ML20204K007
| ML20204K007 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/01/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Lees E GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8608110257 | |
| Download: ML20204K007 (7) | |
Text
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JUL 011986 General Electric Company A TN: Mr. Eugene A. Lees, General Manager Nuclear Fuel and Component Manufacturing P. O. Box 780 Wilmington, NC 28402 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT NO. 70-1113/85-02 Our letter dated July 24, 1985, in response to your letter of July 16, 1985, stated that we were evaluating your response which denied Violations 1, 2, and 3 of Inspection Report No. 70-113/85-02 and that we would notify you of the acceptability of your response in the future.
After careful consideration of the bases for your denials of Violations 1, 2, and 3, we have concluded for reasons given in the enclosure to this letter that the violations occurred as stated in the Notice of Violation. Our review of your response, discussions with your staff, and subsequent inspections of your facility indicate that you have taken action to correct the violations.
Therefore no further response is required.
With regard to the discussion of the contamination control program in the CHEMET Lab presented in attachment 1 to your response, we understand the nature of the program.
We believed that at the time of the inspections (70-1113/84-15, 70-113/84-17, and 70-113/84-02) increased management attention was needed to address specific deficiencies in the CHEMET Lab Contamination Control Program.
While ve agree that even under the best of conditions, events occur that result in the spread of contamination in normally clean areas; this was not the case in the CiEMET Lab.
Your routine surveys, as well as special surveys performed at t!e request of the NRC, indicated that some areas were repeatedly contaminated above your administrative action level. In some cases, you cleaned the specific area as required by license condition without attempting to identify the cause or to take specific action to prevent a recurrence. Your staff appeared to adopt a mindset that these levels of contamination in the lab were normal rather than unusual.
Repeated identification of contamination above your administrative action level on floors and furniture is indicative of poor work practices, failure to follow procedures, or inadequate training of workers in this regard.
We recognize that the administrative action level for contamination in the CHEMET Lab at the time of the inspection was significantly below the limit for controlled areas imposed by the NRC in your license, that the action level was selected by you, and that it was equivalent to the level required to release equipment and areas for unrestricted use. However, we disagree that your policy of " cleaning up spills immediately" was effective in maintaining the lab as a relatively " contamination-free" environment.
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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC's Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely, Original Strd by R.D. Walker J. Nelson Grace Regional Administrator
Enclosure:
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In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC's Public Document Room.
Should you have any questions concerning this letter, please contact us.
Sincerely, Original Eir= d by R.D. Walker J. Nelson Grace Regional Administrator
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ENCLOSURE Staff Evaluation of Licensee Response to Inspection Report No. 70-1113/85-02 Dated July 16, 1985 I.
Violation 1 In your response, you denied that the drums were improperly labelled in that' the readings were obtained and documented using approved procedures, instrumentation, and techniques by qualified and trained Radiation Protection Technicians. You also stated that neither General Electric nor NRC review has indicated any violation or weakness in the program and that a similar occurrence had been investigated during an NRC inspection conducted on February 21-24, 1984 (Inspection Report No. 70-1113/84-04), without identifying any deficiencies in GE's program.
NRC Response:
While the inspector was unable to identify any specific weaknesses in your procedures for preparing radioactive material for shipment, in the qualification and training of radiation protection technicians who perform pre-shipment surveys, in the calibration of the radiation survey instruments, or in the technique for performing the surveys as was demonstrated by the technicians during the inspection, a violation of ~NRC regulations did occur. Since we did not observe the technician perform the actual pre-shipment survey, we cannot unequivocally state that the proper technique was used or that the survey instrument performed properly.
However, as stated in the inspection report, the shipment was surveyed by an NRC Region V inspector, and those readings were confirmed by a GE Vallecitos, CA survey, which was performed with an instrument of the type used by GE Wilmington. These surveys indicated that the radiation levels on twelve drums labelled with "RADI0 ACTIVE WHITE I" labels exceeded the values reported on your survey by 60-120 percent.
With regard to your discussion of a similar occurrence which was reviewed during an inspection in February 21-24, 1984, a significant difference exists between the two occurrences. The previous occurrence involved the shipment of new fuel to a nuclear power plant. Although the power plant receiving the fuel noted the discrepancy in the labelling, the shipping containers were opened and the fuel was removed before the NRC became aware of the potential violation of NRC regulations.
Therefore, no confirmatory surveys could be performed.
Based on the information available, the NRC could not conclude that you had improperly labelled the containers.
In the later case, the NRC performed the surveys, and the results were confirmed by an independent survey performed by GE Vallecitos at your request.
It is still our position that the twelve BU-7 drums were improperly labelled, and a violation of NRC regulations did occur.
Enclosure 2
Violation 2 In your response, you denied that the individuals in the training class were not instructed in the subjects required by 10 CFR 19.12. Specifically, you stated that: (a) each individual in the class was provided with a personal copy of 10 CFR 19; (b) the ' specific subjects noted in the violation as having been omitted from the instruction (an individual's responsibility to report promptly to the licensee any condition which may lead to or cause a violation of Commission regulations and licenses or unnecessary exposure to radiation and a discussion of radiation exposdre reports which workers may request pursuant to 10 CFR 19.13) were presented orally; (c) questions on the written test concerning records availability and reporting unsafe conditions were correctly answered by the class members; (d) written material provided to the individuals specifically discussed report availability and responsibility of workers to report violations to the licensee; and (e) that reporting and exposure report availability are included on the NRC Form 3 posted pursuant to 10 CFR 19.11.
NRC Response:
10 CFR 19.12 requires that all individuals working in or frequenting any portion of a restricted area be instructed in a number of subject areas including the reporting to licensees of conditions that could lead to or cause a violation of NRC regulations or unnecessary exposure and the availability of radiation exposure reports. While providing a copy of 10 CFR 19 to workers during training may be appropriate, the NRC does not consider that this meets the requirement of Part 19.12 to instruct individuals. The oral presentation should reinforce and amplify the written material.
As stated in the inspection report, GE 4 tended that the instructor cover the two areas which the violation identified as missing, as evidenced by the fact that they were included in the course lesson plan.
In discussions with the instructor following the class, the instructor acknowledged that the reporting of violations and report availability areas had been orally presented to previous classes, however, they were not addressed during this particular class.
The fact that the individuals attending the course correctly answered two questions concerning reporting unsafe conditions and records availability is not an indication that they received instruction in the areas.
As previously stated, giving the individual written handouts covering the specific requirements of 10 CFR 19.12 does not meet the requirement of 10 CFR 19.12 for the licensee to instruct individuals in the specific areas.
Finally, the fact that the reporting and exposure report availability information is contained on the NRC Form 3 which is posted pursuant to 10 CFR 19.11 does not materially alter the fact that 10 CFR 19.12 requires that individuals receive instruction in this areas. The posting of the NRC Form 3 is an additional requirement.
1
Enclosure 3
l In conclusion, it is our pcsition that the individuals attending the training class on January 9,1985, were not instructed in all the required subjects specified in 10 CFR 19.12.
Violation 3 In your response, you'did not deny the observations of the inspector but you did state that:
(a) you take issue with the inspector's opinion that unbuttoned lab coats are an impropriety leading to a radiological hazard and/or a violation of license conditions, regulations, or procedures; (b) deny that waste was being disposed of improperly since only yellow polyethylene bags are used to accumulate waste in the CHEMET Lab; and (c) sampling small quantities of powder on an analytical balance outside of a vented hood has been standard operating procedure for years and that weighing of samples on an analytical balance was not included in the definition of processing as defined in Nuclear Safety Release / Requirement 6.2.7.14.
NRC Response:
Part I, Paragraph 3.2.4.4, of the license application specifies that the minimum clothing requirement for entry into the Wet Lab and Spectrographic Lab.is a lab coat and safety glasses. It is inherent in the requirement to wear protective clothing in a radiologically controlled area (CHEMET Lab) that the protective clothing be worn properly.
In the case of lab coats, they should be completely buttoned.
In discussions with radiation protection and CHEMET Lab supervisory personnel during the inspection, they all indicated that the lab coats should be completely buttoned.
In addition, you stress the proper wearing of protective clothing during your
" red bar" or general employee controlled area training.
The kind of protective clothing required for an area should be based on the potential radiological hazard in the area; however, once the requirements are established, individual workers do not have the option to wear it any way they see appropriate. Licensee management is expected to require employees to properly wear protective clothing designated for an area.
Nuclear Safety Release 6.1.0 requires that the CHEMET Lab radioactive waste be disposed of in containers that are labelled with a " radioactive material" or a " contaminated waste" label. The disposal of radioactive waste was not an issue during the inspection; but, rather a requirement contained in an approved procedure which was not being fol. lowed in that the bags of waste were not properly labelled.
Although the bags of radioactive waste in the CHEMET Lab contain small quantities of radioactive material and labelling may not have been required by 10 CFR 20, your procedure required special labelling, and we would expect you to require your employees to adhere to that procedural requirement.
Nuclear Safety Release / Requirements 6.1.7.14, 6.1.7.29 and 6.1.7.41 require that loose uranium powder be sampled and/or processed in a hood in the rare earth preparation area of the Spectrographic Lab.
We understand the
. ~ E'nc'losure 4
l difficulty in obtaining accurate results from balances located in vented hoods due to vibrations and air flows; nonetheless, your procedures require that powder processing or sampling in the rare earth preparation area of the Spectrographic Lab be performed in hoods. Although you stated that Nuclear Safety Release / Requirement 6.2.7.14 was written to designate where
" processing" of powder samples should occur, the procedure did not exclude sampling from the definition of " processing." In addition, Nuclear Safety Release / Requirement 6.1.7.29 specifically states that " loose powder may not be processed or sampled outside hood."
In conclusion, it is our position that in each instance above you failed to follow approved written procedures.
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