ML20211M560
| ML20211M560 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/03/1985 |
| From: | Barr K, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20211M455 | List:
|
| References | |
| FOIA-86-704 70-1113-85-12, 70-1113-85-12-0, NUDOCS 8612170343 | |
| Download: ML20211M560 (11) | |
Text
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e ATLANTA. GEORGI A 30323
% ,',,. . / SEP 0 5 885 Report No. 70-1113/85-12 Docket No. 70-1113 License No. SNM-1097 Safeguards Group No. III Licensee: General Electric Company Nuclear Fuel Manufacturing Department Wilmington, NC Date of Inspection: June 15, 1984 Type of Inspection: Announced Management Review Inspector: 1 m.
E. J. McAlpin_eg Chief, Mhterial Control and 8/30 /8 5 Date Signed AccountabiliiW Section Approved by: h K. lY. Ba r r , ChTe'f , Nuc l e a r Ma te ri a l s 93 I
/ /Date' Signed Safety and Safeguards Branch, Division of Radiation Safety and Safeguards
SUMMARY
Scope: This special inspection entailed 6 hours on site in the area of regional management review of licensee actions on allegation followup. Results: No violations or deviations were identified. l t 8612170343 861205 PDR FOIA RATNER 86-704 PDR N
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*ir.:s Docu1cnt is not to be
,* reproduced without specific i appro val of IE:II REPORT DETAILS Report No. 70-1113/85-12 l
- 1. Key Persons Contacted
*W. J. Hendry, Manager, Regulatory Compliance R. I. Parnell, Control Programs Engineer
*C. M. Vaughan, Manager, Licensing and Nuclear Materials Management
- Denotes those present at the exit interview
- 2. Exit Interview The inspection scope was summarized on June 15, 1984, with those persons indicated in Paragraph I above. The inspector informed the licensee that since the NRC's and the licensee's reviews of one allegation reached different conclusions, a discussion between the NRC and the leader of the licensee's review team would be necessary. The purpose of the dis:v:sion would be to determine the scope of licensee's review and to understand the basis for the licensee's conclusion. The licensee stated that coordination through the Quality Assurance Manager would be necessary, and agreed to perform that coordination. The discussion with the review team leader is summarized in paragraph 6.
- 3. Licensee Action on Previous Enforcement Matters The subject was not addressed in the inspection.
- 4. Document Review Note: The pronoun "he" is used through this report without regard to the sex of the individual.
During a previous inspection (70-1113/84-05), the NRC inspectors were informed that GE management was reviewing certain other worker concerns related to Material Control and Accountability. This inspection was
. conducted to review licensee findings related to these concerns.
The following documents were reviewed to determine the actions taken by the licensee in addressing allegations.
- a. Document Number 1 - Quality Assurance Review of Employee Allegations of Violations to Company Practices and Procedures by the Consulting Engineer for the Quality Assurance and Reliability Operation which was transmitted to the Quality Assurance Manager by memorandum dated April 26, 1984.
The purpose and scope of this document was stated to be to perform a review in response to a letter from the Quality Assurance Manager dated February 24, 1984 and document titled " Allegations of Violations to
3 9 Company Practices and Procedures in Chemet Laboratory" dated February 21, 1984 by an employee. It should be noted that it is stated later in the document that only allegations concerning quality were addressed by the team. The summary of conclusions section of the document indicated that four alleged violations relative to quality "were found, for the most part, to have substance". (1) The review team was composed of the following three individuals: T. C. Davis, Employee and Community Relations C. R. Ogle, Quality Audits and Customer Service F. J. Wieczorek, Consulting Engineer, Quality Assurance and Reliability Operation (Team Leader) (2) The review team interviewed the following individuals: T. P. Winslow, Manager, Chemet Laboratory R. I. Parnell, Control Programs Engineer P. E. Hann, Supervisor, Chemet Laboratory W. Lacewell, Supervisor, Chemet Laboratory C. G. McLamb, Supervisor, Chemet Laboratory C. E. Rochelle, Test Operator, Chemet Laboratory R. W. Hudson, Test Operator, Chemet Laboratory R. L. Brown, Test Operator, Chemet Laboratory V. P. English, Test Operator, Chemet Laboratory S. W. Sloan, Test Operator, Chemet Laboratory J. R. Sutton, Test Operator, Chemet Laboratory (3) Pre-review and post-review meetings with the team were attended by the following General Electric individuals: H. O. Covington, Manager, Hourly Employee Relations C. W. Doyle, Manager, Quality Audits and Customer Service (Acting l for the Quality Assurance Manager) J. H. Faucette, Manager, Employee and Community Relations W. J. Hendry, Manager, Regulatory Compliance L. A. Sheely, Manager, Fuel Quality C. M. Vaughan, Manager, Licensing and Nuclear Materials Management P. T. Winslow, Manager, Chemet Laboratory (a) Allegation 1.A: Analyzers are not properly calibrated following detector change. The review team concluded that this allegation appeared true if one accepts the alleger's interpretation of the applicable procedure. Also the team pointed out that several inter-pretations of the procedure were obtained by the team from the various individuals interviewed. The team pointed out that differentiation between the terms " calibration" and l __ -. _ . _ ._
r 4
" minimum-U-count" was not clear in COI 411 Rev. 2 and 3. The review team indicated that varied interpretations of the procedure could result in:
inconsistencies in application possible violations of procedure possible questionable validity of results possible preceptive management countenance of operator deviation from procedure loss of time repeating work needlessly (b) Allegations I.A.1.d & I.A.2.c Calibration and verifi-cation were not completed before samples were run and material released during August 20, 1982 and June 22, 1983. The review team concluded that this a .on appeared to be correct. The report indicated that calibration or verification standards were not measure as required by COI 411 Revision 2 & 3. i (c) Allegation I.B.1-4: Results from isotopics are accessible in computer and can be altered. The review team found that all but one supervisor and one operator confirmed the statement. (d) Allegation (No number): Use of 902/903 computer transactions are condoned by supervisor. The review team found that authorization was given on at least one occasion and operators continued to use 902/903 transactions because they thought that they had authori-zation. Access continued after February 22, 1983 and January 25, 1984 when re-emphasis to the contrary was issued by management. (e) Alle i n I.C. Supervisors input data under technician's nd create false data. doc nt indicated that supervisors acknowledged using but only w cons and in the presence of
- s. When th were used, it was only to correct data. The re eam concluded: "There was no falsification of data."
- b. Document Number 2 - Memorandum dated March 15 ulatory 1ance Man er concernt view of the and the n the Chemet aborato y.
5 This memorandum documented an audi of the Cherr.et I.aboratory for sources of and the safety aspects of such sources. resu ts o the au ts were as follows:
- Operation of the without the vent screen in place is dangerous.
Screens were in place when the audit was performed on March 15, 1984. > Periodic cleaning of the screen is necessary to remove buildup on the screen and permit adequate ventilation. Leaks of fumes oor of th is not an indication that re also out, indicates only poor venti ion. The induction furnace contains three dikes to prevent the spillage of mercury. Sulfur is available in the laboratory to aid in the cleanup of ' mercury should a spill occur. is hazardous only to the reception of oca radio station us ng a low quality radio receiver. The memorandum indicated "Th 1.5 the only poten-tial source of dangerous and that potential is realized only in an equipment failure". e memorandum also in-dicated that "The detector equipment available for detecting leaks provides safety assurance beyond the level available to the general public". The memorandum indicated: equipment condition is good i - the job hazard analysis requires testing but no interval is specified I - testing is performed weekly no unacceptable levels of leakage have been noted it is recommended that the weekly testing requirement be placed in a procedure
- c. Document Number 3 - Memorandum dated March 20, 1984 to the Regulatory Compliance Manager concerning the industrial safety of the Chemet Laboratory.
This documented a review of the safety program in the Chemet Laboratory which occurred during the period March 8 to 21,1984. The reviewers concluded that "...the safety program in the Chemet Lab is excellent". Major findings during the review were as follows:
6
" Review of injury, incident and other records does not reveal any pattern or significant events that would indicate safety problems" An employee bumped his head in the laboratory and the injury was diagnosed on April 23, 1982 as a simple contusion.
Isotopic and 0/U Preparation Area
+
No visible emission of chemical materials in the immediate work area.
+ Employees in the lab indicated that rarely are chemical odors noticed.
+ Employees' overall perception of lab management's safety concern and safety emphasis is quite high. Comments like
'goes overboard' ard ' safety conscious' were used to describe lab management's attitude toward safety.
+ Employees indicated that they believe an employee has convinced himself that his concerns are legit and no amount of evidence to the contrary will change his mind.
+ "The processes do not subject employees to significant safety or health risks".
- d. Document Number 4 - Memorandum dated March 15, 1984 from the Plant Medical Director concerning a medical examination of an employee following an accident in the Chemet Laboratory on April 23, 1982.
The memorandum documented the medical diagnoses applicable to the injuries suffered by an employee in an accident which occurred in the Chemet Laboratory on April 23, 1982. The following points were addressed in the memorandum:
Neurological examination was normal except for an abnormal left pupillary reaction due to an old injury."
"My diagnosis was contusion, left front parietal area."
A neurosurgeon, concurs with opinior--simple contusion and no central nervous system injury.
- e. Document Number 5 - Memorandum dated Mirch 23, 1984 from the Senior Nuclear Safety Engineer to the Regulatory Compliance Manager concerning radiation safety in the Chemet Laboratory.
This documents a detailed radiological safety review of the Chemet Laboratory performed by the Senior Nuclear Safety Engineer during the week ending March 23, 1984. The following points were contained in the memorandum:
7 9 Detailed radiological safety review was performed in Chemet Lab this week. ,
Conclusion:
Radiation safety programs as applied to the Chemet t.ab are quite adequate to ensure work safety and compliance. No significant changes are necessary at this time. Several minor recommenda'tions for improvement may warrant con-sideration. Contamination Survey Program
+
Survey is generally on Tuesday or Thursday mornings at no set time.
+
Not preannounced and "preeleaning" or other preparation were not performed.
+
Review of smears from Jan March 13,1984 indicated about 2% o ere reater than the action limi
+ Conclusion - Appears adequate
+
Recommendation - Consider adding the area as a location for a random smear. Air Samp1tng and Bioassay
+
Two stationary air samplers are changed on an our basis.
+
Air samples for 1983 averaged less than 10-11 rocuries per
+
cubic centimeter which is less than 10% of MPC. ody counting is provided annually.
+
urinalysis samples are collected from 1 ran- { om y selected people. {
- + l Review showed no positive intakes for persons working in the lab. -
+ Conclusion - Airborne negligible. i
+
Recommendation - Consider adding an air sampler by the powder 1 hood on east side of West Lab. ' Worker Training, Posting, and Safety Instructions
+
Chemet Lab workers receive the same formal Nuclear Safety training as other controlled area workers from Nuclear Safety Engineering.
+
Chemet Lab supervisors hold monthly safety meetings.
+
Conclusion - Worker training and posting for the Chemet Lab operations is appropriate.
8
'O
+ Conclusion -
Instructions pertaining to nuclear safety are adequate, in general, but improve ent in three areas may be warranted. Revise or review if SOP 0.3.4 is current and/or applicable.
- Provide more detailed information on how to clean powder spills.
- provide more information on where and how dissolved samples are dried.
+ Recommendation - combine applicable portions of 50P 0.3.4 with NSR/R 6.1.0.
+ Recommendation - provide written instructions on cleaning spills and drying dissolved samples in the appropriate procedures.
- Personnel Surveys and Change Room Audits.
+ Conclusion - Adequate training '
+ Conclusion - Overchecks have not indicated that individuals are leaving the lab with measurable contamination.
+ Recommendation - None
- f. Document Number 6 - Memorandum dated May 21, 1984 f rom the Quality Assurance Manager to an employee concerning his allegations.
This memorandum relayed to the employee the results of the " quality review" discussed in paragraph 4.a. above and the results of the
" safety review" directed by the Quality Assurance Manager. Major points in this memorandum are as follows:
- the " quality review" determined that some of your allegations had some substance.
- the safety concerns had no substance.
- the major problem appears to be one of communication.
- a program to improve communication through training or improved procedure or both appears appropriate,
- g. Document Number 7 - Memorandum dated May 17, 1984 from the Quality Assurance Manager to the Chemet Laboratory Manager concerning addi-tional information/ allegations.
This document transmitted two pages of handwritten comments submitted ! by the employee and copies of two " quick letters" from the employee to ! the Control Programs Engineer. The two pages of handwrittem comments
b concerned the enrichment analyzer during two periods--October 13-16, 1982, and June 22-24, 1983. The " quick letters" involved questions concerning volume and number on test tubes. The information was transmitted to the Chemet Laboratory Manager for evaluation.
- h. Document Number 8 - Memorandum dated May 23, 1984 from the Chemet Laboratory Manager to the Quality Assurance Manager responding to document 7 above. ,
1 This document transmitted the results of the evaluation of the in- I formation supplied in Document Number 7. The results of the evaluation were as follows: l the enrichment analyzer concern during the period October 13-16, 1982 had no basis. the enrichment analyzer concern during the period June 22-24, 1983 was not addressed in that it had been the subject of a previous memorandum from the Chemet Laboratory Manager dated April 10, 1984. The inspector did not review the April 10, 1984 memorandum.
- the volume problem had been addressed and corrected by the Control Programs Engineer when it had been brought to his attention by an employee.
the test tube numbering problem had also been addressed and corrected by the Control programs Engineer when it had been brought to his attention by an employee.
- 1. Document Number 9 - Memorandum to File dated June 15, 1984 from the Fuel Quality Manager concerning methods to improve communication between management and operators in the Chemet Laboratory.
l This memorandum to File documented some ideas concerning improvement of communications in the Chemet Laboratory. The concept of improved communications was surfaced in Document Number 6 above. This was not a final document and the writer was informed by the Licensing and Nuclear Material Management Manager that the Quality Assurance Manager wanted some modifications and refinements made to the concept before a program was initiated.
- 5. Interview of the Control Programs Engineer The writer interviewed the Control Programs Engineer for the Chemet Lab-oratory to better understand the sequence of events which surround the changing of a detector in an enrichment analyzer. The following is a summary of the inspector's understanding which resulted from that interview.
After a de as been replaced, a perio quired. When t s been complete , a technicia runs th This
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- 6. Follow-up Action
! App.oximately two wecks later, the inspector contacted the Consulting i Engineer from the Quality Assurance and Reliability Operation to determine whether his review team reached its conclusion based on the raw data (as the
- 11 NRC inspection team did) or o:1 the basis of the log books that are used in the laboratory on an intermittent basis. The inspector was inferrred that the team had reviewed the tapes not the log books. The Consulting Engineer also stated that his opinion was that any interpretation of a procedure is fair when the procedure is written in such a manner as to permit several interpretations. He indicated that he personally agreed with the inter-pretation used by the concerned employee.
The NRC conclusions stated in Inspection Report 70-1113/84-05 dated May 9, 1984, were based on the intended meaning of the procedure obtained through a discussion with the author of the procedure.
#pCte 3, scunaarc uNITLD sf ATLs av couuissim g g M \ 101 M A'llETT A sicEE7.NR ,
*
- ATLANTA.ceomo A 303c3 l
%...../ FEB 211985 J General Electric Company !
ATTN: Mr. Eugene A. Lees, General Manager 1 Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:
SUBJECT:
REPORT NO. 70-1113/85-01 On January 14-17, 1985, NRC inspected activities authorized by NRC License No. SNM-1097 for your Wilmington f acility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report. Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with perso~nnel, and observation of activities in progress. The inspection findings indicate that certain activities violated NRC require-ments. The violations, references to pertinent requirements, and elements to be included in your response are presented in the enclosed Notice of Violation. In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activities and security measures are exempt from public disclosure; therefore, the enclosures to this letter, with the exception of the report cover page which presents a norexempt summary, will noj be placed in NRC's Public Document Room. The responses directed by this letter and the enclosures are not subject to the clearance procedures of the Of fice of Management and Budget issued under the Paperwork Reduction Act of 1980, PL 96-511. Should you have any questions concerning this letter, please contact us. Sincer y, J. Philip Stohr, Director Division of Radiation Safety and Safeguards
Enclosures:
(See page 2) \
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A General Elece.ric Company 2 RB '2 i G85
Enclosures:
- 1. Notice of Violation (Exempt from Disclosure)
- 2. Inspection Report No. 70-1113/85-01 (Exempt from Disclosure) cc w/ enc 1:
- . M. Vaughan, Manager Regulatory Compliance f
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