ML20140G737

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Forwards Formal Safety Questions & Comments Re Vendor 851116 Application for Renewal of License SNM-778,per 860312-14 Site Visit.Response & Comments Requested by 860430
ML20140G737
Person / Time
Site: 07000824
Issue date: 03/27/1986
From: Ketzlach N
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Olsen A
BABCOCK & WILCOX CO.
References
NUDOCS 8604030298
Download: ML20140G737 (9)
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MAR 2 71986 FCUP:NK 70-824 SNM-778 Babcock & Wilcox Research and Development Division Lynchburg Research Center ATTN: Mr. A. F. Olsen Senior License Administrator P.O. Box 11165 Lynchburg, VA 24506-1165 Gentlemen:

Enclosed are the formal safety questions and coments related to the Lynchburg Research Center renewal application for License No. SNM-778, dated November 16, 1985, and its supplement dated February 25, 1986. These questions and comments have been discussed with members of your staff during our visit on March 12-14, 1986. Responses to all the questions and comments should be in writing and included as page changes to your application.

To maintain the review schedule, your response to the enclosed questions and conrients should be received by us no later than April 30, 1986. Should you have any questions, please call Mr. Norman Ketzlach of my staff (301-427-4510).

Please inform us as soon as possible whether or not you expect to meet the time schedule for your response.

Sinc 6ffl Y.m suncil'F Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS l

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Enclosure:

Request for additional information DISTRIBUTION w/ encl.

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MAR 2 71996 COMMENTS ON B&W LYNCHBURG RESEARCH CENTER SNM-778 LICENSE RENEWAL APPLICATION I. General Comments

1. The licensee should incorporate all the applicable license conditions that were imposed at the time of the last renewal and in subsequent amendments. Justification should be provided for any conditions not incorporated.
2. The license conditions section should contain a commitment that approved written procedures shall be established for all operations in which SNM, source, and byproduct materials are stored or handled. All pro-cedures shall include those controls and limits significant to the nuclear criticality and radiation safety of the operation as well as procedures for the nuclear criticality and radiation safety activities.

These procedures shall be followed for all related activities.

II. Specific Comments

1. Page 1-1, Section 1.2 Provide figures ir the license conditions section showing (1) site loca-tion, (2) plant. boundaries, and (3) facility locations (including liquid waste hold-up tanks and all other areas where licensed activities are to be conducted).
2. Page 1-2, Section 1.4 Confirm the >20 percent enrichment items are 220 percent.
3. Page 1-3, Section 1.5.2 Confirm any offsite possession and use of SNM, source, or byproduct mate-rials shall be the responsibility of and under the control of LRC health physics personnel (response to comment should be placed in Chapter 3.0,

" Radiation Protection").

4. Page 1-4, Section 1.6.10 Confirm the source used to calibrate an instrument shall be traceable to an NBS Standard.
5. Page 1-4, Section 1.7.1 The types of authorized activities should be more specific (e.g., hot cell examinations of irradiated materials, analytical; research, and development activities for other companies or B&W divisions including laboratory analy-sis, preparation of and testing of materials and equipment; preparation and 1
  • + - - - -- -~w- - - - - - - - s .- . e -- - - --=

MAR 2 71986 modification of radiation sources; and preparation and decontamination of reactor related hardware for inspecting, evaluati .g, and measuring reactor components at utility sites). Research and development is too broad.

6. Pages 1-4 and -5, Sections 1.7.2-1.7.4 Clarify the disposition of licensed material pursuant to the regulations in 10 CFR 20 and 61.
7. Page 1-5, Sections 1.8.1.1 and 1.8.1.2
a. Provide technical justification for exempting an employee from the bioassay requirement based on absence when the " bioassay counting service is onsite."
b. Provide technical justification for eliminating the analysis for uranium where both Pu and U are present in the air when the Super-visor Health and Safety decides "Pu is more sensitive."
8. Pages 2-1 thru -3, Sections 2.2.4, 2.2.6, 2.2.9, and 2.3 Clarify the reviews of the procedures, RWPs and changes thereto made by the Facility Supervisor, the Supervisor, Health and Safety, the Nuclear Safety Officer, and Safety Review Committee (SRC) include their concur-rence.
9. Page 2-2, Section 2.2.6 Confirm the Supervisor, Health and Safety, has the authority to stop any operation that he believes is contrary to accepted safety practices or license requirements (see Section 11.2.2).
10. Page 2-3, Section 2.3.1
a. Confirm the SRC shall review all SAS audit findings, all overexposures, and unusual occurrences which must be reported to the LRC.
b. State the frequency of these reviews and the means of reporting the results of the reviews.
11. Page 2-3, Section 2.3.1.5 I

Confirm that all operations utilizing licensed material shall be performed in accordance with approved written procedures,

12. Pages 2-3 and -8, Sections 2.3.3.3 and 2.8.3.1, respectively
a. Confirm the SAS Committee audit program is distributed over a 12-month period.
b. Confirm the audits are made in accordance with written guidance to assure all aspects of Section 2.3.3.2 are audited.

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MAR 2 7 1985

13. Page 2-3, Section 2.3.3.4 Specify the minimum qualifications of the SRC and SAS members.
14. Page 2-4, Section 2.5.3 Confirm Managers of Sections handling licensed materials shall have demon-strated knowledge of the application of radiation and nuclear criticality safety requirements relative to their projects.
15. Page 2-4, Section 2.5.4 Specify the type of experience (e.g., in the storage, use, and handling of licensed material) that the degreed Facility Supervisor must have to meet the minimum qualifications when his position depends on having a

" degree in his related field."

- 16. Page 2-5, Section 2.5 Specify the minimum qualifications for the License Administrator (see Section 2.2.10).

17. Page 2-6, Section 2.7 Confirm that all operations with licensed material shall be conducted in accordance with SRC approved operating procedures or RWPs.
18. Page 2-7, Sections 2.8.1 and 2.8.2
a. Specify the minimum frequency for making routine inspections for compliance with the nuclear criticality safety aspects of the operations, by whom made, and to whom the findings are reported,
b. Specify the minimum frequency for making routine inspections for compliance with the health physics aspects of the operations, by whom made, and to whom the findings are reported.
19. Page 2-8, Section 2.8.3.1 a.

Confirm all members of the SRC receive copies of the audit reports.

b. Confirm the annual audit of the Health and Safety Group is performed by a qualified individual (s) who is (are) independent of the Health and Safety Group.
20. Page 2-10, Section 2.10.2 Confirm the safety evaluation of the related process operation as well as the nuclear criticality safety calculations is retained for at least 6 months after termination of the approved process operation.
21. Page 3-1, Section 3.1.1 Please specify that the RWPs shall be reviewed weekly for the adequacy of radiation protection controls.

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MAR 2 7 t935

22. Page 3-1, Section 3.1.2.2 Delete Section 3.1.2.2 as its content is covered by Section 3.1.2.3.
23. Page 3-2, Section 3.2.1
a. Since High Radiation and Airborne Radioactivity Areas are defined in the regulations, we suggest that Subsections 3.2.1.1 and 3.2.1.3 be simplified by stating entry into a High Radiation Area or an Airborne Radioactivity Area shall be controlled by an RWP.
b. Subsection 3.2.1.2 should be deleted. The posting and control of access to Radiation Areas is covered by the regulations.
24. Page 3-2, Section 3.2.1.4 This section on contaminated areas should be modified to include the following:
a. The requirement for protective clothing in the areas.
b. The requirement of the Health and Safety Group approval for an individ-ual who is found to be contaminated above background radiation levels to leave a contaminated area.
25. Page 3-3, Section 3.2.2.6 Confirm that non-stack releases are also monitored for gaseous effluent.
26. Page 3-4, Section 3.2.2.12 Confirm the HEPA filters are tested annually or after they are changed, whichever comes sooner.
27. Pages 3-4 and -5, Section 3.2.3
a. This section should be modified deleting the name of the manufacturer.

This would allow you to change instruments to that of another manufac-turer without NRC approval provided the instrument meets the other specifications.

b. Specify the type of radiation (e.g., p, y, a, q) to be detected by each of the instruments.
28. Page 3-6, Section 3.2.3.4.1 Specify the calibration and test frequency for the criticality monitors.
29. Page 3-8, Section 3.2.4.3 Include a program for fission product detection in your bioassay program.

Regulatory Guide 8.26, " Application of Bioassay for Fission and Activation Products," may be used in establishing this program.

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MAR 2 7 ngg

30. Page 3-8, Section 3.2.4.3.1
a. In the demonstration section, provide your technical justification for the action levels related to the results of your urinalysis.
b. Specify consistent units for the action levels for the uranium concentration in the urinalysis samples (compare your action levels in those sections with those in Table 12-6 (pp. 12-17)).
31. Page 3-10, Section 3.2.4.3.2 In the demonstration section, provide your technical justification for your 1.6E-8 Ci action level.
32. Page 3-11, Section 3.2.4.6
a. Confirm the surface contamination survey shall include monitoring for gamma radiation.
b. Specify the minimum frequency for gamma contamination surveys and the contamination levels when corrective action will be taken.
33. Page 3-12, Section 3.2.4.6.1 Provide justification for bimonthly surveys in the Hot Cells and Cask Handling areas when operations are being performed in these areas.
34. Page 3-13, Section 3.2.4.8 Identify the Radiological Contingency Plan with the renewal license application (e.g., specify current license condition).
35. Page 3-13, Section 3.2.4.9 Provide in the demonstration section, examples when the extremity or supplemental badges will be used.
36. Page 4-1, Section 4.1.2 Specify the function responsible for determining the structural integrity of equipment when it is necessary to provide assurance of nuclear criti-cality safety.
37. Page 4-1, Section 4.1.4
a. Define a unit.
b. Specify the positions approving the posting of nuclear criticality safety limits.
38. Page 4-1, Section 4.1.6
a. Confirm the written operating procedures include all the controls and limits significant to the nuclear criticality safety of the operation.

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MAR 2 71986

b. Confirm the Nuclear Safety Officer, in his audits, verifies that process conditions have not been altered that may affect nuclear criticality safety.
39. Page 4-4, Section 4.2.3.6.1.1 Specify the requirement for validation of the calculational methods used for nuclear criticality safety evaluation. Include accounting for bias in the results of calculations, selection of appropriate cross-section sets, safety margins used, and preparation of a report which contains the items specified in Section 4.3.6 of ANSI /ANS-8.1-1983,

" Nuclear Criticality Safety in Operations with Fissionable Materials Outside Reactors."

40. Page 5-2, Section 5.1.4.4 Include the following in a demonstration section:

Manufacturer's name of equipment.

41. Page 6-1 Discuss, in a general way, the types of activities performed (e.g., hot cell examination, analytical services, repair and decontamination of B&W equip-ment, and kinds of Research and Development). "Research and Development" is too general.
42. Pages 7-1 and -2, Sections 7.1.4 and 7.1.6 Confirm the decontamination of facilities and equipment is in accordance with Condition 12 in your present SNM license (namely Annex C dated November 1976).
43. Page 7-2, Section 7.1.5 Specify the action to be taken if contamination is found at a depth of 1/8-inch.
44. Page 7-2, Section 7.2.1 Provide an update confirming Babcock and Wilcox's continued assurance of its ability to cover the costs of decommissioning the facilities (e.g.,

most recent letter from L. V. Jordan, Assistant Controller, dated September 16, 1985).

45. Page 8-1, Section 8.0 Incorporate the content of Condition 13, Amendment No. 6, dated February 28, 1984, in this section. Identify the LRC as the licensee.
46. Page 10-4, Section 10.4.1.1 Provide Figure 10-6, 6

MAR 2 71906

47. Page 10-5, Section 10.4.2 Describe the method (s) for monitoring containment and its frequency.
48. Page 10-8, Section 10.5.2
a. Provide evidence of insurability by submitting a copy of your Certificate of Nuclear Energy Liability Insurance (facility form).
b. Provide a copy of a recent insurance inspection report.
49. Pages 10-10 through 10-14 Provide figures large enough to be legible (e.g., large enough so that visual aids are not necessary to interpret pertinent items of information).
50. Page 11-4, Section 11.2.7 Confirm the audit report of the Nuclear Safety Officer includes a review of corrective actions recommended during previous audits and that the actions have been taken.
51. Page 11-17, Section 11.4.1 Confirm that all operations with licensed material shall be conducted in accordance with SRC approved operating procedures (same as comment on Section 2.7).
52. Page 12 3, Section 12.3.1 Please correct your reference to the regulations for external radiation exposure. It should be 10 CFR 20.101.
53. Page 12-15, Section 12.8.1.2 Provide your technical justification for the action levels related to the results of your urinalysis (see comment on Section 3.2.4.3.1).
54. Page 12-15, Section 12.8.1.3 Same comment as on Section 12.8.1.2.
55. Page 12-18, Section 12.8.1.4 Include a program for fission product detection in your bioassay program.

Regulatory Guide 8.26, " Application of Bioassay for Fission and Activation Products," may be used in establishing this program (same comment as on Section 3.2.4.3).

56. Page 12-21, Section 12.8.5.1 Confirm the Supervisor, Health and Safety Group, shall evaluate and approve any delays on decontamination work that are longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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MAR 2 71986 .

57. Page 12-23, Section 12.8.5.2 Confirm that approval of the Health and Safety Group shall be required to allow any individual to leave a contaminated area who is contaminated
  • above background radiation levels (same comment as on Section 3.2.1.4(b)).
58. Page 12-24, Section 12.8.5.3 The criteria for release of equipment and packages for unrestricted use will be a license condition.
59. Page 12-26, Section 12.10.1 t

Provide the report of occupational exposure for the past 2 years indicat-ing the number of individuals whose total whole body exposures fall in each specified exposure range.

60. Page 12-37, Section 12.11 Revise this section to specifically describe the measures taken by you to reduce the radiation exposure to the employees and the public. The fol-lowing are two examples of the information required:
a. An ALARA review of the operation or facility design prior to startup is a measure of implementing ALARA.
b. Action taken as a result of reviewing the employees' exposure trends and the effluent release data which tend to reduce the employees' exposure and effluent release or other measures of implementing ALARA.
61. Pages 13-1 and -2
a. Specify the location of sampling points and monitoring stations (on maps or plot plans).
b. Provide the results of your environmental sampling data (radiological and non-radiological) around the plant (e.g., surface water, ground- -

water, air, soil, and vegetation) for the past 2 years, i

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