ML19290E069
| ML19290E069 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 01/11/1980 |
| From: | Gibson A, Millsap W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19290E064 | List: |
| References | |
| 70-1201-79-15, NUDOCS 8003040118 | |
| Download: ML19290E069 (7) | |
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NUCLEAR REGULATORY COMMISSION
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REGION 11 A
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- U ATLANTA, GEORGIA 30303 Report No. 70-1201/79-15 Licensee:
Babcock and Wilcox Company Lynchburg, Virginia 24505
, Facility Name: Commercial Nuclear Fuel Plant Docket No. 70-1201 License No. SNM-1168 Inspection at Babcock & Wilcox Commercial Nuclear Fuel Plant near Lynchburg, Virginia Inspector:
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W. J. Mi 1. p Date Signed Appraved by:
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NO A. F. Gibson Date Signed
SUMMARY
Inspection on December 10-14, 1979 Areas Inspected This routine, unannounced inspection involved 36 inspector-hours onsite in the areas of external exposure control, internal exposure control, respiratory protection program, instrument calibrations, receiving and opening packages of radioactive material, postings and reports, and leak testing of sealed sources.
Results Of the seven areas inspected, no apparent items of noncompliance or deviations were identified in six areas; one apparent item of noncompliance was found in one area (Infraction - Failure to resample based on bioassay result - Paragraph 6.b).
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DETAILS 1.
Persons Contacted Licensee Employees
- W. F. Heer, Manager, Virginia Operations
- D. W. Zeff, Manager, Safety and Licensing R. L. Vinton, Health Physicist
- P. A. Cure, Associate Health Physicist
- K. E. Shy, Foreman, Health and Safety Other licensee employees contacted included two technicians and two operators.
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on December 14, 1979, with those persons indicated in Paragraph 1 above. A licensee representa-tive acknowledged the item of noncompliance discussed in paragraph 6.b and made those commitments described in paragraph 6.b., 6.d(3), and 7.a.
3.
Licensee Action on Previous Inspections Findings Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
External Exposure Control The inspector reviewed the vendor TLD reports for November, 1979 for all individuals on a monthly badging schedule and the TLD reports for the third quarter of 1979 for all individuals on a quarterly badging schedule, paying particular attention to the cumulative results for the year of 1979. In no case did the cumulative results exceed the quarterly limits described in 10 CFR 20.101(a). The inspector had no further questions concerning external exposure.
6.
Internal Exposure Control a.
In-Vivo Analyses The inspector reviewed the results of all in-vivo analyses performed during the last five count periods:
8/78, 11/78, 2/79, 6/79, and 8/79.
The inspector observed no case where the licensee's internal action level for in-vivo analyses of 125pg U-235 described in Procedure No. AS-1121 Rev. 3 " Uranium Bioassay Program" was exceeded.
The inspector had no further questions concerning in-vivo analyses.
. b.
Urinalyses The inspector reviewed the records entitled " Bioassay Record" for the urinalyses results for all people sampled for the year 1979 and compared the results against the 15pg/l and/or 50 DPM/1 action level described in Procedure No. AS-1121 " Uranium Bioassay Program"; any urinalysis result in excess of these limits requires that the individual be resampled, the results evaluated and corrective action taken if warranted.
The records of samples from approximately 100 people were reviewed and, of these, samples from eight people exceeded the 15pg/l action level. Of these eight, the licensee resampled the individuals and evaluated the results except in one case where a urine sample taken fron an individual on June 6, 1979 was assayed to contain 20pg/l uranium and the license failed to obtained a resample. The inspector informed the licensee that this failure to resample was in noncompliance with his license.
At the time of the exit interview, a licensee representative acknowledged this item of noncompliance and stated that this individual would be resampled. In order to prevent future failures to resample, the licensee had instituted a more formalized system to track bioassay results that require resample and a licensee representa-tive stated that this system was in place at the time of the exit interview.
The inspector stated that he would review the results of the licensee's effort during a subsequent inspection (70-1201/79-15-1).
c.
Sampling of Airborne Radioactive Material (1) MPC-Hour Records The inspector reviewed the records entitled "MPC Hour Record" for the first three quarters of 1979 for all persons for whom these records are kept.
The inspector observed no instance of an individual exceeding the 40 MPC-hour control measure described in 10 CFR 20.103(b)(2) or the quarterly exposure limits described in 10 CFR 20.103(a)(1).
The inspector had no further questions concerning this matter.
(2) Control Limits on Static Samplers The inspector reviewed the records entitled " Control bd Areas Air Sample Averages", which give the quarterly averages of the concen-trations of airborne radioactive material as measured by the static air samples, for the first three quarters of 1979 and compared the results against the air sampling action levels described in paragraph 8.2.3 of section V of the license application. The first of these action levels requires that if the average airborne concentration of radioactive material exceeds 25% of MPC it be reported to the Manager of Safety and Licensing, the operation and containment be evaluated, tad to increase air sampling frequency if indicated.
The inspector observed two cases in which the 25% MPC control limit was exceeded:
the granulator scrap feed hood in the first quarter and the powder
. sampling station in the third quarter. In both cases, the licensee's response satified the requirements of the license condition. The inspector had no further questions concerning this matter.
d.
Control of Airborne Radioactive Material (1) Hood and Elephant Trunk Face Velocity Surveys The inspector reviewed the records entitled " Hood and Elephant Trunk Air Flow Audit" from January 5 to December 4, 1979 and compared the results against the requirements of paragraph 8.2.2 of section V of the license application which states that face velocities for hoods and similar enclosures shall be 100 LPM unless it can be demonstrated by air sampling techniques that a lower capture velocity will result in no significant increase in airborne activity and that the minimum velocity at the point of entrance to " elephant trunk" drops in the pelletizing area will be 1300 LPM; this condition also states that hood face velocities and elephant trunks entrance velocities will be measured weekly.
The inspector observed no case where the hoods and elephant trunks failed to meet the minimum face velocity requirements and no case where they were not measured at the proper frequency. The inspector had no further questions concerning these records.
(2) Negative Pressure Surveys The inspector reviewed the records entitled " Negative Pressure Audit" for the period from January 2 to December 10, 1979 and compared the results against the following requirements of para-graphs 8.2.1 and 8.2.2.
of section V of the license application:
(i) General area exhaust units will be operated to maintain areas of greater contamination at a slight negative pressure with respect the lesser contaminated areas; (ii) Exhaust flow rates from gloveboxes shall be such that a minimum negative pressure of 0.25 inches of water is maintained. The above records showed by smoke tests and manometer readings that the areas of greater contamination were being held at a negative pressure with respect to lesser contaminated areas and that, by monometer readings, a minimum negative pressure of 0.25 inches of water was being maintained on the blender glovebox. The inspector had no further questions concerning these records.
(3) Hood Face Velocity Checks A licensee representative, at the request of and in the presence of the ir.spe cto r, measured the face velocities of the following five hoods chosen by the inspector:
the pellet grinder feed hood, the grandulator feed hood, the oxidation furnace hood, QC hood #4 and on opening on the dried pellet turntable hood, and compared the results against the requirements of paragraph 8.2.2 of section V of 'ha license application which states that face velocities for hovJs and similar enclosures shall be 100 LFM
4-unless it can be demonstrated by air sampling techniques that a lower capture velocity will result in no significant increase in airborne activity.
The pellet grinder feed hood, the granulator feed hood and the oxidation furnance feed hood exceeded the 100 LFM face velocity requirement.
However, the QC hood #4 face velocity only marginally met the above requirement and the opening on the dried pellet turntable hood f ailed to meet the requirement.
The inspector discussed the use of these two hood with several licensee representatives.
It was established that the marginal face velocity for QC hood #4 was due to raising the hood door past the point known to provide the proper face velocity and that the opening on the dried pellet turntable hood, which is normally closed, had only recently been used for brief periods on infrequent occasions due to a small operational problem and that the concen-tration of airborne radioactive material in this area had no been noted to be unusually high. At the time of the exit interview, a licensee representative stated the QC hood #4 as well as three others located adjacent to it would be fitted with mechanical devices to prevent them from being raised above the proper level and that similar hoods would be evaluated for the need for these devices (70-1201/79-15-2). Also at the exit interview, a licensee representative state' that the concentration of airborne radioactive material in the immediate vicinity on the opening on the dried pellet turntable hood would, for a representative period of time, be evaluated by air sampling and that appropriate corrective actions would be taken if warranted (70-1201/79-15-3).
The inspector stated that the results of the licensee's efforts would be reviewed during a subsequent inspectica.
7.
Respiratory Protection Program By discussion with the responsible licensee representative and review of Procedure No. AS-1109 Rev. 6 " Respiratory Protection Program", the inspector reviewed the licensee's respiratory protection program in the light of the regulatory positions discussed in Regulatory Guide 8.15 " Acceptable Programs For Respiratory Protection" adherence to which is required by 10 CFR 20.103(c) since the licensee makes allowance for use of respiratory equipment in estimating the exposure of individuals to airborne radioactive material.
The inspector noted no case where the licensee failed to comply with the provisions of Regulatory Guide 8.15.
Certain information, pertinent to this review, is discussed below.
a.
Concentrations of Airborne Radioactive Material In Excess of the Protection Factor Afforded By Respirators Regulatory Position C.2 of Regulatory Guide 8.15 requires that respiratory protection equipment be used so that the average concentration of radioactive material in the air that is inhaled during any period of uninterrupted use in an airborne radioactivity area, on any day, by an individual using the equipment, will not exceed the values specified in Table 1, Column 1 of Appendix B to 10 CFR Part 20.
The inspector
then discussed with a licensee representative those cases, specified in a memorandum entitled " Exceeded Protection Factors" dated July 30, 1979, where the multiple by which the airborne concentration exceeded the maximum permissible concentration exceeded the protection factor af forded by the respirator in use during a particular job. During the discussions the inspector determined that in all job functions for which the protection factor had been exceeded, except one, the licensee had changed respirators in order to increase the protection factor; the inspector verified this by reviewing recent " Air Sample Work Sheets" which record both the work function and the type of respirator used. The one exception had occurred on October 2, 1979 during the changing of a prefilter where the airborne concentration, as measured by a lapel sampler, had exceeded the protection factor afforded by the full face respirator being used.
A licensee representative stated that many prefilters had been changed in the past and that this was the first case where the protection factor afforded by this respirator had been exceeded and that this situation was being watched and if exceeded protection factors became repetitive another respirator with a higher protection factor would be used. The inspector stated that considering that this was one case out of many, based on a possibly contaminated lapel sampler, and considering that the licensee had shown himself to be responsive to this matter in other jobs, he agreed with the licensce's position. At the time of the exit interview, a licensee representative stated that a statement requiring o.1 evaluation of the need to increase the protection factor if the protection factor of a respirator is exceeded would be added to the respiratory protection procedure and that this evaluation would be documented. The inspector stated that the results of the licensee's actions would be reviewed during a subsequent inspection (70-1201/79-15-4).
b.
Medical Status of Respirator Users Paragraph 4.h of Regulatory Guide 8.15 requires that individuals be shown to be physically capable of using a respirator prior to their first use of a respirator and that the medical status be reviewed annually.
The inspector reviewed the current respirator physical and noted that they all met the annual requirement; the inspector then compared unqualified people against the " Respirator Use Authorization" list and found no unqualified people on the list. The inspector had no further questions concerning this matter.
8.
Instrument Calibrations The inspector reviewed the calibration records for selected portable instru-ments and one laboratory alpha counter and compared the results against paragraph 8.3.4 of section V of the license application which requires semi-annual calibrations.
The instruments selected were:
Radector III
(#739), R0-2A (#200), several PAC-4Gs, PNR-4 (#3468) and the NMC automatic counting system.
For the year of 1979, all calibration frequencies were met. The inspector had no further questions concerning this matter.
9.
Picking Up, Receiving and Opening Packages of Radioactive Material The inspector, by discussion with a licensee representative and review of Procedure No. AS-AD-1111 Rev. 2.
" Shipment and Receipts of Radioactive Material", examined the licensee's arrangements for meeting the requirements of 10 CFR 20.205. A licensee representative stated that greater than Type A quantities of radioactive material were not received at this facility and therfore it is exempt from many of the requirements of 10 CFR 20.205.
Those requirements of 10 CFR 20.205 for which the facility is not exempt by virtue of not receiving greater than Type A quantities of radioactive material were adequately covered by the above procedure.
The inspector than examined the "UO Receipt / Shipment Radiation Survey" forms for ten 2
shipments of radioactive material received by the licensee between May 28 and December 6, 1979.
All required radiation surveys were noted to have been performed and to have met the applicable limits. The inspector had no further questions concerning this matter.
10.
Postings and Reports The inspector examined the licensee's posting of notices to workers as a.
required by 10 CFR 19.11.
These postings were present and met'the requirements of 10 CFR 19.11.
The inspector had no further questions concerning this matter.
b.
The inspector reviewed the termination report records of three workers who had terminated employment with the licensee during 1979.
The records revealed than the licensee had met the requirements of 10 CFR 19.13 and 10 CFR 20.408 in these three cases.
The inspector had no further questions concerning this matter.
11.
Leak Test of Scaled Sources The inspector reviewed the licensee's records of the leak tests of a Cf-252 source (Serial (iMRC-CF 131) for 1979 and compared the results against the requirements of paragraph 8.6.5 of section V of the license application for test sensitivity and frequen.y. The licensee's tests met these requirements and the inspector had no further questions concerning this matter.
.