ML20151K964
| ML20151K964 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 07/22/1988 |
| From: | Hosey C, Lauer M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151K947 | List: |
| References | |
| 70-0824-88-06, 70-824-88-6, NUDOCS 8808030325 | |
| Download: ML20151K964 (7) | |
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SO C80 UNITED STATES
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101 MARIETTA STREET,N.W.
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Report No.:
70-824/88-06 Licensee: Babcock and Wilcox Company Lynchburg Research Center Lynchburg, VA 24505 Docket No.:
70-824 License No.
SNM-778' Facility Name: Lynchburg Research Center Inspection Conducted: June 13-16, 1988 Inspector:
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"L N M. T. Laubr Date Signed Approved by:
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/!h/M C. M. Hofef>, SectipnChief Date Signed Division of Radiation Safety and Safeguards
SUMMARY
Scope: This routina, unannounced inspection of the Radiation Protection Program was conducted in the areas of radiation protection instruments and equipment, staffing, external exposures, internal exposures, surveys, radioactive waste management, transportation, follow-up on previnus inspector identified items, and Information Notices.
Results: The licensee maintained their previous level of performance in the areas inspected.
No significant improvements or degradations of the Radiation Protection Program were observed.
The program appeared adequate to accomplish its' safety objectives.
No violations or deviations were identified.
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,-..L REPORT DETAILS 1.
Pers.ns Contacted
- R. Bennett, Manager, Safety and Licensing J. Henderson, Senior Research Engineer
- A. Olsen, Senior License Administrator
- S. Schilthelm, Supervisor, Health and Safety
- L. Trent, Manager, Regulatory Relations Other licensee employees contacted included engineers, technicians, and office personnel.
- Attended Exit Interview 2.
Radiation Protection (33822) a.
Instruments and Equipment Stetion 3.2.3.1.2 of License No. SNM-778 specifies that portable survey instruments be calibrated semiannually.
The inspector observed that portable survey instruments in use or available for use were operable and calibrated as required.
Licensee procedure LRC-TP-342, Rev. O, July 30, 1987, Calibration of Eberline RM-3A for detection of alpha or beta contamination requires that RM-A survey instruments be calibrated annually.
On May 25, 1988 the inspector observed that a RM-3A, being used for cot.tamination surveys of washed laundry was due for calibration on April 29, 1988.
Through discussions with the licensee and review of' Instrument Service Logs, the inspector determined that the instrument had been calibrated before the April 29,1988-due date but the new calibration sticker had not been placed on the instrument.
The inspector noted to licensee representatives that timely updating of calibration stickers after calibration is essential to a quality instrument program.
Licensee representatives stated that they are currently collecting fiscal and technical informatior. on state-of-the-art portal monitors and will eventually purchase one.
The inspector selectively reviewed calibration data for several self-reading pocket dosimeters (SR0s) and verified that they met the twenty-four hour drift limit, 10% of delivered dose limit for response, and the six-month calibration frequency raquirement as delineated by licensee procedure RL-TP-48, Rev.1, April 13,1988, l
Calibration Procedure for Pocka Dosimeters.
l The licensee claims a protection factor (PF) of 1000 for supplied-air hoods.
10 CFR Part 20, Appendix A, footnote H allows a PF of 1000 provided tested-and-certified suppliea-air hoods are used, a minimum L
2 air flow of six cubic feet per minute is maintained, and calibrated airline pressure gauges or flow measuring devices are used.
The inspector verified that all of the above conditions had been met.
No violations or deviations were identified.
b.
Steffing Section 2.5 and figure 2-1 of License No. SNM-778 delineates organizational and personnel education and experience requirements.
The inspector reviewed current staffing levels.
Licensee representatives stated that the Senior Health Physics Engineer recently filled the open position of supervisor, Health and Safety.
Applicants for the Senior Health Physics Engineer position were currently being interviewed.
No violations or deviations were identified.
c.
External 10 CFR 20.101 specifies radiation dose standards for individuals in restricted areas.
The inspector reviewed the current Exposure Summary Report which included individual quarterly exposure data, year-to-date (YTD) exposure data through May 1988, and June 1988, exposure data-taken from SRD only.. All exposures were within NRC limits.
The highest YTD cumulative individual exposure through June 1988 (film badge data through May~1988 plus June 1988 SRD data) was 1270 mrem.
The inspect r reviewed personnel contamination reports (PCR) for 1988.
Approximately 15 reports were written.
Licensee representatives stated that they did not have guidance covering action limits or events which lead to the initiation of PCRs but rather initiation of a PCR is at the discretion of the HP staff and vperational supervisory personnel.
However, included in the ongoing Radiction Protection Pragram formalization project, discussed in Paragraoh 4, it the development of a procedure which will delineate such guidelines.
No violations or deviations were identified.
d.
Internal Exposures The licensee is required by 10 CFR 20.103, 20.104, and 20.201(b) to control intakes of radioactive material, assess such intakes and maintain records.
The inspectc. reviewed breathing zone (BZ) air sample results from May 23, 1988 through April 4,1988, used to assign maximum permissible concentration-hours (MPC-br) to individuals.
The highest observed sample result for alpha (based on Pu-239(1) MPC of a.0x10-11 uCi/ml) was 0.13 MPC-hrs, for beta (based on an unidentified beta / gamma emitting isotope limit of 3x10-9 uCi/ml) was 0.38 MPC-hrs.
Licensee representatives stated that no worker has
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3 exceeded the seven day 40 MPC-hour control measure specified in 10 CFR 20.103(b)(2) since the last inspection.
Stationary air sample results were also reviewed with no significant levels observed.
However, licensee representatives stated that they do not assume these air samples to be representative of the air breathed by the worker and are not used to assign MPC-hrs.
Section 3.2.2.1 of License.No. SNM-778 requires that air flows within Building B.be in the direction of highest potential for airborne radioactive material and that these flows be checked monthly.
The inspector reviewed the air flow surveys for May 1988, and verified that proper air flow directions existed.
The inspector reviewed licensee procedure - RL-TP-247, Rev. O, December 20, 1987, Implementation and Quality Assurance of the NNFD-RL Bioassay Program, which specifies sampling frequency and action limit criteria for results.
The most recent semi-annual in-vivo (lung count) results, as reported in a vendor supplied report dated April 22, 1988, was reviewed by the inspector.
No action limits were exceeded with the highest result being 2.1% of the maximum permissible body burden of Cc-60.
Vendor supplied in-vitro (urinalysis) results for 19873 were also reviewed. All results were less than the lower limit of detection (LLD) uf 5 ug/l for Uranium The inspector verified that selected individuals listed on the respirator issue log were properly trained and medically qualified to wear respiratorc as required by 10 CFR 20.103(c)(2).
No violations or deviations were identified, e.
Posting, Labeling, and Surveys 10 CFR 20.203 specifies 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 give an alternate posting requirement.
The inspector selectively reviewed plant radiation surveys for 1988 and verified through observation that the required controls and postings for specified radiation levels were in place.
Specifically, the Building J yard area with dose rates in excess of 100 mrem / hour was locked and posted as a high radiation area.
During a plant tour the inspector observed that the Eberline RM-3A survey instrument used to survey anti-C clothing was reading 1000 counts per minute (CPM), presumably duc to a high radiation background, while posted guidance for laundry release for reuse included a release limit of less than 500 CPM for shoe scuffs. Also, some release limits specified in the posted g i danc' were unclear as to whether the limit was a not count (backgrc and subtracted) or a gross count (included background).
Licensee representatives stated
that formalized procedures and release limits are planned but not completed, but that the high background count rate on the laundry monitor and the ambiguity in the guidance will be corrected.
The inspector informed licensee representatives that this issue would be reviewed during subsequent inspections.
We are tracking completion of corrective action as Inspector Followup Item (IFI) 70-824/88-06-01.
No violations or deviations were identified.
3.
RadioactiveWasteManagement(84850,88035) 10 CFR 20.311 require that a licensee who transfers radioactive waste to a land disposal facility prepare all waste so that the waste is classified in accordance with 10 CFR 61.55 and meets the waste characteristic requirements of 10 CFR 61.56.
It further establishes specific requirements for conducting a quality control program and for maintaining a manifest tracking system for all shipments.
Licensee representatives stated that no quality control program is currently in place to ensure compliance with 10 CFR 61.55 and 10 CFR 61.56 and that no waste shipments have taken place this year.
The licensee stated that approximately 4,000 cubic feet of low level waste was being stored onsite and that a contractor was in the process of determining an appropriate method to characterize and classify the waste.
Once this determination is made a quality control program will be developed and low level waste shipments will commence.
No violations or deviations were identified.
4.
TransportationActivities(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 regulations appropriate to the mode of transport of 00T in 49 CFR Parts 170 through 189.
The licensee provided the inspector with documentation supporting the determination that D0T 7A packages used, comply with specification 7A packaging design requirements delineated in 49 CFR 178.350.
The inspector reviewed the following radioactive macerial shipments for proper package labeling, radiation monitoring, and shipping paper documentation:
B&W, NNFO-RL to US Ecology Shipment No. YCE-VAT-27 dated December 2, 1987.
3.0x10-4 millicuries of uranium and plutonium waste. Class C waste.
B&W, NNFD-RL to B&W, ARC, RM No. 3895 dated April 29, 1988.
1.07x10-7 curies of contaminated oil, t
5 B&W, NNFD-RL to Ontario Hydro RM No. 3866, dated March 31, 1988.
10 millicuries of Co-60 on a two inch "feeder pipe".
10 CFR 71.12 provides a general license 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, Subpart H.
The inspector determined that the licensees Quality Assurance Program for Radioactive Material Packages, No. 0230 Rev. 5 was approved by the NRC on March 4,1988.
The inspector verified that internal audits were being performed as required by the Program.
The inspector also verified that before each use of any package the licensee performed the required routine determinations and quality control checks as specified by 10 CFR 71.87, Subpart H.
Licensee representatives stated that personnel with transportation responsibilities recently completed formal training courses on the transportation of radioactive material.
No violations or deviations were identified.
4.
Action on Previous Inspection Findings (92701)
(Closed) IF1 70-824/88-01-01, Complete formalization of radiation protection program.
Specifically, completion of Step 5 to prioritize procedures to be modified and developed and to establish a completion date for these procedure modification / developments.
The inspector reviewed a March 14, 1988 memo from the Health and Safety Supervisor and the Senior License Administrator to the Safety and Licensing Manager which documented completion of Step 5 and established January 1,1989, as the completion date for modification or development of all priority 1 procedures.
To date approximately 20% of all priority 1 procedures are complete.
Licensee representatives stated taat the January 1,1989 completion date may require modification due to recent staffing changes but that the NRC would be informed of any changes.
The inspector informed licensee representatives that completion of priority 1 procedures would be reviewed during subsequent inspections.
We are tracking completion of the specified action as IF1 70-824/88-06-02.
5.
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, reviewed it's contents, and taken action, as appropriate and necessary.
. n?'
6 IN 88-08 Chemical Reactions With Radioactive Waste Solidification Agents.
6.
Exit Interview I,
The inspection scope and findings were summarized on June 16. 1988, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
The licensee did not. identify as proprietary any of the material provided to or reviewed-by the inspector during this inspection.
Dissenting comments were not received from the licensee.
Item Number Description and Reference 1
70-824/88-06-01 IFI - Review corrective action for high background count rate on laundry monitor and clarification of laundry release limits, Paragraph 1.
76-824/88-06-02 IFI - Complete modification /
development of priority 1 procedures, Paragraph 4.
l License management was informed that the IFl discus 3ed in Paragraph 4 was considered closed.
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