ML20054C297
| ML20054C297 | |
| Person / Time | |
|---|---|
| Site: | 07000398 |
| Issue date: | 04/02/1982 |
| From: | Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054C290 | List: |
| References | |
| 70-0398-82-02, 70-398-82-2, NUDOCS 8204200322 | |
| Download: ML20054C297 (8) | |
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U. S. NUCLEAR REGULATORY COMMISSION Region I Report No. 70-398/82-02 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 Bureau of Standards 2
Inspection At:
Gaithersburg, Maryland Inspection Conducted:
March 16-19, 1982 Inspectors:
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[N/f2 J. %'h, Project Inspector d'at( signed f
date sigE d M 2*O Aporoved By:
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Keimig,Cdef,P ects Branch #2 date signed Inspection Summary:
Inspection on March 16-19, 1982 (Report No. 70-398/82-02)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector (26 inspector-hours) of the licensed program including:
10 CFR Part 21; organization; facility changes and modifications; internal review and audit; safety committees; review of operations; nuclear criticality safety; emergency planning plans and drills; transportation activities; review of l
licensee events; and, participation in an NRC/ licensee meeting.
Results:
Of the twelve areas inspected; no violations were identified in 11 areas; one violation was identified in one area (Failure to store special nuclear material in an authorized location in the storage vault (paragraph 2b)).
8204200322 820405 l
[DRADOCK 07000399 PDR
DETAILS 1.
Persons Contacted
- L. E. Pevey, Chief, Occupational Health and Safety Division
- T. G. Hobbs, Chief, Health Physics Group
- L. A. Slaback, Jr., Accelerator and Laboratory Supervisory Health Physicist-
- C. E. Kayatt, Director, Center for Radiation Research' i
- T. M. Raby, Chief, NBS Reactor Operations i.
- denotes those present at the exit interview.
The inspector also interviewed 13 other licensee employees or investigators during this inspection.
2.
Review of Operations The inspector examined all areas of the site where special nuclear material (SNM) is handled to observe operations and activities in progress, to inspect the nuclear safety aspects of the facility, to check the general state of cleanliness, housekeeping and adherence to fire protection rules, and, to review operating procedures with members of the laboratory staff.
1 a.
SNM Inventory The inspector reviewed licensee inventory records and as of February 26, 1982, the licensee's inventory of SNM was found to be within the j
limits authorized for License No. SNM-362.
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No violations were identified.
b.
Standard Reference Material (SRM) Storage Vault The inspector noted that the licensee had stacked six cardboard boxes containing a total of 90 plutonium SRM's adjacent to the i
vertical array of storage bins located on the right side of the vault room.
A bin immediately adjacent to the boxes contained 4 ten gallon shipping containers which held additional plutonium SRM's.
The approved license application, dated December 18, 1975, authorizes storage of special nuclear material either in the storage bins or in shipping containers located down the center of the vault room but not adjacent to the storage bins.
Failure to store special nuclear material in an authorized location in the storage vault was identified i
as a violation (82-02-01).
c.
Waste Compactor During examination o' the site waste storage and preparation area, the inspector discus 3ed the use of the waste compactor with licensee l
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It was determined that the licensee had not established procedures or criteria for the operation of the waste compactor. As a result of these discussions, the licensee established and posted a
" Compactor Radiation Safety Procedure" on March 18, 1982. The procedure established air sampling and protective clothing requirements, compactor operational criteria and air sample evaluation requirements.
The referenced procedure stated that a high volume air sampler will be placed within three feet of the top of the barrel.
Through discussions with operators, the inspector determined that according to prior practice, (i.e. during use of the compactor on December 11,1981), a high volume air sampler was placed six to eight feet away from the barrel while the compactor operator worked immediately adjacent to and on the opposite side of the barrel.
The inspector questioned whether the air sample taken was representative of the breathing zone of the worker. The licensee stated that no evaluation had been conducted to assure that the air samples taken were representative even though the operator wore a half-face respirator.
Air sample results for the December 11, 1981 use of the compactor indicated 8 E-12 microcuries alpha activity and 2 E-11.microcuries beta activity for one milliliter of air sampled. As previously stated, the licensee has reduced the spacing from the operator's breathing zone to the air sampler.
In addition, the licensee will j
check and replace the compactor ventilation system absolute filter i
as necessary and the licensee will evaluate the air sampling to assure that it is representative with the operator's breathing zone (82-02-02).
This was discussed at the exit interview.
d.
Operator Discussions The inspector discussed the techniques of conducting radiation and contamination surveys of incoming packages of radioactive material.
In particular, the survey of incoming packages containing sealed radiation sources was discussed.
It was evident from the discussions that the individual contacted was not completely trained in survey techniques required to assure that he did not receive a radiation exposure in excess of that which was absolutely necessary.
Licensee representatives immediately retrained the operator involved and stated that ongoing training would be continued for this individual.
3.
Nuclear Criticality Safety 4
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 series.
Both monitors in series must be set off to activate the horns located on each floor of the building.
Examination of licensee records for the time period September 14, 1981 through March 15, 1982, indicated that the monitors had been
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silent tested once each week by exposing the detector to a built-in I
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i test radiation source.
The criticality monitors were last calibrated i
on February 2,1976.
Since that time licensee records indicate that the meter readings have drifted about 10% which is not considered by i
the licensee to be a significant change in the calibration of the instrumentation. Corrective actions were immediately taken by the licensee when equipment malfunctions occurred.
No violations were identified.
b.
Criticality Alarm Checks and Evacuation Drills The inspector verified through a review of licensee records that monthly criticality siren tests were conducted between September 29, 1981 and March 10, 1982. The licensee also set off the criticality monitors with.a cobalt source to annunciate evacuation drills for Building 222 at least every six months.
Drills were conducted on March 26, 1981 and September 29, 1981.
Licensee records indicated that the evacuations were completed in less than 4 minutes and that the emergency evacuation alarm system functioned properly during each 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 violations were identified.
c.
Audits During March 1980 the licensee established a " Radiation Safety Review Task Force" which conducted a comprehensive review of radiation j
safety practices and procedures at the site. The Task Force then made recommendations to management for revising policies which would improve on site radiation safety. The review was completed within 4
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 concerning the organizational management reporting chain for the Occupational Health and Safety l
Division which will not be modified, were accepted.
During this inspection, the inspector verified that actions have been initiated to increase the authorized staff of the Health Physics Group, expand the role of the site Radiation Safety Committee and computerize health physics records.
i No violations were identified, i
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4.
Organization i
During a previous inspection (70-398/81-03), it was noted that one Accelerator i
and Laboratory Health Physicist and two Accelerators and Laboratory Health Physics technician positions were vacant.
Since that inspection, the licensee filled one of the Health Physics Technician positions with Mr. H. E. Dyson on October 16, 1981.
The licensee is currently attempting to fill the last two vacant positions.
Mr. Dyson has no previous health physics experience and has been working at NBS since 1968. Mr. Dyson attended a local Health Physics Society two day basic health physics course and has been undergoing continuing in-house training.
No violations were identified.
i 5.
Radiation Safety Committee A new charter for the NBS Radiation Safety Committee was issued on January 26, 1982.
The committee was established to assure adeouate impleer,tation i
of the NBS radiation safety policies. Committee functions include review l
of program status, long-range planning, program audits, review of radiation facility and use proposals, and review of incidents including the recommend-ation of corrective actions, where needed.
The committee consists of at least five persons appointed by the NBS Deputy Director.
The Director of the Center for Radiation Research has been designated as chairman of the i
committee for a term of three years. The following were appointed as members of the committee and alternates effective January 4, 1982:
Members:
C. E. Kuyatt, Chairman, Director, Center for Radiation Research R. S. Carter, Chief, Reactor Radiation Division H. L. Rock, Chief, Gas and Particulate Science Division R. S. Caswell, Chief, Nuclear Radiation Division A. H. Sher, Deputy Director, Center for Electronics and Electrical Engineering L. E. Pevey, Chief, Occupational Health and Safety Division T. G. Hobbs, Radiation Safety Officer, Chief, Health Physics Group i
Alternates:
W. A. Cassatt, Jr., Deputy Director, Center for Radiation Research i
T. M. Ruby, Chief, Reactor Operations E. L. Garner, Chief, Inorganic Analytical Research Division F. J. Schima, Physicist, Radioactivity Group J. F. Mayo-Wells, Staf f Assistant for Technical Coordination / Operations, Center for Electronics and Electric Engineering F. H. Haile, Safety Engineer, Occupational Health and Safety Division L. A. Slaback, Jr., Supervisory Health Physicist, Health Physics Group l
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The inspector examined licensee records of 3 meetings of the Radiation Safety Committee held between May 28, 1981 and February 22, 1982. Topics discussed included: drafts of the.new NBS Administrative Manual Chapters
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concerning radiation safety, pending license amendment applications, procedures for handling low level plutonium samples as required by License i
Condition 16 (incorporated by Amendment No. 2 dated November 16, 1981 i
into the facility SNM license), health physics group staffing, the site j
Radiological Contingency Plan, and, internal committee operational procedures.
No violations were identified.
l 6.
Facility Changes and Modifications The inspector determined through examination of the facilities and discussions with licensee representatives that no facility changes or modifications i
within the scope of this inspection had been initiated since the last inspection.
No violations were identified.
7.
10 CFR Part 21 The inspector determined that the licensee had posted the information required by 10 CFR 21.6 at applicable locations throughout the facilities.
The licensee had also established applicable procedures for the review, evaluation and reporting of defects as required by 10 CFR 21.21.
The posting specifies that information concerning observed defects shall be initially reported to T. G. Hobbs, Chief, Health Physics Group.
No violations were identified.
i' 8.
Nonroutine Events j
The inspector determined through a review of licensee records and discussions with licensee representatives that there had been no nonroutine events at this facility, within the scope of this inspection, since inspection i
70-398/81-04.
No violations were identified.
9.
Transportation Activities a.
Shipping and Receiving Records The inspector examined licensee records for the receipt and shipment of radioactive materials from April 30, 1981 through March 15, 1982.
Shipping records indicated that all shipments were labeled, marked, placarded (if necessary), monitored for radiation and recorded as required by federal regulations.
Receipt records indicated that the j
l receipts were monitored for radiation and opened as required.
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7 However, questionable radiation monitoring techniques were followed by the involved health physics technician as previously discussed in paragraph 2.d.
No violations were identified.
b.
QA Program for Shipping The annual audit of the shipping container QA program was conducted on September 18, 1981 by the Chief, Health Physics Group. During this audit, shipping containcr requisitions, vendor QA certifications, inspection records and shipping program procedures, were examined and found to be adequate.
No violations were identified.
10.
Emergency Plan and Procedures The inspector reviewed the current status of the licensee's preparation of the Radiological Contingency Plan as required by the February 11, 1981 Order to Modify License.
A revised " Order" dated July 24, 1981 authorized the licensee to combine the contingency plan required for NRC License No. SNM-362 into a site plan that included the licensee's test reactor facility and extended the submittal date to November 3, 1981. On October 30, 1981, the licensee submitted a letter which requested a time extension to December 31, 1981 for preparation of responses to requirements for radiological contingency plans.
On December 31, 1981, the NRC published a r.otice in the Federal Register which extended the date of submittal of the radiological contingency plans for research and test reactors to four months after adoption of the final revised rule or November 3, 1982 at the latest. On March 2, 1982, the licensee submitted a letter to NRC-NMSS which stated that a radiological contingency plan for License No. SNM-362 will be developed and submitted for review with the plan for the NBS Reactor.
During this inspection, the inspector verified that the licensee had initiated the development of the contingency plan required for the SNM license.
No violations were identified.
11.
Status of Health Physics Instructions The licensee has continued the preparation of a series of 62 internal Health Physics Group " 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, instrument-ation, and effluent / environmental.
Of the 62 instructions identified, 30 have been completed and issued for implementation.
No violations were identified.
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12.
Licensee /NRC Meeting A meeting was held on March 18, 1982 at the licensee's facility. The meeting was held at NRC's request to discuss the current status of several i
licensee amendment application requests and the possibility of consolidating all of the licensee's byproduct and source material licenses into the i
facility special nuclear material license. The meeting was attended by members of the licensee's staff, members of the NRC-NMSS staff and the inspector. As a result of the discussions held, the licensee will request that the pending license amendment requests, for consolidation of the SNM
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license into a byproduct material license and for approval to dispose of low level waste in public landfills, will be withdrawn. NMSS will supply the licensee with the license application form to be used for the consolid-l ation of all the licenses. The licensee will prepare and submit a consolidated i
license application to NRC-NMSS for review and approval.
i 13.
Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 19, 1982. The inspector summarized the scope and findings of the inspection.
Remarks made by licensee representatives have been incorporated into the applicable paragraphs of the report details.
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