ML20198E736

Insp Rept 70-0824/85-07 on 851007-11.Violations Noted: Failure to Control Access to High Radiation,To Calibr Breathing Air Supply Pressure Gauges & to Perform Beta Radiation Surveys During Personnel Entries Into Hot Cell

ML20198E736
Person / Time
Site:	07000824
Issue date:	10/28/1985
From:	Cooper W, Hosey C, Weddington R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198E719	List: ML20198E713 ML20198E721 ML20198E736
References
70-0824-85-07, 70-824-85-7, NUDOCS 8511140150
Download: ML20198E736 (2)

Text

UNITED STATES f* pa KEcoq'o NUCLEAR REGULATORY COMMISSION y '

o REGION ll 3* j 101 MARIETTA STREET. N.W.

t ATLANTA. GEORGI A 30323

/ NOV 0 41985 Report No.: 70-824/85-07 Licensee: Babcock and Wilcox Company Lynchburg Research Center Lynchburg, VA 2/305 Docket No.: 70-824 License No. SNM-778 Facility Name: Lynchburg Research Center Inspection Conducted: October 7-11, 1985 Inspectors: /bh.//! M M

.Weddingtonf

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R. Date Signed Alu' /2 29 W W. T. Cooper. // Da e Signed Approved by: M h C. M. Hose 9, Section Chief

/d[M/j 5 Date Signed Division of Radiat on Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 62 inspector-hours onsite in the areas of radiation protection program and followup on IE Information Notices.

Results: Three violations were identified: (1) failure to control access to a high radiation area, (2) failure to calibrate breathing air supply pressure gauges and (3) failure to perform beta radiation surveys during entries of personnel into the hot cell.

8511140150 851104 PDR C ADOCM 07000824 PDR

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REPORT DETAILS i 1. Persons Contacted Licensee Employees

• A. E. Wehrmeister, Manager, System Development Laboratory "R. Bennett, Manager, Safety and Licensing

*A. F. Olsen, Senior License Administrator J. W. Cure, III, Supervisor, Health and Safety G. Hoovler, Manager, Decommissioning S. Pennington, Health Physics Engineer H. Beasley, Chemist Other licensee employees contacted included a foreman and two technicians.

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• Attended exit interview

! 2. Exit Interview The inspection scope and findings were summarized on October 11, 1985, with those persons indicated in paragraph I above. The following issues were discussed in detail: (1) an apparent violation for failure to control an access to a high radiation area (paragraph 4.f), (2) an apparent violation for failure to calibrate breathing air supply pressure gauges (paragraph 4.e) and (3) an apparent violation for failure to perform beta radiation surveys during entries of personnel into the hot cell (paragraph 4.h). The licensee acknowledged the inspection findings and took no exceptions. 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 (92702)

(Closed) Violation 70-824/85-05-01 Failure to package a shipment of LSA radioactive material in a 00T Specification 7A Type A package or a strong tight package. The inspector reviewed and verified the corrective actions as stated in the licensee's letter of August 28, 1985.

(Closed) Violation 70-824/85-05-03 Failure to comply with disposal site criteria for radioactive waste container classification labeling. The inspector reviewed and verified the corrective actions as stated in the licensee's letter of August 28, 1985.

4. Radiation Protection (83822)  !

a. Radiation Protection Procedures  !

l Appendix A.6.2.5 of the license application required that general 1 health physics procedures shall be established, maintained and followed

3 for all operations involving the processing, handling and storage of licensed material.

Appendix A.6 of the license application required that work involving the use of licensed material that is not covered by an approved written procedure shall be performed pursuant to a Radiation Work Permit (RWP).

The inspector reviewed selected licensee health physics procedures and verified that any changes made to tnose procedures since the last inspection were consistent with applicable regulations and license requirements. Through discusdogs. with licensee representatives and review of selected records, the inspector verified that RWP's had been established for radiological work performed during the calendar year not covered by an approved written procedure.

No violations or deviations were identified,

b. Instruments and Equipment Appendix A, paragraph A.9.2.5 of the license application identified 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.

No violations or deviations were identified.

c. External Exposure Control 10 CFR 20.101 specified the applicable radiation dose standards. The inspector reviewed records of individual radiation exposure during the period January through June 1985, and verified that the radiation doses recorded for plant personnel were within the quarterly exposure limits of 10 CFR 20.101.

No violations or deviations were identified.

d. Internal Exposure Control The licensee was required by 10 CFR 20.103, 20.201(b) and 20.401 to control uptakes of radioactive material, assess such uptakes and maintain records. During plant tours the inspector observed the use of ventilation systems and containment enclosures. The inspector discussed the use of this equipment with radiation protection personnel.

10 CFR 20.103(a) specified the limits for exposure of individuals to concentrations of radioactive material in air in restricted areas.

This section also required that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted areas and that appropriate l I

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i bioassays be performed to detect and assess individual intakes of radioactivity.

1 The inspector reviewed selected results of general in plant air samples taken during calendar year 1985 and the results of air samples taken to  :

! support work ' authorized by specific radiation work permits. The 4 inspector reviewed selected results of bioassays and the licensee's assessment of individual intakes of radioactive material performed i

during calendar year 1985.

4 10 CFR 20.103(b) required the use of process or other engineering controls to the extent practicable to limit concentrations of

radioactive material in air to levels below that specified in

, 10 CFR 20, Appendix B, Table 1, Column 1 or limit concentrations, when c averaged over the number of hours in any week during which individuals are in the area, to less than 25 percent of the specified concentrations. The use of process and engineering controls to limit airborne radioactivity concentrations in the facilities and the use of 1

such controls was observed during tours.

l No violations or deviations were identified.  ;

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. e. Respiratory Protection 10 CFR 20.103(b) required that when it is impracticable to apply

! process or engineering controls to limit concentrations-of radioactive i material in air below 25 percent of the concentrations specified in 1 Appendix B, Table 1, Column 1, other precautionary measures, such as

!. use of respiratory protection, should be used to maintain the intake of 1

radioactive material by any individual within seven consecutive days as

} far below 40 MPC-hours as is reasonably achievable.

l 10 CFR 20.103(c) permits the licensee to make allowance for use of l respiratory protective equipment in estimating exposures of individuals

to concentrations of radioactive material in air provided that l protection factors for the respirator are as specified in Appendix A of i 10 CFR 20. 10 CFR 20, Appendix A, footnote h, states that a protection j factor of no more than 1000 may be used for tested and certified supplied air hoods when a minimum air flow of 6 cubic' feet per minute

• j is maintained and calibrated airline pressure gauges or flow measuring

devices are used.

I The inspector reviewed records ' of individual label air sampling j performed during the period September 1,1983, to August 16, 1985. The

records indicated that _ respiratory protective equipment (supplied-air I~ hoods) had been-worn by the individuals and that protection factor credit for the hoods had been applied in estimating individual j exposures to ' concentration of -radioactive material in ' air. The i inspector reviewed MSHA/NIOSH Approval Number TC-19C-124 for the hoods i to verify that the hoods had been tested and certified.

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5 Licensee representatives stated that a dedicated compressor is used to supply Grade D breathing air to an air control panel in the vicinity of the Building B hot cells. The air control panel had a manifold which allowed attachment of individual air supply hoses to hoods worn by individuals during hot cell entries. The inspector observed during a facility tour that the air control panel for the breathing air system had a number of pressure gauges to indicate the air pressure at the control panel and that going into each air line at the manifold. There were no other gauges in the system. Licensee representatives stated that the pressure gauges had never been calibrated since the system was placed in service sometime during 1980.

Licensee representatives stated that in June, 1984 they had measured the air flow being delivered at the air line outlet which attaches to the supplied-air hood and had verified that the air flow rate was at least 6 cubic feet per minute when the system was operated at the minimum pressure required by their procedures. The inspector stated that such a test did not constitute calibration of the pressure gauges.

During review of the licensee's air sampling records, the inspector noted that if protection factor credit had not been applied for the supplied-air hoods, individual exposures to concentrations of radioactive material in air would not have exceeded the limits specified in 10 CFR 20.103(a).

Failure of the licensee to calibrate the pressure gauges in the supplied-air system was identified as an apparent violation of 10 CFR 20, Appendix A, footnote h (70-824/85-07-01),

f. Posting, Labeling and Control 10 CFR 20.203(c)(2) required that a licensee, who establishes a high radiation area for 30 days or more, control each entrance or access to the area by one of the following methods: (1) equip it with a control device which shall cause the level of radiation to be reduced below that at which an individual might receive a dose of 100 millirems in one hour upon entry into the area; or (2) equip it with a control device which shall energize a conspicuous visible or audible alarm signal in such a manner that the individual entering the high radiation area and the licensee or a supervisor of the activity are made aware of the entry; or-(3) keep it locked except during _ periods when -access to the area is required, with positive control over each individual entry.

During a tour of the facility, the inspector noted in the Cask Handling Area of Building B that an extension ladder reaching to the hot cell roof was placed against the hot cell outer wall. A permanently installed ladder on an adjacent hot cell outer wall was posted as a High Radiation Area and was covered with a locked ladder guard. A licensee representative stated that the roof of the hot cells is a permanent high radiation area. The latest licensee radiation survey record for the cell roof area performed 'on September 26, 1985 showed

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that the highest dose rate in the area was 3,500 millirem per hour.

Licensee representative stated that the extension ladder had been

placed against the hot cell wall to permit access to the top of a cask that had been in the area a few days before and not to circumvent the access controls for the high radiation area. There was no evidence j that licensee personnel had made unauthorized entries into the high

, radiation area. Failure to control access to the high radiation area on the hot cell roof was identified as an apparent violation of

10 CFR 20.203(c)(2) (70-824/85-07-02).

g'. Posting of Notices 4 10 CFR 19.11 required posting of form NRC-3, the license and other

pertinent.information. If posting of a document was not practicable,

! the licensee 'was permitted to post a notice which described the document and stated 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.

No violations or deviations were identified.

h. Surveys 4

l 10 CFR 20.201(b) required that each licensee shall make or cause to be

! made such surveys as may be necessary for the licensee to comply with j the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present. 10 CFR 20.101(a) j specified the quarterly dose limits to the skin of the whole body and

! lens of the eye.

l The licensee had made a series of personnel entries in the Building 8 j . hot cells during June and July, 1985. The inspector reviewed licensee

! records of radiation surveys performed during those entries. The i surveys had been performed with a R0-3A portable beta gamma survey i meter and with a teletector. The highest contact radiation level noted j was 50 Rem per hour on a container removed from the hot cell and the

! highest general area level noted in the hot cell was 10 Rem per hour.

Licensee representatives stated radiation levels were measured remotely

by inserting the teletector probe through a hot cell face plug prior to l permitting personnel entries. Health physics personnel then conducted

, additional radiation surveys in the hot cell during the personnel entries. These surveys were performed with either the teletector or

.' the R0-3A with the beta shield. removed.

Through discussions with licensee representatives the inspector

determined that the licensee did not perform any measurements to i

quantify the magnitude of the beta radiation field at any time prior to i or during personnel hot cel1~ entries. The instruments used by the licensee measured either gamma (teletector) or beta gamma (RO-3A) i

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7 radiation levels. Since these instruments were calibrated for gamma radiation, the beta radiation level could be higher than the level indicated on the beta-gamma survey instrument. Beta radiation, primarily attributable to the analysis performed on spent nuclear fuel within the hot cell, was preseat and personnel had received beta exposure during hot cell entries as evidenced by individual film badge records. The film badge records indicated that the shallow (beta) dose had been a factor of 2 to 3 higher than the deep (gamma) dose.

Licensee representatives stated that they did not perform beta radiation suruys because the hot cell exposure experience had been that if they ontrolled an individual's whole Lcdy (gamma) exposure well below the 3 Rem per quarter limit of 10 CFR 20.101(b), then the individua's skin (beta) exposure would also be less than the 7.5 Rem per quarter exposure limit due to the consistent beta to gamma ratios noted. The inspector acknowledged that the experience to date would indicate that no individual likely had received an excessive skin exposure, however, there was no assurance that the beta to gamma ratios

< would always be favorable.

] Film badge results reviewed after the exposure had occurred also did not constitute an adequate r:diation hazard evaluation since the purpose of such evaluations is to control exposures before they occur.

Failure to perform beta radiation surveys to evaluate the extent of the beta radiation hazards that were present in the hot cells and ensure that individual exposures were maintained below regulatory limits was identified as an apparent violation of 10 CFR 20.201(b).

(70-824/85-07-03).

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1. Notification and Reports 10 CFR 20 required certain reports and notifications as follows:

! 10 CFR 20.402 - Loss or thef t of material.

10 CFR 20.403 - Incidents.

10 CFR 20.405 - Overexposure.

10 CFR 20.408 - Termination reports tc the NRC.

10 CFR 20.409 - Termination reports to the individual.

Through review of selected records and discussions with licensee representatives, the inspector determined that the subject requirements had been met.

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No violation or deviations were identified.

j. Scurce Leak Checks License Condition 11 required that sealed sources shall be tested in accordance with the instructions contained in Annexes A and B to the 9

license.

Through reviewed of selected records the inspector determined that the licensee's sealed sources had been leak checked.

No violations or deviations were identified.

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5. IE Information Notice (IEN) (92717)

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

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

IEN 84-24: Physical Qualification of Individuals to Use Respiratory Protective Devices IEN 84-40: Emergency Worker Doses IEN 84-50: Clarification of Scope of Quality Assurance Program for l Transport Packages Pursuant to 10 CFR 50, Appendix B i

l IEN 84-56: Respirator Users Notice for Certain 5-Minute Emergency

! Escape Self-Contained Breathing Apparatus IEN 84-59: Deliberate Circumventing of Station Health Physics l

Procedures l IEN 84-60: Failure of Air-Purifying Respirator Filter to Meet j Efficiency Requiren. ant

. IEN 84-72: Clarification of Conditions for Waste Shipments Subject to Hydrogen Gas Generation i IEN 84-75: Calibration Problems - Eberline Instrument Mouel 61128 Analog Teletectors IEN 84-82: Guidance for Posting Radiation Areas IEN 85-06: Contamination of Breathing Air Systems IEN 85-42: Loose Phosphor in Panasonic 800 Series Badge TLD Elements IEN 85-43: Radiography Events at Power Reactor

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4 IEN 84-46: Clarification of Several Aspects of Removable Radioactive Surface Contamination Limits for Transport Packages IEN 85-48: Respirator Users Notice: Defective Self-Contained Breathing

Apparatus Air Cylinders IEN 85-57

Lost Iridium-192 Source Resulting in the Death of Eight l

Persons in Morocco

IEN 85-60

Defective Negative - Pressure, Air-Purifying, Full Facepiece Respirators i

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