ML20031F987
| ML20031F987 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 09/28/1981 |
| From: | Crocker H, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20031F981 | List: |
| References | |
| 70-0398-81-04, 70-398-81-4, NUDOCS 8110200619 | |
| Download: ML20031F987 (10) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
70-398/81-04 Docket No.70-398 License No.
SNM-362 Priority 1
Category UR & PU Licensee:
U. S. Department of Commerce National Bureau of Standards Washington, D. C. 20234 Facility Name:
National BureaJ of Standards Inspection at: Gaithersburg, Maryland Inspection conducted:
September 14-17, 1981 Inspectors:
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A /2h'/[c/ _
J( oth, Project Inspector Vate signed Approved by j-/
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H. W. Crock'er, Chief, Fuel Facility
- (date figtfed Projects Section, PB#2, DR&PI Inspection Summary:
Inspection on September 14-17, 1981 (Report No. 70-398/81-04)
Areas Ins ected:
Routine, unannounced inspection by a region-based inspector of the licensed program including: organization; facility changes and modifica-l tions; internal review and audits; safety committees; training; procedure control; review of operations; nuclear criticality safety; emergency planning-facilities, equipment, procedures, tests and drills; transportation programs; and, licensee action on regional office circulars. The inspection was initiated on the day shift and involved 24 inspector-hours on;ite by one NRC region-based inspector.
Results: No items of noncompliance were identified.
l Region I Form 12 (Rev. April 77)
'9110200619 810930
.PDR ADOCK 07000398 C
DETAILS 1.
Persons Contacted
- L. E. Pevey, Chief, Occupational Health and Safety Division
- T. G. Hobbs, Chief, Health Physics
- L. A. Slaback, Jr., Accelerator and Laboratory Supe. visory Health Physicist
- W. Cassatt, Deputy 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.
l 2.
Organization The inspector determined through discussions with licensee representatives that the facility and Health Physics Section organizations were as previously described in Inspection Reports 70-398/80-04 (facility) and 70-398/81-03 (Health Physics) with the following exceptions. The position title for the Director, Administrative and Information Services has been cnangd to Director of Administration. Similarly, the position title for the Deputy Director, Administrative Systems has been changed to Deputy Director of Administration.
In addition, one of the two vacant Accelerator and Laboratory Health Physics technician positions is expected to be filled by October 18, 1981. The second vacant technician position is expected to be filled by December 31, 1981.
No items of noncompliance were identified.
3.
Review of Ooerations 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; and, to check the general state of cleanliness, housekeeping and adherence to fire protection rules.
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a.
SNM Inventory The inspector reviewed licensee inventory records and, as of July 31, 1981, the licensee's inventory of SNM was found to be within the limits authorized for License No. SNM-362. The licensee intends to reduce the inventory of SNM and the authorized limits to less than 450 grams of SNM by November 3,1981.
No items of noncompliance were identified.
3 b.
Standard Reference Material (SRM) $torage Vault The inspector examined the SRM Storage Vault located in Room B118 of Building 222. All fissile material which was not contained in shipping packages was stored in the storage bins located along each side of the vault room. Source materials including natural and depleted uranium and thorium were stored in shipping containees on the floor of the vault and closed shipping packages containing quantities of Pu-238, Pu-240 and Pu-244 were stored down the center of the room as described in the approved license application.
The inspector noted that many of the labels on the SRM Pu-946 2R containers could not be read because of aging.
Information on the labels included the SRM number, number of curies of SNM contained, packaging date, etc. Many of the containers were packaged during the time period 1968 to 1971 and were sealed with wax. The wax apparently penetrated the labels and in many cases obscured the information printed on the labels.
The inspector also noted that the information contained on labels attached to the SRM Pu metal I
949e 2R containers did not identify the quantity of SNM contained.
The labels showed a value of 0.0369. There is no way of determining if this value was the number of curies in the container, the weight of SNM in the container or the number of curies per gram of SNM.
According to licensee representatives, each container held 0.5 grams of SNM which corresponded to 0.0369 curies per container.
Licensee representatives stated that the unreadable labels would be changed and that units will be added to the ;RM 949e labels.
Nu items of noncompliance were identified.
4.
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 January 1, 1981 through September 14, 1981, indicated that the monitors had been silent tested once each week by exposing the detector to a butit-ir test radiation source. The criticality monitors were last calibrated on February 2, 1976. Since that time licensee records indicate that the meter readings have drifted about 10% which is not con <,idered to be a significant change in the calibra-tion of the instrumentation.
No items of noncompliance were identified, t
4 b.
Criticality Alarm Checks and Evacuation Drills The inspector verified through a review of licensee records that monthly criticality siren tests were conducted between January 1, 1981 and September 14, 1981.
The licensee also set off the criticality monitors with a cobalt source to conduct evacuation drills for Building 222 at least every six months. The last drill was conducted on March 26, 1981.
Licensee records indicated that the evacuation was completed in less than 4 minutes and that the emergency evacuation alarm system functioned properly during the drill. The records also indicated that corrective actions were taken in a timely fashion whenever the alarm system was found to be improperly operating.
No items of noncompliance were identified.
c.
Area SNM Limits During inspection 70-398/80-04, the inspector noted that there were inconsistencies in the authorized area (laboratory) limits from one license application to the next.
Licensee representatives stated that these inconsistencies would be corrected in an upcoming license amendment application which will be submitted to NRC-NMSS to reduce the authorized licensed limits.
No items of noncompliance were identified.
d.
Audits During March 1980 the licensee established a " Radiation Safety Review Task Force" which conducted a comprehensive review of radiation safety practices and procedures at the site.
The Task Force then made recommendations to management for revising policies which would improve site radiation safety. The review was completed within six months. Specific recommendations were made to management concerning staffing of the Health Physics group, expanding the role of the site Radiation Safety Committee, acquisition of Health Physics measuring and monitoring equipment, computerizing health physics records, facility construction, environmental monitoring and training. The report was transmitted to licensee management by memorandum dated February 17, 1981.
Licensee management reviewed the report and issued a response dated April 14, 1981. All recommendations made by the task force with the exception of one was accepted for implementa-tion by management.
The one recommendation which was rejected involved the organizational management reporting chain for the Occupational Health and Safety Division. The management reporting chain will not be modified.
An internal program review of the Health Physics Section was conducted by the Health Physics Chief and the two supervisory health physicists
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during the month of June 1981.
The purpose of this review was to
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identify functional areas, and to assign responsibilities for these areas. As a result of this review, functional areas have been assigned to specific individuals within the group and the need for staff reassignments, written procedures and equipment has been identified.
Actions are currently underway to resolve the identified items.
No items of noncompliance were identified.
i 5.
Safety Committees A Radiation Safety Committet.ias been established to advise the Deputy Director of NBS,through its chairman, on matters pertaining to radiation safety, including the scope, ramifications, and safety programs required for all possible existing radiation hazards generated by NBS operations or through the use of NBS equipment or facilities. The Director of the Center for Radiation Research has been designated as chairman of this committee and will coordinate the activities of this committee with the Radiation Safety Officer. 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 i
R. S. Caswell, Chief, Nuclear Radiation Division R. S. Carter, Chief, Reactor Radiation Division T. M. Raby, Deputy Chief, Reactor Radiation Division C. T. Reimann, Director, Center for Analytical Chemistry 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 Through discussions with the committee chairman, the inspector determined that the committee held one meeting between March 1981 and September 15, 1981. This meeting was held on May 28, 1981. During this meeting, the committee reviewed the management response to the Task Force report previously discussed in paragraph 4.d and initiated work on the development of a new charter for the committee as recommended in the Task Force
- report, a
No items of noncompliance were identified.
6.
Facility Changes and Modifications The inspector determined through examination of the facilities and discussions with licensee representatives that no facility changes or modifications within the scope of this inspection had been initiated since the last inspection.
No items of noncompliance were identified.
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7.
Licensee Action on Regional Office Circulars The inspector determined through discussions with licensee representatives that IE Circular 80-20, dated August 21, 1980 " Changes in Safe-Slab Tank Dimensions" had been received and reviewed for applicability to the facilities and activities licensed under NRC License No. SNM-362.
Licensee records, dated April.23, 1981, indicated that there were no safe-slab tanks installed in the licensed facilities; therefore, no further action by the licensee on this circular was required.
No items of noncompliance were identified.
8.
Emergency Plans and Procedures During inspection 70-398/81-03, the inspector identified an unresolved i
item with respect to contents of the facility emergency plan and proceaures.
During that inspection, the inspector was informed that the licenses had submitted a letter to NRC-NMSS dated March 2, 1981 which requested a waiver to the " Order to Modify License" dated February 11, 1981. The Order to Modify License No. SNM-362 required that the licensee prepare and submit radiological contingency planning information to NRC for review.
The basis of the request for waiver was "that the activities at s
NBS governed by SNM License No. SNM-362 (were) such that the potential for employee exposures or for offsite radiation doses...(was) negligible."
1 Subsequent to inspection 70-398/81-03, NRC-NMSS denied the licensee's request for waiver and on July 24, 1981 issued a revised order which extended the submission date to November 3, 1981 and authorized the licensee to combine the contingency plan required for NRC L! cense No.
SNM-362 into a site plan that included the licensee's test reactor facility.
During this inspection, the inspector was accompanied onsite by a represen-tative of the NRC-NMSS Emergency Contingency Planning Section. The licensee's SNM use and storage facilities were toured in order for this individual to obtain an appreciation for the extent to which SNM is ustd and stored at this facility. The licensee was informed that the need for the contingency plan was still present but that this need will be re-examined once the licensee reduced the SNM inventory (see paragraph 3.a for additional detail).
No items of noncompliance were identified.
9.
Transportation Program l
a.
Shipping Records The inspector examined licensee records for the shipment of radioactive materials during the time period April 21, 1981 through September 17, 1981.
The records indicated that'all shipments were labeled, marked; placarded (if necessary), and recorded as required by federal regulations.
7 The inspector also examined the records for a shipment of radioactive waste which was shipped from the site on June 16, 1981. The shipment l
was made through the Department of the Army - Armament Material Readiness Command to the contractor, Southwest Nuclear Company. The contractor transported the waste to the Richland, Washington burial site. The waste consisted of 20 55 gallon drums of dry, soild radioactive waste. The inspector determined that the disposal forms and shipping papers were properly completed and that the records indicated that the containers were marked and labeled as required.
No items of noncompliance were identified.
b.
Transportation Procedures The inspector examined the following procedures relative to the packaging and transportation of radioactive materials.
HPI 4-2 (approved-undated) " Shipping and Receiving" HPI 8-3, dated May 1981, "Dispcsal of Radioactive Waste" These procedures incorporated the information required to assure that radioactive materials were properly prepared, packaged and transported as required by federal regulations.
No items of noncompliance were identified.
c.
Californium-252 Cask Incident On September 14, 1981 NBS was notified by the carrier (Roadway Express Company in Stratford, Missouri) that external damage occurred to a shipping cask containing 489 millicuries of Californium-252 in two sealed sources. White powder was oberved on the floor of the truck below the cask.nd a hatch on the bottom of the cask had been damaged. The c.=L ';'t NBS on September 10, 1981 and was enroute to the Los Alamos,oientit'ic Laboratory (LASL). A survey performed by representatives from the State of Missouri indicated no excess radiation or contamination levels, that the sources remained locked in the shielded position and that the package could be transported safely. The radiation levels observed were similar to levels measured at NBS prior to departure.
The white powder found on the floor of the truck was not radioactive.
Subsequent to this notification, the licensee noted similar white powder on the Building 245 loading dock under the location where the cask had been stored prior to departure.
Analysis of the powder showed it to be of the same composition as that of the cask shielding material; a water extended polyethylene with boron. The material appeared to be weeping past bolt penetra-tions in the bottom of the cask.
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8 As a result of this observation, the licensee is evaluating the need to submit a 10 CFR Part 21 defect report to the NRC since there appears to be some question about the integrity and stability of the shielding material in the cask.
The cask was manufactured for and is owned by LASL.
No items of noncompliance were identified.
10.
Procedure Control a.
Use of Radioactive Material The facility " Radiation Safety - Rules and Regulations Manual" incorporated into the facility license by License Condition 10 describes the procedural requirements for the acquisition, use, handling, control and disposal of radioactive materials including special nuclear materials.
The procedural requirements relative to the loss, theft or accidents involving radioactive sources is also discussed.
The licensee uses the following forms to maintain control over radioactive materials:
(1) NBS-364 " Proposal to Acquire Radiation Source" (2) NBS-365 " Proposed Change in Utilization of Radiation Source" (3) NBS-366 " Record of Inspection for Radioactive Material" (4) NBS-367 " Proposed Removal or Transfer of Radiation Source or Irradiated Equipment" (5) NBS-368 " Report of Loss, Theft or Accident Involving Radiation Source" (6) NRC-741 " Nuclear Material Transfer Report" for Facility YBC The initiation of a project involving ionizing radiation must have prior approval from the Health Physics Section. This approval covers the initial procurement, installation, location and use of the source. Any changes which might affect radiation safety consider-ations for a project already underway must also have prior approval.
All forms must be completed and submitted to the Health Physics Section by the initiator. Approval by the Health Physics Section is shown by signature on the appropriate form.
9 In order to review the implementation of procedure control requirements with respect to the use of radioactive material on the site, the inspector examined NBS-364 and NBS-367 forms issued between January 23, 1981 and August 3, 1981.
It was noted that the licensee completes these forms to initiate acquisition, use and transfer of radioactive materials.
If there was a change in use of the radioactive material, a revised NBS-364 form was issued. The inspector observed that all forms examined appeared to be properly completed.
No items of noncompliance were identified.
b.
Internal Health Physics Procedures The licensee has. initiated the preparation of a series of 57 " Health Physics Instructions" covering all aspects of the operation including:
health physics action levels, emergency planning, training, special nuclear material control, dosimetry, reactor monitoring, general monitoring, laboratory / accelerator monitoring, sample analysis, instrumentation, and effluent / environmental. Of the 57 instructions listed,16 were found to be in various ':ges of preparation and were examined by the inspector.
No items of noncompliance were identified.
11.
Training a.
Safety Orientation for New Employees Prior to about February 26, 1981, safety orientation classes for new employees were held every two months. All new employees were required to attend the first scheduled class on safety after starting 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 of radiation and safety signs and labels used in the nuclear and non-nuclear industries.
(2) Applicable portions of the NBS Radiation Safety Manual and NRC Rules and Regulations for those working directly with radiation and/or radioactive materials. These employees are then tested to determine cognizance of required rules, regulations and procedures.
Licensee records indicated that a total of 75 new employees were given the safety orientation during the calendar year 1980.
No items of noncompliance were identified.
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10 Ii b.
Refresher Training The licensee conducted a series of refresher training classes for personnel working with radiation or radioactivity other than at the NBS Reactor. These training sessions were conducted periodically between January 8,1980 and September 2,1981. A total of 127 users were retrained during these sessions which covered topics including radwaste; preparation of acquisition, use, and transfer forms; 10 CFR 19, 20 and 21; handling of radioactive material; and packaging of radioactive material.
Each user (352) was also issued, IAEA leaflets which discussed the hazards and effects of radiation, and, memoranda containing information describing radioactive waste disposal requirements.
The licensee has also initiated the use of an in-house "NBS Safety Newsletter" for the dissemination of radiation safety information to all personnel onsite.
The April 1981 issue of the "Newslatter" contained an article " Radiation Warning Signs Used Onsite" and the May 1981 issue discussed " Radiation in Everyday Life".
Future topics will include:
risks of radiation exposure; sources of radiation at NBS; radiation exposure limits; health physics - what is it; and radiation and pregnancy. The inspector stated to licensee'representa'-
tives that an article on " site evacuation procedurcs" should also be considered for inclusion into the series.
No items of noncompliance were identified.
f' c.
Health Physics Technician Training Licensee records indicat.ed that during the time period March 5,1980 through August 21, 1982 at least 15 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; feJeral
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regulations; health physi:s instructions (procedures); emergency response; use of supplied air masks; instrument calibrationf ALARA concepts; air sampling techniques; bioassay calculations; and, i
monitoring of high level radiation. 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.
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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 on September 17, 1981. The ins'pector summarized the scope and findings of the inspection and informed the licensee representatives that no items of noncompliance had been identified.
Remarks made by the licensee representatives have been incorporated into the applicable paragraphs of the report details.
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