ML20210S070

Final Response to FOIA Request for GE ,J Stohr to Lees & Memo Re 850710 Telcon Between Collins & CM Vaughan Concerning Insp Rept 70-1113/84-15.Forwards App a Documents.Documents Also Being Placed in PDR

ML20210S070
Person / Time
Site:	07001113
Issue date:	04/30/1986
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Ratner M RATNER, M.G.
References
FOIA-86-230 NUDOCS 8605200425
Download: ML20210S070 (2)

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. . TW4 i o l pn nec UNITED STATES jo NUCLEAR REGULATORY COMMISSION 8 g W ASHINGToN. D. C. 20555 3 I

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APR 3 0 556 Mr. Mozart G. Ratner 4400 Jenifer Street, NW ,

Suite 350 IN RESPONSE REFER Washington, DC 20015 TO FOIA-86-230

Dear Mr. Ratner:

This is in regard to your request, pursuant to the Freedom of information Act, to which the NRC assigned the above number.

This is a partial response to your request. We will .-

notify you upon completion of search for and review of any additional records subject to your request.

_X__ The staff has completed the search for and review of ,

records subject to your request, and this is the final response to your request.

The NRC has no records subject to your request.

Records subject to your request'are available for public inspection and copying at the NRC Public Document Room

= (PDR), 1717 H Street, NW, Washington, DC 20555, as noted on the enclosure (s). The PDR accession number is identified beside each record description.

X Records subject to your request are being made available for public inspection and copying at the NRC Public Document Room (PDR), 1717 H Street, NW, Washington, DC 20555, in the PDR file folder undar the above number and your name. These records are listed on the enclosure (s). ,

We are enclosing a notice that provides information about charges and procedures for obtaining records from the PDRJ Sincerely, DoEdieH.Grimsley, Director Division of Rules and Records Office of Administration Enclosure (s): As stated 8605200425 860430 PDR FOIA f RATNER 86-230 PDR

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l Appendix A-Records Being Placed in PDR

! 1. 03/07/85 Ltr. to J. Stohr from C. Vaughan re: 1) NRC License SNM-1097,

! Docket #70-1113, and 2) NRC Insp. Report 70-1113/84-15 dated i 2/07/85, received 2/11/85 (4 pgs.)

! 2. 05/09/85 Ltr. to J. Stohr from C. Vaughan re: 1) NRC License SNft-1097, l Docket #70-1113,2) NRC Insp. Report 70-1113/84-15 dated 2/07/85, ,

received 2/11/85, and 3) Ltr., JP Stohr to EA Lees, 4/9/85 (4 pgs.).

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l GENER Al h ELECTRIC (8 WUmeGTON MANUFACTURNG DEPAATMENT GOERAL ELECTWC COMMNY

• PO BOX 700 41LMNGTON, NORTH CAROLNA 98409 C

May 9, 1985 ,,

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% %W Mr. J. Philip Stohr, Director -

1. Y Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission, RII -o hh

- cs 101 Marietta Street, NW - Suite 2900 m $%

Atlanta, Georgia 30303 r@

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Reference:

(1) NRC License SNM-1097, Docket i 70-1113 (2) NRC Inspection Report 70-1113/84-15 dated 2/07/85, received 2/11/85 (3) Letter, JP Stohr to EA Lees, 4/9/85 As requested in Reference 3, attached is a supplemental response to the item of apparent noncompliance with NRC requirements which was identified during the inspection conducted at our licensed fuel fabrication plant by Mr. E. L. Clay of your office on November 13-16, and December 3-7, 1984. This attachment is marked pursuant to Reference 2.

We appreciate your inspector's comments and suggestions related to public and employee health and safety. These comments and suggestions are helpful to us in our constant efforts to improve these programs, and ensure our compliance with NRC_ regulations.and license conditions. We also welcome further discussion with your staff on the item-in your letter and in our related reply, if necessary, for further clarification of this item.

Sincerely, GENERAL ELECTRIC COMPANY ff9 f& 4Sf- (zafh~~-

Charles M. Vaughan, Manager Regulatory Compliance M/C J26 c

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GENERAL , ELECTRIC i

Mr. J. Philip Stohr May 9, 1985 Attachment - Page 1 ATTACHMENT On March 7, 1985, General Electric Company responded to the

" Notice of Violation," in NRC Inspection Report 70-1113/84-15, dated 2/07/85. On April 9, 1985, the NRC requested supplemental information (letter, JP Stohr to EA Lees), which is provided as follows.

"Your letter appears in error in that the inspector did not accompany the technician into the LEA room for the survey performed on the morning of November 78, 1984."

General Electric has re-reviewed the details and circumstances associated with the special survey conducted on 11/28/84 at approximately 0900, and has found the following:

(1) NRC Inspector C. M. Hosey requested Radiation Protection support on the morning of 11/28/84 to perform a special survey of the Chemet Laboratory.

(2) J. E. Williams, Radiation Protection Technician, was dispatched to the Chemet Lab to support Hosey.

(3) Williams indicates that ,Hosey provided direction and identified the areas to be surveyed. William's impression was, and continues to be, that Hosey was with him all or most of the time he was performing the work for Hosey. Williams does indicate,,however, that he cannot swear to the fact that Hosey was in close contact with him at the time Williams made the requested measurement in the LEA room.

General Electric apologizes for any miscommunication or misunderstanding resulting from the phrase " performed in the presence of an NRC inspec-tor". We believe that your inspector will concur with the information included in this clarification.

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G EN E R Al; f) El.ECTRIC j Mr. J. Philip Stohr May 9, 1985 Attachment - Page 2

"[P]rovide us ... w!.th a written statement of the actions you have taken or plan to take to correct and prevent recurrence of this violation ..."

As stated in our 3/7/85 response and clarified here, several actions have been implemented in the Chemet Lab to increase the effectiveness of the Lab contamination control program. These were as follows:

o The importance of recognizing and immediately cleaning up spills was're-emphasized to Lab employees. These communications are documented in internal memorandums maintained by Chemet Lab supervision.

o Internal lab procedure Calibration & Operation Instruction (COI) 8409, " Isotopic and O/U Analysis Using Gravimetric Techniques",

Revision 3, was issued to provide guidelines for prevention of contamination and spills within the LEA measurement room.

o An independent self-monitoring program for fixed and smearable contamination was implemented which augments the long standing contamination control program in the Chemet Lab and enables Lab personnel to be more effective in cleaning up spills, o The number of locations tested for fixed and removable contamination during routine surveys has been temporarily increased.

Also in ou 3/7/85 hesponse, we indicated that the NFMD contamination survey program is under review to continue to help define any additional avenues for improvement. Since 3/7/85, additional measures have been implemented to increase the Chemet Lab contamination program e,ffectiveness as follows:

o Radiation Protection personnel, working with Chemet Lab supervision, have identified areas in the Lab where a potential for spills exists. These areas are being incorporated into the routine survey program effective no later than 5/31/85.

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.. l GENER AL @ ELECTRIC Mr . J . Philip Stohr May 9, 1985 ,

Attachment - Page 3 '

l o The Chemet Lab Nuclear Safety Release / Requirement (NSR/R 6.1.0) is being modified to include a Radiation Protection notification requirement for large spills of radioactive materials and to provide clarity in the requirements of the radiation protection program as applied to the Chemet Lab.

Some of the changes were incorporated in Revision 5 on 3/8/85.

The remaining changes will be implemented no later than 5/31/85.

o Recognizing that unencapsulated uranium is handled in the Lab and that this area is designated as a restricted area with special controls, the internal administrative action limits for the Chemet Lab have been increased from 220 dpm (smearable) and 2200 dpm (fixed), to 1000 dpm (smearable). This action will allow the Lab operations to be carried out appropriately while, at the same time, maintaining acceptable removable contamination levels consistent to those specified in Section 1.8.2 of SNM-1097. These levels are acceptable for release of facilities and equipment for unrestricted use and therefore justifiable within the Chemet Lab.

... and the date when full compliance will be achieved."

The identified program will enable GE to be in full compliance by May 31, 1985.

i CM Vaughan

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. GENERAL h ELECTRI. .

WueeG10N 6 00MTMENT spent ELEC1mc COMmNr. PO. 00K NO . WUNNGlON, NOmH CMOLMA 940t March 7, 1985 s

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Mr. J. Philip Stohr, Director Z:

Division of Radiation Safety and Safeguards jG R[

r7 *,i U.S. Nuclear Regulatory Comunission, RII -

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101 Marietta Street, NW - Suite 2900

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Dear Mr. Stohr:

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Reference:

(1) NRC License SNM-1097, Docket # 70-1113 (2) NRC Inspection Report 70-1113/84-15 dated 2/07/85, received 2/5,1/85 Thank you for your letter reporting the results of the inspection L. Clay conducted at our licensed fuel fabrication plant by Mr. E. l of your of fice on November 13-16, and December 3-7, 1984.

Pertaining to the one item of apparent noncompliance with NRC requirements in your letter, the reply to this item is given in the This attachment is marked pursuant to attachment to this letter. -

1 Reference 2. . . ..u

! Ne appreciate your inspector's consnents and suggestions related to

public and employee health and safety. These comments and 1 suggestions are helpful to us in our . constant efforts to improve

' these programs, and ensure our compliance with NRC regulations and j license conditions. Ne also welcome further discussion with your staff on the item in your letter and in our related reply, if 5 necessary, for further clarification of this item.

Sincerely, l' .

GENERAL ELECTRIC COMPANY k.O

' Charles M. Vaughan, Manager Regulatory Compliance

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, G EN ER Ath ELECTRIC Mr. J. Philip Stohr March 7, 1985 l

ATTACBMENT The information given below refers to the item in Enclosure 1,

' Notice of Violation," in the NRC Inspection Report 70-1113/84-15, dated 2/07/85.

License Condition 9 requires that licensed material be used in accordance with the statements, representations, and conditions of Part 1 of the licensee's application. Part 1, Section 2.2.1.1 of the licensee's application ,

requires that the Area Manager establish and approve written operating procedures (

incorporating radiation safety controls.

1 Contrary to the above, the requirements of the l license condition were not met, in that on l 4 December 3, 1984, visible uranium <

contamination was observed in the LEA l measurement room which had not been cleaned up immediately as required by plant procedure Nuclear Safety Release 6.1.0.

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

General Electric Company acknowledges that on 12/3/84 visible contamination was observed in the low enrichment analyzer (LEA) measurement room.

The reason the contamination had not been cleaned up by laboratory personnel, in accordance with Nuclear Safety Release requirement 6.1.0, Rev. 4, was that the spill had not been reported or observed, during routine surveys or otherwise, prior to the NRC inspector identifying it. The area involved had been surveyed by Radiation Protection during an NRC inspection (70-1113/84-17) ,

on day shift, 11/28/84, and a second time on the next working shift. The first survey was performed in the presence of an NRC

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, GENERAL h ELECTRIC Mr. J. Philip Stohr March 7, 1985 Attachment - Page 2 inspector. No contamination above the action guidelines was observed or detected during either of these surveys.

I Once the spill was identified, it was immediately cleaned up.

Laboratory personnel were verbally alerted to the situation and reminded that established procedures require immediate clean-up of l- radioactive material spills.

/ In order to avoid further violations of this type and to assure l compliance with existing NFMD procedures, the Chemet Lab has f instituted an independent self-monitoring program for fixed and smearable contamination in addition to the regularly scheduled Radiation Protection area surveys. This activity is independent I of and does not constitute a component of our licensed radiation I protection program. It does, however, provide a technique for the laboratory personnel to verify the ef fectiveness of their clean-up procedures.

Concurrently, we have been reviewing the routine radiation a protection survey practices. The current practices were designed to monitor high traf fic areas and selected work stations. The theory supporting this type of program is that monitoring these areas would be most ef fective in detecting contamination.

Since the subject NRC inspection, the number _pf points surveyed by Radiation Protection and their frequency have been temporarily increased in the Chemet Lab to more clearly define the

'ef fectiveness of laboratory practices and the self-monitoring program... Surveys in the lab have been expanded to include areas that are not normally accessible to personnel in addition to' the normal workspace locations. We expect this program to provide information to help in defining any additional avenues for improvement.

Chemet Lab.. supervisors have re-emphasized to lab employees the importance of recognizing and immelfat~ely cliaiiinfup spills of contamination by anyone. Internal lab pgocedures will be updated to provide guidelines for prevention of contamination within the LEA measurement room and the Chemet Lab.

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GENERAL $ ELECTRIC Mr. J. Philip Stohr March 7, 1985 Attachment - Page 3 ,

The identified program will enable GE to be in full compliance by l May 31, 1985.

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4 - g CM Vaughan

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