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Insp Repts 50-054/93-03 & 70-0687/93-03 on 931116-18.No Violations Noted.Major Areas Inspected:Status of Previously Identified Items,Maintenance of Exhaust Gas Monitoring Sys, Lab Quality Assurance,Procedures & Recordkeeping
	ML20059K210
Person / Time
Site:	05000054, 07000687
Issue date:	01/13/1994
From:	Dragoun T, Joustra J, Peluso L; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20059K191	List: ML20059K189; ML20059K210;
References
	50-054-93-03, 50-54-93-3, 70-0687-93-03, 70-687-93-3, NUDOCS 9402020016
	Download: ML20059K210 (6)
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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.. 50-54/93-03 and 70-687/93-03

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Docket Nos.- 50-54 and 70-687

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License Nos. R-81 and SNM-639

Licensee: Cintichem. Inc.

P. O. Box 816 ;

Tuxedo. New York 10987

Facility Name: Research Reactor and Radiochemical Processing Laboratory i

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Inspection At: Tuxedo. New York

Inspection Conducted: November 16-18. 1993 !

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Inspectors: rp % / 3 9V l

Thomas DRig'oun, roject Scientist, Effluents date ,

Radiation Protecti n Section (ERPS), Facilities j

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Radiological Safety and Safeguards Bmnch (FRSSB)

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Ladric Pelus0, Racl/ition Phy/cist, ERPS, FRSSB

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Approved By: A* At k>co

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, Juc ' i 'un t , Ch ; , F -)S, FRSSB, d' ate / I

D vlie. < l'aiiation Sk ty and Safeguards i

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Areas Insprcted: Status of previously identiDed items, maintenance of the exhaust gas

monitoring system, laboratory quality assurance, procedures and recordkeeping, strontium

analysis program, and the water management prognun.

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Results: No safety concerns or violations of NRC regulatory requirements were observed. i

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9402020016 940114 !

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DETAIIJ .

1.0 Persons ContitrJed ,

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1.1 I,icensee Personnel l

J. Adler, Manager, Health, Safety, and Environmental Affairs (TLG)

L. Glander, Supervisor, Health Physics l

J. Garrett, Manager, Site Operations and Security

J. McGovern, Plant Manager

F. Morse, Project Manager, Decommissioning ,

J. Olynyk, Laboratory Supervisor !

R. Strack, Manager, Quality Assurance ;

L. Thelin, Health Physicist

E. Truskowski, Manager, Health Physics and Environmental Monitoring ;

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1.2 New York State Personnel

B. Youngberg, NYS Department of Environmental Conservation

Attended the exit interview on 11/18/93. Other licensee and contractor personnel

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were interviewed during the course of the inspection.

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2.0 Status of Previously Identified Items

2.1 (Closed) Followup Item (50-54/9J-02-02) Licensee to ensure that the flow rate in q

the airborne exhaust monitoring systems are adjusted to ensure isokinetic sampling. l

The Health Physics Manager was made responsible for determining if flow in the !

exhaust duct had changed and if the sampling system flowrate needed adjustment. l

The responsibility for adjustment of the sampling system flowrate was assigned to the - I

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Health Physics Supervisor. A review of records indicated that the sampling systems

were properly adjusted.

2.2 (Onen) Followun Item (50-54/93-02-03) Increase the sensitivity of the laboratory

analysis of airborne exhaust samples by increasing count times and compositing

samples. Count times were increased from one minute to ten minutes. Weekly

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samples are now composited and counted quarterly. Filter media samples from 1992

and 1993 held in storage were composited and counted. The licensee is evaluating

methods for statistical assessment of analytical results, many of which are less than

minimum detectable activity (negative values). This final item will be reviewed in a

future inspection.

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3.0 Maintenance of the Exhaust Stack Monitorine System

The exhaust stack monitoring system continuously monitors the airborne gaseous and

particulate activity in the main duct leading to the elevated stack. This equipment was

checked daily by an instrument technician and the results recorded. There are two

alarms, one for an instantaneous concentration, and the other for a weekly average

concentration set at 25% of the maximum permissible concentration specified in NRC

regulations. The alarm setpoints are based on calculations by the Health Physicist

which factored in the contributions from the various radioactive isotopes in the

Reactor Building and Hot Lab Building, which both discharge into this duct. This

approach appeared to be reasonable. A review of records indicated that all discharges

were within limits.

4.0 Analvtical Lnboratory Performance

In addition to the continuous stack monitor, there are separate sampling systems on

the Reactor Building and Hot Lab Building ducts which feed into the main exhaust

duct. These sampling systems contain particulate and carbon cartridge filters that are

changed _ weekly. There is also a weekly charcoal filter sample drawn from the main

stack. All filter media are analyzed for activity in the on-site laboratory, which also

analyses liquid effluent samples. The inspector reviewed the performance of the

laboratory program through observations of maintenance and calibration of equipment,

interviews with laboratory and Quality Control personnel, and a review of procedures

and recordkeeping.

4.1 Ouality Assurance

The site Quality Assurance group consists of a supervisor and an auditor with a

chemistry background. The QA program for the laboratory consists of maintaining

control charts, providing spiked samples for anaipb, periodic audits, and

participation in the EPA Laboratory Intercomparison (EPA Lab) program.

Parameters to be control charted are determined by the QA group. The lab

technicians report any out-of-band condition to the QA group and place the effected

apparatus out-of-commission until an evaluation is completed. The QA group also

prepares spiked samples using radioactive material obtained from the EPA and

certified by NIST. The number of spiked samples is targeted to be about 10% of the

total number of samples processed by the lab. Some spiked sampics are decay

corrected and reused. An audit was conducted from February to April 1993. No

major deficiencies were noted in the report.

The licensee participates in several categories of the EPA Lab program including

measurement of alpha, beta, and gamma emitters on airborne filter media (began in

1991), gamma emitters in water (began in 1992), and strontium 90 in water (began in l

1993). All results met the EPA acceptance criteria. The inspector observed that the

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, analytical results for gamma activity were consistently reported near the high end of ,

l the EPA acceptance band. This observation was confirmed by the QA auditor and

laboratory supervisor. The lab supervisor stated that in order to get a broad energy

spectrum for the calibration of the thin window, high efficiency, N-type germanium

detectors a mixed standard source consisting of antimony-125, europium-154, and

l europiun -155 was used for the annual calibration. This calibration extended the

l useful range of the detectors into the soft x-ray region (< 10 Kev) and allowed

identification of atoms from their characteristic x-ray emission (usually the K-alpha

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spectral line). As a result, the analytical capability of the laboratory was excellent.

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However, the lab supervisor determined that four of the gamma peaks from the Eu- '

154 were coinciding with gamma peaks from the other isotopes in the standard

l source. The effect of this coincidence counting was to lower the apparent efficiency

of the detector by 10% to 20% in the range be-tween 247 Kev and 873 Kev. The

computer software then raised the corrected counts for samples with gamma peaks in

this region. The reported activity was therefore 10% to 20% higher than the actual

activity. The lab supervisor stated that although the reported activities were always

conservative, the software will be modified to eliminate the coincidence counting.

The results for the 1994 EPA comparison are expected to be much closer to the mean ,

value. This represents an excellent licensee initiative.

Within the scope of this review, no safety concerns were identified. The inspector

concluded that the assurance of quality in the laboratory was excellent.

4.2 Procedures and Record Keenine

The inspector reviewed the procedure manuals to evaluate the implementation of the

effluent control programs in accordance with Section .7.0 of the NRC-approved

Decommissioning Plan. The Health Physics (HP-M) and the Health Physics {

Environmental l2boratory (HP-EM) Manuals contained the procedures for soil and .

water sampling, sample preparation and analysis, calibration of counting

instrumentation, quality assurance and quality control procedures, and the water ,

management program. The procedures were clear, concise, and contained the !

required direction and guidance for implementing effective programs. The inspector l

noted that several of the procedures were in the process of revision to reflect program i

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changes. Procedures of the HP-EM manual correctly referenced procedures and '

forms of the HP-M. The inspector noted that there were no obvious mistakes or

omissions. The inspector noted that the licensees record keeping was very good. The

licensee was able to k>cate files and records upon request in a timely manner. Forms,

such as the water release permit forms contained the appropriate information, and

accurately coincided with the appropriate procedures, with one minor exception. The

licensee made a note and will correct immediately. Chain of custody, release permit,

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and sample control forms were effectively used according to procedures. Based on

the procedure review and discussions with personnel, the inspector determined that

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the licensee has in place effective procedures and recordkeeping for the effluent

controls program.

4.3 Sample Preparation and Countine

The inspector reviewed laboratory activities including processing, preparation,

analysis of the sample media, and reporting of results. The inspector also followed !

an actual sample through this process. The inspector noted that after samples had ;

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been analyzed, the results were transferred by hand into a logbook and were

subsequently transferred to a computer spread sheet which was used to produce

reports to the NYS-DEC. The records indicated that all gaseous and liquid discharges

were within limits specified in 10 CFR 20, Appendix B, Table II. During a review

of these final steps, the inspector and licensee found that a former employee had made

errors in transcribing data from the computer spreadsheet to the report form. The

licensee has initiated an investigation and will take steps to ensure that transcription

errors are detected and corrected. This was an isolated case and is not an NRC

regulatory concern. The inspector noted that the licensee counts samples twice, once

to meet their release criteria and once to meet analysis criteria. The release criteria

was logged but the analysis criteria was not logged. The inspector noted that the

difference in the two results did not significantly alter the final results. Within the

scope of this review, no safety concerns were identified.

4.4 Strontium Analysis

The radioactive isotope Sr-90 has presented unique problems for the licensee. It has -

been frequently detected in the water in sump S-4, it is one of the limiting isotopes in

the NRC approved soil release criteria, and is difficult to quantify. The licensee used

the services of an off-site analytical laboratory but experienced delays in obtaining

results. To resolve these issues, the licensee recently developed an on-site laboratory

program for strontium analysis. The inspector interviewed the lab personnel and

determined that they were experienced and qualified. Both water and soil samples are

prepared in the lab. The analytical technique consists of passing a prepared liquid

sample through an ion specific resin column. The strontium is then eluted from the

column with nitric acid, the eluant is dried on a planchet and counted with a thin

window alpha-beta detector. The detector system is calibrated with an Sr-90 and Pu-

239 standard sources. The lab reports the sample counts to the lab supervisor who

corrects for in-growth of Y-90 using a computer spreadsheet program. The minimum

detectable activity of this procedure for water samples was reported to be about 8E-10

Ci/ml and about 0.2 pCi/mg in soil. Both values are well below the applicable

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limit. The licensee is participating in the EPA Lab program for Sr-90 and achieved

acceptable results in the 1993 round.

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Within the scope of this review, no safety concerns were identified. Licensee

management was commended for developing this program.

5.0 Water Manaeement Procram

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The inspector reviewed the water management program to verify the licensee's ability

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to effectively control liquid releases to the environment in accordance with the

Decommissioning Plan. The Manager of Maintenance and Security has the

responsibility for the water management program. The inspector toured the licensee's

facility including the reactor building (Bldg 1), the hot cell building (Bldg 2), and the

locations of the 5,000,10,000 gallon storage tanks and the mobile tankers. Water

from buildings 1 and 2 flow to the 5K tanks and water from other ground / surface

water sources flows to the retention pond. The 10K tanks are no longer used. After

the tanks and/or pond has been sampled, analyzed, and verified for release, the

Utilities Technicians release the tanks. The inspector noted that the Utilities

Supervisor reviews the release log book daily and confirms that the status of the tanks

and the position of the valves are correct. Based on the above review and discussions

with personnel, the inspector determined that the staff members understood the

importance of the effluent control program and implemented the program effectively

and professionally.

6.0 Exit Interview

The inspector met with the licensee representatives indicated in Section 1.0 of this

report on November 18,1993 and summarized the scope and findings of this

inspection. The licensee acknowledged the findings. j

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ML20059K210

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