IR 05000170/1979001
| ML19296A407 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 02/05/1979 |
| From: | Crocker H, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296A390 | List: |
| References | |
| 50-170-79-01, 50-170-79-1, NUDOCS 7903190551 | |
| Download: ML19296A407 (12) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT g
Region I Report No.
50-170/79-01 Docket No.
50-170 License No.
R-84 Priority Category F
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Licensea:
Defense Nuclear Agency Armed Forces Radiobiology Research Institute Bethesda, Maryland 20014
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Facility Name:
AFRRI TRIGA Reactor Inspection at:
National Naval Medical Center, Bethesda, Maryland Inspection conduc e :
January 10-12, 1979 L%
1/ I/
Inspectors:
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K. E. Plumide, Radiation Specialist date signed date signed date signed (AcA J/f/79 Approved by:
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m H. W. Crocker, Acting Gniet, Radiation
/date signed Support Section, FF&MS Branch Insoection Summary:
Inspection on January 10-12, 1979 (Report No. 50-170/79-01)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the research reactor radiation protection program, environmental protection pro-gram, and radioactive waste management including:
radiction protection training; procedures; instruments and equipment; exposure control; posting; labeling and control; surveys; reports; effluent systems; waste disposal; and organization.
Upon arrival, areas where work was being conducted were examined to review radia-tion safety control procedures and practices.
The inspection involved 22 inspector-hours on site by one NRC regional based inspector.
Results: Of the ten areas inspected, no items of noncompliance were identified in eight areas. Two items of noncompliance were identified in two areas (Infractions -
failure to maintain the liquid seal in the reactor building ventilation exhaust stack drain line, paragraph 2.a; and failure to maintain the specified minimum face flow velocity in the hot laboratory radiation hood, paragraph 2.b).
Region I Form 12 (Rev. April 77)
7903190 W
DETAILS 1.
Persons Contacted Mr. J. M. Arras, Head, Operational Health Physics Division Mrs. M. F. Brown, Physical Sciences Technician Lt. Commander P. J. Durfee, USN, Health Physicist
- Colonel D. W. McIndoe, USAF, MC, Director AFRRI CS0 M. L. Moore, Senior Reactor Operator
- Mr. L. A. Slaback, Jr., Head, Radiological Safety Department HMI E. Sorensen, Health Physics Technician Staff Sgt. L. Vernon, Health Physics Technician Mr. W. R. Webber, Head, Radioanalysis and Dosimetry Division denotes presence at the exit interview on January 12, 1979
2.
Ventilation Systems and Laboratory Hoods Part of the inspection effort was to review the operation and testing of the ventilation equipment and hoods.
a.
Ventilation Exhaust Stack A requirement of Technical Specification Section I.A.1, " Facility Description - Reactor Building", is that the effluent from the reactor building ventilation system shall exhaust through abso-lute filters to a stack having a minimum elevation that is 18'
above the roof level of the highest building in the AFRRI complex.
On January 10, 1979, the inspector observed that a liquid seal, or trap, in the reactor building ventilation exhaust stack drain line was dried out, and that a small part of the stack flow was being released outdoors at floor level by leakage through the drain line.
The direction of flow was verified on January 11, 1979 using a smoke trace.
No radioactivity was detected by surveying the line and its opening.
The inspector identified the exhaust through the drain line as noncompliance with the above requirement, resulting from failure to maintain the liquid seal (170/79-01-01).
The licensee representative subsequently stated that on January 12, 1979, the trap was filled with water and that a periodic routine procedural check of the seal would be established to prevent any recurrence of flow leakage through this lin b.
Hood Face Flow Velocities Technical Specification Section III, " Administrative and Pro-cedural Safeguards", states in paragraph C that written in-structions shall be in effect for, but not limited to:
...
9.
any operation deemed necessary by... the Research Pro-gram Coordinating Office... and the Reactor and Radiation Facility Safety Committee.
The licensee documented the radiation protection program in a letter dated June 13, 1977, which applied to License Nos.
R-84, SNM-706, SMB-670,19-08330-2 and 19-08330-03.
The letter listed, as part of the program, the Radiological Safety In-structions (kSIs) and included the following statement, which is currently incorporated in AFRRI Instruction No. 3020.6A, January 5,1979:
"All AFRRI personnel shall be familiar with and shall comply with the applicable portions of these in-structions. "
The above letter listed RSI 510, " Unsealed Radioactive Source Use", and RSI 140, " Support Services by Radiation Safety Personnel", which were retained in the current list of pro-cedures (paragraph 4).
RSI 510 specifies that for a Type C lab the hood face velocity shall be greater than 75 fpm (and for a Type B lab > 125 fpm).
RSI 140 includes an index Of Health Physics Procedures (HPPs)
developed to implement the requirements of the RSIs, one being HPP 3-5 " Hot Lab and Pneur. tic Tubes", which states that Hot Lab operations will always be performed with at least the pre-cautions required for a Type C lab. The Hot Lab is a facility that was described in the Safety Analysis Report for the reactor.
On January 10, 1979, the inspector observed that, with radioactive material present in the large hood in the Hot Lab, there was no measurable face velocity with the hood open 6 inches or more using an NRC velometer for the measurement.
The inspector identified this as noncompliance with the above requirements (170/79-01-02).
The licensee subsequently performed a hood face velocity measurement using the equipment and procedures indicated in HPP 8-5 " Chemical Hood Testing" (which is being revised).
The maximum face velocity measured was 25 fpm and this was obtainable only by turning off the air-curtain supply for the above hood.
The previous licensee measurement, dated June,1978, had been 90-110 fpm for various hood opening The licensee representative stated during the exit interview that the 'iot Lab Hood was closed down and would net be used for radioactive materials until a design review of the hood was completed and proper face velocity was established. (Para-graph 13 ).
c.
Bujlding Heatino and Ventilation Systems The Safety Analysis Report indicates the design of the building heating and ventilation. Technical Specification Section I.A (paragraph 2.a above) requirer certain absolute (HEPA) venti-lation exhaust filters, and also automatic closure of the reactor room ventilation dampers on alarm of the reactor room continuous air monitor. TS Section II.C.8 requires monthly visual and opera-tional checks of the damper operations.
Procedure HPP 3-2, in Section 7.a " Reactor Radioactivity Filter Changes" requires a 00P test of the HEPA filter efficiency when a new filter is installed.
Observation of the equipment did not identify any faulty, non-operating or neglected equipment.
No radioactivity was identified on surveying the ventilation filters and ducts.
As described above, there were radioactive materials in the hoods that were designated for radioactive use.
In addition, the inspector identified an unlabeled temperature regulator in the reactor room that was 50 mrem /hr on contact, not including 70,000 cpm alpha activity. The source of activity was nearly at eye-level and there was no cover or shield to reduce the radiation dose to the eyes.
The licensee representative replaced the regulator with a non-radioactive regulator. The licensee determined that greater than 2 microcuries of radium (and radium daughter) activity was present in the luminous face of the regulator tnat was removed.
Review of the licensee records of ventilation filter flow re-sistences (APs) and filter efficiency detenninations did not identify any items of noncompliance.
The inspector had no further questions on this ite.
3.
Radiation Protection Trainino Part of the inspection effort was to review compliance with the requirements of 10 CFR 19 to provide notices, inst.uctions, in-formation and reports to workers, and the requirements of RSI 120
" Radiation Safety Training: AFRRI/USUHS Personnel" to provide an initial radiation safety briefing to each person who is permitted unescorted access to restricted areas or is issued radiation dosi-metry, a:: well as recuirements for specialized training and annual retraining for individuals classified as source users. General information is provided in a booklet i: sued to each user, " Radio-logical Safety for the AFRRI/USUHS."
Discussion with various individuals and review of records and materials used in training did not identify any items of non-compliance.
Training records will be reviewed again on a subse-quent routine inspection (170/79-01-03h 4.
Radiological Protection Procedures Review of the licensee's radiological protection procedures listed below did not identify any inconsistencies with the license ap-plication (paragraph 2.b above) requirements of 10 CFR 19 and 20, Technical Specifications, or the Safety Analysis Report.
a.
List of AFFRI Radiolouical Safety Instructions 1.
Series 100:
RSI 110 Joint Safety Policy and Administrative Controls RSI 111 Reporting Defects and Noncompliance RSI 112 Institute and University Facilities RSI 120 Radiation Safety: AFRRI/USUHS Personnel RSI 130 Radiation Safety Committees RSI 140 Support Services by Radiation Safety Personnel RSI 150 Health Physics Instrumentation 2.
Series 200:
RSI 21^ Personnel Access to AFRRI and USUHS
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RSI 220 Personnel Monitoring Administration
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RSI 230 Staff Personnel Monitoring RSI 240 Non-Staff Personnel Monitoring
3.
Series 300:
RSI 320 Radioisotope Laboratory Incidents 4.
Series 400:
RSI 410 Authorization to Possess Radionuclides RSI 420 Procurement of Redioactive Material RSI 430 Radioactive Source Accountability 5.
Series 500:
RSI 510 Unsealed Radioactive Source Use RSI 520 Sealed Radioactive Source Use RSI 530 Radiation Producing Machines RSI 540 Special Work Permits 6.
Series 600:
RSI 610 Laboratory Radioactive Waste Disposal RSI 620 Radioactive Animals RSI 630 Transfer of Radioactive Materials RSI 640 Environmental Releases 7.
Series 700:
RSI 710 High Radiation Areas RSI 720 Large Source Administrative Requirements b.
Index of Hea'th Physics Procedures (Enclosure 1. to RSI 140)
0-1 Safety ining Formats 0-2 Healtn Physics Action Levels 0-3 Source Receipt Survey and Notification 0-4 Radioanalysis Support Services 0-5 Transportation of Radioactivity 0-6 Annual Health Physics Summary 1-1 Dosimetry Record Management System 1-2 Personnel Dosimetry Records 1-3 Supplementary Personnel Dosimetry 1-4 Entering and Departing Personnel 1-5 Non-Staff Personnel Dosiruetry 1-6 Internal Exposure Monitoring Drogram 1-7 Dosimetry Quality Assurance l-8 TLD Readout
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2-1 Perimeter Monitoring Program 2-2 Environmental Sampling and Analysis 2-3 Stack Effluent Monitorirc System 2-4 Airborne Radioactivity Sampling 2-5 Environmental Release Evaluations 3-1 Reactor Exposure Room Entry 3-2 Inplant Reactor Surveys and Samples 3-3 Warm Storage Room 3/
Fission Foil Operations 3-5 Hot Lab and Pneumatic Tubes 3-6 Radioiodine Monitoring 4-1 Linac Monitoring Guidelines 4-3 Cobalt Facility Leak Testing 4-4 Cobalt Facility Health Physics 4-5 Standards Laboratory 5-1 Sealed Source Use 5-2 Leak Testing of Sealed Sources 5-3 Two Curie Cs-137 5-4 Ten Curie Pu-239 BE Source
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5-5 Ninety Curie Cs-137 Irradiator 5-6 One Curie Co-60 Camera G-i Unsealed source Use 6-2 Lab Waste and Laundry Pickup 6-3 Solid Radioactive Waste 6-4 Waste Tank Facility 6-5 Radioactive Animal Handling 6-6 Radioactive Spills and Emergencies 6-7 Radioactive Laundry 7-1 Health Physics Survey Instruments 7-2 Radiation Area Monitors 7-3 Continuous Air Monitors 7-4 Laboratory Counting Instruments 7-5 Special Instruments 8-1 Radiological Surveys 8-2 Emergency Equipment Check 8-3 Special Work Permit (SWP) Instructions 8-4 Hazardous Chemical Disposal Methods 8-5 Chemical Hood Testing 8-6 Radsafe Buyer's Guide The inspector had no further questions on this ite.
5.
Instruments and Equipment Part of the inspection effort was to review the licensee's compliance with requirements of the Technical Specifications to maintain at least the following operable instruments during reactor operation (TS Section II.B.3):
Reactor Room - two area radiation monitors
- one continuous air monitor Preparation Area - two area radiation monitors Stack effluent sampling system RSI 150 and HPP 7-1 to 7-5 list the survey instruments, radiation area monitors, and continuous air monitors required and used at AFRRI, as well as various test and calibration requirements.
The inspector noted that manufacturer's instructions were maintained for all of these instruments, and the licensee has check sources, calibration capabilities and personnel for testing, calibrating and servicing these instruments. The condenser R-meter was scheduled for an off site calibration.
Review of licensee test, calibration and service records did not identify any items of noncompliance.
Observation of instrument availability and operability did not identify any problems.
The inspector had no further questions on this item.
6.
Exposure Control Part of the inspection effort was to review the licensee's control of external and internal exposures to personnel.
Access to radioactive materials and radiation facilities is controlled by labels, posted signs, barricades, locked doors and by the author-ization of proposed experiments and uses by Radiation Safety Committee revie *
.
Administrative controls include the control of the procurement and use of radioactive materials, a special work permit procedure, personnel dosimetry, servevs, air sampling and bioassays.
The inspector reviewed c..e licensee's TLD dosimetry evaluation practices and records.
The licensee uses the manufacturer's instructions to eval" ate the TLDs, and uses NBS traceable sources for TLD calibrati sposes. The licensee is obtaining an auto-
'
matic TLD reader.
Observation during the inspection did not identify and omissions to wear the assigned badges.
No distinction was evident in the individual radiation exposure re-cords between exposures to radiation due to the research reactor or to other sources such as radioisotopes possessed under other licenses, or accelerators or X-ray equipment.
Health Physics personnel typically were exposed to more than one of these sources of radiation during a single badge period.
The licensee maintained individual records on military radiation exposure forms.
The AFRRI/USUHS Radiological Safety booklet, is-sued to each radiation worker, describes the availability of reports to workers.
Gamma sensitive TLD badges typically were isssued and evaluated on a monthly schedule. The maximum annual exposure indicated to any in-dividual due to gamma radiation did not exceed 500 mrem during either 1977 or 1978.
Neutron TLD badges were issued to 20 individuals during 1977 and to 34 individuals during 1978; typically these were evaluated once during the year or following some specific job involving a possibility of measurable neutron exposure.
There were 14 badges that indicated detectable neutron exposures to individuals during 1977 and again during 1978.
The maximum annual exposure indicated to any individual due to neutron radiation did not exceed 200 mrem during either 1977 or 1978.
Review of licensee records of personnel dosimetry including whole body, skin and extremity dosimetry and bioassays did not identify any problems.
Review of survey and air sample records did not identify any problems.
The inspector had no further questions on this area of the inspectio.
7.
Posting, Labeling and Control of Radiation Areas and Radioactive Materials Part of the inspection effort was to observe the licensee's compliance with the requirements of 10 CFR 20.203 involving posted signs, barricades locked and interlocked doors,and posted notices pursuant to 10 CFR 19.
No problems were identified in this area of the inspection.
The inspector had no further questions on this item.
8.
Airborne Effluents The release of airborne radioactivity is regulated by the License (Condi-tion C requiring 10 CFR 20 limits); Technical Specifications (Section I);
by licensee's RSI 640 " Environmental Releases", which states a policy allowing no greater than a few percent of the 10 CFR 20 limits; and by procedure HPP 2-5 " Environmental Release Evaluations" specifying the method of calculating unrestricted area environmental doses.
Review of the licensee records and release summaries indicated that typically about one curie of Ar-41, caused by the research reactor operation, and 1 to 2 curies of isotopes such as N-13 and 0-15, caused by accelerator operation, are being released each month.
No items of noncompliance were identified.
9.
Liquid Effluents The release of liquid radioactive effluent is regulated by 10 CFR 20, RSI 640 and HPP 2-5 (preceding paragraph).
The licensee maintains a radioactive liquid waste collection system and requires sampling of the collection tank before any release to the sanitary sewer.
The recorded releases and summaries indicated that a few microcuries were being released each month with about 80% being tritium and the remainder being radioisotopes such as I-125, C-14 Fe-59 possessed
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under licenses other than the research reactor liceu The total v
annual release to the sanitary sewer was indicated to be 7 m 11 fraction of a curie.
No items of noncompliance were identifie '
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10.
Solid Waste Review of licensee procedures and records indicated that solid waste was collected and shipped during 1978 in Type A quantities to author-ized recipients.
Observation of waste on site at the time of the inspection did not identify any storage problems.
The radioactive carcasses were kept refrigerated or frozen.
No items of noncompliance were identified.
11.
Environmental Monitoring The Technical Specifications in Section II.E, " Environmental Moni-toring Program" require the licensee to maintain a program to determine effects of the facility on the environs and set limits requiring the curtailment or cessation of reactor operations if these levels are reached.
Procedure HPP 2-1 " Perimeter Monitoring Program" and HPP 2-2 " Environmental Sampling and Analysis" require the maintenance of dosimeter stations on the AFRRI roof and at locations up to 2 miles from the facility, as well as sampling a nearby stream and the soil and vegetation.
The inspector toured the exterior of the AFRRI building.
No radio-activity was measured using an instrument capable of detecting less than 0.05 mrem /hr.
Inspection of 3 dosimeter stations indicated that one had been de-molished during earth moving activities or some unknown cause.
Review of records did not identify any problems.
No items of noncompliance were identified.
12.
Organization The Radiological Safety Department includes te Head of the Department and an Operational Health Physics Division cc:. O ed of the Head of the Division, a Health Physicist and two Technicians The Radiological Safety Department also includes the Radioanalysis and Dosimetry Divi-sion, composed of the Head of the Division, a Health Physicist, a Chemical Specialist and a Technicia,
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The inspector observed that the coverage required of the above personnel greatly increased with the inclusion of the USUHS under the program.
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No items of noncompliance were identified.
13.
Exit Interview The inspector met with the licensee representatives (denoted in para-graph 1) at 11:00 a.m. on January 12, 1979; and later at the conclu-sion of the inspection at 3:30 p.m. on January 12, 1979 the inspector met with Mr. L. A. Slabak, Jr.
The Director of AFRRI was out of the facility during the second meeting.
The licensee representatives reviewed the corrective actions on the apparent items of noncompliance identified by the inspector.
The licensee's ventilation equipment and hoods were discussed.
The Health Physics workload was discussed.
The licensee's reply to IE Bulletin 70-07 was reviewed. The licensee representative stated there were no plans to use airline respirators.
The use of divers in performing underwater work did not involve the typa of equipment addressed in the bulletin.