ML20237B424

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Insp Rept 70-1113/98-02 on 980713-17.No Violations Noted. Major Areas Inspected:Evaluation of Licensee Conduct of Plant Operations,Mgt Controls & Environ Protection Program
ML20237B424
Person / Time
Site: 07001113
Issue date: 08/07/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20237B422 List:
References
70-1113-98-02, 70-1113-98-2, NUDOCS 9808180249
Download: ML20237B424 (16)


Text

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1 U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:'

70-1113 License No.:

SNM-1097 Report No.:

70-1113/98-02 ;

t Licensee:

General Electric Company Wilmington. NC 28402 Facility Name:

Nuclear Energy Production Dates:

July 13-17, 1998

- Inspectors:

D. Ayres. Senior Fuel Facility Inspector D. Seymour. Senior Fuel Facility Inspector R. Swatzell Fuel Facility Inspector i

Approved by:

E. J. McAlpine Chief Fuel Facilities Branch l

Division of Nuclear Materials Safety I

t Enclosure 9808180249 980807 PDR ADOCK 07001113 C

PDR a

EXECUTIVE

SUMMARY

General Electric Nuclear Energy NRC Inspection Report 70-1113/98-02 The primary focus of this routine unannounced iilspection was the evaluation of the licensee's conduct of plant operations, management controls, and environmental protection programs. The report covered a one week period and included the results of inspection efforts of three regional fuel facility inspectors.

Plant Ooerations The licensee's responses td the unusual incidents occurring since the e

last inspection appeared adequately focused on preventing recurrence.

The incident involving loss of double contingency for moderation control e

in a moderation restricted area (MRA) was deemed a safety-significant, licensee-identified, non-cited violation (NCV):-(NCV 98-02-01).

Manacement Controls and Organization Recent organizational changes were within the structural requirements of e

the license.

The qualifications of the two newly appointed managers adequately met license requirements.

The system for reviewing General Fractices and Procedures (P/P) and e

Nuclear Safety Instructions (NSIs) was being adequately implemented. and safety committees adequately met license requirements.

The licensee's system for conducting Nuclear Safety audits of the e

radiation safety and criticality safety programs was thorough, well-managed, and can be considered a program strength.

Environmental Protection The analytical results from the various environmental samples collected e

indicated that there was no radioactive material from plant operations accumulating or concentrating at the sample locations.

The development and implementation of the Environmental Compliance Data e

Management System (ECDMS) is considered an Environmental Program strength.

l e

Internal Environmental Protection audits were scheduled and conducted as required by the License A) plication (LA).

Due to the lack of supporting documentation, however, t7e inspectors could not conclude whether the four of the six audits were effective.

Enclosure L_._.________

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REPORT DETAILS 1.

Summarv of Plant Status This report covered the efforts of three regional inspectors for a one week period. The Ammonium Diurante (ADU) and Dry Conversion Process (DCP) powder production facilities were being cleaned for the annual Special Nuclear Material (5NM) inventory listing scheduled for July 31, 1998. Pellet production, rod loading, bundle assembly, and uranium recovery continued operations prior to the inventory shutdown in those areas. The west nitrate waste lagoon was being cleaned out in preparation br it to be relined. There were no unusual plant operational c;currences during the onsite inspection.

2.

Plant Goerations (03) (IP 88020) a.

Review of Previous Events (03.07)

(1)

Insoection Scooe Internal investigations for a number of unusual incidents I

were reviewed for adequacy of licensee responses and corrective actions to prevent recurrence.

I (2)

Observations and Findinas l

l The inspector reviewed the licensee's Unusual Incident Report (UIR) concerning steam line pressure relief valves leaking into a moderation restricted area. The inspector discussed the details of the incident and the impact of the i

incident on criticality safety witn licensee management.

The ins]ector noted that the steam leak did not produce any measura)le condensate and that the licensee's safety i

analysis determined the amount of uncontained water that l

could be present without producing a safety concern. The inspector found that the licensee's response to the incident was adequate.

]

The inspector reviewed two VIRs concerning the weighing of moderating material additives into DCP powder blends.

The l

first of these incidents occurred when process control j

software would not operate properly while scanning a container of additive that was to be added to a powder i

blend.

The operator bypassed the scanning function and manually entered information into the process control system as allowed per procedure.

It was later noted that the additive was 30 grams more than called fcr by the blend plan. This overage amount was not enough to be a I

significant criticality safety concern however the incident I

helped identify a weakness in the control software that was corrected in a timely manner.

The licensee's response to the incident was considered adequa N.

2 The second incident involving the weighing of moderating material additives occurred when the required weighing procedure was not followed.

Since moderation is the only controlled parameter for nuclear criticality safety (NCS) in the licensee's moderation restricted areas (MRAs), dual controls on the amount of additives placed in a U0 powder f

2 blend must be used to demonstrate double contingency. Thus, moderating materials that are added to a blend must be weighed on two separate scale systems.

During this incident a supervisory operator found one of the two scale systems to be inoperable and subsequently added moderating material to a p.owder blend after weighing the additive on only one scale system. Upon discovery of the incident, the licensee issued a Bulletin 91-01 report for loss double contingency.

The inspector observed that the licensee's corrective actions were adequate and included retraining and emphasizing the NCS controls associated with MRAs. The inspector found that since the incident was reportable under Bulletin 91-01, it was a safety significant event identified by the licensee. The inspector also found that the event was caused by the failure to adhere to approved procedures, and was thus, a violation of NRC requirements.

This non-repetitive, licensee-identified and corrected violation is being treated as a NCV (NCV 98-02-01). consistent with Section VII.B.1 of the NRC Enforcement Policy.

The inspector reviewed an incident where maintenance work being performed on a boiler that provides steam to Ammonium

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Diuranate (ADU) calciners.

During the work, the boiler was i

filling with water when a criticality (false) alarm sounded.

4 Tne maintenance worker evacuated per emergency plan requirements without shutting off valves associated with the boiler.

Excessive moisture flowed to the line No. 5 calciner and into a can of Uranium Dioxide (UO ) powder.

2 The corrective actions of reviewing their evacuation procedures and lockout /tagout requirements were still under investigation by the licensee.

The inspector also reviewed incident reports for other problem areas.

The inspector observed that the blinding of stationary air sampler filters in the Uranium Recovery Unit (URU) was corrected by fixing chemical leaks in the area.

The inspector observed that the inadvertent burning of plastic sheeting in a Calcium Fluoride (CaF storage area occurred shortly after a problem was identik)ied by NRC in l

i l

the licensee's cutting and welding procedure, and was being l

properly focused upon by the licensee.

The inspector observed that holes in the west nitrate lagoon liner were being corrected by the installation of a new liner.

The inspector observed that a fire in a small vacuum cleaner used for cleaning zirconium fines resulted in the redesign of vacuuming equipment. The inspector observed that the l

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spraying of an operator with uranyl nitrate (UN) solution due to a failed component in URU was corrected by redesigning the system such that any subsequent failures

.would direct UN solution away from normal operator access areas. The inspector found tilat the licensee's responses to all of these incidents appeared adecuate, but also noted that corrective actions involving administrative controls (retraining, revising procedures, etc.) may be more susceptible to recurrences of incidents.

(3)

Conclusions The licensee's " responses to the unusual incidents occurring since the last inspection appeared to be adequately focused on preventing recurrence. Many corrective actions involve improvements in administrative centrols that warrant continued tracking to identify potential recurring problems.

One incident reviewed was deemed a safety-significant, licensee-identified. NCV (98-02-01),

b.

Followuo on Previously Identified Issues (92701 and 92702) i (1)

. Inspection Scoce Corrective actions to issues identified in previous inspection reports were reviewed for completion and adequacy.

l (2)

Observations and Findinas The inspector reviewed the final corrective actions associated with Inspector Followup Item (IFI) 97-08-02 involving unauthorized change to a pellet boat design. The inspector had identified in a previous inspection report (70-1113/98-01) that corrective actions to prevent l

recurrence was to include a review of other types of l

portable containers (in addition to 3ellet boats) used for j

uranium processing. The inspector o) served that this review had been completed, and that the containers reviewed met the i

l dimensions in the applicable criticality analyses.

l-Therefore. IFI 97-08-02 is closed.

The inspector reviewed the corrective actions associated with violation (VIO) 98-01-01 involving the 1maroper storage of unscanned drums of contaminated solvent.

T1e inspector observed the content of the retraining effort for the personnel that handle and store unscanned drums. The inspector found that the retraining was adequate to minimize 4

the likelihood of recurrence.

Therefore. VIO 98-01-01 is closed.

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The inspector discussed the progress on the higher level critique identified by the licensee as being needed for an incident involving the release of a contaminated component

.offsite without a proper survey being conducted.

The completion of this critique was being tracked as IFI 98-01-04. The inspector found that the critique had not been completed due to a change in the personnel responsible for-conducting the critique. The inspector observed that the completion of the critique was still active and being tracked in the licensee's regulatory commitment tracking system. This item will remain open.

The inspector noted that an in-office review of open items l

3erformed prior to this inspection showed that VIO 96-10 01 lad not yet been closed in the NRC record system. A further review of inspection documents revealed that no response was required from the licensee for this violation because adequate corrective actions were verified during the inspection. This item is closed.

(3)

Conclusion Licensee actions associated with IFI 97-06-02 and VIO 98-01-01 have been adecuately completed and are closed.

VIO 96-10-01 was considerec closed with no licensee response l

required. Actions associated with IFI 98-01-04 have not L

been completed and will remain an open item.

l 3.

Manacement Organization and Controls (05) (IP 88005) a.

Organizational Structure (05.01)

(1)

Insoection Scooe l

Changes in personnel responsibilities and functions l

occurring in the past year were reviewed to verify license requirements for structure and personnel qualifications were being met.

(2)

Observations and Findinas The inspector reviewed recent changes in the licensee's organizational structure and new assignments of personnel to key positions with responsibilities important to safety.

The inspector noted that the current organizational l

structure was not precisely as diagramed in the License Application (LA). A separate Nuclear Fuel General Manager l'

position had been created that had previously been combined with the position of Vice President for GE Nuclear Energy.

The inspector also noted that the Site Security and Emergency Preparedness Function actually reported to the Facility Licensing Manager instead of directly to the

5 Environment Health and Safety Manager ds depicted in the LA.

The inspector noted that the key positions important to safety listed in the LA were in place within the licensee's

organization and essentially get the structural form depicted in the LA. The licensee indicated that the 7

positions not shown on the organizational chart in the LA i

would be modified for accuracy as part of a future license amendment.

l The inspector interviewed two managers that had recently assumed positions required in the LA. These positions included the Ar.ea Manager for radwaste handling and j

treatment o)erations and the plant Industrial Safety i

i

Manager, T1e inspector found that both new managers met the i

educational and experience requirements of their positions, i

The inspector also found that both managers were knowledgeable of their roles with respect to the plant's safety programs. The inspector noted that although industrial safety is not specifically mentioned in the LA, the Industrial Safety Manager would manage the Chemical and l

Fire Safety Function as described in the LA.

i (3)

Conclusions l

l Recent organizational changes were within the structural requirements of the LA. even though two current management L

positions were not included in the organizational chart in the LA. The qualifications of the two newly appointed managers adequately met license requirements.

b.

Procedure Controls (05.02)

(1)

.Insoection Scoo; l

The licensee's systems for reviewing General Plant Practices and Nuclear Safety Instructions (NSIs) were examined for consistency with license requirements.

(2)

Observations and Findinas l

The inspector reviewed the licensee *s system of Practices and Procedures (P/Ps) that implement the General Plant l

Practices.

The inspector observed that according to the LA, each safety significant P/P was required to be reviewed within two years of the previous issue date. The inspector observed the timeliness of reviewing and issuing revisions i

to safety significant P/Ps and found no significant discrepancies.

i The insoector reviewed an indexed list of all P/Ps and noted l

those p'rocedures that were not identified as safety significant, and thus were on a four-year review cycle. The i

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inspector noted that one such obsolete ecuipment and tools. procedure involved disposal of The inspectcr observed that this procecure included a decision tree to determine whether l

' or not the equipment / tools needed to be decontaminated and to which type of disposal site it was to be sent. The f

inspector indicated to the licensee that these types of decisions could be considered safety significant and thus the procedure would be required to be on a two year review cycle. The inspector reviewed revision history of the procedure and found that although it had been on a four year l

review cycle for the past twelve years, the decision tree had not changed significantly in that time. Thus, the safety significant portion of the procedure was not affected l

by the fact that the procedure had been on a four year review cycle. However, the licensee agreed to review the safety significance of the procedure to determine if it should be on a two year review cycle in order to be consistent with the licensee *s procedure for reviewing P/Ps.

l The ins)ector examined the review and revision status of l

NSIs. w11ch are procedures that govern-the Radiation and Criticality Safety functional areas. The inspator observed that all NSIs were reviewed and reissued within the two year time frame required by the LA.

i (3)

Conclusions The licensee's system for reviewing General P/Ps and NSIs was being adequately implemented, c.

Internal Reviews and Audits (05.03) l (1)

Insoection Scoce The licensee's system for auditing operational safety programs was reviewed to assess adequacy and verify l

consistency with license requirements.

l j.

(2)

Observations and Findinos The inspector reviewed licensee procedure P/P 40-06.

" Regulatory Compliance Audits" and observed that, with one exception, the requirements therein were consistent with.

the requirements in the LA. The inspector found one discrepancy in that the 3rocedure required record retention for at least two years w111e the LA required three years.

The inspector observed that actual practice met the license requirements. and the procedural requirement was immediately corrected upon notification of licensee management.

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The int)ector reviewed the Nuclear Safety Quarterly Audits conducted in the past year. The ins)ector observed that all required Nuclear Safety audits were 3eing performed each quarter.

The inspector also gbserved that most Nuclear Safety audits were performed ]y Area Managers and resulted f

in numerous findings.

The ins)ector found that this indicated the apparent thoroughness and depth of the audits.

The inspector also observed that persons conducting these audits rotated areas of audit responsibility each quarter to provide a' variety of experience in reviewing each area.

The inspector found that this helped minimize the chances of overlooking potential safety significant items over the course of a-year.

(3)

Conclusions The licensee's system for conducting Nuclear Safety audits of the radiation safety and criticality safety programs was thorough, well-managed, and is considered a program

strength, d.

Safety Committees (1)

Insoection Scooe The functions of the licensee's safety comittees were reviewed to verify consistency with license requirements.

(2)

Observations and Findinas -

The inspector reviewed the meeting reports from the Wilmington Safety Review Committee (WSRC). The inspector observed that the WSRC meeting frequer.cy, scope of activities, reporting of findings and recommendations, and document retention were all within license requirements.

The inspector reviewed procedure P/P 40-31, " Operational Radiation Safety Committee ~ and found it to be consistent with the LA. The inspector also reviewed the monthly Radiation Safety Committee minutes and found them to be consistent with license and procedural requirements for frequency, scope, merabership, reporting, and record retention.

(3)

Conclusions The licensee's safety committees adequately meet requirements in the LA.

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8 3.

Environmental Protection (88045) (R2) a.

Monitorina Proaram Implementation. Results and Reoorts (R2.01.

R2.02. RP.06) f(1)

Insoection Scooe The licensee's Environmental Protection Program was reviewed to verify that program implementation and sample results were consistent with license requirements.

b.

Observations and Findinas The inspectors reviewed results from a wide variety of samples collected and analyzed in 1997 and 1998 as part of the licensee's routine environmental monitoring program.

The inspectors determined the licensee was collecting and analyzing environmental samples as required by their LA and supporting evaluations. The results reviewed by the in.spectors indicated that the specified sampling frequencies and routine minimum detection levels for the analyses were met, with the exceptions noted below.

Two exceptions were identified by the inspectors during this review. The first involved the semiannual analyses for fluorides in vegetation.

The inspectors identified that the Minimum Detection Level (MDL) specified in the LA (1 part per million (ppm)) was not met for four of the six samples analyzed in 1997 and 1998.

Four sample results were reported as <20 ppm. <25 ppm. <30 ppm. and <30 ppm; the remaining two sample results were 32 ppm and 22 ppm.

The inspectors observed that all of the reviewed sample results for fluorides in vegetation were well below the action level (AL) of 100 ppm.

The second exception was the apparent failure of the licensee to analyze for uraniua in three of the F-series wells, as specified in the licensee's evaluation for these wells. The inspectors determined, based on discussions with 4

the licensee and on a review of the licensee's procedures f

for sampling these wells, that the evaluation was in error.

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and that the licensee had never intended to analyze for 1

uranium in the three wells.

These two exceptions constituted violations of minor safety and environmental significance and are not subject to enforcement action.

i However, the inspectors will track the licensee's efforts to l

establish consistency with their license requirements as l

IFI 70-1113/98-02-02.

i The inspectors noted that the licensee had implemented a data base management system called the Environmental Compliance Data Management System (ECDMS).

The inspectors 1

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L observed that this program should allow for more efficient control of the environmental monitoring program.

This system automatically tracked required sampling frequencies

, and exceedence of ALs and facilitated sample result input j

and environmental report generation. The licensee was j

p continuing to develop the capabilities of the system.

The development and implementation of ECDMS was considered an l

Environmental Program strength.

l The inspectors observed that the licensee was using a l

groundwater monitoring frequency model to systematically optimize the sa.mpling frequencies of their environmental 4

l monitoring points. The inspectors observed that the model l

used inputs from the analysis of variables such as contaminant concentration levels, contaminant migration characteristics distance to potential receptors, etc. The inspectors found that the sampling frequencies generated as a result of this modeling program were implemented into the licensee's environmental program.

)

The inspectors noted that Als were specified in documented procedures for environmental monitoring parameters as i

appropriate as required by the LA.

This included the l

nitrate bearing liquids, and the process liquid onsite discharge. Action levels were also specified for most environmental sam)les in the licensee's ECDMS, the computer program used by t1e licensee to track and trend their environmental sampling and analyses.

The inspectors noted the licensee completed environmental action level (EAL) reports for sample analyses that exceeded the specified AL.

The inspectors reviewed selected EAL reports that documented elevated samale results that occurred in 1997 and 1998.

Typically, t1e licensee's follow-up actions consisted of l

watching for a developing trend for the sam)le parameter.

The inspectors noted that exceeding or reac11ng an AL did not roquire the licensee to take any action (procedurally or otherwise) other than filling out the EAL report. The inspectors indicated and the licensee acknowledged that other actions may need to be considered.

I The inspectors also noted that the Als in the ECDMS for the final process lagoon discharge point were extremely high when compared to typical sample results. The Als were 30.000 and 100.000 picocuries per liter (pC1/1) for gross alpha and gross beta, respectively. Typical values for these results were in the range of 10 to 100 pC1/1. The licensee acknowledged that the inspectors' comments would be reviewed for consideration of changing these ALs.

The inspectors reviewed the groundwater monitoring results from wells installed down gradient from the northwest calcium fluoride (CaF ) storage area relocation project.

2 l

If This review followed a previous inspection report (70-1113/97-03) which identified elevated uranium concentrations in the down gradient wells. The inspectors reviewed the total uranium (ppm) results from wells CaF06A.

CaF07A. and CaF12A.

The inspectors found that this data showed the total uranium concentration (ppm) in groundwater down gradient from the former CaF storage area had trended downward to levels of <0.02 ppm. 2 Additionally, aggressive sampling (5 X 5 X 5 meter triangular survey: surface to one meter depth composites) of the northwest CaF storage g

area was planned for final closure purposes.

This sampling had been delayed due to the high water table which had been experienced in this area during 1998. The licensee tentatively planned to begin this sampling in October 1998.

The inspectors also noted that the locations of F Series Wells around the Fuel Manufacturing and Fuel Component Areas were not in accordance with Figure 10.5d of the LA.

The figure identified the locations of an earlier set of F Series wells which were abandoned and/or replaced with new wells in mid-1997. The licensee indicated that this figure would be corrected.

c.

Conclusions Analytical results from the various environmental samples collected indicated that radioactive materials at the sample locations were within the required limits.

The development and implementation of the ECDMS was considered an Environmental Program strength.

2.

Manacement Audits. Inspections. and Controls (R2.03) a.

Insoection Scooe The licensee's environmental protection internal audit program and its results were reviewed to evaluate the effectiveness of the Environmental Protection Program.

b.

Observations and Findinas The inspector reviewed the quarterly audit records for internal environmental protection audits for 1997 and 1998, to date. The inspectors determined that an audit schedule l

was developed on an annual basis for 1997 and 1998, and that j

the audits were performed in accordance with documented practices, as required by the LA.

Each of quarterly audits focused on a particular aspect of the Health and Safety program, including:

stack sampling, river water monitoring, surface water discharge, ambient air, soil and vegetation sampling. ventilation maintenance, and chemical storage.

1 11 The inspectors noted that four of the six audits reviewed had no specific comments, findings. recommendations, or corrective actions. The inspectors could not determine the

' depth of review. or the effect;iveness of the audits, because supporting documentation (specific audit plans, etc.) was not generated and/or maintained.

The remaining two audit f

reports contained more information (recommendations and corrective actions), and appeared more thorough.

c.

Conclusions Internal Environmental Protection audits were scheduled and conducted as re' quired by the License A) plication.

Due to the lack of supporting documentation 10 wever the inspectors could not conclude whether the four of the six audits were effective.

4.

Exit Interview On July 17. 1998, the inspection scope and results were summarized with licensee representatives. The ir.spectors discussed in detail the routine program areas inspected, and the findings, including the potential Licensee-Identified Violation for loss of moderation controls.

No dissenting comments were expressed by the licensee.

The licensee identified materials provided during the inspection as proprietary, although proprietary information is not contained in this report.

Subsequent to the inspection. NRC received the following report from the North Carolina Department of Environmental and Natural Resources.

Division of Radiation Protection:

Report on: Environmental Radiation Surveillance around Brunswick Steam Electric Plant. Shearon Harris Nuclear Power Plant. McGuire Nuclear Station, and General Electric Uranium Fuel Fabrication Plant in North Carolina. January 1997 -

December 1997. The report was submitted to the U.S. Nuclear Regulatory Commission for Contract NRC-29-83-627.

The environmental data contained in the above report will be reviewed by the NRC. Any identified issues will be addressed in a subsequent inspection.

The review and follow up on issues in the report are being tracked as IFI 70-1113/98-02-03.

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l ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel

  • D. Barbour, Team Leader. Radiation Protection
  • D. Brown. Team Leader. Environmental Programs
  • B. Crate. Manager. Industrial Safety
  • T. Crawford. Sr. Environmental Engineer
  • S. Dale. Compliance Auditor: Environment. Health & Safety
  • D. Dowker Manager Chemical Product Line
  • T. Flaherty. Manager. Dry Conver.sion Project l

R. Foleck. Senior Licensing Specialist

  • A. Mabry. Program Manager. Radiation Safety Engineering
  • R. Martyn. Acting Manager. Facility Licensing
  • C. Monetta. Manager: Environment. Health & Safety l
  • R. Pace. Manager. Facilities and Logistics
  • L. Paulson. Manager. Nuclear Safety
  • B. Robinson, Nuclear Safety Engineer
  • H. Shaver. Nuclear Safety Engineer
  • S. Smith, Radiation Safety
  • C. Tarrer. Leader. Configuration Management
  • K. Theriault. Manager. Fuel and Chemical Lab Quality
  • R. Troilo. Sr. Engineer l
  • D. Turner. Engineer: Environment. Health & Safety l
  • C. Vaughan. Acting Manager. Facility Licensing Other licensee employees contacted included engineers, technicians, production j

staff, security, and office personnel.

  • Denotes those present at the exit meeting on July 17. 1998.

INSPECTION PROCEDURES USED IP 88005 Management Organization And Controls IP 88020 Plant Operations IP 88045 Environmental Protection t

IP 92701 Followup IP 92702 Followup On Corrective Actions For Violations And Deviations LIST OF ITEMS OPENED CLOSED, AND DISCUSSED Ooened 70-1113/98-02-01 NCV Licensee identified failure to follow procedure resulting in loss of double contingency for moderation control in the DCP moderation restricted area.

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2 70-1113/98-02-02 IFI Establish consistency between procedures and the license for sampling requirements of F-series wells.

p 70-1113/98-02-03*IFI Review environmental data contained in the Report on:

Environmental Radiation Surveillance around Brunswick l

Steam Electric Plant. Shearon Harris Nuclear Power f

Plant. McGuire Nuclear Station, and General Electric Uranium Fuel Fabrication Plant in North Carolina.

January 1997 - December 1997 and address any p

identified issues during a subsequent inspection.

I Closed l

70-1113/96-10-01 VIO Failure to follow procedures in Chemet laboratory.

70-1113/97-08-02 IFI Review of hi change to pegher level critique for unauthorized let boat design.

70-1113/98-01-01 VIO Failure to properly store unscanned drums containing i

radioactive materials per posted safety instructions.

70-1113/98-02-01 NCV Licensee identified failure to follow procedure resulting in loss of double contingency for moderation control in the DCP moderation restricted area.

Discussed 70-1113/98-01-04 IFI Review results of higher level critique for release of f

contaminated equipment.

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I ACRONYMS ADU Ammonium Diuranate AL Action Level s

CaF Calcium Fluoride 2

DCP Dry Conversion Process EAL Environmental Action level ECDMS Environmental Compliance Data Management System GE General Electric IFI Inspector Follow-up Item IP Inspection Procedure LA License Application MDL Minimum Detection Level MRA-Moderation Restricted Area NCS Nuclear Criticality Safety NCV Non-Cited Violation NRC lluclear Regulatory Commissica NSI Nuclear Safety Instruction l

P/P Practices and Procedures pC1/1 Picocuries Per Liter ppm Part Per Million l

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3 SNM Special Nuclear Material UIR Unusual Incident Report UN Uranyl Nitrate UO Uranium Dioxide urb Uranium Recovery Unit V10 Violation f

WSRC Wilmington Safety Review Committee I

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