ML20203H480

Responds to 850925 Request for Withdrawal of Violations 1 & 2 of Insp Rept 70-1113/85-04.Violation 1 Deleted from Records.Corrective Actions for Violations 2 & 3 Acceptable. No Further Response Required

ML20203H480
Person / Time
Site:	07001113
Issue date:	07/07/1986
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Lees E GENERAL ELECTRIC CO.
References
27240, NUDOCS 8608040425
Download: ML20203H480 (3)

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g General Electric Company-ATTN: Mr. Eugene A. Lees, General Manager g RECElVED ,

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P. O. Box 780 9- u.s. NUCLEAR REGULATORY Wilmington, NC 28402 - UEjj" C'

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SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 70-1113/85-04)

Our letter dated October 21, 1985, in response to your letter of September 25, 1985, stated that we were evaluating your response and that we would notify you of the acceptability of your response in the near future.

Af ter careful consideration of the bases for your request for the withdrawal of Violations 1 and 2, we agree with your position regarding Violation 1 and have deleted the violation from our records. Violation 2 did not meet the self-identification criteria in that the violation was not identified by you, but rather by the receiver of the package containing the missent radioactive material. Therefore, the issuance of Violation 2 was appropriate.

With regard to your response to Violation 3, you denied the part of the violation thcc states that all bioassay data must be included in the database used to genet ate a radiation exposure termination report required by 10 CFR 19.13(c).

Specifically, you ask us to clearly indicate that it is not necessary to include each urinalys.is and lung count result in termination reports. As noted in the details of the Inspection Report, the violation was issued primarily because you failed to include all of the available assigned airborne data in the determination of the internal dose reported in the termination report issued in accordance with 10 CFR 19.13(c). You took no exceptions to that part of the violation. When you generated the termination report in question, you had other data (urinalysis and lung count results) available which should have been evaluated before concluding that the omission of the data wculd not significantly effect the internal dose reported on the termination report As stated in your response and in the Inspection Report details, you have on occasion substituted the dose calculated from lung count data for that calculated from the assigned airborne data because that dose was more conservative. It is the NRC position that all the available data should be used to arrive at the best estimate of internal dose received by a worker. However, you are not required by NRC regulations or license condition to list the results of each urinalysis or lung count on the termination report. It is acceptable to calculate an internal dose considering all,the data available and to report this value on the termination report.

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e . . kneral Electric Company 2 The corrective actions for Violations 2 and 3 reported in your response are acceptable and no further response is required. We will examine the implementation of your corrective actions for Violations 2 and 3 during future inspections. -

We appreciate your cooperation in this matter.

Sincerely, r

J. Nelson Grace Regional Administrator cc: T. Preston Winslow, Manager Licensing and Nuclear Materials Management 0

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