IR 05000054/1979002
| ML19256E127 | |
| Person / Time | |
|---|---|
| Site: | 05000054 |
| Issue date: | 08/10/1979 |
| From: | Donaldson D, Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256E120 | List: |
| References | |
| 50-054-79-02, 50-54-79-2, NUDOCS 7910290139 | |
| Download: ML19256E127 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
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Report No. 50-54/79-02 Docket No. 50-54 License No. R-81 Priority
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Category F
Licensee:
Union Carbide Corooration i
P. O. Box 324 Tuxedo, New York 10987 Facility Name:
Union Carbide Nuclear Company Research Reactor Inspection at:
Corporate Research Laborat'>ry, Sterling Forest, New York Inspection conducted:
March 13-15,1979
/d 79 Inspectors: A A14d A
D. Donaldson, Radiation Specialist date s'igned
/ t' W eMn
./ ohr, ' Chief, Environmental and d6te signed J
St Special Projects Section, FF&MS Branch date signed
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Approved by:
u J. P./Stohr7 Chief', Environmental and date signed Sp6cial Projects Section, FF&MS Branch
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Inspection Summary:
s Inspection on March 13-15, 1979 (Report No. 50-54/79-0 2)
Areas inspected:
Routine, unannounced inspection of environmental protection, emergency planning and radiation control, including:
under environmental protection, airborne effluents, liquid effluents and solid waste; under emergency planning; emergency plan verification, outside agency coordination, training, drills, emergency equipment; and under radiation control; posting and labeling, training, radiation and contamination surveys, personnel exposures, calibration of health physics instrumentation.
In addition, the inspector reviewed the status of unresolved items from a previous inspection and split liquid and gaseous effluent samples for comparison of analysis results.
The inspection involved 28 inspector-hours onsite by two regional based NRC inspectors.
Resul ts: Of the 15 areas inspected, six apparent items of noncompliance were identified in 2 areas (Infractions - Failure to label radioactive materials container, Paragraph 3.b; Failure to rope-off contaminated ar.ca, Paragraph 3 b; Failure to survey airborne radioactivity, Para-graph 3.b; Failure to maintain complete exposure records, Paragraph 3.d; Failure to perform urinalysis every six months, Paragraph 3.d; Failure to evaluate airborne effluents for I-133, Paragraph 4.a).
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- DETAILS 1.
Persons Contacted Principal Licensee Employees
- Dr. H. Fritz, Site Manager
- Mr. J. McGovern, Projection Manager, Radiochemicals
- Mr. L. Thelin, Health Physicist aMr. C. Konneith, Health, Safety and Environmental Affairs Manager The inspector also interviewed sey.eral other licensee employees during the course of the inspection. These included health physics technicians and reactor operations.
Other Personnel Mr. H. Preris, New York State Department of Environmental Conser vation
- denotes those present at the exit interview and "a" denotes contact via telephone on March 26, 1979.
2.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (77-04-01):
Evaluation of sampling line losses.
The inspector held discussions with licensee personnel who stated that an evaluation of potential line losses had been performed.
Results indicated a negligible effect.
(Closed) Unresolved Item (77-04-02):
Surveys for I-133 in gaseous efflu-ent. Additional information provided during the current inspection in-dicated that the previous unresolved item now constituted noncompliance.
See Paragraph 4.a for details.
3.
Radiation Control a.
Posting, Labelf J and Access Control The inspector toured the licensee's reactor facility to observe general aspects of the licensee's radiation control program which regard to posting, labeling and access control.
The inspector noted that:
the posting of notices to workers were consitent with the
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requirements of 10 CFR 19.11; a hand and foot monitor was available and operable at the main egress from the facility; and personnel were observed to be wearing required personnel dosimetry (film badges and pocket ionization chambers) to measure any exposure to ionizing radia-tion. The inspector also noted that various areas within the facility exhibited posting of radiation, high radiation and contaminated areas.
No items of noncompliance or deviations were identified during the facility tour.
b.
Radiation and Contamination Surveys The inspector held discussions with licensee representatives, reviewed available records and performed independent measurements to review the licensee's established program for surveying direct radiation levels, for monitoring the presence of radioactive contamination and for proper posting of existing radiation, high radiation and contaminated areas and radioactive materials containers.
During the tour of the licensee's facility, the inspector and a li-censee representative mea:,ured radiation levels of approximately 20 millirem per hour at one inch from the outer surface of a 55 gallon steel drum. The inspector noted that the drum was unattended and marked with the words " transfer only" written in black felt-tip pen on the lid.
The licensee representative stated that drums of this type were used to collect solid radioactive waste for transfer to the compactor area.
The inspector informed the licensee that the failure to have affixed a sign of the proper type bearing the words " Caution, Radioactive Material (s)" to include information sufficient to permit individuals handling the drum or in the vicinity thercar 'o take precautions to avoid or minimize exposure constituted noncompliance with the requirements of 10 CFR 20.203(f) (79-02-01).
Later in the tour, the inspector and a licensee representative per-formed radiation and contamination surveys in the area near the heat exchanger. The inspector noted that a gate to the heat exchanger area was in the full open position and a contaminated area sign on the open gate was reversed such that the information on the sign was not visible.
The inspector also observed tools lying on the heat exchanger hallway floor. The inspector and licensee representative entered the heat exchanger area hallway, without protective clothing, and performed radiation and contamination surveys of the area.
Contamination wipes were taken from the heat exchanger hallway floor and the area under the heat exchanger.
Subsequent evaluation of the wipe taken from the heat exchanger hallway floor revealed removable contamination of approximately 7,600 disintegrations per minute (dpm) per 100 cm2,
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Due to the presence of contamination in the area, the inspector ques-tioned the methods for controlling access to contaminated areas and the precautions to be observed in such areas.
The licensee stated that contamination levels had been established at which certain actions were taken. The levels were established as follows:
Level (dpm)
Action 200-500 Inform health physics supervisor 2,000-5,000 Rope off area 10,000-30,000 Rope off area, inform health physics supervisor and decontaminate The inspector informed the licensee that the failure to have the heat exchanger area roped off and for the licensee representative and inspector to have been permitted entry into the heat exchanger area without protective clothing constituted noncompliance with the require-ments of Section E.3 of the licensee's Final Hazards Summary Report incorporated as license conditions per 10 CFR 50.36(d)(1) (79-02-02).
Upon further discussion of the circumstances surrounding the heat exchanger area contamination and the tools observed to be lying on the heat exchanger hallway floor, licensee representatives informed the inspector that the tools had been used to work on the ion exchange column. The inspector reviewed the control room log and noted that the last work in the heat exchanger area had taken place on March 12, 1979 during the hours of 10:00 p.m. and 11:00 p.m.
The inspector was informed that this job was normally accomplished during normal working hours when health physics coverage was readily available.
The inspector requested records of air samples taken in the area during the work and the name of the individual who performed the work.
The licensee representatives stated that from available records they were unable to determine who had performed the work.
It was further stated that air samples had not been taken and that it could not be readily determined whether the individual had worn protective clothing while performing the noted work. The inspector informed the licensee that the failure to survey the air in the heat exchanger area during the period of time work was being performed in the area of the heat exchanger constituted noncompliance with the requirements of 10 CFR 20.201 regarding the performance of an evaluation of radiation hazards to include a physical survey of measurements or concentrations of radioactive materials present (79-02-03).
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c.
Training The inspector held discussions with licensee personnel to verify that a program for instructing all individuals who work in or frequent the 1 m see's facility regarding the health protection problems associated M ca radiation and the radiation safety practices and procedures to be observed while at the facility.
Each individual is provided with a copy of a re.ently developed manual which covers those subjects re-quired by 3 CFR 19.12.
No items of noncompliance or deviations were identified during this portion of the inspection.
d.
Personnel Exposures The inspector reviewed the radiation exposure records of 17 indivi-duals, covering calendar year 1978.
This review indicated theat quarterly whole body exposures averaged 42% of the 10 CFR 20.101 limit of 1.25 rem. The inspector also noted that three individuals had received quarterly exposures greater than 1.25 rem but less than 3 rem. A review of additional records indicated that the individuals had current exposure histories and the exposures did not cause their permissable accumulative doses to be exceeded.
Quarterly skin and extremity exposures were observed to have averaged < 20% of the 20.101 limits for the 17 individuals.
The inspector held discussions with licensee management, to determire the methods being employed to keep exposures as low as reasonably achievable.
In particular, the inspector discussed the need for continual assessment of current exposure histories as a basis of authorizing individuals to receive greater than the 20.101 lower limits and for selecting the particular individuals to work in areas where the potential for exposure exists.
The licensee stated that the provisions for maintaining exposures as low as reasonably achievable had recently come under closer review.
This increased attention resulted due to the observation that back-ground exposures had risen in the last two years as a result of a corresponding increase in workload.
The inspector had no further questions at this time.
As a reFult of the review of personnel exposure records, the inspector observed a discrepancy involving the completeness of personnel exposure records.
The Form NRC-5 equivalent records of one individual did not contain any entry for the period of December 26, 1977 through January 8, 1978.
Discussions with licensee management concerning the apparent
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omission indicated that a processing error had rendered the indivi-duals film badge unreadable.
The licensee further stated that they had intended to determine the individual's exposure for the period using pocket ionization chamber readings that had been recorded during the time period in question, but, as yet, this had not been done. The inspector informed the licensee that the failure to determine the individual's exposure and record that value on the individual's ex-posure record constituted noncompliance with the requirements of 10 CFR 20.401 (79-02-04).
In addition to the aforementioned areas, the inspector also reviewed procedures, records and results of thyroid scans and urinalysis of employees.
The inspector noted that thyroid scans were performed on a self-initiated basis, with the counting equipment readily available for use by all employees.
Review of records indicated that I-131 and I-125 uptake by those employees who have been scanned average < 10%
of the maximum permissable body burden.
Discussion of urinalyses procedures and results revealed that urinalysis was performed annually for all personnel.
The inspector informed the licensee that a yearly frequency was not in accordance with the semi-annual frequency estab-lished in the licensee's Final Hazards Summary Report and incorporated as a licen:;e condition by 10 CFR 50.36(d)(1) (79-02-05).
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Calibration of Health Physics Instrumentation The inspector held discussions with licensee personnel and reviewed available records to verify that a program for routine calibration of personnel dosimeters and radiation survey instruments was established.
The inspector determined that instrument calit, rations were perfonned quarterly. The inspector further noted that there were no requirements in this area and had no further questions.
4.
Environmental Protection The inspector reviewed the licensee's effluent monitoring and environmental protection in the following areas:
a.
Airborne Effluents Airborne activity from the Union Carbide facility is released via a stack which is fed by two ducts - one from the reactor building and one from the hot laboratory.
Each of these ducts are quantitatively sampled for particulate and halogen activity.
In late January 1978, the licensee switched the halogen sampling medium from 1 mm thick by 47-50 mm diameter charcoal impregnated filter to 21 mm thick by 75 mm diameter charcoal canisters.
The inspector reviewed halogen sampling
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data for the four weeks before and four weeks after initiation of new media use.
In mid 1978, the licensee placed in service a newly in-stalled bank of charcoal filters in the stack gas effluent path to reduce the halogen activity in the gaseous effluent from the stack.
The inspector reviewed the licensee's gaseous affluent data for 1977 and 1978. Totals and percentage of allowable limits are summarized in the following table:
Noble Year I-125*
%MPC I-1 31 *
%MPC Gas *
%MPC 1977 3.6
55.0
21,681
1978 3.1
40.8
19,494
- Curies A detailed review of 1977 gaseous effluent data indicated that the licensee had not evaluated facility releases for I-133 per the results of a previous inspection conducted on November 29 - December 2, 1977 (IE Inspection Report No. 50-54/77-04, Detail 3.d).
During the pre-vious inspection, the licensee was informed that I-133 releases for 1977 were approaching, and in all probability would exceed,10% of MPC.
Consequently, the licensee was informed of the requirement to demon-strate ccmpliance with the survey requirements of 10 CFR 20.201 by accounting for isotopes present in mixtures in amounts greater than 10% MPC.
During the current inspection, the inspector attempted to review the licensee's evaluation for I-133 in gaseous effluents for 1977 but was informed that the evaluation had not been done.
Using the same calculational approach detailed in IE Inspection Report No. 50-54/77-04, Detail 3.d, the inspector computed the 1977 I-133 release fraction to have been 14% MPC and the 1978 release fraction to have been 11% MPC.
The inspector informed the licensee that the failure to evaluate 1977 and 1978 gaseous effluents for the presence and concentration of I-133 constituted noncompliance with the requirements of 10 CFR 20.201 relating to surveys (79-0_2-06).
Review of 1978 gaseous effluent data indicated that halogen releases for the last quarter of 1978 dropped to.6% MPC concurrent with the attainment of full operability of the newly installed stack effluent charcoal filter banks.
This level represents a significant decrease from the approximate 30% MPC radiciodine release concentrations ex-perienced before installation of the filter system.
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Particulate releases for 1978 compare with the less than 3i MPC levels attained in 1976 and 1977.
The inspector inquired into the isokentic nature of the particulate sampling system.
The licensee infermed the inspector that they believed the sampling to be isokenetic, but were unable to produce documentary evaluation to support the contention.
The inspector stated that this item would be unresolved pending the outcome of a licensee evaluation to determine the sampling profile of the system (79-0_2-07).
b.
Liquid Effluents Liquid radioactive waste from Buildings 1 and 2 is collected in the reactor building sump.
Radioactive liquid waste from building 4 is collected in two 250 gallon receiving tanks.
Both the reactor building sump and the two 250 gallon receiving tanks are transferred to a 5,000 gallon hcidup tank (T-1). The waste is then processed through an evaporator with the distillate returned to either the reactor canal or to two waste tanks where the liquid is sampled and analyzed for gross beta - gamma activity prior to discharge to the Indian Kill River.
During calendar year 1978, the licensee discharged a total of 538.9 uCi of gross beta activity.
The average liquid releases in 1978 were approximately 7% of MFC.
The inspector noted that no activity is generally observed but is assumed to be present at the limit of sensi-tivity.
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Discussions between the inspector and licensee representatives indi-cated that the two mall tanks could not be discharged due to abnormally high activity.
In pursuing the nature of the abnormally high activity, the inspector determined that the source of the activity was water from the floor of the 5,000 gallon holdup tank room.
Recent heavy rains and snow melt was postulated to have leaked into the stack exhaust train and drained into the room through a cross pipe that had not been valved out during installation of the new charcoal filters in the exhaust train. The licensee further stated that the pipe thought to have allowed the leakage had since been closed off.
When the water was first discovered, the licensee began pumping the liquid from the room to one of the two mall tanks.
A sample of the liquid was analyzed at the beginning of the transfer operation, and based upon the activity detected (primarily I-1311 the transfer operation was stopped.
At the time of the inspection, the mall tanks and the water standing in the holdup tank room were being held for the activity to decay to accept-able levels prior to discharge.
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The inspector discu:: sed seval issues in relation to the aforemen-tioned event.
Since the enit had recently occurred and the licensees evaluation of the circumstances was still incomplete, the licensee was not able to address the issues fully.
Consequently, the inspector informed the licensee that the circumstances and evaluation of the situation would be unresolved pending completion of the licensee's evaluation and subsequent review by the NRC (79-0,2-08).
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The following issues were addressed by the inspector with regard to this condition.
(1) The source of the effluent to the exhaust air stream; (2)
Provisions for draining / checking the exhaust conduit for subse-quent collection of water while the drain was plugged; (3) An evaluation of the possible effect of the water's presence upon filter effectiveness; (4) The potential for seepage of the water from the holdup tank room into the ground surrounding the room; and, (5)
Provisions to correct future similar situations.
c.
Solid Waste
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The majority of the solid waste generated by the licensee is under the N. Y. State byproduct material license or SNM license.
A review of shipping papers for 1978 indicated no items of noncompliance.
d.
Split Samples Split airborne particulate and charcoal and liquid warte samples were taken by the licensee and the inspector for the comparison of analysis results. Analyses will be performed by the licensee using his n;;rmal methods and by NRC:I.
Joint analyses of actual effluent samples and subsequent comparison of the results determines the license 2's capa-bility to measure radioactivity in effluent samples.
The results of these analyses will be reported in a subsequent inspection report.
e.
Environmental Monitoring _
The inspector re"iewed the licensee's environmental monitoring program as documented in Section 3.b of the Final Hazards Sumary Report and compared its scope and nature with the environmental monitoring activi-ties actually being perform (d.
The inspector noted that the instituted program was in conformance vith requirements.
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The licensee collects air samples at four locations designated as:
Carbide site, Sterling Forest Maintenance; Tuxedo Park; and Laurel Ridge. The Laurel Ridge site was added in late June of 1979.
Since the last inspection of this area, the licensee has changed the collec-tion madium from charcoal impregnated papers to charcoal canisters and has reduced the sampling flow rate from 7.5 cfm to 3 cfm in order to achieve a longer residence time for radiciodines.
Air samples are analy::ed weekly and monthly for I-125 and I-131.
The demonstrated minimum detectable amounts for these two isotopes are.023% MPC and a
.053% MPCa, respectively.
In addition to envirunmental air sampling stations, the licensee Sas placed thermoluninescent dosimeters (TLDs) at each air sampling station and collects rain and surface water samples.
The inspector reviewed the licensee's environmental monitoring data for 1977 and 1978.
The inspector observed that the average concentration of I-131 at the sampled locations was approximately.5% MPC averaged <.24, with the last quarter of 1970.
During 1978, this value less than.05%.
The trend toward reduced environmental levels of I-131 was attributed to improve handling of gaseous effluents via installation of charcoal filters in the Hot Laboratory exhaust train.
The mspector noted that all environmental monitoring values were less than either the licensee's MDA or background.
No items of noncompliance or deviations were identified.
5.
Emergency Planning The licensee's program for coping with emergencies at the reactor facility is described in Section 5 of the Final uazards Summary Report and procedure EP-01, Emergency P1an.
a.
Verification of Response Capability The inspector held discussions with key licensee personcel concerning the actions to be.taken in responding to a postulated incident. These di.scus.si.ons. indi,cate that persons could recognize an emergency situa-tion and respond in a manner as described in the Emergency Plan.
b.
Supporting Agencies The licensee's emergency planning program incorporates support f rom the Tuxedo Police, New York State Police, County Civil Defense Organi-zation, the Tuxedo Fire Department and Tuxedo Hospital.
The inspector noted that there were no regulatory requirements in this area and had no further questions.
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c.
Monitoring Systems / Alarms / Emergency Equipment The inspector examined the effluent and area radiation monitoring systems and noted that they were available and operable.
The in-spector also noted that emergency equipment was in position in the reactor building lobby and building 4.
The inspector verified that the above equipment was periodically inspected to insure availability.
d.
Training The inspector reviewed the licensee's emergency training program. The program consists of indoctrination training for new employees and refresher training for reactor operators during the requalification program.
e.
Drills The inspector reviewed records of emergency drills conducted at the Sterl.ing Forest Research Facility durinn 1978.
The inspector noted that radiological drills were conducted, but limited to involvement in the Hot Labcratory.
Evacuation was included as part of these drills.
The inspector noted there were no regulatory requirements in this area and had no further ques.tions.
6.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations.
Unresolved items disclosed during this inspection are discribed in Details 4.a and 4.b.
7.
Exit Interview On March 15, 1979, at the conclusion of the inspection, the inspector met with the licensee representatives denoted in Paragraph 1.
On Mu ch 26, 1979, the inspector contacted Mr. K. Konnerth by telephone.
During these meetings / discussions, the inspector summarized the purpose and scope of the inspection and the inspection findings, including each item of noncompli-ance and unresolved item.
Licensee representatives acknowledged the items of noncompliance and made the following comments with regard to certain of the items discussed by the inspector:
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Failure to Conduct Air Survey During Work on the Ion Exchanger Column The licensee representative stated that this job had been performed many times over the past years and air samples indicated that no airborne hazard was ever indicated. Therefore, air surveys were not performed based upon this experience.
The inspector pointed out that the nature of the job as currently being performed was different due to the presence of-contamina-tion on the flocr of the working area and the more frequent need to perfonn the job.
Consequently, surveys taken undar a particular set of conditions do not suffice if the conditions change.
Failure to Rope-Off a Contaminated Area The licensee stated that normally, there would be more than one wipe taken 1.n an area to establish whether or not contamination existed and that the level at which. contamination exists is not defined.
Isokinetic Particulate Sampling The licensee stated that the sampling ;nethods would be evaluated to ascer-tain the kinetic nature of the sampling system for the reactor building.
Presence. of Water in Air Effluent Duct The licensee stated that continued attention would be given to determining the cause, possible impact and final resolution of similar events in the future.
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