ML20029D198
| ML20029D198 | |
| Person / Time | |
|---|---|
| Site: | 07000008 |
| Issue date: | 04/26/1994 |
| From: | France G, Kniceley J, Kurth M, Mccann G, Shear G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20029D195 | List: |
| References | |
| 70-0008-94-01, 70-8-94-1, NUDOCS 9405040168 | |
| Download: ML20029D198 (19) | |
Text
1 U.S. NUCLEAR REGULATORY COMMISSION REGION III Report No. 070-00008/94001(DRSS)
Priority 1 License No. SNM-7 Licensee:
Battelle Memorial Institute 505 King Avenue Columbus, OH 43201-2693 Inspection Conducted On-Site: January 31 through February 3, 1994 Inspection Locations: King Avenue site West Jefferson site Inspector:
D/'
f' 1
N/W Michsel F.lKurt>
J' '
Date
/
Radiation Specialist N'
O Inspector:
George' M. Frhnce, Ili f
Date[
Senior Fuel Facilities Inspector Inspector: bM A bd Jafnes R. Kniceley 3
Date Physical Security Inspector fL Y
d /Y Reviewed By:
'P George MI McCadn, Chief Date /
/
Fuel Facilities and Decommissioning Section Approved By:
A4d t-9 24[f/
Gary L. $ hear, Chief Dat'e
/'
Fuel Cycle and Decommissioning Branch Inspection Summary Inspection on-site from January 31 throuah February 3.1994. and review of additional information aathered throuah March 25. 1994 (Recort No. 070-00008/94001 (DRSS))
Areas inspected: This was an announced, special safety team inspection conducted at the licensee's facilities in Columbus and West Jefferson, Ohio.
The inspection consisted of a review of the licensee's overall radiation 9405040168 940426 PDR ADOCK 07000008 C
I I
safety program to determine if the use of radioactive materials is adversely impacting the safety of employees or the public and to determine compliance with the Commission's rules, regulations, and License Conditions. The inspection included:
visits to numerous research laboratories and field sites (King Avenue and West Jefferson); observation of decommissioning activities (King Avenue and West Jefferson); and observation of radiography operations (King Avenue).
Results: One violation of NRC requirements was identified:
Failure to secure radioactive material against unauthorized removal and to maintain constant surveillance, 10 CFR 20.1801 (Section 6 of this report).
l Four non-cited violations were identified:
(1)
Failure to inform the NRC of a Radiation Safety Officer change j
(Section 3 of this report);
l (2)
Failure to provide training to personnel (Section 7 this report);
i (3)
Failure to perform a survey instrument calibration at the proper frequency (Section 9 of this report); and (4)
Failure to utilize the proper radiation postings (Section 16 of this report).
i In addition, documentation regarding the final disposition of nine low l
activity radioactive calibtstion/ check sources could not be located.
This is considered an inspection follow-up item [(Section 10 of this report, Inspection Report No. 070-00008/94001(DRSS))(IFI No. 070-00008/94001-01)].
i
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l DETAILS 1.
Persons Contacted
- 0K. Brog, Ph.D., Corporate Vice President, Environmental Safety and Health (ES&H)
- 0V. E. "Ed" Castleberry, Manager, Decontamination Operations, ES&H
- 0S. Layendecker, certified Health Physicist (CHP), Manager, ES&H Support
- D. Clum, Radiation Safety Officer (RS0)
- C. Jensen, CHP, Radiological Technical Support Manager
- C. Horton, Field Services Manager
- G. Erickson, Quality Manager
- J. Hallgren, Health Physics Supervisor
- S. Helgerman, Health Division, ES&H OG. Fess, Licensing Coordinator l
T. Baillieul, Environmental Scientist, U.S. Department of Energy The NRC inspectors also interviewed numerous laboratory staff, researchers, and other employees.
- Indicates those present at the on-site exit meeting held on February 3, 1994.
O Indicates those present at the Region III Management' Meeting held on March 11, 1994.
2.
Licensed Proaram i
In 1943, Battelle Memorial Institute (BMI) performed atomic energy research and development while under contract with the Manhattan Engineer District. These programs continued under the Atomic Energy Commission (AEC) and the Department of Energy (DOE). Other nuclear programs were operated under Nuclear Regulatory Commission (NRC) Special Nuclear Materials License No. SNM-7. Work conducted under SNM-7 included evaluations of power and research reactor fuels, post irradiation examination of fissile material, control rod, structural components, operation of a critical assembly laboratory, and operation of a research reactor.
Currently, the licensee has authority to perform industrial radiography l
and agricultural and animal research utilizing byproduct material.
These programs are conducted in 15 buildings and. associated grounds located at the King Avenue Site in Columbus, Ohio, and the West Jefferson Site in West Jefferson, Ohio.
In 1986, BMI discontinued its nuclear fuel research and began remediation of its facilities, such that, they would be available for l
unrestricted use. Since the majority of special nuclear materials used were obtained from the DOE, DOE has assumed primary responsibility for decontamination and decommissioning (D/D) of the BMI facilities.
DOE will support 90 percent of the cost for D/D operations, while Battelle l
is committed to provide financial assurance for 10 percent of the 3
I
project.
Accordingly, the activities performed under NRC License No. SNM-7 are also factored into the D/D operation.
Decontamination plans for areas that were operated under SNM-7 are included in the license.
The research and development program (R&D) consists of approximately 40 laboratories,12 principal investigators, and 100 technicians who use byproduct material.
Currently, research experiments utilize microcurie amounts of hydrogen-3, carbon-14, and sodium-22. Microcurie amounts of carbon-14 have been usec in field studies at the West Jefferson site.
Also, research using an iridium-192 sealed source, less than 100 curies (3.7 E12 becquerel (Bq)), to develop new radiography devices and techniques has been conducted.
The decommissioning and decontamination operations are being conducted at the King Avenue and West Jefferson facilities. Approximately 100 contract employees are working to D/D several buildings at the King Avenue site. The West Jefferson facility is in a " Surveillance" mode, with minimal D/D activities being performed. The licensee is concentrating its efforts to decontaminate the King Avenue facilities, after which the West Jefferson facilities will be decontaminated.
3.
Oraanization The Battelle Columbus Division is headed by Mr. Olesen, who is the President and the Chief Executive Officer for the Battelle Memorial Institute. Dr. Brog serves as the Corporate Vice President of the Environmental, Safety and Health Department (ES&H).
Dr. Brog oversees the ES&H Department and the Decontamination and Decommissioning Operations at both the King Avenue and West Jefferson facilities.
Mr. Castleberry is ',he Operations Manager for the Battelle Columbus Laboratory Decomminioning Project (BCLDP). Mr. Castleberry oversees the decontaminatica and decommissioning activities at the King Avenue and West Jeffersw facilities. Mr. Layendecker is the Support Manager of the ES&H Department. Mr. Clum is the Battelle Columbus Division's Radiation Safety Officer. Mr. Clum oversees the use of radioactive materials in the research and development area. Mr. Fess is Battelle l
Columbus Division's NRC Licensing Coordinator. Mr. Fess assures that all radiological activities falling under NRC jurisdiction are performed in 7. manner ccnsistent with the NRC license.
Radiation Protection is provided by two Health Physics sections.
Radiological Field Operations provides operational health and safety l
support, while dosimetry, As low As Reasonably Achievable (ALARA) l programs, and technical support is provided by the Radiological i
Technical Support Section. The sections also include environmental j
se by and health specialists, who report to the Corporate Vice l
President, Environmental Safety and Health.
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i The licensee's Radiation Safety Committee (RSC) is chaired by Mr. Means.
The RSC evaluates, approves and disapproves radioactive material uses to assure that activities are within the limits of the license. Another member of the RSC is Mr. Clum, the Radiation Safety Officer (RS0).
With regard to the RS0 position, the Battelle July 1992 self assessment identified a change in the RS0 position which occurred without notification to or approval by the NRC.
In approximately July 1992, Battelle hired Mr. Clum to replace Mr. Roe as the RSO.
Battelle applied for an amendment to its license in February 1993 requesting a RSO change. A license amendment was issued October 5, 1993, approving the RS0 change, license Condition No. 13. However, the licensee changed the RS0 without prior notification to or approval by the NRC.
The health and safety significance of this finding is minimal.
The Battelle staff indicated that this was an oversight on their part.
Since the findina was considered to be of minor health and safety sianificance. was l
identified by Battelle. was not a violation that could reasonably be
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expected to have been prevented by corrective actions for a orevious j
violation or previous Battelle findina within the cast two years. was corrected in reasonable time. and was not a willful violation.
discretion will be exercised and the firwiina considered to be a non-cited violation.
One non-cited violation was identified.
4.
March 11. 1994. Manaaement Meetina j
On March 11, 1994, a Mi.nagement Meeting was held at the Region III office with those indiv duals identified in Section 1 of this report.
The purpose of this meeting was to discuss the recent inspection, self assessments, openness with the NRC, decommissioning activities, and the Battelle radioactive source accountability program.
During the meeting Battelle agreed to:
Conduct an assessment of residual activity in the spent fuel pool; a.
b.
Restructure the license into three separate licenses covering the decommissioning and decontamination activities, research activities using byproduct material, and industrial radiography using byproduct material; c.
Provide additional information regarding the sealed calibration / check sources that are unaccounted for; and d.
Continue to share results of internal audits with the NRC.
5.
Enforcement History The licensee was last inspected on November 8-10, 1993.
No violations of NRC requirements were identified.
5
A routine inspection was conducted on Jaly 27-29, 1993. No violations of NRC requirements were identified.
6.
Internal Audits or Insoections In July 1992, Battelle hired a contractor to conduct an independent safety inspection or safety audit of Battelle's radiation protection program. This audit focused on its research and development program.
The audit was self-initiated and was designed to be critical in nature.
The audit evaluated the radiation protection program against NRC requirements, DOE requirements, OSHA requirements, and other good practices. Approximately 240 person hours were devoted by the contractor in performing this audit.
The audit identified 201 deficiencies or weaknesses in the program. The NRC evaluated all 201 of these items and determined that as of the date of this inspection, all 201 items had been adequately addressed.
Review of the audit documentation showed that, in many cases, description of the audit finding was vague thus making it difficult to determine if the finding was related to NRC regulations or license conditions.
As a result, the NRC took a conservative approach to these findings and any finding that could be remotely related to NRC regulations or license conditions was considered a potential violation.
These findings were then grouped into 6 categories which could be considered potential NRC violations. The potential violations are as follows:
a.
The failure to timely inform the NRC of an RSO change; b.
The failure to provide training to personnel; c.
The failure to calibrate a survey instrument at the proper frequency; d.
The failure to secure laboratories which contained radioactive materials; e.
The failure to utilize the proper radiation postings; and f.
The failure to account for radioactive sources.
Our review of each of the above items revealed that Items D and F remained unresolved at the time of the inspection. The inspection determined that the failure to secure laboratories containing radioactive material had been corrected for those laboratories identified in the audit. However, during the inspection a separate laboratory was identified which was not properly secured in accordance with 10 CFR 20.1801 and is later discussed in this section.
The inability to account for several sources was reviewed in detail with the licensee.
Battelle is confident, through interviews with personnel 6
and reviews of documentation, that these sources were properly disposed as radioactive waste, transferred to an authorized recipient or remain in storage in the hot cells awaiting decommissioning.
Furthermore, based on the information developed from these interviews and reviews of l
records, Battelle believes this issue is the result of a previous recordkeeping problem.
Battelle is confident that the sources are not in the public domain or in an unrestricted area of the facility. The NRC is confident, from the information provided during the inspection, that the sources were properly disposed of as radioactive waste, l
transferred to an authorized recipient or remain in storage in the hot cells awaiting decommissioning. However, since the sources havt not l
been physically accounted for, the NRC will continue to monitor this l
issue during future inspections and consider this an inspection l
follow-up item (IFI No. 070-00008/94001-01). This is discussed in greater detail in Section 10 of this report.
The other four areas are being treated as non-cited violations and are detailed in the following sections of this report:
Item A The failure to timely inform the NRC of an RSO change (Section 3));
l Item B The failure to provide training to personnel (Section 7);
Item C The failure to calibrate a survey instrument at the proper
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frequency (Section 9); and Item E The failure to utilize the proper radiation postings (Section 16).
The remaining audit findings were related in some way to Batte11e's research and development safety program. These findings have been categorized under one of the following:
a.
Good laboratory practices; b.
Additional information was identified after the audit to invalidate the finding; or c.
Related to the radiatior, safety program, but not considered an NRC requirement.
Corrective actions for the audit findings were verified by conducting audits of the laboratory facilities; interviews with Battelle employees; and a review of records and documents that were associated with the general health and safety of Battelle employees and the public.
In addition to Battelle's periodic assessments by outside contractors, it has three health physics technicians who perforrr, monthly audits of the radioactive use laboratories. These audits consist of the performance of radiological surveys in restricted and unrestricted areas; a review of records maintained by the principal users (receipt, 7
use, disposal, etc...); observations of general laboratory practices; 4
and observations of ALARA principles in use.
4 The radiological surveys are most often conducted by taking a series of smears in restricted and unrestricted areas. This is appropriate since most of the researchers who use byproduct material use hydrogen-3 or i
carbon-14 as tracers. Also, one principal researcher uses sodium-22 in research activities.
In this case, a series of smears and radiation surveys using a survey instrument is performed.
In addition to the monthly smears, the technicians perform daily smears in the hallway areas of the research laboratories.
During the laboratory audits, technicians observe individuals working in the laboratory to verify that safe laboratory practices and ALARA-principles are being followed. They ensure no-food or drink is stored or consumed in restricted areas.
They verify individuals are wearing laboratory coats, safety goggles, rubber gloves, etc...
They verify that, if required, the proper dosimetry is being worn by individuals.
If shielding for the byproduct material is warranted, they verify that it is being utilized. A qualitative check of the fume hoods is performed to ensure proper operation. Also, they verify that radioactive materials are properly secured in the laboratories.
Any deficiencies identified are documented and filed in a specified folder for each laboratory. Also, if any deficiencies are noted, they are brought to the principal user's attention and corrected immediately.
Twenty of the approximately 40 iaboratories utilizing byproduct material were audited during the inspection. The laboratory technicians and principal investigators interviewed had been provided the proper initial radiation safety training and annual refresher training.
No food or drink was observed in the laboratories. The proper records were being maintained.
A series of side-by-side smears were taken in several laboratories.
The smears were analyzed by Battelle and the NRC.
No contamination was identified.
The radioactive materials were observed to be properly stored and shielded. Also, laboratories were evaluated to determine if they were properly secured to prevent unauthorized removal of radioactive materials.
It was identified that one of the laboratories which is used to store radioactive materials was not locked and was not under constant surveillance by any individual.
10 CFR 20.1801 requires that Battelle secure from unauthorized removal or access licensed materials that are stored in unrestricted areas.
10 CFR 20.1802 requires that the licensee control and maintain constant surveillance of licensed material that is in an unrestricted area and that is not in storage. As defined in 10 CFR 20.1003, unrestricted area means an area, access to which is neither limited nor controlled by the licensee.
Contrary to this, Battelle did not secure from unauthorized removal or limit access to approximately 2.5 microcuries of hydrogen-3 i
as radioactive waste located in Room 7314 of the King Avenue site, an unrestricted area, nor did Battelle control and maintain constant surveillance of this licensed material. The failure of the licensee to 8
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i secure radioactive materials from unauthorized removal or limit access is a violation of NRC reauirements, i
The health and safety significance of this violation is minimal.
Controls are in place to limit access to research buildings to Battelle employees only.
However, Battelle employees who have not had the prerequisite radiation safety training can gain access to the laboratory buildings, and therefore, any unsecured laboratory.
Battelle's radiation safety service staff immediately corrected the violation by locking the laboratory.
The Battelle ES&H staff verbally committed to re-instructing principal investigators and laboratory technicians regarding securing laboratories which contain radioactive materials.
Also, the monthly audits of radioactive use laboratories will include the verification that laboratories are properly secured, or attended.
In addition to the technicians' monthly audits, an annual review of radiological activities is conducted by the RSO and the RSC i
subcommittee. These reviews consist of:
exposure data; bioassay documents; environmental monitoring data; maintenance of possession limits; radiation safety training; adequacy of radiation safety procedures; and certain recordkeeping items. The inspectors conducted a brief review of the Battelle 1992 annual audit. The audit was adequate and was performed as described in the Battelle license.
1 One violation of NRC requirements was identified.
- n 7.
Trainina. Retrainina and Instructions to Workers Radiation safety training is provided to employees and contract workers prior to involvement in operations. The training is commensurate to the 1
person's job duties. The individuals who work with or in the vicinity of radioactive materials view a radiation safety videotape.
Laboratory technicians and principal investigators attend a radiation safety lecture and are provided a radiation safety manual. There are two individuals and a health physics technician who provide radiation safety training and maintain documents of the training provided. Also, it is the respunsibility of the principal users to ensure laboratory technicians attend the radiation safety lecture prior to using any i
byproduct material, j
All laboratory technicians and principal users interviewed during the inspection stated that they had attended the radiation safety lecture prior to using any byproduct material. Also, the laboratory technicians indicated they were provided specific radiation safety training commensurate to their laboratory duties by the principal user, the i
person in charge of the laboratory.
{
l The Battelle July 1992 self assessment inferred that certain weaknesses in the radiation safety training program may exist.
The self assessment identified that training was not being provided to personnel.
This finding was discussed with the Battelle Radiation Safety Service staff (RSS) and was believed, by the RSS staff, to be a recordkeeping problem.
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'l The RSS staff interviewed personnel verifying that the proper training l
was provided. However, the records demonstrating that the training was l
provided were not maintained. Battelle enhanced its training program by i
j hiring additional staff to conduct training and maintain training t
documents. Additionally, all the Battelle employees interviewed l
indicated that they were provided initial radiation safety training.
l Since the findina was considered to be of minor health and safety l
sianificance was identified by Battelle, was not a violation that could j
reasonably be exoected to have been orevented by corrective actions for l
a previous violation or orevious Battelle findina within the past two y_qars. was corrected in reasonable time. and was not a willful l
violation discretion will be exercised and the findina is considered to a
be a non-cited violation.
One non-cited violation was identified.
8.
Facilities A tour of the laboratory facilities was conducted during the inspection.
In general, the laboratories and buildings were found to be secure.
However, as detailed in Section 6 of the report, a laboratory was found to be unsecured which constituted a violation of NRC requirements.
The Battelle July 1992 audit identified and corrected several laboratories which were found to be unsecured containing radioactive materials.
Although it appears immediate corrective actions were instituted, long term corrective actions were not a.dequately instituted as demonstrated by the violation identified during this inspection.
One violation of NRC requirements was identified, as detailed in Section 6 of the report.
9.
Eauioment Each principal user at Battelle is required, by internal policy and NRC License No. SNM-7, to possess or have access to a survey instrument.
The Radiation Safety Service has a number of survey instruments on hand if needed by the users.
License No. SNM-7 and Battelle's internal policy requires the principal users and the Radiation Safety Service to have their instruments calibrated at the proper frequency. The Radiation Safety Service provides assistance to users to send their instruments, as well as the Radiation Safety Service's instruments, outside of Battelle to be calibrated.
In addition, each user, if warranted, has access to a scintillation counting system.
During the inspection of the laboratories it was verified that each user possessed a survey instrument or had access to one. Also, each user has access, if warranted, to a liquid scintillation counter.
The survey instruments were observed to be calibrated at the proper frequency and functioned properly.
The Battelle July 1992 self assessment identified that one survey instrument out of approximately 50 possessed by the licensee was out of calibration by approximately one year.
Battelle personnel indicated 10
l that this was an oversight on their part.
Battelle's immediate i
corrective action was to calibrate the instrument.
To avoid future incidents, the Radiation Safety Service inventoried all survey instruments and initiated tracking of.their calibration dates.
l Notifications are then made to users to calibrate the instrument before the expired calibration date is reached.
Since the findina was l
considered to be of minor health and safety sianificance. was identified i
by Battelle. was not a violation that could reasonably be expected to have been orevented by corrective actions for a orevious violation or orevious Battelle findina within the past two years. was corrected in l
reasonable time, and was not a willful violation. discretion will be i
exercised and the findina is considered to be a non-cited violation.
One non-cited violation was identified.
10.
Materials Battelle's research and development program uses microcurie amounts of j
hydrogen-3, carbon-14, and sodium-22 in conducting experiments.
Approximately 40 nickel-63 foil sources, each containing a nominal l
15 millicuries (5.55 E8 Bq), are used in gas chromatographs. Also possessed are several sealed sources used for radiography purposes. A cobalt-60 sealed source, approximately 16-18 curies (5.92-6.67 Ell Bq),
and two iridium-192 sealed sources, one approximately 5 curies (1.85 Ell Bq) and another 75 curies (2.78 E12 Bq), are possessed.
The Radiation Safety Service Department maintains a central inventory list of all radioactive sources on hand.
l The Radiation Safety Service performs leak tests of sealed sources and l
the inspection confirmed that leak tests were performed at the proper frequency. Also, when performing leak tests of such items as nickel-63 foils, a physical inventory is conducted to verify the sources are still in Batte11e's possession.
The Battelle July 1992 self assessment included a review of the radioactive materials possessed. Receipt, transfer, and disposal records were reviewed indicating that a discontinuity between source accountability records existed.
Battelle's efforts to rectify the discontinuity in the source accountability records identified nine sources for which final disposition documentation cannot be located.
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i The following table provides a list of these sources:
Unaccounted For Sealed Sources l
Isotope Original Activity Assay Date Form i
(microcurie)*
l (1) cesium-137 1182.0 8/1/85 Button l
(2) cesium-137 119.0 6/1/81 Mylar (3) americium-241 0.05 9/1/77 Foil (4) americium-241 0.05 9/1/77 Foil i
l (5) plutonium-239 0.05 7/17/76 Disk l
(6) plutonium-239 1.29 4/26/69 Disk l
(7) plutonium-239 0.13 5/19/61 Disk l
(8) plutonium-239 0.01 5/19/61 Disk (9) plutonium-239 1.25 3/11/69 Disk For the conversion of microcurie to becquerel, multiply the microcurie amount times 3.7 E4.
Battelle's search for final disposition documentation on these nine sources has revealed that the larger cesium-137 source was in all likelihood transferred to Crystal River Nuclear Power Plant (Crystal River). This source was one of 16 sources utilized in a research project.
Battelle believes that all 16 sources were transferred back to Crystal River.
Crystal River has verified that 15 of the 16 sources are accounted for.
Battelle is continuing to work with Crystal River to confirm the transfer of the sixteenth source.
The other eight sources lacking disposition documentation are believed, by Battelle, to have been disposed of as radioactive waste or combined with radioactive waste in hot cells awaiting decommissioning.
The NRC agrees that the preponderance'of evidence identified by the licensee supports this conclusion.
4 Subsequent discussions between the NRC staff and Battelle radiation safety staff and management have determined that the sources have little probability of being in the public domain.
Battelle has conducted an exhaustive search in an attempt to identify records accounting for the sources.
Battelle determined that, due to ALARA concerns, it would be unwise to enter the sealed hot cells to attempt to locate the sources until the decommissioning activities commence. The hot cells are to be decommissioned in the late 1990's.
Although Battelle considers this issue to be a recordkeeping problem, it will continue to treat the sources as unaccounted for and continue its attempts to either locate the sources or identify documentation describing the sources final disposition.
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Due to the likelihood that the sources were either disposed of as radioactive waste, transferred to an authorized recipient or are adequately secured, the NRC does not consider this a significant health and safety issue. This will be monitored during future inspections as an inspection follow-up item (IFI No. 070-00008/94001-01).
No violations of NRC requirements were identified. One inspection follow-up item was identified.
11.
Receipt and Transfer of Radioactive Material i
Radioactive materials are received at Battelle's Central Receiving area at the King Avenue facility. A visual inspection is performed by Central Receiving personnel, the package is placed in an isolated area and the Radiation Safety Service is contacted.
The Radiation Safety Service staff pick-up the package, verify its contents, and survey the interior of the package. The package is then either delivered to the principal user or, on occasion, is picked-up by the user.
Interviews were conducted with Central Receiving personnel. They appeared to be knowledgeable regarding the proper steps to take when receiving packages, including proper handling if the package was damaged.
Interviews were conducted with principal users and laboratory technicians regarding the transfer of radioactive material between different users. They indicated that it was not common practice to transfer radioactive materials between users.
All indicated that they had never transferred radioactive materials between users.
No violations of NRC requirements were identified.
12.
Area Surveys Principal users and laboratory technicians are required to perform periodic surveys of radioactive storage and use areas.
The frequency of the survey is determined by the amount and type of radioactive material used.
The periodic surveys vary anywhere from immediately after conducting the experiment to once a month.
Based on the amount and type of radioactive materials used in the experiments, surveys are conducted at least once a month by the principal users and laboratory technicians.
As previously stated, the type of survey conducted varies with the type of radioactive material in use.
For example, if microcurie amounts of hydrogen-3 are used, then a series of smears is taken of the area and analyzed using the scintillation counter. Whereas for the use of microcurie amounts of sodium-22, a survey instrument is used to detect contamination in the area accompanied with a series of smears to identify any removable contamination.
Interviews conducted with several laboratory technicians indicated that surveys are being performed at the proper frequencies. Also, survey 13
records were reviewed indicating that the proper survey frequency was performed and that the proper survey technique was utilized.
No violations of NRC requirements were identified.
13.
Personnel Radiation-Exposures Radioactive Material Applications (RMA) are submitted to the Radiation Safety Officer and, on occasion, the Radiation Safety Committee, for review and approval for the use of radioactive materials. A portion of the review includes the determination of whether personnel dosinottj is needed.
For example, if microcurie amounts of carbon-14 were tc be used, a whole body badge is not issued to the users.
However,--it millicurie amounts of sodium-22 are to be used, the users are assigned a whole body badge and a ring badge. The Radiation Safety Officer and/or the Radiation Safety Committee follow established guidelines in determining whether dosimetry is needed.
Laboratory audits conducted during the inspection demonstrated that selected personnel were assigned whole body badges or ring badges. They indicated that the dosimeters are exchanged once_every three months.
Radiography personnel indicated that their dosimetry was exchanged on a monthly basis. A National Voluntary Laboratory Accreditation Program (NVLAP) approved supplier provides dosimetry badges to Battelle.
The Battelle dosimetry exposure data was reviewed-for the year 1993.
A review of the records indicated that their were-no unusual exposures and-that the exposures were well below the 10 CFR Part 20. limits.
Included in the review of the RMA is the determination of whether bioassays need to be performed during the time of use of radioactive materials.
Everyone who works in the laboratories and uses radioactive materials receives an initial " baseline" bioassay prior to performing the research. When the research project is concluded, a final bioassay is performed.
Certain guidelines are followed to determine if additional bioassays are needed during the course of the research.
Also, bioassays are required following unusual circumstances, such as a spill of radioactive materials. The 1993 bioassay' data was reviewed and determined to be well below the 10 CFR Part 20 limits..
No violations of NRC requirements were identified.
14.
Waste Manaaement and Disposal Radioactive waste is generated in the research laboratories and held in special radioactive waste bins or bags. Radioactive waste handling personnel gather the waste at least once a week for consolidation.
Prior -to pick-up, the users label the amount and type of radioactivity contained in the bin or bag..No radioactive liquid waste is disposed in the sanitary sewer by the users. The liquid waste is gathered by the waste handling personnel and, if within NRC regulations, is disposed in the sanitary sewer and recorded in a log book.
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According to discussions with the licensee, a review of the King Avenue site drawing and the site environmental report, ER-1992, waste water discharges to the Columbus Municipal sewer system at six locations.
Accountability for the disposal of liquids by release into sanitary sewerage is controlled by a permit for " Volumetric Release,"as described in Battelle's health physics procedure HP-0P-106.
The operating manager fills out a release permit that upon approval, limits the radioactive concentration of a specific radionuclide, based on radiochemical laboratory-analysis, that may be discharged.
The permit to discharge must be approved by the Environmental Safety and Health Oversight Managers. The permit describes the chemical composition, whether hazardous waste is present, and whether radioactive material concentrations are below release criteria or greater than the " Lower Limit of Detection (LLD)."
The inspectors concluded that the licensee's " Volumetric Release" program is adequate for determining whether water or liquid can meet 10 CFR Part 20.2003 requirements for release into sanitary sewer systems. The data reviewed revealed that releases into the sanitary sewer system were well below the 10 CFR Part 20 limits.
The inspectors examined the licensee's progrnm for disposing of specific wastes. Records were maintained in accordance with 10 CFR Part 20.2005(c). Data recorded on the licensee'r " Liquid Scintillation Media De Minimis Verification Form," disclosed that the licensee is meeting the requirement of 10 CFR Part 20.2005 (a) which allows material to be disposed as general waste, if the radioactive concentration is less than 0.05 pCi (1.85 kBq) per gram of medium used for liquid scintillation counting.
No problems were noted.
Battelle performs evaluations to determine the waste handling technique for animal carcasses containing radioactive materials.
If within 10 CFR Part 20 limits of 0.05 pCi (1,85 kBq) of carbon-14 per gram of animal tissue, the carcasses may be incinerated as general waste.
Several research records were reviewed where animal carcasses were incinerated 1
as general waste.
The calculations were determined to be below 10 CFR Part 20 limits for the incineration of animal carcasses containing i
radioactive materials.
While touring the King Avenue and West Jefferson facilities, the inspectors observed that radioactive and hazardous waste materials were i
adequately stored. There was no evidence of loss of containment among encapsulated waste material, or trafficking of loose coatamination.
l Where radioactive bearing asbestos material was stored, asbestos abatement procedures were invoked and storage containers were appropriately marked.
Battelle is currently seeking approval from the USEPA to increase its storage limit of ligdd waste from approximately 10 drums (55 gallons per drum) to npproximately 175 drums as governed by the USEPA Resource Conservation and Recovery Act (RCRA).
Some liquid waste is classified j
as mixed waste, containing a radioactive and a hazardous component.
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There is a 90 day on-site storage limit for the hazardous component as required by USEPA regulations. Consequently, the licensee is required to ship from one to 10 drums within the 90 day limit.
Pending the approval from the USEPA, the 175 drum limit can be stored up to a year and waste disposal shipments can occur with larger and more economically controlled volumes. ~ The USEPA has not approved the new storage requirement at the time of this inspection.
In the interim, the-licensee has improved an indoor storage area complete with an USEPA
" Spill Prevention Control Containment" system (concrete dike).
i The inspectors concluded that the licensee has implemented a waste management program that meets NRC regulatory requirements for the areas reviewed.
Further, there is no apparent radiologic impact from this program to the general public.
No violations of NRC requirements were identified.
15.
Environmental Protection According to SNM-7, License Condition No. 15., the licensee must provide copies of its annual environmental report to Region III and NRC Headquarters. The most recent environmental data was collected in 1992 and summarized in the report issued in September 1993. Results derived i
in 1993, as required by USEPA regulation 40 CFR Part 61, were also reviewed.
l Minimum detectable levels (MDL)-for radionuclide analyses were determined to a 95 percent confidence level. The MDL was defined by multiplying the confidence factor 4.66, times the square root of the background counting rate, times the conversion factor from count rate to activity. As a conservative measure, the licensee assumed that the MDL's were positive releases.
Subsequently, the MDL was used to estimate the maximum dose to the nearest receptor.
a.
West Jefferson Silg An analysis of effluent releases based on the inventory of suspected radionuclides resulted in concentrations below the MDL.
Thus, effluent releases were well below the 10 CFR Part 20 limits.
The licensee operates a sanitary sewage system in accordance with State of Ohio regulations.
Liquids are treated in a septic tank and released to a contained sand and gravel filter bed.
The effluent is discharged from the filter bed and treated with chlorine and released to Big Darby Creek.
The average concentration of total activity in the downstream sample was less than 6.0 E-09 microcurie per milliliter (pCi/ml) (2.0 E-04 Bq/ml) for alpha. This is significantly less than the uranium-235 and americium-241 allowable limit specified in Appendix B to 10 CFR Part 20.1 through 602.
Consequently, effluent releases from the site to Darby Creek do not exceed 10 CFR Part 20 limits.
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.i According to the environmental report no isotopes were present above minimum detectable levels for air releases or for liquid discharges to Darby Creek from the West Jefferson. site. Nor did the dose to the nearest receotor exceed the effective dose equivalent (EDE) of 10_ mrem (100 pSv), the limit described by EPA.
in 40 CFR Part 61.102.
b.
Fina Avenue Site There were no radiological releases from stacks at the King Avenue site in 1992. Hence, no stack sampling was performed. However, an air sampler is lucated at the east boundary.,The sampler is_
located according to the predominant wind direction which was derived from the wind rows diagram developed at Columbus International Airport. Sample results were all below the 10 CFR i
.Part 20 limits.
l The licensee installed three additional air ' samplers during 1993.
An air sampler is now located to represent the four major compass points. Due to electrical variations one air sampler was inoperative at the time of this inspection.
The licensee used a computer code " COMPLY" discussed in EPA regulation Appendix D to 40 CFR Part 61, to determine the radiologic impact on the nearest receptor.
For calendar year 1993, the amount of unsealed radionuclides, or. source material possessed for use at the King Avenue site was about 1.62 curies (6 E10 Bq). According to.the COMPLY computer program the potential dose would be less than 0.1 millirem ((mrem)(1 gSv)) to the nearest receptor if the entire 1.62 curies (6E10 Bq) of uncontained radionuclides were released at one time. The NRC's total effective dose limit to a member of the public is 100 mrem (1 millisievert) as specified in 10 CFR Part 20.1301.
Waste water is discharged to the Columbus Municipal sewer system from the King Avenue site. Monthly sampling for gross alpha and beta resulted in concentrations that were well below the Appendix B to 10 CFR Part 20.1 through 602 limits for the most i
restrictive beta activity.
l During the inspection it was determined that the licensee has controlled l
its operations in a manner that effectively maintains effluents within applicable limits and ALARA, as is required by NRC regulation 10 CFR l
Part 20.1101(b).
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j No violations of NRC requirements were identified.
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l 16.
Postina and Labelina During the course of the inspection approximately 20 laboratories were
{
randomly audited to determine if the required NRC postings were in i
place. All laboratory areas toured appeared to have the proper l
l radiation postings.
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The Battelle July 1992 audit identified a number of potential NRC related posting deficiencies.
Battelle evaluated the findings and took an aggressive approach to post these areas where required.
During the NRC inspection, audits were conducted of several laboratories where radiation posting deficiencies were identified.
It was verified that i
the posting deficiencies were corrected. The Battelle personnel stated this was an oversight on Battelle's part.
The health and safety significance was minimal.
Since the findina was considered to be of minor health and safety sianificance. was not a violation that could reasonably be expected to have been prevented by corrective actions for l
a previous violation or previous Battelle findina within the oast two j
vears. was identified by Battelle. was corrected in a reasonable time.
and was not a willful violation. discretion will be exercised and the findina is considered to be a non-cited violation.
One non-cited violation was identified.
17.
Transportation of Radioactive Materials The inspectors reviewed the licensee's program for shipment of radioactive materials.
Records indicated that 14 shipments containing over 29,900 cubic feet of radioactive waste material were made during I
the March through September 1993 operating period.
Nuclear material packaging and transportation manifests are maintained by a computer tracking system. The Site Shipping Officer routes waste shipments and maintains, or supervises, the licensee's computer tracking system.
During this inspection, one waste shipment was being prepared for transport. The transport driver informed the inspector about the planned arrival time, implementation of emergency procedures, and two-way communication equipment generic to the carrier.
The inspector determined that the waste material packages were surveyed, weighed, tagged and placed in the central staging area for loading onto the carrier in accordance with Battelle's license requirements.
The inspector concluded that the licensee met the requirements for shipping and identifying radioactive material as " Low Specific Activity" (LSA), according to the Department of Transportation (DOT) regulation 49 CFR Part 172.101, Appendix A.
Removable external radioactive contamination was less than the limits listed in 49 CFR Part 173.443,
" Contamination Control."
No violations of NRC requirements were identified.
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Other Areas Inspected In addition to the above areas, the inspection included a review of the Radiation Safety Committee, recordkeeping for decommissioning, and the l
receipt of bulletins and information notices.
No violations of NRC requirements were identified.
19.
Independent Measurements i
While performing audits of several laboratories, a series of side-by-side smears were taken by Battelle health physics technicians and the NRC inspectors. Analysis of the smears indicated that no removable contamination above Battelle's action limits was detected.
Also a survey instrument, a Ludlum Model 3 with attached pancake probe, was used to detect excessive count rates in the laboratories.
No instrument readings above background levels (50 counts per minute) were detected.
No violations of NRC requirements were identified.
20.
Exit Meetina l
j At the conclusion of the on-site inspection on February 3,1994, the l
f nspection team met with those individuals identified in Section 1 of tais report. A summary of the areas inspected, the apparent violations, the NRC's concerns, and the forthcoming letter were discussed.
Battelle management and employees did not identify any information provided l
during the inspection as proprietary.
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