ML20236C518

Insp Rept 70-0824/87-01 on 870629-0701.Deviation Noted.Major Areas Inspected:Radiation Protection,Solid Waste Mgt,Solid Waste,Transportation of Radioactive Matls & Followup on Previous Enforcement Issues

ML20236C518
Person / Time
Site:	07000824
Issue date:	07/15/1987
From:	Hosey C, Revins B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236C458	List: ML20236C455 ML20236C505 ML20236C518
References
70-0824-87-01, 70-824-87-1, NUDOCS 8707300093
Download: ML20236C518 (9)

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' in atoug UNITED STATES

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101 MARIETTA STREET,N.W.

ATLANTA, GEORGI A 30323 yo JUL 2 21987 ReportNo.:--70'-824/87-01 Licensee: Babcock and Wilcox Company Lynchburg Research. Center Lynchburg, VA 24505 Docket No: 70-824 License No.: SNM-778 Facility Name: Lynchburg Research Center Inspection Conducted: . June 29 - July 1, 1987 Inspector: l/ h 7 // 5'D7 B. K. Revsin " - Date Signed Accompanying Personnel: H. Bermudez Approved by: f TM~

~ C. M. Hosey, Sectic n Chief 7// f/87 Date Signed Division of Radiation Safety and Safeguards '

SUMMARY

Scope: This routine, unannounced inspection involved onsite inspection in the areas of radiation protection, solid waste management, solid waste, transportation of radioactive materials and followup on previous enforcement

. issues.

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. Results

One deviation - failure to complete steps of the procedure review program.as specified in licensee's letter dated February 19, 1987.

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2 REPORT DETAILS

1. Persons Contacted Licensee Employees

• J. A. Eanes, Manager, Emp'loyee, Community and Regulatory Relations

• D. M. Stevens, Manager, Nondestructive Methods and Diagnostics

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

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

• A. F. Olsen, Senior Licensing Administrator

• S. W. Schilthelm, Senior Health Physicist O. R. Harris,. Health Physics Technician T. Grochowski, Health Physicist J. A. Jakobowski, Records Administrator

• Attended exit interview.

2. Exit Interview The inspection scope and findings were summarized on July 1,1987, with those persons indicated in Paragraph 1 above. One deviation, failure to complete steps of the procedure review program (Paragraph 4.j.), was discussed in detail. 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 (70-824/85-05-02) Failure to ship fissile material in a proper package. The inspector reviewed the licensee's response dated August 28, 1985, and verified that the corrective action specified-in the response had been implemented.

(Closed) Violation (70-824/86-06-01) Failure to implement respiratory protection program requirements. The inspector reviewed the licensee's response dated February 19, 1987, and verified that the corrective action specified in the response had been implemented.

(Closed) Violation (70-824/86-06-03) Failure to delineate audit findings in reports to management. The inspector reviewed the licensee's response dated February 19, 1987, and verified that the corrective action specified in the response had been implemented.

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L4. -Radiation Protection (83822)  ;

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a.. Bioassay Program (1) License l 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 requires health physics (HP) to administer a plutonium bioassay program to include a resample of an individual - within five . working days. when urinalysis results indicate activity -in excess of 0.2 disintegrations- per minute  :

(dpm) per liter.  ;

During a previous inspection (70-824/86-06), the inspector had identified one individual whose June 1,1985 urinalysis result  !

was 0.4 dpm- per liter and for whom no resampling or other followup action had been taken as required. While this value is above the License action level of 0.2 dpm per liter, an activity -  !

of 0.4 dpm per liter is below the limits for irM1ation-specified in 10 CFR 20.103(a)(1) and the.40-hour control measure specified by -10 CFR 20.103(b)(2). In response to the Notice of ,

Violation issued on January 21, 1987, for failure to take -  !

appropriate. action when an action level specified by License

.No. SNf1-778 was exceeded, the licensee stated in a letter dated . I February 19, 1987, that a procedure will be written for urinalysis l results that will specify action levels, calculational-methodology I and eligibility for bioassay and will require documentation of-the actions taken and the evaluations performed in response to positive results. The licensee stated that full compliance had i been achieved as of the date of the letter.

On June 29, 1987, the inspector was informed that while work on a draft procedure had begun, a final procedure had not been approved and implemented that covered the areas specified in the licensee's response. The licensee stated that when their letter o

indicated that full compliance had been achieved, that did not l

mean that the procedure had been developed, but that the records of the individual who had exceeded the License action level had been examined and that all intakes were determined to be below regulatory limits. The inspector stated that the date when full compliance will be achieved included both immediate corrective i actions and corrective actions planned to avoid further violations.

l. The inspector examined the urinalysis results for both plutonium and uranium from January 1,1987 to June 5,1987, and found all ,

results to be below License action levels.

(2) In addition to a urinalyses bioassay program, whole body counts were obtained for workers. Whole body counts were performed l

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4 twice each year by a vendor. . The inspector reviewed the results of the last .whole body counts performed during April 12-22, 1987. All detected activity was well within regulatory limits, and was generally at the lower limit of detection of the whole body counting systems.

No violations or deviations were identified.

b. Air Sampling The licensee is required by 10 CFR 20.103, 20.201(b) and 20.104 to i 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 Maximum Permissable Concentration (MPC) y hour logbook for 1987, 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 assignments for workers were found to be less than the limits for exposure of individuals to airborne radioactivity as specified in 10CFR20.103(a) or the 40-hour control measure specified by k 10 CFR 20.103(b)(2). All MPC hour assignments had been made from breathing zone (lapel) air sample measurements.

The inspector also reviewed the results of selected fixed air samplers from January 1 to June 1,1987. In all cases, fixed air sample results showed average concentrations (filters changed weekly) of less than ten percent of MPC.

,. No violations or deviations were identified.

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c. 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, f i

the inspector verified that entrances to and from areas where licensed activities were conducted, were posted with the required documents or a notice describing the document and where it may be examined. The inspector verified that the documents were available

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L for review at the location specified by the posting.

No violations or deviations were identified.

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d. External Exposure Control 10 CFR 20.101 specifies the applicable dose standards. The inspector reviewed records of personnel . radiation exposures for .1986, and for the period January 1 to May 31,1987, and verified that the radiation doses recorded for plant personnel were within the quarterly exposure limits of 10 CFR 20.101. :For 1986, the two highest individual doses '

were 2470 and 2380 millirem. For the first five months of 1987, the highest doses were 740 and 620 millirem.

No violations or deviations were identified..

e. RadiationWorkPermits(RWPs)

~ Appendix A, Section 6 of the License Application requires the 1 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 selected RWPs written.for Hot Cell work in 1 1987, and verified that adequate HP controls' had been specified for the work. The inspector also reviewed RWP No. 3362, Separation of Headers and Tubes from Shell of Letdown Cooler, June 22 to July 17, 1987. This RWP covered dismantling and inspection of a letdown heat j

exchanger to ascertain the root cause of leakage. The inspector- l i

observed work in progress under this RWP, and found the work to be compatible with requirements of the RWP.

No violations or deviations were identified.  !

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f. 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.

i The inspector reviewed selected records of radiation and contamination surveys performed during the period January to May 1987, and verified that survey requirements specified by the License were met.

No violations or deviations were identified.

g. 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.

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No violations or deviations were identified.

h. Audits License Condition 9 of License No. SNM-778 requires adherence to I statements, representations and conditions contained in Appendix A of i the License Application. 1 i

(1) Appendix A, Section A.6.4.1 of the License Application 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. ]

The inspector reviewed the monthly radiation safety audits for 1987 and verified that they had been conducted in accordance with a written plan. A quarterly report of the monthly audits was reviewed for the fourth quarter of 1986, which was issued on April 12,1987. The licensee stated that the quarterly report q for the first quarter of 1987, had not been issued as of July 1, 1987. The licensee stated that the three to four month time delay in issuance of the quarterly reports was typical due to the priorities placed on various activities. The licensee stated that this situation would improve upon receipt of the new License (due in July 1987) wherein a deadline of two weeks was specified in the new License.

(2) Appendix A, Section A.7.2 of the License Application states that the Safety Audit Subcommittee (SAS) of the Safety Review Committee shall perform audits of LRC operations to assure compliance with safety requirements.

On March 19 and 20, 1987, the SAS conducted an audit of various HP activities which included RWPs, shipping records, posting and labeling, and classification and characterization of solid waste. Deficiencies were noted in the solid waste program which are described in Paragraph 5 below.

No violations or deviations were identified.

1. Instruments and Equipment Appendix A, Section A.9.2.5 of the License Application specifies radiation protection instrumentation and calibration frequency. The inspector observed that the required type and quantity of instruments 4 were available, and found them operable and calibrated as required as evidenced by calibration labels and records.

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i The inspector reviewed the following calibration procedures:

LRC-TP-49, Calibration Procedures for Eberline R0-3A/R0-3C, Nuclear Chicago Cutie Pie /Victoreen Cutie Pie, Revision 4, ,

January 14, 1987 l LRC-TP-50, Calibration Procedure for Eberline GM Counter, Revision 5, January 14, 1987 LRC-TP-311, Calibration Procedure for MSA Portable Pump Air Sampler, Revision 0, March 7,1987 LRC-TP-51, Calibration Procedure for PAC-4G Gas Pmportional Counter, May 30, 1984 LRC-TP-53, Calibration Procedure for Eberline RM-3A and RM-14 and RM-15, Revision 0, November, 1977 4

During reviews of calibration records for personnel monitors (friskers), the inspector noted .that upon occasion, instruments-returned for routine calibration were found to be significantly in 4 error when the licensee performed "as found" instrument readings. In particular, one instrument, RM-3A, Serial No. 1000906, was found to be in error by 20 (in a conservative direction) and 50 percent (in a non-conservative direction) respectively for the previous two calibrations. Since the calibration frequency for friskers is an annual one, the means by which the licensee determined that friskers were operating properly during the yearly interval was discussed.

The licensee stated that daily response checks of the friskers were performed using a cesium-137 source, i.e., the source was placed against the probe and the technician verified that the needle of the l instrument moved upscale. The licensee further stated that except

) for the PAC-4Gs alpha. counters, no source checks were performed for

{ any other instrumentation, i.e., placing a source of known activity (National Bureau of Standards traceable) in a fixed geometry in relation to the detector and verifying that the instrument read accurately, plus or minus a permissible error. .

( The licensee stated that for instrumentation other than friskers, a program was in place for instruments found to be out of calibration upon return for routine calibration. All measurements performed with the suspect instrument were evaluated. However, such a program was l

l not possible for personnel friskers since they were used on a daily basis for release of personnel from contaminated areas. The inspector stated that for that reason it was important to have assurance that friskers were operating properly rather than finding that a frisker may have been giving inaccurate results perhaps as 1

much as a year later. The inspector also stated that performing source checks of instruments prior to use was a standard industry i practice.

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Using a set of NBS traceable sources of technetium-99 (beta maximum j energy of 300 kev) corrected for two pi geometry and 40 percent j backscatter, the inspector source checked several friskers in use. "

The source check was performed on the two ranges most often used by I the licensee. For the lowest activity source, 100 corrected count I per minute (ccpm), six of nine friskers registered no change in activity. For the source of 700 ccpm and using the licensee ]

calculatea efficiency for the instrument, it was determined that l two of five friskers responded 39 and 43 percent high while the I remaining three friskers responded within 10 percent.  !

In further discussion of this issue with the licensee, the licensee I stated that practices in this area would be re-evaluated for all instruments. The inspector stated that this area would be examined during future inspections and would be considered an inspector followupitem(70-824/87-01-01).

No violations or deviations were identified. l

j. Procedures In a letter dated February 19, 1987, the licensee stated in response l to NRC concerns of apparent weaknesses in procedural controls for l radiation protection activities (Inspection Report No. 70-824/86-06) ,

that formalization of the Radiation Protection program would be  !

conducted in a six phase program. Phase 1, defining program l elements, would be complete on April 1,1987 and Phase 2, identifying the regulations, license requirements and technical guidance that apply to each element, would be complete by June 15, 1987 On June 29, 1987, the inspector reviewed the licensee progress in this area. Phase 1 had been completed on schedule and had divided the radiation and safety program into 18 areas. Of these 18 areas, 14 impinged directly on radiation control. In Phase II, the licensee had begun to identify the regulations and standards that were applicable to each area; however, of the 14 areas dealing with radiation control, only 10 had been completed.

The licensee stated that they were aware of the fact that the l June 15, 1987 commitment had not been met but in the press of daily  !

business had forgotten to notify the NRC. The inspector informed the licensee that failure to meet he June 15, 1987 deadline would be considered an apparent deviation from a written commitment to the NRC (70-824/87-01-02).  !

5. Solid Radioactive Waste (84850 and 88035) 10 CFR 20,311 stipulates the requirements for control of transfers of radioactive waste intended for disposal at a land disposal facility.

These requirements include classification and characterization of the waste and a quality control (QC) program to ensure compliance with 10 CFR 61.55 and 61.56. i J

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Through discussion with licensee representatives, the inspector became aware that the licensee did not have a program in place for waste classification and/or characterization in that procedures covering these 4 activities had not been approved and implemented. The licensee stated  !

that a program had never been developed, u1d consequently, except for shipments of contaminated soil from the decommissioning of Building C, no shipments of waste had been made to a land disposal facility for a number j of years. The inspector examined the Radioactive Materials shipment log  ;

and verified that except for three shipments of soil as described above, no waste had been shipped since February,1985. 4 The inspector examined the records of Shipment No. 3186 made on October 23, 1985, and noted that in addition to arums of' contaminated a soil, the shipment contained other drums of compacted trash and filters. l The licensee informed the inspector that classification of the shipment i had been determined from an isotopic analysis of each drum.of soil using a drum scanning system, while the radionuclides content of the remainder of the drums, which contained fission products as well as transuranic radionuclides, had been determined by performing a gamma scan on a sample from each drum for the above shipment.

The inspector discussed 10 CFR 20.311(d)(3) with licensee representatives which requires the licensee to conduct a QC program to assure compliance with waste classification and characterization requirements specified in 10 CFR 61.55 and 61.56. Also discussed was the role of procedures in a QC program. The licensee stated that this deficiency had been recently ,

identified during an internal audit (Paragraph 4.h.2) and that prior to  ;

making other waste shipments, a formal QC program would be put in place. '

The licensee was informed that failure to conduct a QC program for the three waste shipments that had been made in 1985, would normally be considered a violation of 10 CFR 20.311(d)(3). However, the NRC Enforcement Policy as delineated in 10 CFR 2, Appendix C,1986, states  !

that a Notice of Violation will generally not be issued for violations I identified by the licensee provided that the licensee identification meets the criteria specified by 10 CFR 2. The inspector stated that this apparent violation met the required criteria and consequently would be considered licensee identified. The licensee's corrective actions will be reviewed during future inspections (70-824/87-01-03).

6. Transportation-(86740) l 1

10 CFR 71.5(a) requires that each licensee who transports licensed material outside the confines of its plant or other place of use to comply l with the applicable requirements of the Department of Transportation in l 49 CFR Parts 170 through 189.

i The inspector reviewed the records of selected radioactive material shipments made during 1987, and found that the requirements of 49 CFR 170-189 had been met.

No violations or deviations were identified.

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