ML20133L655

Insp Rept 70-1113/84-16 on 841127-30 & 850114-16.Violation Noted:Failure to Investigate & Take Corrective Action When Control Stds Limits Exceeded

ML20133L655
Person / Time
Site:	07001113
Issue date:	02/08/1985
From:	Bates J, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132C968	List: IA-85-208, Insp Rept 70-1113/84-16 on 841127-30 & 850114-16.Violation Noted:Failure to Investigate & Take Corrective Action When Control Stds Limits Exceeded ML20132C963 ML20132C972 ML20133L544 ML20133L556 ML20133L563 ML20133L592 ML20133L633 ML20133L655
References
FOIA-85-208 70-1113-84-16, 70-1113-84-16-0, NUDOCS 8508120689
Download: ML20133L655 (7)

Text

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. t.3 Ca t UNITED ETATES

,, 'o NUCLEAR REGULATORY COMMISSION g , REGloN II

• 101 MARIETTA STRE ET.N.W. '

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s ATLANT A. GEORGI A 30323 '

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Report No. 70-1113/84-16 Docket No. 70-1313 License No. SNM-1097 Safeguards Group No. 3 Licensee: ' General Electric Company, Nuclear Fuels Manuf acturing Department Date of Inspection: November 27-30, 1984 and January 14-16, 1985 Type of Inspection: Unannounced Material Control and Accountability inspector: " b bih e , 2[8[85 J. W. Bate), Safeguards \ Chemist 7 Date Signed Approved by: CD_le /+ , 2/8/85 E. J. P. cal;hne, Chief, katerial Control and. Date Signed Accountability Section, Nuclear Matirials Safety and Safeguards Branch, Division of '

Radiation Safety and Safeguards

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Inspection Summary Areas Inspected: This routine, unannounced inspection involved 50 inspector- 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> by one NRC inspector in the area of measurements.

Results: One violation was identified .- failure to investigate and take ccrrective action in a timely manner when control standards exceeded the ,0.05 control limits.

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8508120689 850702 PDR FOIA POLSONBS-208 PDR

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l REPORT DETAILS 1

Report No. 70-1113/84-16

1. Key Persons Contacted "J. R. Bergman, Manager, Manufacturing

• C. M. Vaughan, Acting Manager Regulatory Compliance

• B. F. Bentley, Manager, Fuel Chemical Operation

• W. W. McMahon, Manager, Quality Assurance

'D. Starr, Manager, Site Support Quality

• T.'P. Winslow, Manager, Chemet Laboratory

• C. Schiltz, Manager, Fuel Fabrication Engineering

• G. R. Mallett, Senior Engineer, L&NMM

• R. C. Hawk, Manager, Operational Planning '

• H. Stern, Manager, Mi&E0

'R. G. Patterson, Acting Manager, Manufacturing' The inspector also interviewed several other licensee employees.

• Denotes those preser,t at the exit interview

2. Exit Interview ,

The inspection scope and findings were summarized on ' November 30, 1984 and January 16, 1985, with those persons indicated in Paragraph 1 above. One

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violation (paragraph 3.b) was discussed concerning the failure to investi-gate and take corrective actions in a timely manner when measurement contro,1 data exceeded control limits. The licensee acknowledged the finding and took no exceptions.

3. Review of Employee Concerns Regarding Measurements (MC-85207)

a. It was asserted by a General Electric Wilmington Nudear Fuels 5anu-facturing Department employee that (1) an out-of-service tag was improperly removed from an analyzer on August 23, 1982 in violation of a General Electric procedure, (2) that production samples were released' during the stabilizing period for a new detector, and (3) that labora tory employees were discouraged from talking to the NRC inspectors. The NRC review of these employee concerns was as follows:

(1) Allegation An out-of-service tag was improperly removed from an analyzer on August 23, 1982, in violation of a General Electric procedure.

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Discussion l

The manager of the Chemical Laboratory was interviewed and procedures relating to equipment tagging were examined. A procedure entitled Administrative, Lock, Tag and Try, No. 302 dated October 1, 1980, was examined. The procedure specifies that a yellow "out-of service" tag is used when there is reason not to operate the equipment and there is no danger to personnel.

The procedure' also requires that whenever the yellow "out-of service" tag is to be placed on equipment, the reason is to be noted and the tag shall be signed and dated. Only the person signing the tag or supervisor of his area is permitted to remove the tag.

The, laboratory manager was questioned about the circumstances surrounding the removal of an out-of-service tag on or about .

August 23, 1982. He said that he recalled the incident. He had been called at home and, not knowing the status of the analyzer at the time, .he had instructed a technician to tag the analyzer out-of-service to prevent its use for analyzing production samples. The laboratory manager indicated that the out-of-service tag was presumably removed by the laboratory supervisor (which is allowed by procedure) and operations- resumed .af ter it had been determined that the analyzer was functioning properly. .The tag in question could not be visually examined by the inspector because yellow out-of-service tags are not retained once they have been removed from a piece of equipment. The bottom.of a tag states that any employee operating . apparatus to which the tag is attached, unless ' authorized to do so, will be subject to dis-missal.

The inspector requested that the laboratory management review

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applicable . shift logs for any reference to equipment being tagged as out of service. The licensee performed the review and could.

find no written reference regarding this incident. -

Through inquiries of the three laboratory supervisors and the process control specialist it was determined that two of the laboratory supervisors and the process control specialist had no knowledge concerning the removal of an out of-service tag on August 23, 1982. The "2" shif t supervisor said that he recalled discussing the matter with a concerned empicyee. The supervisor stated that he may have personally removed the tag, but that he could not be certain. He further stated that a technician on the preceding shift had informed him that the minimum U cca had been determined for the analyzer in question. The technician was interviewed and the matter discussed; however, the technician could not recall the incident. To gain further information regarding equipment changes the inspectors interviewed a measurement systems specialist in the Calibration and Instrumentation Suppert Unit. This was formerly the Technical Equipment Support Unit and has the responsibility for detector chance outs. He could not recall the incident. _ _ __ _ _ __

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It was disclosed during this interview that records documentation was insufficient to provide information concerning detector change-outs. It should be noted that logs of this type are not required to be maintained by the licensee and are used primarily for trend analysis related to equipment failures. The technician who ini.tially placed the out-of-service tag on the instrument on August 22, 1982, was interviewed by the inspector. The technician indicated he recalled the incident and had tagged the equipment out-of-service as a precautionary measure. The decision to apply the tag was made in concert with the technician's supervisors.

The technician could recall no irregularities with the incident.

Findings ,

On the basis of discussions with licensee employees and the lack of physical evidence, the inspector could not determine whether ~

or not the tag had been removed improperly.

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This allegation could not be substantiated. No violations or deviations were identified.

(2) Allegation _ _

Production samples were released at 0243 and 0524 hours0.00606 days <br />0.146 hours <br />8.664021e-4 weeks <br />1.99382e-4 months <br /> on August 21, 1982 du' ring the , stabilizing period for .a new detector on enrichment analyzer No. 4.

Discussion The GE written procedure for this measurement method specifies that at the beginning of a detector calibration, following a '24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> burn-off, a calibration be performed using six sample standards that cover the range of operations followed by a verification of three standards that also cover. the range -of operations. Following a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> burn-off time that began at 1000 on August 19, 1982, a calibration was performed at 1121 on August 20, 1922. Between the hours of 1121 and 232E on August 20, 1982, a total of eight calibrations or calibration / verifications were performee. Acain on August 21, 1982 between 0004 and 0242 hours0.0028 days <br />0.0672 hours <br />4.001323e-4 weeks <br />9.2081e-5 months <br /> two additional calibration / verifications were performed prior te the documented analysis of twelve anknown production samples. The high standard (3.S78 weight percent U-235) was counted at least six times and completed at 0750 on August 21, 1982 as specified by procedure C01-411, Rev. 2, dated February 10., 1952. The printed Laboratory Measurement Control Systes.(LMCS) recording tape,was examined to verify dates, times and events as described. The procedure was modified on February 9,1983, to clarify that it was acceptable to measure production samples during the period of collecting the six high standard counts data used to determine the minimum U-count limit.

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Findings Production samples were not released prior to equipment.stabili-2atier They were not measured until after stabilization of the equipment had been completed.

This allegation could not be substantiated. No violations or deviations were identified.

(3) Allegation Laboratory employees were discouraged from talking to the NRC inspectors.

Discussion Twelve laboratory technicians were interviewed and were speci-fically asked if they had been discouraged from talking to the NRC inspectors.,,, Two of the twelve technicians interviewed indicated that they were told to refer any questions asked of them to their supervisors but they were not discouraged from talking to NRC inspectors. The remaining technicians all indicated that the matter of communications was near d.iscussed between themselves and management. '

Findings This allegation could not be substantiated. No v'iolations or deviations were identified. .

b. The procram for monitoring and controlling the performance of standard measurements for some of the analytical methods used for accountability purposes was examined. The analytical methods for uranium and U-235 have control limits ' determined by statistical techniques and based upon ,

the historical performance of the method. Each measurement system-has control limits at the 0.05 and 0.001 level of significance that are reevaluated at least once each material balance period. The measure-ment methods, the frecuency of out-of-control situations, the periods examined, and the number of standard measurements performed during the period are presented '.n Table 1.

Each time control limits are exceedad, an investigation is performed and the probable cause of the occurrence and the corrective actions taken are documented. During the review of control chart data the inspector determined that neither the measurement control coordinator nor his officially designated alternate were being notified when control data fell between the .05 and .001 control limits.

A letter to the licensee from the Office of Nuclear Material Safety and Safeguards dated May 14, 1984, presented the NRC position on timely investigation and corrective action for control data falling between the .05 and .001 control limits. The May 14, 1984 letter instructed the licensees to implement a program for reporting a single or two

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consecutive data points that fall between the .05 and .001 control limits to the measurement control coordinator or his officially designated alternate within 48 and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, respectively. This criteria was effective on the date of the letter. Sixteen data points fell between the .05 and .001 control limits during the period reviewed for these measurement systems identified in Table I. These occurrences were as follows: Three consecutive data points exceeded the .05 control limit for the total metallic impurity (TMI) standard during the period October 8-12, 1984; two :ensecutive data points exceeded the .05 control limit again for the TM1 standard during the period November I and 2, 1984; two consecutive data points exceeded the .05 control limit for a uranium titrimetric standard on November 8, 1984; and the remaining data points were single occurrences that exceeded the .05 control limits. None of those occurrences were reported to the measurement control coordinator or his officially designated alternate; thus the licensee was not investigating and taking corrective action

- in a timely manner. This is a violation. (84-16-01)

4. . Independent Inspection Findings (M; 92723)

The NRC inspector observed the sampling of the V-308 fluoride waste' system on November 29, 1984. Two samples were withdrawn from the daily composite sample, one routine and one replicate. The roc.ine sample (No. 625E16) was forwarded to the laboratory for analysis of uranium and other attributes.

The replicate . sample is retaineo, composited and analyzed ty an off-site laboratory for uranium-235 enrichment. It was determined that the approved sampling procedure was followed, that the sample containers ~ were properly labeled and that sampling information was proviced to permit followup.

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MAR 9 tr 93 General Electric Company ATTh: Mr. J. A. Long. General Manager Wilmington Manufacturing Department  :

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4. le ngton. NC 28402  ;

Gentlemen:

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e SUBXCT: REPORT NO. 70-1113/83 %

r b N /. , e  ;: . % [N This refers to the. routine! $assp1N coriducted.by Mr. J. W. Sabados of this - '2l%

office, on February S-13b :1M3n of c.' activities authorized by NRC License ' N i No.-38#t-1097 for the Wilmington facility and to 'the discussion of our findings C

- held wf th 8tr. tJil.!Jaughen,lManeger.: Licensing and Nuclear Material Management, '?

, at.the conclusion 4the,tespectlen.

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" Areak esamined duit "4 f.

this;ie q ( V testfachseed your, program for nuclear materN1 Og n

i.-contvei tand Ifty'under Mpp1fcable provtstons of Title 10,- Code ofy W

- 7 Fedeaal' Reguletteenjfact ML 141 Ilut) ear Material", and spectfic license Mi.y

Iceedittens., Withla these areas,2;Ahe ~. inspection ' consisted of selective examina '93 tiens ef procedures 'and represehtattwe records, interviews with personnel,_ 9 performance testsJand observations by the: inspector. M

by' 45 $' [~ '); .. ,

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~ E Ouring the inspection, ft was1feund that'certain. activities under your license appear to violate MC requiremoets.x . These -items?and references to pertinent ~$j regalresents art c19sted . in i thei hotice Jef' Violation enclosed herewith . as ..' '

Appendix A.

Elements, te' be' included in[your response are delineated in. d..

Appendia A. j.9a  ? # A

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'fd We 'have esamined actions you h4ee takoviEwith' regard to previously reported M

unressived matters. The status gf these items is df scussed in the enclosed report. 4 4-P -

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In accordance with Sectt'en 2.790(d) of the NRC's " Rules of practice", Part 2 T*tle 10, Code of ' Federal Regulations, activities involving safeguards and

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'ceurity measures are esempt from public disclosure; therefore, the enclosures to

this letter with the exception of the report cover page, which is an inspection summary, will _not be placed in the 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 as required by the Paperwork Reduction Act of 1980. PL 96-511.

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J. Philip Stonr Director Division of Emergency Prepareeness and Materi41 5 Saf ety Programs i- i u s u r e '.

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