ML19343B570
| ML19343B570 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 10/24/1980 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19343B564 | List: |
| References | |
| 70-0398-80-04, 70-398-80-4, NUDOCS 8012240261 | |
| Download: ML19343B570 (10) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
70-398/80-04 Occket No.70-398.
License No.
SNM-362 Priority 1
Category up Licensee:
U. S. Department of Commerce National Bureau of Standards Washington, D. C.
20234 Facility Name:
National Bureau of Standards Inspection at:
Gaithersburg, Maryland Inspection conduct September 29-October 1, 1980 Inspectors:
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/# A V (1 Approved by:
,1 HI /'. C' rocker, Chid, Fuel Facility ddte sfgned P Mjects Section, FF&MS Branch Inspection Summary:
Inspection on September 29-October 1.1980 (Report No. 70-398/80-04)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of the licensed program including: organization; facility changes and modifications; internal review and audits; safety committees; training; review of operations; criticality safety; transportation program; licensee action on previously identified enforcement items; followup on regional office bulletins; and followup on Head-quarter's requests.
The inspection was initiated on the day shift and involved 19 inspector hours on site by one NRC region-based inspector.
Resul ts: Of the eleven areas inspected; one item of noncompliance was identified in one area (Deficiency - Failure to label a package of radioactive material prior to shipment as required by 49 CFR 172.403 (80-04-03), paragraph 10c).
Region I Form 12 (Rev. April 77) f 8012240
OETAILS 1.
Persons Contacted
- L. E. Pevey, Chief, Occupational Health and Safety Division
- H. L. Rook, Acting Chief, Gas and Particulate Science Division
- T. J. Hobbs, Chief, Health Physics C. E. Kuyatt, Director, Center for Radiation Research
- Denotes those present at the exit interview.
The inspector also interviewed 14 other licensee employees during the course of this inspection.
They included NBA custodians, health physics technicians, scientific staff members and general office personnel.
2.
Licensee Action on Previously Identified Enforcement Items (Closed) Infraction (3Sd/79-02-01):
Two instances of failure to maintain control over procedures concerned with the use of radioactive materials.
The inspector verified that the licensee has modified the forms used to acquire and/or describe the use of radioactive materials.
The forms now contain the appropriate information needed to assess the safety of the use of radioactive materials. ' Instructions for the completion of each form have been issued and a list of qualified users has been generated.
The inspector examined several active proposal forms at ranaom and determined that descriptions of the " source" (radioactive material) and facilities being used, safety precautions employed and operating procedures appeared to be adequate. Corrective actions have been completed on this item of noncompliance.
(Closed) Inspector Follow Item (398/80-02-01):
Incorporation of applicable regulatory requirements into operating procedures for shipping.
The inspector verified that the licensee has prepared and issued a procedure " Shipping and Receiving of Radioactive Material" dated May 21, 1980.
This procedure incorporates the applicable federal regulations required for the shipping of radioactive materials from this facility.
l (Closed) Inspector Follow Item (398/80-02-02):
Training of packagers of radioactive material.
The inspector verified through review of licensee records and discussions with licensee personnel that the packagers of radio-active material had received training during the month of March,1980.
This training included a review of the applicable federal regulations (10 CFR and 49 CFR); shipping-receiving procedures; the Shipping Quality Assurance Program; use of the compactor; and, package inspection, closure, marking and labeling requirements.
(Closed) Infraction (398/80-02-03):
Failure to submit the Quality Assurance Program for Shipping as described in 10 CFR 71.51 as required by 10 CFR
4 3
71.12. The inspector verified that the shipment of radioactive materials in excess of Type A quantities had been terminated on March 21, 1980.
A Quality Assurance Program for Shipping was submitted to NRC-NMSS on May 30, 1980 and was approved by NRC under Docket Number 71-0390, effective September 1, 1980. The licensee resumed shipment of radioactive material in excess of Type A quantities subsequent to September 1, 1980.
Corrective actions have been completed on this item of noncompliance.
3.
Organization The current organizational structure and incumbents relative to License No.
SNM-362, as of the date of this inspection, were:
E. Ambler, Director, National Bureau of Standards R. G. Kammer, Deputy Director, National Bureau of Standards G. W. Chamberlin, Jr., Director, Administrative and Information Systems K. E. Bell, Deputy Director, Administrative Systems L. E. Pevey, Chief, Occupational Health and Safety Division T. J. Hobbs, Chief, Health Physics As a result of an internal audit (see paragraph Sc for details), the staff of the Health Physics group is being increased to 15.
The projected staff is as follows:
T. J. Hobbs, Chief, Health Physics L. S. Coker, Secretary, Nuclear Materials Accountability Assistant (Vacant), Reactor Health Physics Supervisor P. R. Cassidy, Reactor Health Physicist J. J. Shubiak, Reactor Health Physicist (Vacant), Reactor Health Physicist F. Moore, Reactor Health Physics Technician D. Hoaney, Reactor Health Physics Technician (Vacant), General / Accelerator Health Physics Supervisor K. H. Eggert, General / Accelerator Health Physicist (Vacant), General / Accelerator Health Physicist J. H. Kroll, Accelerator Safety Engineer J. H. Terry, General / Accelerator Health Physics Technician C. R. Tynes, General / Accelerator Health Physics Technician G. W. Randel, General / Accelerator Health Physics Technician l
4.
Review of Operations The inspector examined all areas of the site where Special Nuclear Material (SNM) is handled to observe operations and activities in progress; 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.
4 a.
Storage of Neutron Source Standards The inspector noted that Building 245 Room B-24 was no longer being used for the storage of neutron sources.
The sources containing SNM which had been previously stored in this room have been moved to room B-132 in Building 245.
This room is a license authorized storage location for these sources.
No items of noncompliance were identified.
b.
SNM Inventory The inspector reviewed licensee inventory records and as of August 31, 1980 the licensee's inventory of SNM was found to be within the limits authorized for License No. SNM-362.
No items of noncompliance were identified, c.
Area SNM Limits The inspector noted that there was an inconsistency in the area SNM limits as specified in the facility license.
The approved license application dated September 19, 1978 states, in part, in other areas (except Room B118 of Building 222) it is unlikely that material quan-tities will reach 450 grams (SNM).
This implies a maximum allowable limit of 450 grams of SNM in any applicable area.
The limits for the Analytical Chemistry area (Rote A344 of Buildit,g 222) as stated in the approved license renewal application dated December 18, 1975 are 10 mgraa plutonium in solution; 1 gram uranium as oxide; and up to 1 kilogram uranium for enrichments of 50% and above.
The inspector examined the area inventory records and individual items of SNM stored in this laboratory and found in excess of 13 grams uranium as oxide, 0.2 gram of U-233 and 2.1 grams of plutonium.
In another instance, the approved license application dated December 18, 1975 states that the quantity of SNM allowed in the Reactor Facility Building 235 under this license was "no more than 50 grams of plutonium or Uranium-235, except as Pu-Be neutron sources...no more than 160 grams of plutonium as Pu-Be...".
In this case the inspector determined that 96 grams of SNM as plutonium and/ur uranium-235 was stored in this building.
The inspector did not identify any unsafe conditions or accumulations of SNM.
However, the inconsistencies within the approved license applications were discussed at the exit interview.
Licensee representatives stated that the inconsistencies would be reviewed and action would be taken to clarify the license.
(80-04-01)
No items of noncompliance were identified.
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d.
Standard Reference Material Storage Vault The inspector examined the SNM storage vault located in Room 8118 of Building 222.
All fissile 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 cf 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.
No items of noncompliance were identified.
e.
Procedure Review The inspector reviewed the safety implications and operational require-ments of the following procedure with a staff member and determined that this individual had a good knowledge and understanding of the procedural requirements.
" Administrative Control of Ionizing Radiation Sources", dated 5/21/80.
This procedure was found to be applicable to all radioactive materials handled at this facility except for radioactive materials controlled under the provisions of the NBS Research Reactor ifcense.
Other radiation sources not applicable to this license are also controlled.
The procedure covered the procedural and documentation requirements for the acquisiiton of radioactive materials, changes in use, location or handlers of radioactive materials and the removal of radioactive material fism the site.
No problem areas were identified.
5.
Nuclear Criticality Safety a.
Criticality Monitors The SNM Vault Room B118, Building 222 is protected by four criticality monitors.
These monitors are wired in such a way as to constitute two dual monitors connected in a 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 C:tober 1,1979 through September 29, 1980, indicated that the monitors had been silent tested once each week by exposing the detector to a built-in l
test radiation source.
The criticality monitors were last calibrated on February 2, 1976.
Since that ti.ne licensee records indicate that the meter readings may have drifted about 10% which is not considered sem-w 9
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Na items of noncompliance were identified.
b.
Criticality Alarm Checks The licensee conducts a monthly siren check to assure that the alarm system remains operable.
The ifcensee set off the criticality monitors with a cobalt source to annunciate evacuation drills for Building 222 every six months between September 28, 1979 and September 24, 1980 as indicated by ifcensee records.
The records indicated that the evacua-tions were completed in less than 4 minutes and that the emergency evacuation alarm system functioned properly during each drill. Licensee records indicated that corrective actions were taken immediately whenever the alarm system was found to be improperly operating.
No inadequacies with the emergency alarm system or evacuations were identified.
No items of noncompliance were identified.
c.
Audits The licensee established a " Radiation Safety Review Task Force" which has conducted a comprehensive review of radiation safety practices and procedures and will make recommendations to management fo revised policies which would improve on radiation safety where nec55sary.
The task force was established during March 1980 and was expected to complete the Review within six months.
Members of the task force included:
H. L. Rook, Acting Chief, Gas and Particulate Science Division, Center for Analytical Chemistry - Chairmar.
J. J. Rush, Staff, Reactor Radiation Division, Center for Material Science E. H. Eisenhower, Chief, Office of Radiation Measurement, Center for Radiation Research G. P. Lamaze, Staff, Staff National Measurement Laboratory C. J. Powell, Chief, Surface Science Division, Center for Thermo dynamics and Molecular Science T. E. Gills, SNM Accountability, Office of Standard Reference Materials In addition to the above task force members, advise was sought from the:
7 Radiation Safety Committee Occupational Health and Safety Division personnel Health Physics Officer Reactor Safety Evaluation Committee Through discussions with the Task Force Chairman, the inspector determined that the task force reviewed procedures, previous NRC inspection reports, records, and held discussions with management and operating personnel at all levels.
According to the Task Force Chairman, the review has been completed and the report is being written.
Specific recommendations will be made to management concerning Health Physics staffing, record keeping, acquisition of equipment, environmental monitoring, facility construction and training.
The inspector will review the completed report during a subsequent inspection.
(80-04-02)
No items of noncompliance were identified.
6.
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 Cent' r for Radiation Research has been designated as chair-e man of this committee. Members of the Radiation Safety Committee as of this inspection include:
C. E. Kuyatt, Chairman, Director, Center for Radiation Research T. G. Hobbs, Radiation Safety Officer, Chief, Health Physics R. S. Caswell, Chief, Nuclear Radiation Division R. S. Carter, Chief, Reactor Radiation Division T. M. Raby, Deputy Chief, Reactor Radiation Divis'on R. R. Greenberg, Inorganic Analytical Research Division l
J. N. Brewer, Chief, Plant Division W. J. Rabbitt, Security Officer L. E. Pevey, Chief, Occupational Health and Safety Division M. A. Greene, M.D. Medical Officer l
The inspector examined licensee records of four meetings of the Radiation l
Safety Committee held between November, 1979 and April, 1980.
Topics dis-l cussed included, Health Physics Section staffing and equipment problems, federal and state inspections and the charter of the Radiation Safety Review Task Force discussed previously in paragraph Sc.
No items of noncompliance were identified.
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8 7.
Facility Changes and Modifications The inspector determined through examination of the facilities and dis-cussions with licensee representatives that no facility changes or modi-fications, except for the moving of the neutron source storage area from Room B-24 to Room B-132 in Building 245, as discussed in paragraph 4a, had been initiated since the last inspection within the scope of this inspection.
8.
On-Site Lagoons The inspector determined, through discussions with licensee representatives, examination of site plot plans, and examination of the site, that this licensee has not installed open lagoon or settling basins to which contamina-ted process water could be directed. Thus, there appears to be no potential for the contamination of ground water under this site with radioactive contaminants.
No items of noncompliance were identified.
9.
Licensee Action on Regional Office Circulars The inspector determined through discussions with licensee representatives that IE Circular 80-14, dated June 24, 1980, "Radicactive Contamination of Plant Demineralized Water System and Resultant Internal Contamination of Personnel" had been received and reviewed for applicability for the facili-ties and activities licensed under NRC License No. SNM-362.
It was deter-mined that there is no site-wide capability for the generation and distri-bution of demineralized water.
Licensee representatives indicated that demineralized water is generally located in each laboratory as needed.
Documentation, dated August 18, 1980, being maintained by the licensee, discusses the results of an internal review of this matter.
(80-CI-14)
No items of noncompliance were identified.
10.
Transportation Program a.
Quality Assurance Program As discussed previously in paragraph 2 the licensee has submitted and has had approved by NRC-NMSS a quality assurance program for shipping.
This approved program is applicable to all shipments in excess of Type A quantities after September 1, 1980.
The shipping activities QA Program authorized by NRC approval include procurement maintenance repair and use of packages.
All other shipping activities (i.e.,
design, fabrication assembly, and testing) will be satisfied by obtain-ing certifications from package suppliers that these activities were conducted in accordance with en NRC approved QA Program.
9 The licensee has also written a Quality Assurance Procedure to assure that tha shipment of radioactive materials in excess of Type A quanti-ties is conducted in a safe manner.
The activities covered include:
design; procurement document action sequence; operational description development; document authorizations; special processes; inspections; operational activities; activity and status identifiers; activity bypass; nonconformance; and, audits.
For each activity listed, an established checklist is completed according to the supplied instruc-tions and then the checklist is filed under the direction of the Quality Assurance Program Manager.
No items of noncompliance were identified.
b.
Shipping Records The inspector examined licensee records, at random, for the shipment of radioactive materials during the time period July 1, 1980 and September 16, 1980.
The records indicated that all shipments except one, were labeled, marked, placarded, and recorded as required by federal regulations.
One shipment of U-233 (0.95 mci) dated August 25, 1980 was identified as a transport Group III isotope and was thus exempt from package labeling requirements.
Licensee records indicated that this package was not labeled.
The inspector identified U-233 as a transport Group II isotope which required package labeling if in excess of 0.1 aci.
However, the inspector also noted that this radio-active material had been properly packaged and transported in a Type A container to the customer.
According to the licensee, transport of this material in a properly prepared Type A container reduced the potential of hazards associated with failure to label the package.
Failure to label the package was identified as an item of noncom-pliance (80-04-03).
11.
Training a.
Safety Orientation for New Employees Prior to about February 26, 1980 safety orientation classes for new employees were held every two months.
All new employees were required to attend the first scheduled cicss on safety after staring to work at NBS.
Subsequent to about February 26, 1980 the safety orientation classes for new employees have been administered to the new employees on an individual basis by members of the Occupational Health and Safety Division staff during the first day of employment with NBS.
Contents of this orientation class include:
(1) Identification, display and discussion on radiation and safety signs and labels used in the nuclear and nonnuclear industries.
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These employees are then tested to determine cognizance of required rules, regulations and pro-cedures.
No items of noncompliance were identified.
b.
Refresher Training The licensee conducted a series of refresher training classes for personnel working with radiation or radioactive materials other than at the NBS Reactor.
These training sessions were conducted between November 2, 1979 and December 14, 1979 and covered information relative to 10 CFR 19, 20 and 21.
A total of 332 persons attended these train-ing sessions.
No items of noncompliance were identified.
c.
Health Physics Technician Training Licensee records indicated that during the time period March 5, 1980 through June 30, 1980 at least six training sessions were held with Health Physics technicians attending.
These training sessions covered the subjects of packaging and shipping; preparation of contaminated waste for shipping; the QA Program for Shipping; federal regulations; Health Physics operation onsite; and emergencies.
The licensee has also started a review of the document ANL 7291 Revision 1 " Radiation Safety Technician Training Course" which is being and will be used as a text for an ongoing series of training classes for the Health Physics technicians.
No items of noncompliance were identified.
12.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection at 2:00 pm on October 1, 1980.
The inspector summarized the scope and findings of the inspection.
Remarks made by the licensee representatives have been incorporated into the applicable para-graphs of the report details.
_