ML20207T445
| ML20207T445 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 02/19/1987 |
| From: | Ayres P BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8703240023 | |
| Download: ML20207T445 (5) | |
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Babcock & Wilcox Uy*n*c'*EIg'U.7.7cI*c*."n'E*'*"
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a McDermott cornpany P O. Box 11165 Lynchburg, Virginia 24506 1165 n TEB 25 all : y1 February 19, 1987 Director Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission
-101 Marietta Street, NW Atlanta, GA 30325
Subject:
Responses to Notice of Violation (NRC Report No. 70-824/86-06
Dear Sf r:
My responses to the subject report are attached.
Additionally, in your letter dated January 21, 1987, you requested my re-sponse to a concern regarding an apparent weakness in our procedural controls for Radiation Protection activities at the Lynchburg Research Center (LRC).
The Health and Safety Group at the LRC has been actively engaged in procedure development since 1983, in an effort to address inadequacies that were iden-tified during internal audits.
To date, there are one hundred one technical procedures prepared for licensed activities, for which the Health and Safety Group was primarily responsible.
These procedures have been developed on an as-needed basis and I feel that it is now time to examine our progress.
Therefore, the Safety and Licensing Section has agreed to continue with the formalization of our Radiation Protection program in the following way:
1.
Define the program elements.
2.
Identify the regulations, license requirements and technical guidance that apply to each element.
3.
Prepare a program plan that combines the results of I and 2 above.
4.
Compare the existing procedural controls with those indicated in 3 above.
5.
Set the priorities for taking the necessary actions as indi-cated in 4 above.
6.
Develop the procedural controls indicated in 5.
8703240023 870219 I
.C ADOCM 07000824'd l
PDR i
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Director, Division of Radiation Safety and Safeguards n,
Page 2 il February 19, 1987 r:
I feel that the results of following the above plan will be a well thought-out Radiation Protection program that meets the needs of our employees, neighbors, the environment and the regulatory requirements.
Very truly yours, B COCK & WILCOX P. S. Ayres, Manager-Lynchburg Technical Operations Lynchburg Research Center Attachment i
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RESPONSE TO NOTICE OF VIOLATION Report No. 70-824/86-06 A.
- A urinary plutonium level of 0.4 disintegrations per minute per liter was observed and no follow-up action was taken.
1.
- Admission or denial of the violation:
I admit to the violation.
2.
Reason for the violation if admitted:
The reason for this violation is not clear.
There is no documentation of the evaluation.
I can only assume that it was the result of an over-sight on the part of the responsible individual.
3.
Corrective steps which have been taken and the results achieved:
The internal exposure records of the individual whose June 1, 1985 sample indicated above the action level were reviewed, and there is no other indication of subsequent internal exposure.
4.
Corrective steps which will be taken to avoid further violations:
A procedure will be written for urinalysis results that will specify action levels, and require documentation of the actions taken and of evaluations performed,_ in response to positive results.
5.
Date when full compliance will be-achieved.
The LRC is now in full compliance.
B.
Audit findings and actions taken to correct previous findings were not delineated in quarterly reports of monthly radiation safety audits for 1985 and'1986.
~1.
Admission or denial of the violation:
I admit to the violation.
2.
Reason for the violation if admitted:
The monthly audits performed by the Supervisor, Health and Safety are conducted according to a written pl an.
The audit plan was not sufficient in the details for the report format.
The plan did not specify that findings and actions taken to correct previous findings were a mquirement of the report.
3.
Corrective steps which have been taken and the results achieved:
The format of the audit report for the fourth quarter 1986 report has been modified to include findings and actions taken to correct pre-viously identified items.
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RESPONSE 'TO NOTICE:0F VIOLATION - Report No. 70/82'4/86-06.
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- Page 2
-4.
' Corrective steps which will be taken to avoid further violations:
~
The a'udit plan will be' revised to require that. findings and corrective actions on previously identified items be. included in the audit report.-
'5.
Date' when. full compliance will be achieved:
The LRC is now in full compliance.
C(1) During 1985 and 1986, the licensee did not have written procedures re- -
garding maintenance of records showing. that. an individual had been issued a ' respirator.
.1.
Admission or dental of the violation:
.I admit to the violation.
2.
Reason -for the violation if admitted:
- A Radiation Work. Permit (RWP) is required for the use of mspirators at the LRC and serves as the record of issuance.. The need for a procedure
'to specify that the RWP serves as a record of ~. issuance -was -not l
recognized.
.3.
Corrective steps which have been taken and the results achieved:
The. procedure. for respiratory protection, LRC-TP-95, has been mytewed and the need to revise this procedure has been identified.
It has been determined that this procedure needs to include the clarification that the RWP shall serve as the record of respirator issuance..
- 4.-
Corrective-steps which will,be'taken to _ avoid further violations:
' The procedure for respiratory protection, LRC-TP-95, will be revised to specify that the RWP shall serve as the mcord of mspirator issuance.
- 5. -
Date when-full compliance will be achieved:
Full ' compliance will be achieved'on.or'before April 1,1987.
'C(2) The June 14,1977 written policy statement issued by licensee management on respirator usage did not address 'the routine, non-routine and emergency use of respirators.
4 1..
Admission or denial of the violation:
..I admit to the violation.
l 4.
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. RESPONSE-T0 NOTICE OF VIOLATION - Report No. 70-824/86-06 Page 3 2.-
Reason for the violation if admitted:
During internal audits of the respiratory protection program,. the existence of a policy statement was verified but its content was not evaluated against the regulatory requirements.
3.
Corrective steps which have been taken and the results achieved:
A-newL policy statement has been issued that addresses each of the re-
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quirements 1n 10'CFR 20.103.
4.
Corrective steps which will be taken to avoid further violations:
No additional corrective steps are needed.
5.
Date when full compliance will be achieved:
-The LRC is'now in full compliance.
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