ML19296D047
| ML19296D047 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 01/02/1980 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D024 | List: |
| References | |
| 70-0398-79-02, 70-398-79-2, NUDOCS 8002290287 | |
| Download: ML19296D047 (10) | |
Text
3 U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-398/79-02 Docket No.70-398
'1 License No. SNM-362 I
UR Priority Category Licensee:
U.S. Department of Commerce National Bureau of Standards Washington, D. C.
20234 National Bureau of Standards Facility Name:
Inspection at:
Gaithersburg, Maryland N vember 14-16, 1979 Inspection conducted:
Inspectors:
hif
/[7-[9"4 J.koth,ProjectInspector date ' signed date signed date signed Approved by:
A (W$
is,
//-)./,96 H.W. Crocker, Cdief, Fuel Faility dite / signed Projects Section, FF&MS Branch Inspection Summary:
Inspection on November 14-16,1979 (Report No. 70-398/79-02)
Areas Inspected:
Routine, unannounced inspection by region-based inspector of:
10 CFR Part 21; organization; facility changes and modifications; internal review and audit; safety committees; procedure control; review of operations; nuclear criticality safety; emergency planning-drills; and followup on licensee event. The inspection was initiated on the day shift and involved 23 inspector-hours onsite by one NRC region-based inspector.
Resul ts:
Of the 10 areas inspected, no apparent items of noncompliance were identified in 9 areas.
One item of noncompliance was identified in one area. (Infraction
'...: instances of failure to maintain centrol over procedures concerned with the use of radioactive materials (79-02-01) -
paragraph 8 and 9.
Region I Form 12 (Rev. April 77) 2h-T 8002290 I
4
't.
DETAILS 1.
Persons Contacted
- R. P. Bartlett, Director of Administrative and Information Systems
- A. Schwebel, Chief, Health Physics
- T. J. Hobbs, Supervisory Health Physicist
- L. E. Pevey, Chief, Occupational Health and Safety Division C. E. Kuyatt, Director, Center for Radiation Research
- Denotes those present at the exit interview.
The inspector also interviewed 13 other licensee employees during the course of this inspection. They included MBA custodians, health physics technicians, scientific staff members and general office personnel.
2.
Organization The current organizational structure and incumbents relative to License No. SNM-362, as of October 1, 1979, are:
E. Ambler, Director, National Bureau of Standards T. A. Dillion, Deputy Director, National Bureau of Standards R. P. Bartlett, Director, Administrative and Infomation Services K. E. Bell, Deputy Director, Administrative Systems L. E. Pevey, Chief, Occupational Health and Safety Division A. Schwebel, Chief, Health Physics T. J. Hobbs, Supervisory Health Physicist The Site Radiation Safety Connittee, described in Paragraph 5, reports administratively to T. A. Dillion, Deputy Director, National Bureau of S, mdards.
3.
Review of Operations The inspector examined all areas of the site where Special Nuclear Material (SNM) is handled to observe operations and activities in progres.,; to inspect the nuclear safety aspects of the facility; to check the general state of cleanliness, housekeeping and adherence to fire protection rules; and, to review operating procedures with members of the laboratory staff.
3 a.
Postings The inspector noted that the various laboratories and storage locations are not posted with SNM quantity limts allowed by license conditions with the exception of Room 118, Building 222 and the Standard Reference Material (SRM) storage vault.
This vault was posted as required by license conditions.
The other areas were not required to be posted with quantity limits by license conditions.
However, the the inspector determined through discussions with laboratory operating staff members that they were not ware of the SNM quantity limits allowed.
For example, the license states that Room B25, Building 221 " Mass Spectrometry" would not contain more than "a maximum of 10 milligram uranium. fio plutonium work is conducted here."
It was noted that in each case examined, the quantity of SNM in each unposted area was below the limits stipulated in the license.
This was discussed with licensee representatives at the exit intervie.v, who indicated that a major change in the current program would have to take place inorder for the authorized license limits to be approached in actual practice.
Thus, the licensee did not consider it necessary to post the stipulated licensc limits.
The inspector indicated that some mechanism should be devised to inform the operating staff of the established limits in each area.
This will be reexamined during a subsequent inspection.
b.
Waste Containers The inspector noted that each container which was authorized fcr the disposal of waste potentially contaminated with radioactive material was properly labeled and had an inventory sheet attached which indicated the type and estimated quantity of radioactive material being disposed of.
c.
Standard Reference Material Storage Vault The inspector examined the SRM storage vault located in Room Bil8 of Building 222.
All fissle material which was not contained in shipping packages was stored as required in the storage bins located along each side of the room.
Source Materials including natural and depleted uranium and thorium were stored in storage containers on the floor of the vault against the wall and closed shipping packages containing quantities of Pu 238, Pu 239, Pu 240 and Pu 244 were stored down the center of the room away from the rear wall as described in the approved license application.
It was noted that a
4 storage container marked as containing thorium metal read about 16 mr/hr on contact and about 5.2 mr/hr at one foot and was not labeled with a caution Radiation area or Radioactive Material sign.
Since this room was a limited access area with access limited to the vault custodian in attendance at all times this container was exempted from the labeling requirement.
However, it was pointed out by the inspector that identification of the radiation levels on this container would help preclude individuals from stopping to talk in the vicinit, of this container especially since the container was being stored just inside the entrance to the room.
A licensee representative imediately labeled this container in a adequate manner.
d.
Procedure Review The inspector reviewed the safety implications and operational requirements of the following procedure with a staff member.
NBS Special Publication 260-27 " Standard Reference Materials:
Uranium Isotopic Standard Reference Materials" issued April 1971.
Through discussions with this staff member and through examination of the above procedure the inspector determined that the procedure addressed analytical techniaues for the analysis of samples but did not address SNM handling techniques and lot procedures.
General information relative to the availability of safety equipment is discussed in the facility Radiation Safety Manual.
However, safe handling techniques and procedures including the use of protective clothinq is not spelled out in any procedures which are immediately available to the operating staff.
Further information on this aspect of procedural controls is given in paragraph 9 of this report.
e.
Vault Custodian Training The inspector was informed that the SNM vault custodian had joined the ICAL-SNM staff on August 1,1979.
The inspector determined that this individual, who was a professional level scientist, had been provided with formal training in the necessary fields, had been indoctrinated by health physics personnel in radiation safety and criticality control but had not completed at least 6 months on-the-job training by the previous custodian.
Discussions with licensee representative indicated that this individual will not be given final authority to operate independently as the vault custodian until February 1, 1980.
5 4.
Nuclear Criticality Safety a.
Criticality Monitors The SNM Vault Room B 118, Building 222 is protected by four criticality monitors.
These monitors are wired in such a way as to constitute two dual monitors connected in series.
Both monitors in a series must be set off to activate the horns located on each floor of the building.
Examination of licensee records for the time period February 7,1977 through November 13, 1979, indicated that the monitors had been silent tested once each week by exposing the detector to a built-in test radiation source.
The criticality monitors were last calibrated on February 2,1976.
Since that time licensee records indicate that the meter readings may have drifted about 10% which is not considered by the licensee to be a significant change in the calibration of the instrumentation.
b.
Criticality Alarm Checks The licensee conducts a monthly siren check to assure that the alarm system remains operable.
The licensee set off the criticality monitors with a cobalt source to annunciate evacuation drills for Building 222 every six months between September 29, 1976 and September 28, 1979 as indicated by licensee records.
The records indicated that the evacuations were completed in less than 4 minutes and that the emergency evacuation alarm system functioned properly during each drill.
No inadequacies with the emergency alarm system or evacuations were identified.
c.
Audi ts The licensee has not had a formal audit system to assure that all criticality safety aspects of the operation were conducted in compliance with federal regulations, License SNM 362 and/or internal operating procedures.
The licensee health physics technicians conduct a " spot check" periodically while conducting contamination surveys for the applicable areas.
These checks are informal in nature and no records are maintained of the observations made.
Through discussions with licensee representatives it was determined that the licensee is considering the establishment of an external audit program with two other agencies (the Armed Forces Radiobiology Research Institute, (AFRRI) and the Naval Research Laboratory (NRL).
If and when
6 this program is instituted, teams of health physics personne?
from each of the facilities would audit the health physics programs at the other facilities at some specified frequency.
Whel this program is instituted it will eliminate a program wea) ness discussed during a previous inspection of this facility.
(See Paragraph 7b, inspection report no. 70-398/77-02).
5.
Safety Committees A Radiation Safety Committee has been established to advise the Deputy Director of NBS on matters pertaining to radiation safety, to coordinate the activities of this committee with the Radiation Safety Officer, the Director of the Center for Radiation Research has been designated as chairman of this committee.
Members of the Radiation Safety Committe as of this inspection include:
C. E. Kuyatt, Chairman, Director, Center for Radiatbn Research A. Schwebel, Radiation Safety Office, Chief, Health Physics R. S. Caswell, Chief, Nuclear Radiation Division R. S. Carter, Chief, Reactor Radiation Division T. M. Ruby, Deputy Chief, Reactor Radiation Division R. R. Greenberg, Inorganic Ana'ytical Research Division J. N. Brewer, Chief, Plant Div :sion W. J. Rabbitt, Security Officer L. E. Pevey, Chief, Occupational Health and Safety Division M. A. Greene, M.D. Medical Officer Records maintained by the licensee and examined by the inspector indicated that meetings of the Radiation Safety Committee for the years 1978 and 1979 were held on October 23, 1978 and October 30, 1979 respectively.
Topics discussed during these meetings included, a review of the NBS health physics operations; badging (film or TLD) of Building 245 personnel; review of the NBSR and Building 222 emergency evacuation plans; conduct of criticality evacuation tests; reactor staffing, training, and status of the dosimetry program.
6.
10 CFR Part 21 Inspection The inspector determined that the licensee had posted the information required by 10 CFR 21.6 at applicable locations throughout the facilities.
The licensee had also established applicable procedures for the review, evaluation and reporting of defects as required by 10 CFR 21.21.
7 7.
Facility Changes and Modifications The inspector determined through discussions with licensee representatives and examination of the various areas of the facilities that no facility changes and/or modifications had been initiated since the last inspection within the scope of this inspection.
8.
Followup on Licensee Events The inspcu ar examined licensee event reports for the calendar years 1977 and 1978.
On April 4, 1978, an experimenter in Room B48, Building 243, had an accident while attempting to ignite an oxygen torch to flame-seal some glass ampoules containing 241 Pu.
The glove box that the individual was working in had filled with oxygen after the torch went out and, when he tried to re-light the torch, the oxygen ignited and blew the face plate out of the box.
The experimenter was not injured in the resulting explosion.
Health Physics responded to the call for assistance.
Smears were taken of the surrounding floor area in the laboratory and the glove box itself, but no contamination was found.
The experimenter was surveyed for contamination and found to be free of activity.
The ampoules containing the 241 Fu were inspected end found to be intact in spite of the explosion.
Hence, it was determined that no activity had been released as a result of the accident.
The inspector discussed this incident with the experimenter and health physics personnel and determined that no further corrective actions had been taken to preclude a repeat of this type of incident.
After the laboratory had been cleaned up the experimenter transferred the ampoules out of the affected glovebox into a hood and completed flame sealing the ampoules.
Under normal circumstances this type of ampoule was flame sealed in a hood.
However, because these ampoules contained plutonium the experimenter decided to conduct this operation in a glovebox.
The NBS Radiation Safety Manual in Part III paragraph Cl requires the Form NBS-365 " Change in Source Utilization" be submitted to Health Physics prior to implementing a change in procedure as in this situation.
This fona was not submitted for review by Health Physics as required.
This was identified as an instance of noncompliance. (79-02-01).
In addition, the inspector determined that the licensee had not taken corrective actions to assure that this type of incident would not occur in the future.
For example, the use of oxygen-gas torches for flame sealing in hoods or gloveboxes was not reevaluated.
When discussed with licensee representatives the inspector was informed that this type of operation would no longer be conducted in gloveboxes.
The inspector discussed the use of limited volume gas welders, using water as the source of the gas which is generated at a controlled rate, for such operations.
8 9.
Procedure Control The facility " Radiation Safety - Rules and Regulations Manual" incorporated into the facility license by License Condition 10 describes the procedural requirements for the acquisition, use, handling, control and disposal of radioactive materials including special nuclear materials.
The procedural requirements relative to the loss, theft or accidents involving radioactive sources is also discussed.
The licensee uses the following forms to maintain control over radioactive materials:
a.
NBS-364 " Proposal to Acquire Radiation Source" b.
NSB-365 " Proposed Change in Utilization of Radiation Source" c.
NBS-366 " Record of Inspection for Radioactive Material" d.
NBS-367 " Proposed Removal or Transfer of Radiation Source or Irradiated Equipment" e.
NBS-368 " Report of Loss, Theft or Accident Involving Radiation Source" f.
NRC-741 " Nuclear Material Transfer Report" for Facility YBC The initiation of a project involving ionizing radiation must have prior approval from the Health Physics Section.
This approval covers the initial procurement, installation, location and use of the source.
Any changes which might affect radiation safety considerations for a project already underway must also have prior approval.
All fonns must be completed and submitted to the Health Physics Section by the initiator.
Approval by the Health Physics Section is shown by signature on the appropriate form.
In order to review the implementation of procedure control require-ments, the inspector examined 30 NBS-364 forms issued between July 25, 1979 and November 9,1979 which were on file in the Health Physics Section.
Form NBS-364 requests information including, but not limited tc; proposal approval and date; method of acquisition; source description (detailed); use to be made of source (. describe in detail including handling procedures; places to be stored; custodian and source users including whether or not qualified by health physics); license number; date of review by Health Physics; whether or not approved by Health Physics;and the Health Physics section signature.
Of the 30 NBS-364 forms examined, 26 did not
9 describe the use to be made of the source in detail (procedures, etc.) as required, one was blank; 9 did not have the proposal date filled in; 8 did not show the storage locations; 14 did not show the applicable license number; 7 did not indicate the source users; 9 did not show that the users had been qualified by Health Physics; and,5 did not indicate the date reviewed by Health Physics.
Failure to complete the NBS-364 forms as required was identified as an instance of noncompliance.
(79-02-01).
In addition, the inspector selected three NBS-364 forms (identified as RS No. 1171 dated July 26, 1978; RS No. 1175 dated July 28, 1978 and Pu Be Source M737 dated September 11,1979) and attempted to trace the radioactive material from acquisition through use to disposition. With considerable effort it was determined that the Pu Be Source M737 had not been received; the radioactive material associated with RS 1175 was traced but no handling procedures were available or indicated on the NBS-364 form,with respect to RS 1171, the available information indicated that 100 standard reference material samples had been prepared but only 95 could be accounted for. Discussions with licensee representatives indicated that apparently only 95 samples had been prepared.
Once again material handling procedures were not spelled out on the NBS-364 form.
It was this material, plutonium nitrate, which was involved in the incident described above in paragraph 8.
The inspector expressed concern about the procedure control problems observed and also noted through discussions with licensee representatives and examination of available records and information that no procedures have been issued to or are easily available to users of radioactive materials to describe the handling of radioactive materials, protective clothing requirements, etc.
These procedures are available in the facility Radiation Safety Manual copies of which were not found to be readily available to the users of radioactive materials.
This was discussed at the exit interview and the licensee representatives indicated that the entire issue of procedure control and/or availability will be reviewed.
The licensee issued a memorandum to all Division Chiefs on November 16, 1979, which reminded users of radioactive materials concerning the use and completion of the NBS-364 and 365 forms.
It also requested a list of qualified users and a list of facilities and equipment which were to be evaluated by Health Physics.
10 10.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph
- 1) at the conclusion of the inspection at 1:00 p.m. on November 16, 1979.
The inspector summarized the scope and findings of the inspec tion.
The inspector also made the following remark to the licensee representatives.
Remarks made by licensee have been incorporated into the applicable paragraphs of the report details.
License management was requested to notify the NRC Region I office whenever unusual events took place at the facility.
The licensee indicated that the project inspector would be advised of unusual events as they occur.
.