ML20134M541
| ML20134M541 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 08/16/1985 |
| From: | Alto R BABCOCK & WILCOX CO. |
| To: | Stohr P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8509040169 | |
| Download: ML20134M541 (5) | |
Text
P Babcock & Wilcox MEhw a McDermott company P.O. Box 11646 Lynchburg, VA 24506-1646 05 AUG20 AIO : 10 m4) 522.wm August 16, 1985 i
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United States Nuclear Regulatory Commission Region II 101 Marietta Street, NW Suite 3100 Atlanta, GA. 30303 ATTENTION:
Mr. Philip Stohr, Director, Division of Radiation Safety and Safeguards
REFERENCES:
(1)
SNM-1168 Docket 70-1201
,(2)
Inspection Report No. 7.0-1201/85-05 Gentlemen:
This letter addresses the findings noted in Inspection Report No.
70-1201/85-05.
The inspection was performed by Mr. R. Albright of your office on June 11 - 14.
1985.
VIOLATION:
1.
10 CFR 20.103 (c) (2) requires that a determination be made by a physician, prior to the initial use of respirators and at least every 12 months thereafter, that an individual is physically able to use the respiratory protective equipment if the licensee makes allowance for the use of equipment in estimating exposures of the individual to airborne radioactive material.
Contrary to the above, allowance for the use of a respirator was made for an individual and more than 12 months had passed since the individual had been evaluated for respirator use by a physician, in that an individual was last evaluated by a physician on October 23, 1983, and allowance was made for the individual's use of the respirator in estimating his exposure to airborne radioactive material on February 13, March 7, 8 and 9, 1985.
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r United States Nuclear l August 16, 1985^
Regulatory Commission
RESPONSE
Admission or Denial of the Alleged Violation 1.
We acknowledge the validity of the-facts contained in the notice of violation.
2.
Reasons for Violation Our respiratory protection program does not permit radiation workers to don their own respiratory protection.
When respiratory protection is required, a health physics technician selects the appropriate respirator, aids the employee in donning the device, and performs a leak test to assure a proper fitting.
A list of. qualified operators is maintained-at the Health.
Physics Technician's work station.
Prior to fitting an employee with a respirator, the technician refers to this list to assure the employee is qualified.
i The circumstances surrounding this incident are as follows:
James Tweedy has' bean qualified to wear respiratory protection devices for several. years.
It was
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recognized that James was~due for requalification and.was, y scheduled for a respiratory protection physical.
A few days prior to his appoi'ntment he became ill.and was hospitalized.
The list c'f qualified operators was
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updated, removing-James Tweedy's name from the list.
However, for the-first time, CHARLES TWEEDY'S name was added.
The. Health Physics Technician, in reviewing the list saw the name Tweedy;and assumed it was James.
3.
Corrective Steps Taken and Results Achieved On June 13, 1985, James Tweedy was reexamined by b; physician and was requalified for respirator use..
4.
Corrective Steps Which Have Been Taken to Avoid
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Further Violation
'g The Health Safety 0..oup has been reinstructed to review?
the person's entire name when checking the list'of /#
employees. authorized to wear respiratory prote'etive devices.
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United States Nuclear August 16, 1985 VIOLATION:
2.
10 CFR 70.42 requires that prior to transferring special nuclear material to another licensee, the transferring licensee verify that the receiver's license authorizes
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receipt of the type, form, and quantity of special nuclear material to be transferred.
Contrary to the above, the requirement to verify prior to shipment of special nuclear material that the receiving licensee was authorized by license to receive the type, form, and quantity of special nuclear material (SNM) to be shipped was not met, in that, on September 24, 1984, and December 12, 1984, shipments of SNM were made to License SNM-145 held by a B&W facility in Apollo, Pennsylvania, and the transferor had not verified that the receiver could receive the type, form, and quantity of SNM to be shipped.
RESPONSE
1.
Admission or Denial of the Alleged Violation The facts as stated in the inspection report are correct except that the document used to verify the authority of Apollo to receive the material was a certificate consistent with 10 CFR 70.42 (d) (2) received in 1977.
2.
Reason for Violation The violation occurred because the responsible CNFP personnel considered the certificate in hand appropriate satisfaction of the regulation as provided for in 10 CFR 70.42 (d) (2).
The certificate was dated October 7, 1974 and bears the notation of having been received 8/13/77 (enclosed is' a copy of the certificate providing the transferee's authorization to receive nuclear material, and specifying type, form, quantity, license number, issuing agency, and expiration date).
j At the time of the shipments noted in the inspection j
report, the Apollo Facilities and the CNFP were and still are part of the same B&W operating department (Nuclear Fuel Services of the Nuclear Power Division).
As a result, CNFP has regular contact with responsible persons c'
from the Apollo operation, and are aware of the facility status.
The viability of that awareness was borne out by Region I having affirmed that Apollo indeed was authorized to receive the material involved.
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l United States Nuclear August 16, 1985 Regulatory Commission The fact that the license had no expiration date led the CNFP person to feel the document continued to be in full force.
3.
Corrective Steps Taken and Results Achieved Shipments to Apollo have been discontinued until a current document verifying the authority to receive is obtained, and Apollo has been requested to provide the necessary document.
We have reviewed the status of documentation for others to whom we ship, and established that, in all other cases, an expiration date for the license has been reported, or we are requesting new documents.
4.
Corrective steps which will be taken to avoid further violation The procedure for Radioactive Materials shipments will be revised to provide for periodic (prior to expiration) reverification of authority to receive nuclear materials.
Date when full compliance will be achieved.
Full compliance has already been achieved.
The information contained herein is true and correct to the best of our knowledge and belief.
Sincerely, R. A. Alto
O O.
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' ATTACHMENT 1
/.,
. LICENSE CERTIFICATI0fl
,r (Special Nuclear Materials)
This is to certify that Nuclear Materials and Equipment Corporation
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(NUMEC) located in Apollo, Pennsylvania and Park.s hip. Pennsylvania, is authorized to possess the following Special Nuclear. Materials:
Quantity Type Form Enrichment (Kgs) location
. License flo. Sf!M-145
?
Uranium All f,orms
> 5%
2,000 Apollo, Pa.
- All forms
$ 5%
115,000 Apollo, Pa.
R&D all enrichments
. Apollo, Pa.
License No. Sf!M-414 Pu and/or Uranium All forms
.:) 5%
2,000 Parks Twp.
(Leechburg,Pa.)
233 U
All forms 4
238Pu Scaled Sources
.06 238Pu Metal-or oxide
.06 35 0
In storage i 5%
223,000
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The authority to possess these materials. is derived from the U.S. Atomic En Commission under Special f;uclear Material License flumber Sf;M-145 for Apollo,ercy
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Pennsylvania' and Sf;M-414 for Parks Township, Pennsylvania. There are no emiration dates for License SUM-145 or SNM-414.
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Signed Scott L. G'arrett Title Manaaer. Marketina A riaterials Mgm.
Date. October 7,1974 9
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