ML20199C750
| ML20199C750 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 06/12/1986 |
| From: | France G, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199C729 | List: |
| References | |
| 70-0008-86-01, 70-8-86-1, NUDOCS 8606180240 | |
| Download: ML20199C750 (11) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 70-008/86001(DRSS)
Docket No. 07000008 License No. SNM-7 Licensee:
Battelle Columbus Laboratories 505 King Avenue Columbus, OH 43201 Facility Name:
Battelle Columbus Laboratories Inspection At: West Jefferson and King Avenue Facilities Inspection Conducted: May 12-16, 1986 Inspector:
I g -M-86 Date Approved By:
L.
rege ief 4-M ~86 Facilities Radiation Protection Date Section Inspection Summary Inspection on May 12-16, 1986 (Report No. 70-008/86001(DRSS))
Areas Inspected:
Routine unannounced health and safety inspection, including:
internal reviews and audits; training and operations review; nuclear criticality safety; radiation protection program, including audits, training, instruments and equipment, exposure control, surveys, notifications, and reports; and radioactive waste management, including transportation activities, emergency preparedness, maintenance surveillance, and environmental monitoring.
Results:
One violation was identified by State of South Carolina inspectors for excessive radiation levels on the outside of a package - Section 7.
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DETAILS 1.
Persons Contacted W. Bradford, Master Technician (Instrument Maintenance)
T. Emswiler, Transportation Specialist R. Evans, Environmental Health Physics Program, (Part-time Employee)
E. Fromm, Supervisor, Quality Assurance
- G. Kirsch, Supervisor, Operational Health Physics
- D. McKown, Radiological Safety Officer
- R. Nathan, Director of Technology Management
- V. Pasupathi, Manager, Nuclear Technology
- E. Roe, Health Physicist E. Swindall, Master Technician
- H. Toy, Manager, BCL Nuclear Services Group The inspector also interviewed other members of the licensee's staff.
- Denotes those present at the exit meeting conducted May 16, 1986.
2.
General This inspection of onsite licensee activities, which began at 1:30 p.m.
on May 12, 1986, was conducted to examine activities at the West Jefferson site under Materials License No. SNM-7.
The inspector toured both the West Jefferson and King Avenue facilities.
An exit meeting was conducted on May 16, 1986, at each of the facilities.
3.
Management Organization and Controls The inspector reviewed the licensee's management organization and controls for radiation protection and operations, including changes in the organi-zational structure, and utilization of audit systems, a.
Organization Several personnel changes have occurred since the previous inspection.
Inspection Report No. 70-008/85002(DRSS).
The Supervisor of the Instrument Laboratory (SIL) has retired.
l The SIL has agreed to continue to support instrument maintenance requirements by serving as a retired staff member.
The instru-ment laboratory maintains radiation survey instruments and gamma /
neutron monitors for the West Jefferson facility. With the SIL's retirement, the licensee's instrument maintenance program consists of two onsite technicians and two on-call technicians stationed j
at the King Avenue site.
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A Health and Safety Manager (officed at the King Avenue site) has been installed to direct corporate health and safety policy in
. compliance with regulatory requirements.
i A new position, Manager of Technical Programs,'has been instituted to_ manage among others, the Nuclear Technology and Nuclear Services Programs.
The Hot Cell Laboratory Manager was assigned to the Manager of Nuclear Technology position and is responsible for hot cell operations and laboratory activities.
The licensee stated that nonreplacement of personnel formerly engaged in safety and or safety support services does not affect the public health and safety or compromise worker safety because the nonreplacement of personnel is based on reduced activities in hot cell operations.
Additionally, several retired employees (Supervisor Instrument Laboratory, Environmental Specialist and Master Technician involved in health physics programs) have agreed to serve as members of the licensee's retired staff.
Persons serving as members of the licensee's retired staff are available to provide assistance to licensee activities on an as needed basis.
b.
Internal Reviews and Independent Audits An audit conducted by the licensee's Radiation Safety Officer confirmed that ALARA concerns and personal radiation exposure was reviewed during radiation safety awareness training.
The audit also reviewed quality control performance of the licensee's radiological safety systems.
No problems were noted.
c.
Procedure Revising and Updating The inspector reviewed the licensee's quality assurance program and confirmed that radiation protection procedures and operating i.
procedures pertaining to onsite activities are periodically reviewed by the Manager of Nuclear Technology, the Manager of Nuclear Services, i
and the Supervisor of Operational Health Physics.
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The inspector determined that the licensee's review and approval of
_ rocedures complies with the schedule maintained by the Supervisor, i
p Quality Assurance.
No violations or deviations were identified.
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-Radiation Protection i
The inspector reviewed-the licensee's internal and external exposure control programs, including the required records, reports and notifications, and the respiratory protection program.
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a.
Internal Exposure Control Whole body count results of inhouse personnel were reviewed for fission and activation products.
Results for each individual disclosed that no activity other than natural potassium was observed.
Urinalysis results for hot cell workers requiring uranium (enriched) and plutonium monitoring for the August 1985 through March 1986 operating period did not reveal any levels above the action level of 0.2 dpm/ liter.
b.
External Exposure Control Biweekly results of TLD badge readings were reviewed for the period August 1985 through April 1986.
No doses exceeding 10 CFR 20.101 limits were noted.
The maximum whole body dose to any individual for the 1985 operating year was about 3300 millirems.
c.
Source Leak Tests The inspector examined licensee records for leak testing byproduct material sealed sources.
In compliance with a six-month test interval, the licensee's records disclosed that all 12 sources passed the leak test criteria.
The-tests were performed in accordance with the provisions of SNM-7.
d.
Maintaining Occupational Exposures ALARA Because of reduced activities in hot cell operations, monitored work practices, and engineering controls (see Inspection Report No. 70-008/85002(DRSS)) occupational exposures remained less than the licensee's action levels.
As mentioned in Section 3.b, Management Organization and Controls, ALARA concerns-are emphasized during radiation safety awareness training.
e.-
Surveys and Contamination Control The inspector reviewed the licensee's program for radiological surveys
- to verify compliance with the regulations and with licensee require-ments including:
schedules for periodic surveys, effectiveness of surveys, and adequacy of instrumentation.
l Using check sources with'different levels of radioactivity the inspector monitored the licensee's program for detecting radioactivity on personnel prior to their exiting the site. The licensee maintains G-M pancake probe friskers at two points of egress, one from the hot cell laboratory to associated offices and the other from the guard I
house to the parking lot. The efficiency of survey instruments used at points of egress was about 28 to 34 percent when measured with a Sr-90, Y90 beta source.
The licensee uses Ludlum Model 177 rate meter and/or an Eberline Model 14 rate meter coupled to a pancake beta gamma detector.
During the plant tour the inspector noted that_the instrument alarmed about 200 counts per minute above background.
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This is approximately equivalent to 0.0004 uCi or 750 dpm Sr-90, Y90.
The licensee also used foot monitors to monitor foot trafficking of radioactivity from the hot cell area to the associated offices (unrestricted area).
Detection of radioactivity by foot monitors seemed quite inefficient.
The efficiency for measuring Sr-90 was about two percent.
The area of detection as identified with a Cs-137 check source (0.326 mci) appeared to be localized around the heel of the shoe. When the check source was located in the area occupied by the sole of the shoe no radiation was detected using the 0.326 mci Cs-137 source.
Nonetheless, a survey meter, Ludlum or Eberline rate meter, equipped with beta / gamma (pancake) detector is used by the licensee for final survey at each point of egress in lieu of the inefficient foot monitor.
In addition, survey records disclosed that the practice of using masslin oil impregnated cloths for cleaning the hot cell floor (see Inspection Report No. 70-008/84002) continues to be effective in reducing foot trafficking of contamination.
f.
Respiratory Protection The inspector reviewed the licensee's respiratory program in accordance with Quality Assurance Document NS-NS-3 and Page 1.31 of the licensee's renewal application, dated October 5, 1981. The licensee's respiratory program was designed to comply with the following regulations and standards:
Title 10 CFR, Part 20.103(c)
DOE Respirator Manual, UC-41 NUREG-0041 ANSI Z 88.2 Regulatory Guide 8.15 During the onsite inspection of May 12-16, 1986, it appeared that other than the signature of the individual worker, there was no record of a medical determination to show the physical ability of the worker to perform work using respiratory protective equipment.
On May 21, 1986, the licensee contacted Region III and noted that medical records reflecting the medical status of each respirator user had been found.
In support of these findings on June 2, 1986, the licensee submitted documents to Region III describing the overall respiratory program and the integration of a medical evaluation of respirator users by a licensed physician.
In accordance with 10 CFR 20.103(c)(2) a physician must make an annual determination that the individual user is physically able to use the respiratory protective equipment.
Additionally, the licensee plans to modify the respiratory protection program to ensure that the Supervisor of Health Physics is notified in writing by the physician as to any concerns about the individual employees' work restriction.
Appropriate documentation of the licensee's respiratory program will be checked during a future inspection and is identified as Open Item (No. 70-008/86001-01).
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g.
Airborne Releases and Quantification During the previous inspection (see Inspection Report No. 07-008/85002), the licensee was seeking clarification of the license requirement to track the cumulative weekly concentration in process ventilation systems relative to 10 CFR 20 limits for alpha and beta / gamma levels.
In an October 1, 1985 response to the licensee, NMSS accepted the licensee's use of nuclide specific MPC limits based on quantitative isotopic analyses and an MPC limit of 2 E-14 uCi/ml for unidentified radionuclides; standard engineering practices are specified for corrective actions.
Based on the October 1, 1985 response from DFMS/NHSS, it appears that the licensee's approach to quantify data is acceptable.
No problems were noted.
Unresolved Item No. 70-008/85001-01 is considered closed.
Because of the recent limited hot cell activities the licensee did not detect any alpha or beta excursions above MPC levels.
Plutonium-239 and stroatium-90 are used as isotopic indicators for airborne monitoring.
h.
Quality Assurance (QA)/ Instrument Maintenance Based on QA schedules routine (six-r.onth frequency) maintenance and
. instrument calibration was performed on the hot cell neutron detection system.
The Master Technician of the Instrument Maintenance Section, noted that back up systems for gamma and neutron detection are available and functional.
Other required QA maintenance includes hand held radio units, the mobile radio unit, and gamma and criticality alarm systems.
Radio communication is used by the security force in routine security operations and by licensee personnel assigned to emergency response teams.
I As identified in Inspection Report No. 70-008/85001 concerning non-routine operations for the JN-18 HCL pool water, increases in the l
j radioactivity in the pool water are acceptable provided the licensee i
follows the steps outlined under SNM-7 Section 4.0, Part I.
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licensee actions, which include weekly analysis of pool water, were clarified with NMSS and communicated to appropriate licensee personnel.
No problems were identified.
(Closed Open Item No. 70-008/85001-03).
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The inspector interviewed the QA supervisor and determined that the l
licensee reviews compliance with license conditions when conducting QA l
audits.
(Closed Open Item No. 70-008/85001-04).
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No violations or deviations were identified.
5.
Operations Review The inspector reviewed with the licensee the status of operations at the West' Jefferson and King Avenue sites.
During facility tours the inspector observed licensee performance in accordance with statements, representa-tions, and conditions contained in Appendix A of the licensee's application.
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The licensee anticipates receiving authorization to demonstrate the reduction of combustible radioactive waste volumes by incineration in the near future. The incineration program will probably be licensed as an amendment under existing Materials License No. SNM-7.
After participating in DOE programs for more than 40 years, the licensee has initiated plans to decontaminate the DOE facilities and terminate the DOE project. The decontamination and decommissioning program will involve locations in 15 buildings, with completion expected in about seven to 10 years. A previous decontamination and decommissioning effort, which was completed in 1983, resulted in release of Building JN4, a major j
plutonium handling area for DOE activities.
4 Under existing SNM license, the licensee is investigating a project to consolidate fuel assemblies using commercial (Unites States Tool and Die) equipment and methodology. The existing Battelle fuel storage pool will require a modified fuel storage rack in order to accommodate the additional
-assemblies.
Rochester Gas and Electric Company's Robert E. Ginna Power Reactor will be the beneficiary of the consolidated fuel assembly program.
The inspector interviewed the licensee's Chairman, Nuclear Safety Subcommittee, and the overall program manager, and discussed the operational aspects and health and safety concerns of the fuel consolidation project.
The licensee agreed to provide Region III with a copy of the nuclear criticality safety analysis, the operations or project procedure, and the safety concerns necessary to complete the project.
The inspector emphasized these issues during the exit meeting.
The pending review by Region III of the licensee's fuel consolidation program is identified as an Open Item (No. 70-008/86001-02).
No violations or deviations were identified.
6.
Maintenance Surveillance The inspector examined the licensee's maintenance operations and confirmed that QA records disclosed that safety and alarm checks were performed on gamma / neutron instruments pertinent to the safe operation of hot cell i
systems.
See Section 4.h., " Radiation Protection / Instrument Maintenance,"
for more discussion on instrument maintenance.
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No violations or deviations were identified.
7.
Transportation Activities The inspector examined the licensee's transportation records and determined that the fuel assemblies which arrived at Battelle for the fuel consolida-l tion program were shipped in compliance with DOT /NRC regulations.
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On December 10, 1985, a cask containing reactor activated waste (reactor components) shipped from BCL to Chem-Nuclear at Barnwell, South Carolina l
via flatbed trailer was discovered to have an external surface reading of 300 millirem per hour. This appears to be a violation of 49 CFR 173.441 i
and 10 CFR 71.47 which prohibit radiation levels in excess of 200 millirem per hour on the accessible external surface of a package unless the i
shipment is an exclusive use shipment made in a closed transport vehicle, the package'is secured in a fixed position during transport, and there are no loading or unloading operations between the beginning and end of the shipment.
Also, upon examining the waste manifest, the South Carolina Department of Health and Environmental Control (SCDHEC) discovered that Column 9, which indicates whether or not the shipment was consigned as exclusive use, was not comoleted by the licensee. On June 9,1986, however, a representative from SCDHEC informed the inspector that the violation was intended to be issued for the excessive radiation level on the surface of the cask and not for improper execution of the Radiation Survey Manifest.
Discussions with personnel from NRC Inspection and Enforcement Office also indicated that omitting Column 9, did not appear to violate any DOT regulation.
The inspector 'eviewed the Notice of Violation (December 13, 1985) to BCL from SCDHEC; the letter (December 30, 1985) to SCDHEC from BCL enclosing a check in payment of the civil penalty imposed and the licensee's corrective actions to be taken to avoid further violations; the letter (January 13, 1986) from SCDHEC to BCL reinstating BCL's radioactive waste permit; and confirmed that BCL's State of South Carolina Radioactive Waste Transport Permit was reinstated effective January 13, 1986.
The licensee implenented several corrective actions to prevent future incidents of noncompliance in shipments of radioactive material.
These corrective actions include:
An in-depth review of operational procedures by the appropriate management personnel from both the generating facility and the Battelle Columbus Nuclear Services Group.
Review and revision of specific quality assurance documents dealing with the packaging, shipment and disposal of radioactive waste materials. A "one over one" signature review and approval of specific shipping documents by cognizant management personnel was established to ensure their proper execution.
On matters related to proper interpretation of any questionable local, state or federal regulation dealing with shipments of radioactive materials, responsible personnel have been directed to contact the appropriate regulatory body for guidance and verification in the correct interpretation of any questionable regulation.
Questions such as those regarding the interpretation of 49 CFR 173.441(b) (1 through 4) for shipment No. 1285-172-8 will be directed to the D0T Office of Hazardous Materials Regulations or other cognizant authority such as Chem-Nuclear Systems, Inc., Regulatory Affairs Group.
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The inspector examined the licensee's QA document file concerning transportation procedures and verified that the following documents are in place.
NSI-PI-14 Advance Notification of Shipment of Large Quantities of Licensed Nuclear Waste or Spent fuel.
NS-PI-10 Transportation Emergency Plan for Spent Fuel and Gl.her Radioactive Material Shipments.
Operating Procedure and Documentation traveler for Receipt of an Empty NLI-Shipping Cask and Loading of Fuel Assembly for Shipment.
One violation was identified by State of South Carolina inspectors.
8.
Criticality Safety The inspector reviewed criticality safety audits, documentation of criticality training, toured the Hot Cell' Laboratory (HCL), and reviewed documentation of facility changes requiring criticality considerations.
The licensee is currently reviewing risk and safety analyses pertinent to fuel assembly consolidation.
United States Tool and Die performed an onsite demonstration of techniques required to consolidate fuel. The cold run demonstration was witnessed by representatives from the licensee's Nuclear Safety Subcommittee and other licensee personnel involved in the project.
A nuclear safety analysis establishing the operating parameters for the fuel consolidation program will be forwarded to Region III.
Quality Assurance records included results of the licensee's annual criticality safety lecture.
A proctored test was given after the lecture.
Test scores ranged form 80-100 showing an average of 93.
The inspector confirmed that management of the licensee's nuclear safety program is commensurate with the license application.
No violations or deviations were identified.
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Environmental Monitoring The inspector reviewed the licensee's environmental monitoring program, the l
annual environmental report, and specific requirements of Materials License No. SNM-7, License Condition No.19.
The annual dose to the nearest resident (0.47 miles) from effluents released during 1985 was 3.18 E-06 mrem / year from airborne inhalation and 1.90 E-07 mrem / year from airborne ingestion.
The nearest population group affected by the Battelle operation is Darbey Estates, a community of about 3,000.
Annual dose to this community from airborne inhalation and ingestion was 5.16 E-06 and 5.7 E-07 person-rem respectively.
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e According to the report, offsite levels of radionuclides attributable to the West Jefferson nuclear operation were not significantly different from background levels.
Exposure levels at the site boundary line during 1985, was less than background at the Girl Scout Camp (adjacent property) located 0.5 km east of the nuclear site.
No violations or deviations were identified.
10.
Emergency Preparedness The inspector examined QA documents and determined that the licensee controls the distribution of Emergency Plans and Procedures and that all members of the licensee's Emergency Control Groups and authorized State and federal regulatory agencies receive updates to the plan. Offsite agencies responsive to BCL emergency concerns and their respective telephone numbers were verified in March 1986 by Region III; no problems were found.
- However, the USNRC telephone listing in the Columbus, Ohio telephone directory was incorrect; a disconnected line message was received.
The Division of Resource Management and Administration, Region III, will take appropriate action to correct the USNRC number.
Onsite emergency control groups include Access Control, Emergency Site Unit, First Aid Group, Fire Control Group, Radiological Control Group, and Personnel and Environmental Survey Unit.
Personnel assigned.to a specific group may also act as alternates in one or more of the other groups.
In view of the cross training required to staff the various emergency control groups, the inspector discussed with the licensee the desirability of having all members and alternate members assigned to an emergency control group undergo annual respiratory protective training.
In the course of this inspection, the inspector determined that only the personnel assigned to the Fire Control Grcup were assured of annual respiratory training.
This and correction of the NRC phone number will be reviewed during the next inspection (0 pen Item No. 70-088/86001-03).
The licensee Fire Control Group is responsible for evaluating the severity of a fire, extinguishing minor fires, and assisting the Village of West Jefferson Fire Department in fighting onsite fires and by informing the Village of West Jefferson fire fighters of radiological chemical or other unusual hazards, during fire control activities.
The licensee Fire Control Group consists of a Fire Control Leader, an alternate, and six members.
Records disclosed that training is conducted quarterly, and all members participated in an annual respiratory protection training session.
No violations or deviations were identified.
11.
Exit Meeting The inspector met with licensee representatives (denoted in Section 1) at the conclusion of the onsite inspection.
The inspector summarized the scope and findings of the inspection and discussed the violations and open items described in the report.
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During the course of the inspection and the uit meeting, the licensee did not identify any documents or inspection statements or references to specific processes as proprietary.
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