ML20133A688
| ML20133A688 | |
| Person / Time | |
|---|---|
| Issue date: | 03/10/1971 |
| From: | Epstein E, Nelson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20008D730 | List:
|
| References | |
| FOIA-85-111 NUDOCS 8507200142 | |
| Download: ML20133A688 (10) | |
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592 BACKUP NOTES l
Region I, Division of Compliance Newark, New Jersey
- 1. Licensee: 2. Date of Inspection: March 5, 1971 i Radiation Machinery Corporation 3. Type of Inspection: Announced rein-25 Eastmans Road spection Parsippany, New Jersey 07054
- 4. License No. 29-12649-01 Amendment 8, dated November 3, 1968 Category E, Priority III
- 5. There is no company confidential information contained in this report.
- 6. Scope of Inspection:
Parts 20 and 30.
- 7. Inspector Accompanied By:
Mr. P. Veerling, DML New Jersey authorities were invited, but declined to appear.
- 8. Persons Contacted:
Mr. George Taylor, Vice President and Acting RSO.
Mr. G. Dietz, Vice President Mr. McKimm, Hot Cell Operator 9.
[.t.a L ' b'O lri:
Inspected by: Eugene Epstein /s/ March 9, 1971 Radiation Specialist Date of Report s %
Reviewed by:
O 1 R. Nelson
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/s/ March 10, 1971 Senior Radiatiori Specialist Date 8507200142 850510~
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DETAILS l Backaround Information
- 1. License No. 29-12649-01 was last inspected on August 21, 1968. No items of noncompliance were noted and Form AEC 591 clear was issued.
, During the latter inspection, use of materials was minimal.
Organization and Administration 1
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- 2. There has been a complete change in organization and administration.
, Mr. George Taylor, Vice President and Acting RSO, stated that since the l last inspection there has been an almost complete financial collapse i ;
and personnel has declined from a maximum employment of 150 persons in a 1968 to 10 persons at the present time. He stated they also have com-plately abandoned the Wood products irradiation program under License 4 -03, and that all sources were removed from the large irradiation pool.
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- 3. Taylor stated that he reports to Mr. Carl Wootten, President. He also i
stated that on April 1,1971, the company will be absorbed by Interna-tional Controls Inc.
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- 4. Taylor stated that Peter Loysen, RSO and Chairman of the Isotope Committee,
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left on August 1,1970 and since that time he has tried to recruit an RSO, without success. He stated that the Isotope Committee since then has been reconstituted and now consists of himself as Chairman with mem-bers as follows; Robert Duff, Vice President, Carl Wootten, President, t'
and George Dietz, Vice President.
, Facilities and Uses of Materials
- 5. An inventory record of sources on hand, dated March 1, 1971, was shown to the inspector by Taylor and showed possession of the following:
License Item Form Max. Amount Auth. On hand
- a. Co-60 Sealed sources 1,000,000 C1 167,500 Ci (3/1/71)
- b. Cs-137 Sealed Sources 1,000,000 C1 127,604 Ci in hot cells plus 15 sources of 400 Ci each for Gammators.
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i i License Iten Form Max. Amount Auth. On hand i ,
- c. Sr-90 Sealed Sources 20,000 C1 160 Ci as 8 sources l
20 Ci each for extra corporeal blood ir-radiators
- a. Co-60 Sealed Sources .009 Ci Tracerlab
- R-31 calibration
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- 6. Taylor stated no other sources are possessed or used at present. Re-cords indicated that a total of 989,100 Ci of Co-60 as NPI sealed sources were transferred back to NPI in NPI DOT approved devices in i 1969.
Facilities
- 7. Taylor stated that since March 4,1970, they have been performing ir-radiations of commercial products in hot cells two and three. Records indicated that they started with 40,000 Ci and increased it to 90,000 I Ci shortly afterward and at present have in cell 2 and 3, which is ac-tually one combined hot cell, 162,500 C1 Co-60 in a circular array, consisting of 25, one-half inch diameter stainless steel tubes, 5' long.
Each tube, according to Dietz, in charge of irradiations, consists of 2500 Ci Co-60 as GE or NPI sealed pellets. The diameter of the array is 7", according to Dietz.
- 8. Dietz stated they irradiate cosmetics, paint products, medical supplies and plastics. A use log indicated irradiations are constant; 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> daily. Dietz and Taylor both stated that this use of Co-60 was not authorized by any provision of the license. Records indicate that Loysen, the former RSO, authorized this operation.
- 9. In a conference at DML on January 20, 1971, attended by Dietz and Taylor, the licensee admitted unlicensed operations in hot cells 2 and 3. (See letter to files signed by Veerling, DML, dated March 3, 1971.) Taylor stated to the inspector that they are continuing hot cell irradiations because that is.the only source of income, and that an application for i amendment to authorize these irradiations in hot cells was sent to DML in October, 1970.
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- 10. The inspector examined the hot cells and surrounding area and it was
! noted that Cells 2 and 3 are actually one cell. Entrance to the cell 4 .
is made directly into the cell by opening a rear 6' thick concrete
! shielding door. Entry into the service area behind the cells is via i
' a locked door. The cell itself has concrete walls and ceiling 4' thick.
The cell entry door was noted to be equipped with a refrigerator type lock handle and Taylor stated it could be opened from the inside.
, 11. Taylor stated that the cell entry door is locked with a padlock when not in use, and that a double key procedure is used; one key opens the pad-lock and the other key opens the additional refrigerator door lock.
Taylor stated only he and McKimm, the hot cell operator, have keys and that any person must have he or McKima personally open the second lock.
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- 12. The inspector noted that when McKimm opened the rear door of Cells 2 and 3, a red light over the cell door was energized. License Condition 15 requires the licenses to follow the procedures set forth in a letter dated May 2, 1969. Paragraph 7 of Page 2 of that letter states that the hot cell doors are equipped with a Kirk electrical interlock which ener-gizes audible and visual signals in the operations area when unlocked.
Taylor described the Operations Area as the areain front of the hot cells where controls for slave units are located. He described the rear of the hot cells as the Service Area. Taylor stated and it was observed, that a red light is energized in the Operations Area, but there is no audible alarm or signal when such door is opened as stated in the letter of May 2, 1969.
- 13. The inspector noted,that in the service area in the hunediate rear of Cell 2 and 3, an overhead GM detector. The inspector noted and Taylor stated that this was connected to a Victoreen read out and alarm which was not operative. Taylor stated that all Victoreen equipment; a contin-uous stack monitor, a service area monitor and other area monitors were all inoperative because of money problems between Victoreen and RMC.
- 14. Taylor stated that all the hot cell operator uses at present is a Jordon
" Rad-Gun" survey meter to monitor radiation levels when he opens the rear
.- cell door.
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- 15. The inspector noted and Taylor stated the roof of the hot cell is 10'
, high and the normal shielding has been reinforced by the addition of l four feet of cement blocks.
- 16. Hot Cell 2 and 3 has three viewing windows made of lead glass. Each window has four elements. One window faces the rear Service Area, the 4
other two face the front Operations Area. The inspector noted that the inside element of both the rear window, and the left front window were cracked. Taylor stated this occurred in March,1970 during use of i
i 90,000 ci co-60 and was due to radiation damage,
- 17. The inspector noted that each window had two 2" thick lead windows cover-1 ing the windows on the inside of hot cell 2 and 3. Taylor stated these lead shields were added to tha cell windows after radiation damage was j noted.
- 18. Paragraph 11 on Page 5 of the letter of May 2, 1969 states, "The pressure differential between hot cells and the plant area will be 0.8 inches of wate r" . The licensee was noted to have manometers located on the front face of the hot cells and the inspector noted the indicated differential pressure between cell 2 and 3, and the Operations Area, at the time the door was closed, was only 0.25 inches water. McKimm and Taylor both stated that there was no negative pressure drawing air into the hot cells.
The air system has an auxiliary fan which automatically kicks in when the cell door is opened to maintain a negative pressure. McKina stated he keeps this auxiliary fan disconnected because the design cut off was at a dip of 0.8 inches water and if it cut on it would not cut off, because they could not get up to 0.8 inches water, and if operated continuously would cause the motor to burn out. He stated thenaximum DP that they can
, achieve is 0.25 inches water.
- 19. Sources when not irradiating materials are stored in a water pool located immediately below cell 2 and 3. McKimm stated the sources are stored below 18' of water. He stated the pool can not drain as it is doubly con-tained and all pumps and filters are located above the pool surface. The pool is however, equipped with a liquid level alarm, according to McKimm.
Water is recirculated through an ion resin bed. McKima stated they have had no reason as yet to change the ion exchange resin.
- 20. cell 2 and 3 is equipped with a hoist which raises sources from the pool into the cell. Sources can be passed through lead shielded pass ports into cell 1 or outside into a side restricted service area. Taylor stated 4
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I the side passport is locked and will not be used. The passport door operates remotedly by means of pneumatic pressure cylinders.
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- 21. McKinna stated.that cell I has been used to load Gannator irradiators
-and the extra corporeal irradiators.
- 22. The inspector observed McKima in operations. McKLun connected the lift
, cable to the source array using a long rod from the top of the pool.
i He then, inside the cell, pulled the cable taunt thus placing the source array below cell-2 and 3. He opened the left front window lead shield j slightly, and thenlocked the rear door of the hot cell. From the front
- of the, cell he was noted to watch the cable as he energized the lift j mechanism. It was noted that when a small rag wound around the cell
-cable appeared, he halted the lift mechanism. He stated the sources were
. now in proper position. He stated the rag was the position where the sources were above the ficor of the hot cell. -
Surveys
- 23. A. Restricted Areas Records of direct radiation surveys were noted to be maintained.
The licensee has a variety of survey meters. Taylor stated he performs direct physical surveys on a monthly basis.
- 24. 1. Radiation levels above the hot cells were reported to have been 500 mR/hr prior to adding cement blocks. Thesc levels are now reduced to between 25 to 105 mR/hr. Taylor reported and the inspector noted that there is no access to the area bumediately above the hot cells.
- 2. The roof over the building was noted to be 20' above the top of the hot cella and had reported radiation levels of 8 mR/hr.
- 3. The . rear of the hot cells at two inches from the door of cell 2 and 3, had reported levels of from 12 to 40 mR/hr.
- 4. The cell face in front of cell 2 and 3 had reported levels from 3 to 15 mR/hr at two inches distance frondhe surface.
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- 5. The beta laboratory hood which abuts the rear of hot cell I had reported levels of 6 to 18 mR/hr.
- 6. The pass drawer on the side of hot cell 2 and 3, had reported readings of 20 to 75 mR/hr at two inches from the surface.
B. Unrestricted Areas
- 25. No sky shine was reported in Taylor's surveys in unrestricted areas outside the licensee's building. Unrestricted office areas inside i the licensee's facility such as offices, and lunchroom had radiation readings no greater than 0.3 mR/hr.
- 26. The inspector perfonned direct physical surveys of the same areas using a Victoreen Model 444 Ionization survey meter, and noted approx-i imately the same radiation readings during the time the 162,500 Ci of Co-60 was exposed.
Smear Surveys
- 27. Taylor reported he makes monthly smear surveys of all areas surrounding the hot cells using filter paper smears and counting the smears using a gas flow windowless counter and scaler. He stated and records indicated no removable activity in excess of background 50 to 52 cym. Taylor stated he uses a co-60 beta standard.
Other Surveys
- 28. Taylor stated no other surveys were performed. He stated because the sources are doubly encapsulated and in turn contained in stainless steel tubes, there was no likelihood of airborne activity in restricted or unrestricted areas.
Personnel Monitoring l 29. Taylor reported that Landauer fibn badges processed monthly were used for personnel monitoring. Exposure records were noted to be maintained on Form AEC-5, with all entries completed. Examination of the records indi-cated McKimm, the hot cell operator, received the highest calendar quarter year exposure, that of 290 mrem.
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- 30. Other personnel did nok receive more than 100 mrem / calendar quarter year.
Records were reviewed since the date of the last inspection. Taylor re-ported that self-reading pencil dosimeters were also worn by all person-I nel in the service or operations areas. He stated that records of these l exposures were not maintained prior to January 1,1971. He stated he has maintained records of dosimeter exposure since that date. The records of dosimeter l exposure rsveals that McKinut receives whole body exposures of 60 to 80 mren/ month. Records were noted to be maintained on a daily basis and totalled monthly.
Postina and Labelina
! 31. .The inspector noted that Form AEC-3 was posted at the entrance to the re-
! stricted area. The hot cell walls and roof were noted posted with signs i
reading, " Caution - High Radiation Area" with symbol and " Caution - Radio-active Materials", with symbol. Other restricted areas and the facility roof were noted posted with signs reading, " Caution - Radiation Area" with symbol.
Records
- 32. Records were noted maintained of all receipt and transfer. The records indicated the kind of material- involved, date of receipt or transfer as well as assay.
License Conditions
- 33. Condition 10 - Place of use was noted to be and records reflect use thus far only at 25 Eastmans Road, Hanover, New Jersey.
34 Condition 12 - Taylor stated all present uses of material were used'by persons designated by the Isotope Committee - Peter Loyson, Chairman.
The inspector noted a written authorization signed by Loyson designated McKina as Hot Cell Operator.
- 35. Condition 12 - Records indicate that tests for leakage of all sealed sources on hand were performed at intervals which do not exceed six months by McKimm, who stated he remotely wiped,using slave units, the surface of the sources with filter paper and counted these in the gas flow proportion-al counter against a Co-60 beta standard. He orally reported to the in-spector that no detectable activity above background existed. Examination of the records revealed that McKima only recorded the fact that a leak test was performed. The inspector could find no record of results, counting data or any notation in units of microcuries. McKima stated he did not make any such record. License Condition 13(b) requires that records of
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leak test results be kept in units of microcuries and maintained for a
inspection by the Commission.
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- 36. Condition 14 - McKima was noted to have a copy of the referenced instruc-I tions and appeared familiar with its contents. Taylor stated that all persons were given a copy of the instructions. He also stated no changes have been made since September, 1969.
- 37. Condition 15 - A review of the listed documents was made and compliance was noted except as stated otherwise in report details.
l Items of Noncompliance t
- 38. a. 10 CFR 30.34(c), " Terms and Conditions of licenses", Contrary to 10 CFR 30.3, co-60 has been used for service irradiations inside hot cells, a use not authorized by License Condition 9A. (See Paragraphs 7 through 9 of report details and License Condition 9A.)
- b. Contrary to License Condition 13B, records of tests for leakage and removable contamination were not in units of microcuries or maintained for inspection by the Commission. (See Paragraph 35 of report details.)
- c. Contrary to License Condition 15 which incorporates the provisions of a letter dated May 2, 1969, differential pressure between hot cells and surrounding operations and service areas has been maintain-ed at less than 0.8 inches water and an interlock device on hot cell doors did not energize both a visible and audible signal when opened as stated in the referenced letter. (See Paragraph 12 and 18 of re-
. port details.)
Management Review
- 39. The items of noncomplian:e were discussed at a conference immediately following the inspection. Attending the conference besides the inspec-tor was Peter J. Veerling, DML and George Taylor, Vice President.
- 40. Regarding the noncompliance for 10 CFR 30.34(c), conducting unauthorized service irradiation in hot cells. Veerling acknowledged that the licensee had submitted an amendment to authorize such activity and indicated that DML would grant such authority in a license amendment. Taylor stated they would not conduct unauthorized operations in the future.
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.41. Regarding failure to maintain records showing the results of tests for i leakage, Taylor stated he would remove authority for performir.g these j tests from operations and he would do these tests himself, and maintain
' proper records.
- 42. Regarding the interlock device, Taylor stated they would add the audible alarm to the present interlock.
l 43. Regarding the low differential hot cell pressure and the lack of negative pressure between surrounding areas, and hot cells. Taylor stated he did not know whether he could correct this. He stated he has full knowledge that the cell air flow makes the facility inadequate to perform encapsul-ation activities or to use powdered cesium as presently authorized. He i
stated he would resist any pressure by higher management to encapsulate or to use powders.
44 Veerling asked Taylor if he would withdraw these items from his license application. Taylor stated he could not do so because the new corporate management of International Controls, Inc., reviewed the license before taking over the company. Veerling did not reply.
- 45. The inspector told Taylor that the facility is adequate for present ac-tivity with sealed sources, but inadequate for any encapsulation or powder work.
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