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IE:I Form 12. (Jan 75) (Rev) ,

U. S. NUCLEAR RECULATORY CC'CIISSION E

OFFICE OF INSPECTION AND ENFORCDtENT

REGION I.03006117/76-01 0300611703006157/76-01 01006157

IE Inspection Repcrt No: 74 135/76-22 Docket No: 70-13537-04456-01

Licensee: Babcock and Wilcox Company License No : SNM-14537-07030-01

Nuclear Materials Division Priority: 1

P. O. Box 1260 Category: A(1)t

Lynchburg, Virginia 24505 SafeguardsGroup:

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Location: Aoollo. Pennsv1vania '

Type of Licensee: Fuel Processor

Type of Incpection: Routine, Unannounced~~

Dates of Inspec tion: November 15 - 19, 1976

Dates of Previous Ins pec t io n: March 3 - 5, 1976 . ,

Reporting Inspector: # ' I x - ~ -: - [D AT EP. E. Clemons, Radiation Specialist

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R. L. Swetnam, Radi'ation Specialist DATE

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[Other ccompanying Perso . 1: None

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\ )Reviewed By: Y2 v%A - |- b <7 7

P. J. Knapp, Chief, Radiat1h Support DATESectionFuel Facility and Materials Support Branch

8601020216 770112PDH ADOCK 07000135

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SUMMARY OF FINDINGS

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Enforcement Action

Items of Noncompliance

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A. Violations1

,E None.

B. Infractions..a

[ 1. 76-22-01 (SNM-145) - Failure to Make Proper Evaluations

$$10 CFR 20.201 requires an evaluatien of the radiation hazardsincident to the production, use, release, disposal or presenceof radioactive material or other sources or radiation under aspecific set of conditions.

b Contrary to the above, the licensee failed to make evaluations- for the presence of radioactive material on November 15, 1976 and

November 17, 1976. (Details, 4)

2. 76-22-02 - Failure to Follow Respiratory Protection Program

Appendix 3, Part 5.2 of the Health Physics Manual requires thatthe respiratory protection program shall meet the requirementsof American National Standard Z88.2-1969.

Contrary to the above and Section 7.5 of the standard, fourindividuals were observed wearing respirators in such a mannerthat would prevent a good face seal. Two individuals had signi-ficant beard growth, and two other individuals wore surgeoncaps uncer the facepiece of the respirator. These individualswere involved in operations observed on Wednesday morning,November 17, 1976. (Details, 5)

3, 76-01-03 (37-07031-01) - Failure to Complv with Regulations

10 CFR 70.24(a) requires a criticality monitoring system to haveclearly audible alarm signals.

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Contrary to the above, the criticality monitoring system in the ==

[ Laundry Area did not have a clearly audible alarm signal at the 9! time of inspection, in that when the alarm was activated it could --

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not be heard by persons working in the area served by tbs- system. ]-'"'

- (Details, 6) --

! 5[ 4. 76-22-04 - Failure to Follow Procedures -

FE Section 6.1.6, Page I-8, Amendment No. 91, to License SNM-145 =[ *- stat.es that "staf f specialist. .will develop procedures for.

:- safe operation under normal operating conditions. ." Such g. .

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3procedures are contained in the approved Health and Safety

- Manuals and plant personnel are required to follow them. ,

pe3 Contrary to the above, personnel failed to follow approved proce- -

[ dures in the following instances: ME 3

Health and Safety Manual, Section 5.2.9, states that super- 'a.;-

' vision is to be apprised of the results of surv2ys, and is T

F responsible for tahing immec.iate corrective action if-

E Contamination Limits are exceeded. 1E

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Supervision was notified in July, 1976, and September, 1976 gt-

ithat limits were exceeded, but sur c rvision did not take

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I corrective action. (Details, 7)

b b. Appendix 9, Section 3 of the Health and Safety Manual states @

i that " Operating supervisors. . review the proposed work with -p~~.

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the Health, Safety, and Licensing representative. .". .

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b The proposed work associated with the RCWPs issued on Novem-4 ber 15, 1976 and Nover'ber 17, 1976 was not reviewed by the j

5 operating supervisors and a health and safety representative ,,

- according to a license representative. 4

Health and Safety Manual, Section 5.2.16, requires allc.,

personnel to monitor their clothing and shoes before exitings_

I from a controlled contamination area. 1

On Wednesday, November 15, 1976 an employee was observed by) the inspectors leaving the CF-1 area through a side door

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F without monitoring. A second employee was observed by anB inspector on the same day leaving the change room of the- Apollo Uranium Facility without monitoring. (Details, 9),

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d. Health and Safety Manual, Section 5.2.11 permits smoking and,

drinking in areas approved and posted by Health, Safety, and<

Licensing.

? An employee was observed by an inspector on Friday, November; 19, 1976 smoking in an area in the laboratory that was not

_approved and posted by Health, Safety, and Licensing. (Details,

10)i

; 5. 76-01-01 (37-07031-01) - Failure to Follow Procedurese

Section 2.2 of the General Laundry Operating Procedures (Attachmentt A of the Byproduct Material License Application dated July 27,;. 1972) states that detailed operating procedures applicable to the- laundry shall be written, approved by the applicable plant safetyP committee, updated as necessary, and rigidly adhered to by all

applicable personnel.

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Contrary to the above, personnel failed to f ollow approved procedurese

in the following instances:r

n- a. The General Laundry Operating Procedure, Section 2.1.3 requiresI that beta-gamma monitoring is mandatory before removal of pro-

[ tective clothing, and that the protective clothing must be

; removed prior to crossing the change line in the change rocm of

[ the Laundry Processing Area.

[ On Monday evening, November 35, 1976, three employees wereobserved wearing protective clothing in the laundry office area

. by the inspectors. Beta gamma monitoring capability was noty available at the. change line. (Details, 11)

b. Manufacturing Instruction L.O.P. No. 1. Section 4.1 requires

[ the external surface of all incoming containers be surveyed

L for beta-gamma and alpha radiation and the results recordedp on an approved " Received and Shipment" sheet.L

Manufacturing Instruction L.O.P. No. I was not adhered 'o inthat survey results were not recorded as required by Section

F 4.1 from March, 1976 to November, 1976. (Details, 12)

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c. Manutacturing Instruction L.O.P. No. 7 requires:

(1) A one (1) liter sample be cc11ected from the hold-up tank. _

(2) Sludge samples be collected on a monthly basis and analyzedfor special nuclear material.

(3) A visual inspection ba performed each month for sludge build-up in the waste hold-up tanks.

Manufacturing Instruction L.O.P. No. 7 was not adhered to inthat:

-- The licensee failed to collect the one liter liquideffluent sample as required by Section 4.1.2 during.

1976.

-- The licensee failed to collect and analyze sludge samplesfrom the hold-up tanks on a monthly basis as required bySection 6.2 during 1976.

-- The licensee failed to make visaal inspections for sludgebuildup in the waste hold-up tanks as required by Section6.3 during 1976. (Details, 13)

d. Section 2.1.3 of the General Laundry Operating Proceduresrequires personnel and visitors to wear protective clothingin the laundry process area.

Three employees were observed by the inspectors on Tuesday,November 16: 1976 entering the Laundry Process Area withoutlab coats. (Details, 14)

6. 76-01-01 (37-04456-01) - Failure to Leak Test Sources

License Condition 14.A(1) of the Byproduct Material License 37-04456-01 requires that each sealed source containing byproductmaterial, other than Hydrogen 3, with a half-life greater thanthirty days and in any form other than gas shall be tested forleakage and/or contamination at intervals not to exceed sixmonths.

Contrary to this license condition, two sealed sour s, a small

Californium-252 source and a small Strontium-90 sour e, were not

tested for leakage at the required frequency during 1975 and 1976.(Details, 15)

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C. Deficiencies

1. 76-01-02 - Failure to Comply with License Condition (License No.37-07031-01)

Byproduct Material License No. 37-07031-01, Condition No. 11, citesthree individuals as being responsible for the laundry operations.

None of the individuals cited have direct responsibility for the

laundry operations. One person is not with the company, and theother two individuals have other assignments. (Details, 16) y

2. 76-01-02 - Failure to Post Area (License No. 37-04456-01)

10 CFR 20.203(e)(1) requires each area or room in which licensedmaterial is used or stored and which contains any radioactive

material (other than natural uranium or thorium) in an amountexceeding 10 tLmes the quantity of such material specified inAppendix C of 10 CFR 20 shall be conspicuously posted with asign or signs bearing the radiation caution symbol and the words" Caution, Radioactive Material (s)".

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Contrary to the above, the Instrument Shop was not posted asan area containing radioactive material. There were three sourcesin the area exceeding the limits as specified in Appendix C:

Sources Appendix C Limit

Pu (0.5 microcurie) 0.01 microcurieCs-137 (5.0 millicurie) 0.1 millicurie

Co-60 (9.5 millicurie) 0.01 millicurie

(Details, 17)

3. 76-01-03 - Failure to Label Container (License No. 37-04456-01)

10 CFR 20.203(f)(1) and 20.203(f)(2) requi es that each containerof licensed material shall bear a durable, clearly visible labelidentifying the radioactive contents, and the label shall bear theradiation caution symbol and the words " CAUTION, RADI0 ACTIVEMATERIAL" or DANGER RADIOACTIVE MATERIAL"

Contrary to the above, the licensee failed to identify, withan appropriate lavel, a five (5) millicurie cesium-137 sourcepossessed unuer License No. 37-04456-01. (Details, 18)

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Licensee Action on Previously Identified Enforcement Action

Not inspected.

Design Changes

None.. .

Licensee Events

Date of Event Date Reported Regulatory Requirements,

6/ 1/76 6/29/76 10 CFR 20.4055/10/76 6/ 4/76 10 CFR 20.405(a)(3)4/ 5/76 5/ 5/76 10 CFR 20.4053/26/76 4/21/76 10 CFR 20.4053/ 1/76 3/24/76 10 CFR 20.405'

2/21-22/76 3/19/76 10 CFR 20.4052/21/76 3/19/76 10 CFR 20.405

These items will be reviewed during a subsequent inspection.

Other Significant Findings

A. Current Findings

1. Acceptable Areas

No inadequacies were identified during inspettion of the followingareas:

Portable Instrument Calibration Program.Smear Survey Program.Air Sample Program.Personnel Monitoring (TLD) Program.Bio-Assay Program.

2. Unresolved Items. .

None.

3. Infractions and Deficiencies Identified by the Licensee

None.

4. Deviations

None.

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B. Status of Previously Identified Unresolved Items

Not inspected.

Management Interview

A management interview was conducted at Apollo, Pennsylvania on November 19,1976.

Persons Present

W. F. Heer, General ManagerR. A. Williams, Manager, Technical ControlP. E. Fuller, !!anager, Regulatory ComplianceJ. J. Hoynacki, Manager, Low Enriched U. Mfg.R. V. Carlson, Manager, High Enriched 3. Mfg.A. J. Breuer, Manager, Health and SafetyR. D. Corridoni, Coordinator, Health and SafetyB. B. Ernst, Manager, Licensing

( T. A. Bauman, Supervisor, Health and SafetyC. R. Wilson, Auditor, Health and Safety and Radiological Compliance

Items Discussed

A. Purpose of the Inspection<

The purpose of the inspection was to review the Health Physics programassociated with the laundry operations and the high enriched and lowenriched uranium operations, with special emphasis on personnel protec-tion, training, surveys, and instrument calibration.

B. Acceptable Areas

The items discussed are as identified under the "Other Significant

Findings" section of this report.

C. Items of Noncompliance

The items discussed are as identified under the " Enforcement Action" sectioni

of this report.

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j DETAILS6

:! 1. Persons Contacted

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[ T. A. Bauman, Health and Safety Supervisor U.R A. T. Breuer, Health and Safety Manager

R. D. Corridoni, Health and Safety CoordinatorE P. E. Fuller, Compliance Manager

| B. B. Ernst, Licensing Manager. C. R. Wilson, Health and Safety and Radiological Compliance Auditor[ P. Jones, Foreman, Laundry OperationL3 2. Scope of the InspectionFF

h The scope of the inspection consisted of an off-shift audit, a review ofthe laundry operttions and procedures, and a review of the health physicsr

E program concerned with air sampling, bio-assay, instrument calibration,'

source leak test, record keeping, and hood linear face velocity measure-

[ ments.b

3. Plant Records,

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E The inspector reviewed the following records for the periods of August,5 1976 to November, 1976 and found that they appeared to be acceptable.I- Bio-Assay Records.- Personnel Monitoring Records,

g Air Sampling Records.

F Portable Instrument Calibration Records.

,Smear Survey Records.

[- 4. Evaluations,

y On November 15, 1976, on the second shift (4:00 p.m. - 12:00 p.m.) in thea rea known as PC-2 a RCWP operation was pe r f o rmed (pre-filters were

- r' moved from the exhaust system). The licensee representative statedair samples were not taken as the operation was being done. The inspectorobserved a high volume air sample taken at some time after the operationwas completed. The result of this sample could not be representative of

- the condition that existed as the operation was being performed becausethe work itself could be expected to effect the ai rborne concentrr tions.

The Health and Safety Technician that took the sample was not in f o rmed-

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when the job was completed and did not know if his sample was taken lE

immediately arter the job was completed, or three hours after the,

job was completed.K -

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1 On November 17, 1976 the inspector observed another RCWP job being' performed in the low enriched area (exhaust ducting was being

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replaced). Again, the inspector observed that representative air

msamples were not taken in the immediate area of the operations, as =

1 the operacions were being peformed. The inspector identified the 2e

failure to take air samples at appropriate times and appropriate ,j'

locations as no.. compliance with 10 CFR 20.201(b) (26-22-01). -

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Noting that sinca the samples were not representative, adequate-

surveys had not been performed. mm

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5. It was during the exhaust duct replacement operation in the low--

enriched area that the inspector observed two individuals withbeards wearing respirators. Two other individuals wore a surgeon's

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cap under the respirator in such a way as to interfere with the 3face seal. ANSI Z88.2-1969, Section 5, states " .nespirators _!.3

shall not be worn when conditions prevent a good face seal. Such,

conditions may be a growth of beard, sideburns, a skull cap that if;

$ projects under the facepiece. ." The inspector stated that _. .

this was an item of noncompliance (76-22-02) inasmuch as it contra- m

dicts Appendix 3, Part 5. 2 of the Health Phy s':s Manual. +q

i- 6. During the inspection of the laundry area the VAMP VictoreenI Criticality Alarm System was actuated manually by the Heal +h and dE

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- Safety Supervisor on Tuesday, November 16, 1976. He was observed -

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by one of the inspectors. The second inspector standing apprcximately _-- thirty feet away, engaged in conversation with the new compliance

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auditor did not hear the alarm. Criticality alarms must be clearly_

audible to everyone as required by 10 CFR 70.24. This was cited as-

_ an item of noncompliance by the inspector during the exit interview"

(76- 01-03 This item was corrected before the conclusion of the =m

inspection. ,_

- 7. Health and Safety Manual, Section 5.2.9 requires supervision beapprised of the results of surveys, and is responsible for taking -

_ immediate corrective action if contamination limits art exceeded.On two occasions (July, 1976 and September, 1976) supervision was

""= notified that contamination limits in the High Enriched Area were

exceeded. Supervision did not take immediate corrective action as -:

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.zstated by a licensee representative, and this fact was confirmed by

"I- the results of a smear survey taken in the High Enriched Areaduring this inspection. This was cited as an item of noncompliance

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with Amendment 91 of SNM 145 (76-22-04).

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8. Health and Safety Manual Appendix 9, Section 3, requires operating-

supervisors to review proposed RCWP operations with the health and a

safety representative. The two RCWP operations performed on November g*

15, 1976 and November 17, 1976 were initiated by operating super-vison, signed by a health and safety technician and the operat!ons

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conducted and completed, but there was no review of the proposedoperations by Health and Safety. To further complicate the matter,the supervisor of tb~ Tow Enriched Area in which the RCWP operations _

involving the duct war, were being performed on Wednesday morning,November 17, 1976, was not aware of the ongoing operations andneither was he aware of the radiological conditions. The facts

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were obtained by the inspectors during conversation with the Health,

and Safety Supervisor and the supervisor of the Low Enriched Area ion Wednesday morning, November 17, 1976. This was cited s an item :of noncompliance by the inspector during the exit in t e rv i, (76-22- .

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9. Health and Safety Manual, Section 5.2.16 requires all personnel tomonitor their clothing and shoes before exiting from a controlledcontamination area. On Wednesday, November 17, 1976, the inspectors {observed two individuals exiting the contaminated area without j

monitoring. In the first instance a janitor was observed exiting ,

the contaminated area through a side door near the maintenance :

contaminated shop (C.F.-1). In the second instance an individual ;

was observed exiting through the change room of the Apollo Uranium -

Facility without monitoring. This was cited as an item of noncom- -

pliance with Amendment 91 of SNM-145 (76-22-04). -

10. Section 5.2.11 of the Health and Safety Manual permits smoking inapproved and posted areas. On Friday corning, November 19, 1976, 5

an individual was observed by the inspector smoking in the laboratory.-

This area was not approved and posted as a smoking area. This was'cited as an item of noncompliance with Amendment 91 of SNM-145

(76-22-04).

11. Health and Safety Manual Addendum No. 4 Section 2.1.3 states thatbeta-gamma monitoring is mandatory before removal of protectiveclothing, and that the protective clothing must be removed priorto crossing the change line in the change room of the Laundry Processing _

Area. $

On Monday evening, November 15, 1976, three female employees were .

in the office area of the laundry facility. These employees werewearing protective clothing, as observed by the inspectors, in anarea beyond the change line in the change room of the Laundry ProcessingArea.

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: Beta gamma monitoring capability was not available; therefore, thei employees could not perform the required monitoring at the change

line. This was cited as an item of noncompliance with License No.

.37-07030-01 (76-01-01). _

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Manufacturing Instructions L.O.P. No. 1, Section 4.1 requires allj 12.,

incoming containers to be surveyed for beta gamma. .and the.

results recorded on an approved " Received and Shipment" sheet.

There is no record of survey results of incoming containers asobserved by the inspectors for the year 1976. The inspector notedthat this constituted an itam of noncompliance with License No.

37-07030-01 (76-01-01).

13. Manufacturing Instructions L.O.P. No. 7, Section 4.1.2 requiresthat a one liter liquid waste sample be co lected from the holduptank after the liquid waste is circulated for one-half hour.

There are no reccrds available for 1976 to indicate that a oneliter sample had been taken. A 50 milliliter sample is beingcollected instead according to a licensee representative. Theinspector noted that this was an item of noncompliance with LicenseNo. 37-07030-01 (76-01-01).

Section 6.2 of the same Manufacturing Instructions requires that asludge sample from the holdup tank be collected and analyzed monthlyfor special nuclear material. This has not been done as statedduring 1976 according to a licensee representative. The inspectorstated this was an item of nonco.pliance with License No. 37-07030-01

(76-01-01).- Section 6.3 of M.I.L.O.P. No. 7 requires monthly visual inspections

for sludge buildup in the waste holdup tanks. This is not beingdone as stated according to a licensee representative. The inspectorstated this was an item of noncompliance with License No. 37-07030-01(76-01-01).

14. Section 2.1.3 of the General Laundry Operating Procedures requirespersonnel and visitors to wear protective clothing in the laundryprocess area.

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On Tuesday, November 16, 1976 at lunch time, three individuals wereobserved by the inspector crossing the change line into the controlledcontaminated area of the Laundry Facility without protective clothing.These individuals also carried food and drink into the area. This was

7 cited as an item of noncompliance with License No. 37-07030-01 (76-01-01).

15. License Condition 15.A(1) of Byproduct Material License No. 37-04456-01requires that sources be leak tested at intervals not to exceed sixmonths. Two sources were nc,t leak tested in that time frame as required

as observed by the inspector.

The Strontium-90 Sentron sources were leak tested on November 13, 1976,

April 10, 1976, and May 31, 1975. The Californium-252 source was leaktested on February 3, 1976 and May 31, 1975. This was cited as an itemof noncompliance with Condition 14. A(1) of License No. 37-04456-01(76-01-01).

16. Byproduct Material License No. 37-07031-01, Condition No. 11, citesthe names of three individuals as being responsible for the laundryoperations. One individual cited in Condition No. 11 is no longeremployed by the licensee, and the other two individuals cited do nothave any direct responsibility for the operation. This fact wasobserved by the inspectors as they reviewed the license on Tuesday,November 16, 1976. This was cited as an item of noncompliance withCondition No. 11 of Byproduct Material License No. 37-07031-01 (76-01-02).

17. The Instrument Shop where instruments are repaired and calibratedcontained three sources that are used for calibration as observedby the inspector. The activity of the sources exceeded the exemptquantity limits; therefore, requiring the shop to be conspicuouslyposted as an area containing radioactive materials. The InstrumentShop was not posted as required by 10 CFR 20.203(c)(1) . This was citedas an item of noncompliance (76-01-02). This item was corrected beforethe conclusion of the inspection.

The sources contained in the area were:

Sources Appendix C Limit

Pu (0.5 microcurie) 0.01 microcurie

Cs-137 (5.0 millicurie) 0.1 millicurie

Co-60 (9.5 millicurie) 0.01 millicurie

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18. the five (5) millicurie Cesium-137 Calibration source container isrequired to have a durable, clearly visible label identifying thecontents, and also the caution symbol, and words warning of thepresence of radioactive material. The Cesium-137 source containerwas not labe.11ed as required by 10 CFR 20.203(f)(1) and (f)(2) asobserved by the inspector during the inspection. This was citedas an item of noncompliance (76-01-03).

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