ML19323F468
| ML19323F468 | |
| Person / Time | |
|---|---|
| Site: | 07000572 |
| Issue date: | 05/19/1980 |
| From: | Slawinski W, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19323F464 | List: |
| References | |
| 70-0572-80-02, 70-572-80-2, IEB-79-19, NUDOCS 8005290055 | |
| Download: ML19323F468 (12) | |
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 1
REGION III I
Report No. 70-572/80-02 4
4.
Docket No.70-572 License No. SNM-567 Priority 1 Category B Licensee: Monsanto Research Corporation Dayton Laboratory 1515 Nicholas Road Dayton, OH 45407 Type of License: Manufacturer and Distributor Type of Inspection: Unannounced Routine Dates of Inspection: March 19 and 20, 1980 April 14-16, 1980 Inspectors:
W. J. Slawinski [//
/f!/O D. J. Sreniawski 5/m/so i
/
Inspection Summary Inspection on March 19-29, 1980 and April 14-16, 1980 (Report 70-572/80-02)
Areas Inspected: Routine, unannounced inspection of radiation protection practices at a nuclear source production facility included:
response to I&E Bulletin No. 79-19; organization; training; internal audits; facil-ities; equipment; transfer of material; external radiation protection; internal radiation protection; posting; access control; materials control; surveys; notifications and reports; radioactive effluent controls; sealed sources; quality assurance; stack monitoring, confirmatory measurements; and independent inspection effort. The inspection involved 41 inspector-hours on-site by two NRC inspectors.
Results: There were no items of noncompliance or deviations identified.
ON 8005290
DETAILS 1.
Persons Contacted
- R. L. Schimmel, Manager, Engineered Products Dept.
- R. R. Taylor, Manager of Operations, Engineered Products D'ept.
4.
- S. D. Hoadley, Health Physicist and Radiation Protection Officer H. L. Coleman, Manager of Manufacturing D. Kiehne, Inventory Clerk C. A. Garthwait, Chemist E. A. Steinmetz, Internal Auditor D. E. Sevy, Technical Specialist L. Walker, Technical Trainee
- Denotes those who attended the exit interview.
2.
License Action on Previous Inspection Findings (Closed) Noncompliance (70-572/79-01): Failure to limit extremity exposure of one radiation worker to Part 20.101.
The inspector found that procedures for pre-irradiation surveys of work places, and lower in-house action levels for personnel exposures were being followed.
(Closed) Noncompliance (70-572/79-01): Failure to record action taken to prevent recurrence after an individual's intake of radio-active material in excess of the equivalent of 40 MPC-hours. The licensee lists assignments of MPC-hours to individuals in their
" Health Physics Log."
This log includes the " Action to Prevent Recurrence." (Attachment 1, Blank Health Physics Leg Form)
(Closed) Item of Concern (70-752/79-02):
Concern for management control to assure adequate shielding of radiation levels during shipments _of neutron sealed sources. The inspector found new pro-cedures which require a second party inspector to review the ade-quacy of shipping container and shipment survey and sign-off on the survey record form NPD-4, if he approves of the shipment.
3.
Organization The licensee's organizational structure remains as described in the Licensee's Specifications Part 5.2 (March 15 3).
S. J. Dearth (formerly S. J. Mougey) of Nuclear Manufacturing Support no longer performs the inventory of Special Nuclear Mate-rial and Byproduct Licensed Material. This function has been assumed by D. Kiehne, Inventory Clerk.
No items of noncompliance or deviations were noted.
0 4.
Radiation Protection Procedures 0
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 vas as described Up the License Specifications and the Operations Manual submitted with the U
May 25, 1978, amendment.
No items of noncompliance or deviations were identified.
5.
Licensee's Internal Audit The inspectors reviewed the reports of the licensee's Biannual Health Physics audits conducted by E. A. Steinmetz, the quality control officer, on July 24, 1979, and December 12, 1979.
Included in the items reviewed were the air sampling program, film badge records, training, smear survey, bioassay, direct radiation surveys, procedures, license requirements, and general record review.
The Safety Committee Meeting minutes were reviewed by the NRC in-spectors for the following days:
1980 - 1/18, 2/1, 2/15, 3/13, 3/20, 3/27, 4/4 1979 - 5/4, 5/25, 6/8, 6/21, 6/24, 7/27, 8/10, 8/24, 9/13, 9/20, 10/10, 10/19, 11/15, 12/14 and 12/22.
The licensee also maintains a " Health Physics Log" of any note-worthy events. The inspectors selected the following entries from the log for review.
Date 5/17/79 - Californium-252 sealed source shipped to Westinghouse where the source cap unscrewed from the outer body.
R. R. Taylor (MRC) determined there were no 10 CFR Pa: t 21 implications.
6/22/79 - Two Am-241 gamma window acurces received at Ohmart Cor-poration taped together. Ohmart Corporation personnel could not remove tape because their procedures do not allow hands on sources.
10/30- - Air sample in old room exhaust duct was 233 MPC-hrs 10/31/79 (Pu-238). Occurred when ventilation reversed during removal of old ducts. Air sample in room showed no levels above normal which supported finding that activ-ity was contained in the duct and was not released.
9/19/79 - Inadvertant exposure to film badges (2) when they were not returned to rack but left on cloth! : in work area containing 16Ci AmBE neutron source. Exposures were 40 and 80 mrem for the two week use period.
Individuals reminded to return badges to rack for storage.
11/15/79 -Results of investigation of shipment to Diablo Canyon Power Plant of 3.5Ci Am-241-Be neutron source with radiption levels in excess of 200 mrem /hr at the bottom surface of g.
the shipping container.
12/16/79 -Gloveline exhaust system failed, due to failed bearing in fan motor. System shutdown in the designed sequence. Air samples showed no release of activity.
Licensee intends to install back-up motor with automatic changeover.
4/3/80 - Twopersonsassigned12.1ggC-hr(Am-241)exposureafter air samples showed 1.5x10-uCi/ml when tape seal on duct filling failed. New, improved seal material now applied to fittings.
All problems were resolved, none were items of noncompliance.
6.
Training New employees who work in the process area are required by License Specification 5.7.1 to receive a two month apprenticeship. As they are trained they are " work certified" [ Attachment 2, Work Certifica-tion - Nuclear Form Rev. 2 (2-79)]. An interview of the most recent hire showed his awareness of the process.
Retraining sessions are required to be held at least quarterly by License Specification 5.7.2.
Review of the retraining records showed the following sessions were held:
Date Topic 4/22/79 Hand exposures, radiation survey requirements.
6/21/79 Operation of new survey meters, review of exposure limits, report of last NRC inspec-tion results.
9/20/79 Topic not recorded by NRC inspectors.
12/22/79 Topic not recorded by NRC inspectors.
3/27/80 I & E Bulletin No. 79-19 and new procedures, NPD-STD-032 for shipments and NPD-STD-002 for Waste Storage and Disposal.
No items of noncompliance or deviations were identified.
1 7.
Facilities 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 compromis-ing the support area. These latter rooms involve facilities for counting and leak testing equipment, certain machine operadions, QA g
storage, packaging.and receiving of material. Diagrams and descrip-tions of the facility are contained in Section 7.3 of the licensee operations manual.
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 per-mitted for authorized persons only. The process area is padlocked during off-shift areas.
Designs have been completed and funds appropriated for construction of an underground bunker for storage of radioactive material. The design provides for tornado proof construction.
A portion of the emergency shower facility is being converted to an in plant laundry for protective clothing used in the process area.
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 Li-censee's Operation Manual.
The final filter bank, exhaust fans, and portions of the duct system servicing the room exhaust system have been replaced. The system provides for back-up exhaust so that if one unit fails the second fan switches on automatically. Return to power after a total power loss is sequential so that the glove boxes are either at static or negative pressure.
Provisions were included for a " bag-out" filter change system.
-Portable survey instruments are calibrated quarterly; records show March 3,-1980 to be the most recent date of calibration.
No items of noncompliance or deviations were identified. -
9.
Transfer of Materials The licensee made approximately 285 shipments of licensed material for the period May 11, 1979, to April 9, 1980. Records of three shipments were reviewed after being chosen at random from the "Out-going Shipment" Log, they were:
4.
Shipping Transport Date Customer Source Curies Index 5/18/79 Schlumberger Well Service MRC-GB 0.33 each 9.1 3369-3377 5/22/79 Combustion Engineering MRC-AMBE 9.2 39.4 3521-3534 12/18/79 Australia Pu-238 3.5 4.7 Be-463 The NRC inspectors verified the licensee had copies of the customer's licenseF which authorized possession of the material ordered, leak tests were made of the sources before shipment, records of radiation surveys were properly maintained and the record of labels attached to the shipment was adequate.
The licensee received 42 shipments of licensed material and 243 empty returnable containers for the period May 2, 1979, to April 14 1980.
Smear surveys of the shipping containers were less than 9x10 6 uCi.
Direct surveys of the container surfaces were less than 10 mrem /hr at three feet.
No items of noncompliance or deviations were identified.
10.
Shipping Incidents The licensee shipped a nominal 3.5Ci americium-241-beryllium special form neutron source to Diablo Canyon Power Plant in California on October 29, 1979. Radiation levels at the surface of the shipping container were in excess of the 200 mrem /hr Department of Transporta-tion limit. The incident was the object of a special inspection (see Report No. 70-572/79-02 dated February 12, 1980).
11.
Personnel Radiation Protection - External The licensee's program for external exposure control consists of ex-posure 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 dosimeters are read daily.
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The licensee's direct radiation monitoring program, the survey re-cords, and the use of monitoring devices were reviewed daring this inspection and found to be in accordance with the applicable sec-tions of the Licensee Specifications, Operating Procedures and the Safety / Health Physics Program Manual.
Personnel monitoring records were examined for the second, Third, and fourth quarters of 1979 and the first quarter of 1980. As a' result of an evaluation made in 1976, the licensee assigns hand exposures as twice the wrist film badge results.
In an attempt at ALARA (As Low As Reasonably Achievable) the licensee has reduced their action level for whole body exposures to 500 mrem per quarter. The maximum quart-erly exposure 4 were as follows:
Second atr.
Third Qtr.
Fourth Qtr.
First Qtr.
1979 1979 1979 1980 Whole Body 0.54 rem 0.53 rem 0.52 rem 0.51 rem Extremity 8.26 rem 7.40 rem 3.88 rem 6.72 rem There are fourteen persons routinely badged.
No items of noncompliance or deviations were identified.
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 concentrations. All of these 18 fixed station: samples are collected at the rate of 20 litere per minute for periods of eight hours at a time to coincide with the work shift. Multiple counts are required on each sample due to natural airborne 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 4, 1979, to April 4, 1980. There was one "above normal" air sample.
On April 3, 1980, two persons were compacting waste in a Room 9 glovebox.
The seal on the ventilation duct failed when they placed some waste metal objects against the wall and tried to reduce the size by break-ing it with hammer bl They were assigned 12.1 MPC-hrs (Am-241) each when the 1.5x10 ggs.uCi/ml air sample result was used as their breathing concentration for the conservative assumption of an entire 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shift. The incident was recorded in the " Health Physics Log."
The entry includes the action taken to prevent recurrences.
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 desig-nated weekend. Routine samples are analyzed for americium-241 and plutonium-238 by Controls for Environmental Pollution, Inc., Santa Fe, NM.
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 g
licensee utilized action levels as specified in License Specification 7.9.3(5) for resampling and investigation action. Urine sample re-cords were reviewed for the period May 13, 1979, through February 14, 1980. Samples were 0.00 i 0.05 dpm alpha and 0 5 dpm gross beta.
Since no nasal swipes of greater than 100 dpm nor air samples in excess of 80 MPC-hrs were encountered, no whole body ra-diation measurements or fecal samples were taken during this in-spection period.
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.
No 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.
Con-taminated 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 accordance with 10 CFR 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.
l No items of noncompliance or deviations were identified.
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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 J
monitoring for contamination. A review was made of the records of weekly surveys made by the Radiation Protection Officer for the period May 5, 1979, to March 7, 1980. 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.
I No items of noncompliance or deviations were identified.
15.
Notifications and Peports j
Based on a review of records and statements by licensee representa-tives, there has been no loss of material, and one reportable inci-dent since the previous inspection. The incident involved shipment of a source with radiation levels in excess of 200 rem /hr at the container surface.
(See Report 70-752/80-02) i 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 retentica 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.
There was one transfer of liquid from the retention 2
tank to the sanitary sewers for the period May 1979 to March 1980.
Itconsistedof190gallonsonSeptember6,19g9.
Sampling of this water prior to transfer showed it was 0.2x10- uCi/ml (insoluble alutonium-238concengrationlimitinAppendixB,10CFR20, Column
-, Table II is 3x10- uCi/ml).
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 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 mil-lirem 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. Twenty-one drums (55 gallons each) were shipped on November 28, 1979, and seventeen drums on December 5, 1979, to Chem-Nuclear Systems, Inc., Barnwell Waste Management Facility, Barnwell, S.C. for disposal as waste. 2 Records of the shipment survey showed the drums were 20 d/m/100cm alpha and 100 d/m/100cm beta-gamma on swipes and up to 1 R/hr at contact, 60 mR/hr at 3' on direct surveys.
The waste was shipped in a " sole use" closed transport vehicle and produced 0.5 mR/hr at the driver's seat, 190 mR/hr at the tiuck's surface and 4.5 mR/hr at 6 feet from the truck's surface.
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 exhaust 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 ex-haust and HEPA filter and each exhaust system is sampled at the rate of 20 liters per minutes for periods of eight hours or more to coincide with the work shift.
An examination of the air sample results since the previous inspec-tion showed a 10 MPC-hrs release on April 4, 1979, as compared to the average release concentration of less than 10% of the insoluble Pu-238}imitin10CFRPart20,AppendixB,TableII, Column 1 (1x10 3 microcuries per milliliter).
D.O.P. tests were performed on the six final filters on November 13, 1979. The ranged from 99.98 to 99.99% efficient.
The inspector noted the room area exhaust was replaced with a new improved system since the last inspection.
It was also noted that twelve soil and ten vegetation samples were taken October 10, 1979 as part of a new annual procedure. Results from the analysis were not available at the time of the inspection.
No items of noncompliance or deviations were identified.
18.
Sealed Sources Sealed sources used by the licensee were leak tested in September 1980 within the required six months interval. The tests showed less than 5x10 6 microcuries alpha and less than 4.5x10 5 microcuries beta gamma of removable contamination.
No items of noncompliance 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 con-trol procedures, techniques and methods for assuring the quality of finished products which include tha cataloging of the items, verifications of total activity and concentration, laak ted.ing, and labeling. QA also has responsibility for inventory of licensed U
material. As of the last full inventory on March 31, 1980, the licensee was within his possession limits.
No items of noncompliance or deviations were identified.
20.
Confirmatory Measurements The inspectors measured exposure rates of direct gamma and neutrons in the controlled process area, and along the fence outside the building. Smear surveys were also taken of nineteen locations and pieces of equipment in the process area. The direct survey results were consiotent with the posted readings and the licensee's records of past surveys. The smears were counted initially by the licensee andthenagajnbyNRC-RegionIII. The smears yere less than 100dpm/100cm alpha and less than 100dpm/
for one corridor floor spot (735dpm/100cm}00cm beta gamma except alpha-283dpm/100cm beta gamma) and oge bench top in Room 9 (176dpm/100cm alpha-69dpm/100cr beta gamma). The licensge decontaminated both areas immedigtely to less than 20 dpm/100cm alpha and less than 100dpm/100cm beta gamma.
Personal surveys of shoes and shoe 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 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 (listed in Para-graph 1) at the conclusion of the inspection on March 20, 1980.
The inspection findings were discussed. The licensee had no ques-tions concerning these findings.
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The inspectors commented on the improvements of the process area j
room ventilation system, the addition of an annual soil and vegeta-tion sampling program, and the plans to build a waste storage bunker as indications of management support.
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