ML20210D828

Insp Rept 70-0824/86-06 on 861215-19.Violations Noted: Failure to Implement Respiratory Protection Requirements W/ Two Examples,To Follow Up on Plutonium Urinalysis Result & to Provide Required Info to Mgt from Monthly Audits

ML20210D828
Person / Time
Site:	07000824
Issue date:	01/06/1987
From:	Hosey C, Revsin B 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, IEIN-86-020, IEIN-86-022, IEIN-86-023, IEIN-86-041, IEIN-86-043, IEIN-86-055, IEIN-86-20, IEIN-86-22, IEIN-86-23, IEIN-86-41, IEIN-86-43, IEIN-86-55, NUDOCS 8702100172
Download: ML20210D828 (8)

Text

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i AMtiu UNITED STATES pf 'o,, NUCLEAR REIULATORY CCCMISSIEN O o REG lON ll 5

• .$* 101 MARIETTA STREET N.W., SUITE 2000 ATLANTA, GEORGIA 30323

\..../ JAN 211987 Report No.: 70-824/86-06 Licensee: Babcock and Wilcox Company Lynchburg Research Center Lynchburg, VA 24505 Docket No.: 70-824 License No.: SNM-778 Facility Nane: Lynchburg Research Center Inspection Conducted: December 15-19, 1986 Inspector: b.h.

B. K. Revsin 2Alkn } fb,f 8'9 Date Signed Approved by: I /k/ M7 C. M. Hosey, Sectio \ Chief Date Sighed Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection involved onsite inspection in the area of radiation protection and included: external exposure control and dosinetry; internal exposure control and respiratory protection, radioactive materials control, surveys and monitoring, posting, labeling, audits and program for maintaining occupational dose as low as reasonably achievable (ALARA).

Results: Three violations: 1) failure to implement respiratory protection requirements with two examples, 2) failure to followup on plutonium urinalysis result and 3) failure to provide required information to management from monthly audits.

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REPORT DETAILS

1. Persons Contacted Licensee Employees

• P. S. Ayres, Manager, Technical Operations

• R. L. Bennett, Manager, Safety and Licensing

• A. F. Olsen, Senior License Administrator

• G. S. Hoovler, Supervisor, Health and Safety

• S. W. Schilthelm, Senior Health Physicist

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on December 19, 1986, with those persons indicated in Paragraph 1 above. Threeviolations,(1) failure to implement res airatory protection requirements with two examples

[ Paragraph 4.a(1):, (2) failure to followup on plutonium urinalysis result

[ Paragraph 4.a(2)], and (3) failure to provide required information to management from monthly audits (Paragraph 4.f), were discussed in detail.

Inadequacies in the area of written and approved health physics procedures for implementing 10 CFR 20 and the License Conditions were discussed with management. 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 (Closed) Violation (50-013/85-01-01) The inspector reviewed licensee responses dated August 28 and November 14, 1985, and verified that the corrective action specified in the response had been implemented.

4. Radiation Protection (83822)

a. Internal Exposure Control (1) Respiratory Protection 10 CFR 20.103(c) provides that the licensee may make allowance for the use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air, provided that the licensee maintains and implements a respiratory protection program that includes as a minimum, written procedures regarding issuance records. The licensee is also required to

issue a written policy statement on respirator usage covering such things as: use of practicable engineering controls instead of l

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. w respirators; routine, nonroutine and emergency ushof respirators;

• periods of respirator use; and relief from respirator use. .

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During tours of the facility, the inspector observed the storage' F

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of respiratory protective devices, the facilf tles for maintananc(

- and cleaning of respirators, and verified that respiratory '"

< m~ A protection equipment in use had NIOSH/MSHA certification. .

Licensee Technical Procedure LRC-TP-95, REgitat'ory-ProtectionM ~

Program, Revision 0, March 26, 1986, was review 6d'and it was noted w that issuance records for respirators had not been addressed. The

< licensee stated that no issuance records were maintained to show -

{ that an individual had been issued a respiratory protection device and that no licensee procedure required maintenance of such records. It was further stated that while not addressed by procedures, issuance records for respiratory protection equipment could be constructed from Radiation Work Permit (RWP) sign-in

sheets since all work involving wearing of respiratory protection devices required an RWP. A review of the Maximum Permissible Concentration (MPC) hour logbook showed 'that protective factor credit for respiratory protection devices had been documented.

The inspector stated that there were numerous methods by which respirator issuance could be tracked (including RWP sign-in sheets) provided that such a function was specified by written procedure. ,

Failure to maintain written procedures co cerning respirako?

issuance records was identified as an apparent violation of m

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, 10 CFR 20.103(c) (70-824/86-06-01). .

Procedure LRC-TP-95 also contained the licensee's written policy ,

V statement concerning respirator usage. Excmination of this 1#

statement showed that the routine, nonroutine and emergency use of

respirators had not been addressed. The inspector reviewed the original statement which had been promulgated in a memon from the Director, Lynchburg Research Center (LRC) to all radiation workers on June 14, 1977.

It, too, failed to address the routine,

nonroutine and emergency use of respirators. ,.

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"t Failure to address the routine, nonroutine and emergency use>of respirators in a written policy statement was identified as a O_

second example of an apparent violation of 10 CFR 20.103(c) u .

(70-824/86-06-01). -

Review of Procedure LRC-TP-95 for medical examination requirements '

indicated that while medical qualification for respirator users * '

was required, the frequency at which medical qualification was -

required was not specified. The inspector reviewed the personnel

files for selected radiation workers and verified that medical qualification of the respirator users had been performed on a 12-month basis. J i

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(2) Bioassay Program License Condition 9 of License No. SNM-778 requires adherence to statements, representations and conditions contained in Appendix A of the License Application.

Appendix A, Section A.9.2.3 states that health physics (HP) shall administer a bioassay program for uranium and plutonium and shall implement the action levels and actions to be taken as presented

& in Table A-1. Table A-1 requires that when plutonium urinalysis E .results exceed 0.2 disintegrations per minute (dpm) per liter,

> , resample the individual within five working days. If the result is confirmed, investigate to determine how the exposure occurred, take corrective action, and verify if area surveys support the

' urinalysis result.

s Licensee Procedure, LRC-TP-242, Employee Urine Sampling for

- Uranium, Plutonium and By-product Materials, Revision 0, November 13, 1984, provided instructions on the collection of urine samples and methods for shipment. The licensee used a vendor for excreta analyses and a turn around time of four to six weeks was required to receive the results.

The inspector reviewed the results of the excreta analyses for

., v 1985 and 1986 and noted that in April 1985, fecal analyses for plutonium had beet, performed for two workers. The licensee stated that the intake occurred during the decommissioning work in Building C where drums of plutonium waste had been stored. Fecal analyses had been performed as a result of the concentration of radioactive material observed on lapel air sample filters worn by the workers. Calculation of MPC hours from the fecal analysis

- with the highest plutonium activity gave a maximum intake for one worker of 2.7 MPC hours.

Results of urinalyses for plutonium and for uranium were examined for 1985 and 1986. On June 1, 1985, results for one worker showed an activity of 0.5 dpm per sample plutonium. Correcting for urine

. volume, the final activity was 0.4 dpm per liter, which exceeded the license action level of 0.2 dpm per liter. Further review of bioassay results showed that the worker had not been resampled to confirm the result as required nor had any other followup action been taken. The licensee stated that no records could be found of any action or evaluation that took place as the result of the event. An activity of 0.4 dpm per liter is below the limits for inhalation specified in 10 CFR 20.103(a)(1) and the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> control measure specified by 10 CFR 20.103(b)(2).

Failure to follow up on the plutonium urinalysis results which exceeded the action level specified in Appendix A of the Application was identified as an apparent violation of License Condition 9 (70-824/86-06-02).

4 (3) Air Sampling The licensee is required by 10 CFR 20.103, 20.201(b) and 20.104 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 and discussed the use of- this equipment with radiation protection personnel.

The inspector reviewed the MPC hour logbook for 1986, which contained the MPC hour entries accumulated by all radiation

, workers. In all cases, the respiratory protective device used had been supplied air hoods and a protective factor of 1,000 had been taken. All MPC hours were found to be less than the limits for-exposure of individuals to airborne radioactivity as specified in 10 CFR 20.103(a) or the 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> control measure specified by 10 CFR 20.103(b)(2). All MPC hour assignments had been made from breathing zone (lapel) air sauple measurements.

The inspector also reviewed the results of selected fixed air samplers from July to December 1986. In all cases, fixed air sample results showed average concentrations (filters changed weekly) of less than ten percent of MPC.

No deviations were identified.

b. Posting of Notices 10 CFR 19.11 requires posting of Form NRC-3, the license and other pertinent information. If posting a document is not practicable, the licensee is permitted to post a notice which describes the document and states 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 i notice describing the document and where it may be examined. The l inspector verified that the documents were available for review at the location specified by the posting.

No violations or deviations wcet ide tified.

c. External Exposure Control (1) Dose 10 CFR 20.101 specifies the applicable dose standards. The inspector reviewed records of personnel radiation exposures during the period January to September 1986, and verified that the radiation doses recorded for plant personnel were within the quarterly exposure limits of 10 CFR 20.101. As of September 30, 1986, the highest individual dose received was 2,020 millirem.

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5 (2) Ra'diation Work Permits (RWPs)

Appendix A, Section 6 of the License Application ' requires the .

preparation of-RWPs for operations or maintenance work not covered by an area operating procedure and .which involves. entry into a system containing special nuclear material or where a potential-for release of contamination exists.

The inspector. reviewed Operating Procedure B-HP-1, Preparing and Use of Radiation Work Permits, March 13, 1985. The inspector also reviewed RWP No. 3260, Cell 1 Entry and Wrist Repair, October 1 --

November 3, 1986, and RWP No. 3246, Perform Spent Fuel Dissolution, August 14 - September 26, 1986, and-verified that the RWPs were prepared and the work controlled consistent with B-HP-1, applicable regulations and license requirements.

(3) Surveys and Monitoring 10 CFR 20.201(b) requires each licensee to make or cause to be made such surveys as-may be necessary for the licensee to comply with the regulations and are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present.

During tours of the facility, the inspector performed surveys using NRC equipment and compared the results with survey records maintained by the licensee. The inspector reviewed selected records of contamination surveys performed during the period January to December 1986 and verified that contamination survey requirements specified by the license had been met.

No violations or deviations were identified.

d. Posting, Labeling, and Control 10 CFR 20.203 specifies the posting and labeling requirements for areas and containers. During tours of the facility, the inspector observed that areas and containers were posted and labeled as required.

No violations or deviations were identified.

e._ Instruments and Equipment Appendix A, Section 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.

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The following calibration procedures were reviewed:

LRC-TP-47, General Calibration Procedure for Health Physics Instruments, Revision 2, February 27, 1984 LRC-TP-49, Calibration Procedure for Eberline R0-3A/R0-3C, Nuclear Data Cutie Pie and Victoreen Cutie Pie, Revision 3, June 7, 1985 LRC-TP-51, Calibration Procedure for PAC-4G, Gas Proportional Counter, Revision 3, June 1, 1984 LRC-TP-54, Calibration Procedure for Eberline Teletector, November 2, 1978 RDD-1713-01, Measuring Equipment Control and Calibration System (R&DD)

LRC-TP-276, Use of the PRM-7 Microroentgen Meter, Revision 0, May 16, 1985 LRC-TP-282, Use of the RSS-111 Microroentgen Meter, Revision 0, May 3, 1985 The licensee stated that a 150 millicurie source of Cs-137 was used for instrument calibration. The calibration record for the source was reviewed and it was found that a vendor had calibrated the source and attenuators using National Bureau of Standards traceable equipment on February 11, 1985. The licensee utilized a vendor for calibration of very high range and very low range instruments. Calibration records for one high range teletector was reviewed, Serial No. 1000956.

No violations or deviations were identified.

f. Audits License Condition 9 of License No. SNM-778 requires adherence to statements, representations and conditions contained in Appendix A of the License Application.

Appendix A of the License Application, 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, LRC and with a copy to the License Administrator including the areas inspected, findings, and status of action taken to correct previous findings.

The inspector reviewed the monthly radiation safety audits for 1986 and verified that they had been conducted in accordance with a written plan. Quarterly written reports of the monthly audits were reviewed for 1985 and 1986. Areas inspected during the audits were specified in the quarterly reports; however, no findings were enumerated nor was the i

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status of action taken to correct previous findings included. The quarterly reports contained the statement "No problems were noted that were not either corrected at the time or within the next few days."

Failure to document audit findings and status of action taken to correct previous findings of monthly radiation safety audits in quarterly reports to management was identified as an apparent violation of License Condition 9(70-824/86-06-03).

g. Notification and Reports 10 CFR 20 requires certain reports and notifications as follows:

10 CFR 20.402 - Loss or Theft of Material 10 CFR 20.403 - Incidents 10 CFR 20.405 - Overexposure 10 CFR 20.408 - Termination Reports to 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.

No violations or deviations were identified.

5. IE Information Notices (92717)

The inspector determined that the following Information Notices had been received by the licensee, reviewed for applicability and distributed to appropriate personnel.

86 Excessive Skin Exposures Due to Contamination with Hot Particles 86 Evaluation of Questionable Exposure Readings of Licensee Personnel Dosimeters 86 Underresponse of Radiation Survey Instrument to High Radiation Fields 86 Low Level Radioactive Waste Scaling Factors,10 CFR Part 61 86 Problems with Silver Zeolite Sampling of Airborne Radiciodine 86 Delayed Access to Safety-Related Areas and Equipment During Plant Emergencies