ML19260B344
| ML19260B344 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 10/18/1979 |
| From: | Gibson A, Millsap W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19260B322 | List: |
| References | |
| 70-0824-79-06, 70-824-79-6, NUDOCS 7912100070 | |
| Download: ML19260B344 (7) | |
Text
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'o UNITED STATES NUCLEAR REGULATORY COMMISSION
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.E REGION 11 0,
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101 MARIETTA ST., N.W., SUITE 3100
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ATLANTA, G EoRCIA 30303 Report No. 70-824/79-06 Licensee:
Babcock and Wilcox Lynchburg Research Center Lynchburg, Virginia 24505 License No. SNM-778 Inspection at Lynchburg Research Center near Lynchburg, Virginia.
Inspected by: [A)h / h m, A
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Date Signed Approved by:
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A. F. Gibson, Section Chief, FFMS Branch Date Signed
SUMMARY
Inspection on September 10-14, 1979 Areas Inspected This routine unannounced inspection involved 38 inspector-hours onsite in the areas of internal and external exposure, liquid and airborne effluents, radia-tion work permits, respirator protection, internal audits, glovebox disposals, picking up and receiving radioactive materials, solid waste, followup on an IE Circular and independent surveys.
Results Of the 12 areas inspected, no apparent items of noncompliance or deviations were identified in 11 areas; one apparent item of noncompliance was found in one area (Infraction - Improper use of respirators - Paragraph 8).
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DETAILS 1.
Persons Contacted Licnesee Employees
- J. C. Engelder, Director, Lynchburg Research Center
- C. E. Bell, Manager of Faciliites
- J. W. Cure, Supervisor, Health and Safety A. F. Olsen, License Administrator
- W. S. Pennington, Health Physics Engineer
- W. R. Sutherland, Quality Assurance Administrator K. D. Long, Nuclear Materials Accountability Specialist J. B. Younger, Senior Technician D. R. Harris, Senior Technician
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on September 14, 1979, with those persons indicated in Paragraph I above.
The licensee was informed of the apparent item of noncompliance discussed in Paragraph 8 and committed to certain actions descc'. bed in Paragraphs 5, 7, 8, 11 and 15.
The licensee agreed to conplete the actions described in Paragraphs 5, 7, 8 and 15 withia 70 days of this exit interview.
3.
Licensee Action on Previous Inspection Findings
-.e Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Internal Exposure Lung and Whole Body Counts a.
The inspector reviewed the results of the vendor lung and whole body counts performed during the following periods: May 17-23, 1978; November 27-30, 1978 and June 12-15,.979.
Of the 151 individual assays for corrosion, activation and mixed fission products, none showed a significant internal deposition; of the eleven individual lung counts for Pu-239 and Am-231, no positive results were obtained; and, of the 28 individual lung counts for U-235, four positive counts were obtained with none exceeding the maximum permissible lung burden.
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. b.
Urinalysis The inspector reviewed the results of urinalysis performed during the first seven months of 1979. Of those individuals assayed for plutonium and other transuranics only one showed a positive count (Pu-239 at 1.610.3 dpm/ sample). This result exceeded the licensee's resample limit of 0.2 dpm/24 hour sample.
As required by license condition 8.2.3, this individual was resampled, this time with no plutonium detected. Of those individuals assayed for uranium during this period, three showed uranium concentrations in excess of the licensee's investigation level of 20 ug/24 hour sample for uranium of less than 4 weight percent enrichment; these individuals were resampled with resulta less than the investigation level.
Determination of the Bioassay Adequacy for One Individual c.
Although no bioassay showed evidence of an exposure exceeding limits, one individual showed repeated evidence (both lung counts and urinaly-sis) of internal uranium. The inspector discussed this with a licensee representative and stated that the bioassay frequency might be inadequate to detect the presence of a transportable compound.
At the time of the exit interview, the inspector asked the licensee to further evaluate and document this individual's exposure to uranium making certain that the bioassay frequency is adequate and with attention to reducing this person's exposure if practical; the licensee agreed to do so.
(70-823/79-06-01) 6.
External Exposure The inspector reviewed the records entitled " Individual Exposure Record" for the period January 1 to June 30, 1979, for 110 individuals employed in Buildings B and C. In no case were the limits described in 10 CFR 20.101 exceeded.
7.
Radiation Work Permits The inspector reviewed several recent Radiation Work Permits (RWP's) and noted several shortcomings. Examples of these deficiencies are: on RWP numbers 1668, 1666, 1665 and 1661, no erpected dose rates were given; on RWP numbers 1681, 1666, 1665 and 1660, the workers failed to indicate the times in and out of the controlled area; and RWP 1648 implied that one individual was respirator qualified when, in fact, he was not. The inspector discussed these deficiencies with a licensee representative who agreed that this situation required improvement. At the time of the exit interview, the licensee agreed to develop a procedure (at present, the RWP form stands alone as self-explanatory) detailing the proper use of the Radiation Work Permit.
(70-824/79-06-02) 1517 240
. 8.
Respiratory Protection Respiratory Protection Program a.
The inspector reviewed with a licensee representative, the respiratory protection program and compared it a8ainst the requirements of Regula-tory Guide 8.15 " Acceptable Programs For Respiratory Protection". The inspector noted that although the licensee's procedures appeared to meet the minimum requirements of Regulatory Guide 8.15, certain proce-dures, such as the ones controlling issuance and return of respirators, training, and inspection and repair, needed strengthening. The licensee representative acknowledged the inspector's comment. At the time of the exit interview, a licensee representative agreed to review and strengthen as needed the written procedures in the light of the guidance provided by Regulatory Guide 8.15 (70-824/79-06-03) b.
Respiratory Physicals The inspector chose from radiation work permits five people who had recently worn respirators and checked to see if they had received the evaluation of physical condition required by Regulatory Guide 8.15; all had.
Selection and Use of Respirators c.
The inspector discussed with a licensee representative his method for properly choosing and using respi:ators; in particular, the inspector asked the licensee representative if on February 5, 1979, when three individuals entered cell #1, their respirators were used such that the average concentration of radioactive materials breathed by the indi-viduals did not exceed the values specified in Table 1, Column I of Appendix B to 10 CFR 20.
The licensee representative stated that they were neither chosen nor used to supply this degree of protection. The inspector stated that this was in noncompliance with 10 CFR 20.103 which states that if a licensee is to take credit for the use of respirators in determining the exposure of individuals to airborne radioactive materials, the equipment is to be used according to Regulatory Guide, in particular, in this case Regulatory Position 2.
(70-824/79-06-04) 9.
Monthly Health Physics Audits The inspector reviewed the reports of the monthly radiation safety audits required by Paragraph 5.3, Appendix A to the license for the months of January through June, 1979. A report was present f:r each monthly audit and the inspector had no questions concerning these audits.
10.
IE Circular No. 79 Bursting of High Pressure Hose and Malfunction of Relief Valve and "0"-Ring in Certain Self-Contained Breathing Apparatus 1517 24/
. The inspector discussed this circular which concerns itself with malfunc-tions in the SurvivAir Mark I SCBA with a licensee representative who stated that this apparatus was not in use at his facility.
The inspector had no further questions.
11.
Liquid Effluents The inspector reviewed with a licensee representative, the methods used to determine the amount of radioactive material reported as released to the environment in a liquid form during January to June 1979 in the letter to the NRC dated August 27, 1979, as required by 10 CFR 70.59.
The inspector reviewed the original data and his determination of the gross beta gamma activity released from the LRC agreed with the licensee's, and indicated that the limit described in 10 CFR 20.106(a) was not exceeded.
- However, the report noted that the total activity reported as released to the environ-ment was corrected for a 50% decontamination efficiency for the NNFD waste treatment plant through which the LRC liquid waste is discharged. The inspector questioned the licensee representative about the basis for using a 50% efficiency for the NNFD waste treatment plant for the types of beta-gamma emitting materials being discharged from the Center.
The licensee representative stated that this was an estimate, believed to be conserva-tive, made by the LRC health physicist and a waste treatment plant engineer.
The inspector stated that such an evaluation was not adequate for use in determining the amount of radioactive material discharged to the environment and asked the licensee to perform a better evaluation of the efficiency of the waste treatment plant for the materials discharged by the LRC; the licensee representative agreed to do so.
At the exit interview, a licensee representative stated that the evaluation would take the form of a detailed calculation or of physical measurements and stated that if measurements were made it would be necessary to await a tank of water with a sufficient concentration of radioactive materials to allow for meaningful measurements; the inspector acknowledged this.
(70-824/79-06-05) 12.
Airborne Effluents The inspector discussed with a licensee representative the methods used to determine the amount of radioactive material reported as released to the environment in airborne form during January to June, 1979 in the letter to the NRC dated August 27, 1979, as required by 10 CFR 70.59.
The inspector also compared the reported airborne releases to the limits on the annual quantity of radioactivity discharged to the t.sironment as airborne effluents stated in License Condition #18 and noted that the releases were well within these limits. The intpector had no further questions concerning airborne effluents.
13.
Independent Surveys The inspector, using an NRC rate meter and 2"X2" NaI gamma scintillator, sarveyed four large common (non-radioactive) trash containers used oy the LRC. No radioactive contamination was found.
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. At the request of the inspector, a licensee representative took sr.3ars, in locations chosen by the inspector, in normally uncontaminated areas of the facility such as hallways, clean machine shop, building entrances, etc.
Those smears were counted for both beta gamma and alpha radioactivity; no significant contamination was found.
14.
Plutonium Glovebox Disposal The inspector toured the plutonium processing area, observed' gloveboxes in various stages of preparation for shipment and discussed the overall project with a licensee representative. The disposal project proceeds generally in this fashion:
the gloveboxes are cleaned (internally), then dried and sprayed with a clear lacquer to fix the remaining material; the boxes are then separated, filled with a rigid foam and externally sealed; the boxes are then moved to a loading area where they are loaded into a Typr A shipping container, foamed into place, welded shut, and loaded into a Type B shipping container; finally, they are shipped to a burial facility.
a.
Procedures The inspector discussed the job planning with a licensee representa-tive noting that the plans had been formalized into t'ce following approved Building C area operating procedures:
C-SP-22 Glovebox Disposal C-SP-23 Glovebox Cleaning and Spraying C-SP-24 Separating of Gloveboxes C-SP-25 Foaming and Sealing Gloveboxes C-SP-26 Movement and Packaging of Sealed Gloveboxes The inspector had no questions concerning these procedures.
b.
Air Sampling (1) The inspector reviewed the results of fixed air samples taken in laboratories 17, 19 and 20 (plutonium labs) during the months of July and August, 1979 and saw no result that exceeded the MPC value for insoluble Pu-239 which constitutes the bulk of the activity in the gloveboxes.
(2) The inspector reviewed the results of breathing zone air samples taken on various people working on the glove box disposal project between June 6 and August 24, 1979, and observed no result that exceeded the MPC value for insoluble Pu-239. A licensee repre-sentative stated that at least one member of each group that has worked with the glove boxes has been provided with a breathing zone air sampler when any possibility of airborne material existed.
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- c.
Bioassay The results of recent plutonium bioassays are discussed in Para-graph 5 of this report. A licensee representative stated that it is the present intention to lung count each individual involved in the disposal project at the next opportunity.
d.
Shipping Container The inspector viewed the film of the free drop test of the steel shipping container required by 49 CFR 173.398 (b)(3)(i. to certify that the container is a Type A packaging. The film shewed the container being dropped from a distance of four feet or to a unyielding concrete slab after the container had been loaded with materials designed to simulate the heaviest expected load. The container impacted on one corner and the damage to the container did not appear to be great enough to substantially reduce the effectiveness of the container.
The inspector had no further questions concerning this matter.
1*.
Picking Up and Receiving Packages of Radioactive Material The inspector questioned a licensee representative about his arrangements for complying with 10 CFR 20.205(a), (b) and (c) which concern themselves with arrangements for picking up and receiving packages of radioactive materials.
The licensee representative explained these arrangements and noted that although they were informal they had proved workable in the past. The inspector stated that the arrangements needed to oe formalized into approved written procedures so that the absences of key personnel would not disable these mechanisms. At the time of the exit interview of licensee representative agreed to prepare approved written procedures to implement 10 CFR 20.205(a), (b) and (c) giving consideration to Regulatory Guide 7.3 " Procedures For Picking Up and Receiving Packages of Radioactive Material".
(70-824/79-06-06) 16.
Shipping Containers The inspector examined the physical condition of drums of waste awaiting a.
shipment to a burial facility, paying attention to rust and structural damage. None of the approximately twenty drums inspected showed any signs of significant deterioration.
b.
At the request of the inspector, a licensee representative opened two drums (Numbers 2174 and 2305), chosen by the inspector, of solidified liquid waste and the contents were inspected. The contents of the drums were in solid form and the drums contained no free standing water. The inspector had no further questions concerning this matter.
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