC%**5Y PO b* ~Ki EVAPON, <W CC" M 03 J'JL 7 A9:02 l
June 30, 1983 f
i Mr. J.
Philip Stohr, Director Division of Emergency Preparedness &
Material Sa fety Programs U.
S.
Nuclear Regulatory Con. mission, RII 101 Ma ri e t t a Street, NW - Suite 2900 Atlanta, GA '30303 Ce a r Mr. Stohr:
Re f ere nce s :
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/83-12 Dated 6/10/83, Received 6/15/83 General Electric has received your letter reporting the results of the special safety inspection conducted by Mr.
C.
M.
Hosey on April 18-20, 1983, and the subsequent Enforceaent Conference held at our facility on May 18, 1983.
The General Electric reply to the item of noncompliance with NRC requirements is given in Attachments A and B to this letter.
As indicated in Attachment B, General Electric believes that the Severity Level of the violation has not been correctly reported under the rules of practice 10 CFR 2 Appendix C and hereby requests reconsideration of this decision.
The Notice of Violation cites an infraction of 10 CFR 20.301 relating to transfer of unauthorized material to a licensee.
The Enforcemen t Conf erence of May 18, 1983, was exclusively addressed to the unauthorized presence of liquid in waste boxes shipped to Chem-Nuclear Systems, Inc. for burial at Ba rnwell, S.
C.
Based upon subsequent telephone conversations with Region II staff members, it is Ceneral Electric's understanding that the issue of NRC concern and the cause for the Enforcement Conference is specifically the presence of unauthorized liquid in waste box shipments to Chem-Nuclear Systems, Inc.
There is no indication
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GENER AL h ELECTRIC J.
Philip Stohr June 30, 1983 Page 2 nor im ]ication of a General Electric programmatic deficiency involving shipments of nuclear material.
in waste recogni zes the NBC concern regarding unauthorized liquid box shipments and, as indicated in Attachment A, is taking action to prevent recurrence of the problem.
South Carolina Depa rtment of Heal th and As you are aware, Environmental Control, in their role as an Agreement State, issued General E3ectric civil penalties of $1,000 for each of the three shipments found by their inspectors to contain liquid.
waste box In addition they requested and received our plans for corrective independent of our action.
The s e interactions preceded and were-receipt of the NRC Notice of Violation.
sta f f and ranagement's con ents We appreciate your inspector's, and suggestions related to our enployee sa fety and environ.-ental These coma.ents and suggestions are helpful protection programs.
to us in our constant efforts to improve these programs, to ensare a nd to ensure the continued health and safety of plant personnel, conditions.
We our compliance with NRC regulations and license also welcome further discussion with your staff on the iters in your letter and in our related reply, if necessary, for further clarification of these items.
Your inspection report referred to above does not contain informa-tion which we believe to be proprietary.
Sincerely yours, GENERAL ELECTRIC COMPANY
'iY d f % ' fit fmf ")
w Charles M.
Vaughan, Manager Li ce ns ing & Nuclear Materials Management M/C J26 CMV/cd Attach. Tents JSD-I
GENER AL h ELECTRIC J.
Philip Stohr June 30, 1983 Page 3 ATTACHMENT A The NRC Notice of Violation in Inspection Report 70-1113/83-12, dated 6/10/83 states in part:
"10 CFR 20.301 speci fies authori zed me thods for disposal of licensed material and prohibits disposal by other acans.
One authorized method is by transfer to an authorized recipient.
Contrary.to the above, on March 29, March 30 and April 22, 1983 the licensee transferred special nuclear material in liquid form to Chem-Naclear Systems, Inc., a person not authorized to receive it under the specific terms of their license.
SFC license 45-13536-01 prohibits Chem-Naclear Systems from receiving liquid waste which has not been solid ified.
This is a Severi ty Level IV Violation (Supplement V)."
General Electric concurs that boxes of solid radioactive waste
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(UN2912: Rad ioactive Ma terial, LSA) transferred to Chem-Nuclear Systems, Inc. (NRC License 45-13536-01) on March 29, March 30 and
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April 22, 1963, were found, upon inspection at the burial site, to contain varying amounts of liquid.
The boxes transf erred on March 29 and March 30 had been packaged in accordance with approved General Electric procedures.
As a result of the discovery of liquid in the boxes shipped on March 29 and March 30, special proccdures were implemented to assure that the next waste box shipment was dry.
The boxes which were subsequently transferred on April 22 were also packaged in accordance with approved General Electric procedures.
In addition, these boxes were emptied and the contents inspected for dryness.
The material was repackaged in known dry boxes and stored in a protected area prior to shi paen t in a closed truck.
The reason for the violation is currently unexplainable.
General Electric was not af forded an opportunity to inspect the first two groups of boxes and subsequent investigations by GE and the NRC of activities at Wilming ton were unable to identify a posi tive ca use.
The preparation and handling of the third group of waste boxes was accomplished in a manner which should have provided an ex treme measure of assurance that no f ree liquid would be in the boxes upon arrival at the burial site.
It is also clear that GE is keenly aware of the fact that free liquid is not allowed in burial material as evidenced by our license verification files, training
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programs, procedures, entries on required shipping papers, and the
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extensive waste handling upgrades completed for the Wilmington facility.
,v.
G E N E R A L ((( E L E CT Rit:
June 30, 1983 Page 4 ATTACHMENT A ( Cont inued )
Following the transfers of March 29 and 30 and the discovery of liquid in some of the boxes, General Electric committed to a corrective action program to South Carolina Department of Health and Environmental Control (SC DHEC).
The short term corrective action commitment was to unpack, inspect, repack in known dry bcxes, and store and ship protected from the elements.
The short term corrective actions were used for the April 22 shipment at were apparently not effective.
The longer term corrective action was to install drain plugs which would be used. to verify the absence of water immediately prior to shipaent.
Currently, GE has in place a self-imposed " St op Shi pn.e nt Notice" for vaste burial activities which was is.<ued prior to SC DEEC 's temporary suspension of our South Carolina Waste Transport Pe rm i t necessary for transport of waste in South Carolina.
Corrective action steps which GE is currently planning to take to avoid further violations include the installation of drain plugs in all vaste boxes and the use of them for verification of the r'
absence of liquid immediately prior to shipment, plus the use of
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an absorber within the box as permitted in 10 CFR 61.56(a)(2) and (b)(2) and as approved by SC DBEC per Chem-Nuclear bulletin ED-286-3, da ted 5/20/83.
Full compliance will be achieved before additional waste boxes are transferred to Chem-Nuclear.
The precise date for this compliance is indeterminate at this time, since GE must supply SC DHEC with corrective action information to secure a reinstatement of the South Carolina Waste Transport Permit and resolve the self-imposed "Stop Shipment Notice."
We anticipate that GE will be resuming compliant operations in July 1983.
l
o J.
Philip Stohr GENER AL h ELECTRIC June 30, 1983 Page 5 ATTACHMENT B General Electric denies and requests a reevaluation of the NRC classification of the subject violatiop (8 3-12-03) as Severity Level IV (Supplement V).
General Electric believes that in accordance with 10 CFR 2, Appendix C, the violation should have been classified as Severity Level V (Supplcment IV).
l The Notice of Violation cites 10 CFR 20.301, " STANDARDS FOR PPOTECTION AGAINST RADI ATION, Waste Di sposal, General Eequirement." Applicable references in 20.301 include Part 61 and 70; Part 61 is "L AND D ISPOS AL O F R A 10 ACTIVE W ASTE"; Pa rt 70 is
" LICENSING OF SPECI AL NUCLEAR MATERI AL," and it includes 70.3, l
"Li cense Requirements" a nd 7 0.4 2, "Tr ansf er of Special Nuclear Material," as applicable to the event.
A violation of 20.301, including the ref erence s to 10 CFR 61, 70.3 a nd 7 0. 4 2, can be clearly characterized as a potential safety-related concern of health physics nature involving the transfer of u,mauthorized material to a licensee who does not have the authority to receive, possess, use or store it.
In this event, the unauthorized material was f ree liquid in the waste boxes.
Transportation is clearly not.an issue, based upon the specific l
regulatory reference (20.301) in the citation and the f act that no NRC ref erences have been made to 10 CFR 71.
The inspection report which stated that return of the boxes to GE did not constitute a violation of DOT requirements additionally supports this conclusion.
Section 20.301 specifies authorized transfer, 70.3 requires authorization and 70.4 2 requires license verification as a control prior to transfer; all of these activities are clearly involved in I
10 CFR 2 Appendix C, Supplement IV, which is identified as a health physics activity area and clearly relates to 10 CFR 20.
In evaluating the saf ety/ environmental significance of the transfers, one most consider the f act that the liquids, which were non-corrosive, were a very small portion of the box contents (i.e., ranoing f rom 0.0 71 to 0.2 % of the total box volume).
The NRC requirement in 10 CFR 61.56(a)(3) and (b)(2) allows up to 1%
by volume of non-cor';osive I f quid.
Further, the analysis of samples of the liquids indicated activity concentrations of 1.2 - 1. 5 6 X 10-6 vCi/ml uranium which is only 4-51 of the 10 CFR 20 MPC values for disposal to sanitary sewer y
systers.
These considerations clearly demonstrate a very insignificant saf ety/ environmental hazard.
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GENERAL h ELECTRIC J.
Philip Stohr June 30, 1983 Page 6 ATTACHMENT B ( Con t i nu ed )
10 CFR 2 provides additional insight' relevant to the NRC enforcement action:
explains that the NRC enforcement program is acconplished by obtaining pr ompt corrective action and by detering future non-compliance.
With regard to the current violation there is clear evidence that General Elect ric t ook pronpt action to correct the problem.
Corrective actions, which were taken by GE prior to and independent of the NRC citation, and which should have a f for6ed an ex treme level of as surance that requirements vould be met, were not effective.
10 CFR 2, Appendir C, IV.A, indicates that ' licensees are not ordinarily cited for violations resulting fron matters not within their control".
There is no evidence that the violation was caused by deficient ac ti ons on th e pa r t of General Electric.
No deficiencies have been identified by GE or by the NRC in the procedures or systeas used in handling weste bcxes at Wiln ing ton.
The cause of the problem is
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extremely subtle and prevention was apparently not po s s i bl e within the SC DEEC regulations then in force.
Tne recent SC DHEC action (on 5/2 0/E 3, after our discussions with them) to alicw the use of absorbers in waste box shi pn e n ts in a fashion similar to that permitted by the NRC in 10 CrR 61, clearly indicates that the liquid in the waste boxes may have been created by non-definable technical ci r c ums t ance s ra the r than by activities which were within our control.
Ina sauch as General Electric initiated corrective action prior to receiving the NRC citation and since a change in SC DBEC requir ements was necessary to finally resolve the problem, it is not apparent that a NRC severity level IV violation (rather than the minin am severity level V) was necessary f or enforcement.
Therefore, in view of the rule cited in the violation, the minor safety and environnental significance of the incident, the guidance of 10 CFR 2, 20, 01 and 70, the subtlety of the problem and the SC DBEC action to permit absorbers, Ge neral Electric requests that the NRC reclassify the violation as Severity Level V (Suppicment IV).
This reclassification will not influence the degree of importance GE places on resolving the issue.
As we hPve committed, modification to our current procedures will be negotiated with SC DHEC to provide a higher level of assurance that our waste transfers meet the conditions of the Chem-Nuclear license in the future.