ML20207A872

Notice of Violation from Insp on 860929-1003

ML20207A872
Person / Time
Site:	07001113
Issue date:	10/31/1986
From:	Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207A870	List: ML20207A866 ML20207A872 ML20207A883
References
70-1113-86-19, NUDOCS 8611110365
Download: ML20207A872 (3)

Text

ENCLOSURE 1 NOTICE OF VIOLATION General Electric Company Docket No. 70-1113 Wilmington, NC License No. SNM-1097 During the Nuclear Regulatory Comission (NRC) inspection conducted on September 29 - October 3,1986, violations of NRC requirements were identified.

The violations involved failure to meet Department of Transportation requirements for shipment of empty radioactive material packages, failure to calibrate airline pressure gauges or flow measuring devices for supplied-air hoods, and failure to follow written, approved procedures. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

-A. 10 CFR 71.5(a) requires a licensee who transports licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, to comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.

49.CFR 173.427(c) specifies that any packaging which previously contained radioactive materials and has been emptied of contents as far as practical, was excepted from DOT marking and labeling requirements provided that internal contamination does not exceed 100 times the limits specified in '

49 CFR 173.443(a) (22,000 disintegrations per minute per 100 square centimeters).

Contrary to the above, 00T requirements were not met in that on April 20, 1985, a uranyl nitrate cargo tank was shipped as an " EMPTY" package without performance of surveys to demonstrate that internal contamination was less than the limit established by 49 CFR 173.427(c).

This is a Severity Level IV violation (Supplement V).

B. 10 CFR 20, Appendix A, Footnote h, states that a protection factor of no more than 1000 may be used for tested and certified supplied-air hoods provided that a minimum air flow of six cubic feet per minute was maintained and calibrated airline pressure gauges or flow measuring devices were used.

Contrary to the above, the requirement that calibrated airline pressure gauges or flow measuring devices for supplied-air hoods be used in order to BlollllDS/4 swasi PW AbecXs 0700f H3 C P6A

General Electric Company Docket No. 70-1113 Wilmington, NC 2 License No. SNM-1097 take protection factor credit was not met in that from 1978 to October 1, 1986, the supplied-air system provided for workers in the New Decon room did not utilize pressure gauges or flow measuring devices that had been calibrated and protection factor credit had been taken for estimating workers' exposure to airborne radioactive material.

This is a Severity Level IV violation (Supplement IV).

C. Condition 9 of Special Nuclear Material License No. SNM-1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the License Application ' dated May 14, June 20, September 24, October 23, November 12, November 20, December 3, and December 19, 1984.

Part I, Section 2.2.1.4 of the SNM-1097 Application requires that radiation protection function activities be conducted in accordance with written procedures.

Process Requirement and Operator Document (PROD) No., 80.20, Breathing Air System, Revision 5, June 18, 1980, requires that the performance checks of the breathing air system specified in Attachment I to the procedure be performed prior to use of.the system and that a log be maintained documenting the performance checks.

Contrary to the above, the requirement to perform checks of the breathing ~

air systems prior to use and to document these checks in.a log was not met in that on October 2, 1986, the inspector determined that the requirements of PROD No. 80.20 had not been met in that:

1. no log book had been maintained, and ,

2. no performance checks had been performed prior to the use of the systen.

This is a Severity Level IV violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, General Electric is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a. written statement or explanation in reply including for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the

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General Electric Company Docket No. 70-1113 Wilmington, NC 3 License No. SNM-1097 results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION hf k-p J. Philip Stohr, Director Division of Radiation Safety and Safeguards Dated at Atlanta, Georgia this 31 day of October 1986

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