ML20205B153

Insp Rept 70-0824/86-03 on 860721-25.No Violations or Deviations Noted.Major Areas Inspected:Actions Taken to Complete Requirements of 841221 Confirmatory Action Ltr CAL-824/84-01 & Insp of Radiation Protection & Radwaste Mgt

ML20205B153
Person / Time
Site:	07000824
Issue date:	08/05/1986
From:	Hosey C, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20205B136	List: ML20205B132 ML20205B153
References
70-0824-86-03, 70-824-86-3, CAL-824-84-01, CAL-824-84-1, IEIN-86-024, IEIN-86-044, IEIN-86-046, IEIN-86-24, IEIN-86-44, IEIN-86-46, NUDOCS 8608110534
Download: ML20205B153 (9)

Text

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UNITE *J STATES

[km naio"'o NUCLEAR REGULATORY COMMISSION l l' e REGloN ll l

'g 101 MARIETTA STREET, N.W. l 1

• I I *j ATLANTA, GEORGI A 30323 I s.,*****/

AUG 0 51986 Report No.: 70-824/86 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: Ju y 2 - , 1986 Inspector: h G. L. TrouK Date Signed

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Approved by: .- 1W h[Date Signed rfk C. M. Hose 9 h S'ection Chief Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, announced inspection involved a review of the actions taken by the licensee to complete the requirements of Confirmation of Action Letter CAL-824/84-01 of December 21, 1984, and an inspection of the radiation protection, radioactive waste management and radioactive materials transportation program.

Results: No violations or deviations were identified.

0608110534 860005 PDR ADOCK 07000824 C PDR

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m; REPORT DETAILS l

1. Persons Contacted ,

Licensee Employees ' _-

• A. E. Wehrmeister, Acting Technical Operations Manager

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

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

• A. F. Olsen, Senior License Administrator

• R. H. Lewis, Manager, Chemistry and Nuclear Engineering Section T. L. Hardt, Supervisor, Radioanalytical Chemistry

• S. W. Schilthelm, Senior Health Physicist Other licensee employees contacted included two health physics technicians.

• Attended exit interview.

2. Exit Interview The inspection scope and findings were summarized on July '18,1986, with those persons indicated in Paragraph I above. The inspector described the areas inspected and discussed in detail the Jnspection findings. No dissenting comments were received from the licenste. The licensee did not identify as proprietary any of tne 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' Class II Material in Proper Package. The inspector reviewed and verified the corrective actions as stated in the licensee's letter of Augus,t 28, 1985.

(Closed) Violation 70-824/85-07-01, Failure to Calibrate Pressure Gauges in Breathing Air. Supply. Followup actions are discussad in Paragraph 5.e.(2).

(Closed) Violation 70-824/85-07-02, Failure to control Access to a High Radiation Area. Followup actions are discussed in Paragraph 5.f.(3).

(Closed) Violation 70-824/85-07-03, Failure to Perform Beta Radiation Surveys. Followup actions are discussed in Paragraph 5.h.

4. Confirmation of Action Letter Followup (94703) g

a. As the result of an extremity overexposure'1 Inspection Report No. 70-824/84-06), a Confirc4ation. of Action Letter was issued by Region II on December 21, 1984, to restrict the dissolution and analysis of irradiated fuel samples. By letters dated January 30 and April 8,1985, the licensee was authorized to resume irradiated fuel

3 dissolutions under certain conditions (principally sample radiation levels). On June 23, 1986, the licensee submitted a letter to Region II stating that all of the corrective actions had been completed and requested approval to resume all fuel dissolution activities.

b. The inspector discussed the actions with cognizant supervisors, reviewed the consultant's report and new procedure for har;dling the fue' sampics, observed the shielded hood and sample holder beta shields and the mock-up hood. The inspector determined that the licensee had completed the actions as stated.

c. At the exit interview, the inspector informed licensee management that he had no further questions. However, authority to resume operations would be the subject of separate correspondence. This was acknowledged by licensee management.

5. Radiation Protection (83822)

a. Radiation Protection Procedures Appendix A.6.2.5 of the license application requires that general health physics procedures shall be established, maintained, and followed for all operations involving the processing, handling, and storage of licensed material.

Appendix A.6.5 of the license application requires that work involving the use of licensed material that is not covered by an approved written procedure shall be performed pursuant to a Radiation Work Permit (RWP).

The inspector reviewed selected licensee health physics procedures and l verified that any changes made to those procedures since the last inspection were consistent with applicable regulations and license requirements. The inspector also reviewed five new procedures issued since the last inspection and determined that they were consistent with the license requirements and had been reviewed and approved as specified in plant procedures. Through discussions with licensee representatives and review of selected records, the inspector verified l

that RWPs had been established for radiological work performed during i the calendar year not covered by an approved written procedure.

[ The inspector elso attended an RWP planning and review meeting. The meeting attendees and the topics reviewed were in accordance with the RWP procedure for the facility.

No violations or deviations were identified.

b. Instruments and Equipment -

Appendix A, Paragraph 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 l

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4 were available and found them operable and calibrated as required as evidenced by calibration labeli and records.

No violations er deviations were identified.

c. External Exposure Control 10 CFR 20.101 specified the applicable radiation dose standards. The inspector reviewed records of individual radiation exposure during the period January through June 1986, and verified that the radiation doses recorded for plant personnel were within the quarterly exposure limits of 10 CFR 20.101.

The inspector discussed the exposure limits, permissible doses and extended doses with licensee representatives, and observed the use of dosimetry devices of plant personnel.

No violations or deviations were identified. s

d. Internal Exposure Control The licensee was required by 10 CFR 20.103, 20.201(b) and 20.401 to control uptakes of raaioactive material, assess such uptakes and maintain records. 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.

10 CFR 20.103(a) specified the limits for exposure of individucls to concentrations of radioactive material in air in restricted areas.

This section also required that suitable measurements of concentrations of radioactive material in air be performed to detect and evaluate the airborne radioactivity in restricted areas. The inspector reviewed selected results of general in plant air samples taken during calendar year 1985 and the results of air samples taken to support work

/ authorized by specific radiation work permits.

No individuals had been exposed to greater than two MPC-hrs in a day or 40 MPC-hrs in a week, based on air sample results and authorized protection factors for respiratory protection equipment, if used.

No violations or deviations were identified.

e. Respiratory Protection (1) The inspector reviewed the licensee's respi ratory protection program and determined that the program is documented (Procedure LRC-TP-95), responsibility for the program is assigned, a management policy statement concerning existing respirators, and records of air sampling and respirator use are maintained. The

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5 inspector also verified that respiratory protection equipment in use has NIOSH/MSHA certification.

(2) In Inspection Report No. 70-824/85-07, a violation concerning the failure to use calibrated pressure gauges in supplied-air systems as required by 10 CFR 20, Appendix A Footnote h. was identified (85-07-01). The inspector reviewed the corrective actions specified in the licensee's letter of December 3, 1985, and determined that the actions had been completed. The inspector also observed that the gauges installed in the breathing air system in Building C had calibration stickers affixed and that the gauges are included in the instrumentation QC program printout.

This item is closed for record purposes.

No violations or deviations were identified,

f. Posting, Labeling, and Control (1) During tours through the facility buildings and areas, the inspector observed the postings for different areas, and reviewed survey records to verify that postings were consistent with regulatory requirements. Postings reviewed were for radiation areas (10 CFR 20.203(h)), high radiation areas (10 CFR 20.203(c)),

radioactive material areas (10 CFR 20.203(e)), and container labeling (10 CFR 20.203(f)).

No violations or deviations were identified.

(2) On June 21, 1986, the licensee submitted a report in accordance with 10 CFR 20.405 regarding a radiation area which had been identified in an unrestricted area in excess of the limits of 10 CFR 20.105(b)(2). The inspector reviewed the corrective actions taken to correct the situation, and had no further questions. As this item was identified and corrected by the licensee, in accordance with 10 CFR 2, Appendix C, Part V, no violation is cited.

(3) In Inspection Report No. 70-824/85-07, a violation concerning failure to control access to high radiation areas on the hot cell roof was identified (85-07-02). The inspector reviewed the corrective actions specified in the licensee's letter of December 3, 1985, and discussed the actions with licensee representatives. Action was taken to relocate and shield the materials so that the high radiation area no longer exists.

No violations or deviations were identified.

g. Posting of Notices 10 CFR 19.11 required posting of Form NRC-3, the license and other pertinent information. If posting of a document was not practicable, l

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6 the licensee was permitted to post a notice which described the document and stated 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 notice describing the document and where it may be examined.

No violations or deviations were identified.

h. Surveys In Inspection Report No. 70-824/85-07, a violation concerning the failure to perform beta radiation surveys in the hot cells (85-07-03).

The inspector reviewed the licensee's corrective actions specified in the letter of December 3,1985, and reviewed the surveys of the cask area. The inspector discussed the surveys and survey techniques used in the hot cells to determine beta levels in the area.

No violations or deviations were identified.

1. Notification and Reports 10 CFR 20 required 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 10 CFR 19.13 - Termination reports to the individual Through review of selected records and discussions with licensee l representatives, the inspector determined that the subject requirements had been met.

j No violations or deviations were identified.

6. Radioactive Solid Waste (88035)

a. The inspector reviewed the procedures, shipping records and license requirements for shipments of radioactive waste to the disposal site.

Regulatory requirements in 10 CFR 20.301 and 10 CFR 20.401 for the l

disposal of waste were also reviewed.

No violations or deviations were identified.

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b. 10 CFR 20.304 specified the general r'equirements for disposal of waste by burial in soil. Licensee representatives stated that no disposals have been made under the provisions of this regulation.

No violations or deviations were identified.

7. Radioactive Waste Management (84850)

a. Management Controls The licensee has established procedures for the packing, loading, and shipping of radioactive materials in LRC-TP-XX type procedures. These procedures include the assignment of responsibilities, identification of materials, packaging, surveying, labeling, and noti fying the consignee.

b. Quality Control The procedures and Standard Radioactive Shipment Checklist, as well as the supplemental checklists, specify specific items to be determined and signed off. Additionally, specific requirements exist for quality assurance sign-offs. The inspector reviewed the shipping records for two waste shipments and verified that the required checks had been performed.

c. Waste Manifests 10 CFR 20.311(b) and (c) require that a manifest system be used for all shipments of waste to a licensed burial facility. The inspector determined that the manifests had been completed and forwarded as required for the two waste shipments reviewed.

d. Waste Classification, Characterization, and Labeling 10 CFR 61.55 requires that waste be classified and identified as Class A, B, or C. The inspector reviewed the isotopic survey results for containers in two waste shipments and determined that the classifications shown on the manifests were in agreement with 10 CFR 61.55.

e. Tracking of Shipments The Radioactive Material Shipment procedures and checklists irclude provisions for determining the estimated date of arrival of the shipment, written, and telephone notification of the receiver, as well as forwarding an acknowledgement form with the manifests. The inspector verified that the two waste shipments had been verified as having been received at the disposal site.

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f. Disposal Site License Condition The Radioactive Material Shipment procedures and checklists require that the authority of the consignee to receive the material be verified, whether it be a material shipment or waste shipment. The inspector verified that the licensee had a copy of the burial site license and criteria on file and had verified that the shipments met the license conditions.

No violations or deviations were identified.

8. Transportation Activities (86740)

a. Quality Assurance Program 10 CFR 71.12 provides a general license to transport, or to deliver to a carrier for transport, licensed materials in packages for which a license or certificate of compliance has been issued, provided the licensee has an approved quality assurance program in accordance with 10 CFR 71, Part H.

The inspector determined that the licensee has an NRC approved quality assurance program for packaging, approved under Docket 71-0230, with an expiration date of October 31, 1990.

b. Selection of Packagings The inspector discussed the use of packages which require an NRC Certificate of Compliance with cognizant licensee representatives and reviewed the shipping papers for one shipment. The licensee had the Certificate of Compliance on file (10 CFR 71.12(c)(1)), was registered as a user for the package (10 CFR 71.12(c)(3)), and it was not a foreign-approved packaging requiring DOT revalidation (49 CFR 173.173 or 10 CFR 71.16).

The inspector determined through discussions that DOT Spec 55 containers are not used and the licensee is aware of the prohibition of use (49 CFR 173.415(b)), that no plutonium shipments have been made nor are planned to be made by air (10 CFR 71.88), and the licensee does not rely on special form determinations to qualify shipments (49 CFR 173.469).

c. Preparation of Packages and Delivery to Carrier The inspector determined from review of applicable procedures, review of shipping checklists and review of shipping papers, as well as

9 discussions with licensee representatives, that the following requirements are applied:

Routine use of container (10 CFR 71.01)

Liquid package requirement (49 CFR 173.412(n))

Package weight (49 CFR 173.411)

Package marking (49 CFR 172.300 et. seq.)

Radiation surveys (49 CFR 173.441)

Bracing of packages (49 CFR 173.442)

Shipping paper documentation (49 CFR 172, Subpart C)

• Notification of consignee (10 CFR 20.311)

No violations or deviations were identified.

9. IE Information Notices (IEN) (92717)

The inspector determined that the following information notices had been received by the licensee, reviewed for applicability, distributed to appropriate personnel and that action, as appropriate, was taken or scheduled.

IEN 86-24 Respiratory Users Notice: Increased Inspection Frequency for Certain Self-Contained Breathing Apparatus Air Cylinders IEN 86-44 Failure to Follow Procedures When Working in High Radiation Areas IEN 86-46 -Improper Cleaning and Decontamination of Respiratory Protection Equipment 1