ML20148F619

Insp Rept 70-1201/88-01 on 880201-03.Violation Noted.Major Areas Inspected:Areas of Radiation Protection Program,Solid Radwaste Mgt,Transportation of Radioactive Matls & IE Info Notices

ML20148F619
Person / Time
Site:	07001201
Issue date:	03/08/1988
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20148F586	List: ML20148F584 ML20148F602 ML20148F619
References
70-1201-88-01, 70-1201-88-1, IEIN-87-031, IEIN-87-31, NUDOCS 8803280237
Download: ML20148F619 (8)

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e NUCLEAR REGULATORY CCMMISSION REGION 11

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e.,,, ATLANTA, GECRGIA 30323 Report No.: 70-1201/88-01 MAR 0 81988 Licensee: B&W Fuel Company Commercial Nuclear Fuel Plant Lynchburg, VA 24505 1 1

Docket No.: 70-1201 License No. SNM-1168.

Facility Name: B&W CNFP Inspection Conducted: February 1-3, 1988  :

Inspector: 2/ J' 8'T T."R. Coliins Date Signed Accompanying Personnel: )A. W. Grella Approved by. C%

C. M. Hosey, Secttpn Chief 3/7 / li Date Signed Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routir.c, unannounced inspection was conducted in the areas of radiation protection program, solid radioactive waste management, ,

transportation of radicactive materials and IE Information Notices.

Results: One violation was identified - radiation levels in an unrestricted area in excess of NRC limits.

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8803280237 880308 PDR ADOCK 07001201 C DCD

2 REPORT DETAILS'

1. Licensee Employeee. Contacted

• R. Alto, Plant Manager

• W. Engelke, Manager 3 Quality and Safety D. Ferree, Manager, Manufacturing

• T. Ford, Manager, Fuel Manufacturing

• R. Penoza, Manager, Field Operations

• P Watters, License and Control Administrator

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on February 3 -1988, with those persons indicated in Paragraph l' above. A viciation for failure to limit radiation levels in an unrestricted area to the extent that an individual, if continuously present, would receive a radiation i dose that would be less than 100 millirem in seven consecutive day: l (Paragraph 4.c) was discussed in detail. No dissenting comments were ,

received from the licensee. The licensee did not identify as proprietary I any of the material provided to or reviewed by the inspector during this inspection.  !

3. Licensee Action on Previous Enforcement Matters j This subject was not addressed in the inspection.

4. Radiation Protection (83822)

, a. Procedures 4

The inspector reviewed changes made to Health and Safety procedures (AS series) as related to radiation protection. All revisions appeared to be consistent with the facility license and the regulations. All revisions were reviewed and approved as required.

I No violations or deviations were identified.  !

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b. Instruments and Equipment I During tours of the areas of the facility, the inspector observed the radiation protection instrumentation in use or available for use.

The inspector verified that all of the instruments were in the 3

current calibration period. The inspector also checked certain

instruments for adequate battery operations and response check.

4 The inspector reviewed the calibration records for various beta / gamma portable survey instruments and PAC-4G alpha survey instruments and l

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verified ttat the calibrations had been performed at the specified intervals and to the required accuracy.

No violations or deviations were identified.

c. -External Exposure Controls 10 CFR 20.101 specifies the radiation dose standards. 10 CFR 20.105 specifies the permissible radiation levels in unrestricted areas. [

The inspector reviewed the computer printout of external exposures (which serves as the Form NRC-5 equivalent) and verified that no individuals had exceeded either the regulatory or plant administrative limits.

10 CFR 20.105(b)(2) states that no licensee shall possess, use, or transfer licensed material in such a manner as to create in any unrestricted area from radioactive material suc .other sources of '

radiation in his possession radiation bets which, if an individual were continuously present in the ar-A, could result in his receiving i a dose in excess of 100 millirems in any seven consecutive days.

During tours of the facility, the inspector independently performed '

radiation surveys to determine if radiation levels in 10 CFR 20.105  ;

the unrestricted area were less than the limits specified in '

10 CFR 20.105. On February 3, 1987, the inspector determined that-the radiation levels in the unrestricted area in the vicinity of Building ECH0-330 were up to 0.7 millirem per hour (mR/hr), as measured by the licensee. This radiation level is equivalent to  ;

117.6 millirem in seven consecutive days. The inspector reviewed the previous survey of this area perfonned on January 28, 1988, which  ;

indicated that the radiation levels in the unrestricted area were up  :

to 0.4 mR/hr or less than 100 millirem in seven consecutive days.  !

However, the 0.7 mR/hr measurement found on February 3, 1988, indicated that the radiation exposure levels to the unrestricted area from January 28, 1988 to February 3, 1988 was 100.8 millirem in six i consecutive days which would have been in excess of 100 millirem if an individual remained in the area for seven consecutive days. After ,

further interviews and discussion with licensee representatives the  !

inspector determined that licensee personnel had previously entered Building ECH0-330, to perform clean up activities. During this task ultrasonic test (UT) equipment used to detect fuel leakers at reactor sites was moved to the south wall of the building which caused  ;

the radiation levels to exceed the unrestricted area limits. The  :

maximum radiation levels on contact with the UT equipment, as measured by the licensee, was 120 millirem per hour. Discussions with the licensee indicated that the UT equipment wou'd have remained in the storage area undisturbed for the seven day perlod. Failure to assure that radiation levels in an unrestricted area were such that an individual, if continuously present, would not receive a radiation

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dose in excess of 100 millirem was identified as an apparent violationof10CFR20.105(b)(2)(70-1201/88-01-01).

The inspector also determined that the licensee had identified on December 3,1987, the dose rates to the unrestricted area in the vicinity of Building ECH0-330 to be up to 1.0 mR/hr or 168 millirem in seven consecutive days. On December 9,1987, the licensee corrected the problem and reduced the radiation levels to the-unrestricted area to 0.4 mR/hr or 67.2 millirem in seven consecutive days. After further interviews and discussion with licensee representatives the inspector determined that the licensee cleaned (deconned) the UT equipment to reduce the radiation levels. Health physics personnel resurveyed the area outside Building ECH0-330 after decontamination of the UT equipment and the radiation levels still remained above the limits as stated in 10 CFR 20.105. On December 9, 1987, health physics personnel notified licensee management that the actions taken to reduce the radiation levels to the unrestricted area were not adequate and requested the UT equipment to be moved to the north end of the building. This was performed on December 9, 1987.

However, from December 3,1987, to December 9,1987, the radiation levels were measured to be 144 millirem in six consecutive days.

Since the corrective action taken by the licensee failed to prevent a recurrence of the violation, credit for licensee identified was not given, 10 CFR 2 Appendix C states that the NRC will not normally issue a Notice of Violation for a violation that was identified by the licensee if it fits in Severity Level IV or V, was reported if required, it was or will be corrected and was not a violation that could reasonably have been prevented by the licensee's corrective action for a previous violation. This second example of radiation levels greater than 10 CFR 20.105(b)(a) limit, although identified by the licensee, was identified as another example of an apparent violation.(70-1201/88-01-01).

d. Internal Exposure Controls 10 CFR 20.103(a)(1) and 10 CFR 20.103(a)(2) specify the limits for internal exposure control to radioactive materiais.

10 CFR 20.103(a)(3) specifies the requirements for air samplino and bioassay to assess internal exposures. 10 CFR 20.103(b)(2) establishes the control measures and applicable evaluation to control internal exposures.

The inspector reviewed the computer printout of the evaluation of potential exposures based on daily air sample results. The program evaluates daily, seven-day and quarterly exposures in MPC-hours. >

During 1987, analysis results indicated that no individual exceeded the seven-day or quarterly exposure limits.

The inspector verified that the licensee has established and implemented procedures for air sampling (AS-1103), bioassay (AS-1121) and use of engineering controls (AS-1101).

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No violations or deviations were identified.

e. Respiratory Protection 10 CFR 20.103(c) specifies the program requirements for using respiratory protection equipment to limit the inhalation of airborne radioactive materials. The licensee has implemented - the program through Procedure AS-1109, Respiratory Protection Program.

The inspector reviewed the respiratory issue log for 1987 and verified that the users were on the list of authorized users, had been trained in the use of respirators, and had current medical clearances when the respirator had been used.

No violations or deviations were identified,

f. Posting, Labeling and Control 10 CFR 20.203 specifies the requirements for posting of areas or containers based on radiation levels or the presence of radioactive materials. License Condition 16 provides an exemption to the labeling of containers specified in 10 CFR 20.203(f) and gives an  !

alternate posting requirement. During tours of the facility, the inspector observed that the postings of entrances, fences, and areas were in accordance with the requirements.

10 CFR 19.11 requires that certain forms and documents be posted at I the entrances to areas containing licensed materials. The inspector i verified that the materials were posted at the entrances used by '

plant personnel and in other plant areas.

No violations or deviations were identified.

g. Surveys The inspector selectively reviewed the plant radiation surveys and contamination surveys for 1987 and the semi-annual radioactive source leak tests performed in 1987.

i No violations or deviations were identified. ,

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5. RadioactiveWasteManagement(84850,88035)

a. Management Controls The licensee has established procedures for the packaging and shipping of radioactive solid wastes and radioactive scrap which is transferred for compaction and final packaging in Procedure AS-1111, Shipment and Receipt of Radioactive Materials. This procedure specifies the responsibilities of the various groups for operations, l such as container inspection, packaging, surveying, and checks. I U

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l) 6 Procedure AS-1110, Waste Control, also assigns responsibilities by organizational entity.

No violations or deviations were identified,

b. Quality Control Procedure AS-1111 includes inspections and audits of waste package contents to assure that the contents conform to burial site requirements, reviews of the closure, marking, etc., as well as a final audit of the shipment package.

The licensee made only one waste _ shipment for burial during 1987.

The inspector reviewed the Radwaste Shipping Records for the one waste shipment made on September ~23, 1997, and concluded that all'the requirements of AS-1111 were met.

No violations or deviations were identified,

c. Waste Manifests 10 CFR 20.311(b) and (c) require that a manifest system be used for all shipments of waste to a broker or licensed burial facility. The inspector verified that procedures and forms are available to make out the required manifests. The inspector also verified that the waste manifest was appropriately made out for the one waste shipment made during 1987.

No violations or deviations were identified.

d. Waste Classification, Characterization, and Labeling 10 CFR 61.55 requires that waste be classified and identified as Class A, B, or C. Procedure AS-1111 includes the classification of waste and identification of wastes in accordance with 10 CFR 61.55.

The licensee only ships Class A waste for burial.

No violations or deviations were identified,

e. Tracking of Waste Shipments By review of one waste shipment and the applicable waste and shipping procedures and discussions with licensee representatives, the inspector verified that the licensee has a program in place for sending manifests to the burial site and for tracking the shipment to assure that the shipment was received and burial was accomplished.

No violations or deviations were identified.

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6. Transportation Activities (86740)

a. Management Controls Depending on the type of material shipped (fuel assemblies, fuel pellets, etc.), different procedures apply for shipment. However, the inspector. determined that the procedures include the assignment

- of responsibilities for accomplishing -the various tasks '(including inspections and overchecks) t'o different organizational entities.

Procedures included in the preparation for shipment and receipt of materials and empty containers were reviewed and verified to include the designation of responsibilities.

No violations or deviations were identified.

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b. Quality Assurance Program 10 CFR 71.12 provides a general licensee to transport, or to deliver to a carrier for transport, licensed materials in packages for which a license or certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR 71, Part H.

The inspector verified that an NRC-approved quality assurance program exists. The licensee's program "Shipping Container Quality Assurance Program" was approved by the NRC and has an expiration date of January 31, 1990.

No violations or deviations were identified,

c. Procurement and Selection of Packaging ,

The inspector verified that Certificates of Compliance are current for containers used for the shipment of fuel pellets, and fuel  !

assembly shipping containers, and the licensee is registered as an '

authorized user for these containers. 1 No violations or deviations were identified.

d. Preparation of Packages The inspector verified that approved proceoures are provided for the preliminary and routine determination of the acceptability of the packages. The procedures also specify the requirements for the preparation of the packages and routine maintenance.

Procedure AS-1111 provides for the radiation and contamination surveys, container marking and labeling, and the labeling of waste boxes.

No violations or deviations were identified.

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7. Information Notices (92717)

The inspector reviewed the following IE Information Notice (IEN) with licensee management representatives. The inspector determined that the licensee had received the notice, had reviewed it, and taken action, as appropriate and necessary.

IEN 87-31: Blocking, Bracing and Securing of Radioactive Materials Packages in Transportation L

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