ML20236F598
| ML20236F598 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 10/23/1987 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Lees E GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8711020228 | |
| Download: ML20236F598 (4) | |
Text
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I OCT 2 31987
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-General' Electric Company ATTN: Mr. Eugene A. Lees, General Manager Nuclear Fuel and Components j
Manufacturing P. O. Box 780 Wilmington, NC 28402 Gentlemen:
SUBJECT:
NRC INSPECTION REPORT N0. 70-1113/87-10 l
Thank you.for your response of. 0ctober 2,1987, to our Notice of Violation
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issued on August 28, 1987, concerning activities conducted at your Wilmington facility. We have evaluated your response and found that it meets the require-ments of 10 CFR 2.201.
We note however, while you do not explicitly deny the violation, your response tends to question the validity of the regulatory basis upon which it was imposed. As a result, we have enclosed our staff analysis of
.your response to clarify the basis of this enforcement action.
It was noted in your response that corrective action has been taken. Accordingly, we will examine the implementation of your corrective actions during a subsequent inspection.
We appreciate ycur cooperation in this matter.
Sincerely, J. Philip Stohr, Director l
Division of Radiation Safety I
and Safeguards
Enclosure:
Staff Assessment of Licensee Response cc w/ enc 1:
T. Preston Winslow, Manager Licensing and Nuclear Materials Management bec w/ encl:
Document Control Desk (RIDS IE03), 016 Licensing Branch, Division of Safeguards and Transportation, 825-SS bec w/o encl:
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ENCLOSURE.
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' Staff-Assessment of Licensee Response t
-Issue:
iThe licensee was 1ssued a Notice of Violation for; failure to perform particular.
i analytical: measurements in accordance with written: procedures.
The violation L was ' based on.a Dlicensees employee-providing : verbal. instructions to -Chemet-LaboratoryLanalysts to perform certain additional, processing steps'on analytical samples which were not specified in the written procedure.
Licensee's Response:
LThe' licensee.'. agreed L that 1aboratory analysts' were ' verbally. instructed to
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perform' additional treatment-on-certain-samples. The-licensee argued that-the.-
" instructions were given' to. minimize' the variability' of a particular attribute which would provide for. improved measurement precision in the analysis being -
. performed. The. licensee:further argued that the Chemet Laboratory analysts are-
- i highlyf trained,7sk111ed, and qualified and are. frequently called. upon Eto exercise good judgement in applying sound laboratory practices and techniques.
The' licensee stated'that'these practices-and techniques are not,.and'could not reasonably be, ' comprehensively ' detailed. in documented instructions.
The-licensee's final argument is that since established measurement. parameters were not violated, revision of the procedure to reflect the verbal instruction's was:
.not necessary.
The licensee, however,. modified the procedure.
,NRC Positio'n:
The NRC's position on _ measurement proced' ures is. specified in 10.CFR'70.57 and 10 CFR.70.58.
Important provisions are:
1.
A management system' to provide for. the development, revision, implementation, and enforcement of nuclear material' control and accounting procedures.
2.
The review and approval, before use, of written procedures for performing compositional analyses.
3, The establishment of a single individual with responsibility for I
planning, developing, coordinating, and administering the measurement control program which is organizationally independent and objective.
The NRC has Standard Review Criteria which were given to the licensee specifying that the individual referred to above must approve
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measurement procedures.
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Enclosure 2
4.
The establishment of independent' reviews and audits of the measurement 4
control' program to:
a.
determine program adequacy, b.
assess the applicability of current procedures, and c.
verify conformance with all aspects of the program.
5.
The establishment of procedures and performance criteria for training,
. qualifying, and _ periodically requalifying all' personnel who perform measurements.
The licensee's measurement control program failed to meet the above provisions
-in that:
1.
The Chemet Laboratory analysts were not trained and qualified using a procedure which contained the extra verbal instructions.
2.
The written procedure was not revised, reviewed, and approved before use as required for changes to the pre-existing procedure.
3.
The management system did not adequately provide for the enforcement of existing written measurement procedures.
Licensees should continue to make improvements to measurement procedures where possible; however, licensees may not use measurements being performed for material control and accounting purposes as experiments to - attempt such measurement improvements.
The experiments must be performed on samples not intended to produce material control and accounting measurements.
If the efficacy of the system of accounting measurements is maintained or improved as a result of these experiments and the licensee wishes to implement the changes, the procedure must be modified and approved, and measurement personnel must be retrained before the change is implemented.
For the above reasons the violation is considered valid.
i I
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