ML20236Q986
| ML20236Q986 | |
| Person / Time | |
|---|---|
| Site: | 07000364, 07003085 |
| Issue date: | 07/08/1998 |
| From: | Todd Jackson, Roberts M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236Q976 | List: |
| References | |
| 70-0364-98-01, 70-3085-98-01, 70-3085-98-1, 70-364-98-1, NUDOCS 9807210168 | |
| Download: ML20236Q986 (10) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket Nos.: 070-00364 070-03085 License No.: SNM-414; SNM-2001 Report No.: 08-01;98-01 Licensee: Babcock & Wilcox (B&W Services, Inc.)
Facility: Parks Township Site and Shallow Land Disposal Area Location: Parks Township, Pennsylvania Date: June 8-12,1998 Inspector: /8 i
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W Todd J. Jhe#sWCHP Health Physicist Approved by: o Mark C. Roberts, Chief Decommissioning and' L'tboratory Branch
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9807210168 980708 PDR ADOCK 07000364 C PDR
EXECUTIVE
SUMMARY
Babcock & Wilcox NRC Combined Inspection Report 070-00364/98-01:070-03085/98-01 This was an unannounced safety inspection of the Parks Township facility and the Shallow Land Disposal Area, operated by B & W Services, Inc. The inspection included review of the licensee's organization, status of decommissioning in site facilities, security and control of radioactive materials, radiation protection and ALARA programs, and radioactive waste handling and shipping. The inspector was accompanied by a representative of the Pennsylvania Department of Environmental Protection.
No violations of NRC requirements were identified. The organizational change to incorporate all functional responsibilities under the on-site General Manager was an effective improvement in management controls. Radioactive material and personnel access were observed to be adequately controlled. Corrections of assigned radiation worker doses for 1994-96 did not show any exposures greater than regulatory limits.
The licensee was investigating circumstances related to two positive bioassay measurements and agreed to keep the NRC informed of results of the investigations.
Airborne releases of radioactive materialin January -May 1998 were within regulatory limits.
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070-00364/98-01:070-03085/98-01
- 1. Management Organization and Controls
- a. Inspection Scone l
l The management of site radiation safety activities and control of decommissioning i operations was reviewed.
- b. Observations and Findinos -
The licensee described organizational changes at ;he site sitae the last routine inspection. Mr. William Heer is the newly ast.irgncd General Manager on-site at the Parks site, responsible for project management. Mr. Richard Bartosik is the new Manager of Licensing, and Mr. Douglas Craig is the new Manager of Environmental, Safety, Health & Quality. The site organization had been restructured to consolidate all site functional organizations under the direction of the General Manager, Mr. Heer. Previously the Health & Safety' organization reported to a manager located in Lynchburg, Virginia.
- c. Conclusions No violations of NRC requirements or safety concerns were identified.
Incorporation of all functional responsibilities under the on-site General Manager was an effective improvement in management controls.
- 11. Facilities
- a. Inspection Scone The inspector toured the site to observe current status and condition of facilities.
- b. Observations and Findinos Buildino A Survey and decontamination work continued in Building A. Final surveys had been completed in portions of the building which were being controlled to prevent recontamination. Other parts were being used to stage waste, and for packaging waste in preparation for shipping. The inspector observes the collection of roofing material samples from the roof over Fab 9 high bay, being collected as prescribed in Engineering Release (ER) procedure "BLDGA 1189". A new ventilation system had been installed in a trailer at the north end of the building. Designated as RF9A, this system provides ventilation to the Fab 6 area. In the trailer are two filter banks, with a pre-filter housed within a shed adjacent to the trailer. The inspector reviewed the new system startup test procedure and readiness j evaluation, completed prior to putting the system into service. l 070-00364/98-01:070-03085/98-01
Fab 8 is being used for temporary storage of materials and waste. A locked aree
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is posted as a high radiation area. This location, the sole remaining posted high '
radiation area on the site, is used for storage of sources and contaminated materials. Access into Fab 6 remains limited following the personnel contaminations !n June 1997. Preparations were in progress for recovery of the interior of Fab G, and these were reviewed in detail by the inspector (see section V.b. below).
Buildino B Samples were being collected from the f% slab and below in the former machine shop. Areas of the building were in variou conditions of decontamination and post-decontamination surveys. Some areas were posted as contaminated.
Buildino C The inspector toured the interior and exterior of the building, including the adjacent utility buildi6g. Condition of the building has been examined durihg several past inspections, and the inspector previously conducted independent measurements for comparison with the licensee's survey measurements (NRC Inspection Report 070-00364/96-01). The licensee submitted a complete post-decontamination survey report to NRC on April 30,1998, and the NRC approved the survey by letter dated May 15,1998.
Also reviewed were the preparations to begin dismantling of the building. The licensee planned to begin mobilizing contractor personnel by June 23,1998,and to begin controlled dismantling in July 1998. Nine engineering releases (ERs) were expected to be generated to control the work, and the inspector reviewed the first five which had been completed. Each reviewed ER included a job safety analysis (JSA) and job. ALARA determination (JAD) as required by the license's procedures. Based on the JADs, none of the Building C dismantling jous required an ALARA review due to the low expected personnel radiation exposures. Each ER specified review and approval by the Industrial Health Specialist, the Manager-Environmental, Safety, Health & Quality (ESH&O), Licensing Manager, the QA/QC Specialist, and an Operations Supervisor. Some of the ERs reviewed had not yet been signed by the Operations Supervisor, due to the planned action to review them with the contractor personnel prior to sign-off. The licensee stated that B&W personnel would be supervising the contractor's work, and the job will be performed under the existing B&W site health and safety program, using B&W procedures.
Those areas in Building C known to be contaminated were marked with paint and ,
identified on survey maps. The licensee planned to further mark these areas with !
high visibility yellow paint to further assure control during dismantling.
l Contaminated sections are to be cut out during dismantling and disposed of at a ,
licensed low-level radioactive waste burial site. Those parts of the structure '
which were inaccessible for survey will either be handled as contaminated, or will be surveyed as they become accessible during dismantling. All structural steel will bt. sent to a facility for potential recovery or disposal. The licensee described 070-00364/98-01:070-03085/98-01
plans for placing additional air samplers in the vicinity of work at Building C during dismantlement. The licensee showed the inspector the planned location for placement of an additional environmental air sampler, expected to be operating during dismantling work. Additionally, the licensee plans to use three temporary air samplers in the vicinity of work, as well as selected bruthing zone air samplers for some of the workers on some jobs to confirm the expected low airborne dust levels. Water misting was also planned by the licensee a.s another means of controlling potential dust generation for work on the uncontaminated areas of the structure.
Other Site Areas The inspector toured the remaining areas of the site, including Building J where some waste was stored prior to shipment, various sheds and fenced yard areas, and the security access checkpoint. Also examined was the Kiskiminetas River bank in the vicinity of site outfall 3. The riverbank remained adequately stabilized following the partial remediation work performed in 1996 by the licensee. The licensee is preparing plans for c'omplete characterization of the soil around outfall 3 piping, and plans to submit them to NRC for approval prior to performing the characterization and remediation work. This area will be reviewed in future inspections.
- c. Conclusions No violations of NRC requirements or safety concerns were identified. Plans for characterization and remediation of the Kiskiminetas riverbank will be reviewed in a future inspection.
Ill. Shallow Land Disposal Area
- a. Inspection Scope Status and condition of the Shallow Land Disposal Area (SLDA) were reviewed.
- Selected groundwater monitoring well data was reviewed, and the collection of groundwater samples was observed.
- b. Observations and Findinas The inspector toured the SLDA to observe the trenches and the monitoring wells.
- The trenches were unchanged in appearance from the last observation of the site
! (1997). Technicians were in the process of collecting water samples from site monitoring wells utilizing procedure ER SLDA 2040 for routine quarterly sampling.
Piles of crushed stone were staged near the trailers at the site, and the licensee stated the stone was being used to maintain and upgrade the roadways on the site used for sampling access. The concrete aprons around the base of numerous monitoring wells were cracked. The licensee informed the inspector that work was planned for 1998 to repair or replace the deteriorated aprons, which will mitigate the potential for surface water intrusion into the wells.
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The inspector reviewed data of groundwater radioactive material concentrations for samples collected in February 1997, May 1997, August 1997, November 1997, and February 1998. Only the May 1997 sample from location MW-22 exceeded the licensee's criteria of 15 pCi/l alpha radioactivity, with a result of 88.98 pCi/l. The licensee followed up this result with a gamma spectrometry measurement at MW-22 using the next quarterly sample in August 1997. Neither gamma spec or t.he routine analysis showed any radioactivity greater .than (
background in August 1997, producing the licensee's conclusion that the May )
1997 result was not indicative of trench-related radioactivity. MW-22 data from February 1998 also contained typical background radioactivity, and was the sample most closely preceding the May 1997 sample.
I Because the data indicate stable and consistent conditions, typically indicating no alpha radioactivity greater than 15 pCi/l, the licensee was considering reducing the frequency of groundwater sample collection from the current quarterly frequency.
The inspector noted that License SNM-2001 permitted the licensee to modify the monitoring program without prior NRC approval as long as the changes do not reduce the overall effectiveness of the progfam.
- c. Conclusions No violations of regulatory requirements or safety concerns were identified.
Licensee actions planned to repair monitoring well aprons will help assure integrity of monitoring data.
IV. Security of Materials
- a. Insptction Scope Security and control of radioactive materials were reviewed.
- b. Observations and Findinas At all times the site was either guarded by access security personnel or was locked. Radioactive material and personnel access were observed to be adequately controlled.
- c. Conclusions No violations of regulatory requirements or safety concerns were identified.
Security and control of radioactive materials was adequate.
V. Radiation Protection
- a. Insoection Scope l The licensee program for protection of workers was reviewed, with emphasis on f the planning for entry into the Fab 6 section of Building A following the personnel i
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l l l contamination incident of June 1997. This inspection focused on the work planning process, monitoring of work in progress, and worker dose assessment.
- b. Observations and Findinas l Work Plannina and Preparations The inspector reviewed the work planning process, including examples of completed job safety analyses (JSA) and job ALARA determinations (JAD).
ALARA reviews involved personnel who would be performing the work. The licensee was planning work related to demolition of the above-grade structure of l l Building C, and also for recovery of Fab 6 in Bu%ng A. Preparations for work in {
Fab 6 were discussed in detail with the licensee. Fab 6 contains significant Pu contamination and therefore presents working conditions different than the balance of the site. ER BA1242 was written for the recovery of the south end of Fab 6, the most contaminated portion of the room. Fab 6 is approximately bisected by a plastic curtain, with recent entries limited to access of the less c6ntaminated north end. The licensee planned to construct a containment for placement over the most contaminated corner of the room, and to vacuum loose material through the containment. Additionally, a smaller containment was planned for use over the vacuum head while cleaning loose materialin the balance of the Fab 6 south end. An aerosol fixative had also been sprayed into the south end to reduc 9 the tendency of loose material on surfaces in the room to become airborne.
Planning considered the airborne concentration of radioactive materials expected to be generated through the recovery activities. Some contingency planning appeared incomplete at the time of this inspection. The licensee was also reviewing the adequacy of pre parations in light of an unexpected internal exposure incurred during work performed at the north end of Fab 6. A positive bioassay result from May 1998 was reported by the licensee's laboratory, indicating an l unanticipated exposure pathway. Although the licensee's preliminary analysis did not indicate excessive personnel exposure, additional review of plans for Fab 6 is warranted. The inspector also discussed with the licensee the need to more l clearly specify exit strategies from the work area in case of unanticipated conditions or occurrences. The licensee stated that additional planning would be conducted before the work proceeded. The conduct of this work and related l internal exposure dose assessments will be reviewed during a future inspection. l l
Airborne Surveys The inspector reviewed recent improvements to the licensee's program for measuring airborne radioactive material and determination of radiation doses from exposure to airborne radioactivity. The radiation work permit (RWP) procedure was revised to collect better data on the duration of exposure. Personnel now sign-in when beginning work and sign-out when leaving the work area, even for short periods such as on breaks. In the past, personnel signed-in at the start of the work day and signed-out at the end of the work day. Additionally, the licensee found that formerly procedures allowed personnel to sign-in on more than 070-00364/98-01:070-03085/98-01 L_____ _ _______ _ _ _
one RWP at a time. These practices required assumptions to be made in l calculating personnel exposure producing excessively conservative dose l assignments. The new practice will provide taore accurate data, enabling more
- accurate dose assignments.
l l The inspector also reviewed licensee re-evaluations of assigned personnel doses
- resulting from the application of dust lo.ading corrections calculated as corrective action to a previous violation (NRC Inspection 070-00364/97-001). Corrections had been made to the assigned committed effective dose equivalent (CEDE) for exposed individuals in the three years 1994-1996. The greatest increases in corrected CEDE for these years was 72% in 1994,207% in 1995, and 102% in 1996. No corrections were necessary for 1997 because the annual doses already accounted for air sample self-absorption corrections. The inspector reviewed the letter sent by the licensee to affected employees, informing them of the revised dose assignments. The licensee had not yet determined if any corrections were required for doses assigned prior to 1994. Results of the evaluation of pre-1994 data will be reviewed during a future inspection.
The licensee had determined during the dose evaluation for 1994-96 that the computer program used was inadequate for continued use in the routine calculation of personnel doses due to exposure to airborne radioactivity at the site.
The program required several simplifying assumptions be made for each individual, allowing only one nuclide and one solubility class to be used in calculations for a year. Because personnel at the Parks site may encounter more than one nuclide, as well as both soluble and insoluble forms, the licensee determined that the model was inappropriate and would no longer be used. The inspector aviewed the revised dose calculation methodology which more precisely accounted for exposure time, nuclide mix, and solubility class as well as necessary self-absorption corrections. The licensee had identified the calculation problem and documented the corrective action taken in Corrective Action Report (CAR) No.97-031, completed on March 31,1998.
Bioassav The licensee described a positive bioassay result for a sample collected in March 15,1998. The result had been confirmed, and the licensee was investigating potential dates and locations in which intake of Pu-239/240 could have occurred.
Dose estimates resulting were indeterminate at the time of the inspection, pending completion of the investigation. The licensee provided the inspector with an interim evaluation of the known circumstances, dated June 11,1998, and stated that a complete report of the final evaluation would be submitted to the NRC at conclusion of the investigation.
Effluent Monitorina The inspector reviewed licensee data for effluents released in 1998. No liquid i
effluents were released from the site. Liquid wastes were collected and/or l
processed for transport offsite by a licensed hauler. Airborne releases of 070-00364/98-01:070-03085/98-01
radioactive materials are continuously sampled, and releases for 1998 were within regulatory limits.
- c. Conclusions No violations of NRC requirements were identified. Corrections of personnel assigned doses for 1994-96 did not show any exposures greater than regulatory l limits. The licensee was investigating circumstances related to twp positive l bioassay measurements and agreed to keep the NRC informed of results of the
! investigations. Completion of the licensee's evaluation of assigned doses prior to 1994 and the planning for recovery of Fab 6 will be reviewed in a future j inspection. Airborne releases of radioactive materialin January -May 1998 were within regulatory limits.
VI. Radioactive Waste Management
- a. Inspection Scope The inspector observed waste packages and containers stored at various locations l around the facility and interviewed personnel responsible for radioactive waste management at the site.
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- b. Observations and Findinos
- The inspector discussed with the licensee the continuing actions to assure waste packages and shipments comply with requirements. ER GENS-6061," Packaged Waste Re-Inspection", defines actions to assure no free standing liquid is present in packages. This procedure requires packages be inspected by four separate site organizations, that drums be punctured to assure no free liquid has accumulated in the bottom and resealed, and that adsorbent be added to assure no liquid remains ,
from unanticipated changes during transport. The licensee stated that the use of l tamper seats has also been expanded to obtain greater assurance that packages !
are not changed following inspection. )
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- c. Conclusions j 1
No violations of NRC requirements or safety concerns were identified. Successful i l
shipments to burial sites had been made since the last NRC inspection in December 1997.
Vll. Management Meeting The inspectors presented the inspection results to the licensee representatives identified on the following page at the conclusion of the inspection on June 11,1998. The licensee acknowledged the findings presented.
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PARTIAL LIST OF PERSONS CONTACTED Licensee William Heer, General Manager Parks Project Douglas Craig, Manager, Environmental, Safety, Health & Quality Rich Bartosik, Manager, Licensing David Fogel, Parks Project Engineering Manager Douglas C!uca, Health & Saf.ety Supervisor David Connor, Operations Superintendent- -
Kenneth Conway, Health Physics Engineering Supervisor Lori Galo, SLDA Engineer; BWSI Data Manager Pennsvivania Department of Environmental Protection Roy Woods, Bureau of Radiation Protection l
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