ML20245K750

Insp Rept 70-1201/89-05 on 890717-20.No Violations & Deviations Noted.Major Areas Inspected:Review of Radiation Protection Program,Including Daily Radiation Protection Activities & Transportation of Radioactive Matl

ML20245K750
Person / Time
Site:	07001201
Issue date:	08/09/1989
From:	Lauer M, Potter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245K639	List: ML20245K635 ML20245K750
References
70-1201-89-05, 70-1201-89-5, NUDOCS 8908210138
Download: ML20245K750 (8)

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' Licensee: : B&W Fuel; Company ' . '

Commercial Nuclear Fuel Plant.

t Lynchburg, VA '24505

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DocketNo.:;L70-12012(CNFP)- '

License No.: SNM-1168 Facility Name: Commercial Nuclear' Fuel Plant

Inspection. Conducted: ' July'17-20, 1989 t/ .

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.Jkt. Potter Chief..

Ih Daty Signed Facilities Radiation Protection Section '

Emergency Preparedness 'and Radiological Protection Branch.

Division of. Radiation Safety and Safeguards

SUMMARY

Scope:

This' . routine, unannounced inspection involved review of the radiation protection; program including daily ~ radiation protection, activities, transportation of radioactive ' material, radioactive wastes management, and Information Notices.

?Results:

Within -the scope ' of the inspection,- no violations or deviations were tidentifisd. The licensee was maintaining an acceptable level of performance in the radiation program areas inspected. Manufacturing processes at the facility

- continue to require relatively limited radiation protection activities.

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i REPORT DETAILS

1. Persons Contacted Licensee Employees

• R. Alto, Plant Manager

• W. Engelke, Manaaer, Quality and Safety

• D. Ferree, Manager, Fuel Operations

• G. Lindsey, Health and Safety Foreman

• K. Shy, Health Physicist

• Attended exit interview

2. Radiation Protection (83822)

a. Organization and Staffing The inspector reviewed the organization and staffing of the onsite health physics (HP) group with respect to criteria contained in Section 5 of the Application for License Number SNM-1168, dated January 29, 1985 and revisions thereto, further referenced in this Report as the' License Application.

Licensee representatives stated that an individual responsible for licensing and compliance issues had recently been added to the Health-Safety Section. Due to the individual's HP background additional technical responsibilities may be assigned within HP in the future. Operational HP staffing under the station Health Physicist included a Health and Safety Supervisor and three technicians. The staffing level and quality was adequate to maintain an appropriate level of safety.

The inspector observed appropriate management involvement in, and oversight of, the HP Program.

No violations or deviations were identified.

b. External Exposure Control The licensee is required by 10 CFR 20.101 and 102 to maintain workers' doses below specified levels. 10 CFR 20.202 requires each licensee to supply appropriate personnel monitoring devices to specific individuals and require the use of such equipment.

The inspector observed proper use of personal dosimetry, specifically thermoluminescent dosimeters, during plant tours. A review of 1989 First Qvarter exposure data verified that no production worker exceeded 100 mrem. Some workers defined as radiation workers at the l j

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plant and wno do the majority of their work at customer reactor sites did receive in excess of 100 mrem however, no quarterly or yearly exposure totals approached the regulatory limits.

No violations or deviations were identified,

c. Internal-Exposure Control )

10 CFR 20.103(a)(1) requires that the quantity of radioactive material inhaled by an individual be limited to 520 Maximum 1 Permissible Concentration hours (MPC-hrs) per calendar quarter as determined using concentrations of radioactive material in air specified in Appendix B, Table I, Column 1.

I The licensee's internal exposure control and personnel dosimetry )

programs were reviewed by the inspector. This included facilities, '

euipment, personnel, records, and procedures used to control i exposures and determine doses.

(1) Respiratory Protection The inspector reviewed 1989 Second Quarter MPC-hour Assignment Records, dated July 12, 1989, which included daily, seven day cumulative, and quarter cumulative exposures. It was observed that 27 individuals had been assigned MPC-br exposures for the quarter. The highest Second Quarter MPC-hr assignments were observed to be 24.4 MPC-hrs and 27.2 MPC-hrs with most totals equal to 1 to 3 MPC-hrs. Licensee representatives stated that no individual had approached _ or exceeded the 40 MPC-hr investigative limit specified in 10 CFR 20.103.

The inspector verified the use of appropriate protection factors in assigning airborne exposures relative to the respiratory protection equipment employed. The inspector also verified that all individuals identified as respirator users had been trained and medically qualified in accordance with Health-Safety Procedure No. AS-1109, Respiratory Protection Program, Revision (Rev.)12.

(2) Engineering Controls Section 8.2.2 of the License Application requires that hood j velocities be measured weekly with a minimum velocity of '

100 linear feet per minute (LFM) maintained. Weekly Hood Air Flow Audits for 1988 and 1989 were reviewed. The inspector verified that the instrument used, a heated thermocouple anemometer, had been calibrated annually by the supplier with a

National Bureau of Standards (NBS) traceable mass flow meter.

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Health-Safety Procedure No. AS-1103, Airborne Radioactive Materials Control (Uranium), Rev.12, required that, on an

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3 annual- basis and/or after major maintenance, the air cleaning systems shall- be D0P tested in accordance with NRC Regulatory Guide 3.2, Efficiency Testing of' Air-Cleaning Systems Containing -

< Devices for Removal of Particles, dated January 8,1973.- The.

. inspector verified that the facility HVAC High Efficiency Particulate Air (HEPA) filter had been'00P tested annually from

, 1986-through'1989, and that the method used was in accordance with Regulatory Guide 3.2.

(3) Air Sampling 10 CFR 20.103(a)(3) states that for purposes of determining compliance with the requirements of this'section, the licensee shall use suitable measurements of concentrations of radioactive '

materials in air. for detecting and evaluating . airborne radioactivity in restricted areas.

Licensee representatives stated that during pellet loading operations, a total .of approximately six stationary air samplers are used with their particulate filters changed every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and counted for alpha radiation. During inquiries into the . alpha counting equipment's capabilities, the -inspector determined that corrections in the raw data to account for alpha absorption and filter efficiency were . not performed. The licensee provided the inspector with studies completed in 1980, which concluded that errors due to filter self-absorption of alpha radiation and filter penetration were negligible. The-inspector reviewed the studies and concurred with the licensee's position.

Quarterly airborne : concentration averages for 1988 Fourth Quarter and 1989 First Quarter were reviewed by the inspector.

This data included stationary and lapel samples broken down into specific' work locations. Most stationary sample averages were less than one percent MPC with most lapel averages less than five percent MPC.

Section 8.2.3 of the License Application requires that if any one air sample measures 100 percent MPC, the location and occurrence shall be investigated. The inspector reviewed -

reports written for air samples exceeding one MPC for 1989.

Three occurrences were identified. In all cases individuals involved had lapel air samplers on for accurate assessment of the air breathed by the worker. All three events were minor with one resulting in an individual seven day cumulative i

exposure of 14.40 MPC-hours. The reports included documentation of investigations and corrective actions.

l' Health-Safety Procedure No. AS-1103 requires that air samplers  !

be calibrated using an air flow meter on a semi annual basis.

The inspector verified compliance with this requirement for 1988

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and 1989, and that a properly calibrated air flow meter had been used. During plant tours, the inspector observed proper air flow settings on stationary air samplers in use.

(4) Bioassay Program Section 8.4.3 of the License Application states that persons who work routinely in areas where there is a potential for bodily intake of radioactive materials shall be subject to determination of the extent of intake and retention by analysis of excreta or body counting. License representatives stated that wholebody counting is performed by a vendor using portable counting equipment, brought to the site twice a year. That frequency may be increased to four times annually.

Urinalysis is performed offsite by a vendor laboratory.

Licensee representatives stated that fluorometric analysis is no longer performed on the urine with only radiometric analysis methodology currently being used. Lung counting and urinalysis capabilities reviewed and documented in Inspection Report No. 70-1201/88-08 were unchanged.

The inspector reviewed urinalysis and lung count results for selected individuals from 1987 through July 1, 1989. No regulatory concerns or excessively high values were observed.

No violations or deviations were identified.

d. Control of Radioactive Materials and Contamination Section 8.4.5 of the License Application contains criteria for monitoring and controlling contamination. Health-Safety procedure No. AS-1105, Surface Contamination Control (Uranium), Rev. 14, implements these criteria. The inspector independently smear surveyed numerous areas within the controlled area and clean area.

Routine survey records were reviewed and found to be completed at the License required frequency. Appropriate posting and labeling was -

observed throughout the facility. Housekeeping in the controlled area was good.

Licensee representatives stated that the amount of area defined as controlled will soon be increased. Activities currently performed in the Service Equipment Refurbishment Facility also known as the ECHO 330 Building will be transferred to a large area within the main building. These activities include work on contaminated equipment used at customer reactor sites. Modifications to the building layout to ensure that the area could be positively controlled as a

l. contaminated area were ongoing.

l- During plant tours, the inspector verified that radiation survey instruments in use or available for use had been calibrated within i

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the past six months as required by Health-Safety Procedure No. AS-1129, Calibration and Maintenance of Radiation Survey Instruments, Rev. 3.

No violations or deviations were identified.

3. Transportation of Radioactive Materials (86740) 10 CFR 71.5(a) requires each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189. The inspector reviewed selected radioactive material shipments and verified that package quality control checklist were completed, where applicable, and that shipping manifests were completed in accordance with DOT regulations.

Licensee representatives stated that to ensure staff cognizance of current transportation regulations the Healtn-Safety Foreman recently completed a Packaging and Transportation of Radioactive Materials course offsite.

No violations or deviations were identified.

4. Radioactive Waste Management (84850, 88035) 10 CFR 20.311 contains requirements for transfer, for disposal, radioactive waste including use of manifests, conduct of a quality control program, and references to Parts 61.55 and 61.56 dictating waste classification and characterization, respectively.

The licensee recently began using the services of a waste broker for the disposal of dry active waste stored on site. The inspector reviewed waste shipments completed in 1989 to the waste broker and directly to a waste site. All applicable regulatory requirements had been met. The inspector also verified that the licensee was in possession of the transferee's license which authorizes the receipt of the type, form, and quantity of byproduct material shipped as required by 10 CFR 30.41(c).

On November 29, 1988, the licensee was notified by a South Carolina waste l site that a State inspector determined that three drums out of a 66 drum shipment on November 28, 1988 were unacceptable due to the presence of rust. The Stute did not believe the drums failed to meet the criteria of a strong tight container. The drums were painted by the waste site I operator and buried. The State of South Carolina informed the NRC.

Shortly after discovery of the rusted drums the licensee committed to the NRC to revise shipping procedures to ensure that all drums shipped are free from rust. The inspector verified that Health-Safety Procedure No. j lill, Shipment & Receipt of Radioactive Materials, Rev.19, included a revised Steel Drum Rad Waste Burial Audit sheet which required all drums to be free of rust and corrosion, j

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No violations or deviations were identified.

5. Audits-Section 6.6 of the License Application requires the conduct of weekly audits by Health-Safety personnel and quarterly audits by independent auditors.

The inspector reviewed Weekly HP Audits from January 6,1989 to July 7, l 1989. The audits included identified deficiencies, the responsible l manager, and follow-up information. Quarterly independent HP audits for l the last half of 1988 and the first half of 1989 were also reviewed by the inspector. The auditor was qualified and independent from the site. The audits appeared to identify legitimate deficiencies, included documented corrective action, and were in accordance with criteria found in Health-Safety Procedure No. AS-1125, Health-Safety Audits, Rev. 8.

No violations or deviations were identified.

6. Information Notices (92717)

The inspector determined that the following Information Notices (IN) had i been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or planned.

1 IN No. 88-32: Prompt Reporting To NRC of Significant Incidents Involving Radioactive Material i

IN No. 88-62: Recent Findings Concerning Implementation of Quality Assurance Programs By Suppliers of Transport Packages IN No. 88-100: Memorandum of Understanding Between NRC and OSHA Relating to NRC Licensed Facilities l

IN No. 89-02: Criminal Prosecution of Licensee's Former President for Intentional Safety Violations i IN No. 89-13: Alternative Waste Management Procedures In Case of Denial of Access to Low-Level Waste Disposal Sites IN No. 89-19: Health Physics Network )

IN No. 89-25: Unauthorized Transfer of Ownership or Control of Licensed Activities IN No. 89-27: Limitation on the Use of Waste Forms and High Integrity ,

Containers for the Disposal of Low-Level Active Waste IN No. 89-47: Potential Problems with Worn or Distorted Hose Clamps on Self-Contained Breathing Apparatus l

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7. Exit Interview The inspection scope and findings were summarized on July 20, 1989, with those persons indicated in Paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection. Dissenting comments were not receiv.ed from the licensee.