ML20151K136

Insp Rept 70-1201/88-08 on 880613-15.No Violations or Deviations Noted.Major Areas Inspected:Radiation Protection Program,Including Exposure Controls,Staffing,Radwaste Mgt, Transportation & Followup on Previous Enforcement Issues

ML20151K136
Person / Time
Site:	07001201
Issue date:	07/18/1988
From:	Hosey C, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151K115	List: ML20151K110 ML20151K136
References
70-1201-88-08, 70-1201-88-8, IEIN-88-008, IEIN-88-8, NUDOCS 8808030131
Download: ML20151K136 (5)

Text

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'JUL2V NO Report No.: 70-1201/88-08 Licensee: Babcock and Wilcox Company Commercial Nuclear Fuel Plant Lynchburg, VA 24505 Docket No.: 70-1201(CNFP) License No.: SNM-1168 Facility Name: Comercial Nuclear Fuel Plant Inspection Conducted: June 13-15, 1988 Inspector: /8<- M < f #/rF K. T. Lauer ( tate' Signed Approved by: K7W //

C. M. Hoset, Sectior Chief Date Signed Division of Radiati(n Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection of ~ the Radiation . Protection Program was conducted in the areas of exposure controls, staffing, radioactive waste management, transportation, followup on previous enforcement issues and inspector identified items, and Information Notices.

Results: The areas inspected were observed to be adequate for the limited amount of work currently involving radioactive material. No violations or deviations were identified.

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7 REPORT DETAILS

1. Licensee Employees Contacted

• R. Alto, Plant Manager

• W. Engelke, Manager, Quality and Safety G. Lindsey, Health and Safety Leader

• K. Shy, Health Physicist

• J. Watters, License and Control Administrator

• Attended exit interview

2. Radiation Protection (83822)

a. Internal Exposure 10 CFR 20.103(a) specifies limits for internal exposure to radioactive material and requirements for air sampling and bioassay.

10 CFR 20.103(b) specifies methods and procedures to limit internal exposure.

The inspector reviewed vendor supplied performance data for in-vivo (lung counts) and in-vitro (urinalysis) analyses used by the licensee. Lung counts are performed on mobile equipment which periodically visits the site. Urine samples are sent offsite. The in-vivo lung counting lower limit of detection (LLD) equals approximately 1-3 milligrams (mg) of depleted uranium and 30-60 micrograms (ug) of U-235. The detector uses two 5-inch diameter "phoswhich" detectors mounted on a lead shielded bed. The excreta bicassay LLDs for uranium are as follows:

Urine Radiometric = 0.5 dpm/ liter Urine Fluorometric = 5 ug/ liter Fecal Radiometric less than 2 dpm/ gram Fecal Fluorometric = 2 ug/ void (approx.10 grams)

Sampling frequencies are based on Regulatory Guide 8.11, 1974.

Frequencies and bioassay action lirits are delineated in Licensee Procedure AS-1121, Uranium Bioassay Program, Rev. 8, February 11, 1988. The inspector reviewed urine and lung count results on selected individuals covering their entire employment history at this facility. Few values were above the specified LLDs with no results observed which approached or exceeded the licensee's action limits.

During walk throughs of the plant the inspector observed that the area within the plant having the greatest potential for airborne contamination, specifically, the Pellet Loading Area, was within a containment structure and maintained at a negative pressure relative

2 to the surrounding area. In the Pellet Loading. Area the inspector observed the placement of stationary air samplers and work place ventilation structures. Licensee representatives stated that only air purifying respirators are used for non-emergency respiratory protection. Licensee representatives also stated that, year-to-date, approximately two to three RWPs have been written which required the use of respirators. During discussions with the licensee, the inspector determined that lapel air samplers are used to assign maximum permissible concentration hour (MPC-hr) values for individuals wearing respirators. During routine operations, when respirators are not employed, stationary air sample results are used to assign MPC-brs.

Approximately 10% of all stationary air sample results are verified for representativeness using lapel air samplers. The inspector reviewed lesson plans for the licensee's respiratory protection training and established that training topics were appropriate and commensurate with those specified in 10 CFR 20.103(c)(3).

Licensee procedure AS-1105, Surface Contamination Control, Rev.13, December 11, 1987, dictates a contamination action limit of 5,000 dpm/100cm2 for radiation control zones (RCZ). At the time of the inspection the only two RCZs at the facility were the Pellet Loading Area and the ECHO 330 Building. The inspector reviewed selected surveys of the ECHO 330 Building for 1988. Using a check source, the inspector established that the frisker at the entrance / exit control point for the Pellet Loading Area was working properly and alarming at 100 counts per minute above background.

No violations or deviations were identified.

b. Staff The inspector reviewed the licensee's organizational structure and staff, and staff stability. The inspector verified that current Health and Safety staff consists of one Health Physicist, one Health and Safety leader, and two Health and Safety monitors as specified by Section II, Part 5.1 of the application for License SNM-1168. l Management commitment to maintaining the staff's technical conpetence was evident in that continuing education initiatives, both fonnal and informal, existed for all of the Health and Safety staff.

No violations or deviations were identified.

c. AuditsSection V, Part 6.6 of the application for License SNM-1168 requires that independent audits of health physics activities and responsibilities be conducted on a quarterly frequency. The )

inspector verified that audits were being conducted at the required frequency. The inspector reviewed External Health Physics Audits l HS-88-2 dated May 26, 1988, and HS-87-01 dated April 13, 1987. The l

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3 inspector established that the audits were performed by personnel technically qualified in radiological safety, the appropriate level of management review existed, and that findings and deficiencies were addressed.

No violations or deviations were identified.

3. Radioactive Waste Management (84850) and Transpc' ation (86740)

Licensee representatives stated that a radioactive waste shipment has not occurred since September 1987. The September 1987 shipment was previously inspected in Report No. 88-01. A shipment may be made the end of August, 1988. Licensee representatives stated that approximately 435 cubic feet of Class A unstable waste is currently being stored on site awaiting shipment.

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

10 CFR 71.12 provides a general license to transport, or to deliver to a carrier for transport, licensed material 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, Subpart H. The inspector reviewed the following shipments and verified that package quality cont.ol checklists were completed, where applicable, 4 and that shipping manifest were completed in accordance with D0T regulations.

Shipment No. YNJ-YLJ-102, March 3, 1988.

Shipment No. YNJ-YLJ-103, April 14, 1988.

Shipment No. YNJ-YLJ-104, April 28,1988.

No violations or deviations were identified.

4. Licensee Action On Previous Enforcement Matters (92702)

(Closed) Violation 70-1201/88-01-01, Failure to assure radiation levels to unrestricted areas were less than 100 millirem in seven consecutive days.

The inspector reviewed the licensee's response of March 28, 1988. In that response the licensee committed to the installation of a physical barrier (fence) to increase the distance of the restricted area boundary from the suspected source of radiation, specifically, the ECHO 330 Building. The inspector verified that the fence was installed and properly posted. A review of weekly surveys of the restricted area boundary from January 7, 1988 to June 13, 1988, indicated a maximum of .5 millirem / hour. With the occurrence of this radiation level the licensee increased the distance of the boundary from the ECHO 330 Building. On June 13, 1988, the weekly survey indicated that radiation levels were 0.17 to 0.15 millirem / hour at the boundry.

4

5. Action On Previous Inspection Findings (92701)

(Closed) IFI 70-1201/87-02-16, Performing annual medical examinations for fire brigade members including pulmonary and electrocardiogram (EKG) testing. Licensee representatives stated that those individuals who are assigned to the fire brigade are given medical exams annually. During these exams the physician has the option to perform pulmonary and EKG tests at his discretion based on the individuals age, medical history, etc.

6. Information Notices (92717)

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

IN 88-08 Chemical Reactions With Radioactive Waste Solidification Agents.

7. Exit Interview The inspection scope and findings were summarized on June 15, 1988, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed the inspection findings with licensee representatives. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

Dissenting comments were not received from the licensee.

Licensee management was informed that the Enfercement Matter discussed in Paragraph 4 and the Inspector Followup item discussed in Paragraph 5 were considered closed.

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