ML20148D185

Ack Receipt of AEC Re Items of Noncompliance Cited in Insp Rept 50-201/72-03 on 720919-23 & 26-29. Corrective Actions:Operators Were Reprimanded for Actions & Proper Methods for Solution Transfers Were Reviewed

ML20148D185
Person / Time
Site:	West Valley Demonstration Project
Issue date:	01/26/1973
From:	Duckworth J EMVNFWV, NUCLEAR FUEL SERVICES, INC.
To:	Nelson P US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20148D021	List: ML20148D017 ML20148D053 ML20148D058 ML20148D105 ML20148D112 ML20148D119 ML20148D132 ML20148D139 ML20148D158 ML20148D166 ML20148D174 ML20148D179 ML20148D185 ML20148D192 ML20148D197
References
NUDOCS 8009150132
Download: ML20148D185 (2)

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966! car Fuel Services, Inc.f P.O. Box 124 % West Valley, New York-14171 F"

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Mr. Paul R. Nelson, Chic' E"r Radiological & Environmental Protection Section I'

US' Atomic. Energy Cornission E-Directorate of Regulatory Operations Region'I F:.

970. Broad Strcot Newark,' New Jersey'07102 ~

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Dear Mr. Nelson:

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LThis will acknowledge and. respond to your letter of. January 5, 1973, hi%

concerning three.ite=s'of apparent non-compliance discovered-during

!S the~ inspection conducted by Mr. Epstein'of your office on Septc=ber 19-23 W

and 26-29, 1972.

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.I.tems-1 and 3 I:.

L Itens 1 and 3 both appear io result from the procedures used in the vaste N'

disposal of certain cement blocks rcreved from the Off Gas Aisle.

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.procedurcs were as follows:

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The cecent blocks were surveyed during packaging with an open pT window survey =cter to determine' surface dose rates.

On the basis of these surveys ar.3 in consideration of the inherent s

characteristics of cement blocks, it was apparent that these O:

cement blocks would have signifiennt removable contamination

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5 levcis without the necessity of additional sect.r surveys.

h:yn The cement blocks were then packaged in plastic wrappings for p,

removal by truck to the burial grounds.

Apparently when the cceent blocks were raised.onto the truck for re= oval to the p

burial grounds,.the' lift forks cust have punctured the plastic wrappings..

the time, the puncture of the plastic wrappings "j

At went' unnoticed, and the truck carrying the cement blocks was dispatched to the burial grounds.

When the truck. carrying the cement blocks arrived at the burial grounds, the' waste burial monitor failed to recognize the existance of significant contamination levels of the cenent blocks and instructed an employee to unload the materini into

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a highilevel burial hole.

The employce backed the truch up to the hole,.renoved the plastic wrappings frc the ecmcat blocks, s.

and lowered each of thc= into the buri:1 hole. individually.

I is esticated thct the employce's total hanCldng rice on the cement 4

biccks arounted to five minutes.

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In view of the procedures outli~ned above, we complied with Technical im Specification 7.1.2 and Health and Safety Procedure S.2.5.4.in making all the surveys for radiation levels and removable contamination that would be required by those provisions under the circumstances.

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ally, we complied with-Technical Specification 4.13.3 in packaging the 55 cement-blocks in. plastic urappings, which, coincidentally, is the sama packaging caterial specified in Health and Safety Procedure 8.2.5.4.

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Nevertheless, in order to prevent any recurrence of the type of accident

@f that ultfr'*.ely did occur with respect to the waste burial.of cement blocks, the corrective action outlined in a letter f rom J. P. Duckworth to Lawrence D. Low, Director, Divisica of Compliance, United States p

pj Atomic Energy Commission, Washington, D.C.,

dated July 26, 1972

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(cc: J. P. O'Reilly), has already been undertaken.

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%Ya Item 2 appears to have resulted from the procedure used to transf er supernate from a disposal tank to storage lagoon #2 so that the filter media in such disposal tank could be changed.

This procedure was as 7

follows:

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An. operator cn the afternoon shift heran decanting the supernate from a disposal tank containing used filter media from the (p.

Anthracite Filter at the Low Level Waste Facility.

Since the water was originally f rom the restricted storage lagoon and was being returned to the same, the operatar reasoned a sample of

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the water uns not required.

This naterial was syphened into a i

ditch in the restricted area and returned into the facility's E

1. 2 storage lagoon, which is also in the restricted area and not

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covered by Technical Specification 5.1.1.

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Ac your letter indicates, the incident was repcrted and discussed with E

your office the following day.

A telephone call f rca your of fice a f ew hh days later indicated the incident was net reportable, and a report was not filed with your office.

In tha interest of further assuring that imnidents of this nature do not occur, the operaters involved were reprimacded f or their actions, and I

their super'~iser reviewed the proper methods for these solution trsasf ers with them.

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Should you have any further questions, we wruld be happy to discuss them with you.

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Very truly yours,

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Nucicar Fuel Services, Incorporated Docket No. 50-201 q;

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JAttention:

Mr. R. N. Miller'

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President-a=..;

6000 Executive' Boulevard Q

Rockville, Maryland 20852 MT

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References:

Your letter dated January 26, 1973 In response to our 1,etter dated January 5, 1973 at:;

Gentlemen:

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Thank'you'for your letter informing us~of the action you have.taken to f

i correct the items of noncompliance which we brought to your attention

.R following our recent inspection of your licensed program.

Your'correc -

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tive action will be verCfied during our next inspection of your program.

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g In accordance with Section 2.790 of the AEC's " Rules of Practice,"

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Part 2, Title.10, Code of Federal Regulations, a copy of this letter if and the enclosed inspection report w111 be placed in-the AEC's Public il Document Recm.

If this report centains rny information that'ycu.(cr.

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your contractors) believe to be proprietary, it is necessary that you

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-make a written application within 20 days to this office to withhold

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such information from public disclosure.

Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary, and should be prepared E

so that proprietary information identified in the application is I;)..

contained in a separate part of the document.

If we de not hear jj from you,in this regard within the specified period, the report will p

be placed in the Public Document Room.

N-E Your cooperation with us is appreciated.

Sincerely, J

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Paul R. Nelson, Chief, M

Radiological and Environmental y

Protection tranch d

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Enclosure:

M Inspection Report No. 50-201/72-03

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,j Muclear Fuel Services, Inc. 6000 Executive Boulevard. Suite 600. Rcckville, M.vy

,g n g (300 4P4-1 l14h l A Gubsidiary of Getty 01 Company i

Narch 12, 1973 Mr. Paul R. Neinon, Chief Radiologi' cal and Environmental Protection Branch Directorate of Regulatory Operations -

Region I U. S. Atomic Energy Commission.

970 Broad Street Newark, New Jersey 07102

Dear Mr. Nelson:

This is in response to your letter of February 5, 1973, which transmitted a copy of Inspection Report No. 50-201/72-03, hereinaf ter referred to as q

the " Report."

We request that the 2ntire Report he withheld ftam publication in the public document room.

The pertinent regulation that requires publication in the public document room' applies only to " final" dc.cuments.

10 C.F.R. 2.790(a).

The Report is not a final document and is not within the purview of the regulation.

On the contrary, the Report is more in the nature of an inLernal memorandum which serves to generate subsequent AF.C action and documents, such as notices of violations, responses thereto, (tc.

It in these subsequent documents that are final documents.

The regulation also includes a specific exemption from publication in the public document room for investigatory files compiled for law enforcement purposes.

10 C.F.R.

2. 790(a) (8).

The Report is part of the AEC's investi-gatory files complied for law enforcement purposes and would be within the scope of the foregoing exemption whether or ncet it is a final document.

The content of the Report illustrates that it is interim in nature, not a fir.a1 document, and that it is a typical part o f the. AEC's inves tigatory files compiled for law enforcement purposes.

This content includes vario"s e

matters which are presented in an extremely sensitive v8y.

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Some of these matters are not predicated upon cither follow-up or' the slightect' allegation of a violation of law, regulation, or safety practice.

One of these matter; appears to have been investigated and included in the i

Report only becausa.cf an anonymous letter while another is.not even the result of our activities and is not within the AEC's jurisdiction or related to.the pr oper exercise of its law enforcement dutics, although the Report clearly 1tplies; the contrary. One of these matters appears to have j

been investigated and' included in thc' Report only because we had furnished the AEC a prior informational letter with regard to our knowledge thereof 7

(publication of these types of matters in the public document-room might cause us to re-evaluate.our policy of voluntarily furnishing the AEC information' when not otherwise required by law to do so).

Undoubtedly, thesc matters constitute valuable information for future background or investigatory purposes and are properly a part of the AEC's investigatory files compiled in the normal course of business and retained as interna 1' memoranda; but these matters are not appropriate for publica-tion in the public document room.

Publication of these matters in the public document room would be prejudicial. to our bert interests if for no other reason than that publication alone implies our wrongdoing and involvement.

Finally, the Report contains a number of errors, certain miscalculations,

and miss tatements. We have addressed each of these below in discussing specific items in the Rtport. We presume that verified errors and miscaleu-lacions will be ccrrected without further ado.

We also hope that any mis-atatements will be as readily corrected; however, should any of these misstatements actually find their way into the public document room, we will be compelled to deny their accuracy and to rebut them by whatever means are availaole.

We now turn to a discussion of specific items in the Report to which we object, without withdrawing our request that the entire Report be withheld from publication in the public document room.

1.

It is indicated that no other AEC personnel accompanied the principal inspector during the inspections (cover page).

However, Mr. Kinney was also presett during-at least part of the inspections.

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Mr. Paul R. Nelson, Chief March 12, 1973 Page 3 2.

The origin of paragraph 17 of the Report in described as " licensee

' letter of September 12, 1972, to Directorate of Regulatory Operations, reporting external overexposure of nine contractor employees" (second page, under " Unusual occurrences," item G).

However, this is partially mislead-ing and partially in error.

First, it implies that'the occurrence resulted from our activities and is subject' to the jurisdiction of the AEC when, in

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fact, the occurrence resulted from a New York State licensee's activities, involved exposure to that ' licensee's radiation source, and is subject to the jurisdiction of New York State.and not the' AEC. ' The only reason that we furnished a letter concerning the occurrence to the AEC was that we happened to have significant knowle.dge thereof because. it occurred on our site while the New York State licensee was making radiographs of welds, and vc wished -

to volentarily. pass such information to the AEC out of courtesy.

The only.

possible-relatiot. ship the occurrence ever had with respect to our operations

.vas ' to : limit deployment of certain of-the contractor employees on our site -

during theLshort term' future.

Second, alth'ough nine contractor amployees were exposed to radiation.as a result of the New York S tate licensee's activities, only three such emp'oynes received an overexposure, i.e.,

an

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exposure exceeding the applicable State of New York regulations. Addi-tionally, we have made further comments concerning paragraph.17 of the Report as a whole below.

3.

The title of W. A. Oldham (third page, under " Management Interview")

chould be corrected to read " Manager, Engineering and Construction."

4.

The names and titics of various persons are wrong and should be corrected to read as follows:

(fourth page, under " Persons contacted,"

item 1):

T. K. Wenatrand Manager, Health and Safety D. Couhig

' Assistant Operations Manager R. T. Smokowski Contract Administrator and Secretary of the Safety Ceccittee J. P. Maier Health Physics Technician M. Jump Technical Services Manager P; Burns Process Engineer R. Hay Maintenance Manager r

E. J. Halas Blaw-Knon - Welder J. D. Jabinnsky, Jr.

Buffalo Electric - Electrician J. C. Van Ausdall Blaw-Knox - Welder D. C. Crockett Blaw-Knox - Welder Esacsone Q (s * @

i ca Mr. Paul' R. ' Nelson, Chie f '

March 12,1973-Page 4 J. F. ' Skrzypek '

Blaw-Knox - Welder Norris Nobles Blaw-Knox - Carpenter J. B. Hol t, J r.

Blaw-Knox - Pipefitter Foreman E. S. Ro ths child, M. ' D.

H. Benz Vice President, Benz Labor Agency G. W.. Mcdonald Plant Assistance Engineer-

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E. Birchler Plant Assistance Supervisor I Additionally, actually ' identifying the contractor employees by name raises.another problem.- They. are such a small, select group that subsequently setting forth details of their radiation exposure and medical

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treatment in paragraph 17 of the Report (although not specifically by name).would appear to constitute an unwarranted invasion of their privacy in violation of the spirit, if not the letter, of the exemption from pub-lication in. the public document room-provided for such information.

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10 C.T.R. 2.790(a)(7). We have made further comments concerning part oph 17 of-the Report as a whole below.

. tam 2, sentence 3 (unnumbered), should read 5.

Fourth page, i

" Licensee representatives stated that corrective action was achieved by rerouting the Condensate and Cooling Water to an interceptor."

6.

Fifth page, item 5, paragraph 2 (unnumbered), sentence 2 (unnumbered), should: read "The inspector made a confirming survey through-out the Process Building and adjacent areas."

7.

Sixth page, item 6 continued, sentence 1 (unnumbered) on that page, should read "Masal swabs are taken, accordin8 to records, after each zone entry and the swabs are routinely counted in a beta and alpha counter."

8.

Seventh page, item 8, paragraph 6 (unnembered), sentence 2 (unnumbered), should read "The inspector noted that the operation of these monitors are checked daily and that the results of checks are entered in a log maintained by the Health and Safety Department."

9.

Twelfth page, item 13, paragraph 2 (unnumbered) (throughout),

delete the word " underground."

page, sentence 4 (unnumbered), should ~ road "Using 1 x 10~gragraph on that 10.

Thirteenth page, item 14 continued, firs t full p uC1/mi the ihmit exFressed in Appendix B, Table I, 10 C F.R. 20 and an inhalation of 5 x 10*7 ml/40 hr. week, up to 500 nCi could have been inhaled before the 40 MPC hrs. Itmit would have been exce-ded."

(Note:

the chaage in sign of the second exponent).

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Mr. Paul R. Nelson, Chief March 12, 1973 Page 5:

-11.

Thirteenth page, item 14 continued, second full paragraph on that page, sentence 1 (unnumbered), should read "A nasal smear taken.on 7/7/72 showed un activity of - 5800 dpm, equivalent to 2.64 nC1."

(Note:

the change from microcuries to nanocuries).

12.

Lirteenta page, item 15, paragraph 2 (unnumbered), sentence 2 (unnumbere'd), should read "On 6/23/72 SWP No. 5034 uhich authorized the

' removal of. the cement bricks, showed dose rate measurements of 15 R/hr.

whole body exposure, 40 R/hr. skin of whole body exposure, and 250 R/hr.

extremity exposurc."

13.

Fourteenth page, item 15 continued (throughout), in every place "Ru-116" appears it should be changed to read Tu-106," and in every place "ZrNi or ZrN1-95" appears it should be chauged to read "ZrNb-95."

14.

Fourteenth page, item 15 continued, second full paragraph on that page,.centence 3 method with 7.74 x 10+junnumbered), should read "Using the licensee's c1 air /40 hr. work week instead of 5. x 10+7 ml air /40 hr. work week, an exposure of 72.5 MPC hours o'r 1.89 x MFC was obtained." (Note:

the change in the sign for both exponents).

15.

Fourteenth page, item 16, paragraph 1 (unnumbered), sentence 5 (unnumbered), should raad "The records also indicate an extremity and skin exposure, for 5.25 years, of 11.7 rem."

(Note:

the ' change from " rad" to " rem'.').

16 Fourteenth page, item 16 (general), sets forth details concerning an investigation undertaken in response to an anonymous letter (sce, the Report at page 2, item F) into the death of a former employee.

7 This employee was retired, was not on our premises at the time of his death, and did not die as ?ne result of an injury suffered or disease incurred while on our premises.

The employee's attending physician

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believed that the c=ployee was advanced in age (72), smoked to an excess, and ultimately died of a c>aligna cy unrelated to his prior employment with us (see, the Repcre at page 15).

The employee's radiation exposure never exceeded the 1.25 rem quarterly limit set farth in 10 C.F.R. 20 during the whole of his employment, and his entire urinalysis and whole body counting record during the whole of his employment is wfthout significence (see, the Report at pages 14 - 15).

Thus, we see no legitimate interest in includ-ing all these details in the Report JJ it is to be published in the public docu=ent room, i.e.,

no public interest whatsoever in their disclosure.

This a8ain proves the wisdcu of treating the Report as an internal memoran-dum and as part'of the AEC's investigatory files cocpiled for law l

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Mr. Paul R. Helson, Chief March 12, 1973-Page 6 i

enforcement' purposes, not subject-to publication in the public document Indeed, ~ the only reason that these details are in the Report appears room.

.to_be the existence of the aforementioned anonymous letter.

The death of I

employees and former employees who for all intents and purposes have died of natural causes unrelated to our activities are not routinely investigated, and we do not believe there is any intention to routinely investigate them in the future since we have numerous employees, all of whom must inescapably die for some reason at-some time in the future.

It seems very dangerous indeed to establish the precedent of publishing details of en employee's death in the public document room merely because of an anonymous letter which has proven demonstrably false or baseless.

We cannot - take ' solace in the fact that if this item is published in the j

public document room the details of the employee's death are exculpatory in nature.

On'the contrary, at present there is no_ connection or associa-tien between the ' employee's death and our activities.

Publication of this item in the public document room will sow the seed of suspicion or raise the question of a connection or. association between the employec's death and our activities for the very first time; and no matter how much the details are exculpatory in nature, some residue of suspicion or question 4111 remain.

Finally, this item contains the statement that " Licensee representatives, interviewed, all-sta t ad that no suit at law was pending from any interested party" (aeo, the Report at page 15).

We consider this st'are=ent very pre-judicial to our best interests and believe that there is no jurisdictional concern of the AEC involved and uno public right to know or be informed of such information.

17.

Fif teenth page, item 17 (general).

This item sets forth the details of an investigation into the exposure of certain contractor employees to an iridium source owned and being used by a New York State licensee to radiograph welds on our premises.

Since neither our activities nor our radiation sources were involved, and the occurrence was the sole result of the activities of the New York State licensee, tha. occurrence is subject to the jurisdiction of New York S tate authoritics, not the AEC.

Thus, details of the occurrence shculd not be in the Report and the Report should be limited in content to matters within'the jurisdiction of the AEC and related to the law enforcement duties of the AEC.

18.

Sixteenth page, item 17 continued, third full paragraph on that Page, sentence 2 (unne=bered).

One of the contractor employees is quoted as saying, "Look what that thing did to me."

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Mr. Paul R. Nelsou, Chief March 12, 1973 Page 7 c

We deny the accuracy of the foregoing quote.

P. K. Morrow Assistant Manager, Health and Safety, was present at all times during.the conversations between the. contractor employees and the AEC inspector and states that no contractor employee made the quoted statement or any s tatement similar in nature at any time.

i 19.

Sixteenth page, item 17 continued, third ful) pa ragraph On tha t page, l

sentoncei4 '(unnumbered) states tgat "The blistered area on each finger was noted to be approximately 0.2 cm." Our records indicate that the blisters were approximately 1,0 cm.

(Note: This would reduce the result of the calculations in Exhibit B in the Report by a factor of 5.)

20.

Sixteenth page, item 17 continued, fif th full paragraph en that page, sentence 2 (unnumbered), states that no one had previously informed the

. physician attending the contractor employees of the actual circumstances of the exposure at the time the physician was interviewed by the inspector.

We deny the accuracy of that s ta tement. According to both parties involved, t

T. K. Wenstrand, Manager, Health and Safety, informed the physician, a

E. S. Rothschild, of the circumstances of the exposure bcfore the physician ever made his initial examinations of these contractor employces on August 16, 1972.

21.

Sixteenth page, item 17 continued, fif th full paragraph on that page, sentence 4 (unnumbered) states "Af ter the employees Icf tv the physician expressed the opinion that the blisters could represent a possible radiation i

syndrome, and tha t ' further expert evalua tion was needed."

We deny the accuracy of that statement, According to the physician, he clearly informed the AEC inspector that it was his opinion that the contractor r

employec in all probability received the blisters in the routine performance of his work as a welder, i.e.,

in handling hot metal items.

22.

Seventeenth page, icem 17 continued, only paragraph on that page, sentence 2 (unnumbered), quotes one of our representatives (T, M, Wens trand.

Manager, Health and Safety) as saying the- 'He realized. that che exposure rate (cciculated for one of the contractor e,,loyees) was low but that he had no other sources of information to reft-to" and the Report s tates that 1-the inspector referred him to the Handbook or Health phvs tes, OSP-70, April, t

1963, page 158, which shown a dose rate por curie Ir-192 at 1 cm. distance of 5,000.R/hr.

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ale Mr. Paul R. Nelson, Chief F6rch 12, 1973 Page 8, We deny'the accuracy of that statement.

According to Mr. Wenstrand, he never made such a statement and was never referred to the foregoing text.

23.-

Seventeenth page, item 17 continued, only paragraph on that page, sentence 4 (unnumbered),- states that "The inspector calculated, using the same factor used by the licensee representative, a dose rate of.160 rads per second to the area of the finger involved." However, we do not believe

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that'the inspector's calculations used the same techniques or factors as our representative used.

Our reprecentative, Mr. Wenstrand, used knova data on the handling of radium needles corrected for curie quantities and the difference between exposure rates per curte as compared to the l

inspector's techniques seen in Exhibit B.

i 24.

Seventeenth page, item 17 continued, enly paragraph on that page, sentence 6 (unnumbered), states that "Ecployee No. 2 could have rcccived a j

calculated exposure to s limited portion of his finger during 30 seconds handling time of 4,800 ead.

However, in the first full -paragraph on page 16, the ' Report specifically states that " Reenactment [of the handling at the time i

of occurrence]11mited the handling time to 15 seconds." There appears to be an irreconcilable inconsistency within the Report.

25.

Eighteenth page (Exhibit A), entitled " Calculations." The second set of calculations contains certain errors and should read ar. follows:

trNb 3 x 10-8 uC;/mi x 7.74 x 10+7 ml = 2.32 uci or 2320 nci.

Ru-106 = 6 x 10~9 uC!/mi x 7.74 x 10+7 ml = 0.46 uci or 460 nci.

Sr-90 = 1 x 10~' uCi/ml x 7.74 x 10*7 ml =.0774 uCi or 77.4 nCi.

-12 Pu-239 - 2 x 10 uci/mi x-7.74 x 10+7 ml = 15.5 x 10-5 uCi or 0.155 nC1.

26.

Eigheeenth page (Exhibit A), entitled " Calculations." The third set of calculations contains certain errors and should read as fo11cus:

ZrNb-95 Ru-106 Sra90 +

Pu-239 i

611 + 544 nci 22 + 19.6 nCi 0.5 nci

.10 +.109 1155 nCi

+

41.6

+ 0.5 nC1 +

__0.209 2320 460 390 0.155

= 1.94 x 40 0.50

+

.09 0

1.94 x 40 = 77.5 MFC hrs.

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' Mr., Paul R. Nelson, Chief March 12, 1973 Page 9

'27.- Eighteenth page (Exhibit A), entitled " Calculations." In contrast with the' inspector's' calculations, our calculations are'shown below:

Zr-95~= (3 x 10~0 uCi/ml)(7.74 x -10+7 ml) = 2.32 uci = 2320 nCi Nb-95 = (1 x 10~ uC1/ml)(7. 74 x 10+7 ml)' = 7. 74 uC1. = 7740 nCi c

Ru-106 = (6 x 10~9 uCi/ml)(7.74 x 10+7 mi)..-- 0.46 uCi = 460 nCi Sr-90 --(1 x'10-9 uC1/ml) (7. 74 x.10+7 ml) = 0.0774 uCi = 77.4 nCi Pu-239 = (2 x 10-12 uC1/ml)(7.74 x 10+7 mi) = 15.5 x 10-5 uCi = 0.155 nci Zr and Nb are in equilibrium, so we assumed that there were equal amounts of each.

1155 578 nCi Zr-95 and 578 nCL'Nb-95

=

40 MPC hra. b S78 nCi Zr-95, 578 nCi Nb-95 41.6 nCi Rn-106 g 0.5 nCi Sr-90,

4 2320 nCi 7740 nC1 460 nCi 77.4 nCi

0. 209 nCi of Pu-239 O.155 nC1.

40 [. 0.25 + 0.075 + 0.09 + 0.006 + 1.35 3 MFC bra.

=

40 [ 1.77 ] '=

72 MPC hrs.

The forego!.ng constitutes our major arguments for withholding the entire Report from publication in the public document room and points out specific items in the Report of which we are. aware and to which we object.

Should you have any questions or need for further information, please advise, Ver t-ly yours,

/

Rooert N. Miller President RNM/byd 6t4C.LOSOt?f:: h b@

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DIRECTORATELOF~ REGULATORY;CPERATICSS S

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REGION I-

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'? ROilnspection Report No.:

. Docket No..:

(.s w i.( >

50-201/72-01

T'.:'::::,,

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-Licensee:

Nuclear ~ Fuel Services 'Inecroort.ted l License No.: CST 1 5N"

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• I p.o'. nox'124:

' Priority:

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l' Category:

'A-(1) -

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Location:

West Vallev, New Yerk 14171 i

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. Type of.Litensee:

Fuels ' Reorocessine-7q

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.j Type of. Inspection: Special - unannounced j'

2 1

Datds of Inspection: Scotember 19-23 6-26-29.~1972

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3 Dates of Previous Inspection: September 6. 1972 n..,.

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7:.7.

3 y-Princi al Inspector:

Wh4 N.YA_./

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P

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Eugene Ep Nein, Radi'acion Specialist Date j

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Accompanying Inspectors:

None

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'l Date

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Other Acccmpanying Personnel:

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- 4 U.'W..Ki.nney, Fuel Facilities Inspector-i.

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.Revicwed By:

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R. F../$mith, Acting-Senior, Fccilities ?.adio-.

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' logical Proccetion.Section

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_SlD0fARY OF FINDINGS' F

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.-Enforecment Action

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" A '. ' Violations M

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Solid radiocc ive waste not packed to preven: ' dispersion.,

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' (Report' Details,' Paragraph 15) g;_

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-1 analyzed'for activity.

2.

All batches of liquid cffluen:-not (Report. Details', Paragraph 13) o 3.

Violation of~ Procedures-(Report Dc: ails, Paragraph 15) g,.

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M' B.' Safcty Items:

10; w:

..1 None

' i kM l'.*; t i

I t em's ys Licensec Action:en Previously Identified Enforcement A.

' Item No. 4, Inclosure 1,'of li'censee le::cr dated April 7, 1972 to-J:7.

P~

Directorate of Regulatory Operations.

(Repor:~ Details,'?aragraph 2).

. - 3.

Item No. 5, Enclosure 1 of licences le::er da:cd ' April-17,1972 to td

Directo, rate of Regulatory Operations (Repor: Details,-Parcgraph 3)'

C.

Item No

~6, Enclocure 1, of' licensee le:ter dated April 7, 1972 3.e..

to Directorate of Regulatory Operations (Report Details, Paragraph P :i 4)

9. '

u D.

Item No. 1, Enclosurc 3, licensee ic:ter dated April 21, 1972'

~~

to Directorate of Regulatery Operations (Repor: De: ails, Paragraph p

~5) il u

E.

Item No. 2, Enclosure 3, licensee letter dated April 21, 1972 to M

L[ -

Directorate of Regulatory Operations (Report De:ctis, Paragraph 6)

p. < f F.

Item'No. 3, Enclosure 3, license-ter dated April 21, 1972 to e

i Direc: orate of Regulatory Operata;

-(Repor: Details, Paragraph 7)~

c e

G.

Iten-No. 4, Enclosure 3, licensee ic:ter da:cd April 21, 1972 to

' p 4

Directorate of Regulatory Operations.

-(Repor: Details, Paragraph 8)

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Item No. 5, Enclosure 3, licensu letter dated April 21, 1972 to

..B

" Directorate of Regulatory Operations.

(Report Details, P a rag rc.ph

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Item No. 6,' Enclosure 3, licensee letter dated Apri) 21, 1972 to Directorate of Regulatory Operations.

(Report Details, Paragraph

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10)

[.i.ai e-Desir:n Chances None f.?

r Unusual Occurrences r

' f;:

A.

Licensee letter dated June 21, 1972 to Directorate of Regulatory Operations reporting a liquid effluent release.

(Report Details, g

Paragraph 11) n.

B.

Licensee telephone call on Junc.16,1972 to Directorate of Regula-

[

tory Operations, Region I, report:,.ng a malfunction of a stack mon-itor.

(Report Details, Paragraph 12) i:

C.

Licensee telephone call on June 16, 1972 to Directorate of Regu-intory Operatiea.s, Region I, reporting a re] ease of licuid ef-fluent to ground surf ace run-of f.

(Report Details, Paragraph 13)

p....

1 D.

Licensee telephone call on July 12, 1972 to Directorate of Reguia-E b

t.ory Operations, Region !, reporting contamination transf erred to

'one employee's residence.

(Report Details, Paragraph 14)

[

i E.

Licensee letter dated July 26, 1972 to Directorate of Regulatory

[

Operations reporting an overexposure.

(Repor t Details, Paragraph 15)

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F.

Anonymous 1cteer dated September 3, 1972 to the AEC Directorate yp r

9 of Licensing.

(Report Details, Paragraph 16)

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Other Sic ni ficant 7indints t..

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t. :

A.

Currect Fd.ndinns The NFS plant is in shutdown cendition.

No fuel has been repro-cessed since January 1972 and no irradicted fuci has been repre-cessed since Sevember 1971.

Approximately 80 cmployces have been laid off.

Licensee representativcs stated that they use contract employees, f or a minimum of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> work.

These employces are ob-toined f rom local labor contractcrs and are used, according ta re-cords of ther,e contractors and statements of licensec repre-sentatives, to perf orm decontamination and replace hot cell h

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4 equipment.

These employces work until a whole body exposure of 2.

rem / calender que.rter has been receivad.

Contractor records indica-

?

ted a total of-516.such employees were used in 1972.

9 B.

Status of Previousiv Reoorted Unresolved Items e

None E..~:..-

Management Interviou A management interview was held September 29, 1972 with the following individuals:

(:;;

J. P. Duckworth, Plant Manager i

i B. E. Knight, Manager, Operations i

W.

4. Oldham, Mansgcr, Engineering and Construerion T. K. Wenstrand, Manager, Health and Safety i::

The following subjects were discus' sed:

}

A.

The current AEC' policy of providing the licensee uith a copy of the incpection report to define proprietary information prior to releast of the report to the Public Document Room.

i

r. :

3.

The proper packaging of radioactivo vaste and contaminated material particularly pointing oct the.t f ailure to properly package such m"

vaste had caused a reportab)e incident.

(Report Details, patagraph 15)

C.

'"he release of licuid effluent to ground water prior to anclysis

,1 M

. particularly pointing out that employees had failed to follow sta-ted procedures.

(Report Details, Paragraph 13) g

-E t-.

i D.

The failure to perform smear surveys of contaminated material prior

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to transfer.

(Report Details, Paragraph 15) ju b

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E 3;y C DETAILS

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Persons Contacted

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.Wenstrand, Manager, Ucalt'h and' Safety

' 1. ' T. ; K

' D. Couhig, Assistant ' Operations Manager

@:g G

R. T. Smokowski, Contract Administrator and Secretary of the Safety Committee J. P. Maier,'Ucalth Physics Technician M. Jump, Technical Services Panager P:

P. : Burns, Process. En;;ineer R. May, Maintenance Manager

[

H. Benz, Vice President, Bene Labor Agency i

C. W. Mcdonald,. Plant Assistar.cc Engineer

,~n J.. E. Birchler, Plant Assistance Supervisor E -

ib Current Status of Previous 1v Tdentified Enf orcement Items 1

f, 1

b:

4' 2.

Licensee representatives stated that they had identified the F:

source of surf ace run-off water as bcing the wake frem the Con-I-

densate and Cooling Tower.

Licensee representatives sts.ted that this cooling water gathers activity via small leaks in opera-g tional equipment.

Licensee representatives stated that correc-

..; 9; tive action was achieved by re-routing the Condensate and Ccoling Uater to an intercepter.

Surface stream activity which prior t.o

[.,'

the corrective action vag as high as 1.85 x 10-5 uCi/cc beta i

was lowered to

. 8 x 10-uCi/cc beta.

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3.

Licensee representatives stated that the Diesel Motor drir to li -

provide emergency power for the Head End Ventilation System uas

'f.

never installed.

They stated'that the propano gas motor, uhich

[:

was first evaluated in 1967 and submitted to DML and approved, it was installed.

Licensee personnel stated that a Diesel Motor requires several minutes to ccme to full power whereas a Propone Gas motor immediately gives full power.

7t

.The inspector inquired if other changes were evaluated to re-

~

flect whether a safety question existed.

Tic f ollowing proj ec t reports'were reviewed:

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LInstallation of a passport into the Process Mechanical Cell E;

l a.

b.

Addition of a tank to the Fuel Receiv1ng and Storcgc pool.

~

O The inspector noted that.in both of these additions a full s fet>

25 f!

' evaluation ~uns made as.$ndicated by examination of the Safety ly Committec Minutes.-

=##

in:e 3:

4 '. - The-inspector by examination of Safety Committee Minutes and ob-

.... sa servation, noted that the ddasel engine driving the electric 5"

generator was scrapped and e eriginally approved propanc gas E

motor electric generator

.stc13ed instead.

The minutes 2

of the Safety Committee indicated no unrevisucd safety matters.

~,,

y:.

5.

Licensee ' representatives reported that radiation levels within the plant and adjacent areas were due to the present ccid recov-ery system.

The inspector noted that a'new acid recovery system n

housed within a.sepcrato concretc chielded building was under cen-5-

struction.

Licensee representatives stated, that the plan was in b

a shutdown condition cad.had been for the past six cenths.

They reported that the present work program activity censists of new H

construction, decontamination and replacc=ent of. faulty equipment.

[

Records of surveys, which were reviewed, revealed that the opera-tion of the Head End Ventilation System caused a reduction in r ;

contamination, cir concentratiens cnd radiction levels within the

='

' Operations Building cnd adjacent areas.

The inspector mcdc a con-firming survey throughout the Process Building cnd adjacent Radiation levels inside the building were noted not arcas.

to exceed 1.0 mR/hr and were less than 0.2 mR/hr in any outside area FD within the fence restriction.

r.

The inspector also excmined film bcdge and TLD reports from De-cember 1971'to September 1, 1972 and noted that the avercge whole body exposure for permanent plant employees was 2.4 rem during

[:

the first six months of 1972.

Records also indicated thct addi-t:

tional contract help was obtained from local icbor cgencies.

per-sonnel monitoring records indicated that the average expcsure for these persens was 1.73 rem.

The average whole body exposure fo:

th.e first six months 1972 has decreased from that noted during a K.

similar period in 1971.

If -

y L

u.

6.

Licensee representatives stated that they have replaced the chest 5

L 4

counter with a shielded whole body counter.

He sented that all

,1 plant personnel are now routinely counted by the whole body counter

'I once yearly and at any other time there is reason to believe en uptaka has occurred.

The licensee representatives also sttted tha-therc~hcs been no case, within the plant itself, in 1972 vh:re thete i

' was excessi"e exposure to concentraticas of radionuclides ir air.

There was one case reported in 1972 where one persen was exposed i

to concentrations of radionuclides in cir at the vaste burial site.

3)P O #

W-D rd w u 3 Exumw R O, &

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..1 6-Nasal swabs are taken; cecordinr, to records, after cach cene entry c4_,

i i

the swabs are routinely counted in a beta and alpha counter.

If acti-ity is detected, urine analysis and whole body counting is perfecccd.

If alpha activity is detected, above a value of 3 dpm/ day in urin-alysis, fecal sampling is performed.

Records of these analyses were examined and no overexposure was revealed, except as stcted aoove, gil.;

i E:-

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Per cnent E:nlovees-

7. 3.=.

(.~..'.'l Licensee representat stated tha. all permanent c=ployees have

~~

rocciv ed formal cincs.. son training including use of films and

. training guides.

The curriculum vcs noted to include the subjects given and the examinations and grades chtained ucrc'obcerved in

, y listed in the licensee reply.

Formal uritten examinaticas werc I:

i

'.i formal roccrds, The exc.minatica covered types of radiatien sur' vcys, instrumentation, whct rec.dinp,s =cen, cetions to bc :nnen uhen instrument recdings are obtained, exposure 1 mits, vorking time L

Jlimitr special vork permit procedures, protective clothing, and cacrger.cy precedures.

Ques: 1cning by the incpecter, of three pe?-

n.anent czployees revealed thct they had received the training st.:

had taken uritten examinction: i= cdictcly following the lectures.

They also stated thst they periodically see tre.ining filus and re-i ccive,.1 ct n.rcs fica the Health Phy.ci es S taf f.

Contracter F.melovces u

.l.

i One Health Physics technician was noted to be permanently acsirned to contractor employees.

The inspector spoke te one con:ractor cmpicycc, who ctated that he had been at the SFE stte for six verrse i

Fe stated that he had' received training in rcdiation safety unen first caployed cnd pcriodic refresher trcining since then.

Two

[

,other contractor employces vorhing at the SPS site fer cac cnd two y1 years stated that they too had rec tived training.

Ecch cnc b

2 c;u cc t io n ed, kneu the exposure they could receive in any dcvs work, [

reperting rec;uirements, as util ac c=crgency t._;ica and evacuction

~

. procedures.

.t h.

_Tc=norarv E= _nlovecs

[.

The inspector verified by a visit to one 1cbor agency thc 516 m:ch cmployce: frpm thin ancacy were used at NPS in 3972, to dete.

..i e

.e labor Contractor reportCd that these people do nCC r e C r.ive f e rr?.1 training.

Licencee representativer. vernice this and stated '. S a t they ucrk enly under the direct surveillance of a hecith and scie:S technician.

A The licer.sce reprocentative stated that the:c personn 'rc instructe-i in the use pf proreceive cluthina

.d

. as and a]no recnive. r. q 4

tion in the.une 01. nelt. r eaa ;.:; cc:nnm c.r pencils nr.d wear t.:o uri p

i bb bk M

_ = ___

__ = ___

=_

7-s pencils, a lou range 0-200 mR, cnd a high range, 0- 1 P..

Licensec represents:1ves stated that these temporary employce: are used for exposure in any calendar quarter up to 2R, to the uhole body.

E=0 i&.

All ceployees whether temporary, contractor or permanent vere noced E?M to have signed Forms AEC-4 with all entries completed.

hims

=

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8.

_ Environmental Samuling EE5u b

The program for sampling air an'd water was described by the lican-5%

see representatives as follows:

a Section 3 of the licensce's Health and Saf ety Procedures Maauc1 dated 5/3/72 specifics the location and frequency for scmplin; of:

air cnd water; backgroun ' radiction measurements, deer, fallout, fish, food crops, milk, sil: from Buttermilk and Cat-p taraugus Creeks, and water from all sources of release were i

noted specified.

The inspector noted that the procedures specified the data sheets to be used and the method to record and calculate resul:s.

Thesc data cheets were examined and in no case were AEC or Technical L

Specification limits exceeded.

i Solid k'aste Control 6

Solid Waste Management Control was noted to be covered ccmpletely n

in Sections 8 and 10 of the licensce's Health and Scfe:y Precedurcs

[

a, Manual.

The Manual specifies the hcndling, packaging surveillance b

monitoring and control of both high icyc1 and low level solid.aste.

4i Adecuccy of In:ctnal Oualit:. Centrol Svstems to assura relicbfl{-;.

of Analytical procedures and snacificatiens for checking cnd cali-2.

bration of analytical instru=antation Section 10.2.2.1 - 10.111 Health Safc:y Procedures describes stack monitors,what readings mean, sc: points and calibrction of stack conitors to de:crmine particulate and gcscous release.

The inspec-I-

tor noted that the operation of these acnitors arc checked daily

,and tha

ht results of checks are en:cred in a log maintained by the shift supervisore Section 20.3.1 - 10.4 describes liquid check procecures anc ar.a-lytical procedures to check the presence of fission products in liquid.

Sections S.1 - 8.5 of the Health and Safety Procedures describes methods for taking all in-p3 ant samples, logs for results, instruments used,calibrationandanalyticalprocedurestode:craineconcentrc:ionsj}

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- of in-plant air concentrations.

These procedures are dated 4/10/72.

,[h

~R Trainine for Transients s'nd Visitors FM

=-

Transient workers and visitors according-to documentation are 2.7 i

never unescorted.- Licensac personnel stated that these persons receive instruction according to need.

Visitors were noted to 4:'M receive at the guard gate, a' dosimeter pen and required escort,

..s

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according to observations made by the inspector.

They also. pass

.~i;;

through hand and foot conitoring stations, one located at the 9

i

' plant cain entrance and one located at the guard reception shack.

3

~

They receive from the escort, instructions commensurate with the

' hazards in the area to be visited.

l n

i a

-l Reccrdine of date:

exoosures, versonnel monitoring, no t ifies tion s,i

_f bioassay, uhole body countint and corsarison of e::cesure determina:fcn D d.

m methods g

r -

E :

The licensec's Fealth and Safety Procedures prescribes precisely r

, how the information obtained' is to be recorded.

[.

~1 Environmental Samples of water were noted by the inspector to-have b'

been split betueen NFS, and two off-site contractors.

The resu'is

{g were aca11abic and examined by the inspector and shcwed that all j

three split sample results were within 20%.

Film badge and TLD kj systems were also compared anG found to be within close agr.eement.

i_j

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9.

~The licensee condue:ed a complete e=crgency evacuation drill on

(:

4/22/72 which was filmed.

The inspector reviewed the fil: and h :.1

.[ d noted the following:

Upon sounding the alarm, the plan was evac-uated.

Attendance of evacuee's was noted to be checked at the guard shack beyond the gate.

A :endance revealed, one person miss-ing, (a simulated casualty).

A rescue force properly suited and i

equipped with survey instrumentation en:cred the plant and located

{

o y

the person, removed him via s:retcher in:o a vehicle and transpor:ec hi= to Chaffcc Memorial Hospital in Springville.

The simula:cd casualty was wrapped in plastic to prevent spread of' contamination.

~4 a

Twelve doctors and the nurstag staff were in attendance and ucre u

briefed and instrue:cd as to how to handic and treat a radiation

.j casullty.

All biological sera was collected and tagged.

All no-4!

tifications to NY State, AEC, Police, and Fire authoritics were g

made.

2 Chapter 9 of the Safety Procedures Manual entitled F.mcrgency Pru-

?!"

.cedures was approved by :he Safe:y Com:1:cee on 4/5/72 and the Plant Manager on 4/6/72.

Section 3 also contained procedures fcr "d

' personnel at Chaf f ee Memorial Hospital.

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The plan was noted to contain' procedures for. monitoring surveyin;;

and decontamination.

A-rcsponsible person has been ~ designated to'-

g notify loutside agencies.

The plan places duty upon the Technical

'~

Serviccs Manager or in his cbsence o person designated by the Plant 7

. Manager.- The plan contains criteria for notification of outside E,

agencies.

The inspector:noted all alarms were sounded and tested cach Friday

[

precisely at 11:00 a.m. with loud speaker annou ccments of a test.

mua Records indicato evacuation. drills have been held at least fou.

times yearly.

m

=.

10.

Head'End Ventilation System (HEVS) a t

Records examined includet. minutes of the Safety Committee.

These

.i

_d records indicated a training program in filter removal was give.n

% fj to 16 people on 10/19 - 21/70.

The system was transferred by the

[.j $

vendor co the licensec on 10/25/70 cecording to records.

The com-a mittee minutes indicated that on 10/2/70 all TOP's (Tc=porary op-P-

er. ting Proceduree), were approved for operation of the Head End

.j Ventilation System.

These were later changed to 50P'a, Ros. 15-20 p'

and -21.

P A n ;,

Operating logs of the Chemical Cell indicate that all operators E

t l.

vorked with'the vendor in Joing over all pcrts of the ventilation l

.i

' system. A licensee representative stated that c formal training bJ program was given only 3 drys before the system was schedulcJ to Fi go into operation but insisted that this was a better method since EI i

the training received was fresh in the mens mind.

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n.

According to a written repori: dated 10/25/70, the HEVS uas accepted 4

without meeting design criteria as to air flow.

The report listed some 50 system checks, the identity of the person responsible fo.

cach check, and the date the checks were completed.

All checks l

were complete by'10/24/70 at 2300. tours.

The data obtained showed 5.. d that of 15 locations checked for air flow, 11 of the locations did j

not meet' design specifications.

Locations 11 cnd 12, the north and j

' south glove aisic in the filter chcnge room designed for 100 cm had fj an airflow of 7 CFM.

y

1 1

Licensec representatives stated that the deficiencies were corrected

,_j

~

by installing larger becrings and increased fan speeds.

Airflow 0d study reports which were reviewed, show that the design goal, nc; -

...N tive pressure with respect to opercting cells, vcs obtainct.

On 11/6/70, a work report to the safety committee stated that in the f;

1 glove port aisics of the filter change room, the gloves were re-moved to obtain higher air flow cad pressure diff erentisl.

The 3

report showed the radiation icvois were below that required for j.a ]

Zonc'III entries.

The Safety Committec minutes also show the re-Ea quirement, th t the gloves be replaced prior to any filter ch:nges d

and that those persons performina this operation wear air supplied g=j masks.

l 0

g r]

cm o

n J-6tMtA40R.E R 60 09 k jy

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e

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4

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Licensee representatives stated that the spray system was no:

y tested prior to' turnover.

The representatives stated that the gig...

~

duct spray system was'in1 tic 11y availabic but locked'out of f]

the line at the time of' turnover uith all water supply valves M=='

closed.

The apray system was checked out at a later date and.

1. EF j

found to ncet design specifications.

E. :

i;;::.::.

Licensee representatives sta'ted that the general DOP test pro-

~ ~ 1,:.s

.cedure_availcble at the time for testing filters required no

+

special procedurc to : cst the filters in the HEV system.

Records-

"Y

, of. tests showed :that they were performed on.10/21/70 showi.;g 99.98% cfficiency for the^ filters.

Another DOP test was pc.rformed

[.}

on 5/7/71 showin; 99.98% efficiency.

The licensco's procedures

.-i?

k for. D0? testing of filters arc 'contcined in Chapter 10.2.4 of the health and Saf ety Procedures Manual dat ;d 3/19/69.

Licensee rep-

[

resentatives stated that these procedures were followed.

{.,

m Llw Licensee representatives stated that original. drawings of the EEV f

cysten ucre approved.cn 6/16/67.

Revision 1 was approved 10/3C/

67.

Revision 2 was approved 11/17/67 "As buil:" drauings'ucre P

approved 6/22/70 and final drawings vera assembled and submitted to the Plant Mcnager'on 12/2/70.

p pu.w Low Level Waste Treatment Facility (LLWT)

t. v:

t' n Training records =aintained by Operctions showed that all operators 9

,had received training in the opert non of the LL'4T on 4/20 and g

21/71, approximately one month prior to turning over the f acility y

to the licensee.

Tcaporary operating procedures - TOP-02 and 04 p.

1 were approved by the scfcry committee on 5/21/71, according':e :he 1

Safety Committee minutes.

The entirc system was checked ou: uith x6 non-radioactive water en 4/15, 17 and 20/71 prier to opera:iens.

}

All checks were compic:cd by 5/10/71.

DOP rests of Filters were perf ormed on' 5/7/71 cnd found to be 99.98% efficient..

Licensee persennel stated tha: the LUC facility did no: rect de-sign cr.pectation of louering Sr-90 concentrations to the extent

' anticipated.

However, research is being continued with different ion exchange media which appccrs to have promise.

The LUC does, f

how'ever, reduce other fission produe: concentrations in Cst:cr-f.'

augus Creek by a fcetor of 100.

The records,ciso show that Sr-90

(

concentrations exist in the order of 3 X 10-o uCi/a1 water fter

=

operation of the system.

This is still belcw 10 CFR 20 Ap-

y::.

pendix B, Table II levcis et 3 X 10-/ uCi/ml.

The inspector noted thc the licensee has modified the LL'4T sys-tem to increacc its efficiency and operation by institution of

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E steady inflow rates and ph adjustment.

Full sets of plans were noted to have been available prior to operation of the system.

@ll=G 11.

Unusual Occurrences

--sa -

A review of the licensce's "haalth Physics !

g" revealed tha: jet

'55

1. 4C-7 wc accidently left oren on May 25. ;>72, causing an esti-mated release of 2.02 mei bcca activity.

The log revealed that v:..

prior to the incident a decontaminating solution had been run

q.,

through this particular jet.

The los revealed tha: the operator Ii=

on the morning of May 26, 1972 noticed that the liquid Icvc1 on hll Tank 6 4D-8 was increasing and thct solution ucs leaking out of the ratio-relay on the 4C-7 pressure pot.

The cperator closed the valve and notified the Health and Safety Division and his shift p

supervisor.

p F -

S

,t The log' indicated that the Upper Extrac: dun Aisle hcd a puddle h _

of water on the floor due to c total leakage of 1 1/2 - 2 gcllons acid-wa ter mi:: ure and tha t this area was isolated and surveyed.

Surveys were performed with an Eberline PAC-4 and sho. ed rczdings of 7000 cp: alpha on the liquid cnd the surrounding floor are 50,000 epa alpha.

Air concentrations of room air samplers in con-I tinueus operation v'erc noted to be 8.4 X 10-13 uCi/mi, alpha cnd F.

3.0 X 10-12 uCi/ml, beta.

I After several decontamination efforts, :he contcmination was re '

duced to 45 dp: alph.a/100 cm2 on 5/30/72.

The activity in the E

puddle was identified as Pu-239.

31ocssay records, which vere reviewed, indica:cd tha: those involved in operations and in the decontcmina: ion effort were counted by a whole body counter en 1

6/9/71 and no alpha activity uas found.

The cause of the inci-b33 dent was determined by licensee representatives as due to a con-

.Il.

trol room operator telling a workman to close the 4-C-7 jet.

The y

workman stated that he did no: hear the operator cnd lef: the jet open.

Corrective action, according to licensec representatives, uas the issuance of an SOP requiring tha; all valving cpers: ions q[

be performed by the control room o~perator.

The 50?, which wcs re-viewed by the inspector, also specified that this duty canne: be delegated.

r:

i.-

12.

Records of the Heath Physics log ucre examined and revealed that on June 15, 1972 operctors in the Upper Extraction Aisic (UXA) had been preparing c permangcncte solution to be used in g;.g decontcmination.

The record indicated that during the solu:ica preparation, some solution splashed onto the walls of the U:.A aisle and the operators cleaned and removed the per cngana:a with

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'opious cmounts of water.

Some of the va cr spicshed on:o the c

e-m

t 8.,

' s,;.l:. s s

1 ?

I W,

.i

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clectronics portion of the continuous stack monitor, shorting out the' system, which caused full scale readine,s.

An air sampler fil-

[

l

'I ter paper mounted at t.hc 00. f oot )cvel of the ntack van in acdiately

[ll pulled and counted.

Ac tivitv released uns determined to have nipha M

i relcace rate and correspond to 2.05 X lo->,are 2.

^

l i

icnn of 1.15 X 10-12 uCi/nl and beta concentrations accre concentrapd 1.5 x 10-uci/ml.

These concentrations 7% of the allowabic

....m

'i.

uci/sec alpha and 2.6S m.

~j X 10-3 uCi/sec, beta,andVerewithintechnicalspecificationlimits.l?

i=s

.l o

2;

. 13.. Licensce reprcscntatives stater that they change the anthiacito f11-

)

ter media of their lou level uaste treatment fccility (bL'lI) at per p

~)

iodic intervo]s.

The procedure requires flushing the filter nedia a

from the LLWT into two-1000 gallon burial tanks.

The anthracite i

.: 3 filter media settics to the bottom and the'cupernatent 1iquid is to i

he ciphaned off into a drain which leads to Storage Lagoon #2 in; il m

P i

acco.rdance with 50P-15-1, Plant Liquid Releases.

r!

g at 23:30 hours I

A revicu of the "licalth Physics Log", revealed that p

l on 6/15/70, an operator, apparently decided th:

the siphoning ac-

~

tion f rem the tank to the drain vac proceeding too slouly.

He in-scrted a second siphon pump but the non:le enc of the duct could not f it into the drain se the supernaten liqvid, pulled from the tank py the cecend siphon, uas a11 cued to flou alon; the ground L

ij surface.

At 03:00 hours on 6/16/72, the vater was acted to be

+

running onto the ground.

3 L

4lj The uator remaining in the hose line was sat.. pled on the morr.ing np ti of 6/16/72 by the Health Physicc Croup and beta activity of 8.9 h

{

X 10-4 uC1/ml uns r.o ted.

An esti.ated 600 gallens had be:n re-

'l leased to the greund surface.

A total of 2.02 mei mixed beta ac-

[

tivity uns released.

Lican;ce representatives stated th: t the i

soil, where activity ucs noted to exist because of the relcese, t

j.

vas removed, poched in.' acte drums, and buried in the ASDA burial b

/

site.

The ground had acasured radice.ctivity icvels of 50 mP/hr at j

s q

the surfacc.

Licensec reprenentati-cc s tated that the liquid ci-jp phoned of f the charcoal contained activity due to being in contact with contaminated equipment.

5 i'

14.

The incident report revealed that the subject involved uns a la-N bo'rcr vorhing at the vaste burial cite.

The subject, by eclf "f

monitoring at 16: 45 hours5.208333e-4 days <br />0.0125 hours <br />7.440476e-5 weeks <br />1.71225e-5 months <br /> en July 7, 1972, diceovered conr.cmina-

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Li-

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tion on his person and ircmediately notified hin supervinor.

consce reprcuentatives stated that a Health Phycies t echr. ic i a r.

l immediately reported to the cite, r.nd using an Eberline GM cnd windou probe, reported 3000 cpm on the subj ecto jacket, 6000 cpm, on his r.hirt and on bis forehead 1000 - 2000 cp:.

I, j,

on the eveninn of July 7,1972 a victt van made to the subjen:.s home at Scranton, S.Y.

by a tech:,ician from the itcal th Phynics

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' 55

=7 Group,.and a survey with a GM ~ revealed contamination existing on

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a pillowcase, washcloth, sliec t and j acket in the order of 250 -

W

3000 cpm.

.(

A tovel had activity of 25,000 cpm.

..s s

=::- ;

Urinalysis samples provided by the subject en.7/7/72 revealed in

[pf(jjf two samplings,11 and 14 dpm/24 hours void of fission uroducts',

p;j:1 Cs-134, - 2 3 7.

A. chest count. performed July 10, 1972 revealed if the presence of 32 nCi Cs-137.

With this cuantity representing 12.5% of whn was inhaled, then 256 nci could have been inhaled.

9:

Using 1 x 10'Y' uCi/ml the limit expressed in Aupendix 3,-Table

~

f.l.

7 I, 10'CFR 20 and an. inhalation of 5 x 10 ml/40 hr week, 500 nCi could have been inhaled 'to equal an exposure to 40 M?C hours.

p g

.. m L A nasal sacar taken on 7/7/72 showed an ac:ivity of 5800 dpm, y,

equivalent to 2.64 nC1.

Investigation by licensee ocrsonnel

[6%

.) _

revealed the contamination occurred on July 6,1972, when the 1aborer was oiling the lif t crane in the. waste burial area.

{

Licensee personnel stated that procedures have been set forth t-whereby head covers would be worn in addition to other yrotective h

clothing.

h n.

15.

Licensec representati'ves stated that on 6/26/72 at 13:00 hours, h

cement blocks, which had been used in the of f gas aisle - (CGA),

j vere removed for burial.

Examination of the Health Physics log b

indicated that the cement blocks were wrapped in plastic and L

5 brought to the roof of the OCA uhere they were transferred frca

[=

the roof to a " Red Stake Truck".

A health physics technician E

measured the dose rates and no cd radiation icvels of 52/hr. frca h

the cement blocks.

He stated and the records indicated that no D

,=

contamination surveys were made.

Licensec representatives sta:cd

~

that no person noted or repaired the torn plastic vrapoings.

Li-consee representatives stated that the cement blocks were grossly

~

contaminated and had been used to shield an acid recov.s.ry line in the OCA, They stated that the removal of the cement blocks was part of the currant program to reduce radiation icvels and contamination in production areas.

,The person became exposed, for a period of approximately 5 minutes, while unicading manually, the cement blocks f rc= the P.ed Stake Truck.

On 6/23/72 SWP No. 5034 which authorized the rc= oval of the cement bricks, shoued dose ra:e measurements of 15 R/hr.. vnn e i

body exposure, 40 R/hr. skin of whole body exposure, and 250 R/hr.

5 extremity exposure.

During the 5 minutes unloading time a self-rcr. ding dosimeter showed a reading of 100 mR.

The person en:2csed follow' ed the proper procedure by passing through a monitoring station r

mm o

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at 16:30 and the monitor alarned.

The perscn notified his suncr-3ll@

visor, who in turn notified the Health and Lafety Group,.ehich immediately' responded to the. scene.

A Healch Physics Technician

=#

=

imediately obtained a nasal swab which showed activity of 130

GE; dpm alpha and 170,000 dam beta

ecual to 77 nCi beta ' activity' fif.f i

The nasal swab was analyzed chemically and' showed Ru-106 - 19.6 c

. nCi, Sr 0.24 nCi, Pu-0.109 nC1, Zr-Nb-544 nC1.

Ratio studies gjjid

. crc:

ZrNb-95 544 = 27.7 T2 w

Ru-106 19.6

==

3_.

l Z rFb'-95 544 = 2305 ZrNb 95 544. = -.5000

- fg

. Sr-90

.236 Pu-239

.109 if. :i p

u-The person was decontaminated and also had nasal flushes performed.

Pi He was 'immediaccly whole body counted and the results of-this : count and aucceedint, whole body counts are shewn in the licensec 's letter n

of-July 26, 1972.

The licensee calculated that the subject was ex-p' posed to 7' MPC hours uf combined concentrations of Pu-239, Ru-106 and' ZrNbo-95 or 1.77 x 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> MPC as stated in Appendix 3, Table I,

~

10 CTR 20.

A review was made of the mqthods used for evaluating the exposure'and it was'noted that the evaluation was proper.

9 9

m' The li:cchsee stated that the surveys of the blochs prior to trans-m fqr consisted only of direct ree.diation measurements.

The recetds

[

indicated that no survey was made to determine contamination icvels, i.

Licensee representatives stated that the cement blocks were being

'P for solid waste burial and were not packagcd to prevent sent

[

con-tamination of handlers.

The laborer, involved, was stated to be t.

a handler.

Proper packaging, according to the licensee represen-

[( g tatives would include plastic covering over the cement blochs E.. '

themselves plus a plywood container.

The licensee representatives

[9 stated that n,o plywood container was provided for the ccment block F

burial.

L V:.%

16.

The items of concern described in the anenymous Iceter were re-viewed in depth and no radiological problems were observed.

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