ML20056E632
| ML20056E632 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 08/20/1993 |
| From: | Rosenthal P BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9308240364 | |
| Download: ML20056E632 (3) | |
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,. B&W Nuclear Environmental Services, Inc.
a McDermott company P.O. Box 11165
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Lynchburg. VA 24506-1165
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(804) 522-5414 FAX (804) 522-6860 August 20,1993 l
U.S. Nuclear Regulatory Commission Attn: Document Control Desk
.t Washington D.C. 20555
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Subject:
Reply to a Notice of Violation i
Gentlemen:
I In accordance with 10 CFR 2.201, the B&W Nuclear Environmental Services, Inc.~
Lynchburg Technology Center, is providing the attached reply to the referenced Notice of l
Violation contained in NRC Inspection Report No. 70-824/93-01,' dated July 23,1993.
If you should have any further questions concerning this matter, please feel free to contact l
me or Mr. Charlie C. Boyd, our Licensing & Compliance Officer.
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Sincerely, B&W Nuclear Environmental Services, Inc.
Philip. Rosenthal Manager, Environment, Safety & Health i
Attachment cc.
U.S. Nuclear Regulatory Commission
{
Attn: Stewart Ebneter, Regional Administrator i
101-Marietta ST., N.W.
Atlanta GA 30323 C.C. Boyd R.V. Carlson
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OAnnn-9308240364 930820 "Q
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PDR ADOCK 07000824 A
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Attachment a
REPLY TO A NOTICE OF VIOLATION l
The following response is the B&W Nuclear Environmental Services, Inc. (B&W NES1) reply to the Notice of Violation which was issued as part of NRC Inspection Report No. 70-824/93-01.
i Violation A The licensee failed to meet requirements for DOT shipping paper descriptions in that:
(1)
Selected shipping paper descriptions required by 49 CFR 6s172.201-205 for a consignment conducted May 27,1992, were not listed on consecutively numbered pages nor were the correct total number of pages containing all the required information notated.
(2)
Shipping paper descriptions for June 18,1992, and October 26,1992, radioactive waste consignments havmg reportable quantities of radioactive materials did not include the "RQ" designation either before or after the basic description required by $172.202.
t (3)
Shipping paper descriptions for a May 27, 1992 consignment of radioactive material l
which included packages containing fissile material exempted from the requirements of
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ssl73.451-459 in accordance with 5173.453, did not include the additional description of the hazardous material as " Fissile Exempt" These examples are considered collectively as a violation.
Response To Violation A t
- We accept the violation as stated.
Concerning the first item listed in the violation, our interpretation of the requirements of 49 CFR 172.201 for decades was that the Bill of Lading (which was numbered as "Page 1 of 1") was the parent, stand-alone document and that the Radioactive Shipment Manifests (RSM) referenced on the Bill of Lading was an attachment with'its pages to be numbered consecutively. We understand and are willing to accept the inspector's interpretation of the requirement. The second and third items listed in the violation were inadvertent errors.
Procedure TP-409 will be revised to; (1) change the applicable checklist to include the Bill of Lading with the RSM as page 1 of consecutively numbered pages, (2) include a step to check reportable quantities as either "XX" or "RQ", and (3) include a step to check " Fissile Exempt".
j Furthermore, the individuals responsible for implementing procedure TP-409 will be retrained, emphasizing the need for attention to detail when completing shipping papers.
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. Attach' ment B&W NESI is now in compliance with the specified requirements. Procedure TP-409, which was in the process of being revised before the inspection took place, because of its voluminous size will be completed by September 30,1993.
Violation B The licensee failed to conduct adequate surveys for airborne effluents in that surveys of effluent releases did not include evaluations of iron-55 (Fe-55) concentrations.
Resnonse To Violation B We accept the violation as stated.
I We were acting in compliance with Sections 5.1.3.5 and 5.1.4.4 of our license, which requires sampling and counting of liquid and gaseous effluents for alpha and beta activity on a low background, alpha / beta counting system. Although the effluents were not specifically evaluated ihr Fe-55, we had evaluated the effluents as a whole, conservatively using Sr-90 and U-235 l
MPC values to represent the activity action levels based on the radiological risks. The inspector supported the conservatism of our evaluation when he noted that even with "Fe-55 concentrations equalling the total beta-gamma activity reported, no concerns regarding effluent releases to unrestricted areas were noted."
Nevenheless, immediately following the inspection, two samples were submitted for Fe-55 analysis as well as a gamma scan. One of the samples was an air filter composite consisting of 52 air filters from our stack monitor for the year 1991 (representadve of our current airborne effluents). The other sample was a volume weighted sample representing liquid effluents for January through July of this year. The results of the analysis were received by July 23,1993, and indicated Lower Limit of Detection (LLD) values for both samples. The low background
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counting system used to count effluent samples was also evaluated and found to be more than adequate to detect Fe-55.
The maximum amount of Fe-55 activity released in the airborne effluent was 0.83 pCi and in the liquid effluent,96.3 pCi, i.e., assuming the Fe-55 activity was as high as the LLD. This represents 8E-06% and 0.02% of the 10 CFR 20 Effluent Concentration Limits (ECL's),
respectively. Thus, this evaluation confirmed that the contribution of Fe-55 to the airborne and liquid effluent is negligible. Using the COMPLY computer code, the calculated doses to the maximally exposed off-site individual are identical with or without the Fe-55 present.
Based on these findings, we will continue with our current effluent monitoring program and not specifically analyze for Fe-55. B&W NESI plans no further action on this issue.
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