ML20155A143
| ML20155A143 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 03/26/1986 |
| From: | Hosey C, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20155A124 | List: |
| References | |
| 70-1201-86-01, 70-1201-86-1, NUDOCS 8604080240 | |
| Download: ML20155A143 (9) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION y
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REGION il y
y 101 MARIETTA STREET. N.W.
2 ATLANTA, GEORGI A 30323 49 *... *,o APR 011996 Report No.:
70-1201/86-01 Licensee:
Babcock and Wilcox Company Commercial Nuclear Fuel Plant Lynchburg, VA 24505 Docket No.:
70-1201 (CNFP)
License No.:
SNM-1168 Facility Name:
Commercial Nuclear Fuel Plant Inspection Conducted: Marc 10-14, 1986 Inspector:
1ma 3!Z sv 1
G. L. Troup s
Date Signed
. Approved by: h 3/lb [26 C. M. Hothr, Section Chief Date Signed Division of Radiation Safety and Safeguards SUMARY Scope:
This routine, unannounced inspection involved 31 inspector-hours onsite in the areas of radiation protection, solid radioactive waste management, transportation of radioactive materials, and review of previous inspection findings.
Results:
Of the areas inspected, no violations or deviations were identified.
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0604080240 860401 PDR ADOCK 0700 1
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2 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- R. A. Alto Plant Manager
- D. V. Ferree, Manager, Manufacturing
- D. W. Zeff, Manager, Operations Support
- J. T. Ford, Manager, Fuel Manufacturing
- K.
E. Shy, Health Physicist
- J. P. Watters, License and Control Administrator
- K. L. Harris, Section Manager, Inspection
- R. J. Flicker, Specialist, Quality Engineering Other licensee employees contacted included three technicians, two operators, and office personnel.
- Attended exit interview 2.
Exit Inter' view The inspection scope and findings were summarized on March 14, 1986, with those persons indicated in Paragraph 1 above.
Licensee management acknowledged the inspector's comments and observations and expressed no dissenting views.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters (Closed) VIO (70-1201/85-05-01) This violation concerned the iscuance of a respirator to an individual who had not been evaluated for respirator use by a physician for more than 12 months. The inspector reviewed and verified that the corrective actions as stated in the licensee's letter of August 16, 1985, had been completed and implemented.
4 (Closed) VIO (70-1201/85-05-02) This violation concerned the shipment of special nuclear material without verification that the receiver was authorized by license to receive the type, form, and quantity of material shipped. The inspector reviewed and verified that the corrective actions as stated in the licensee's letter of August 16, 1985, had been completed and implemented.
4.
Radiation Protection (83822) a.
Procedures
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The inspector reviewed the changes made to seven Health-Safety procedures (AS series) related to ractation protection. All revisions appeared to be consistent with the facility license and the regulations.
All revisions were reviewed ar.d approved as required.
3 No violations or deviations were identified.
b.
Instruments and Equipment During tours of 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 current calibration period. The inspector also checked certain instruments for adequate battery operation.
The inspector reviewed the calibration records for portable survey meters and for air samplers and verified that the calibrations had been performed at the specified interval and to the required accuracy. The inspector noted that many air samplers listed on the record sheets had not been calibrated.
The cognizant supervisor stated that with the changes in plant operations, these samplers had been removed.
He acknowledged that the record sheets were confusing and stated that the record sheets would be revised to include only those samplers presently
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installed. Action to revise the record sheets was initiated by the licensee during the inspection.
Ne violations or deviations were identified.
c.
External Exposure Controls 10 CFR 20.101 specifies the radiation dose standards,10 CFR 20.102 specifies the requirement for prior dose history, and 10 CFR 20.104 specifies the exposure limits for minors.
10 CFR 20.401(a) specifies the requirements for maintaining exposure records.
The inspector reviewed the couputer 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.
Although Procedure AS-1108, Fersonnel Monitoring, limits workers to 1,250 mrem per quarter, the exposure history for each individual is prepared en Form NRC-4.
The cognizant supervisor explained that some plant workers go to reactor sites to do work, and the Form NRC-4 nrovides a means to maintain a continuous exposure history.
The inspector reviewed the Form NRC-4 for six individuals, including two who had worked at reactor sites and verified that they were properly completed.
Procedure AS-1108 limits the exposure of minors to 10% of the regulatory limit, in accordar.ce with 10 CFR 20.104(a).
However, a licensee representative informed the inspector that the policy is not to hire minors on either a temporary or permanent basis.
The inspector observed that the personnel dosimetry devices and accident dosimatry were being utilized in accordance with the regulations and Section N,8.1 of the license application.
l No violations or deviations were identified.
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m.
4 d.
Internal Exposure 10 CFR 20.103(a)(1) and 10 CFR 20.203(a)(2) specify the limits for internal exposure to radicactive materla h.
10 CFR 20.103(a)(3) specifies the requirements for air sampling and bioassay to assess
' r.ternal expesures.
10 CFR 20.103D)(E) establishes the control measures and applicable evaluations t.v 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-brs. Through February, analysis results indicated that no individual exceeded the seven-day or quarterly exposare limits.
The inspector also reviewed two evaluations perfortred in hptember 1985, of possible exposures in excess of the control limits.
Neither evaluation showed that the individuals had exceeded ary limits.
The inspector verified that the licensee has established and implenented procedures for air sampling (AS-1103), bioassay (AS-1121) ard use of engineering controls (AS-1101).
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No violations or deviations were idsntified.
1 e.
Respiratory Protection 10 CFR 20.103(c) specifies the program requirements for u si r.g rnpiratory prr.tection eculpment to limit the inhalation of airborne radicactive materials.
Tne licensee has implemented the program through Procedure AS-1109, Respiratory Protection Program.
The licensee has also issued a management policy statement regarding the use of respiratory protection equipment.
The inspector reviewed the respirator issue log for 1986 and verified that the users were on the list of authorized users, had been trained in the use respirators, and had current medical clearances when the respirato s had been used.
The inspector also discussed with the resoonrlble personnel, factors such as air sample results, work permit requirements, selection, use of protection factors, fit testing, inspection, anc cleaning of respirators.
No violations or deviations were identified.
4 f.
Postir.g, Labeling, and Control 10 CFR 20.203 specifies the requirements for posting of areas or
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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 requirenent.
During tours of facility areas, the inspector observed that the postings of entrances, fences, and areas were in accordance with the requirements.
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5 30 CFR 19.11 requires that certain forms and documents be posted at the entrances to areas containing licensed materials.
The inspector verified that the materials were posted at the entrance us ed by plant personnel and in other plant areas.
No violations or deviations were identified.
g.
Surveys The inspector reviewed the plant radiation surveys for 1985, the
. contamination surveys for the period August - Cecember 1985, and the semi-annual radioactive source leak tests perforned in 1985.
The inspector also reviewed the air flow measurement tests for hoods and
" elephant trunks" performed during October - December 1985.
No violations or deviations were identified.
h.
Notifications and Reports 10 CFR 20 requires that certain notifications or written reports be submitted to the NRC:
10 CFR 20.402 - Theft or loss of licensed material 10 CFR 20.403 - Notification of incidents 10 CFR 20.405 - Overexposure 10 CFR 20.407 - Personnel monitoring reports 10 CFR 20.408 - Termination of employment Additionally, 10 CFR 19.13 requires that an exposure report be sent to the individual following termination of employment or work.
The inspector discussed the conditions or situations which would have required a report under 10 CFR 20.402, 20.403, or 20.405 with the cognizant licensee supervisors.
No instances were known to the licensee which would have required such reports.
The inspe: tor also reviewed the exposure report and the annual personnel monitoring report subnitted to the NRC (20.408).
No exposures were identified which would have required an overexposure or incident report.
The inspector also reviewed the records for five individuals who were listed as " terminated" and verified that the required reports bad been sent to the individual (19.13) and to the NRC (20.408).
No violations or deviations were identified.
5.
Radioactive Waste Management (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 i-for compaction and final packaging in Procedure AS-1111, Shipment and f
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6 Receipt of _ Radioactive Materials.
This procedure specifies the responsibilities of the various groups for operations, such as container inspection, packaging, surveying, and checks.
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.
A licensee representative informed the i-spector that no waste shipments to a burial site were made in 1985.
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. A licensee representative informed the inspector that the procedures and forms are available to make out the required manifests but no shipments had been made since the manifest system went into effect.
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.
No violations or deviations were identified.
e.
Tracking of Waste Shipments By review of the applicable waste and shipping procedures and discussions with the cognizant supervisor, 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 shipment was received and burial was accomplished. A similar tracking system is used to assure that shipments of scrap are received at the intended destination.
No violations or deviations were identified, j
7 g.
Disposal Site License Conditions The inspector reviewed Procedure AS-1111 and verified that it includes provisions for the verification that an intended receiver is authorized to receive the material to be shipped, including quantity and form.
The inspector also verified that the licensee has copies of the burial
. site disposal criteria and appropriate licenses (state and NRC).
The procedure includes the requirement to verify that the current license is on hand prior to any shipment.
No violations or deviations were identified.
G.
Transportation Activities (86740) 4 a.
Management Controls l
Depending on the type of materiel shipped (fuel assemblies, fuel pellets, scrap, etc.), different procedures apply for shipment.
However, the inspector determined that the procedures include the assignment of respecsibilities for accomplishing the various tasks (including inspections or overchecks) to different organization 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 (AS-XXX, QC-XXX, and MA-XXX series procedures).
No violations or deviations were identified.
b.
Quality Assurance Program 10 CFR 71.12 provides a general license to transport, or to deliver to a carrier for transport, licensec materials in packages for which a license or certificate of compliance has been issued, provided the licenswe has an approved quality assurance in accordance with 10 CFR 7}, Part H.
The thspector verified that ar. NRC-approved quality assurance program exists.
The licensee's program " Shipping Container Quality Assurance Program" was submitted to the NRC and was approved as of January 23, 1985 (expiration date January 31, 1990). Additionally, foci assembly Shipments and the inspection and repair of fuel assembly shipping containers are included in the licensee's program " Quality Assurance Manual f9r Commercial Nuclear Fuel Plant."
The insp9ctor also reviewed the QC-XXX series procecures which implement the requirements of the programs.
No violations or deviations were identified.
c.
Procurement and Selection of Packaging The 11censee has developed a nev container for shipping packages of fuel p'llets or uranium powder. The inspector verified that the design e
and qualification testing had beer submitted to the NRC and a
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Certificate of. Compliance (USA /9203AF) was. issued.
The licensee is listed as an authorized user for these coltainers.
As the licensee is fabricating the containers, the inspector verified that the licensee has approved procedures for the inspection of components made by other manufacturers, and for the assembly of the containers. Procedures also exist for the ir.spection of the containers-before loading and preparation for shipping.
Additionally, the licensee is preparing procedures for the inspection of the containers upon their return after use.
The inspector verified that Certificates of Compliance ala current for other 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.
49 CFR 171-178 and 10 CFR 71 contain restrictions or prohibitions on the shipment of licensed materials. The inspector verified that the licensee does not use Spec-55 containers, does not ship plutonium, and does not ship materials in liquid form or special form.
The licensee's approved procedures include the specification of the containers to be used for the shipment of licensed materials.
No violations or deviations were identified.
d.
Preparation of Packages s,
The inspector verified that approved procedures are provided for the preliminary and routine determinations of the acceptability of the packages (QC-948,QC-509,MA-470,MA-133). The procedures also specify the requirements for the preparation of the packages (including such items as torquing of fasteners, installation of accelerometers, etc.)
and routine maintenance.
Procedure AS-1111 provides for the radiation and contamination surveys, container marking and labeling, and the labeling of waste boxes.
For overseas shipment of materials, the procedure also includes the labeling requirements for the outer container. The procedures (AS-111 and QC-980) provide for records of preparation of packages.
No violations or deviations were identified.
e.
Delivery to Carriers A licensee representative informed the inspector that licensed materials are shipped by exclusive use vehicles or a " limited quantity" shipments by mail. Procedures are used to assure that the required shipping paper documentation is provided to the driver, including the instructions to the driver regarding accidents, maintenance of the load and emergency telephone numbers.
The driver is required to sign the instruction sheet to document that he is aware of the requirements.
9 The inspector reviewed records of past shipments and verified that none of the shipments in the past year qualified as " highway route controlled quantities" or required advance notification to states.
No violations or deviations were identified, f.
Shipment During the inspection, the licensee mace a shipment of licensed materials.
The inspector observed that the transport container was labeled as required and tamperseals were installed.
Records included in the documentation package include a signed copy of the instructions to the driver, shipping forms (including the shipper's certification, radioactive materials shipp.ing form, a certificate of competent authority, and the QC inspection checklist).
Records also indicated that the consignee had been informed of the estimate date of shipment and arrival.
No violations or de.iations were identified.
7.
Information Notices (92703)
The inspector reviewed two IE Information Notices with the cognizant supervisor.
The inspector determined that the licensee had received the notices. had reviewed them, and had taken action, as appropriate and necessary.
Notices reviewed were:
a.
84-24: Physical Qualification of Individuals to Use Respiratory Protective Devices b.
84-40:
Emergency Worker Doses
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