ML20141K702

Insp Rept 70-1113/97-05 on 970414-18.No Violations Noted. Major Areas Inspected:Rp & FP Programs

ML20141K702
Person / Time
Site:	07001113
Issue date:	05/16/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141K692	List: ML20141K690 ML20141K702
References
70-1113-97-05, 70-1113-97-5, NUDOCS 9705290321
Download: ML20141K702 (16)

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i U. S. NUCLEAR REGULATORY COMMISSION REGION II  !

i Docket No.: 70 1113 j License No.: SNM 1097 Report No.: 70-1113/97-05 Licensee: General Electric Company i

Facility: Nuclear Energy Production Location: Wilmington, North Carolina j

Date

April 14-18, 1997 t

i i Inspectors: A. Gooden, Radiation Specialist  ;

l W. J. Tobin Senior Safeguards Inspector  ;

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Approved by: E. J. McAlpine, Chief l

Fuel Facilities Branch Division of Nuclear Materials Safety i

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Enclosure 9705290321 970516 PDR C

ADOCK 07001113 PDR ,

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l EXECUTIVE

SUMMARY

General Electric Nuclear Energy Production NRC Inspection Report 70 1113/97 05 The primary focus of this routine announced inspection was the observation and evaluation of the licensee's radiation 3rotection and fire protection programs. In addition, the status of t1e new Dry Conversion Facility (DCF) was reviewed with respect to radiation protection and fire protection. The report covered a one week period and included the results of inspection efforts of two regional fuel facility inspectors. The inspection identified the following aspects of the licensee programs as discussed below:

FIRE PROTECTION The licensee's Fire Protection Program was well managed, and meeting the intent and goals of the NRC's criteria and technical position. Specifically:

o Positive measures such as redundant pumps and water supplies, various kinds of detectors and fire extinguishers, and several response vehicles were noted for the fire detection and fire suppression systems located throughout the site, as well as, the training and organization of the licensee's Fire Brigade.

e Fire load remains as a challenge to the licensee specifically in the FM0X Building where debris was observed in the hallway near electric heaters. Most construction residue has been removed from the Dry Conversion Facility.

e Although the licensee does not have a formalized Pre Fire Plan nor a Fire Hazard Analysis, other documents, reports and drawings largely meet the intent of the Plan and Analysis.

RADIATION PROTECTION i e A non cited violation was identified for failure to follow procedures governing controlled area activities.

e The installation of stationary air sampling equipment within the DCF had been completed and the licensee's schedule for conducting an air sampling representativeness study indicated late May 1997.

e Although radiation warning signs were not posted, a map indicating the  !

aroposed locations for posting warning signs had been completed for the I XF.

e Requirements for >ersonnel monitoring and bioassay associated with the DCF had been estaalished and documented procedurally.

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e Contamination survey maps depicting the DCF layout were developed and  !

awaiting implementation.

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e e An inspector followup item (IFI) was ident, ed due to the myriad use of blue warning lights plant-wide. -

e The performance of the Radiation Safety Committee (RSC) was effective in trending and maintaining awareness of projects to ensure exposures are maintained as low as is reasonably achievable (ALARA).

e The radiation safety assessments incorporated into nuclear safety recuirements (NSR/Rs) associated with the DCF appeared to be detailed anc technically sound.

e The licensee had developed and effectively implemented a DCP Startup- t Radiological Punchlist as a mechanism for tracking each item to closure.

Attachments:

Partial List of Persons Contacted Inspection Procedures Used List of Items Opened, Closed, and Discussed List of Acronyms 1 1

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j REPORT DETAILS  ;

I. Introduction A. Inspection Overview ,

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1. Puroose

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. l This' inspection was conducted to determine the adequacy of the licensee's radiation protection and fire protection programs, and was l conducted through a review of selected records, interviews with i personnel, and direct observation of work activities. i

2. Ma.ior Areas of Emohasis Areas inspected included-o Radiation Protection Program Implementation i

! i l e Fire Protection Program ,

j e DCF Operational Readiness in the areas of Radiological Protection and Fire Protection. -

l B. Summary of Plant Status  !'

l j This report covered a one week period. There were no unusual plant i

operational occurrences during the onsite inspection. Construction and testing activities for the DCF were progressing.

II. SAFETY OPERATIONS A. Fire Safety (88055)

1. Fire Prevention. Detection. and Suporession

a. Inspection Scope The inspection was conducted to review the licensee's program for fire prevention, detection, and suppression. Specifically, the Dry Conversion Process facility was inspected for the provisions of fire safety. License Condition 4.2.13. " Criteria for Fire Protection and Areas Containing Fissile Material," (Revision 29, dated February 14, 1992), commits the licensee to provide equipment, processes, and facilities with protection from fire' while minimizing the use of water in moderation control areas.

The License Condition was the performance standard of this ins action: other criteria utilized included the NRC Branch

! Tec1nical Position or Fire Protection for Fuel Facilities, published in the Federal Reaister dated August 10, 1992.

Additional criteria was found in the NRC's Generic Letter 95 01, "NRC Staff Technical Position on Fire Protection for Fuel Cycle

Facilities," and t' licensee response of March 14, 1995.

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b. Observations and Findinas  ;

(1) Fire Prevention The licensee uses the WSRC to perform the duties of a fire  :

and safety review committee. The WSRC consists of a least  !

I five senior managers from the scientific and engineering i disciplines, it reports to the Facility Manager. There are i at least quarterly meetings concerning such _ issues as

• radiation safety, personnel exposures, environmental monitoring, industrial safety, major changes in plant l

activities, and criticality safety. The inspector reviewed the 1996' records of the WSRC meetings and noted several i meetings lasted two hours, to include a special meeting '

which reviewed the fire in an incinerator at another MRC licensee, i i

The WSRC had institutionalized the Pre operational Readiness  !

Review effort of the Dry Conversion Process (DCP) facility.  :

this effort utilized the services of two contract members of l

, the Wilmington, North Carolina Fire Department who were  !

tasked specifically with evaluating the DCP fire protection system. Several recommendations relative to additional i extinguishers of different capabilities and relocation of j existing extinguishers were made by these-contractors and <

have been acted upon by the licensee.

i The WSRC had also sponsored an Integrated Safety Analysis (ISA) of the DCP facility. This ISA analyzed criticality, fire safety, chemical and radiation hazards, industrial and environmental safety. The " configuration management" discipline was utilized by the licensee to ensure changes to structures or processes were well prepared and coordinated throughout the many departments and levels of management.

The WSRC is formalized via Procedure No. 48 01. "Wilmington Safety Review Committee," Revision 12, issued October 27, 1997.

In the response to Generic Letter 95 01, the licensee referred to its ISA, configuration management, Radiological Contingency and Emergency Programs and inspections performed by the insurer. The inspector reviewed all of these elements and also the April 1992, Halobertan Hazard Study, a "HAZ0PS" analysis of the processes, facilities and

, protection strategies using national standards. This study, while not reviewed every two years as recommended in Position 10 of the NRC Branch Technical Position, does meet the intent of a Fire Hazards Analysis in that it was a systematic study of " fire areas" throughout the facility

relative to construction, operations, storage. transfer, and 1 fire protection equipment.

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Also addressed in the response to NRC Generic Letter 97 05 is the licensee's position that while it does not have a Pre Fire Plan (Position 9 of the NRC Branch Technical Position) it relies on drawings of buildings and rooms which are kept at the Emergency Control Center (ECC) in addition to its Radiological Contingency and Emergency Plan (RC&EP) which has been coordinated with offsite responders and instructs fire fighters to minimize water useo in moderation control areas. The ins)ector reviewed training and procedures based upon t11s RC&EP and, as recommended by the NRC Branch Technical Position, noted that each building in the Control Access Area (CAA) is assigned to a " Building Engineer" who responds to the ECC in the event of a fire alarm where offsite and onsite responders are given current building and process instructions.

Work Permits are issued in accordance with Procedure 503,

" Cutting and Welding Permits" which requires a Building Engineer to authorize each fire watch as necessary to be posted during and after such activities.

(2) Fire Detection The inspector toured the facility and noted the presence of smoke and heat detectors which annunciate in the ECC. The inspector was present in the ECC and witnessed the audio-visual annunciation of such detectors being tested by technicians in the DCP facility. Also annunciating in the ECC were " tamper" alarms on the Position Indicating Valves (PIVs) and flow alarms from the wet sprinkler systems. It is the duty of the security officer posted in the ECC to call for offsite assistance. Pull boxes alarm 't the ECC and also locally. The inspector reviewed the report of the contractor who annually inspects and re) airs the smoke detectors located inside the ducts of t1e uranium recovery facility. Four of the 23 detectors failed the ionization test: two were repaired and two were replaced in a timely manner.

While not " detectors," the inspector noted that closed i circuit televisions were inside the DCP facility at several elevations overlooking the kiln operations, which would allow operators to remotely detect fires or smoke.

l The inspector discovered a housekeeping problem in the l hallway of the FM0X facility where the licensee was storing l books and numerous documents on shelves. The inspector noted many shelves had collapsed resulting in general clutter in the hallway. This housekeeping issue was brought

to the attention of the licensee at several stages of management, and also discussed during the Exit Meeting. The licensee reacted positively to the inspector's comments.

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! The inspector also brought to the attention of the licensee  ;

that in its. correspondence of February 19, 1997, to the NRC l from the Manager of Fuels and Facility Licensing regarding o

the ISA of the DCP, the licensee states that, " Alarm signals i are relayed to both the DCP control room and the Site  !

L Emergency Control Center." In. fact, the ins ctor i determined that the alarm signals for the h rogen and i l hydrogen fluoride detectors in the DCP faci ity are relayed i only to the DCP control room and not to the ECC. It is the ,

l licensee's intent to correct this correspondence.

(3) Fire Suppression i

The licensee has a wet sprinkler fire suppression system fed  !

from a 150,000 gallon (reserved) tank and from a 300,000 I gallon (minimum) pond. An electrical pum) is dedicated to the tank, a diesel pump is dedicated to t1e >ond. At the pond there is also a gravity flow valve whic1 can be used by fire trucks for refill purposes.

The inspector brought to the attention of the licensee that a letter from Fluor Daniels, dated May 30, 1996, to Factory  ;

Mutual Engineering. states that no pond water source is used i for the sprinkler system, when in fact a pond source is used. The licensee intends to correct this correspondence. l

, All four kinds of fire extinguishers were available at ,

appropriate locations throughout the CAA, this included the '

availability of " met 1-x" extinguishers near zirconium areas. The PIVs were found to be locked "open," except for PIV #33 which had a broken lock attached to it. This condition was fixed immediately by the licensee upon notification from the inspector.

Also corrected immediately were the following:

- The false ceiling of the Incinerator Oil Room had been disrupted such that several sprinkler heads were obstructed by tiles, which were immediately removed by the licensee.

The " retard chamber bypass" valve of the sprinkler header along the north wall of the FM0X Warehouse l (Zone #3490) was mis msitioned such that the exterior gong bell would not lave sounded had the sprinkler flowed water. This valve had been turned at 90 degrees and was immediately correctly repositioned to be inline with the pipe by the licensee.

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5 q The inspector toured the kitchen area of the cafeteria in the FM0 Building and found the halon system to be correctly charged and positioned appropriately over the gas fired burners. l Moderation control areas were well marked as to preclude the use of water. Elsewhere, hose stations were well identified and adequate in number and length of hoses.

A fire station is exterior to the CAA, inside is a Haz Mat vehicle, an ambulance, and a 280 gallon fire truck. These vehicles were adequately equipped with protective clothing, i axes, portable lights, breathing apparatus, fans, radios, spill containment kits, and other gear.

The 64 numbers of the Emergency Response Team (ERT) adequately staff the fire brigade on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis, they .

receive four hours of training per month. Annually, the ERT l completes 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of fire suppression and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of I hazardous material training. It is licensee's agreement -

with the New Hanover County volunteer response department that any fire alarms from the facility will automatically be responded to by four volunteer fire companies. This allows for special vehicles (such as an aerial truck) to be called l upon for responses.  !

c. Conclusion l There were no violations nor deviations identified. The licensee i will correct two documents that contain inaccuracies relative to the source of water for it's fire sprinkler system and relative to alarm annunciation from the DCP facility. Through the interaction '

i of the Radiological Contingency and Emergency Plan, Haloberten Hazard Study, the Wilmington Sfety Review Committee, the DCP Startup Integrated Safety AnMysis, numerous fire detection and suppression systems, the availability of the ERT and the assistance offsite responders the license is adequately meeting the intent and goal of the NRC Branch Technical Position.  !

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III. Radioloaical Controls )

A. Radiation Protection (83822)

1. Radiation Protection Procram Procedures (R1.02) j

a. InsDeCtion SCoDe The inspector reviewed the licensee's program for the development and implementation of Nuclear Safety Release / Requirements (NSR/Rs) and Radiation Work Permits (RWPs). License Condition 9 of

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SNH 1097 requires the licensee to comply with the statements, representations, and conditions contained in Part I of the application dated October 23, 1987; and supplements thereto.

Chapter 3, Section 3.1.1 of the License Application specifies the conditions for issuing a RWP. Specific requirements for the RWP 3rogram were documented in Procedures NSI 0 9.0 (Radiation Work

'ermits, Revision 29, issue date November 8, 1996), and P/P 40 09, (Service Work on Contaminated Equipment, Revision 12, issue date June 4, 1996).

Chapter 2, Section 2.7.1 of the License Application states that

" Area Managers shall assure preparation of written operating procedures incor) orating nuclear safety control limitations established by tie criticality and radiation safety functions."

b. Observations and Findinas The inspector reviewed the licensee's procedures for issuing RWPs and examined the RWP requirements and workers performance in complying with the associated RWP. The inspector reviewed three RWPs. Two of the three RWPs were closed and one was considered opened. The requirements for protective equipment, air monitoring, work hazard, and special instructions were clearly delineated. In response to the open RWP, the inspector interviewed the licensee contact with RWP responsibility and discussed training and bicassay requirements associated with the opened RWP. Names of workers who acknowledged having reviewed the RWP were selected at random to determine if appropriate training was provided. No problems were noted.

The inspector reviewed the status of selected procedures and NSR/Rs for startup of the DCF to process natural uranium. The NSR/Rs were referred to as Revision 0 with the emphasis placed on radiological safety requirements. According to a licensee contact, all subsequent DCP NSR/Rs (Rev.1) will be specific to the enriched operations and emphasis on criticality safety requirements. The inspector also reviewed the status of procedural develoament and approval for the bioassay program. No proble.as were caserved. Regarding the bioassay program, Procedure NSI 0-2.0

" Bioassay (Excreta)-Program, was revised to incorporate the details and requirements for individuals assigned to the DCP. In addition, Practices and Procedures (P/P) 40 19 " Bioassay Program" was modified to reflect the more conservative values of Uranium for work restrictions. Regarding 3rocedural changes to reflect the external dosimetry program for DC), the licensee had not completed the procedural details but was aware of the necessary changes as evidenced by the discussion of external exposure assessment addressed in the rad safety analysis associated with the vaporization area.

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c. Conclusions  !

Based on the review of documentation and tours of the controlled area, the inspector determined that the RWPs were requested and generated in accordance with procedures and Chapter 3 of the license application. The appropriate reviews, check lists, and forms were executed by radiation protection personnel. The radiation safety assessments requested for input to NSR/Rs were very detailed and appeared to be technically sound and in some cases incorporated lessons learned from existing owrations involving Ammonium Diuranate and a DCF located in Trance.

Documentation indicated that the licensee's actions in the development and issuance of RWPs and NSR/Rs were consistent with the license commitment and procedures.

2. Radiation Protection Procram Eauipment (RI.03)

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a. Inspection Scope Equipment was examined at various locations to verify that radiation protection equipment and controlled area survey equipntwascalibratedandoperationalinaccordancewithNSI0-4.0 Nuclear Safety Instrumentation." Included was the stationary air sampling system and other radiation protection equipment necessary to support operations in the new DCF.

b. Observations and Findinas The inspector toured the chemical product line, pellet production and rod load areas, DCF, and the laundry area. Instruments used for frisking were checked at step off pads and exiting locations for operability and a current calibration sticker. The inspector observed a Radiation Protection Monitor performing a daily check on equipment used for detecting the presence of contamination prior to counting samples. Selected instruments were examined and determined to be operational and within calibration dates.

Selected stationary air samplers (SASS) were observed to be operational and sample flow rates were within procedural setpoint.

During tours of the DCF, the inspector noted that most of the SASS had been installed and had current calibration stickers affixed to the rotameter. The inspector also noted during the tours the myriad use of blue warning lights plant wide, and depending on the location the significance as evidenced by the following:

e DCP flashing light indicates a hydrofluoric acid release in progress (in vaporization area), or criticality accident

(grit / sand blasting facility).

l e FM0 - flashing light indicates excess weight (chemical L area), or an opened door (gadolinia shop).

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4 In light of the above observations, the inspector discussed with licensee contacts the confusion which resulted during the tour regarding the need to evacuate as a result of the blue light that ,

was indicating. In response to the inspector's comments and human factors concerns associated with the use of blue lights, the licensee stated they would perform a review and evaluation of the site wide use of warning lights for making improvements. A licensee contact indicated that the review and evaluation would be completed in 60 days. The inspector informed the licensee that the review and evaluation of warning lights from a human factors  ;

standpoint was considered an inspector followup item (IFI 70-1113/97-05 01).

The inspector also noted during the review of the licensee's DCP  :

Startup Radiological Punchlist that certain equipment items must be resolved before DCF startup (e.g., operation of air samplers).

c. Conclusions Based on the response of instruments and calibration dates, instruments were operable and calibrated at the required frequency in accordance with license requirements and procedures. The licensee's radiological punchlist provided an effective administrative control for tracking equipment installation and functional testing to sup> ort DCF startup and operations. At the time of the inspection, t1e licensee had not completed an air  !

sampling representativeness study for DCP. l l

3. Postinos (R1.07) l

a. Insoection Scope The inspector examined DCF to determine if adequate postings were in place to support operations in the new DCF.

l b. Observations and Findinos During tours of the DCF, the inspector noted that the facility was  !

in the final construction stages and the necessary radiation l protection postings had not been installed. The inspector l reviewed this matter with the licensee contact assigned responsibility for )osting. In response, the licensee contact provided a map whic1 displayed the proposed locations for posting the radiation warning signs. In addition, the inspector was shown exam)les of the signs that were ordered, and the installation of l

! the 3eforementioned signs were included on the pre operational j checklist for DCP. l The inspector also reviewed the status of evacuation routes and posting of evacuation signs during the DCF tours. A map showing the evacuation routes had been completed, but the evacuation Plan for DCF was incomplete at the time of the inspection. The j l

5 evacuation signs appeared to direct workers to the nearest exit in the event of an accident or emergency. The inspector noted that signs were a combination of permanent (which according to the licensee contact illuminated in the dark) and temporary. The inspector was informed that the temporary signs were installed as interim measures until the inventory of permanent signs ordered were received.

c. Conclusions Although the necessary radiation protection posting and evacuation plan had not been completed, the licensee was tracking these items for completion before DCF startup.

4. Surveys (R1.08)

a. Inspection Scope The licensee's contamination control survey program was reviewed to determine if the program was adequate and implemented in accordance with 10 CFR Part 20. license conditions, and procedures.

b. Observations and Findinas The inspector accompanied a Radiation Protection Monitor during the performance of contamination surveys, and observed the collection of smear samples from locations within the Process Technology Lab (PTL), can storage, and fuel preparation room. The performance of the Monitor in conducting surveys and attention to details associated with sound health physics practices was good.

Personnel demonstrated excellent familiarity with procedures. When visible contamination (powder) was found, the contact took prompt actions in accordance with procedural requirements to prevent airborne exposure and/or spread of contamination.

l In addition to the above observations, documentation in support of periodic surveys were reviewed for the period December 1996 thru January 1997, covering Bundle Assembly, FM0 Calciners/ Sluggers, URU HVAC, and the URV Control Room and Laboratory. The  !

documentation for randomly selected areas disclosed that the l surveys were performed at the required frequency in accordance with procedure NSI 0 6.0 (Contamination Measurement and Control.

Rev. 32. Issue Date February 24, 1997). '

During the performance of surveys discussed above, the inspector did not identify any significant weaknesses in the licensee's program to maintain and control radioactive materials. However, ,

the inspector observed examples where licensee wrsonnel failed to follow general rules associated with food, drin(s. gum or tobacco in the controlled area. Discarded candy wrappers were found in three different locations within the controlled area: blender-

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I warehouse, Chemical Foreman's air lock area, and the low enriched '

blending and powder storage area. Actual consumption or chewing was not observed. Section 3.2.1 of the license application required that access points to controlled areas are established through change rooms. The instructions controlling entry and exit from controlled areas are posted at the entry points. The referenced instructions are implemented via NSR/R CHANGER 00H PROD No. 85.04 entitled CONTROLLED AREA GENERAL RULES. NSR/R CHANGER 00M PROD No. 85.04 (CONTROLLED AREA GENERAL RULES, Rev. 10.

DATE ISSUED September 23, 1992) states that "No food, drinks, gum or tobacco are permitted in the Controlled Area." In response, the following actions were taken by the licensee immediately after the inspector's discovery:

o Training was conducted on all shifts regarding the site policy on candy, gum, and any other substance placed in the mouth while in the controlled area. Training, according to documentation, emphasized that actions would be swift and severe (including possible termination) if an employee was found with anything in their mouth while inside the controlled area.

o Handatory reading was required by all shifts emphasizing that food in the controlled area was a violation of the radiation safety )olicy. In addition, the required reading discussed the risc and hazard associated with violating the policy. All em)loyees were required to sign a training sheet acknowledging laving read and understood the rule regarding food in the controlled area.

o A Meeting Notice (referred to as "11 Hinute Meeting") with plant wide distribution was planned for issuance on Honday, April 21, 1997, to further emphasize issue regarding housekeeping requirements for controlled and non-controlled areas.

o A status summary was compiled of self identified findings involving gum, candy, etc., in the controlled area since the last NRC inspection of this area (August 1996). The summary disclosed that in mid October and November 1996, findings were identified and corrective actions were implemented i during November and December 1996. The corrective actions appeared to be effective in that no repeat findings were

! made until February 1997. The February 1997 finding was attributed to windy conditions transporting material from outside during construction / repairs in vicinity.

o During weekly safety training, the policy regarding gum, foods, etc., will be included in discussion.

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7 The licensee was informed that the examples of candy wrappers I found in the controlled area was a violation for failure to follow controlled area requirements in N5R/R CHANGER 00M PROD No. 85.04.

However, in light of the above actions, this NRC identified violation is not being cited because the violation met the  !

criteria specified in the NRC Enforcement Policy. The licensee was informed that this finding was considered a Non cited Violation (NCV 70 1113/97 05-02).

c. Conclusions Although a NCV was identified for failure to follow procedures i governing controlled area activities, no concerns were noted with  ;

the licensee's surveys. Smears were effective in contamination control. The program was implemented in accordance with procedures, license conditions, and requirements in 10 CFR 20.1501.

5. Imolementation of ALARA Proaram (R1.10)

a. Inspection ScoDe The licensee's ALARA program was reviewed to determine if the  !

program and ALARA goals were being developed and implemented in i accordance with Section 3.1.2 of the license.

b. Observations and Findinas The inspector reviewed selected aspects of the licensee's training program associated with radiation workers refresher training, to ascertain if ALARA concepts and or company policy associated with i ALARA was clearly communicated. No problems were noted. The l refresher training for 1996 was effective in combining both instructions and class participation in the identification of poor health physics practices in maintaining ex3osures ALARA. During a l previous review of the training program (Il 70 1113/96 07), the inspector noticed the lack of variability in the exam questions for the initial training provided to radiation workers. In response, the inspector was informed that the Nuclear Safety training program was under review for making improvements.

Consequently, during the review of the annual refresher training

, the status of the Nuclear Safety training review was discussed.

I The licensee contact indicated that the program changes were .

I incomplete at this time. However, a commitment tracking number j l was assigned to the licensee's internal tracking system

(NRC COM 97-03) to complete the evaluation of Nuclear Safety training (NS 203) and develop new course outline and exam.

The inspector attended the April 16, 1997 RSC meeting and noted that attendees provided status updates regarding progress in meeting milestones for exposure reductions, UIRs. audit results, i

etc.. In addition, the inspector reviewed RSC meeting minutes

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covering the period September 1996 thru December 1996, and i determined that the RSC was effectively tracking, updating, and >

prioritizing ALARA goals and commitments. In accordance with the license application and arocedures, the inspector noted that the 't annual review of the ALARA program was )erformed by the Wilmington Safety Review Committee (WSRC) on Decem>er 19. 1996. The inspector reviewed meeting minutes which disclosed that the WSRC discussed the ALARA accomplishments in 1996 by the RSC and i reviewed challenges for 1997. Selected sections of the document  :

used to compile the annual ALARA report were reviewed and the following accomplishments were noted for 1996: a significant '

reduction was made in the number of missed bioassay samples; most of the ALARA projects for 1996 were completed; and the average total dose to workers was reduced 20% from the previous year (1995). In addition, goals and objectives for 1997 were established including the assignment of responsibility for projects. The inspector noted that many of the 3rojects for 1997 s involved contamination control and reducing air)orne concerns in "

certain areas of production. Further, as challenges in 1997, the WSRC included the smooth transition to full scale DCP operations; and new process startu) which included Decontamination and Volume Reduction Facility (DVlF), and the Uranium Recovery from Lagoon Sludge (URLS) Non Leach and New Product Warehouse. According to -

the ALARA report reviewed by the WSRC, the projected exposures for 1996 were: Total Effective Dose Equivalent (TEDE) was projected to be less than five percent of the NRC limit: Skin Dose Equivalent (SDE) was Dose Equivalent (DDE) projected projection wasto0.5 be percent less than 0.1 percent:

of NRC Deep limit: and the Committed Dose Equivalent (CDE) projection was less than 5 percent of the NRC limit.

c. Conclusions ,

The RSC was conducting frequent and effective meetings to maintain an awareness of projects to ensure exposures are maintained ALARA.

The WSRC evaluated the ALARA program as required by license and procedures. Based on projected exposure results, it appears as though the ALARA program was effective in reducing exposure and improving plant conditions.

6. Management Oversight of Program-(R1.11)

a. Inspection Scope

, The inspector reviewed the adequacy of management controls for

! ensuring the investigation and followup of events or activities l resulting from significant elevated airborne concentrations.

criticality alarms, or acute internal exposures to personnel.

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b. Observations and Findinas .

The inspector reviewed the licensee's Unusual Incident Reports (UIRs). Randomly selected incidents were reviewed for the period Se)tember through December 1996 to determine if the licensee was tacing actions in response to incidents consistent with procedural requirements. Based on documentation resulting from VIRs, the licensee was properly documenting and responding to VIRs in a timely manner.

c. Conclusions The inspector determined that the UIR system appeared to be l working in providing a mechanism for followup on events resulting from elevated airborne concentrations and internal exposures.

7. Information Notices (92701)

a. Inspection Scope The inspector reviewed the following Information Notice (IN) to  !

determine if the information had been received by the licensee:

i e IN 96 57: Incident Reporting Recuirements Involving Intakes, During A 24 Four Period That May Cause '

A Total Effective Dose Equivalent In Excess Of 0.05 Sv (5 rem), dated October 30, 1996. l

b. Observations and Findinas The inspector determined that IN 96 57 had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate, was taken or scheduled.

c. Conclusion The licensee's actions were appropriate.

IV. Facility Support A. Emergency Preparedness

1. Drills and Exercises (F3.05)

! a. Inspection Scope l

The inspector reviewed the licensee's program for scenario development and planning to verify that scenario response details included provisions for participation by offsite resporsse organizations.

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b. Observations and Findinas l The inspector was informed by the licensee contact that offsite response organizations (State, local, and NRC) were invited to participate. In response to NRC participation, the licensee l l contact discussed aspects of the scenario details that would afford the op>ortunity for testing the' interface between the ,

licensee and iRC accident assessment personnel,

c. Conclusions i

Based on the discussion with the licensee contact assigned  ;

responsibility for exercise development and planning, the t l inspcctor determined that coordination had been completed for r l participation by offsite agencies in the June 1997 exercise.  !

V. Management Meetinas  ;

A. Exit Interview The inspection sc.pe and results were summarized on April 18, 1997, with i those persons indicated in the Attachment. The inspector described the  :

, areas inspected and discussed the inspection results, including the  :

violation in the area of access control, and the likely informational content of the inspection report with regard to documents and/or ,

processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the pro)rietary nature of these documents or processes has '

been deleted from t11s report. Dissenting comments were not received from the licensee.

l The inspector informed the licensee that notification regarding the l categorization of the violation as cited or non cited would be provided '

via telephone following additional review by regional management. The licensee was contacted telephonically on April 22, 1997, and informed that based on the additional review of details and subsequent actions by 4 the licensee, the failure to follow access control procedures associated l with food, drinks, gum, or tobacco in the controlled area met the  !

criteria specified in the NRC Enforcement Policy for a NCV.  !

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PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel

• D. Barbour, Radiation Team Leader

• D. Brown, Environmental Projects

• S. Dale. Auditor

• R. Foleck, Senior Licensing Specialist

• D. Godwin, Fire Chief L. Gutermuth, Manager, Industrial Safety l *R. Keenen, Site Emergency Manager l *J. Kline, Manager, Powder Product Line l

• A. Mabry, Program Manager, Radiological Safety l

• R, Martyn, Manager, Material Control and Accountability

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• C. Monetta, Manager, GE NE Environment. Health & Safety l

• S. Murray, Team Leader, U0 Production Team '

• L. Paulson, Manager, Nucle,ar Safety

• L. Quintana, Manager, Fabrication Product Line l

• R. Reda, Manager, Fuels and Facility Licensing )

• B. Robinson, Principal Nuclear Safety Engineer E. Rouse, Monitor, Radiation Protection

• H. Shaver, Nuclear Safety Engineer

• G. Shrow, Environmental Engineer

• G. Smith, Team Leader, FM0 Maintenance Support l *C. Tarrer, Team Leader, Configuration Management & ISA C. Vaughan, Project Manager, EH&S- New Facility Licensing / Safety D. Whaley, Monitor, Radiation Protection .

, Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.

• Denotes those present at the exit meeting on April 18, 1997 Other Personnel j G. Bryan, Wilmington, NC Fire Department J. Green, Wilmington, NC Fire Department J. Griffin, Fluor Daniel, Project Engineer INSPECTION PROCEDURES USED IP 88055 Fire Protection IP 83822 Radiation Protection J

12 LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED I l

i Item Number Status Descriotion l l

70 1113/97-05-01 Open IFI verify that the licensee review and l evaluate warning lights from a human factors standpoint.

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70-1113/97 05 02 Closed NCV - Failure to follow access control requirements in N3R/R CHANGER 00M PROD No. ,

85.04.  !

LIST OF l.CRONYMS AC Area Coordinator AEC Active Engineered Control ALARA As Low As Is Reasonably Achievable CAA Controlled Access Area CFR Code of Federal Regulations DCF Dry Conversion Facility DCP Dry Conversion Project DVRF Decontamination and Volume Reduction Facility ECC Emergency Control Center EH&S Environment, Health & Safety EMT Emergency Medical Team ,

ERT Emergency Response Team '

FHO Fuel Manufacturing Operation FTI Functional Test Instruction GE NEP General Electric- Nuclear Energy Production i HazMat Hazardous Materials HF Hydrofluoric Acid HVAC Heating Ventilation, and Air Conditioning IFI Inspector Follaw up Item IN Information Notice IP Inspection Procedure IR Inspection Report ISA Integrated Safety Analysis NCS Nuclear Criticality Safety NCV Non Cited Violation NRC Nuclear Regulatory Commission NSI Nuclear Safety Instruction NSR/R Nuclear Safety Recuirements/ Release P/P Practices & Procecures i P&ID Piping and Instrumentation Diagram PIV Position Indicating Valve PTL Process Technology Lab RP Radiation Protection RSC Radiation Safety Committee RWP Radiation Work Permit l

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4 13 SAS Stationary Air Sampler SNM Special Nuclear Material  !

UF Uranium Hexafluoride i UIk Unusual Incident Report i UR Uranium Recovery i

URLS Uranium Recovery From Lagoon Sludge '

URV Uranium Recovery Unit i r

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