ML20203D044

Forwards Recommendations Re B&W Lynchburg Research Ctr Renewal Application,Per 851218 Memo.N Ketzlach Will Accompany Region II Senior Radiation Specialist on Routine Insp on 860310-14

ML20203D044
Person / Time
Site:	07000824
Issue date:	03/24/1986
From:	Barr K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
26704, NUDOCS 8604210358
Download: ML20203D044 (4)

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/ MAR 2 41986 RETURN TO 396-SS  !

MEMORANDUM FOR: W. T. Crow, Acting Chief, Uranium Fuel L.icensing Branch Division of Fuel Cycle and Material Safety, NMSS FROM: K. P. Barr, Chief, Nuclear Material Safety and Safeguards Branch Division of Radiation Safety and Safeguards 4

SUBJECT:

LICENSE RENEWAL APPLICATION - BABC0CK AND WILC0X LYNCHEURG RESEARCH CENTER DOCKET NO.70-824 In accordance with your memorandum of December 18, 1985, Region II submits the enclosed comments and recommendations on the Babcock and Wilcox - Lynchburg Research Center (B&W-LRC) renewal application. Our inspection schedule for B&W-LRC has been verbally transmitted to Norman Ketzlach. Plans are for Norman to accompany the Region II-Senior Radiation Specialist on a routine inspection of the licensee the week of March 10-14, 1986.

1 We appreciate the opportunity to furnish comments and recommendations. If you have any questions, please contact me. p K. P. Barr

Enclosure:

Comment on B&W-LRC License Renewal

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i MAR 2 4190 w-ENCLOSURE COMMENT ON B&W-LRC LICENSE RENEWAL 1.6.8 A " Qualified Person" shall be trained in nuclear safety and radiation protection, not just " Familiar with the hazards in the area" (refer to 2.6.1 and 2.6.2) 1.6.10 The definition of calibration is vague. Calibration includes the determination of range and accuracy within appropriate range and accuracy to a known standard. The definition as written does not include adjustment to assure that the reading (result) falls within an acceptable accuracy.

1.8.1.1 Waiver of bioassay just because the individual "is absent from LRC" is not a sound technical basis for the program. Criteria should be stated in terms of air concentrations, previous results and known exposures. A limit should also be established for how many consecutive bioassay periods may be missed (not more than one) before special bioassays or work restriction is required.

(Refer to 3.2.4.3 and 12.8.1).

2.3.1 The SRC shall review all SAS audit findings, all overexposures, and all unusual occurrences which must be reported to the NRC.

l 2.5.4 As written, the qualification of the Facility Supervisor have been f decreased from those currently in effect. (Previously, position required degree +3, or 8 yrs, experience - now requires degree +3 or 5 yrs experience). Justify this action.

2.6.4 Specify the reoairements for retraining in Respiratory Protection.

2.7.3 ACPs shall be strictly adhered to by all personnel, not just OPS 3.1.1.1 This section must be clarified as to intent. As presently written, it states " levels of radiation specified in 10CFR20." At what estimated exposure levels are RWPs to be required? This does not address the case where A0Ps specify "RWP required" or other sections of the license specify an RWP, such as 12.2.2.

3.1.2.5 How will ALARA performance will evaluated? How, when and by whom are the ALARA performance goals established?

Section 3.1.2.5 states that the SRC will evaluate the AL ARA performance by reviewing the ' annual report from the Supervisor, Health and Safety. Where is tha requirement for preparing and t

submitting such a report? (2.1.2.1 does not require audit reports l to be sent to SRC).

3.2.2.6 Why are non-stack releases only monitored for particulates? Why not gas and/or iodine samples as circumstances dictate?

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. . MAR 2 41986 Enclosure 2 .

3.2.2.12 Test method?

Add the following phase to item 3.2.2.12 "Whichever is sooner",

3 Without this phase, filter testing could be conducted at frequencies greater than one year.

3.2.3.4.1 What is calibration and test frequency of the criticality l monitors?

3.2.4.3.1.2 The action levels specified for uranium enriched in U-235 > 4%

are not consistent with those specified,in Table 12-6 (55 dpm/

sample vs 55 dpm/l.)._ Specify_a consistent action level. Paragraph a 3.2.4.3.1.2 shEuld state uranium enriched,.in U-235 rather than enriched U-235._ -- -

3.2.4.5 Specify the criteria, regiufaiions etc. which will be used in implementing the._Raspiratory-Protectidn~ Program.

3.2.4.6.1 Justify the stated - frequench for coiitamination surveys. When

operations are goin.g on in_the4 Hot Cell or Cask handling, how is a

bimonthly curvey frequency,justjfied?

l 3.2.4.9 When will extremity bad es,or,supplemen.tal badges be used?

q 5.1 No mention is made_conqqrning"demonstratio'n of compliance with 40 CFR 190 . requirements. The licensee should include a brief discussion on how this will be done.- '

5.2 The environmental m,onitoring.. program description should be more i comprehensive. ' The program should be strengthened through the following commitmentw-- ~~ ~

1. Air sampling at fitb Ei6undar'f"in the prevailing wind directions; air s,ampligg at .the_ paints of maximum X/Q

2. Upstream wa.ter-sampling-(above-discharge) n1T N!

3. . Annual onsite a&offsite so11~sa1EpTTn_g p.. .rggram ,

4. Semi-annual vegetation sampling program I 5. Establishment of a direct radiation monitoring network - TLD program on site (at site boundary at least).

5.2.3 The qualification basis of outside ' concerns "who evaluate i environmental sampling program and results should be specified.

8.0 Submit a current copy of the Radiological Centingency Plan which describes the current status of operators and facilities at LRC which come under the preview of SNM-778.

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