ML19269C630

Responds to NRC 781218 Ltr Re Violations Noted in IE Insp Rept 50-201/78-09 on 781115-17.Corrective Actions:Corrected Tables to Require Surveillance Surveys.Breathing Zone Air Sample Results Will Be Properly Transcribed

ML19269C630
Person / Time
Site:	West Valley Demonstration Project
Issue date:	01/05/1979
From:	Oldham W EMVNFWV
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19269C629	List: ML19269C630
References
1-79-004, 1-79-4, NUDOCS 7902070007
Download: ML19269C630 (3)

Text

. .

,y Nuclear Fuel Services, Inc. P.O. Box 124

• West Valley, New York 14171 A Subsidiary of Getty Oil Company (716) 942-3.

January 5, 1979 l-79-004 Mr. George H. Smith, Chief Fuel Facility and Materials Safety Branch US Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pa.19406

Dear Mr. Smith:

This will acknowledge and respond to your letter of December 18, 1978 (received December 21,1978) regarding Inspection No. 78-09 conducted by Mr. P. Clemons on November 15-17, 1978 of License No. CSF-1 activities. Your inspection indicated one infraction and one deficiency which are discussed in the enclosure of this letter.

We believe the corrective actions specified in the enclosure will prevent recurrence.

Very truly yours ,

b& L -

W. A. Oldham General Manager WA0: bon Enc.

79020700 1

ENCL'05URE - W. A. Oldham to Nuclear Regulatory Commission, Region I, January 5, 1979 NFS RESPONSE TO USNRC REGION I LETTER TO NFS December 18, 1978 INSPECTION NO. 50-201/78-09 NRC ITEM A_

Technical Specifications 7.1.4 states " Detailed written procedures...

shall be prcvided for operation of the plant. In addition, procedures for handling abnormal operating conditions, and for radiation protection shall be provided."

Section 8.0 of the Health and Safety Procedures Manual, developed pursuant to Technical Specification 7.1.4, requires routine surveys be made on a scheduled frequency.

Contrary to the above, Section 8.0 of the Health and Safety Manual was not followed in the following instances:

1. Weekly smear surveys for alpha contamination were not performed in the Instrument Shops as required by Table 8.15(b) during 1978.

2. Quarterly smear surveys for alpha contamination were not performed in the Annex Building as required by Table 8.17 during 1978.

3. Weekly beta-gamma radiation surveys were not performed in the Emission Spec Laboratory, or the Mess Spec Laboratory as required by Table 8.15(b) during 1978.

NFS RESPONSE Sections 8.5.2 and 8.5.4 of the Health and Safety Procedures Manual identify the espective weekly and quarterly surveillance of areas and reference Tat ias 8.15 and 8.17 as containing the requirements for surveys.

The specific areas requiring surveys are identified on posted sign-off sheets which are dated and initialed by the Specialist upon completion of the task. The survey results are recorded in the Health and Safety Depart-ment Plant Surveillance Logs.

As surveillance requirements change due to changes in plant conditions, updated regulatory guidance or other factors, corresponding changes in the Procedures Manual and surveillance log books are affected. During the last revision of the Health and Safety Procedures Manual, the discrepancy between the executed and documented surveillance program and the Tables 8.15 and 8.17 listing of survey requirements was overlooked. We have reviewed the survey requirements for the subject areas and find the surveillance log books to be appropriate.

.v NFS Response to USNRC-Region'I Letter to NFS Inspection No. 50-201/

78-09 Corrective action will be accomplished by revising Tables 8.15 and 8.17 to properly reflect the specific requirements and additionally, a complete review of Section 8.5, Plant Surveillance, will be completed by March 16, 1979.

NRC ITEM B 10 CFR 20.201(b), " Surveys," requires that "Such surveys be conducted as may be necessary to comply Mth the regulations contained in each section of Part 20.

10 CFR 20.401(b), " Records of surveys, radiation monitoring, and disposal" states "Each Licensee shall maintain records in the same units used in this part showing the results of surveys required by 20.201(b).. ."

Contrary to the above, the licensee made surveys for airborne radioactive material as required by a Special Work Permit (SWP) on May 10, 1978 and records of the survey were not maintained by the licensee as required.

NFS RESPONSE ,

The deficiency cited of failure to maintain tne record of the survey in the same units as required by 20.201(b) refers to a breathing zone air sample taken during the performance of a Special Work Permit task and left recorded in counts per minute on a machine tape stapled to the sample envelope.

Breathing zone air samples (BZAS) are taken when an estimate of radioactive particulate concentrations near the face area is required. The BZAS sampling device currently in use has a sampling rate much lower than the respiration rate of standard man. The BZAS sampling uevice is worn during the performance of Special Work Permit-covered tasks; the duration is generally counted in minutes. In evaluating the counted BZAS samples, each count-per-minute alpha per hour of sampling is approximately equivalent to MFC for Plutonium-239 (soluble). Thus, the machine count factored for sampling time quickly estimates air concentrations.

On the May 10, 1978 sample, the irtormation was not recorded in the BZAS log in the units specified by 20.P01(b).

Immediate corrective action was a discussion with the Health and Safety Specialists regarding requirements of expedient compliance.

Further corrective action which will be taken by amending the Breathing Zone Air Sample chapter of subsection 1, " Air Sampling", of Section 8,

" Radiation Monitoring", in the Health and Safety Procedures Manual is to include instructions to transcribe BZAS results in appropriate units into the BZAS log. This amendment is to be complete by January 31, 1979.