ML20153D119

Radiological Controls Insp Rept 70-0687/88-02 on 880317-18. Violations Noted.Major Areas Inspected:Licensee Evaluations & Corrective Actions Associated W/Individual Leaving Facility on 880303 W/Contaminated Personal Items

ML20153D119
Person / Time
Site:	07000687
Issue date:	04/22/1988
From:	Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20153D084	List: ML20153D078 ML20153D101 ML20153D119
References
70-0687-88-02, 70-687-88-2, NUDOCS 8805090066
Download: ML20153D119 (12)

Text

n ,

-)

l y-U.S. NUCLEAR REGULATORY COMMISSION REGION I F.eport No. 70-687/88-02 Docket No.70-687 L! cense No. SNM-639 Licensee: Cintichem, Inc.

P.O. Box 324

- Tuxedo, New York 10957 Facility Name: Hot Laboraton Inspection At: luxedo, New York Ins;.ection Conducted: March 17 - 18, 1988 Inspectors: b k. WA f c2/!M b _R . . Nimitz, Senior Radiation Specialist ' date Approved by: gg 3_ L 2As M. M. Shanbaky,'n C' i eY'f

, (In

date

/f/(

Facilities Radiation Protection Section Inspection Sumvary: Inspection conducted on March 17 - 18, 1988 (Report No.

70-687/88-02 Ap as Inspected: Special, unannounced radiological controls inspection of the circumstances, licensee evaluations and licensee corrective actions associated with an individual leaving the facility with contaminated personal items on March 3, 1988.

Re sul_t s : Two apparent violations were identified. (Failure to provide adequate worker training; Section 6 and failure to make airborne radioactivity surveys; Section 8).

,r g ,? p ,

- v-2 <

800%90066 Of 30429 PDR ADOCK 07000487 C y;n

jh J,'

OETAILS 1.0 Individuals Contacted

• J. McGovern, Plant Manager

• T. 'laughn, Manager, Health, Safety and Environment

• L. Thelin, Staff Hedth Physicist

• J. Stewart, Health Physics Supervisor

• W. Ruzicka, Manager, Nuclear Operatiens S. Decker, Senior Reactor Operator F. Morris, Manager, Engirseering and Technology Sales L. Cabati no, Senior Radiophysicist, State of New York

, A. Chibbaro, Associate Radiophysicist, State of New York "Denotes those individuals attending the exit meeting on March 18, 1988.

The inypector also contacted other licensee persorrel.

2.0 Purpose and Scope

of Inspection This was a special, unanrounced ir,spection of the circumstancos, licensee evaluations and corrective actions assorfated with on indiviaval leaving the licensee's facility on March 3, 1988 with contaminated personal items.

The individual's attire was found to be contaminated upon arrival at the West Valley Demonstration Project, West Valley, New York on March 9,

.988.

The individual was contacted by the inspector via a March 22, 1988 telephone discussion.

3.0 Bcckground and Description of Event

3.1 Background

Due to visibility problems, the licensee decided to replace a shielded viewing window located in Hot Cell No. 1 of Building 2.

This was the first window change since initial facility operations

(~25 years). Replacement involved entering Hot Cell No. 1, pulling the windor into the cell, removing the old window from the cell for disassembly and shipment and installation of a new windos into the location of the original window.

During replacement, efforts were made to maintain the cell under negative air pressure to preclude airborne radioactivity problems inside the general work areas of the facility.

The licensee used a contultant, provided by the new shield w few vendor, to provide guidan:e for the window replacement.

s 3

The licensee held several planning meetings to outline the schedule ar.d work scope of the replacement. Procedures for the replacement wora provided by the window vendor and were used by the licensee.

(Details, Saction 9.0).

s 3.2 Description o_f_Evpnts At about noon o', March 9, 1988, licensee representatives were notified by telEftone by personnal at the West Vaiiey Demonstration Project. West Valley, New York that an individual who had recently worked at the Cintichem Facility had alarmed portal monitors while attempting to enter the West Valley Project.

The individual, a contractor, hac worked at the Cintichem Facility as a consultant during the period February 26 - March 3, 1938 and had not )>en involved in any radiological work at any othee facility since arriving at the West Valley Project on March 9, 1988.

Personnel at Wes; Valley performed contamination surveys of the individual and his attire. Survey results indicated contamination of shoes and a jacket. The shoes and jacket were held by the Radiclogical Controls Group. A whole body count of the individual was performed by West Valley personntl. No uptake of radioactive material was identified. The personnel contamination survey and whole body count resuits were provided to Cintichem Inc.

The NRC was notified of this matter by West Valley Project representatives via a March 10, 1938 telephone call.

Specifics The individual arrived at the licensee's Cintichem facility on February 26, 1988.

• Because it was believed the individual possessed a substantial amount of experience working in radiological controlled areas, the individual was not required to attend a full length licensee radiation protection training session prior to working. The individual was provided a 45 minute briefing on radiaticn pro-tection matters by a health physics technician on February 26, 1988. The individual also rer.d and signed a document which outlined the risks he would be taking and the actions the licensee would take to keep his exposure as low as reasonably achievable ( ALARA).

The individuai toured the work area to view the window on Februa ry 26, 1988. The individual did not enter any contaminated areas that day. The individual used a hand and foot monitor when exiting the facility.

m _ m l

4

• The removal of the old shielded viewing window and installation of the new viewing window was performed on February 27, 1938.

• The individual did not enter Hot Cell No.1 during removal of the viewing window. During the operation, the individual wore a lab coat, shoecovers and gloves and remained in relatively low contamination areas outside the cell the majority of the time.

• The individual entered a high contemination area (estimated to e be > 1 x 10' dpm/100 cm 2 ) located outside the cell during one portion of the operation on February 27, 1988.

• Prior to exiting the facility at about 8:00 p.m. on February 27, 1988, the individual used the hand and foot monitor at the main access of Building 2. No contamination was identified.

• The individual did not enter the facility on February 28, 1988.

• On February 29, the individual was involved in advising licensee personnel on how to disassemble and package for shipmert the old viewing window. The individual worked above Hot Cell No. 4 in a postec contaminated area in a lab coat, shoecovers and gleves.

• While leaving the facility at about 4:00 p.n. on February 29, 1988, the individual alarmed the hand and foot monitor. The individual's right hand was fcund contaminated and was subsequently decontaminatej. A whole body frisk was not perfo"med. After decontamination of the hand, the individual used the hand and foot monitor, and it did not alarn,. The individual was released.

• On March 1 and 2, 1988, the individual continued to advise licensee personnel on methods to disassemble and package the old viewing window. The individual used the hand and foot monitor prior to going to lunch and leaving each day. No whole body frisks were performed. The hand and foot monitor did not alarm. The individual left at about 4:00 p.m. each day.

• On March 3, 1983, the individual discussed maintenance of the new viewing window onsite. The individual entered the operating area in front of the cell. No contaminated areas were entered. The individual performed a hand and foot frisk using the hard and foot monitor prior to leaving at about 12:00 noon.

No contamination was found. The individual permanently left the facility.

• The individual arrived at the West Valley Project on March 9, 1988 and alarmed a portal monitor wnile attempting to enter the facility. Contamination monitoring by West Valley

- . .z 1 .

-\. q N .

o .

5 personnel indicated up to 200,000 divin.tegration per minute (dpm) on the upper left shoe, 20,000 dpm.on-the uppe'r.right shoe, and about 1200 dpm on the cuffs of a coat worn by the individual.

The contamination was removable.

o The individual's coat and shoes were confiscated by West Valley personnel.

West Valley Demonstration Project personnel contacted the licensee on March 9, 1988.

• An evaluation was performed by the licensee to estirate the Because the shoes and potential for offsite contamination.

coat were kept in a poly bag after departure from the licensee's facility no potential offsite contamination was

~

identified.

4.0 Notification and Reports The inspector reviewed licensee notifications and reports following the identification of the event. The review was with respect to criteria contained in applicable regulatory requirements.

Findings <

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

5.0 Contamination Control

'The inspector reviewed the adequacy and effectiveness of licensee contamination control practices. The review was with respect to criteria contained in applicable licensee procedures and license requirements.

Evaluation of licensee performance in this area was based on: discussions with cognizant personnel; review of contamination surseys, radiation work permits and other documentation; review of contamin: tion monitoring  :

equipment; and discussions with the contractor individual who was identified as contaminated.

_ Findings Within the scope of this review, no violations were identified. However, at the time of the inct. dent, the licensee's administrative controls for contamination control, procedure quality and implementation and equipment for personnel contamination control and monitoring was considered of marginal quality and in need of improvements.

f

.-~ - ,-_.._ _ __.. _ . ~- . . _ . _ . - . . _ . _ _ , . - , . . . , - - . _ _ . - - _ _ - _ . . _ , . - . _ . _ - . . - . -. _ - , . _ .

1 6

The following matters were identified:

• The operational radiation protection procedures for contamination control (unn' umbered instructions) were_ confusing particularly for use of step-off pads. Also instructions for using a second clean contamination control step-off pad were not implemented. Procedure guidance for performance of a whole body frisk while standing on the second step-off-pad (non-used) were not implemented.

Although the hand and foot moritor was equipped with an external.

probe for frisking, it was considered of marginal quality for detecting low levels of contamination.

The external probe was not required to be u;ed routinely cut was used only when contamination of the hands or feet was identified.

The radiation work permit for removal of the'old viewing window and installation of a new window provided no specific guidance for use of protective clothing by personnel observing the work.

• The radiation work permit provided no specific guidance for the extent of personne' contamination monitoring to be performed after the window replacement.

The hand and foot monitor, used as principal personnel contamination monitor, for monitoring individuals leaving the facility, exhibited a poor sensitivity to radioactive material. Licensee estimates indicated a minimum detectable activity of about 40,000 disintegrations per minute for each detector in an optimum position. License commitments indicate contamination limits for personnel was <150 disin-tegrations per minute.

. Licensee Corrective Actions Subseqcent to the identification of the individual who had left the facility with contaminated attire, the licensee initiated the following corrective actions to prevent recurrence:

The licensee issued a meraracdun to all facility personnel on March 11, 1988 reninding personnel to perform appropriate l personnel monitoring upon leaving work areas.

The licensee held a General Meeting on Radiation Control with supervisors and managers on March 15, 1988 to discuss the event and outline corrective action to be taken. Supervisors and managers were directed to meet with all employees via work team meetings by March 18, 1988 and ensure all practices have been implemented, i

1 1

. . .. _ =. . - _ _ _ . ._. __

. w.

9

a. -

7

• The licensee performed a dose assessment'for the individual on '

March 16, 1988. Maximum exposure was calculated to.be approximately 552 mrem to the skin of the lower left leg.

.* -The licensee moved a hand held frisker with an associated foot I monitor to the stairwell of Building 2. Personnel were-required to perform whole body frisks while standing on the c" foot monitor. This operation was. viewed by closed circuit television in the reactor control room. Individuals who did not appear to be performing appropriate whole body frisks were contacted prior to leaving the area and requested to re-frisk.

,. Additiorlal Observations On March 17 and 18, 1988, the inspector observed personnel frisking activities.at the newly installed frisking station located in the stairwell ~of Building 2. The following was noted:

+

On March 17, 1988, the frisker indicated a background cour,t rate of about 1100 counts per minute. Also, trucks transporting radioactive material in close proximity to the stairwell caused the background of the frisker to increase to 3000 counts per minute as a result of rac'tation emanating from the trucks. This may lead to inability to identify contaminated personnel or contaminated. people leaving the controlled area. 1 The licensee attributed the high background to interference caused by the foot monitor. The foot monitor was disconnected from the frisker and personnel were required to frisk using the hand held probe. The frisker then indicated a background of 40 counts per minute.

+

On March 18, 1988, the inspector observed personnel frisking at the newly installed Building 2 frisker (with foot monitors removed). The following was noted:

4 a

Personnel performed very rapid and generally poor frisking L . of their person.

l l

Licensee personnel accompanying the inspector requested

personnel to frisk at a slower rate when poor frisking practices were noted by the inspector. Subsequent frisking I , by six individuals identified 4 of 6 individuals to be contaminated. Maximum contamination ranged up to 2000 counts per minute. One individual, exhibiting 2000 counts per minute on his left hand, had previously used the hand and foo; frisker which did not alarm.

The licensea subsequently stationed an inaividual at

!ocation to monitor frisking practices.

L L

. ; .. ~;

,i

• h * *

s. ..

8

.The licensee recognized weaknesses in personnel frisking and plans to purchase'a sensitive whole body frisker.

Licensee procedures do not provide guidance regarding the type

. of personnel frisking to be perforned. Procedures and

, memorandums' indicate "appropriate" frisking to be performed.

Licensee personnel indicated this matter will be reviewed.,

Offsite Contamination-b The inspector discussed the potential for offsite contamination with t.he worker and licensee personnel. The individual stated that the persor,al items identified as contaminated were only worn while working at the facility. They were. stored in a poly bag when in transient batween '

work locations. Tne individual said he surveyed his travel bag which contained the poly bag. No contamination was found. The individual's i

rental automobile was also surveyed by West Valley personnel. No contamination was found.

The inspector did not identify any significant potential for offsite contamination by the individual.

. NOTE: The licensee subsequently performed surveys of f.he ,ialkways outside Building No. 2. No contamination was found.

. 6.0 Train'ng The inspecter reviewed the training and qualification of the individual with resoect to c:iteria contained in 10 CFR 19.12, Instructions to Workers.

Evaluation of licensee performance in this area was based on discussions with cogriizant personnel, review of training material and review of documentation.

Finding When the contractor individual arrived on site, a decision was made not to require the individual to attend a full length radiation worker training prog >a:.1 because: 1) the individual had experience in the nuclear field, 2) woeld be under crsntinuous escort and 3) would be onsite for only a short period of time. Consequently, the indiv Mual was provided limited training in radiation protection. The training nas a 45 minute briefing by a radiation protection technician.

The inspector noted that the technician did not provide any guidance or instructions regarding frisking to the individuai.

- - . . - .-. . -- -- . ~. .. - -

^ gf' ,

9 5

.Although the individual signed a docu. tent summarizing the licensee's efforts to reduce exposure to as low as~is' reasonably achievable, the -

document did not discuss frisking.

The inspector also noted that the individual was escorted while working in: Building 2. The individual was pro'vided guidance as to how to perform a hand and foot 1 frisk with the hand and foot monitor by at least one of the individual's escorts.

However, although the individual was escorted, no guidance or criteria was provided to the. individual regarding when to use the hand held frisking probe attached to the hand and foot counter. Also, the individual's escort did not perform whole body frisks of tt,a! individual after working in contaminated areas.

The inspector noted that on February 27, 1988, the individuai entered an area with up to an estimated 1X105 disintegrations per minute, the individual did not perform a whole body frisk prior to leaving the site.

The inspector also noted that the individual worked in a contaminated area on February 29, March 1 and' 2,1988 and no whole body frisks were performed by the individual prior to leaving the facility, s

The inspector concluded that the instructions and guidance provided to the individual were inadequate to preclude personnel contamination and were inadequate to allow the individual to identify that he was contaminated.

This is an apparent violation of 10 CFR 19.12 (70-687/88-02-01) 7.0 External Expojure Controls The inspector reviewed the adequacy and effectiveness of selected aspects of the external exposure controls provided for the contractor worker during replacement and preparation for shipment of the shield viewing glass of Hot Cell No. 1. The review was with respect to applicable regulatory requirements and licensee procedures.

1 Evaluation of licensee performance in this area was based on discussions with personnel, review of documentation and observations during facility tours.

Findings i Within the scope of this review, no violations were identified. With the exception of the personnel contamination control concern discussed in Section 5.0 of this report, the licensee provided acceptable external

exposure controls for the worker.

I

l 10 Regarding the externai skin exposure rece.ived by the individual due to radiation from the contamination located on the top of the shoes, the licensee performed an initial dose calculation which indicated a maximum shallow dose of about 552 millirem to the skin of the lower lef t leg. The inspector considered this er.timate to Se conservative because it did not take.into consideration shielding of the skin by clothing. The licensee's final dose estimates will be reviewed during a subsequent inspection (70-687/88-02-02).

The following matters were discussed with licensee personnel as areas for improvement:

• Radiation dose rates encountered in the hot Cells have the potential to be non-uniform (i.e. dose rate gradients may be present).

Licensee procedures do not provide guidance for placement of personnel dosimetry aevices on individuals to ensure the devices are properly placed on individunis.

• Documentation of radiation surveys needs improvements. Seme surveys did not indicate dates or time performed and accurately indicate location of survey points. Standardized methods for indicating survey locations were not used. Also surveys of Mot Cell 1 did not show contamination levels. No contamination surveys were N'oarently made.

The licensee initiated review of these matters.

8.0 Internal Exposure Controls The inspector reviewed the adequacy ar.d effectiveness of selected aspects of the internal exposure controls provided for the contractor worker during replacement and preparation for shipment of the shield viewing glass of Hot Cell No. 1. The review was with respect to applicable regulatory requirements and licensee procedures.

Evaluacion of licensee performance in this area was based on discussions with Jersonnel, review of documentation, review of air sample data, and observation during facility tours.

Findings The individual was whole body counted at the West Valley Project on March 9, 1938. No uptake of radioactive material was identified.

. Within the scope of this review, the following apparent violation was

( identified:

• Although the removable dry surface contamination inside Hot Cell Uc 1 was estimated by the licensee's radiation protection personnel to be in excess of 1X10' disintegrations per minute (dpm), no air

'amples were collected to determine potential airborne radioactivity I levels during the entire duration (~8 hours) of replacement of the

viewing window in che cell.

t i

I

v 11 Licensee personnel indicated that airborne radioactivity, with the exception of I-131, has typically not been sesn in the cells.

The licensee was not able to provide any information regarding airborne radioactivity levels in the hot cell.

The inspector indicated that failure to evaluate airborne radioactivity levels inside the hot cell to ensure compliance with 10 CFR 20.103 airborne radioactivity limits is an apparent violation of 10 CFR 20.201. (70-687/88-02-03)

The inspector was provided results of thyroid ccunts of the workers who entered the cell. The cour.ts were presented as "net counts per minute" and could not readily be converted to intake by the inspector. Licensee personnei indicated the counts were so low as to indicate no apparent intake and therefore inttke was not calculated and that this was typical.

The inspector noted that the individuals working in the cell wore supplied air respirators. Although the licensee does not have an approved respiratory protection program, it appears that the licensee is making allowance for use of the respiratory protection equipment in controlling internal exposures. Negative airborne radioactivity intake results, based on thyroid counts, were considered evidence that no substantial airborne radioactivity was present.

The inspector noted that the presence of the respirator was not considered. The inspector also noted that the licensee does not whole body count pecsonnel. The licensee was unable to provide any data for use in estimating potential intake of other radionuclides relative to I-131 intake.

The inspector indicated the licensee's use of respiratory protectica equipment without an approved program and use of I-131 thyroid counts to identify intakes by workers of other radionuclides are unresolved and will be reviewed during a future inspection (70-687/88-02-04).

The licensee is using an airborne radioactivity concentration of 3x10-9pCi/ml as the maximum permissible concentration (MPC) factor for purposes of controlling personnel exposure to airborne radioactivity. This factor, however, does not appear to incorporate ,

all radionclides (e.g. Pu, Sr, Am) found in the cells.

Licensee personnel indicated no entries would be made into potential high airborne radioactivity areas until the acceptability of the factor has been esaluated.

., p u

• J'

, . i

=

yhy ,

s The potential use.of'an incorrect MpC factor for controlling personnel exposure is an unresolved item (70-687/88-0?/05). ,

. 9.0 Pfocedures and Reviews

. The inspector reviewed the establishment and implementation of procedures for the replacement of the; viewing window in Hot Cell No. I with respect

, to criteria in applicable regulatory requirements. The. inspector also examined the extent of reviews performed for the replacement.

Findings ,

4. ,

Inspector review indicated the licensee used a vender procedure to provide guidance for replacement of the windcw. The procedure was raviewed by the operations group and found acceptable. However, the

.following items were identified as an unresolved item pending further NRC review (70-687/88-02-06).

The vendor procedure was not reviewed and approved by the Nuclear Safeguards Committee. Use of a non-approved procedura is an unresolved matter.

The licensee replaced the viewing window in Hot. Cell No. I with a <

different design window. The new design window was reviewed by the operations group. However, it was not reviewed by the Nuclear Safeguards Committee. Installation of a new design window-that was not reviewed by.the Nuclear Safeguards Committee is an unresolved matter.

10.0 Exit Meeting The inspector met with licensee representatives (denoted in Section 1 of this report) on March 18, 1988. The inspector summarized the purpose, scope and findings of the inspection. ,

I i

6

. . - , - , - - . . . , . . - , . - - - - - - - . - , , - - - - . --->