ML20133M897

Insp Repts 50-054/85-04 & 70-0687/85-07 on 850819-23. Violations Noted:High Radiation Areas Not Posted as Required & Entry to Hazardous Areas Generated by Waste Drums Not Restricted

ML20133M897
Person / Time
Site:	05000054, 07000687
Issue date:	10/21/1985
From:	Mcfadden J, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133M887	List: ML20133M885 ML20133M892 ML20133M897
References
50-054-85-04, 50-54-85-4, 70-0687-85-07, 70-687-85-7, NUDOCS 8510280305
Download: ML20133M897 (11)

See also: IR 05000054/1985004

Text

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-54/85-04

70-687/85-07

, Docket No. 50-54

'70-687

License No. R-81/SNM-639 Priority -1- Category UHBR

,

Licensee: Cintichem, Inc.

P. O. Box 324

Tuxedo, New York 10987

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Facility Name: Research Reactor / Hot Laboratory

Inspection At: Tuxedo, New York

Inspection Conducted: August. 19-23, 1985

Inspectors: M. [2/ /02//f.)~

[date

A.Weadock,Radat' ion /pecialist

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J.McFadden,Raiation/pecialist

. /O 21YS

' ' dath

Approved by: M. , sfu _ /p/2,/!ff

H. Shanbaky', Chief, PW7 ' / date'

Radiological Protec1rion Section, DRSS

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I Inspection Summary: Inspection on August 19-23, 1985 (Report No. 50-54/85-04;

70-687/85-07).

Areas Inspect _e_d: Routine, unannounced inspection of the licensee's Radiation

Protection Program. Areas inspected included posting and labeling, surveys

and sampling, dosimetry, Technical Specification surveillances, and exposure

controls.

J

Results: Three vidlations, one dealing with High Radiation Area control and

posting, (Section 3) one involving labeling of radioactive material, (Section

3) and one concerning failure to perform monthly testing of the stack monitor

(Section 6) were identified during the course of this inspection. .

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DETAILS

1.0 Persons Contacted

During the course of this routine inspection, the following personnel

were contacted or interviewed:

J. Baird, Senior Reactor Operator

J. Ditton, Lead Health Physics Technician

R. Johnston, Health Physics Associate, Senior

• C. Konnerth, Manager- Health, Safety, and Environmental Affairs

J. Kratochwil, Utility Supervisor

• J. McGovern, Site Manager

J. Musumeci, Lab Technician II

P. O'Callaghan, Radiochemical QC Supervisor

W. Ruzicka, Manager, Nuclear Operations

R. Saxton, Reactor Operator

B. Strack, Reactor Supervisor

• Present at the exit interview on August 23, 1985

2.0 Purpose

The purpose of this routine inspection was to review the licensee's

radiation protection program with respect to the following elements:

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Posting and Labeling,

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Surveys and Sampling,

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Dosimetry (External and Internal),

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Technical Specification-required Surve111ances,

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Exposure Controls.

3.0 Posting and Labeling

The inspector toured the licensee's facility on several separate occa-

sions to inspect general housekeeping and evaluate the licensee's posting

and labeling of radiation areas, high radiation areas, and radioactive

materials. Independent survey measurements were made by the NRC inspec-

tors using an Eberline R0-2, Serial #6298, calibrated May 16, 1985. Two

apparent violations, one involving posting and control of high radiation

areas and one involving labeling of radioactive material, were identified.

3.1 High Radiation Area Posting and Control

10 CFR 20.202(b)(3) defines "High Radiation Area" as "any area,

accessible to personnel, in which there exists radiation originating

in whole or in part within licensed material at such levels that a

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l major portion of the body could receive in any one hour a dose in

excess of 100 millirem."

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10 CFR 20.203(c) requires that each "high radiation area shall be

conspicuously posted with a sign or signs bearing the radiation

caution symbol and the words: Caution - High Radiation Area."

10 CFR 20.203(3) also requires that "each entrance or access point

to a high radiation area shall be maintained locked except during

periods when access to the area is required, with positive control

over each individual entry."

During a tour of the reactor building the inspector measured the

following dose rates at the following areas:

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The glovebox in the I-125 loop process area was reading 300

mR/hr at eighteen inches from the glovebox on August 19, 1985.

A general area dose rate of 50 mR/hr was measured at the gate

in the fenced area surrounding the glovebox.

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On August 20, 1985, the inspector surveyed the lower level of

the pump room in the reactor building and measured 150 mR/hr in

the general area around the cation bed ion exchanger and general

area dose rates of 250 mR/hr between the cation and anion

exchangers.

Neither of the above areas was posted as a high radiation area .

required by 10 CFR 20.203(c). The inspector noted that both areas

were maintained locked by the reactor operations section.

The licensee maintains a locked, posted high radiation area on

the upper level of the reactor building for the storage of radio-

'

active material. While touring this area, the inspectors noted two

55 gallon drums of waste located adjacent to, but outside, this

storage area.

The drums were posted with a "High Radiation Area" sign; however,

the inspector noted that access to the drut..s was not locked or res-

tricted. No licensee personnel were in attendance at the storage

area and the inspector's progress into the high radiation area

generated by the drums was not obstructed. Notations on the "High

Radiation Area" sign indicated dose measurements of 150 mR/hr dated

February 1985 and 125 mR/hr dated July 1,1985. The inspector per-

formed a survey of the drums and measured 150 mR/hr at eighteen

inches from the drums and 400 mR/hr on contact with the drums.

l The inspector informed the licensee that the above instances

constitute apparent violation of 10 CFR 20.203, in that:

1) two high radiation areas were not posted as required; and

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2) entry to a high radiation area generated by two drums of waste

was not locked or rettricted (54/85-04-01).

During the exit interview, the licensee indicated their awareness of

the exceptions to access control of high radiation areas specified in

10 CFR 20.203(c)(4), which allows high radiation areas established

for 30 days or less to be controlled against unauthorized entry by

direct surveillance. The licensee stated the 55 gallon drums of

waste on the upper reactor floor constituted a temporary high radia-

tion area, and visual control of the entrance to the reactor building

was being maintained by the operators. The inspector indicated to

the licensee that notations on the "High Radiation Area" sign showing

dose rate measurements in February, 1985 indicated that the high

radiation area was established at least six months prior to this

inspection and could not be considered temporary.

The licensee's HP technicians currently perform daily surface con-

tamination surveys and monthly radiation surveys in the reactor

building. The licensee indicated that, due to the nature of the

operations, dose rates in the reactor building were transitory and

made posting difficult. The inspector noted that, despite transitory

dose rates, the low frequency of radiation surveys may have been

responsible for the failure to identify the above high radiation

areas.

, 3.2 Labeling of Radioactive Material

10 CFR 20.203(f), " Containers", requires that ". . . each container of

licensed material shall bear a durable, clearly visible label iden-

tifying the radioactive contents." During a tour of Building 2 the

inspector identified the following unlabeled material:

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Two control rod armatures, reading from 4 to 20 mR/hr on con-

tact, were found laying on a benchtop in the machine shop. No

j loose contamination was found on the armatures. The two arma-

! tures were unlabeled and were found mixed in a pile of tools

and scrap. No licensee personnel were present or had apparent

responsibility for the material. Licensee supervisory personnel

accompanying the inspector indicated that the machine shop does

not routinely contain radioactive material. The licensee also

indicated that all material leaving the reactor building (Build-

ing 1) is usually surveyed by HP prior to removal.

During a tour of the upper floor of the hot laboratory facility

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the inspectors identified a 55 gallon, unlabeled drum reading

approximately 10 mR/hr on contact. The licensee indicated that

the drum was being used to store scrap material from the hot

cells.

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Licensee failure to label the radioactive material identified

above constitutes an apparent violation of 10 CFR 20.203(f)

(54/85-04-02,687/85-07-01).

The licensee took the following corrective actions during the week of

the inspection:

1) The two drums of waste creating a high radiation area on

the upper level of the reactor building were moved into the

locked, shielded storage area.

2) The I-125 loop process area and the ion exchanger area of

the pump room, lower level were both posted as "High Radia-

tion Areas."

3) The control rod armatures were removed from the machine

shop and placed back in the radioactive material inventory.

4) The 55 gallon drum on the upper floor of the hot lab faci-

lity was labeled as containing radioactive material.

4.0 Surveys and Sampling

4.1 Surveys

Daily routine contamination surveys and monthly routine radiation ,

surveys are performed by the Health Physics Staff for the Reactor / '

Hot Laboratory facilities. In addition, special surveys are per-

formed as required for evaluating radiological hazards associated  !

with specific work activities.

i

Adequacy of the licensee's survey program was assessed by the

following methods:

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independent radiological measurements performed by the inspector,

review of selected surveys for 1984 and 1985,

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observation of an HP technician performing routine surveys,

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discussion with supervisory personnel.

Within the scope of the above review, no violations were noted.

Surveys were generally thorough and appeared adequate in identifying

radiological conditiens. However, the frequency of radiological l

surveys in the reactor building was discussed with the licensee 1

(details, paragraph 3.1).

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4.2 Sampling

The inspector reviewed analytical results and licensee sampling

methods for reactor pool and holdup tank water. Radicactive liquid

from the reactor and hot laboratory operations are collected in a

7200 gallon tank located in the Hot Laboratory Building. Waste from

this tank is evaporated and the distillate passes on to the evapo-

rator condensate tank, where it is collected and sampled. Liquid is

then passed on to one of several collection tanks, wtere it is stored

prior to discharge to the Indian Kill Creek. Liquid from the radio-

chemical operations in Building 4 also passes to the collection

tanks. These 5000 gallon and 10,000 gallon tanks are sampled for

activity prior to discharge.

The inspector reviewed reactor pool and tank sampling records for

1984 and part of 1985 and verified that sampling was being performed

at the required frequency. The inspector noted that sampling tech-

niques vary dramatically between the evaparator condensate tank and

the collection tanks. Air is continually passed through the evapo-

rator condensate tank to promote mixing cf the tank contents.

Samples are obtained from the collection tanks by lowering a

weighted container through a sampling port into the tank. Tank

contents are not mixed prior to sampling. The inspector stated that

samples from the tank collected by this method may not be represen-

tative of the tank's contents and should not be relied upon as an

indicator of the tank's activity levels.

The licensee stated that the present method of sampling the

collection tanks provided a suitable indication of tank contents,

based on the following:

a) The limit used as a go - no go criteria for the sample was

extremely conservative with respect to 10 CFR 20 Appendix B,

Table I limits.

b) Until the beginning of 1985, the licensee had used a composite

sampler to sample the sump in the discharge pathway between the

collection tanks and the Indian Kill Creek. A licensee inter-

comparison of the results of analyses of the sump and the tanks

indicated the tank sampling method provided an adequate repre-

sentation of tank contents.

The results of the licensee's intercomparison and the suitability of

tank sampling methods will be reviewed in a subsequent inspection

. (54/85-04-03,687/85-07-02).

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5.0 Dosimetry (External and Internal)

The licensee's dosimetry program includes the following elements:

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external monitoring by film badge and TLD,

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routine measurements of thyroid burden by thyroid counting, and

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urine bioassay.

5.1 External Monitoring

The licensee contracts with Landauer to provide film badge and badge

processing services. The licensee also has the capability of issuing

and reading in-house TLDs and uses this capability for immediate dose

assessment on high exposure jobs. The licensee also uses TLDs for

extremity monitoring. The Landauer badge reading is used as the

official dose record by the licensee.

The inspector reviewed exposure records for 1984 and 1985 and

reviewed exposure histories for workers exceeding 1250 mrem / quarter

during this time period. All required documentation was complete.

Within the scope of this review, no violations were noted.

5.2 Thyroid Assay

The licensee's SNM license requires that thyroid uptake shall be

determined at least quarterly for all employees " processing and dis-

pensing" iodine. Current licensee activities include the separation

and extraction of I-131 and I-125. The inspector reviewed the

licensee's implementation of a thyroid assay program by the follow-

ing methods:

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discussion with supervisory personnel,

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review of the following procedures:

I.I Procedure for Recording Thyroid Counting Data,

I.II Determination of Allowable Weekly Increments of I-125

and 1-131 in the Thyroid for Radiation Workers,

I.V Calculation of Maximum Permissible Thyroid Burden for

Iodine-125,

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review of air sampling records for 1985,

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review of the thyroid assay logbook.

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The inspector verified by review of the thyroid assay logbook that

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individuals responsible for " processing and dispensing" iodine had

received quarterly thyroid counts. The licensee indicated fulfill-

ment of this requirement was insured by holding back worker's pay-

checks until all required thyroid counts were completed.

1

Due to close proximity of working areas in the licensee's faci-

lity, personnel not specified as requiring thyroid counts could

still be exposed to airborne radioiodine. The licensee stated

suitable air sampling was performed to identify airborne areas.

The licensee's SNM license also requires that a measurement of

thyroid burden will be performed on individuals exposed to 10

MPC-HRS or greater of airborne iodine. Continuous air monitoring

! is used throughout the facility to identify such an occurrence.

The inspector reviewed licensee continuous air monitoring results

for 1985 and did not identify any instances where personnel exposure i

j to 10 MPC-Hours or greater occurred.

5.3 Urine Bicassay Program

The licensee's SNM license requires annual urine analysis for all

! individuals working with open sources of radioactive material. The

licensee is currently performing two types of urine analysis: gross

, beta gamma counting and uranium analysis. At the time of this in-

spection the results of the 1984 urine analyses for uranium were not

available; the licensee indicated that these assays had been per-

l formed but the results were in the possession of a staff member on

l vacation. Licensee fulfillment of the bioassay requirement in their

! license will remain unresolved pending inspector review of the

! uranium analysis data (687/85-07-03).

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Licensee raw data for the beta gamma analysis of urine samples was

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available during this insoection but was not in a finished form

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suitable for review until the last day of this inspection. Compre-

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hensive review of the results of this analysis will be performed

during a subsequent inspection. (54/85-04-04,687/85-07-04).

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6.0 Technical Specification Surveillances

The licens c Reactor Technical Specifications require the following

surveillances and calibrations to be performed at the indicated

frequencies:

Surveillance Frequency

a) Excursion, stack and area annually

radiation monitor calibration

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b) Excursion, stack, and area monthly

radiation monitor channel test

I c) Excursion, stack, and area daily during reactor

radiation monitor channel check operation

and setpoint verification

d) Emergency exhaust system- annually

filter efficiency verification

e) Reactor pool water activity weekly

analysis

The inspector reviewed licensee compliance with the above requirements

by the following methods:

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discussion with supervisory personnel,

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review of licensee calibration and surveillance records, and

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review of applicable calibration and surveillance procedures.

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The inspector determined that the licensee is completing all surveillances

l required above with the exception of the monthly channel test on the stack

monitor. Failure to perform a monthly channel test to verify the stack

monitor operability constitutes an apparent violation of Technical Spe-

,

cification Section 4.4(2) (54/85-04-05)

1

The licensee indicated that the stack monitor (consisting of three sepa-

rate detectors for monitoring gas, particulates and iodine) had no built-

in source for performing a channel test and ennsequently this test had not

been performed since the inception of the Technical Specifications (dated

July,1984). The licensee indicated, however, that the stack monitor is

generally exposed to licensee generated radiation sources on the average

of several times per month. These sources include actual effluent passing

through the stack or large local radiation sources generated when a high

activity drum of waste is removed from a hot cell. The licensee felt that

! monitor response in these instances indicates monitor operability. The

! licensee stated that monitor response in such cases would be recorded on

j the monitor chart recorders and could be retrieved.

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The inspector indicated that the secondary use of radiation sources gene-

rated by normal operations to verify monitor operability does not meet the

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intent of the Technical Specifications, in that:

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1) such sources are randomly generated and do not constitute a formal

surveillance performed with the intent of determining monitor

operability, and

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2) stack monitor response has not historically been specifically

evaluated at the time of exposure to such sources.

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7.0 Exposure Controls

The inspector evaluated the licensee's program for providing radiological '

protection and exposure control for work being performed in the reactor /

hot lab facilities. The licensee has a specific Radiation Work Permit

system which is used to control work performed by contractors or workers

not normally assigned to radiation work. The work permit specifies HP

requirements and is valid only for a specific time limit.

Radiological work performed on a more frequent basis by in-house personnel

is controlled primarily by direct HP coverage. Work evolutions involving

, the potential for significant levels of contamination or dose rates are

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reviewed by HP supervision who then establish radiological controls.

i

The inspector noted that the radiological survey forms used for performing

l job-specific surveys contain check-off lists that indicate radiological

) controls implemented (respiratory protection, extremity TLD's, etc).

j Review of surveys, air sampling records, and the HP logbook indicated that

HP coverage was provided for all major work evolutions.

>

On August 23, 1985 the inspector toured the reactor and hot laboratory

l areas and observed two jobs in progress: operation of the I-125 loop in

the reactor and the pulling of a remote manipulator from hot cell #4 in

l the Hot Laboratory. .

Work on the I-125 loop in the Reactor building involved pumping noble gas

from the core to a shielded container in a glovebox outside the reactor

.

pool to allow for plateout of I-125. This operation can produce high

transient dose rates. The inspector discussed this operation with the

operators performing it and determined that:

a) personnel were aware of the radiological implications of their work, '

b) the operating procedure had appropriate hold points requiring

radiological surveys, and

c) appropriate surveys were being performed ar.d documented by the

operators.

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i The inspector also discussed radiological survey techniques and the

use of survey meters with the operators and verified the operators had

received appropriate training in this area.

l At approximately 10:00 a.m. on August 23, 1985 the inspector observed

licensee personnel pulling a contaminated remote manipulator unit out of

hot cell #4. One worker, wearing a respirator and a full set of protec-

tive clothing, was wiping down the manipulator as it was slowly pulled out

through the hot cell penetration. The inspector later reviewed survey

results and discussed the procedure with the involved HP technician and

determined that:

a) the worker wore extremity monitoring as required,

b) the HP technician providing coverage was familiar with the

i operation and associated radiological hazards,

c) appropriate ventilation was used, and

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d) air sampling and follow-up surveys were performed.

i The following concern was identified in association with the manipulator

pull operation:

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l The individual performing the manipulator wipedown was standing on a

j ladder and his head was consequently approximately 10 feet off the

l

floor. Air sampling for this operation was provided by a continuous air

monitor, located approximately 10 feet away with a filter intake height

of approximately 4-1/2 feet off the floor. The inspector stated that the

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air being sampled may not be representative of the air in the worker's

! breathing zone.

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The licensee indicated that the manipulator pull operation was a routine ,

one and consequently air flow patterns in the room and air sampling '

j methods had been previously evaluated. Portable air samples had been

i taken in the worker's breathing zone in previous instances and compared

! with samples taken using the continuous air monitor, and the licensee

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determined that the air monitor provided representative sampling.

] The inspector did not have the opportunity to review the licensee's

evaluation during the course of this inspection. This area will be

{ reviewed during a subsequent inspection (54/85-04-06, 687/85-07-05).

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8.0 Exit Interview

i

The inspector met with licensee personnel denoted in Section 1.0 at the

l conclusion of the inspection on August 23, 1985. The scope and findings

1 of the inspection were discussed at that time. At no time during this

l

inspection was writter, material provided to the licensee by the inspec-

tor.

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