ML20133D567

Insp Rept 70-0824/85-01 on 850415-19.Violation Noted:Failure to Properly Post Radiation Area

ML20133D567
Person / Time
Site:	07000824
Issue date:	05/07/1985
From:	Hosey C, Lee T, Peery W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133D469	List: ML20133D465 ML20133D500 ML20133D567
References
70-0824-85-01, 70-824-85-1, NUDOCS 8507220237
Download: ML20133D567 (7)

Text

6 p raTo UNITED STATES NUCLEAR REGULATORY COMMISSION 4 p REGION ll y ,j 101 MARIETTA STREET.N.W.

• t ATLANTA, GEORGI A 30323

/ MAY 131985 Report No.: 70-824/85-01 Licensee: Babcock and Wilcox Company Lynchburg Research Center Lynchburg, VA 24505 Docket No.: 70-824 (LRC) License No.: SNM 778 Facility Name: 1.ynchburg Research Center Inspection Conducted: April 15 - 19, 1985 Inspectors: \ I/ 7[85 W. W. Peery 1\ Date Signed T. G. Lee k~ f/7/$.C Datg Signed Approved by: /4 kTN C. M. Hosey, 3ection thief I!?/P)

Date Signed Facilities Radiation Protection Section Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 60 inspector-hours on site in -the areas of radiation protection, radioactive waste management, transporta-tion, followup on a previous enforcement matter involving an extremity over-exposure and followup on two Information Notices.

-Results: One violation - failure to properly post a radiation area.

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8507220237 850513 PDR C

ADOCK 07000824 PDR

2 REPORT DETAILS

1. Licensee Employees Contacted

• T. C. Engelder, Director, Lynchburg Research Center

• A. E. Wehrmeister, Manager, System Development Laboratory

• R. H. Lewis, Manager, Chemical and Nuclear Engineering Section

• H. H. Davis, Manager, Nuclear Materials Section

• P. S. Ayres, Manager, Materials Engineering Laboratory

• J. P. Doran, Manager, Accounting and Administrative Services

• T. L. Hardt, Supervisor, Radiochemistry Group

• J. W. Cure, Supervisor, Health and Safety W.'S. Pennington, Health Physicist J. F. Henderson, Engineer, Post Irradiation Examination Group

• A. F. Olsen, Senior License Administrator J. A. Wilson, Engineer, Radiochemistry Group K.-D. Long, Accountability Specialist

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on April 19, 1985, with those persons indicated in paragraph 1 above. A violation involving failure to post a radiation area as required by 10 CFR 20.203(b) was discussed in detail. Corrective actions and a commitment to preclude a recurrence of a hand overexposure were discussed. Licensee management acknowledged the 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) Violations (84-06-01, 84-06-02, 84-06-03) The three violations -

involved a hand exposure in excess (28.9 rem) of the applicable limits of 18.75 rem of 10 CFR 20.101; failure to make surveys necessary to comply with 10 CFR 20 and failure to follow the procedural requirements of a Radiation Work Permit. An Enforcement Conference was held at NRC, Region II, on January 11, 1985. A Notice of Violation and Proposed Imposition of a Civil Penalty in the amount of Two Thousand Five Hundred Dollars was issued by letter dated February 28, 1985. The inspector verified that the corrective actions presented by the licensee at the Enforcement Conference on 1 January 11, 1985, and contained in letters dated January 10, 1985; January 21, 1985; March 22, 1985, and March 28, 1985, had been completed.

The inspector also reviewed a Health Physics Consultant report dated March 1985 and entitled " Evaluation of an Extremity Exposure at the Lynchburg Research Center" which concluded that:

(1) The' dosimeter (extremity) indicated an exposure which is reasonable and ,

" correct" for the exposure situation. l i

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(2) . Chemist -No. 2 (the overexposed individual) was indeed the maximum exposed individual and his maximum exposure was that indicated by the l

-extremity dosimeter worn on his right hand.

4. Radiation' Protection (83822)

-a. Instruments and Equipment i License No. 778, Appendix A, paragraph A.9.2.5 identifies radiation L . protection ' instrumentation and the ~ frequency of calibration. The

! inspector observed the instrumentation and found it- operable and

[ calibrated as required, as evidenced by calibration labels and records.

i No violations or deviations were identified.

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b. External Exposure Controls,

. -10 'CFR 20.101 specifies -the applicable radiation dose standards. The inspector reviewed the computer printouts (Form NRC-5 equivalent) for 1984 and 1985.

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!- No violations cr deviations were identified.

1 i c. Internal Exposure. Control The licensee was - required by 10 CFR 20.103, 20.101(b), 20.401, 20.403

and 20.405 to control uptakes of radioactive material, assess such uptakes',- and keep records of and make reports of such uptakes. During plant tours the inspector observed the use of ventilation systems and containment enclosures. The inspector discussed the use of this equipment with radiation protection personnel. The inspector reviewed '

! Respiratory Protection Procedures and discussed the program with radiation protection personnel, t

10 CFR 20.103(a) establishes the limits for exposure of-individuals to concentrations of radioactive materials in air in restricted-areas.

4 This section also requires that suitable measurements of concentrations of radioactive materials'in air be performed to detect.and evaluate the i airborne radioactivity in. restricted areas and that appropriate

{. bioassays - be performed to detect and assess individual intakes of i radioactivity.

The inspector reviewed selected results of general in plant air samples taken c'uring calendar year 1984 and 1985 to date and the results of air samples taken to support work authorized by specific radiation work ,

permits. '

The inspector reviewed selected results of bioassays and the licensee's assessment 'of individual intakes of radioactive material performed '

l -during' calendar year 1984 and 1985 to date.

i~ 10 JCFR 20.103(b) requires the licensee to use process or other

[ engineering controls, to the extent' practicable, to- limit i- ,

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concentrations of radioactive material in air to levels below that specified in .Part-20, . Appendix B, Table I, Column 1 or limit t: concentrations, when averaged 'over the number of hours in any week  !

i during which individuals are in -the area, to less than 25 percent of the specified concentrations. The use of process and engineering

controls to' limit airborne radioactivity concentrations in the facilities was discussed with licensee representatives and the use of

such controls was observed during tours.

f.

!~ 10 CFR .20.103(b) requires that when. it is impracticable to apply 4

process or engineering controls to limit concentrations of radioactive material in - air below 25% . of the concentrations specified in

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Appendix B, -Table 1, Column 1, other precautionary measures should be

!. used to maintain the intake of' radioactive material by any individual 1

within seven consecutive days as far below 40 MPC-hours as is reason-L ably J achievable. By review of records, observations and discussions with licensee representatives, the: inspector evaluated the licensee's respiratory' prgtection. program, including training and medical qualifications.

j No violations or deviations were identified. ,

d. Posting, Labeling and Control I

j 10 CFR 20.203 specifies posting and labeling requirements for l containers and areas. During facility tours on April 15, 1985,

independent measurements by the inspector revealed radiation levels of l about.55 mr/hr at two inches and about 6 mr/hr at eighteen inches from l- a shielded radioactive materials sample storage cabinet in the -Fatigue j .and Fracture Laboratory .in' the Hot Cell Area of Building B. The '

i observed radiation levels constituted a radiation area as defined in i

10 CFR 20.202(b)(2) and as such required posting as .specified in 10 CFR 20.203(b). ' The area apparently.had been posted as a radiation. area

.but the sign had fallen and was not visible. Licensee management was

informed that . failure to post the area as a radiation area was a j violation .(85-01-01) of the posting requirements of 10 CFR 20.203(b).

The radiation area sign was replaced 'at .the time of -this -inspection.

i Licensee management informed personnel . present at the exit interview

, -that al_1 posting'should be determined to be as required by the regula-i tions. Containers were observed to' be labeled as required and high

-radiatien areas were lockad and the keys controlled by. Health Physics.

Storage areas - were secured against unauthorized removal ~ of licensed material'as required by 10 CFR 20.207. A Radiation Work Permit system

.is in effect as required by the

license and_ procedures. _

e. Surveys 10 CFR.20.201(b) and 10 CFR 20.401(b) require that appropriate radia-tion-surveys be made and records maintained of the survey results. The finspector reviewed survey records and found that the surveys were being made .and recorded as required. . Leak tests have been performed as

required and the results recorded.

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5 No violations or deviations were identified,

f. Notification and Reports 10 CFR 20 states certain report and notification requirements 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 of work report 10 CFR 19.13 - To Individuals Review of records and discussions by the inspector revealed that the licensee has complied with the above requirements.

No violations or deviations were identified.

5. Radioactive Waste Management (88035)

a. Radioactive Liquid Effluents 10 CFR 20.106 and 10 CFR 20.303 establish limits for releases of radioactive liquid effluents ~ to the unrestricted area. Review of liquid effluent records for the period January 1984 to April 1985, and discussions by the inspector determined that radioactive liquid releases by the licensee have been well below the limits of 10 CFR 20.

b. Radioactive Airborne Effluents 10 CFR 20.106 establishes limits for releases of radioactive airborne effluents. Through review of effluent records for the period January 1984 to April 1985 and discussions the inspector determined that the licensee's radioactive airborne releases have been well below the limits of 10 CFR 20.

c. Records and Reports of Radioactive Effluents 10 CFR 40.65,10 CFR 70.59 and 10 CFR 20.401 state requirements for reporting radioactive effluents and disposals. Review of effluent reports by the inspector verified that the licensee has met the reporting requirements,

d. Liquid and Airborne Effluent Instruments License No. 778, Appendix A, paragraph A.9.2.5 contains requirements for instrument calibration. Review of calibration records and discussions by the inspector revealed that the calibrations have been performed as required.

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e. Radioactive Solid Waste 10 CFR 20.301 and 10 CFR 20.401 contain requirements for disposals and records of disposal of radioactive material. Review of radwaste records and discussions by the inspector revealed that the licensee has complied with the requirements.

f. Waste Burial The licensee performs no waste burials on site.

g. Storage of High-level Liquid Waste

, The licensee has no high-level liquid waste storage on site.

h. Procedures for Controlling the release of effluents Licensee procedures for effluents were reviewed and determinations made that they have been approved by management and supervision and that the procedures are being followed.

No violations or deviations were identified.

6. Waste Management (84850)

a. Through interviews with the licensee and review of applicable procedures the inspector determined chat the responsibilities for radwaste processing had been clearly designated with a clear definition of the authorities and responsibilities.

b. The inspector reviewed the quality control' program of the licensee that assures his ability to maintain compliance with the waste classifica-tion requirements of 10 CFR 61.55 and 61.56. Shipping manifest on shipments were reviewed with particular emphasis on special Nuclear Material.

c. The inspector reviewed the licensee's procedures and records to insure compliance with applicable disposal site license conditions. It was noted that a current version of the disposal site license was on file.

d. The inspector reviewed the certificate of compliance for several of the licensee's packages and examined the documentation supporting his determination that the designs of the packages met the specification of 49 CFR 173.415(a) and 49 CFR 178.350.

No violations or deviations were identified.

7. Transportation Activities (86740)

a. 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of it's place of use or delivers such material to a carrier for transport shall comply with the requirements of 49 CFR Parts 170.through 189.

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-The inspector reviewed the licensee's procedures LRC-TP-237. "Prepara-tion of Waste Shipments to US Ecology Site in Washington," LRC-TP-245

" Estimating Activity of Alpha Emitters by External Radiation Level,"

and LRC-TP-260 " Shipment of Pu contaminated Gloveboxes to US Ecology."

The inspector also reviewed Radioactive Material shipping records 2970 and 3050. Interviews were held with the Accountability Specialist and with the Health Physics supervisor concerning transportation of the above shipments.

b. The inspector determined through discussions that the licensee has clearly delineated individuals, organizational entities, authorities and responsibilities for transportation activities. The inspector also determined that the individuals have received proper training.

c. The inspector reviewed selected receipt records of the licensee and found'them to be consistent with the license condition and the require-ments of 10 CFR 20.205.

d. 10 CFR 71.91 specifies records that the licensee is required to main-tain for non-exempt shipments of radioactive material. The inspector verified that the records required by 10 CFR 71.91 are being maintained by the licensee. In reviewing records it was noted that the licensee has made advance notifications as required by 49 CFR 173.22(b) and 10 CFR 71.89, 10 CFR 73.73.

e. Through discussions and record. reviews the inspector determined that the licensee provides placarding of exclusive use vehicles as required by 49 CFR 173.475(1), 173.445(1), 173.441(c) and 10 CFR 71.87.

No violations or deviations were identified.

8. IE Information Notices (92717)

The following IE Information Notices were reviewed to ensure their receipt and review by appropriate licensee management.

IE-84-24, Physical Qualification of Individuals to Use Respiratory Protective Devices IE 84-40 Emergency Worker Doses No violations or deviations were identified.

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