ML20210D814

Notice of Violation from Insp on 861215-19

ML20210D814
Person / Time
Site:	07000824
Issue date:	01/21/1987
From:	Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20210D807	List: ML20210D801 ML20210D814 ML20210D828
References
70-0824-86-06, 70-824-86-6, NUDOCS 8702100167
Download: ML20210D814 (3)

Text

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ENCLOSURE 1 NOTICE OF VIOLATION Babcock and Wilcox Company Docket No.70-824 Lynchburg Research Center License No. SNM-778 During the Nuclear Regulatory Connission (NRC) inspection conducted on December 15-19, 1986, violations of NRC requirements were identified. The violations involved (1) failure to followup on plutonium urinalysis results, (2) failure to delineate audit findings in reports to management and (3) failure to implement respiratory protection requirements with two examples. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. License Condition 9 of the License No. SNM-778 requires adherence to statements, representations and conditions contained in Appendix A of the Application dated December 21, 1978 and supplements dated September 5, October 26, December 4, December 20, 1979 and January 25, February 18, February 28, March 24, March 25 (two supplements), April 8, May 9, May 20, May 30 and June 16, 1980.

Appendix A, Section A.9.2.3 states that health physics shall administer a bioassay program for uranium and plutonium and shall implement the action levels and actions to be taken presented in Table A-1.

Table A-1 requires that when urinary plutonium levels exceed 0.2 disinte-grations per minute per liter, the individual shall be re-sampled within five working days. If the result is confirmed, investigate how the exposure occurred, take corrective action, and verify if area surveys support the urinalysis result.

Contrary to the above, the requirement to adhere to the statements, representations and conditions contained in Appendix A of the License Application was not met in that on June 1,1985, a urinary plutonium level of 0.4 disintegrations per minute per liter was observed and no followup action was taken.

This is a Severity Level IV violation (Supplement IV).

B. License Condition 9 of the License No. SNM-778 requires adherence to statements, representations and conditions contained in Appendix A of the Application dated December 21, 1978 and supplements dated September 5, October 26, December 4, December 20, 1979 and January 25, February 18, February 28, March 24, March 25 (two supplements), April 8, May 9, May 20, May 30 and June 16, 1980.

g2100167870121 C ADOCK 07000824 l PDR t

Babcock and Wilcox Company Docket No.70-824 Lynchburg Research Center 2 License No. SNM-778 Appendix A, Section A.6.4.1 states that radiation safety audits shall be performed monthly in accordance with a written plan, and that a written report of the audits shall be filed quarterly with the Director, Lynchburg Research Center, and with a copy to the License Administrator including the areas inspected, findings and status of action taken to correct previous findings.

Contrary to the above, the requirement to adhere to the statements, representations and conditions contained in Appendix A of the License Application was not met in that audit findings and actions taken to correct previous findings were not delineated in quarterly reports of monthly radiation safety audits for 1985 and 1986.

This is a Severity Level IV violation (Supplement IV).

C. 10 CFR 20.103(c) provides in part that the licensee may make allowance for use of respiratory protective equipment in estimating exposures of individuals to radioactive materials in air provided that the licensee maintains and implements a respiratory protection program that includes written procedures regarding the maintenance of issuance records. The licensee is also required to issue a written policy statement on respiratory usage covering such things as: use of practicable engineering controls instead of respirators; routine, nonroutine, and emergency use of respirators; periods of respirator use; and relief from respirator use.

Contrary to the above, the requirement to have written procedures regarding issuance records and a policy statement on respirator usage was not met in that:

1. During 1985 and 1986, the licensee did not have written procedures regarding maintenance of records showing that an individual had been issued a respirator. The licensee made allowance for use of respiratory protective equipment in estimating exposures of individuals to radioactive materials in air for purposes of determining compliance with 10 CFR 20.103 during this period.

2. The June 14, 1977, written policy statement issued by licensee management on ru pirator usage did not address the routine, nonroutine and emergency use of respirators. The licensee had made allowance for use of respiratory protective equipment in estimating exposure of individuals to radioactive materials in air.

This is a Severity Level V violation (Supplement IV).

Pursuant to the provisions of 10 CFR 2.201, Babcock and Wilcox Company is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including for each violation: (1) admission or denial of the violation, (2) the reason for the violation if admitted, (3) the corrective steps which have been taken and the

. O Babcock and Wilcox Company Docket No.70-824 Lynchburg Research Center 3 License No. SNM-778 results achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.

FOR THE NUCLEAR REGULATORY COMMISSION

/ /t c J. Philip Stohr, Director Division of Radiation Safety and Safeguards Dated qtr Atlanta, Georg'a thispAday of JpNM 1987

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