ML20005A663
| ML20005A663 | |
| Person / Time | |
|---|---|
| Site: | 07000572 |
| Issue date: | 06/22/1981 |
| From: | Laswk S, Slawinski W, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20005A654 | List: |
| References | |
| 70-0572-81-02, 70-572-81-2, NUDOCS 8106300565 | |
| Download: ML20005A663 (11) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION III c
Report No. 70-572/81-02 Docket No.70-572 License No. SNM-567 Priority i Category B Licensee: Monsanto Research Corporation Dayton Laboratory 1515 Nicholas Road Dayton, OH 4540' Type of License: Manufacturer and Distributor Type of Inspection: Unannounced Routine Inspection Dates: May 18-21, 1981 Inspectors:
S. R. Lasuk 6-/9SI NS'
~t g _g.gl W.J}Sla
'nski Qfgiawski, Chief \\W b ~ N-hl Approved By:
D. J.
Materials Radiation Protection Section 2 Inspection Summarv Inspection on May 18-21, 1981 (Report No. 70-572/81-02)
Areas Ir.spected: Routine, unannounced inspection of radiation protection practices at a nuclear source production facility which included: organiza-tion; radiation protection procedures; internal audits; training; facilities; equipment; transfer of materials; external radiation protection; internal radiation protection; posting, access control, material control; surveys; notifications and reports; radioactive effluent and waste control; stack monitoring; sealed sources; inventory; confirmatory measurements; and in-dependent inspection effort. The inspection involved 47 inspector-hours on-site by two NRC inspectors.
Results: No items of noncompliance were identified.
810 fl 30 0Sd5-c
DETAILS 1.
Persons' Contacted
- R. L. Schimmel, Manager, Engineered Products Dept.
- E. F. Janzow, Manager of Operations, Engineered Products Dept.
'*H. L. Coleman, Manager of Nuclear Manufacturing
- S. D. Hoadley, Health Physicist & Radiation Safety Officer R. R. Taylor, Manager of Smoke Detector Manufacturing J. A. Booth, Acting Manager of Engineering & Quality Assurance D. G. Kiehne, Inventory Clerk E. R. Harrison, Technician L. Walker, Captain of Guards
- Denotes those who attended the exit interview.
2.
Organization The' licensee's organizational structure remains as described in the
. License Specifications, Part 5.2 (March 1978).
E. F. Janzow, Ph.D., replaced R. R. Taylor as Manager of Operations.
Mr. Taylor's new position is shown above.
The following individuals, who were involved in licensed activities, terminated their employment with the licensee:
Name Termination Date Susan Dearth September 15, 1980 Clayborn Garthwait November 24, 1980 Bill King April 17, 1981 Personnel monitoring reports were submitted to the NRC as required.
No items of noncompliance were identified.
3.
Radiation Protection Procedures License No. SNM-567 was amended in its entirety on May 25, 1978, and partially amended on February 27, 1979 and June 24, 1980. License Specifications describe the program which ia conducted under this license. An Operations Manual contains procedures to be followed in carrying out the requirements in the License Specifications.
Any changes in the Specifications are approved by the Commission before being implemented by the licensee. The licensee makes changes in the Operations Manual, as needed, with approved changes in the Specifica-tions. The June 24, 1980 amendment (No. 9) references two letters
-and attachments dated April 18, 1980 and June 6, 1980.
Submitted with the first letter were drawings of the new radioactive waste storage i
facility (Building 7) which is currently in u.e and, attachments to
the second letter were revisions to the Specifications which were required mainly because of the new facility.
No items of noncompliance were identified.
4.
Licensee's Internal Audit The inspectors reviewed reports of the licensee's Health Physics audits conducted by E. A. Steinmetz of the Analytical Technology Department on July 15, 1980 and December 11, 1980. The audits included the waste storage records, air sampling program, film badge records, smear surveys, direct radiation surveys, bioassay records, a review of the Health Physics Log, and inspection of loaded shipping containers; also, sealed source leak tests, soil and vegetation i
analysis records, training, and transportation regulations.
Minutes of Health Physics (Radiation Safety Committee) meetings, held on the following dates, were reviewed by the NRC inspectors:
1980 - 4/18, 5/23, 5/28, 6/6, 6/20, 7/2,-7/25, 9/24, 10/9, 10/17, 11/5, 11/26, 12/15 and 1981 - 1/9, 1/14, 1/30, 3/2, 4/9, 4/23, 5/15.
The following entries from the licensee's Health Physics Log, which contains noteworthy events, were reviewed by the inspectors.
Date 7/16/80 Stack monitor alarmed in Room 6.
The initial and subsequent counts of the air sample showed normal alpha / beta activity.
It is believed that excessive moisture (condensation) in the sample line due to extraordinarily high ambient temperature and humidity caused the alarm. The monitor had to be repaired according to the RSO.
8/3/80 Airoorne activity was discovered when continuous air monitors (CAM's) for the process (production) area alarmed after start-up of the box line exhaust system. The system was temporarily shutdown to repair a 21 P control cylinder 1ccated above the roof. No one was in the process area during the shutdown and therefore, there were no individuals exposed to the air con-tamination.
Subsequent evaluation 9 air samples showed a f
3 maximum concentration gf 7.6 x 10
,pci/ml or, 6 MPC-HRS 3
(based on the 1 x 10
,pci/ml for insoluble Am-241, as shown in Appendix B, Table I, Column 1 in 10 CFR Part 20). Probable cause for this situation was a slightly pressurized box line due to heat from Room 6 cell lights which were left on during the exhaust shutdown.
g 9/10/80 An evacuation drill was held and all personnel responded as required. However, a number of plant horns and sirens failed to sound. The matter was corrected when it was discovered that the failure was due to a burned out relay coil.
No items of noncompliance were identified. l l
5.
Training Training of new employees in the process area and refresher training is covered in Sections 5.7 of the Specifications and 4.7 of the Manual. The inspectors interviewed an employee who began working in the process area in October 1979. His training has been essentially as specified in the above two sections.
A review of group training records showed the following sessions-were held.
Date Topic 6/19/80 Pass box use; recording dosimeter readings and jobs being done (for planning purposes); exposure limits and control; respirator tests; hazardous waste dumping being an illegal act according to letter received by licensee.
9/29/80 Contamination control; survey requirements and exposure control responsibilities of each individual; initial training requirements were reviewed with two new employees.
10/27/80 Atoms, radioactive material and decay; radiation effects; x-ray evaluation.
2/5/E2 A movie, " Radiation and Matter," was shown.
3/12/81 A movie, "SL-1 Accident," was shown.
4/21/81 General review of Section 4.7'.1 of the Operations Manual (regarding Indoctrination of New Employees).
No items of noncompliance were identified.
6.
Facilities The nuclear process area is located in the r. orth wing of Building 2 with the north five rooms, Roems No. 6, 7, 7A, 8, and 9, being used for processing material and Rooms No. 3, 4, 10, 11, 13, and 14 com-prising the support area. These latter rooms involve facilities for counting and leak testing equipment, certain machine operations, QA storage, packaging and receiving of material. Diagrams and descrip-tions of the facility are contained in Section 7.3 of the licensee's Operations Manual.
A new room (Room 7B) has been added to the -nd of the north wing.
This room houses the compactor and is entered from Room 7A.
The licensee controls access to restricted areas by using an elec-tronic interlock system for entrance into the support 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 l
-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. The process area is padlocked during off-shift hours.
A portion of the chain-link access fence was recently taken down to permit removal of some blacktop which will be replaced with concrete.
This work is expected to be completed within a month. The area is posted and adequate precautions have been taken to minimize radiation exposures. Contractor personnel are issued film badges when working in the area. A perimeter fence surrounds the laboratory site and guards man the entrance to this site.
Radioactive waste material is stored in the recently constructed Building 7 which is a poured, reinforced, concrete bunker built into the. incline on the east side of Building 2.
The door to Building 7 is within the fenced restricted access area and is kept locked.
Waste material was initially moved into this building on July 19, 1980.
An in plant laundry for protective clothing used in the process area is now available in a portion of the emergency shower facility. The laundry was initially used on May 5, 1980. The laundry water drains to a 600 gallon retention tank.
Battery operated emergency lights are a new addition in the process area.
No items of noncompliance were identified.
7.
Equipment The licensee utilizes glove boxes, remote boxes, hoods, hot cells and a " canyon" in the process area for the production and handling of radioaccive encapsulated and unencapsulated material in a manner and within those systems which are described in Section 10 of the licensee's Operations Manual.
The exhaust system for the rooms has a back-up provision so that if the primary unit fails, the back-up fac switches on automatically.
The final EEPA filter bank and exhaust fans for this system are located outside of the north wing of Pailding 2, but within the fenced restricted area.
These filters have not been changed as yet but a " bag-out" filter change procedure will be followed when this becomes necessary.
Portable survey instruments are calibrated by the licensee or by the manufacturer, after repairs. Calibration records provided the following information regarding survey meters currently in use or available.
Beta-Gamma Survey Meters: One Eberline, Model R0-2, and One Eberline,
' Model CP, were calibrated on March 24, 1981 and September 12, 1980.
The most recent calibration date for the Nuclear Chicago, Model 2588, cutie pie maintained in the guard house was March 24, 1981.,
i Neutron Survey Meters: Two Eberline, Model PNR-4, were calibrated on March 24, 1981; one of these two units (S/N 2236) was repaired and calibrated by the manufacturer on December 1, 1980.
Alpha Survey Meters: Operational checks are conducted daily on the six Eberline, Model RM-15, meters using a radioactive check source.
No items of noncompliance were identified.
8.-
Transfer of Materials The licensee made approximately 135 shipments of licensed material for the period April 10, 1980, to May 8, 1981. Records of three shipments were reviewed after being chosen at random from the
" Outgoing Shipment" Log, they were:
Shipping Transport Date Customer Source Curies Index 7/22/80 Westinghouse Duke Power Cf-252 0.25 ea.
1.1 117 & 118 1/14/81 Univ. of Auckland, N.Z.
Pu-238 Be 7.6 ea.
6.6 488 & 489 4/29/81 Halliburton Services MRC-AMBE 14.7 9.9 3954-3957.
The licensee has NRC export License No. XSNM0-1388 which authorized the January 14, 1981 shipment. For the other two shipments, the licensee had written certification by the transferee that they were authorized by license to receive the type, form, and quantity of radioactive material transferred. The sources were leak tested prior to shipment.
Direct radiation surveys were made and recorded and shipping labels were ag required. Container surface contamina-tion was less than 9 x 10 pCi.
s The licensee received 21 shipments of licensed material and 154 empty returrable containers during the period of April 15, 1980, to May 19, 1981 6 Smear surveys of the shipping containers were less than 9 x 10-.pCi.
Direct surveys of the containers showed less than ten :nrem/hr at three feet.
There were no shipping incidents during this period of review.
No items of noncompliance were identified.
9.
Pe,rsonnel Radiation Protectior. - External The licensee's program for external exposure control consists of exposure rate measurements, pre-job manrem estimation, whole body 4
n and extremity wrist badges and self-reading pocket dosimeters. Film
-badges are exchange on a weekly basis and pocket dosimeters are read daily. Film badge results are received from R. S. Laudauer by tele-phone the week af ter badges are submitted for processing; Landauer's formal report arrives approximately two weeks later.
Personnel monitoring records were examined for the second, third, and fourth quarters of 1980 and first quarter of 1981. The licensee assigns hand exposures as twice the wrist film badge results based on an evalua-tion made in 1976. Maximum quarterly exposures were as follows:
2nd Qtr., 1980 3rd Qtr., 1980 4th'Qtr., 1980 1st Qtr., 1981 Whole Body 0.49 rem 0.46 rem 0.56 rem 0.52 rem Extremity.
4.42 rem 3.86 rem 6.68 rem 11.66 rem RAD BAR gloves, which contain a thin layer of lead, are now used in the glove box where smoke detector source plates are handled (Am-241 is put on plates in this box). The use of these gloves is primarily to reduce body exposures resulting from the-low energy gamma radiation emitted by the Am-241. The inspectors were told that body exposures from this operatica have been reduced by approximately 30% since these gloves were put into use.
Sixteen individuals are currently badged on a routine basis.
The licensee's direct radiati;a monitoring program, the survey records, and the use of monitoring devices were reviewed during this inspection and found to be in accordance with the applicable sections of the License Specifications and Operations Manual.
No items of noncompliance were identified.
10.
Personnel Radiation Protection - Internal The licensee's program for internal exposute control consists of surface contamination surveys, airbarne rad;oactivity monitoring, urine samples, and in vivo counting when necessary, r
Daily air samples are taken in each room of the process area and also in several locations of the support area. The samples are located so as-to be representative of the breathing zone concentrations. All of these 21 fixed station samplas are collected at the rate of 20 liters 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 five rooms in the process area.
An air sampler is also operating continuously in Building 7; the samples are removed and counted at the end of each week. I
~<~-
l A celective review of in plant air sample records was made for the period April 18, 1980 through.May 6, 1981. Above normal airborne concentrations were found on October 7, 1980, March 17, 1981, and
-March 31, 1981, all due to pass box operations. A maximum of 2.8 MPC-HRS was assigned to an individual as a result of the March 31st operation in Room 6.
The MPC-HRS calculations for exposure to in-plantairconceiBratinsisbased n a C mParison with sci /ml)or_insolublePu-238(3x10){nsoluble Am-241 (1 x 10 u
,pci/ml) limits.
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-hour urine samples are collected as needed.
Such samples are analyzed for various isotopes as required. The licensee's action levels are specified in License Specification 7.9.3(5) for re-sampling and investigation action. Urine sample records were reviewed for the period February 14, 1980 through May 15, 1981. Samples were 0.00 t 0.05 dpm alpha and 0 1 5 dpm gross beta.
Evaluation of routine air samples since mid-April 1980 indicated no need for whole body radiation measurements or fecal sample analyses.
Half face mask respirators are provided for personnel in the process area to use whenever there is a possibility for airborne contamine-tion; e.g., during pass box operations involving unencapsulated material. However, the licensee takes no credit for a respirator program. The respirators are periodically subjected to a smoke test by the RSO to check their efficiency.
No items of noncompliance were identified.
11.
Posting, Access Control, and Material Control During tours of the facility, the inspectors noted that areas in which radioactive materials were stored and/or handled appeared to be properly posted and controlled. Contaminated material and equipment appeared to be properiv contained and labelled. No problems were noted with move-ment of contaminated materials or equipment within the facility. High radiation areas are posted,and control of such areas is established in accordance with 10 CFR 20.203(c)(4).
All visitors and employees not associated with the Engineered Products Departmeat are limited entry to the restricted areas unde. 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 were identified. i
12.
Survevs The licensee performs direct radiation level measurements in and around the north wing of Building 2 and Building 7 plus measurements to deter-mine surface and personal contamination levels. The Radiation Survey Report includes a survey map to identify surveyed areas. A selective review of weekly survey reports was made covering the period April 7, 1980 to May 18, 1981. 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 />. Records of smear surveys in controlled areas showed contaminated surfaces were promptly cleaneg and resurveyed until the levels were below the limit of 225 pCi/100 cm alpha. Contamination limits for items leaving the controlled areas is shown in Section 7.7.2 of the License Specif cations.
No items of noncompliance were identified.
13.
Notifications and Reports Based on a review of records and statements by licensee representa-tives., there have been no reportabic incidents since the inspection in mid-April 1980.
No items of noncompliance were identified.
14.
Radioactive Effluent Control and Waste Control With the exception of radioactive liquid which goes to the retention tank from the emergency shower, laundry, and decontamination sink, all radioactive liquid wastes are mixed with absorbent material, solidified with concrete, and disposed of as solid radioactive waste.
Retention tank waste is drained into the sanitary sewer only if the concentrgtions are below that listed for insoluble plutonium-238 (3 x 10,pci/ml) in Appendix B, Table II. calumn 2 in 10 CFR Part 20.
There were four transfers of liquid ^ from cue retention tank to the sanitary sewer during the period May 19, 1980 through April 10, 1981.
Samplesofthe,fiquid,priortot:ansfer,showedamaximumconcentra-tion of 2 x 10,pci/ml. Records also show total activity and number of gallons released to the sewer system during these transfers.
Radioactive waste is transferred from the process area to Building 7 where it is stored in Spec 17H 55-gallon drums pending transfer to a disposal firm. Each drum is identified by a number which is cross referenced in a logbook. Approximately 56 drums were in storage during this inspection. Radiation surveys conducted by the inspectors showed 0.1 to 0.2 mk/hr at the fence gate in froct of Building 7,1.8 mR/hr through the door of this facility, and 2.7 to 37 mR/hr at approximately one foct from the stored drums.
Twenty-eight 55-gallon drums of waste were shipped on December 28, 1980 to Chem-Nuclear Systems, Inc., Barnwell Waste Management Facility, Barnwell, SC for disposal. This was the only waste shipment during the past year. The shipment record shows a maximum of 450 mR/hr at the.
drum surface and radiation levels around the exclusive use vehicle were as authorized. The licensee's transuranic waste is currently being stored pending notification that a burial site will accept such waste from private industry.
No. items of noncompliance were identified.
15.
Stack Effluent All glove boxes and the hot cells a.e exhausted through HEPA filters and into a common HEPA filter in a single 50 foot high stack. This exhaust system runs continuously at the rate of 360 cubic feet per minute at a rtatic pressure of 4.5 inches.
Stack sampling is con-ducted 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.
Tne exhaust system for ths rooms in the controlled area is described in Paragraph 7 of thic report.
D.O.P. tests were performed on the six final HEPA filters on October 15, 1980. Results ranged from 99.98 to 99.99% efficient. The tested filters are one for the compactor room (Room 7B), one for the box lines, and four in the controlled area rooms exhaust system.
The review of air sample results showed a 17 MPC-HRS stack release on November {,1980,whichisbasedontheinsolubleplutonium-238 limit 3
(1 x 10
,4Ci/ml) shown in Appendix B, Table II, Column 1 in 10 CFR Part 20.
The licensee coll s d 5 il and vegetation samples on their site on November 16, 197.
16 L them analyzed for americium-241, plutonium-238, and beta activity by cua.
>1s for Environmental Pollution, Inc. The reported results were submitted to Region III with a letter from sSteve Hoadley, dated August 20, 1980. Additional environmental samples were collected in May 1980 around Building 7 (before any waste was moved into this facility) and in Centerville, Ohio which is immediately south of Dayton. A copy of the " Report of Analysis" was provided during this inspection and is attached to this report.
No items o,f noncompliance were identified.
~
16.
Sealed Sources The eleven sealed sources used by the licensee were leak tested on March 3,1981, which is within the required six months interval.
The test results showed less than 0.005 pci of alpha and less than 0.005 pCi of beta gamma removable contamination.
No items of noncompliance were identified.
i 17.
Invento ry The licensee's Quality Assurance Program includes responsibility for conducting a periodic inventory of licensed material.
The most recent
. ;sw l
inventory showed the' licensee possessed the following isotopes as of May'1, 1981:
An-241', Cf-252, Pu-238, Cs-137, Co-60, and Sr-90, all' within their possession limits.
In addition, there are 204 curies of Am-241 and'8.1 grams of Pu-238 somewhere within.the processing systems as of January 1,- 1981, according
'to a licensee representative. This refers to licensed material that cannot be retrieved for;any useful purposes.
No items of. noncompliance were identified.
- 18.. Confirmatory Measurements The inspectors made gamma radiation level measurements in the process
' area,;in and around Building 7, along the restricted access fence, and along the surface of-the north wing of Building 2 where the fence was
- temporarily removed, using Region III's Xetex, Model 305B, survey in-struments, S/N 07512 calibrated on March 20, 1981 and S/N 11309 cali-brated on April 1, 1981. Comparable readings.were obtained by the licensee representative who was using their Eberline, Model RJ-2, meter whica was calibrated on March 24, 1981. Readings obtained in selected areas were found to-be consistent with those shown in the licensee's
- records of past surveys. Smears were also-obtained from floor areas and pieces of equipment in the process area. -The ten smears were 5
initially counted by the licensee and-then in the NRC-Region III laboratory. One discrepancy was found between the licensee,and NRC result ;-therefore, the smears were again counted at a national laboratory. The national. laboratory results were in closer agreement with that of the NRC and therefore, the matter will be further pursued with the licensee and smear results will be covered in a separate report.
I 19.
Independent Inspection Effort i
The inspectors checked the response of alpha survey meters in the shoe / shoe cover change areas, the audible alarm on radiation monitoring 4'
-equipment-in the controlled areas, and postings, during escorted tours of the facilities. Licensee representatives described the va-ious
[
operations that are conducted in each room. The survey meter maintained in the guard house was also checked for its response to a radioactive
]
This meter would be used, if necessary, by emergency response
-source.
per,sonnel.
]
No items of noncompliance were identified.
20.
Exit Interview The inspectors met with licensee representatives (identified in Paragraph.1) at the.concl lion of the inspection on May 21, 1981 to discuse the findings. The licensee is currently censidering the removal of glove boxes:in Rooms 8 and 9 and replacing them with 4 -
al remote box to reduce hands and body exposures. The licensee has initiated the use of movies for their training sessions and would appreciate any information regarding available NRC-recommended' film j
for sisch purposes.
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