ML20054L122
| ML20054L122 | |
| Person / Time | |
|---|---|
| Site: | 07000572 |
| Issue date: | 06/23/1982 |
| From: | Matson E, Slawinski W, Sreniawski D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054L109 | List: |
| References | |
| 70-0572-82-01, 70-572-82-1, NUDOCS 8207070169 | |
| Download: ML20054L122 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION i
i REGION III Report No. 70-572/82-01(DETP) 4 Docket No.70-572 License No. SNM-567 Priority I Category B Licensee: Monsanto Research Corporation Dayton Laboratory 1515 Nicholas Road I
Dayton, Ohio 45407 i
Type of License: Manufacturer and Distributor i
Type of Inspection: Unannounced Routine i
Inspection Dates: May 10-13, 1982
' 6[M/80 Inspectors:
W. J. Slawinski 0
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E. R. Matson C C 'M cn-n Approved By:
D. J. Sreniawski, Chief b-D 3-80 Materials Radiation Protect o Section 2 Inspection Summary I
Inspection on May 10-13, 1982(Report No. 70-572/82-01(DETP))
Areas Inspected: Routine, unannounced inspection of radiation protection practices at a nuclear source production facility which included: organi-zation; radiation protection procedures; internal audits; training; facill-ties; 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; radiological contingency plan; confirmatory measurements; and independent inspection effort.
The inspection involved 56 inspector-hours on-site by two NRC inspectors.
Results:
Of the nineteca areas inspected, one item of noncompliance was identified. 49 CFR 173.393 (n)(1) - shipment of licensed material i
not properly packaged (Section 8).
8207070169 B20625 PDR ADOCK 07000572 C
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DETAILS i
1.
Persons Contacted 1
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- R. L. Schimmel, Manager, Engineered Products Department
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- E. F. Janzow, Manager of Operations, Engineered Products Department H. L. Coleman, Manager of Nuclear Manufacturing 4
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- S. D. Hoadley, Health Physicist and Radiation Safety Officer H. A. Malson, Assistant Radiation Safety Officer C. Zahn, Technician R. A. Bocher, Technician Trainee B. A. Coates, Technician Trainee L. Walker, Site Guard
- Denotes those who attended the exit interview t
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2.
Organization The licensee's organizational structure remains as described in the License Specifications, Part 5.2 (March 1978).
C. Zahn is currently in training to replace H. A. Malson as the Assis-l tant Radiation Safety Officer.
R. R. Taylor, Manager of Smoke Detector Manufacturing, terminated employment with the licensee on June 30, 1981.
i No items of noncompliance were identified.
I 3.
Radiation Protection Procedures j
License No. SNM-567 vas amended in its entirety on May 25, 1978, and partially amended on February 27, 1979, June 24, 1980 and March 29, 1982.
The last amendment incorporated the licensee's Radiological Contingency Plan to improve their ability to protect against, respond to, and miti-l gate the consequences of an accident involving radioactive materials.
i License Specifications, submitted with the May 25, 1978 amendment, i
describe the program which is conducted under this license. An Opera-l tions Manual contains procedures to be followed in carrying out the i
requirements in the License Specifications. Changes in the License Specifications are approved by the Commission before implementation by l
the licensee. Occasional Operations Manual modifications are made by the licensee, as needed. No changes have been made in the License l
Specifications or Operations Manual since tae last inspection.
t No items of noncompliance were identified.
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4.
Licensee's Internal Audit i
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Company internal audits of the program are performed by an individual designated by the Laboratory Director who is outside the area of r
4 Engineered Products.
l The inspectors reviewed the report of the licensee's annuni Health i
Physics audit conducted by E. A. Stxinmetz of the Analytical Technology
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Department on September 16, 1981. The audit covered the period i
I January.1, 1981 to September 16, 1981 and included: air sampling i
program, film badge records, smear surveys, direct radiation surveys, t
bioassay program, retraining sessions, material shipment records, sealed source leak tests and review of evacuation drills.
i E. A. Steinmetz will no longer perform these audits. Future auditor (s)
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will be from Mound Laboratory Health Physics Department.
2 Minutes of Health Physics (Radiation Safety Committee) meetings, held
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on the following dates, were reviewed by the NRC inspectors:
1981 -
June 26, September 10, October 2, October 20, November 4, December 4, 4
j December 22 and 1982 - January 22, February 18, March 3, March 17, l
April 8, and May 7.
The licensee also maintains a " Health Physics Log" of any abnormal occurrences or noteworthy events.
The following log entries were reviewed by the inspectors.
Date l
June 18, 1981 Routine evacuation drill held. Noted that personnel are becoming lax in responding and are assuming the alarm is a drill. Matter was cddressed in a subsequent
" News and Views" (laboratory wide newsletter).
August 4, 1981 St. Elizabeth Hospital emergency response personnel and the Dayton Fire Department Senior Paramedic toured the Engineered Products Department. Discussed possible acci-dents in controlled areas and response measures.
t August 12, 1981 Air monitor alarmed in Room 9.
Two individuals just completed a trash pull in Room 6 and were i
loading the trash bags into a drum in Room 9.
Air I
samples showed a maximum concentration of 9.2 x 10 11 i
pCi/ml for eight hours or, 7.4 MPC-HRS (based on 1 x 10 '
pC1/ml for insoluble Am-241, as shown in Appendix B, l
Table I, Column'1 in 10 CFR Part 20).
Both Indi-viduals were assigned the maximum potential exposure j
of 7.4 MPC-HRS. Probable cause for this incident 6
was leakage in one or more of the trash bags.
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Date March 17, 1982 Evacuation drill was held.
Problems noted in radio communications between emergency units and Zone 2 director (Engineered Products Department). A meeting with the Safety Department will be held to resolve matters.
Licensee discovered they st$ipped 0.3 curie Am-241 April 6, 1982 as normal form to Mound Laboratory, in a Type A container. Type A quantity limit for normal form Am-241 is.001 curies. Did not result in a safety hazard.
(See report section 8 for details).
No items of noncompliance were identified.
5.
Training Training of new employees who work in the process area and refresher training for all personnel who are involved in handling radioactive material is outlined in Sections 5.7 of the Specifications and 4.7 of the Manual. New employees in the process area receive a two month apprenticeship under the supervision of an experienced technician.
As they are trained they are " work certified" by the Manager of Nuclear Manufacturing and/or the Radiation Safety Officer.
Three new employees have been hired to work in the process area since the last inspection. The inspectors interviewed two such employees who received their initial indoctrinations in December 1981 and January 1982. The training of these employees has been as specified in the applicable sections of the Specifications and Manual.
- However, one of the new employees has thus far received limited training due to illness and is currently not working in the process area.
Retraining sessions are held quarterly.
A review of group training re-cords showed the following sessions were held.
Date Topic May 28, 1981 A videotape on demonstrations of radiation safety was shown.
July 22, 1981 Review of box line hazards and fire extinguisher use.
September 17, 1981-Use of shoc covers, lab coats and gloves. Material control including tagging and source cards.
December 22, 1981 -
A videotape, reply to 60 minutes segment, was shown. Radiation survey requirements and source handling discussed.
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Date Topic March 18, 1982 Use of alpha survey meters reviewed. Emergency procedures in case of tornado watch / warning.
10 CFR Part 19 and 20 review.
April 15, 1982 Work station surveys, proper isotope storage and respirator usage.
No items of noncompliance were identified.
6.
Facilities The nuclear process area is located in the north wing of Building 2 with the north six rooms, Rooms No. 6, 7, 7A, 7B, 8, and 9, being used for processing material (with the exception of Room 7B which houses the trash compactor) and Rooms No. 3, 4, 10, 11, 13, and 14 comprising 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 des-criptions of the facility are contained in Section 7.3 of the licensee's Operations Manual.
The licensee controls access to restricted areas by using an electronic 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 process area is padlocked during off-shift hours.
The portion of the roof over Rocm 6 was recently raised several feet to facilitate removal of the remote box manipulators for servicing. The licensee plans on installing overhead cranes in Room 6 to aid in manipu-lator removal.
A peaked roof was also constructed over the existing flat roof of the north wing of building 2.
This new peaked roof permits better water /
snow drainage. The licensee's stack exhaust system is now atop the peaked roof. The accessible periphery of the flat roof is still en-closed with a fence and posted as a high radiation area. Access to the peaked roof is controlled by the licensee. Contractor personnel were issued film badges when working on these new additions and adequate precautions were taken to minimize exposure.
Radioactive waste material is stored in 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.
An in plant laundry for protective clothing used in the process area is available in a portion of the emergency shower facility. The laundry water, decontamination sink, and emergency shower drain into a 600 gallon retention tank.
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A perimeter fence surrounds the laboratory site and guards man the en-trance to this site continuously.
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 radioactive 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 fan switches on automatically. The final HEPA filter bank and exhaust fans for this system are located outside of the north wing of Building 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, one Victorcen Model CP, and one Nuclear Chicago Model 2588 cutie pie, worn last calibrated on March 16, 1982. The cutie pie is maintained in the guard house.
Neutron Survey Meters: Two Eberline Model PNR-4 were last calibrated on March 17, 1982.
A fast neutron counter located in the guard house was last calibrated on March 16, 1982.
Alpha Survey Meters: Operational checks are conducted daily on the six Eber11ne Model RM-15 meters, using a radioactive check source.
Remote box manipulator controls have been modified by replacing the
" steel tape" with stronger and more flexible " steel cable".
This re-sults in reduced manipulator servicing.
The licensee has installed hand size halon fire extinguishers within the glove boxes for emergency use.
Personnel monitoring records are now stored in a fire resistant cabinet.
No items of noncompliance were identified.
8.
Transfer of Materials The licensee made approximately 125 shipments of licensed material for the period May 22, 1981, to May 7, 1982.
Records of five shipments were 6
reviewed after being. chosen at random from the " Outgoing Shipment" log, they were:
Shipping Shipping Container Activity Transport Date Customer Source Type (curies)
Index 6/24/81 Texas Nuclear MRC-PuBe A 8.6 4.1 7/31/81 Science Applications MRC-PuBe B 22.4 1.0 464 9/25/81 J. L. Shepherd &
PuBe 495 A 15.4 9.6 Associates 3/29/82 General Atomic AmBe A
3.1 2.9 4490 4/15/82 Monsanto (Soda Co-60 A
.0013 0.9 Springs) 376-379 The NRC inspectors verified the licensee had copies of the customer's licenses or written certifications which authorized possession of the material ordered. The sources were leak tested prior to shipment.
Direct radiation surveys were made and recorded and shipping labels were as required. Container surface contamination was less than 9 x 10 8 pCi.
On March 19, 1982 the licensee shipped four double encapsulated Am-241 heat sources to Mound Laboratory in Miamisburg, Ohio. The sources were shipped in a Type A container as normal form and totaled 0.3 curie, the largest single source was 245 mil 11 curies. The Type A quantity limit for normal form Am-241 is 0.001 curies (49 CFR 173.389 (1)). This is an item of noncompliance with 49 CFR 173.393(n)(1) which requires the ship-per of licensed material to insure that shipments are properly packaged.
This item of noncompliance was licensee identified on April 6, 1982. The sources were designed to meet special form requirements but had not, at the time of shipment, been tested as such. Since the sources had not been certified as special form, the licensee shipped them as normal form without realizing the Type A quantity limit was exceeded. No radiation safety hazard existed as a result of this occurrence.
The licensee has taken corrective actions to preclude recurrence by formu-lating a shipping check list having pertinent quantity limits, radiation limits, labeling requirements, etc.
This check list must be completed and rechecked by another individual prior to shipment of licensed ma-terials. The heat sources have subsequently been certified as special form. This matter is considered closed and no further licensee action is required.
The licensee received approximately 54 shipments of licensed material and 214 empty containers during the period of May 20, 1981, to April 27, 1982. Smear surveys of the shipping containers were less than 45 x 10 ' pCi.
Direct surveys of the containers showed less than ten mrem /hr at three feet.
One item of noncompliance was identified.
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9.
Personnel Radiation Protection - External The licensen's program for external exposure control consists of ex-posure rate measurements, pre-job manrem estimation, whole body and extremity wrist badges and self-reading pocket dosimeters. Film badges are exchanged on a weekly basis and pocket dosimeters are read daily.
Film badge results are received from R. S. Landauer by telephone the week after badges are submitted for processing; Landauer's formal re-port arrives approximately two weeks later.
Personnel monitoring records were examined for the second, third and fourth quarters of 1981 and the first quarter of 1982. As a result of an evaluation made in 1976, the licensee assigns hand ax,,osures as twice the wrist film badge results.
In an attempt at AIAP.A. the licensee has reduced their action level for whole body exposures to 450 mrem per quarter.
The maximum quarterly exposures were as follows:
2nd Qtr, 1981 3rd Qtr, 1981 4th Qtr, 1981 1st Qtr, 1982 Whole Body 0.39 rem 0.38 rem 0.44 rem 0.63 rem Extremity 2.8 rem 8.6 rem 4.05 rem 3.26 rem Seventeen individuals are currently badged on a routine basis.
Personnel monitoring and termination reports were submitted to the Commission as required.
The licensee's direct radiation 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 i
Specifications and Operations Manual.
I No ttoms of noncompliance were identified.
10.
Personnel Radiation Protection - Internal The licensco's program for internal exposure control consists of surface contamination surveys, airborne radioactivity monitoring, urine samples, and in vivo counting when necessary.
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 those 22 fixed station samples 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 licensen has a constant air monitor operating in each of the six 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.
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A review of in-p1< tnt air sample records was made for the period giy 7, l-1981 through May 7, 1902. Above normal airborne concentrations were found on four occasions in(1981 and five occagions in 1982. The maxi-mu.n quarterly,MPC-HRS assygned to an individual was 21.0 MC-HRS during
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j the fourth quarter of 198L Above normal airborne concentrations were
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j due primarily to pass box or trash pull related operations.
The MPC-HRS i
calculations for exposure to in plant air concentrations is based on a i
comparison with insoluble Am-241 (1 x 10 " pCi/ml) or(insoluble Pu-238
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(3 x 10 15 pCi/ml) limits.
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Routine bioassay (urine) samples are collected on a monthly frequency
,for all employees involved in isotope work'. e All' udne voids are col-j lected between midnight Saturday and midnight fanday of the designated
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1 weekend. Routine samples are analyzed for. americium-241 and plutonium-238 by Controls for Environmental Pollution, Inc., Santa Fe, NM. Special l
j 2.4-hour urine samples are collected as needed.. Such samples are analyzed g
j for various isotopes as required. The licenson's, action levels are specified in License Specification 7.9.3(5) for resampling and investi-gation action. Urine sample records were reviewed for the period l
April 12, 1981 through March 14, 1982.
Sample riaximur's were l
0.09 i 0.03 dpm alpha (Pu-238) and 0.00 t 0.05 dpc alpha (Am-241).
3 Tvaluation of routine air samples since May 1981 indicated [n5 need for i
whole body radiation measurements or fecal sampics analyses.\\
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Half face mask respirators are provided for personnel in the process area to use whenever there is a possibility for airborno contamination; a
c.g., during pass box operations involving unencapsulated material.
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However, the licensee takes no credit for a respirator program. The t
i respirators are periodically subjected to a smoke test by the RSO to l
check their efficiency.
l No items of noncompliance were identified.
11.
Posting, Access Control, and Material Control 1
During tours of the facility, the inspectors noted that areas in which l
radioactive materials were stored and/or handled appeared to be properly f
l posted and controlled. Contaminated material and equipment appeared to be properly contained and labelled. No prob hms 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 i
accordance with 10 CFR 20.203(c)(4).
All visitors and employees not associated with the Engineered Products Department are limited entry to the restricted areas under the direct supervision of one of the Department employees. These visitors aie issued a film badge, protective clothing, and are instructed as to the procedures of the area in which they are visiting.
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No items of noncompliance were identified.
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12.
Surveys 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 May 18, 1981 to April 27, 1982. 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 cleaned and resurveyed until 2
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 Specifications.
Work was halted, pass boxes covered and the area deconned prior to modi-fications to the roof over Room No. 6.
No items of noncompliance were identified.
13.
Notifications and Reports Based on a review of records and statements by licensee representatives, there have been no reportable incidents since the last inspection in mid-May 1981.
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 emargency shower, laundry, and decontamination sink, all radioactive liquid wastes are mixed with absorbent material and disposed of as solid radioactive waste. Retention tank waste is drained into the sanitary sewer only if the concentrations are below that listed for in-soluble plutonium-238 (3 x 10 5 pCi/ml) in Appendix B, Table II, Column 2 in 10 CFR Part 20.
There were four transfers of liquid from the retention tank to the sanitary sewer during the period April 10, 1981 through May 7, 1982.
Samples of the liquid, prior to release, showed a maxi-mum concentration of 9.5 x 10 7 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. There were 75 drums in storage during this inspection.
Eleven of these drums consisted of miscellaneous bench /
table trash (Low Specific Activity).
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I No waste shipments have been made since December 28, 1980. The licensee's transuranic waste is currently being stored pending notifi-cation 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 are 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 static pressure of 4.5 inches. Stack sampling is con-i 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.
Air flow through glove boxes is minimal and results from in-leakage only 4
when the box'is closed. Atmosphere within the box is vented through a closed air filtration system designed for an air flow of 50 cubic feet per minute through an 8 inch glove port, should the port be opened.
Box pressure differential (1.0 inches water) is produced by a fan on the roof that exhausts into the 50 foot high stack. The exhaust system for the rooms in the controlled area is described in Section 7 of this report.
I D. O. P. tests were performed on the six final HEPA filters on September 24, 1981. Results ranged from 99.97 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.
Filter acceptance efficiency is 99.95%.
1 A review of air sample results since the previous inspection showed stack releases of 10.7, 4.4, and 71.0 MPC-HRS on July 17,-20, and 31, 1981 respectively, which is based on the insoluble plutonium-238 l
limit (1 x 10_22 pCi/ml) shown in Appendix B, Table II, Column 1 in i
The probable cause for these releases was dislodging of long term trapped material during stack repairs. Stack releases of 5.0, 2.2, and 16.0 MPC-HRS occurred on October 8, 15 and December 14, 1981 respectively, which is based on the insoluble americium-241 limit (4 x 10 12 pCi/ml).
No items of noncompliance were identified.
16.
Sealed Sources I
The eleven sealed sources used by the licensee were last leak tested on March 3, 1982 within the required six months interval. The test results showed less than 0.005 pCi of alpha and beta gamma removable j
contamination.
i No items of noncompliance were identified.
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Inventory The licensee's Quality Assurance Program includes responsibility for conducting a periodic inventory of licensed material. The most recent inventory showed the licensee possessed the following isotopes as of April 1982:
Am-241, Cf-252, Pu-238, Cs-137, Co-60,_and Sr-90, all with-in their possession limits.
No items of noncompliance were identified.
18.
Radiological Contingency Plan In accordance with a Commission Order dated February 11, 1981, the licensee submitted a Radiological Contingency Plan dated August 1981, revised October 27, 1981 and December 24, 1981. The Radiological Contingency Plan describes the licensee's emergency response organiza-
. tion, description and analysis of potential accidents including natural phenomena, and descriptions of the equipment, plans / procedures to pro-tect against, respond to, and mitigate the consequences of an accident involving radioactive materials. This plan was incorporated into license No. SNM-567 by amendment No. 10, dated March 29, 1982. The licensee has 90 days from the date of this amendment to fully implement the plan.
This inspection did not involve a complete audit of the plan. However, portions of the plan were reviewed by the inspectors.
Letters of agreement between the licensee and transporting and medical facili-ties have been received (Dayton Fire Department Paramedics, Dayton Fire Department, and St.
Elizabeth Medical Center in Dayton).
Dis-cussions with these organizations are held periodically. Emergency drills and personnel training, including off-site personnel, are planned in the near future.
Items not implemented into the plan thus far are:
a.
Fabrication of small steel boxes (shoe box size) for placement in remote boxes, not completed. These steel boxes will be used to place unencapsulated materials into (primarily americium and plutonium powders), in case of severe weather warnings. This will limit spread of loose materials in case of remote box rupture.
b.
Not all material storage safes fastened to floor (safe in Room No.
4 containing low level finished sources and standards).
c.
Distribution of plan to all applicable personnel.
No items of noncompliance were identified.
19.
Confirmatory Measurements The inspectors measured exposure rates of direct gamma and neutrons in the controlled process area, in and around Building 7, and along 12
the fence outside the building. Gamma measurements were made using Region III's Eberline, Model E-520, NRC No. 009573, last calibrated April 14, 1982. Neutron measurements were made using the licensee's Eberline, Model PNR-4, last calibrated March 17, 1982. Readings obtained in selected areas were found to be consistent with posted readings and those shown in the licensee's records of past surveys.
Twelve smears were also obtained from floor areas and pieces of equipment in the process area. The smears were initially counted by the licensee and then in the NRC-Region III laboratory.
No items of noncompliance were identified.
l 20.
Independent Inspection Effort l
The inspectors observed portions of neutron source fabrication opera-l tions, were demonstrated the response of the box line exhaust stack alarm and process area room alarm, and observed techniques and postings, during escorted tours of the facilities. Licensee representatives described the various operations that are conducted in each room.
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No items of noncompliance were identified.
21.
Exit Interview The inspectors met with licensee representatives (identified in Section 1) at the conclusion of the inspection on May 13, 1982 to discuss the findings.
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