ML19207B407
| ML19207B407 | |
| Person / Time | |
|---|---|
| Site: | 07000572 |
| Issue date: | 07/05/1979 |
| From: | Pagliaro J, Paul R, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19207B405 | List: |
| References | |
| 70-0572-79-01, 70-572-79-1, NUDOCS 7908280136 | |
| Download: ML19207B407 (11) | |
Text
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III Report No. 70-572/79-01 Docket No.70-572 License No. SNM-567 Priority 1 Category B Licensee: Morsarto Research Corporation Dayton Laboratory 1515 Nicholas Road Dayton, OH 45407 Facility Name: Dayton Laboratory Inspection Conducted: May 21-24, 1979
/
75 Inspectors:
R. A. Paul t
4t/
V D. J. Sreniawski Cp M
7kh7 Approved Bv:
J. A. Pagliaro, Chief Materials Radiological I '
Protection Section 2
[
Inspection Summary Inspection on May 21-24, 1979 (Report No. 70-572/79-01)
Areas Inspected:
Routine, unannounced inspection of radiation protection practices at a production facility, including:
organization; radiation protection procedures; training; internal audits; facilities; equipment; transfer of material; external radiation protection; internal radiation protection; posting; access control, and material control; surveys; notifications and reports; radioactive effluent control; sealed sources; quality assurance; stack effluent; confirmatory measurements; and inde-pendent inspection effort. The inspection involved 49 inspector-hours onsite by two NRC inspectors.
Results:
Two apparent items of noncompliance were identified, the failure to limit extremity exposures for one radiation worker to Part 20.101 criteria and the failure to record action taken to prevent recurrence of an individual's intake of radioactive material in seven days in excesc of an equivalent intake of 40 hrc. at the concentration in Part 20, Appendix B, Table 1, Column 1.
See Items 11 and 12 for details.
855
',20 20082801 %
DETAILS 1.
Persons Contacted
- H. L. Williams, Director, Dayton Laboratory
- R. L. Schimmel, Manager, Engineered Products Department
- R. R. Taylor, Manager of Operations, Engineered Products Department S. D. Hoadley, Health Physicist and Radiation Protection Officer S. J. Mouge, Nuclear Manufacturing Support C. A. Garthwait, Chemist E. A. Steinmetz, Internal Auditor D. E. Sevy, Technical Specialist T. Brown, Technical Trainee
- Denotes those who attended the management meeting.
2.
General A review of the various aspects of the licensee's operations was carried out during this inspection, including the scope of oper-ations, operating logbooks, operating oractices, new or modified operations, incidents or unusual occurrences and unresolved items.
The results of this review indicate the licensee is performing the scope of their operations in accordance with the conditions of their operating procedures and license specifications.
A review of licen-see's inventory and use records indicated the licensed material appears to be used in quantity and kind as authorized.
No significant or unusual occurrences were found during the inspection.
3.
Organization The licensee's organizational structure remains as described in the Licensee's Specifications Part 5.2 (March 1978).
The Radiation Protection Officer, S. D. Hoadley, had the additional responsibility for shipping and receiving from about July 1978 to March 1979. This situation was terminated when it was determined that the radiation safety program required more of his time.
4.
Radiation Protection Procedures License No. SNM-567 was amended in its entirety on May 25, 1978, and partially amended on February 27, 1979. The major changes were an increase in the possession limit for americium-241 and a change in frequency for the formal internal audit of the licensed program from quarterly to annually. The program was as described in the License Specifications and the Operations Manual submitted with the May 25, 1978, amendment.
855 121 No items of noncompliance or deviations were identified.
5.
Licensee's Internal Audit The inspectors reviewed the reports of the audits conducted by E. A. Steinmetz on June 12, 1978, and January 9,1979. The audit was performed with emphasis on review of trends in personal expo-sures, numbers of smear surveys with positive results, numbers of air samples with positive results, survey requirements accomplished within required frequencies, etc.
The licensee also mai tains a " Health Physics Log" of any noteworthy events. There were seven events for the period May 16, 1978, to January 19, 1979. The events included two air samples in excess of MPC, two glove failures, a lab decommissioning, and two container misuse reports. All these items were reviewed by the NRC inspectors.
One of these resulting in an item of noncompliance is discussed in Paragraph 12.
Also reviewed were the minutes of the Management Health Physics Meetings for the period May 31, 1978 to May 4, 1979.
No items of noncompliance or deviations were identified other than that discussed in Paragraph 12.
6.
Training New employees who work in the process area are required by License Specification 5.7.1 to receive a two month apprenticeship.
An interview with an employee who recently completed the program assured the NRC inspectors he had received the required training.
Retraining sessions are required to be held at least quarterly by License Specification 5.7.2.
The subjects discussed are listed in the Operations Manual, Section 4.7.1.
Review of the records from June 5, 1978 to April 22, 1979, showed the sessions were held at the required frequency.
Interviews of employees showed they were aware of the subjects covered. As each employer is trained in a specific procedure he is certified for that procedure and a record is maintained.
No items of noncompliance or deviations were identified.
7.
Facilities General Description The nuclear process area is located in the north wing of Building 2 with the north four rooms, Rooms No. 6, 7, 8, and 9, being used for processing material and Rooms No. 3, 4, 10, 11, 13, and 14 comprising 855 122 nan 7 7 7 -- -
'O 4 U JJJ
the support area. These latter rooms involve facilities of counting and leak testing equipment, certain machine operations, QA storage, packing and receiving of material. Diagrams and descriptions of the facility are contained in Section 7.3 of the licensee operations manual. There have been no significant changes since the last inspection.
The licensee controls access to restricted areas by using an elec-tronic interlock system for entrance into the control and process areas and by enclosing the outside of these areas with a chain-link type fence. The periphery of that part of the roof which houses the licensee's stack exhaust system is enclosed with a barbed wire fence. Access into any of the licensee's restricted areas is permitted for authorized persons only.
No items of noncompliance or deviations were noted.
8.
Equipment The licensee utilizes glove boxes, remote boxes, hoods, hot cells and a canyon in the Process Area for the production and handling of radioactive encapsulated and unencapsulated material in a manner and within those systems which are described in Section 10 of the Licensee's Operation Manual.
There have been no significant additions or changes in equipment since the previous inspection.
No items of noncompliance or deviations were identified.
9.
Transfer of Materials The licensee made approximately 200 shipments of licensed material to customers. Several of the shipments were reviewed after being chosen at random from the " Outgoing Shipment" Log for the period March 10, 1978 to May 21, 1979. The NRC inspectors verified that the licensee had copies of the customer's licenses which authorized possession of the material ordered, that leak tests were made of the sources before shipment, that records of radiation surveys were properly maintained and that the record of labels attached to the shipment was adequate.
The licensee received about 58 licensed shipments and 142 empty returned containers incoming shipments for the period January 10, 1978 to May 18, 1979.
Smear and direct surveys were made and recorded for the incoming shipments.
855 123 -
No items of noncompliance or deviations were noted.
10.
Shipping Incidents The licensee received an incoming shipment on June 26, 1978, of a AmBe sealed source from Halliburton, Company, Oklahoma. The shipping container was of the wrong type, the licensee notified both the sender and DOT.
No items of noncompliance or deviations were identified.
11.
Personnel Radiation Protection - External The licensee's program for external exposure control consists of exposure rate measurements, pre-job manrem estimation, whole body and extremity wrist badges and self-reading pocket dosimeters. Film badges are exchanged on a weekly basis and pocket dosimetera are read daily.
The licensee's direct radiation monitoring program, the survey records and the use of manitoring devices were reviewed during this inspection and found to be in accordance with the applicable sections of the License Specifications, Operating Procedures and the Safety /
Health Physics Program Manual.
The licensee is continuing to study the effect or radiation levels observed in gloveboxes in Rooms 8 and 9 to determine whether whole body film badges reflect total exposure (IE Inspection Report No.
70-572/77-01).
Personal monitoring records were examined for the third and fourth quarters of 1978 and the last quarter of 1979. As the result of an evaluation made in 1976, the licensee multiplies all wrist film ba ge results by two to obtain extremity exposures. The maximum i
quarterly exposures were as follows:
Third Quarter Fourth Quarter First Quarter 1978 1978 1979 Whole Body 0.64 rem 0.72 rem 0.57 Extremity 4.70 rem 4.88 rem 21.38 rem An individual working in a glove box with radioactive solutiens received a total haud exposure of 21.88 rem as reported on the basis of wrist badge results for the first quarter of 1979. The NRC-RIII was notified by letter on April 5, 1979. The letter gave the results of the licensee's investigation and included their corrective actions to prevent recurrence. The NRC inspectors interviewed the individual involved, his supervisor and the Radiation Protection Officer, 855 124 g-
inspected the glove box where the exposure occured, and reviewed the
~
corrective action. The inspectors did not find reason to disagree with the licensee's ascessment as to the cause of the exposure.
This is an item of noncompliance with 10 CFR 20.101(a) which limits the dose to the hand of an individual to 18 3/4 rems per calendar quarter.
12.
Personnel Radiation Protection - Internal The licensee's program for internal exposure control consists of surface contamination surveys, airborne radioactivity monitoring, urine samples and in vivo counting, when necessary.
Daily air samples are taken in each room of the process area and also in three locations of the support area. The samples are located so as to be representative of the breathing zone concen-trations. All of these twelve fixed station samples are collected at the rate of 20 liters per minute for periods of eight hours at a time to coincide with the work shift. The licensee uses HV-70 as the filter media for these samples. Multiple counts are required on each sample due to natural alpha activity.
In addition, the licensee has a constant air monitor operating in each of the four rooms in the process area.
In plant air sample records were reviewed for the period May 1978 through May 1979.
There were two instances of "high" air sampoutsideRoom9therewas4.0x On January 7f8 and 19,1979, and 2.03 x 10 microcuries/ml while work with Pu-238 was in V5 8r*SS (10 CFR 20, Appendix B, Table 1, Column 1 limits = 2 x 10 micro-curies /ml). On each day a glove failed in the glove box.
Based on the exposure time for personnel present in the area, the licensee calculated that the intakeo for one person were equivalent to 20.6 and 26.7 MPC-hours for a total of 47.3 MPC-hours, at the uniform concentrations specified in Appendix B, Table 1, Column 1.
The licensee made evaluations and took actions to assure against recurrence. The licensee maintained records of the evaluation but stated none were maintained of the actions taken to assure against recurrence. Urine samples taken after the occurrence indicated no detectable intake of material. This is an item of noncompliance with 10 CFR 20.103(b)(2) which states whenever the intake of radio-active material in any period of seven consecutive days exceeds that which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concer' ition specified in Appendix B, Table 1, Column 1, then the licensee shall make such evaluations and take such actions as are necessary to assure against recurrence. The licensee shall maintain records of the occurrence, evaluation and actions in a form suitable for review. The licensee failed to record the action taken to prevent recurrence of the January 18,. 1979 and
~
855 125
- f'D4d
January 19, 1979, intake of an individual of Pu-238 equivalent to a total of 47.3 MPC-hours at the uniform concentration specified in Appendix B, Table 1, Column 1.
Routine bioassay (urine) samples are collected on a monthly frequency for all employees involved in isotope work. All urine voids are collected between midnight Saturday and midnight Sunday of the designated weekend. Routine samples are analyzed for americium-241 and plutonium-238 by Controls for Environmental Pollution, Int.
Special 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> urine samples are collected as needed. The special samples are analyzed for various isotopes as required. The licensee utilized action levels as specified in License Specification 7.9.3(5) for resampling and investigation action. Urine sample records were reviewed for the period May 1978 through March 1979.
Sampled were 0.00 1 0.05 dpm alpha and 0 1 5 dpm gross beta. During this period no fecal samples were collected and no in vivo counts were made.
The licensee provides respiratory protection but does not take credit for the program. The inspectors noted several instances when half-face mask respirators were used and also noted that all personnel had masks in their possession when working in the process area.
The Radiation Protection Officer periodically performs a smoke test to determine the unit's efficiency.
One item of noncompliance was identified.
13.
Posting, Access Control, and Material Control During several tours of the facility, the inspector noted that areas in which radioactive materials were stored and/or handled appeared to be adequately delineated and properly posted and controlled.
Contaminated material and equipment appeared to be properly contained and labelled. No problems were noted with movement of contaminated materials or equipment within the facility. High radiation areas are posted in accordance with radiation fields as determined by surveys conducted by either manufacturing or supervisory personnel.
Control of access to high radiation areas is established in accor-dance with 10 CFR 20.203(c)(4).
All visitors and employees not associated with the Engineered Products Department are limited entry to the restricted areas under the direct supervision of one of the Department employees. These visitors are issued a film badge, protective clothing, and are instructed as to the procedures of the area in which they are visiting.
No items of noncompliance or deviations were identified.
855 126 9-
14.
Surveys Radiation surveys performed by the licensee include radiation level measurements at the exterior and to the normal work stations for hands inside glove boxes, contamination measurements and personal monitoring for contamination. A review was made of the records of weekly surveys made by the Radiation Protection Officer for the period December 22, 1978 to May 9, 1979. There were no incidents which deprived use of a facility for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. All records showed prompt cleanup and resurveys when levels exceeded the limits in Part 7.72 of the License Specifications.
No items of noncompliance or deviations were identified.
15.
Notifications and Reports Based on a review of records and statements by licensee represen-tatives, there has been no loss of material, no incidents, and one overexposure since the previous inspection. The licensee reported the overexposure as required by 20.405 in a letter on April 5, 1979.
The letter also included an evaluation and the corrective actions taken to prevent recurrence. An interview with the individual involved verified he had been informed of his exposure and knew of corrective action taken to prevent recurrence.
No items of noncompliance or deviations were identified.
16.
Radioactive Effluent Control and Waste Control With the exception of radioactive liquid which goes to the retention tank from the emergency shower and decontamination sink, all radio-active liquid wastes are mixed with absorbent material and disposed of as solid radioactive waste. None of the retention tank waste is disposed of into the sanitary sewer until the concentrations are below those listed for insoluble plutonium-238 as listed in Appendix B, 10 CFR 20.
On the basis of floor wipe tests and samples of the mop water from the Support Process Area, the licensee now disposes of the mop water from this area into the sanitary sewer system.
There was only one transfer of liquid from the retention tank to the sanitary system of 30 gallons for the period January 1978 to May 1979. The sampling of this water prior to transfer showed it to be well below the insoluble plutonium-238 concentration limits in Appendix B, 10 CFR 20.
The licensee stores sealed solid waste drums in Building 2, Room 7a while waiting for a sufficient number to accumulate for transfer to the disposal agency. Each drum is identified by a number which is cross referenced in a log book. Several drums were in the storage 6 855 127
building at the time of this inspection.
Independent measurements conducted outside the building by the inspector and the licensee during the inspection showed radiation levels of less than two millirem per hour at the outer restricted area fence. The outside area of the building is in a restricted area for the purpose of radiation protection. Fifty-six drums (55 gallons each) were shipped to S. W. Nuclear Company, Louisville, Kentucky as " Low Specific Activity" on May 25, 1978 for disposal. Records of ghe shipmentsurveyshowedthegrumstobelessthan9pCi/100cm alpha and less than 45 pCi/100 cm C-14 on swipes and less than 1 mrem at the surface direct.
No items of noncompliance or deviations were identified.
17.
Stack Effluent All glove boxes and the hot cells are exhausted through absolute filters and into a common absolute filter in a single 50 foot high stack. This edaust system runs continuously at the rate of 360 cubic feet per minute at a static pressure of 4.5 inches.
Stack sampling is conducted on a continuous basis collecting samples covering 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> per week. Each hood and ceiling exit point for the rooms in the Controlled Process Area has a separate exhaust and HEPA filter and each exhaust system is samples at the rate of 20 liters per minute for periods of e'.ght hours or more to coincide with the work shift.
An examination of the air sample results since the previous inspec-tion showed that in general the stack air cone gtrations averaged less than 10% of the applicable limit (1 x 10 microcuries per millilite r).
D.O.P. tests were performed on the six final filters on December 28, 1978. Four of the units were considered acceptable (98.5 to 99.99%
efficient) but two failed (28 and 93%).
Inspection of the two units by the licensee identified the problem to be due to frame fan and duct structural deficiencies rather than filter failure. The NRC inspectors noted that new construction had already been started to correct the problem. The stack monitor systems showed no release of radioactive effluent from these units in excess of 10 CFR Part 20, Appendix B limits.
No items of noncompliance or deviations were identified.
18.
Sealed Sources Sealed sou:.es used by the licensee are leak tested at required intervals. All tests show less than 0.005 microcuries removable contamination. A total of 13 sources, the entire inventory, were tested on March 14, 1979, the date of the most recent test. ~~
855 128
No items of noncourpliance or deviations were identified.
19.
Quality Assurance A review of the Quality Assurance procedures was made during this inspection and it was noted the licensee has written quality control procedures, techniques and methods for assuring the quality of finished prc bets which include the cataloging of the items, veri-fications of total activity and concentration, leak testing and labeling. The inventory records for January 31, 1978 to March 1, 1979, show no Cf-252 Josses since it is used as received, in capsule form. The Pu-233 losses ranged from 0.01 to 0.33 grams per month with one exception of 3.25 grams for April 26, 1978. This occurred when a known amount became contaminated with another nonradioactive material rendering it unusable for source manufacture and discarded as radioactive waste. Q4 also is responsible for keeping the licensee within possession limits.
No items of noncompilance or deviations were identified.
20.
Confirmatory Measurements The inspectors measured exposure rates of direct gamma and neutrons in the controlled process area, on the roof and along the fence outside the building. Smear surveys were also taken of 14 different locations and pieces of equipment in the process area and on the roof of the facility. The direct survey results were consistent with the posted readings and the licensee's records of past surveys.
The smears were counted initially by the licensee and then again by a National Laboratory chosen by NRC-RIII. fhesmearswerelessthan 20 dpm/100 cm# and less than 100 dpm/100 cm By except for one table top below a pass box whien showed 90 dpm/100 cm a.
The ligensee decontaminated this area immediately to below 20 dpm/100 cm.
Personal surveys of shoes and snoe covers by the inspector during visits to the processing area showed no contamination.
No items of noncompliance or deviations were identified.
21.
Independent Inspection Effort The inspectors used the licensee's velometer to measure linear air flow to the two fume hoods. The air flow was less than 50 linear feet per minute. The licensee demonstrated that neither hood was in use, that two new fans had just been installed and were awaiting duct installation. These fans were installed to tervice these hoods. The licensee intends to keep the hoods from use until the entire ventilation system is in service.
855 129 G-
+
The inspectors observed source fabrication operations, for Am-241 smoke detector sources, observed techniques, and made radiation level measurements using licensee-owned ion chamber survey meters.
No items of noncompliance or deviations were identified.
22.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection on May 24, 1979. The scope of the inspection findings and enforcement actions were discussed.
The licensee is continuing his evaluation to determine if any signif-icant personnel whole body exposures are not being reflected on whole body film badges when personnel are working in certain glove boxes in the Controlled Process Area.
855 130
.pkW
_n.