ML20197J780
| ML20197J780 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/08/1986 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 26983, NUDOCS 8605200168 | |
| Download: ML20197J780 (7) | |
Text
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be GENERALO s'acTaic NUCLEAR FUEL & COMPONENTS MANUFACTURING GENERAL ELECTRIC COMPANY
- P.O. BOX 780
- WILMINGTON, NORTH CAROUNA 28402 7'*.,,
May 8, 19 8 6 o s 12 P f,.
Dr. J. Nelson Grace, Regional Administrator U. S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/86-01, 4/08/86 (3) NRC Inspection Report 70-1113/84-04, 3/23/84 Thank you for your letter reporting the results of the inspection conducted on February 3-5, 1986 at our licensed fuel fabrication plant by Mr. P. G. Stoddart of your office.
Response to the first apparent violation identified during that inspection is contained in Attachment 1.
General Electric is distressed by the recent NRC action related to item 84-04-02 identified during a February 1984 inspection.
(See Reference 3.)
General Electric's denial and request for immediate withdrawal of this item is addressed in Attachment 2.
General Electric is additionally concerned with the timing of this action and its mere substitution of one individual's judgment for another's which renders the action wholly punitive and unhelpful to the licensee.
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 yours, GENERAL ELECTRIC COMPANY h hbe 4
-3 T. Preston Winslow, Manager Licensing & Nuclear Materials Management M/C J88 Attachments TPW:bsd cc Mr. J. Philip Stohr NSD-I ptg2;o,ggeg9ggj"gga C
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GENER AL $ ELECTRIC Dr. J. Nelson Grace May 8, 1986 Page 1 of 3 ATTACHMENT 1 The information given below refers to the item in Enclosure 1, Notice of Violation, in the NRC Report 70-1113/86-01, dated 4/8/86.
License Condition 9, of License No. SNM-1097, Docket No. 70-1113, requires the licensee to operate in accordance with the statements, representations, and conditions of Part 1 of the licensee's application dated May 14 and June 20, 1984.
Part 1, Section 2.7,
" Operating Procedures -
Administrative Controls", requires area managers to assure prepacation of written procedures and established reeuirements for a " comprehensive set of written instruations for radiation health and sai ty",
including Environmental Protection Inr.cructions.
Contrary to the above, Procedure No. 340-FME-85-70, "HEPA Filter Change and Certification", Rev. O, dated March 18, 1985, which was used for installation of HEPA filters in the 546-X filter system in November 1985, was inadequate in that it did not provide sufficient written instructions for the correct installation of filters resulting in the defective installation of eight HEPA filters out of a total of 32 HEPA filters.
This is a Severity Level IV violation (Supplement VI).
General Electric concurs with the above finding.
However, three items contained in Enclosure 1 of the inspection report require clarification and/or correction.
First, page 3 item 4 states "Four individuals who were working in the process area at the i
time..." should more correctly be stated as "Four individuals who were working outside the process area in the projected path of the plume at the time...".
Second, item 5 page 4, 13.5 x 10- 12 pCi/cc should be 13.5 x 10-11 pCi/cc.
Third, item 6 page 5, l
GENERAL $ ELECTRIC Dr. J. Nelson Grace May 8, 1986 -
Page 2 of 3 second paragraph, indicates the title of the filter change procedure to be misleading in that no certification was provided as assurance that filters had been properly installed.
Although the title "HEPA Filter Change and Certification" may have been brief, the certification portion of the procedure was intended only to apply to the activities for the weighing of HEPA filters.
Item 4, page 2, of Enclosure 1 correctly pointed out that the uranium content of the HEPA filters could not be evaluated pending a 60-day delay for decay product equilibrium.
The 60-day period has been completed and the HEPA filters uranium content has been established and is available for NRC review, if required.
As correctly identified in the NRC inspection report, the direct cause of the emission release from stack 546X on January 22, 1986, was the improper installation of HEPA filters during routine filter changeout activities November 21, 1985.
Investigation of the 546X secondary filter housing on January 23, 1986, identified one bank of eight HEPA filters where the clamping devices had not been clamped during installation.
Subsequent investigations determined that the November 21, 1985, filter changeout activities had involved a special team of nine persons due to the number of filters to be changed in 546X and other units in the same time period.
Although each of the nine individuals had previously been trained and had satisfactorily performed filter changes in the past, seven of the individuals had not been involved in filter changes over the most recent several months.
Based on management reviews with each of the individuals involved with the November 21, 1985, filter change activities, it was concluded that operator error most likely occurred by failure to engage the clamping device for the eight HEPA filters.
As required by our license, the January 22, 1986, incident was classified as a Class II incident and an investigation team was established under the leadership of the Manager - Regulatory Compliance to review the incident, make recommendations, and identify required corrective actions.
As the secondary filter systems are designed to handle routine as well as unplanned movement of radioactive material in the HVAC system and the cited violation relates to the filter system, the corrective actions for the dry conversion system will not be presented herein.
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GENER AL$ ELECTRIC Dr. J. Nelson Grace May'8, 1986 - Page 3 of 3 With respect to the. improper HEPA filter installation, immediate actions were taken to establish HVAC maintenance teams to inspect all secondary filters for radioactive areas of the plant to assure proper clamping and correction if required.
This inspection activity was initiated on January 23 and completed on February 8, j
1986, for 438 filters in all secondary filter banks for all exhaust points of licensed material.
No filter was found in an unclamped position.such as those found in the filter bank for'546X l
on January 22, 1986.
l Corrective actions which have been or will be taken to prevent the recurrence of improper filter installation involve several quality l
control checks to assure that each secondary HEPA filter is properly installed.
Administrative procedure SAR 340-FME-85.70, which provides the requirements for filter change activities and for certification of j
filter'weighings, was revised on 2/5/86 to require:
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Training and qualification of all personnel who change HEPA filters (previously, only filter weighing personnel required qualification).
(b)
$ one-over-one sign-off for-the installer and the applicable supervisor for each HEPA filter l.
change in secondary banks to assure proper positioning of the HEPA filter, proper operation of the clamping device, and adequate sealing of the HEPA filter.
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Additionally, based upon recommendations contained in inspection report 86-01, SAR 340-FME-85.70 will be revised by May 30, 1986, l
to specify the requirements for the specific quality checks i
relative to orientation of filters, gasket-to-frame gaps, and l
degree of gasket compression.
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The above corrective actions taken or to be taken will result in l
full compliance by May 30, 1986.
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r GENER AL h ELECTRIC Dr. J. Nelson Grace May 8, 1986 - Page 1 of 3 ATTACHMENT 2 The information provided below is in response to the apparent violation identified in Enclosure 1 of inspection report 70-1113/86-01 dated 4/8/86.
Violation (2) reads as follows:
10 CPR 71.0(d) requires licensees who transport licensed material or deliver licensed material to a carrier for transport to comply with the quality assurance requirements contained in Subpart H of 10 CPR 71.
10 CFR 71.113, in Subpart H, requires licensees to establish measures to assure that documents, including changes, are reviewed for adequacy and approved for release by authorized personnel.
Contrary to the above, on February 24, 1984, changes to Procr.ures FS-7 and FS-36, which specified the licensee's methods for assuring that licensed material delivered to a carrier met the requirements of the Department of Transportation and the NRC, had not been approved for release by authorized personnel.
This is a Severity Level V violation (Supplement V).
General Electric Company denies that a violation existed and hereby requests withdrawal of the above referenced violation.
Referenced procedure FS-7, " Radioactive Material Shipments",
references General Electric form NEO-374, " Radioactive Materials Packaging & Shipping Record, and referenced procedure FS-36, " Low Level Radioactive Waste Shipments", contains as typical exhibits form NEO-374 and Chem-Nuclear Systems, Inc., form CNS-201, "Barnwell Waste Management Facility Radioactive Shipment Manifest".
These documents are general purpose radioactive transportation forms which provide manifest, transportation, financial and site-related information.
When completed per the separate instruction for each form, the form primarily fulfills the requirements for shipping papers (49 CFR Part 172, Subpart C) and, in the case of CNS-201, provides other information required by a specific site licensee.
They do not provide information related to 10 CFR 71, Subpart H, Quality Assurance.
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GENERAL $ ELECTRIC c-l Dr.
J.' Nelson Grace
~'E May 8, 1986
' - Page 2 of 3 The gexts of FS-7 and FS-36, therefore, did not require specific revision due to the subject 1983 DOT and NRC regulation changes.
During the February 1984 NRC inspection, FS-7 and FS-36 were in the process of being revised to incorporate minor non-regulatory modifications and/or to insert current exhibits (i.e., forms NEO-374 and CNS-201).
There were no text revisions in FS-7 and FS.36 as a condition of compliance with the 1983 NRC and DOT regylation changes.. However,. changes to the concomitant instructions for completion of' form NEO-374 and CNS-201 were required.
These revisions were accomplished in a timely manner and. compliance wa,s maintained as stated by the inspector in Inspection Report 06-01:
"The shipping forms for radioactive material had been revised.
In addition, review of shipping records by the inspector indicated that' shipments made by the licensee i.
had been in accordance with the revised DOT and NRC regulations."
Measures were-and continue to be in place to assure compliance s
with the requirements of 10 CPR 71.113.
Approvals are required for any radioactive shipping procedures which'contain quality assurance requirements.
Proced're FS-7 does not provide any u
shipping container quality assurance relative to control of the physical characteristics or material / components, therefore, procedure FS-7 only required the approval of the manager of the traffic function.
Procedure FS-36, however, does provide for quality assurance control of the container.
Consequently, FS-36 requires approval of other cognizant functional organizations.
At the time of the February' 1984 inspection, properly approved revisions of FS-7 and FS-36 were in place.
General Electric Company knows of'n'o justification for the NRC to issue a violation in this matter.
There was, as described above, w
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no violation of regulations.
Furthermore, even if there had been, issuing a violation at this late date (aftdr more than two years) serves no useful purpose related to public or employee safety.
The violation is confusing and misleading to the public, and is punitive and unhelpful to our effort to initiate self-identification and correction of proble,ms.
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GENERAL $ ELECTRIC Dr. J. Nelson Grace
.May 8;, 1986 - Page 3 of 3 This is a case where a knowledgeable, well trained inspector, aware of the number of regulatory changes promulgated by the DOT and NRC during 1983, made an observation that the licensee should assure that licensee procedures are up-to-date.
He found nothing wrong and used procedures FS-7 and FS-36 as examples.
His individual actions were similar to and consistent with IE Notice 84-14, " Highlights of Recent Transport Regulatory Revisions by DOT and NRC", issued by the NRC at a later date (3/02/84).
The subject alleged violation was written without any useful purpose by individuals within the NRC who apparently did not properly take inte account the inspector's observations and reporting or the true purpose and intent of the subject regulations.
General Electric accordingly requests that this stated violation be withdrawn.
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