ML20148F676

Insp Rept 70-0824/88-01 on 880203-05.No Violations & Deviations Noted.Major Areas Inspected:Areas of Radiation Protection,Solid Waste Mgt,Transportation of Radioactive Matls,Followup on Previous Enforcement Issues

ML20148F676
Person / Time
Site:	07000824
Issue date:	03/07/1988
From:	Collins T, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20148F668	List: ML20148F662 ML20148F676
References
70-0824-88-01, 70-824-88-1, IEIN-87-031, IEIN-87-31, NUDOCS 8803280258
Download: ML20148F676 (8)

Text

,

pa atoog y* t UNITED STATES g ,je NUCLEAR REGULATORY COMMISSION REGION 11 o,

g ,,,,, [ 101 MARIETTA ST., N.W.

ATLANTA, GEORGIA 30323 MAR 101988 Report No.: 70-824/88-01 Licensee: Babcock and Wilcox Company Lynchburg Research Center l Lynchburg, VA 24505 '

Docket No.: 70-824 License No.: SNM-778' -

Facility Name: B&W NNFD Research Laboratory Inspection Conducted: February 3-5, 1988 l Inspector: '7W 1 / 7 / 28 T. R. Collins l Date Signed  :

Accompanying Personnel: 'A. W. Grella j Approved by: !C h 3!7 b2 C. M. Hosey, Section Chief- Date Signed Division of Radi'ation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection was conducted in the areas of (

radiation protection, solid waste management, transportation of radioactive '

materials, followup on previous enforcement issues and inspector identified items, and IE Information Notices. j Results: No violations or deviations were identified.

4 i

8 l

8803280258 880310 PDR ADOCK 07000824 C DCD

b REPORT DETAILS

1. Licensee Employees Contacted

• R. Bennett, Manager 3 Safety and Licensing T. Grochowski, Health Physics Engineer D. Harris, Health Physics Technician '

• A. Olsen, Senior Licensing Administrator

• S. Schilthelm, Supervisor, Health and Safety

• L. Trent, Manager, Regulatory Relations

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on February 5,1988, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. On March 2,1988, during a telephone conversation between G. L. Troup of our staff and A. Olsen of your staff, a commitment wss mada to complete Step 5 of the formalization of the Radiation Protection Program by March 23, 1988 (see Paragraph 4.1). At this time a date will be established to complete the final step (6) of the Radiation Protection Program. It is our understanding that when the final date is established  !

the NRC Region 11 Office will be notified. No dissenting comments were '

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

3. Licensee Action on Previous Enforcement Matters (Closed) Violation (70-824/86-06-02) Failure to perform followup actions of urinary plutonium levels as required by Appendix A of the License Application. The inspector reviewed the licensee's response dated 3 February 19, 1987, and verified that the corrective action specified in the response had been implemented.

(Closed) Deviation (70-824/87-01-02) Failure to meet a commitment date to formalire the radiation protection program. The inspector reviewed the licensee's response of August 20, 1987, and verifted that the corrective action specified in the response had been implemented.

4. Radiation Protection (83822)

a. Internal Exposure Control The licensee is required by 10 CFR 20.103, 20.201(b) and 20.104 to control intakes of radioactive material, assess such intakes and maintain records. During plant tours, the inspector observed the use j

2 -

.i of ventilation systems and containment enclosures and discussed the l use of this equipment with radiation protection personnel.

The inspector reviewed the Maximum Permissible Concentration '

(MPC)-hour logbook for 1987, which contained the MPC-hour entries accumulated by all radiation workers. In all cases, the respiratory ,

protective device used had been supplied air hoods and a protection factor of 1,000 had been taken. All MPC-hours assignments for -

< workers were found to be less than the 40-hour control measure specified in 10 CFR 20.103(b)(2). All MPC-hour assignments had been made from breathing zone (lapel) air sample measurements.

The inspector also reviewed the results of selected fixed air  !

samplers from January to December 1987. In all cases, fixed air sample results showed average concentrations (filters changed weekly) '

of less than ten percent of MPC which compared favorably with the breathing zone (lapel) air sample results.

No violations or deviations were identified,

b. Posting of Notices a 10 CFR 19.11 requires posting of Fonn NRC-3, the license and other i pertinent information. If posting of a document is not practicable,  ;

the licensee is permitted to post a notice which describes the '

document and states where it may be examined. During tours of the facility, the inspector verified that entrances to and from areas where licensed activities were conducted, were posted with the required documents or a notice describing the document and where it may be examined. The inspector verified that the documents were I available for review at the location specified by the posting. l l

No violations or deviations were identified, j

c. External Exposure Control a

10 CFR 20.101 specifies the applicable dose standards. The inspector reviewed records of personnel radiation exposures for 1987, and verified that the radiation doses recorded for plant personnel were i within the quarterly exposure limits of 10 CFR 20.101. All J individual exposure results reviewed were less than 1,250 millirem 1 per calendar quarter. The total man-rem exposure for 1987 has not yet been determined, however, the total exposure for 1986 was 17.8 man-rem as measured by TLD.

3 No violations or deviations were identified.

d. Radiation Work Permits (RWPs)

Appendix A, Section 6 of the License Application requires the preparation of RWPs for operations or maintenance work not covered by

-, . ~ _ - . _ _ -

__ ~ _ , , - _ _ _ _ - _ . - ,

3 an area operating procedure and which involves entry into a system containing special nuclear material or where a potential for release of contamination exists.

The inspector reviewed selected RWPs written for the facility hot i cell operations in 1987, and verified that adequate controls had been specified for the work. Also, the inspector observed a tasx in which  !

the licensee was exposing a TV camera to a desired radiation exposure level using a 100 curie Cesium-137 source. The inspector concluded that the RWP issued for this task was adequate and verified that the controls specified on the RWP were performed. The inspector also performed independent radiation surveys of the area to assure proper posting and controls were in place to warn personnel of unexpected radiation levels.

No violations or deviations were identified.

e. Surveys and Monitoring l 1

10 CFR 20.201(b) requires each licensee to make or cause to be made I such surveys as may be necessary for the licensee to comply with the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. I The inspector reviewed selected records of special and routine radiation and contamination surveys performed during the period of January to December 1987, and _ verified that survey requirements  !

specified by the License were met. l No violations or deviations were identified.

f. Posting, Labeling and Control 10 CFR 20.203 specifies the posting and labeling requirements for  !

areas and containers. During tours of the facility, the inspector performed independent surveys in the controlled areas and determined that areas and containers were posted and labeled as required.

No violations or deviations were identified,

g. Instruments and Equipment Appendix A Section A.9.2.5 of the License Application specifies radiation protection instrumentation and calibration frequency. The inspector observed that the required type and quantity of instruments were available, and found them operable and calibrated as required as evidenced by calibration labels and records. The licensee calibrates certain portable survey instruments and the others are sent to a vendor for calibration.

4 The inspector reviewed the following calibration procedures:

LRC-TP-49, Calibration Procedures fer Eberline R0-3A/RO-3C, Nuclear Chicago Cutie-Pie /Victoreen Cutie-Pie, Revision 4 January 14, 1987 LRC-TP-51 Calibration Procedure for ' PAC-4G Gas Proportional Counter, May 30, 1984 LRC-TP-53, Calibration Procedure for Eberline RM-3A and RM-14 and RM-15, Revision 0, November 1977-No violations or deviations were identified,

h. Whole Body Counting (Invivo)

The inspector reviewed the licensee's procedure LRC-TP-247 Employee Invivo Bioassay for Uranium, Plutonium and Byproduct Materials. The licensee's invivo counting of personnel is required twice each year by a vendor. The inspector reviewed the results of the last whole body counts performed during October 1987. All detected activity was well within regulatory limits, and was generally at the lower limit of detection (LLD) of the whole body counting system. The lower limit of detection for the vendor's whole body counting system for certain radionuclides are listed as follows:

Isotope LLD Zinc-65 5.7 nanocuries Technetium-99m 1.2 nanocuries Cesium-134 2.4 nanocuries Cesium-137 2.7 nanocuries Uranium 2.54 nanocuries No violations or deviations were identified,

i. Formalization of the Radiation Protection Program B&W NNFD Research Laboratory stated in a letter to the USNRC Region II dated February 19, 1987, that a formalization of the Radiation Protection Program would be completed in a six-phase program, Phase 1 to be ccmpleted by April 1, 1987, and Phase 2 to be completed by June 15, 1987. The following describes the six-phase program:

(1) Define the program elements.

(2) Identify the regulations, license requirements and technical guidance that apply to each element.

e 5

(3) Prepare a program plan that combines the results of 1 and 2 above.

(4) Compare the existing procedural controls with those indicated in 3 above.

(5) Set the priorities for taking the necessary actions as indicated in 4 above.

(6) Develop the procedural controls indicated in Step 5.

The inspector verified that Steps 1 and 2 were completed. However, Step 2 was not completed until August 3,1987, which did not meet the i comitment date of June 15, 1987. The NRC issued a Notice of Deviation in NRC Report No. 70-824/87-01, dated July 22, 1987, for failure to meet the commitment date to complete Phase 2 of the formalization of the Radiation Protection Program. t During this inspection the inspector verified that Steps 3 and 4 were completed by January 14, 1988. However, no commitment was made to i complete the final 2 steps (5 and 6) of the formalization of the  ;

Radiation Protection Program. During a telephone conversation on March 2,1988, as described in the exit interview paragraph, a commitment was made to complete Step 5 by March 23, 1988. At this  ;

time a date would be established to complete the final step (6) of the Radiation Protection Program. The inspector informed licensee  !

representatives that this issue would be an inspector followup item and would be reviewed during subsequent inspections i (70-824/88-01-01). I i

i

, No violations or deviations were identified.

5. Solid Radioactive Waste (84850 and 88035)

10 CFR 20.311 stipulates the requirements for control of transfer of i radioactive waste intended for disposal at a land disposal facility.

These requirements include classification and characterization of the waste and a quality control (00) program to ensure compliance with j 10 CFR 61.55 and 61.56, 1

Through discussion with licensee representatives, the inspector became i aware that a QC program to meet the requirements of 10 CFR 20.311(d)(3) was still under review as identified in a previous NRC Inspection Report l No. 70-824/87-01. The licensee has not made any waste shipments for .

burial since the previous inspection and does not plan to make any future i

) shipments until a formal QC program has been developed and approved to l j assure compliance with waste classification and characterization i requirements specified in 10 CFR 61.55 and 10 CFR 61.56. The inspector l l informed licensee management representatives that this item would remain  !

, open until a formal QC Program has been denloped.

)

No violations or deviations were identified.

I

c 6

6. Transportation (86740) 10 CFR 71.5(a) requires that each licensee who transports licensed material outside~ the confines of its plant or other place of use comply with the applicable requirements of the Department of Transportation in 49 CFR Parts 170 through 189.

The inspector reviewed the records of selected radioactive material shipments made during 1987 and found that the requirements of 49 CFR 170-189 had been met.

The licensee accumulates, receives, and ships a broad range of types and forms of materials, ranging from irradiated fuel assemblies for hot-cell  ;

examination ano hot-cell wastes, to various other radioactive items associated with the R&D programs. The hot-cell waste is the most significant waste generated and is transferred to DOE for disposal. There  :

have been no shipments of Class A wastes to low level waste burial .

facilities during 1987. . The QC procedures for such shipments are currently being updated, in anticipation of a shipment. Several shipments [

of stabilized. Class C waste (due to transuranic content) using a  ;

certified HIC /overpack package had been made to Richland, WA in 1987.

The inspector reviewed the following radioactive material procedures:  ;

LRC-TP-237, Shipment Preparation for Waste to US Ecology Site in [

Washington j LRC-TP-238 Shipment Preparation for Waste to Chem Nuclear Systems, l Inc.

i LRC-TP-293, Procedure for Use of Type B Shipping Containers i i

No violations or deviations were identified.  !

l

7. InspectorFollowupItems(IFIs)(92701) l (Closed) IFI (70-824/87-01-01) Performing source checks of portable survey instruments. The inspector reviewed procedure RL-TP-344 Performance of the Health Physics Daily Operational Checklist and concluded that the licensee had incorporated the requirement to source check all personnel contamination survey instruments on a daily basis to ensure that these I instruments are responding correctly.

8. IE Information Notices (IENs) (92717)

The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to J

~

7 appropriate personnel and that action, as appropriate, was taken or scheduled.

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

,