ML20248C117
| ML20248C117 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/27/1989 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20248C091 | List: |
| References | |
| 70-1113-89-05, 70-1113-89-5, NUDOCS 8908090440 | |
| Download: ML20248C117 (6) | |
Text
e ,
a - x 1
m 3- ,
f,' ]
r 1 L ,;
ENCLOSURE l' NOTICE OF VIOLATION General Electric Company Docket No. 70-1113
. Wilmington, NC License No. SNM-1097 During the Nuclear Regulatory Commission (NRC) onsite inspection conducted on l
May.22-26 and June 12-15, 1989, violations'of NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement' Actions," 10 CFR Part 2. Appendix C (1989), the violations are listed below:
A. 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as .(1) may be necessary for the licensee to comply with the regulations in 10 CFR 20 and (2) are reasonable under the circumstances to evaluate the extent of radiation' hazards that may be present.
10 CFR 20.201(a)' defines a survey to mean an evaluation of the ' radiation protection hazards incident to the production, use, release, disposal, or presence of radioactive materials or other sources of radiation under a-specific set of conditions. When appropriate, such evaluation includes a physical survey of the location of materials and equipment, and measurements of levels of radiation or concentrations of radioactive-materials pre:ent.
10 CFR 20.103(a)(3) requires the lic'ensee for purposes of determining compliance- with the requirements of this section, to use suitable measurements of concentrations of_ radioactive materials in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, to use measurements of radioactivity in the body, measurements of radioactivity excreted from the body, or any combination of such measurements as may be necessary for timely detection and assessment of individual intakes of radioactivity by exposed individuals.
Contrary to the above, licensee surveys were inadequate in that on October 18, 1988, for two contract personnel installing Heating Ventilation Air Conditioning (HVAC) Management and Control System equipment in the overhead and on the recirculation fan platforms located above the Slugger areas, the licensee did not conduct physical surveys of the work location, materials, and equipment, nor did the licensee make adequate measurements of concentrations of radioactive material in the air for detecting and
-evaluating airborne radioactivity hazards present.
This is a Severity Level IV violation (Supplement IV).
8908090440 890727 3 ppR ADOCK 0700 C
p <
m N ,. q
, 1 E : General' Electric Company 2 Docket No. 70-1113 1
- Wilmington, NC-License No. SNM-1097-B.. Parti 1, Secticn 3.2.4.2.1 of the licensee's Application: for License No. SNM-1097. requires the radiation safety function to evaluate annually.
and following process and ' equipment changes, fixed filter sampling points for representativeness of personnel exposures.
Contrary to the above, from .1986-1989, the licensee failed tc conduct adequate. evaluations to demonstrate fixed filter samp%g point representativeness, annually and following process or equipment changes.
This is a Severity Level'IV violation (Supplement IV).
C.' . License Condition Number-(No.) 9 of Special Nuclear Material (SNM) License No.1097 requires that licensed material be used in accordance with statements, representations,- and conditions of Part I of the License Application' dated October 23, 1987.
Part I, Section 2.2.1.4 of the licensee's Application for License No. SNM 1097. requires that radiation protection function activities be conducted in accordance with written procedures.
- 1. Nuclear Safety Release / Requirements (NSR/R) No. 85.04, General Controlled Area Rules, Revision (Rev.) 7, dated April 26, 1988, requires the use of a-(1) yellow and magenta rope or. tape, and yellow and magenta signs displaying various warnings or protection requirements (Example: full face mask required) and/or a (2) flashing yellow light to. alert personnel to conditions causing a high airborne contamination area.
Contrary to the above, the licensee failed to follow procedures for alerting personnel to conditions causing high airborne contamination -
areas on May 25, 1989, in that: (1) a location in the Slab Blender area was barriered off with yellow and magenta tape but was not posted with the yellow and magenta signs displaying warnings or protection requirements; and (2) a location between the Number (No.) 3 ard No. 4 Chemical Area Calciners, posted on one side as an airborne radioactivity area and containing contaminated No. 3 Slugger parts with highest smearable contamination levels of 50,887 disintegrations per minute per 100 square centimeters (dpm/100 cm a ), was not barriered off properly with the barrier rope '
suspended completely around the designated areas.
- 2. .NSR/R No. 85.05, Protective Clothing Rules, Rev. 4, dated August 13, 1987, requires that only authorized personnel wearing appropriate protective clothing / equipment are permitted within a marked-off contaminated area and also that head coverings are worn and cover all hair possible. Posted instructions at the entrance to the Controlled Area stipulate that working and observation personnel wear a cap covering all hair.
1 1 * -
m ,
. General Electric Company 3 Docket No. 70-1113 Wilmington, NC License No. SNM-1097 Contrary .to the above, the licensee failed to follow procedures for use of protective clothing in that: (1) on May 23-25,1989, an estimated ten (10) of 100 personnel observed in the Controlled Area wore their caps in a manner that did not cover all the hair possible; (2) on June 13-14, 1989, nine of 100 personnel observed in the Controlled Area wore their caps in a manner that did not cover all hair possible; and (3) on June 14, 1939, an individual entered beneath the V106 tank, posted as a Controlled Surface Contamination Area, without wearing any protective clothing.
- 3. Practices and Procedures (P/P) No. 40-22, Respiratory. Protection Program, Rev. 5, dated March 23, 1988, Appendix B, Step A.2 and Step -
5 require (1) that individuals return respirators to designated storage areas or Controlled Area laundry when the inmediate use/need is fulfilled and (2) that used respirators are not be be left in the Controlled Area from one shift to another but should be placed in the
" dirty mask" receptacles or returned to the laundry.
Nuclear Safety Instruction (NSI) No. 0-1.0, Respiratory Protection -
Training and Fitting, Rev. 15, dated March 8, 1989, requi res individuals to return respirators to designated storage areas when the innediate use/need is fulfilled.
NSR/R No. 85.06, Face Mask Rules, Rev. 5, dated April 20, 1988, requires that respirators not be left on equipment and/or tool boxes i when no longer needed.
Contrary to the above, the licensee failed to follow procedures for ,
respirator storage in that respirators were noted in the following l unauthorized locations: (1) on May 23, 1989, an unwrapped (used) '
respirator placed on a bucket in the Slab Blender area, and two poly-wrapped (unused) respirators placed inside a fire hose station !
cabinet in the Uranium Recovery Unit (URU) area; (2) on May 25, 1989, ,
one used respirator placed on the work stand opposite the control I panel in the Slab Blender area, and one unused respirator placed inside an area barriered off and posted as requiring a full face respirator near the partially disassembled No. 3 Slugger; (3) on June .
13, 1989, a used respirator placed inside a cardboard box underneath J rags and other pieces of cardboard behind Hammermill No. 6, a used respirator placed on top of an electrical control panel in front of i Hammermill No. 3, two unused half-face respirators placed in the walkway of Hammermill No. 21 and an unused respirator placed in the drawer of a workstation desk beside Slugger / Granulator No. 5; (4) on June 14, 1989, a used respirator placed on a can in the Slab Blender area, and a used respirator placed on a control panel near Hammermill No.3; and (5) on May 23, and June 14, 1989, used respirators in the Slab Blender area not returned to the " dirty mask" receptacles or returned to the laundry between shift changes.
(
u .
3 General Electric Company 4 Docket No. 70-1113 Wilmington, NC License No. SNM-1097
- 4. NSR/R No. 85.08, Personnel Survey leaving Controlled Area, Rev. 7, dated December 8,1986, requires that personal surveys be conducted by placing the scanner probe on an area to be surveyed, holding the probe in place for one to two seconds and monitoring the hands, wrists, chest, TLD badge, neck, face, hair, ankles, and shoes at a minimum.
Contrary to the above, the licensee failed to follow required personal survey procedures resulting in inadequate surveys in that:
(1) on May 23, 1989, of two people observed exiting the U02 i Conversion Controlled Area and one person observed exiting the URV Controlled Area, all three persons moved the probe too rapidly and did not hold the probe in place for the required one to two seconds; J and (2) on May 25, 1989, of 22. people observed exiting the U02 l Conversion Controlled Area six moved the probe too rapidly and/or did {
not survey all designated areas; (3) on June 13, 1989, three of nine {
individuals observed exiting the U02 Conversion Controlled Area moved the probe too rapidly or did not survey all designated areas; (4) on June 14, 1989, three of six workers observed exiting the U02 Conversion and the URV Controlled Areas moved the probe too rapidly {
and/or did not survey all designated areas; and (5) on June 14, 1989, {
an individual observed exiting the controlled area established !
beneath the V106 Tank did not perfocm a personal contamination survey 'j subsequent to leaving the area. i I
- 5. Practices and Procedures (P/P), 40-22, Respiratory Protection j program, Rev. 5, dated March 22, 1988, details cognizant managers as ;
responsible for scheduling respiratory protection training and {
REMTRAC data entry, and the Nuclear Safety Engineering Section as
{
responsible for issuing REMTRAC Status Reports for Fitting / Training status and providing periodic respiratory protection training.
Contrary to the above, as of May 26, 1989, thirteen (13) individuals were overdue their annually scheduled Self-Contained Breathing Apparatus (SCBA) training, as noted by the REMTRAC Status Report ,
dated March 24, 1989.
l
- 6. NSR/R Control No. 4.1.16, Respiratory Testing, Rev. 0, dated January 21, 1982, requires that full-face masks not used after thirty (30) days be returned to the laundry for reinspection.
Contrary to the above, the licensee failed to follow procedures in that unused respirators placed in a storage cabinet in the URU area I on April 24, 1989, had not been returned to the laundry after 30 days for reinspection.
- 7. NSR/R Control No.1.1.26, Empty Can Storage - FMO, Rev. 2, dated June 3,1987, requires that empty cans must have a lid and lock ring i in place and that empty cans must be free of visible contamination.
l l
7 si 7 General Electric Company 5 Docket No. 70-1113 i Wilmington, NC License No. SNM-1097 1
Contrary to the above, the licensee failed to follow procedures for empty can storage in that: (1) on June 13, 1989, nine cans placed in four separate locations of the B&W Blender Area did not have lids and/or lock rings in place and one had visible powder in the bottom, one can located behind Slugger No. 5 had no lock ring in place, approximately ten cans in the Radwaste hallway leading to the Old Decontamination area had no lock ring in place, and one can located in the _ Stacker Warehouse had no lid or lock ring in place; and (2) on j
' June 14, 1989, two cans located in the B&W Hammermill area had no lock rings in place. l
- 8. P/P No. 40-22, Respiratory Protection Program, Rev. 5 dated March 23, 1988, requires Plant Medical personnel to determine that an individual is medically capable to wear a respirator and annually reevaluate this determination.
The criteria listed in Appendix D of the Cotton Dust Standard as found in th t Federal Register, Volume 43, Number 122, dated June 23, 1978, is used by the licensee to determine if a person is medically capable of wearing a respirator. Appendix D requires that at least three forced expirations be carried out by the personnel being tested to demonstrate acceptability to wear a respirator. Appendix D also lists the criteria used to determine when a person is not allowed to wear a respirator or when the person should be retested to verify acceptability. One of the criteria is an excessive variability, greater than 10 percent, between the two largest forced vital capacity (FVC) measurements and forced expiration volume in one second-(FEV1) measurements Contrary to the above, the licensee failed to follow procedures for determining if a person is medically capable to use a respirator in that, for medical records reviewed on June 14, 1989, one individual completed only two forced expirations and for another individual a variation greater than 10 percent was recorded between the two largest FCV's and FEV1's.
This is a Severity Level IV violation (Supplement IV).
D. License Condition No. 9 of SNM License No.1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the License Application dated October 23, 1987.
Part I, Section 2.2.1.4 of the licensee's Application for License No. SNM 1097 requires that radiation protection function activities be conducted in accordance with written procedures.
NSI No. 0-6.0, Contamination Measurement and Control, Rev. 19, dated j June 7,1988, Appendix C, requires that smearable contamination in excess of 10,000 dpm/100 cm2 alpha or visible contamination on floors and 25,000 dpm/100 cm2 alpha on controlled area equipment, be cleaned immediately.
_ _ _ _ _ _ - - . -_-_ _ -_____________-__ _ __-_- _ _ ______________a
i i .
I .
General Electric Company 6 Docket No. 70-1113 Wilmington, NC License No. SNM-1097 Contrary to the above, radiation protection activities were not conducted in accordance with written procedures in that: (1) during June 13-14, 1989, visible contamination was observed on FM0 Powder Warehouse railings and floor areas and a NRC requested contamination survey indicated maxit contamination levels of 30,000 dpm/100 cme on railings and selected equipment in the area; and (2) on May 25, 1989, NRC requested contamination surveys of the No. 3 Slugger equipment parts, which had been maintained in the Controlled Area for several days, indicated maximum smearable contamination levels of 60,000 dpm/100 cm2 This is a Severity Level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, General Electric Company is hereby required to submit a written statement or explanation to the Nuclear Regulah ry Commission, ATTN: Document Control Desk, Washington, DC 20555, with a cqy to the Regional Administrator, Region II, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) ihe date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be teken.
FOR THE NUCLEAR REGULATORY COMMISSION l J. Philip Stohr, Director i Division of Radiation Safety and Safeguards l Dated at Atlanta, G rgia this g74. day ofdr 1989 1
1 1