ML20238E427

Insp Rept 70-1113/87-11 on 870810-14.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Transportation of Radioactive Matls,Solid Radwaste Mgt,Alara Program & Allegations Followup

ML20238E427
Person / Time
Site:	07001113
Issue date:	09/03/1987
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20238E425	List: ML20238E424 ML20238E427
References
70-1113-87-11, NUDOCS 8709140337
Download: ML20238E427 (13)

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e UNITED STATES

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• NUCLEAR REGULATORY COMMISSION y's . /n REGION ll )

,5 ,. , j 101 MARIETTA STREET, N.W. i

• ' t. ATLANTA, GEORGIA 30323

%;. SEP 0 31987 )

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i s Report No.: 70-1113/87-11 4 i

Licensee: General Electric Comp 5ny '

}; Wilmington, NC 28401 "f Docket No.: 70-1113 License No.: SNM-1097 Facility Nane: Nuclear Fuel and Con'ponent Manufacturing l

Inspection Conducted: August 10-14, 1987 i Inspector: 87 T. R. Collins Ddte ' Signed g

3 t < ,t O by 3 C.clta (Bl ApprovedbyJ'C.M.Hosey,Se(tionChief Date Signed )

Division' of Radiation Safety and Safeguards l

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SUMMARY

Scope: This routine, unannounced inspection involved inspection in the area of radiation protection program, transportation of radioactive materials, solid radioactive waste management, program to maintain radiation doses As Low As Reasonably Achievable (ALARA) and allegations followup.

Results: No violations or deviations were identified.

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REPORT DETAILS .j

1. Persons Contacted .

'D. W. Brown, Manager, Uranium Recycle Unit R. C. Pace, Manager, Powder Production D. A. Burns', Manager, . IMJ & L T. P. Winslow, Manager, Licensing & Nuclear Material Management R. L. Torres, Manager,. Radiation Protection G. M. Bowman, Senior Program Managei, Nuclear Safety Engineering E. A. Schaefer, Chemet Laboratory.

R. H. Foleck, ' Senior Specialist,. Licensing . Engineering S. P. Murray, Senior Nuclear Safety Engineer P.'S. Stansbury, Senior Nuclear Safety Engineer ,

R.' J. Keenan, Nuclear Safety Engineer B. S. Dunn, Specialist, Licensing Support Other licensee employees contacted included three construction craftsmen, four technicians, two operators, three security force members, and two _

office personnel. I

2. Exit Interview The inspection scope and findings were summarized on August 14, 1987, with those persons indicated in Paragraph 1 above. The licensee acknowledged the inspection findings and took no exception. The licensee did not j identify as proprietary any of the materials providad to or reviewed by  ;

the inspector during this inspection. 1 1

3. Licensee Action on Previous Enforcement Matters This subject was not addressed'in the inspection. .;

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a. Instruments and Equipment j Paragraph 3 of the licensee's application for License No - SNM-1097 f and. Nuclear Safety Instruction (NSI) No. 0-40, Nuclear . Safety 1

' Instrumentation, identifies radiation . protection instrumentation  !

requirements and the calibration frequency. The inspector observed- i that~ the required type and quantity of instruments were available and j found. them operable and ' calibrated as required by reviewing  !

calibration labels and records for the period of January to August  :

1987.

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b. External Exposur6 Control / j

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/' id ')FR 20.101 specifies the Oplicable radiation dose standards. The ,I inspector, reviewed records r7, individual radiation exposures during s the perio6 of January to NgtAt,1937, and verified that the radiation ];

doses recorded for plant personnel were well within the quarterly limits of 10 CFR 20.101(a). ,

j 10 CFR 20,202 requires each licensee to stoply appropriate . personnel  ;

monitsring equipment to syecific individuait end requires the uSe of  !

such' equipment. During tours fo the plant. 3he inspector observed work @s scaring appropriate personnel monitoring devices.- '

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c. Posting of Notices i

10 CFR 19 al rer/ vires W? licen'iee' to post Form NRC-3, the license i and other p'.ftincet infora tion, I.] posting'of a decament was not practicable,4the licensee may post. A rotice which describes the  ;

document and stites..where it may t;s examined.. During tours of the i facility, the impector verified that entrances to and from areas , i where licensed cctivities were conducted were posted with the requirtid documents or a notice describing the document and where it 1

may be ex mined. \

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d. Surveys j

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Part 1, Section 3.2.4.6 of the licensee's application for License l No. SIM-1097 and NSI No. 0-6.0, Contamination Measurement and Control .

Procedure, specifies contamination survey requirements. The inspector reviewed selected records of contamination surveys ,

performed during' the period January to August 1987,

e. Respiratory Protection ,

t 10 CFR 20.103(c) spa.ifies the program requirements for using respiratory protection ewipment. to limit the intake of airborne radioactive materfsis. The licensee hcs implemented the program l through Practices . gnd Procedures (P/P) No. 40-22, Respiratory Protection ProgrM The inspector reviewed the ' respirator issue log for 1987 and verified that the users were on the list of authorized

, users, had been ' trained in the use of respirators, and had current

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medical clearances when the resisirator had been used. The inspector.

also discussed with responsible personnel, factors such as air sample ;

results, work permit requirements, selection, use of protectiori factors, fit Ssting, inspection, and cleaning of respirators. >

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f. Notification and Reports 10 CFR 20 requires certain reports and notifications as follows:

10 CFR 20.402 - Loss or Theft of Material 10 CFR 20.403 - Incidents 10 CFR 20.405 - Overexposure 10 CFR 20.408 - Termination Reports to the NRC 10 CFR 20.409_ - Tennination Reports to the Individual' The inspector discussed the conditions or situations which would have required a report under 10 CFR 20.402, 20.403, or 20.405 with the l

cognizant licensee supervisors. No instances were known to the licensee which would have recuired such reports. Through review of selected records and discuss"ons with licensee representatives, the inspector determined that the above requirements had been met.

g. Internal Exposure Control (1) Air Sampling The licensee is required by 10 CFR 20.103, 20.201(b), and 20.401 to control intakes of radioactive material, assess such intakes and to maintain records of such intakes. During plant tours, the inspector observed the use of ventilation systems and containment structures. The inspector discussed the use of this equipnent with radiation protection personnel.

10 CFR 20.103(a)(1) specifies the' limits for exposure of individuals to concentrations of radioactive materials in air in restricted areas. 10 CFR 20.103(b)(2) further requires that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted areas. The inspector reviewed the results of the fixed air samplers for the various areas of the plant during 1987, and noted that in general, Maximum Permissible Concentrations (MPC), averaged over an eight-hour period, were well below limits specified in 10 CFR 20, '

Appendix B, Column 1.

(2) Bioassay Part 1, Section 3.2.4.3.2 of the application for License l No. SNM-1097, requires establishment of weekly and daily urine sampling frequencies' where soluble uranium compounds are processed.

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Part 1, Section 3.2.4.3.3 of the application for License l

No. SNM-1097, requires establishment of routine in-vivo lung  ;

l counting frequencies for individuals who work in areas where l l nontransportable uranium compounds are processed. i The inspector reviewed Procedures, NSI No. E-9.0, "Whole Body Counter Calibration," and NSI No. 0-2.0, " Bioassay - Vrinalysis l

Program," which implemented the above license requirements. The i formulae specified for calculating intakes were consistent with WASH-1251, " Application of Bioassay for Uranium," June 1974. ,

The inspector .eviewed selected results of urinalyses and in-vivo lung counts of selected personnel performed during 1987, and determined that among those reviewed, no worker had exceeded the licensee's action limits as specified in the license application.

h. Caution, Signs, Labels and Controls 10 CFR 20.203 specifies the posting, labeling and control requirements for radiation areas, high radiation areas, airborne radioactivity areas and radioactive materials. During tours of the facility, the inspector reviewed the licensee's posting and control of radiation areas, airborne radioactivity areas, contaminated areas, and radioactive material areas.

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1. ALARA Program (1) Part 1, Section 2.3.1 of the SNM-1097 Application requires that an annual ALARA review will be performed which considers the following:

Programs and projects undertaken by the radiation safety function and the operational radiation safety committee.

Performance including, but not limited to trends in airborne concentrations of radioactivity, personnel exposure and environmental monitoring results.

l Programs for improving the effectiveness of equipment used l

for effluent and exposure control.

The inspector reviewed the licensee's annual ALARA review dated October 26, 1986. The review indicated that personnel internal exposures within the controlled area were comparable to those calculated from air sample data and that internal exposures-continued to be reduced to as low as reasonally achievable.

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1 (2) Part 1, Section 3.2.4.2.1 of the SNM-1097 Application requires that the radiation safety function will annually evaluate fixed I j filter sampling points for representativenese of the sampling.

The inspector reviewed the licensee's annual evaluation of fixed filter sampling points for representativeness to actual air concentrations in the work area dated July 31, 1987.

j . Radiation Safety Committee Part 1, Section 2.3.2 of the SNM-1097 Application requires that the Radiation Safety Committee meet at least monthly to maintain a continual awareness of the status of containment projects, performance trends and measurements, the current shop operations, and radiation safety conditions.

l The inspector reviewed t'se Radiation Safety Conmittee Meeting Minutes from January to August 1987, and concluded that the licensee's Radiation Safety Conmittee was performing adequate reviews of plant conditions and tracking problems identified until corrective actions had been performed. Continued reduction in airborne radioactivity indicates that the Radiation Safety Committee has been beneficial in i reducing exposures to personnel. The following projects were  ;

identified and completed by the Radiation Safety Connittee.

Projects Closed Accomplishnert REDCAP Hoods for Provide con-UPMP Feed tamination con-trol during re-pack of mater _ial for UPMP Vaporization /Line 1 0 shifts greater than MPC during the sample period at line 1 Vaporization HVAC Air sample results Upgrade less than 10% MPC, individual chamber exhausts, and upper area ventilation only i

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New Air Sampler New gauges do not Flow Gauges In- require. resetting stallation' and annual' flow

. gauge exchange com-pleted Air Sampler Representativeness-Relocation of air sampler.

improved Screener Room Air- 50% reduction in borne / Air Balancer airborne l average /no airborne problems i noted

k. Radiation Protection. Staff The inspector reviewed the licensee's . radiation . protection ' staff- to verify that adequate radiation safety coverage was available for safe

~p lant operation. The licensee's. radiation protection- staff is nude l up of one Radiation Protection Manager, two Radiation Protection y Supervisors, twelve Radiation Safety, Technicians, and five Radiation Safety Operators. -The. inspector concluded that' the . licensee's .

Radiation Protection Staffing was' adequate and had no further I questions.

No violations or deviations were identified.

5. Radioactive Waste Managenent (84850, 88035)

a. Management Controls i

Procedure NSI 0-17.0 specifies the -licensee's. procedures for the J packaging and shipping of radioactive solid wastes 'and. radioactive-scrap which is transferred for compaction and final packaging. This~

procedure specifies the responsibilities of the various ~ groups for operations such as container inspection, packaging, surveying, and checks. Procedure No. 90-10,. " Receiving and Shipping Radioactive Materials," also assigns responsibilities by organizational entity.

The inspector reviewed the documents controlling the handling of radioactive waste and discussed the program with licens'ee-representatives.

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b. Waste Manifests i'

10 CFR 20.211(b) and (c) requires that a manifest system be used for all shipments of waste to a licensed burial facility. The inspector determined that the manifests had been completed and forwarded as required for selected waste shipments reviewed, j

c. Tracking of Shipments Radioactive material shipment procedures and checklists included  ;

provisions for determining the estimated date of arrival of the  ;

shipment, and written and telephone notification of the receiver.

The inspector confirmed that the selected ' waste shipments had been verified as having been received at the disposal site. The licensee's procedures included a seven-day receipt requirement by the receiver and provisions for tracing the shipment if notification of -;

receipt is not received.

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d. Waste Classification and Characterization 10 CFR 20.311(d)(1) requires that all wastes be prepared so that it is classified in accordance with 10 CFR 61.55 and characterized according to 10 CFR 61.56.

1 10 CFR 61.55 requires that waste be classified and identified as  !

Class A, B, or C. 10 CFR 61.56 specified the characterization  !

requirements for all classes of waste, j The licensee stated that all wastes shipped from the facility for the i l past several years had been Class A, unstable waste and that all l waste streams utilized material accountability for identification of l radionuclides in each container to be shipped. The activity in each container was determined by scintillation counting. The inspector reviewed several waste shipments made to a disposal site during 1987, and found the requirements of 10 CFR 20.311 had been met.

No violations or deviations were identified.

6. Transportation Activities (86740)

a. Management Controls Depending on the type of material shipped (fuel assemblies, fuel pellets, scrap, etc.), different procedures apply for shipment.

However, the inspector determined that the procedures include the assignment of responsibilities for accomplishing the various tasks (including inspections or overchecks) to -different organizational entities. Procedures included in the preparation for shipment and receipt of materials and empty containers were reviewed and verified to include the designation of responsibilities.

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b. Quality Assurance Program 10 CFR 71.12 provides a general license' to transport,'or to deliver.

to a carrier for transport, licensed materials in packages for which a license or certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR 71, Part H.

The inspector verified that the licensee had an NRC approved quality assurance program. The licensee's program ' Shipping . Container Quality Assurance as of October 9,1984.expiration Prog (ram" was date submitted October to the NRC and was app 31,1989).

c. Procurement and Selection'or' Packaging The inspector verified that ' Certificates of Compliance are current for containers used 'for the shipment of . fuel pellets and complete assemblies, and the licensee is registered as an authorized user for.

these containers. The'. Certificates of Compliance (C0C),for RA-2 and RA-3 containers were specifically reviewed. The C0C application'was f dated January 5,1987, and expires on January 31,1992. 1 49 CFR 171-178 and 10 CFR 71 contain restrictions or' prohibitions on the shipment of licensed materials. The inspector verified .that the:

licensee does not use Specification 55 containers, does not ' ship plutonium, and does not ship materials in liquid form or special form.

The licensee's' approved'proceduras include the specification of the containers to be used for the shipment of licensed materials.

d. Preparation of Packages Procedure 90-11, Packaging Documentation Control, provides : for the preliminary and routine determinatir.n of the acceptability of the packages. The procedure also specifir.s .the requirements . for. the preparation of the' packages (includin 4 .such -items as torquing of fasteners, installation of accelerometers, etc.) and routine maintenance. Procedure NSI No. 0-1/.0 provides for radiation and contamination surveys, container marking and labeling, and the labeling of waste boxes. For. overseas; shipment of materials, the procedure also includes the . labeling requirements for the outer container. Procedures NSI No. 0-17.0 and ' 90-11 provide i for records of. preparation of packages. Through a review of records and _

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discussions with licensee representatives, the inspector verified that packages were being properly prepared for shipment.

e. Delivery .to Carriers A licensee representative informed the -inspector that licensed:

materials are shipped by exclusive use vehicles or as'" limited

. quantity" shipments by mail . - Procedures.are used to assure that the required shipping paper. documentation 11s provided to the driver, including. the instructions ~ to the driver regarding : a_ccidents, maintenance of the load and emergency telephone numbers. The driver is required to sign. the instruction sheet to document' that he is aware of the requirements.

The inspector reviewed records of selected shipments made during 1987.

No violations or deviations were identified.

7. Follow-uponAllegations(99014)

a. Allegation (2860166009) l The ventilation systems were often turned off or not working properly in the powder screening room for cost purposes. . Employees.were still ordered to produce. even though there. was airborne contamination, many times airborne contamination clogged radiation safety filter monitoring systems, but yet- packing was ordered to continue.

Discussion and Findings The inspector interviewed three radiation protection ',(RP) personnel (two technicians and one manager) and cognizant. responsible personnel.

for operation of the ventilation system in the powder screening room.

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Tnro igh these interviews and reviews of appropriate air sample l results and ventilation system operating records from 1985 to present, it wts determined that the powder screening room ventilation system was operating properly and airborne contamination was well below limits specified in 10 CFR 20, Appendix B,' Column 1. The allegation was not substantiated.

No violations or deviations were identified.

b. Allegation (2870081001)

A leak of uranium solution in the chemical area which'is adjacent to the chemistry ' laboratory prior to April 27, 1987. Samples. were being ~1 taken and sent to the chemistry. laboratory for uranium' analysis and-that the matter is'being kept quiet.

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10 Discussion and Findings The inspector discussed this matter with licensee management' representatives and determined through discussions and interview of licensee personnel that there had been a leak of uranium bearing liquids found in the chemical area penetrating the curbed flooring on April 8,1987. Subsequent investigation discovered a void under the concrete as well as contaminated dirt. . The inspector reviewed a Radiation Protection Unusual Incident Report, dated April 8,1987, ,

which documented this event. The licensee formed a investigative j team made up of shop operations facility engineering, and Nuclear Safety Engineering and Environmental Protection personnel to determine the extent of the void and radioactivity, excavate the contaminated dirt and concrete, repair the flooring, dispose of the excavated material and conduct preventive maintenance for other potential 3 problem areas. The licensee completed these task and released the j area back for normal use. The inspector concluded that this  :

allegation was not substantiated, in that, the event was well documented, and controlled and cleaned up promptly when detected.

No violations or deviations were identified.

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c. Allegation (2870081002) i There is no forty hour per week air sampling to indicate cummulative

! dosage in the chemical laboratory. The air samples taken daily read extremely low. The sensitivity of the equipment cannot account for the quantities not registered, therefore, if these quantities are accumulated, a representative sample would be provided.

l Discussion and Findings The inspector discussed this issue with the Radiation Protection Manager and two Radiation Protection Technicians. Through these interviews it was determined that there is no requirement for a forty hour per week air sample to indicate cumulative dosage in the Chemet laboratory. Air samples in the Chemet laboratory are changed every eight hours and averaged over a forty- hour period to control l personnel intake of radioactive material in air. Air sample results l for the period of January to August 1987, in the Chemet laboratory

, that were reviewed by the inspector revealed that the airborne l uranium concentrations were less than one-tenth of one-percent the concentration specified in 10 CFR 20, Appendix B, Table 1, Column 1.

This allegation was substantiated, in that, there is no forty hour per week air sample taken in the chemical laboratory, however, no regulatory requirements were violated.

No violations or deviations were identified.

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c. Allegation (2870081003)

The return ventilation filter on: the ' north wall of the chemical '

laboratory 'is not sampled or tested for. activity. The filters @e.

periodically. removed, bagged l and thrown in the trash area. Thq '

filters are being burned but.does.not know for.certain. e

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The inspector interviewed three radiation. protection personnet d (two technicians and one manager) and personnel . responsible for' the'-

ventilation system in. the Chemet laboratory. Through theseEj interviews and additional. discussions with two other RP- technicians it was determined that the filter on the north' wall of the chemical laboratory is surveyed for radioactivity. The results of surveys reviewed by the. inspector during the- period of January to August 1987, ' revealed that the radioactivity was below the licensee's controlled area limits for the _ Chemet Lab as stated in their License Application which are 1,000~ dpm/100 cm2 smearable "and 2,200 dpm fixed. Part 1, Section 1.'8.8 of the SNM-1097 Application authorizes the licensee, pursuant to 10 CFR 20.302(a) and 10 CFR 20.305, to treat or dispose of waste and. scrap material containing. special~

nuclear material . by incineration. The inspector. determined through discussions with licensee personnel that the pre 2 filters are burned-in the incinerator as authorized by their license application.- This allegation was not substantiated.

No violations or deviations were identified.

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