ML19309C823
| ML19309C823 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/15/1980 |
| From: | Gibson A, Millsap W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19309C817 | List: |
| References | |
| 70-1201-80-01, 70-1201-80-1, NUDOCS 8004090302 | |
| Download: ML19309C823 (11) | |
Text
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%'n UNITED STATES NUCLEAR REGULATORY COMMISSION E
REGION 11 4
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'f 101 MARIETTA ST., N.W.. SulTE 3100 b
ATLANTA, GEORGIA 30303 o
Report No. 70-1201/80-1 Licensee: Babcock and Wilcox Company Lynchburg, Virginia 24505 Facility Name:
Commercial Nuclear Fuel Plant Docket No. 70-1201 License No. SNM-1168 Inspection at B&W Commercial Nuclear. Fuel Plant near Lynchburg, VA Inspector:
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Date Signed Approved by:
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f,J1'w 2 fl6 l A. F. Cibson, Section Chief, FFMS Branch Date Signed
SUMMARY
Inspection on January 14-18, 1980 Areas Inspected This routine, unannounced inspection involved 36 inspector-hours onsite in the areas of radioactive airborne effluents; radioactive liquid effluents; procedures for controlling the release of effluents; laboratory counting instruments; efflu-ent reports; IE Bulletins, Circulars and Information Notices; routine use of pack-ages; various DOT requirements; and follow-up on previous inspection findings.
Results Of the nine areas inspected, no items of noncompliance or deviations were identi-fied.
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4 DETAILS 1.
Persons Contacted Licensee Employees
- W. F. Heer, Manager, Virginia Operations T. H. Killingsworth, Manager, Production Planning and Control
- D. W. Zeff, Manager, Safety and Licensing
- R.
L. Vinton, Health Physicist
- P. A. Cure, Associate Health Physicist J. E. Creager, Production Planning and Control
- K. E. Shy, Foreman, Health and Safety J. T. Anderson, NMC Technician
- Attended exit inte rview 2.
Exit Interview The inspection scope and findings were summarized on January 18, 1980, with those persons indicated in Paragraph 1 above.
A licensee representative agreed to the change in calculational method discussed in paragraph 9.
3.
Licensee Action on Previous Inspection Findings (Closed)(77-02-02) Unresolved Item: Radioactive Liquid Releases to Unre-stricted Areas. Concentrations of radioactive material in liquid effluents have been below the license action level for several months. This item is closed. (Details, paragraph 6.c)
(Closed)(78-15-02) Open Item: Airborne Concentrations in the Vicinity of the Grinder.
The inspector discussed this with a licensee representative who stated that the grinder hood had been further enclosed and the design of the pellet dryer, located adjacent to the grinder, had been improved and that these improvements had reduced the airborne concentrations in the vicinity of the grinder. The inspector reviewed the quarterly average MPC values for this station for the first three quarters of 1979 and noted that they were all less that the license action point of 25% MPC. The inspector had no further questions.
(Closed)(79-02-01) Open Item:
Incorporating Latest Liquid Waste Retention Tank Calibration into Procedure No. AS-Il04. The inspector discussed this with a licensee representative who stated that this information had been added to the procedure and showed a copy of the updated procedure to the inspector. The inspector had no further questions.
(Closed)(79-02-02) Infraction: Failure to Isokinetically Sample the Pellet-izing Recirculation System Air.
The inspector inspected the sampling system on this duct and noted none of the deficiencies described in Region II Report No. 70-1201/79-02, paragraph 6.a(3). This item is closed. (Details, paragraph 5.a(1))
. J (0 pen)(79-02-03) Deficiency: Failure to include Pelletizing Recirculation System Damper Effluent in the Semi-Annual Ef fluent Report. The inspector discussed this with a licensee representative who agreed to make certain changes in the method used to determined the magnitude of this release.
This item remains open. (Details, paragraph 9. )
(Closed)(79-02-04) Open Item: Revise Liquid Effluent Procedure to Include Mixing Time f or the Liquid Waste Retention Tanks. The inspector reviewed Revision 3, dated March 7, 1979, of Procedure No. AS-1104 " Contaminated Liquid Ef fluent Control" which specifies, in paragraph 6.1.4, sparging for a minimum of ten minutes. This item is closed.
(Closed)(79-02-05) Open Item:
Revise the Liquid Effluent Procedure to include the Investigation Required by License Condition 8.1.2.
The inspector reviewed Revision 3, dated March 7,1979, of Procedure No. AS-1104 "Contami-nated Liquid Effluent Control" and verified that this investigation had been added to the procedure. The inspector had no further questions.
(Closed)(79-02-06) Open Item:
Bring the Pelletizing Recirculation System Damper Effluent under License Condition 8.1.
1(c) Controls by Procedure.
The inspector reviewed Revision 4, dated March 13, 1979, of Procedure No.
AS-Il03 " Airborne Radioactive Materials Control" and noted that this release pathway had been brought under the required controls. This item is closed.
5.
Radioactive Airborne Effluents Tour of the Facility a.
The inspector toured the facility and discussed with a licensee repre-sentative the general design of the plant's ventilation system used to handle contaminated ef fluents from the pelletizing area, as well as certain particular features of these ventilation systems. The results of these ef forts are given below:
(1) Physical Inspection of the Pelletizing Area Stack and Pelletizing Recirculation System Sampling Systems The inspector examined the sampling arrangement on these two systems and noted that the sampling probes were securely fixed to the ducts and properly oriented with respect to the air flow; that the filter housings had gaskets and were tightly closed; and that air flow was being maintained through the sampling probe.
This verifies the licensee's corrective action concerning the item of noncompliance (70-1201/79-02-02) due to anisokinetic sampling of the pelletizing recirculation system discussed in Region II Report No. 70-1201/79-02. The inspector stated that this item of noncompliance is closed.
The inspector had no further questions concerning this matter.
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. d (2) Dif ferential Pressure Gauges on Filters The inspector noted the presence of differential pressure measu-ring devices on the HEPA filters in the pelletizing stack filter system and the pelletizing recirculation filter system as required by License Condition 8.1.1(a); the inspector also noted that in no case did the differential pressure across these filters exceed the license limit. of four inches of water. The inspector examined 24 prefilters serving equipment in the pelletizing area for the presence of the differential pressure measuring devices required by License Condition 8.1.1(d); in all cases, the devices were present and in no cases was the differential pressure across the filters excessive. The inspector had no further questions concern-ing this matter.
(3) Storage of HEPA Filters The inspector examined the licensee's storage of HEPA filters and saw no case of improper storage.
The inspector had no further questions concerning this matter.
b.
Records of Pelletizing Stack Effluents The inspector examined the records, entitled Area Air Effluent Records for the Controlled Area Effluent, of the releases of radioactive materials out the pelletizing stack for the time period from January 2 to December 2,1979. The inspector noted no case where the concentration of radioactive materials exceeded 10% of the unrestricted area MPC which constitutes compliance with the limits set by 10 CFR 20.106 and the most restrictive case set by License Condition 8.1.1(c).
The inspector had no further questious concerning these records.
Quarterly Verification of Isokinetic Sampling c.
The inspector examined the records, entitled Isokinetic Air Sampling Hate Meter Calculations, of the licensee's quarterly efforts, required by Procedure No. AS-1103 Revision 4 " Airborne Radioactive Materials Control", to assure isokinetic sampling of the pelletizing stack and pelletizing recirculat. ion system.
The records for each quarter of 1979 were present and adequate. The inspector had no further questions concerning this matter, d.
Records of Weekly Checks of HEPA Filter Differential Pressure Gauges The licensee is required by License Condition 8.1.1(a) to weekly check the differential pressure gauges monitoring HEPA filters and to replace the filters when the differential pressure exceeds four inches of water.
The inspector reviewed the records, entitled Manometer and Magnahelic Audit Record, of these checks for the time period from 1/4/79 to 12/19/79. The inspector noted that the records were present
4 e and noted no case where the differential pressure exceeded four inches of water.
The inspector had no further questions concerning these records.
Annual Efficiency Tests of HEPA Filtration System e.
License Condition 8.1.1 requires an annual efficiency evaluation of HEPA filtration systems used to filter airborne effluent streams; additionally, the systems are to be tested upon installation of new filters and following major maintenance. The inspector reviewed an an internal memorandum entitled "DOP Testing of Ef fluent and Recirculation Air Cleaning Systems" dated May 29, 1979, which stated that the required tests had been completed on May 21, 1979, and noted that the stated system efficiencies exceeded the minimum acceptable system efficiency of 99.90%. A licensee representative stated that there had been no maintenance or filter change in the past year. The inspector had no further questions concerning this matter.
6.
Radioactive Liquid Effluent Radioactive Liquid Effluent Records a.
The inspector reviewed the records of the releases of liquid radioactive materials to unrestricted areas, entitled Liquid Effluent Record, for the time period from 1-2-79 to 12-24-79. The inspector noted no case, as required by License Condition 8.1.2, where liquid whose concentration of radioactive material exceeded 75% of unrestricted area MPC was dis-charged.
The inspector chose two examples (Release No. 68 on 5/25/79 and Release No. 89 on 7/9/79) of liquid releases whose concentration exceeded 21% but not 75% of unrestricted area MPC and determined that the requirements of License Condition 8.1.2 had been met. The inspec-tor further chose five examples (Release Nos. 8, 42, 65, 101, and 152) of liquid releases whose concentrations were between 6% and 20% of unrestricted area MPC and determined that the requirements of License Condition 8.1.2 had been met. The inspector had no further questions concerning this matter.
b.
Inspection of Retention Tanks for Sludge Accumulation License Condition 8.1.2(a) requires that the retention tanks be inspected -
monthly for sludge accumulation.
A review of the record entitled Liquid Effluent Record for the time period 1/2/79 to 12/24/79 revealed that each time a retention tank is released, the tank is inspected for sludge accumulation.
In no case was visible sludge reported. The inspector had no further questions concerning this matter.
Capability of the Liquid Effluent Filter c.
The inspector discussed with a licensee representative the installation and capability of the liquid effluent filter installed to reduce the concentration of radioactive material in liquid effluent to less than 1
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-5 the license limit of 6% of unrestricted area MPC. The licensee repre-sentative stated that the filter was approved for operation on June 12, 1979, and had resulted in a significant decrease in the concentration of radioactive material in liquid effluents discharged to unrestricted The licensee representative provided the inspector with monthly areas.
average MPC values of liquid ef fluents for the year 1979. The inspector noted that for the first five months of 1979 the average values were considerably in excess of 6% MPC and that for the last five months they were less than 6% MPC. The inspector stated that this resolves the concern expressed in Unresolved Item 77-02-02 and that this item is closed.
7.
Procedures for Controlling the Release of Effluents The inspector reviewed the changes which according to the procedures' " Record of Revisions" were made in 1979 to Procedure No. AS-1103 Rev. 4 " Airborne Radioactive Materials Control" and Procedure No. AS-1104 Rev. 3 " Contaminated Liquid Effluent Control" and determined that these changes did not lessen the control the licensee had over his effluent releases. The inspector furt.her determined, by discussion with a licensee representative, that these res ised procedures had undergone complete review and approval. The inspector Fad no further questions concerning these matters.
8.
Laboratory Counting Instruments a.
Instrument Calibration The inspector reviewed the records of the calibrations of the NMC PCC-IIT proportional counter, which is used to count all liquid and airborne effluent samples, for the year 1979. All records were present and the calibration method appeared adequate. The inspector had no further questions concerning the calibration of this instrument.
b.
Instrument Sensitivity License Condition 8.3.2 states that the analytical capability for evalu-ation of ef fluent samples shall be such that instrument sensitivity and sample preparation techniques allow:
(1) 0.5% of the appropriate MPC for liquids; (2) 10.0% of the appropriate MPC for airborne effluents.
The inspector discussed with a licensee representative his method of satisfying this license condition and was informed that the method used was taken from NBS Handbook 80, "A Manual of Radioactivity Proce-dures".
The inspector reviewed the licensee's calculations and they appeared to be in order.
The inspector had no further questions l
concerning this matter.
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9.
Semi-Annual Effluent Report
'Ihe inspector reviewed the semi-annual ef fluent report for the first six months of 1979 transmitted to Region-II in ~a letter dated August 13, 1979, as required by 10 CFR 70.59. This regulation requires that the report be submitted within 60 days of July 1, 1979, and that it contain the quantity of each principle radionuclide released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation. The inspector noted that the report was submitted within the required time frame and that it listed the principal radionuclides to be expected. The inspector discussed with a licensee representative the means used to include the effluent from the damper on the pelletizing recirculation system in the semi-annual report; the licensee's previous failure to do so is discussed in Region II Report No. 70-1201/79-02 and the licensee response, cated March 1, 19,79, to this report. The licensee representative stated that the amounts of airborne radioactive material included in the semi-annual reports as discharged to unrestricted areas by this pathway were calculated upon the basis of the damper being open 50% of the time and during the time the damper is open 50% of the air in the recirculation system is discharged to unrestricted areas; the licensee representative further stated that physical measurements have shown these assumptions to be conservative. After further discussion and review of the pertinent measurements, the inspector agreed that this method of calculation produced conservative results. However, the inspector stated that a better estimate of the amount of radioactive material discharged by this pathway could be obtained from the information presently being gathered by t'ae licensee; the inspector further stated that a calculation based on weekly averages would be reasonable and adequate. At the time of the exit interview, a licensee representative agreed to perform the calcula-tion upon this basis in the future.
Item 70-1201/79-02-03 (deficiency) remains open.
10.
IE Bulletins, Circulars and Information Notices a.
IE Bulletin No. 78-07, " Protection Afforded by Air-Line Respirators and Supplied-Air Hoods" The inspector discussed this bulletin with a licensee representative who stated that neither air-line respirators nor supplied-air hoods were used at this facility.
The inspector had no further questions concerning this matter.
b.
IE Circular No. 79-09, " Occurrences of Split or Punctured Regulator Diaphragms in Certain Self-Contained Breathing Apparatus" The inspector discussed this Circular with a licensee representative who stated that the types of SCBA described in this Circular were not used at this facility. The inspector had no further questions concerning this matter.
~7-e c.
IE Circular No. 79-15, " Bursting of High Pressure Hose and Malfunction of Relief Valve and "0"-Ring in Certain Self-Contained Breathing Apparatus" The inspector discussed this Circular with a licensee representative who stated that the type of SCBA described in this Circular was not used at this facility. The inspector had no further questions concerning this matter.
d.
IE Information Notice Nc. 79-08, " Interconnection of Contaminated Systems with Service Air Systems Used as the Source of Breathing Air" The inspector discussed this Information Notice with a licensee repre-sentative who stated that this facility did not have a plant breathing air system. The inspector had no further questions concerning,this i
matter.
11.
Routine Use of Packages 1
The inspector discussed with a licensee representative his routine use of packages for the shipment of licensed material and reviewed with him certain 1
specific regulatory requirements surrounding this use.
Pertinent aspects of this review are discussed below, Maintenance of Certificates of Compliance and Referenced Documents a.
The inspector determined, by discussion with a licensee representative and review of documents, that the licensee had copies of the certificates of compliance and referenced documents, as required by 10 CFR 71.12(b),
for the following packages recently used by the licensee: Model B, BB-250-2 and the LA-36. The inspector had no further questions concern-ing this matter.
b.
Routine Determinations Concerning the Model B Shipping Container The inspector chose the Model B shipping container, used to ship new fuel, as an example and reviewed with a licensee representative his method of assuring compliance with the routine determinations required by 10 CFR 71.54(a)-(i). The inspector determine that items (a), (b),
(c) and (i) are covered by Procedure No. MA-470 Rev. 10 " Fuel Assembly Packing and Shipping" and that (d)-(h) are not applicable to this container.
The inspector had no further questions concerning this matter.
c.
Loading and Closing of the Model B Shipping Container The inspector observed the loading and_ closing of a Model B shipping container and noted that it was being done in accordance with written procedures; for example, routine determinations on the packaging prior to loading were completed in accordance with Procedure No. MA-470 Rev. 10 " Fuel Assembly Packing and Shipping" Attachment A entitled i
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" Fuel Assembly Shipping Container Preloading and Maintenance Check List." The inspector physically inspected this shipping container and noted that it appeared to be in good physical condition and that the sealing gasket was present and free from defects. The inspector had no further questions concerning this matter.
d.
Opening Inst ructions The inspector asked a licensee representative if the consigners of Model B shipments were provided, as required by 10 CFR 71.55, with any special Instructions needed to safely open the package. The licensee representative stated that opening instructions were provided to consignees. The inspector had no further questions concerning this matter.
c.
Reports The inspector discussed with a licensee representative the reporting requirement stated in 10 CFR 71.61 and ask him if he knew of any instance where the effectiveness of the Model B shipping container had been substantially reduced during use.
The licensee representative stated that he knew of the reporting requirement but that. he knew of no case where the effcctiveness of the Model B shipping container had been reduced during use.
The inspector had no further questions concerning this matter.
f.
Records The inspector discussed with a licensee representative the two year maintenance of certain records of fissile shipments as required by 10 CFR 71.62.
The licensee representative showed the inspector the records of fissile shipments for the years 1977, 1978 and 1979 and stated that, to his knowledge, all such records were presently being maintained indefinitely. The inspector chose a fissile shipment dated 10/18/79 and compared its records against the requirements of 10 CFR 71.62 (1)-(10); all applicable requirements were being met.
The inspector had no further questions concerning this matter.
12.
DOT Requirements a.
Shipping Papers The inspector discussed with a licensee representative his preparation of shipping papers for shipping radioactive material, specifically the identification of the radioactive material by nuclide and curie quantity (49 CFR 172.203(d)) as well as the shipper certification (49 CFR 172.204(a)) that the material is properly classified, described, packaged and marked for transport. The licensee representative showed the inspector Procedure No. AS-AD-Illl, Rev. 2, " Shipment and Receipt
-o-..
- of Radioactive Material" and Procedure No. NM-1610, Rev. O, "Documenta-tion of Scrap Shipments" which adequately covers these matters for both fuel assembly shipments and scrap fuel shipments. The inspector had no further questions concerning thic matter.
b.
Package Markings The inspector chose a model B shipping container, readied for shipment, and examined it for the proper markings.
The package was properly marked with the certificate number (Certificate of Compliance USA /6206/
AF), quantity (49 CFR 172.310(2))(Type A) and proper shipping name (49 CFR 172.101) (Radioactive Material, Fissile, n. o. s.).
The inspector had no further questions concerning this matter.
c.
Warning Labels The inspector examined several Model B shipping containers which were ready for shipment for the proper warning labels. Each container had Yellow III warning labels on two opposite sides, as required by 49 CFR 172.403(d)&(f).
The inspector had no further questions concerning this matter, d.
Placards The inspectors asked a licensee representative if the licensee provides the proper placards to the carrier if the vehicle is not already properly placarded (49 CFR 172). The licensee representative stated that such pla-cards were provided if necessary. The inspector had no further questions concerning this matter.
Licensee Control of Radioactive Contamination on Packaging e.
The inspector questioned a licensee representative about his means to control radioactive contamination on packaging below regulatory limits (49 CFR 173.397). The licensee representative stated that this was controlled by the two procedures referenced in paragraph 12.a above; the inspector verified this and had no further questions.
f.
Various Other Requirements The inspector verified by discussion and procedure review that the licensee has properly considered, as noted, the following additional DOT requirements: the licensee representative stated that the require-ment for a security seal (49 CFR 173.393(b)) was covered by his procedures; the licensee representative stated that the minimum dimension of all his packages exceed four inches (49 CFR 173.393(c)); the licensee representative stated that the maximum radiation level limitations (49 CFR 173.393(i)&(j) are controlled by the two procedures referenced in paragraph 12.a; the i
0 e licensee representative stated that the maximum surface temperature limits on packages resulting from radioactive thermal decay energy (49 CFR 173.393(e)) are not, due to their nature, applicable to his packages; and the licensee representative stated that the liquid packaging provi-sion (49 CFR 173.393(g)) are not applicable to his packagings since he does not ship Type A quantities of radioactive material in liquid form.
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