ML20133M897
| 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: |
| 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
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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
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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/
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[date
A.Weadock,Radat' ion /pecialist
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. /O 21YS
J.McFadden,Raiation/pecialist
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Approved by: M. ,
sfu
H. Shanbaky', Chief, PW7
' / date'
Radiological Protec1rion Section, DRSS
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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.
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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:
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,
Exposure Controls.
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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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major portion of the body could receive in any one hour a dose in
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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
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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
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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.
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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
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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
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loose contamination was found on the armatures.
The two arma-
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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.
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During a tour of the upper floor of the hot laboratory facility
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
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surveys are performed by the Health Physics Staff for the Reactor /
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Hot Laboratory facilities.
In addition, special surveys are per-
formed as required for evaluating radiological hazards associated
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with specific work activities.
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Adequacy of the licensee's survey program was assessed by the
following methods:
independent radiological measurements performed by the inspector,
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review of selected surveys for 1984 and 1985,
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
surveys in the reactor building was discussed with the licensee
(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
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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
individuals responsible for " processing and dispensing" iodine had
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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.
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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
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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
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to 10 MPC-Hours or greater occurred.
5.3 Urine Bicassay Program
The licensee's SNM license requires annual urine analysis for all
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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-
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spection the results of the 1984 urine analyses for uranium were not
available; the licensee indicated that these assays had been per-
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formed but the results were in the possession of a staff member on
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vacation.
Licensee fulfillment of the bioassay requirement in their
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license will remain unresolved pending inspector review of the
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uranium analysis data (687/85-07-03).
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Licensee raw data for the beta gamma analysis of urine samples was
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
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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:
discussion with supervisory personnel,
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review of licensee calibration and surveillance records, and
review of applicable calibration and surveillance procedures.
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The inspector determined that the licensee is completing all surveillances
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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-
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cification Section 4.4(2) (54/85-04-05)
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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
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monitor response in these instances indicates monitor operability.
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licensee stated that monitor response in such cases would be recorded on
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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
intent of the Technical Specifications, in that:
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1)
such sources are randomly generated and do not constitute a formal
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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
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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.
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The inspector noted that the radiological survey forms used for performing
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job-specific surveys contain check-off lists that indicate radiological
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controls implemented (respiratory protection, extremity TLD's, etc).
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Review of surveys, air sampling records, and the HP logbook indicated that
HP coverage was provided for all major work evolutions.
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On August 23, 1985 the inspector toured the reactor and hot laboratory
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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
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the Hot Laboratory.
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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
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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,
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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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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.
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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
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operation and associated radiological hazards,
c)
appropriate ventilation was used, and
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d)
air sampling and follow-up surveys were performed.
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The following concern was identified in association with the manipulator
pull operation:
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The individual performing the manipulator wipedown was standing on a
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ladder and his head was consequently approximately 10 feet off the
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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
air being sampled may not be representative of the air in the worker's
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breathing zone.
The licensee indicated that the manipulator pull operation was a routine
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one and consequently air flow patterns in the room and air sampling
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methods had been previously evaluated.
Portable air samples had been
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taken in the worker's breathing zone in previous instances and compared
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with samples taken using the continuous air monitor, and the licensee
determined that the air monitor provided representative sampling.
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The inspector did not have the opportunity to review the licensee's
evaluation during the course of this inspection.
This area will be
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reviewed during a subsequent inspection (54/85-04-06, 687/85-07-05).
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8.0 Exit Interview
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The inspector met with licensee personnel denoted in Section 1.0 at the
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conclusion of the inspection on August 23, 1985.
The scope and findings
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of the inspection were discussed at that time. At no time during this
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inspection was writter, material provided to the licensee by the inspec-
tor.
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