ML20058A281
| ML20058A281 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 10/19/1990 |
| From: | Trent L BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010250375 | |
| Download: ML20058A281 (5) | |
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Babcock & Wilcox u,y.i woci.., ro.i oivmon a McDermott company P. O Box 785 Lynchburg, Wginia 24505 0785 October 19, 1990 (8041522-6000 U.S. Nuclear Regulatory Connission Attnt Document Control Desk washington, DC 20555 Reference Notice of Violation (NRC Inspection Report No. 70-824/90-01),
dated September 19, 1990.
Gentlemen he Babcock & Wilcox Company, Naval Nuclear Fuel Division Research Laboratory (IEFD-RL), is providing the attached reply to the referenced Notice of Violation in accordance with 10 CrR 20,201.
If you should have any further questions, please feel f ree to contact me.
Very truly yours, BABCOCK & WILCOX
//?
L. K. Trent Manager, safety & Safeguards jhc Attachment pct U.S. Nuclear Regulatory Commission Attnt Stewart Ebneter, Regional Administrator 101 Marietta Street, N.W.
Atlanta, GA 30323 9010250375 901019 PDR ADOCK 07000824
-C PDC rEo?
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REPLY 'IO A ICTICE OF VIOLATION is the Babcock & Wilcox Company, Naval Nuclear ruel The following response Division Research Laboratory's (!NPD-RL), reply to the Notice of Violation which was issued as part of Inspection Report No. 70-824/90-01.
Violation A The Licensee did not have records showing the receipt of two varian Model 02-001972-00, 8.0 millicurie Nickel-63 sealed sources, serial numbers 4602 and 4604, received pursuant to NRC Special Nuclear Material License No. 778 (SNM-778) on or about August 5, 1987.
1.
Admission or denial that the violation occurred:
We violation occurred as stated.
2.
% e reason for the violation if admitted
%ese sources were received as an integral part of analytical equipment that was transferred f rom another B&W division.
We sources were possessed by the other division under a General License.
No paperwork identifying the presence of internal radioactive material accompanied the equipment, and therefore it was never received as radioactive material.
3.
We corrective steps which have been taken and the results achieved:
We sources have been added to our sealed source inventory and were leak tested during the inspection.
The results of the leak tests showed no leakage of radioactive material.
4.
The corrective steps which will be taken to avoid further violations:
Procedure No. B-GP-3 will be revised to require workers to chech equipment being brought on site for the presence of radioactive materials in the form of a sealed source. his modification to the procedure will be accompanied by a notice to site workers of the change and the rationale behind it.
In addition to this, a copy of the shipping and receiving log will be reviewed by the Safety & Licensing section periodically to identify analytical equipment received by the Research Laboratory with potential for containing radioactive materials.
Wis equipment will then be examined to determine if any sealed sources are embedded and to allow for proper processing if necessary.
5.
We date when full compliance will be achieved:
NNTD-RL is now in full compliance.
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Violation B ne Licensee failed to perform leak tests within the required six month interval for (1) a californium-252 sealed source from August 19, 1986 through August 17, 1987, and (2) a Nickel-63 sealed source that was put into use on or about June, 1990, after having been in storage and not leak tested since August, 1987.
1.
Admission or denial that the violation occurred:
We violation occurred as stated.
2.
% e reason for the violation if admitted:
The Californium-252 source is seldom used.
Discussions with the individual performing the leak tests at that time indicated that the source was smeared i
xt the smear was never counted. %ey may have thought that the source was exempt since it was in storage.
%e situation concerning the Nickel-63 source is described above in response to Violation A.
Since it was not known that this source was on site, it was not leak tested.
3.
The corrective steps which have been taken and the results achieved:
Both sources were leak tested during the inspection and no leakage of radio-active material found.
4.
2 e corrective steps which will be taken to avoid further violations:
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The leak test procedure currently requires no formal review by an inde-pendent reviewer. Wis procedure will be revised to include a formal review which should aid in identifying any sources which may have been missed or have incomplete results.
5.
The data when full compliance will be achievedt NNFD-RL is currently in full compliance.
Violation C The Licensee failed to provide adequate label information for 63 55-gallon drums and 2 boxes of radioactive waste maintained on an outside storage area (OSA) pad to permit individuals working in the vicinity thereof to avoid or minimite exposure.
1.
Admission or denial that the violation occurred:
The violation occurred as stated.
2.
The reason for the violation if admitted:
he containers which resulted in the violation were scheduled for shipment and transferred to the OSA pad for pick-up. This shipment was postponed and proper storage labels were not applied to the containers. These containers are not normally labeled while an storage but are identified by a number.
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I Access to the normal storage areas for these containers is controlled is (locked) by the Health Physics Group for whom information on content readily available. H Wever, the area in question (OSA pad) was not locked.
3.
We corrective steps which have been taken and the results achieved:
We OSA was locked during the inspection. Also, the containers in question have been shipped.
Technical Procedure No. E-TP-87 has been revised to expand the routine surveying of this area to include all containers.
4.
We corrective steps which will be taken to avoid further violations:
We OSA will remain locked.
%e procedure for the area will be revised to require labeling of all containers per 10 CrR 20.203(f)(2). Special weather resistant labels have been ordered for this purpose.
5.
We date when full compliance will be achieved:
NNTD-E is currently in full compliance.
Violation D We safety Audit subcomittee (SAS) failed to follw written guidance for performing audits in accordance with Section 2.8.3 of the Application.
1.
Admission or denial that the violation occurred:
We violation occurred as stated.
2.
he reason for the violation if admitted:
Although some written guidance was available for the SAS to follw, this guidance was not formalized.
We SAs had therefore exercised flexibility during audits to ensure coverage of significant areas. he license require-ment to strictly follw this guidance was not readily apparent to the SAS.
3.
%e corrective steps which have been taken and the results achieved he written guidance available will be follwed by the SAS on its next audit scheduled to take place in late October or early November.
4.
%e corrective steps which will be taken to avoid further violations:
A formal procedure will be developed to provide guidance for the SAS to meet the requirements of Section 2.3.3.2 of the license by December 31, 1990.
S.
W e date when full compliance will be achieved:
rull conpliance will be achieved by December 31, 1990.
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Violation E Area Operating Procedures (AOPs) B-HC-16, Tuel Rod Handling, Revision (Rev.) 1 and B-HC-41, Handling Operations for the NLI 1/2 Spent ruel Shipping Cask, Rev.
1, tevised on or about December,1989, and latter used, were not approved during a wJsequent Safety Review Committee (SRC) meeting conducted in February,1990.
1.
Admission or denial that the violation occurred:
The violation occurred.
2.
ne reasons for the violation if admitted:
he two procedures were revised and brought before the SRC for review and approval in October, 1989. Due to meeting time constraints and size of the procedures, they were then tabled until the next SRC meeting in December.
At the December meeting, some changes were suggested but more information was desired before the SRC finished their review.
Between the December meeting and the next SRC meeting held in February, 1990, the procedures were modified per the December SRC coments, published as allowed :sf the license, and inadvertently omitted from the next SRC meeting agenda.
We oversight may have been due to the large volume of procedures handled by the SRC during this time frame.
3.
The corrective steps which have been taken and the results achieved:
The procedures were resubmitted at the next SRC meeting for approval.
his meeting took place in September and Procedure B-HC-16 was approved and B-HC-41 disapproved pending additional clarification and resubmittal to the Committee.
4.
%e corrective steps which will be taken to avoid further violations:
A procedure tracking system has been instituted which identifies procedures through the various approval stages which will flag revised procedures not yet approved by the SRC.
5.
%e date when full compliance will be achieved:
NNTD-RL will be in full compliance by December 31, 1990.
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