ML20207N197

Insp Repts 50-054/86-04 & 70-0687/86-05 on 861202-05. Violation Noted:Failure to Label Radioactive Matl

ML20207N197
Person / Time
Site:	05000054, 07000687
Issue date:	01/02/1987
From:	Kaminski M, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207N186	List: IR 05000054/1986004 ML20207N184 ML20207N197
References
50-054-86-04, 50-54-86-4, 70-0687-86-05, 70-687-86-5, NUDOCS 8701140046
Download: ML20207N197 (10)

See also: IR 05000054/1986004

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos. 50-54/86-04

70-687/86-05

Docket Nos. 50-54

70-687

' License Nos. R-81/SNM-639 Priority 1 Category UHBR

Licensee: Cintichem, Inc.

P.O. Box 324

Tuxedo, New York 10987

Facility Name: Research Reactor / Hot Laboratory

Inspection At: Tuxedo, New York

Inspection Conducted: December 2-5, 1986

Ir.spectors: 8-(odx- l[J!F 7

A. Weadoi:k, Radiation Specialist date

th IdvnumoL 19l3ll%

M. Kaminski,~ Radiation Specialist tfate

Approved by: R. L. td M M

M. Shanbaky, Chief,4 acilit.ies Radiation

i I rl 9.1

d'at6

Protection Section, DRSS

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Inspection Summary: Inspection on December 2-5, 1986 (Report Nos. 50-54/86-04

and 70-687/86-05).

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

Protection Program. Areas inspected included posting and labeling, training,

exposure records, effluents and environmental monitoring, bioassay, and surveys.

Results: One violation concerning labeling of radioactive material was

identified during the course of this inspection (section 4.0).

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DETAILS

1.0 Persons Contacted

During the cev se of this routine inspection, the following personnel

were contacted or interviewed:

J. Ditton, Health Physics Supervisor

• C. Konnerth, Site Operations Manager

• F. Morris, Manager - Engineering and Technology, Sales

W. Ruzicka, Manager, Nuclear Operations

• L. Thelin, Radiation Safety Officer

J. Stewart, Health Physics Assistant

B. Strack, Reactor Supervisor

• Present at the exit interview on December 5, 1986.

Other licensee personnel were also contacted during the course of this

inspection.

2.0 Purpose

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

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radiation protection program with respect to the following elements:

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Status of Previously Identified Items,

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Posting and Labeling,

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Training,

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Exposure Records,

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Effluents and Environmental Monitoring,

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Bioassay,

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Surveys.

3.0 Status of Previously Identified Items

3.1 (Closed) Noncompliance (54/85-04-01): Failure to post two High

Radiation areas; failure to control access to a posted High

Radiation Area. Licensee corrective actions as specified in their

i response to the Notice of Violation were reviewed and found to be

l complete. Inspector tour and independent survey inside the Reactor

Building and Hot Laboratory during the current inspection indicated

that all accessible High Radiation Areas are appropriately posted

and controlled. This item is closed.

3.2 (Closed) Noncompliarte (54/85-04-05): Failure to perform required

, monthly channel test on the stack monitor. The licensee has

instituted a formal radiation source check of instrument response

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for the stack monitor system. This source check has been included

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on the monthly "HP checklist" sheet designating activities to be

l performed. This item is closed.

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3.3 (Closed) Noncompliance (54/85-04-02, 687/85-07-01): Failure to label

radioactive material. Licensee corrective actions outlined in their

response to this violation included instruction of Reactor Operators

not to leave radioactive material unattended and instruction of

Health Physics Technicians to ensure proper labeling of waste con-

tainers at the completion of hot cell work and other nonroutine jobs.

Based on the identification of a similar violation during this

inspection (Section 4.0), these actions appear ineffective in pre-

venting recurrence of the failure to label violation. For adminis-

trative purposes, this item is considered closed; additional ana

subsequent licensee actions in the labeling area will be reviewed in

association with the current violation number.

3.4 (Closed) Unresolved Item (687/85-07-03) Verify licensee fulfillment

of bioassay requirement in license. The inspector examined the

results of the 1984 urine analyses for uranium and determined the

licensee to be in compliance with the bioassay requirement. This

item is closed.

3.5 (Closed) Inspector Followup Item (54/85-04-04,687/85-07-04) Licensee

raw data for beta gamma analysis of urine samples not in finished

form suitable for review. The inspector examined finished form

licensee data for the beta gamma ar,alysis of urine samples and deter-

mined the licensee to be in compliance with license bioassay require-

ments. This item is closed.

4.0 Posting and Labeling

The inspectors toured the licensee's facility on several separate

occasions to evaluate the licensee's posting and labeling of radiation

areas, high radiation areas, and radioactive materials. Independent

survey measurements were made by the NRC inspectors using an Eberline

R0-2, serial # 3248, calibrated November 24, 1986. One apparent

violation, involving a failure to label radioactive material, was

identified.

10 CFR 20.203(f), " Containers", requires the licensee to label each

container of radioactive materials with a durable, clearly visible label

i identifying the radioactive contents. The label is required to bear the

! radiation caution symbol and the words " Danger" or " Caution", " Radioactive

l Material". Labeling is also required to provide sufficient information to

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allow workers handling the containers or working in the vicinity to take

precautions to minimize exposure.

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l On December 2,1986, at approximately 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> the inspectors observed

l fifteen 55 gallon waste drums against the wall in the Waste Pit area,

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Building 2. None of the drums were labeled with the radiation caution

symbol and appropriate wording. Two HP technicians were in the process

of surveying the drums when the inspectors entered the area. The inspec-

tor noted that on top of each drun was a strip of duct tape on which was

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written the drum contents, a date, and drum weight. Eleven of the drums,

which had just been surveyed by the HP technicians, also had contact dose

rates written on top of the drums. These dose rates ranged from less

than 10 to greater than 800 millirem /hr. Inspector survey of the four

previously unsurveyed drums indicated dose rates ranging from less than

10 to 50 millirem /hr.

Questioning of one of the HP technicians surveying the drums identified

the following concerning the status of the drums:

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None of the drums had any markings giving contact dose rates prior

to the technicians surveys and marking of drums on that day.

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The drums contained waste compacted by the facility engineers,

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The drums were routinely moved into the Waste Pit area from the

waste packing station by the facility engineers. No HP direction

or supervision of the waste packing process was required.

The inspector also interviewed a facility engineer in the area who sub-

stantiated the above statements. He indicated that drums were routinely

moved into the Waste Pit area as they were packed, to accumulate before

transport to the Waste Storage Building. The facility engineer also

stated that no surveys were routinely performed by the HP staff or the

engineers during low-level waste packing or the subsequent transport of

packed drums in to the Waste Pit area.

Both the facility engineer and HP technician indicated the drums had been

stored in the Waste Pit area for several days; however, they could not

provide exact dates as to when the drems had been moved into the area.

Dates on two of the drums, however, indicated they had been packed as far

back as October 1986. Review of a routine radiological survey in the

Waste Pit area, dated October 27, 1986, indicates at least six drums were

stored against the wall in this area.

On December 3, 1986, the inspectors noted approximately sixteen 55 gallon

drums stored in the hallway across from the Waste Evaporator, Building 2.

Seven of the drums were marked with pre printed yellow and magenta tape

featuring the radiation caution symbol and appropriate wording. Seven of

the drums did not feature the required labeling. Inspector surveys of

these drums indicated dose rates of up to 40 millirem /hr.

Failure to appropriately label the 55 gallon drums observed in the Waste

Pit area and the hallway outside the Waste Evaporator constitutes an

apparent violation of 10 CFR 20.203(f) (54/86-04-01; 687/86-05-01).

No exemption in accordance with 20.203(f)(3) applied.

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This apparent violation is of particular concern in consideration of the

following:

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The licensee was cited for failure to label radioactive material

in 1985 (NRC Combined Report No. 54/85-04,687/85-07).

- The remarks of the facility engineer indicate that radioactive

material is compacted, transported, and stored at the discretion of

the workforce, without HP direction or attendance. Such material may

remain unmarked throughout the facility for significant periods of

time.

Licensee corrective actions taken during the week of the inspection

included labeling of drums outside the Waste Evaporator area and

transport of drums from the Waste Pit area to the Waste Storage building.

5.0 Training

The licensee conducts initial and requalification training for all

employees at the facility. The inspector reviewed the requalification

programs for the following work groups:

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Health physics technicians,

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Personnel handling special nuclear material (SNM), '

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Technicians.

5.1 Health Physics Technician Training

The Radiation Safety Officer is currently responsible for the initial

training and continuing training of health physics technicians. The

initial training is formalized and requires the successful completion

of an Indoctrination Checklist. The health physics technician con-

tinuing training program consists of a series of lectures scheduled

and presented by the Radiation Safety Officer on topics currently of

interest or concern at the licensee's facility. In addition, indivi-

dual technicians may raise questions concerning job-related tasks.

The individual may then receive one-on-one training in the area of

concern or, at the discretion of the Radiation Safety Officer, the

entire Health Physics staff may be given the training.

The inspector reviewed the Radiation Safety Officer's log book,

spoke with several Health Physics technicians, and reviewed train-

ing records of randomly selected Health Physics technicians. The

inspector determined that Health Physics technician training and

retraining were being conducted as stated.

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

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5.2 Retraining of Personnel Qualified to Handle Special

Nuclear Material (SNM)

In accordance with SNM License 639, personnel authorized to work

with SNM must complete an annual requalification checklist. A review

of training records showed that all personnel authorized to work with

SNM had completed the annual requalification checklist as required

for 1985. However, for 1986 approximately one-half of these people

have not yet completed the requalification checklist. The inspector

discussed this concern with the licensee. The licensee indicated

awareness of the situation and is taking action to assure the comple-

tion of the SNM requalification checklists for 1986.

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

5.3 General Technician Retraining Program

The General Technician Retraining Program involves all technicians.

Retraining is, for the most part, informal consisting of on the job

training or job-specific training provided by supervisors on an as-

needed basis.

In addition, section 2.6(b) of SNM License 639 requires that, at .

least annually, the Health Physics Department shall review the radia-

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tion exposure history of all employees who have exceeded 25 percent

of the annual dose limit and shall determine the need for additional

training. The licensee stated that reviews of employee exposure data

have always been conducted on a bi weekly basis. Through 1934 the

need for individual retraining was based on these reviews. In order

to formalize the satisfaction of the above license requirement, the

licensee, beginning in 1985, has conducted ~an annual review of the

exposure history of employees who have received greater than 25 per-

cent of the annual dose limit. From this group the Radiation Safety

Officer (RS0) selects a random number of employees to be retrained

and tested. This process is now documented by the RSO. The inspec-

tor reviewed the documentation of the selection, retraining and

testing of technicians. The inspector determined that the licensee

has selected personnel for retraining but noted that of 10 employees

selected for training in a February 1986 memorandum only 4 had been

trained as of December 1986. The inspector discussed this apoarent

lack of timeliness with the licensee. The licensee stated that

training is now progressing in a more timely manner and should be

completed by January 1,1987.

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

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6.0 Excesure Records

The licensee monitors exoosure to ionizing radiati3n through the.use of

pocket ion chambers (PIC) and Landauer film badges. The film badge read-

ing is used as the official record of dose. The PIC is used to provide

daily dose readings. In addition, the licensee has the capability of

issuing and reading thermoluminescent dosimeters (TLD) in house. The TLD

is used for extremity monitoring and immediate dose assessment on high

dose jobs.

The inspector reviewed several randomly selected exposure records

for 1986, exposure histories for workers exceeding 1250 mrem / quarter,

and lost /high-reading dosimetry reports. From the review of this

documentation it appea s that no overexposures occurred.

Within the scope of this review no violations were identified.

7.0 Effluent and Environmental Monitoring

The inspector reviewed the licensee's implementation of both an effluents

and environmental monitoring program by the following methods:

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discussion with cognizant personnel,

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review of various environmental monitoring and sampling procedures,

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review of the following data:

1) 1986 land use census,

ii) 1985, 1986 environmental sample results,

iii) 1986 monthly hold-up tank analysis,

iiii) 1986 stack sampling data.

The licensee's environmental monitorino program includes air, water, and

direct radiation radiological sampling at several loca-ions in the site

environs. The licensee's current sampling program includes more sample

stations than those required by the Reactor Technical Specifications.

Review of environmental and effluents release data indicates surveillances

and sampiing are performed as required and technical specification limits

are not being exceeded. Environmental data was clearly presented and

readily accessible.

Liquid wastes generated in the Reactor Building and Hot Laboratory are

processed and routed to several collection tanks. These tanks are sampled

prior to each tank discharge to the Indian Kill C eek. An aliquot of each

tank sample is held to make up a monthly composited sample of all tank

discharges. This composite sample is then analyzed to evaluate monthly

activity discharge.

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The inspector noted that sample aliquots may, therefore, be held up to

a month pending analysis and questioned the licensee concerning sample

preservation techniques. The licensee indicated no preservatives are

added nor acidification performed to prevent radionuclide plateout on

sample container walls. The inspector also noted that, although sample

containers are re-used month to month, no analysis was ever made of the

empty containers to identify if plateout was occurring.

The inspector stated that failure to acidify the above samples or evaluate

containers for plateout makes the licensee's composited sample results

questionable. The licensee indicated they would review their methods for

holding collection tank samples to determine if the procedure could be

upgraded. This will be reviewed in a subsequent inspection (54-86-04-02),

687/86-05-02). The licensee also indicated that the go-no go tank samples

collected prior to each tank discharge were ar,alyzed immediately and would

consequently not be subject to significant radionuclide plateout.

The inspector had no further questions in this area.

8.0 Bioassay

8.1 Thyroid Scans

The minimum requirements for the licensee's bioassay. program are

specified in SNM License 639. Saction 3.2.4 of the license requires

that the thyroid uptake shall be determined at least quarterly for

all employees processing and dispensing iodine. The inspector

examined the licensee's procedures for determining and recording

iodine burden, the thyroid assay log book, selected air samples for

1985-86, and the thyroid counter itself.

The inspector verified that individuals responsible for processing

and dispensing iodine had received quarterly thyroid counts. In

additior., the licensee indicated that compliance is insured by hold-

ing back worker's paychecks until all required thyroid counts are

complete.

Within the scope of this review no violatiens were identified.

8.2 Urine Analysis

The licensee SNM License 639 Section 3.2.4 also requires an annual

urine analysis for all individuals working with open sources of

radioactive material. The licensee is currently performing two types

of urine analysis: gross beta gamma counting and uranium analysis.

The inspector reviewed the results of the 1984-85 urine analyses and

found the licensee to be in compliance with license requirements.

Within the scope of this review no violations ware identified.

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9.0 Surveys

The licensee's ongoing radiological survey program includes the perfor-

mance of routine facility surveys and job-specific surveys performed to

support work activities. The adequacy of the licensee's surveys in

evaluating radiological hazards associated with specific work activities

was assessed by the following methods:

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discussion with cognizant personnel,

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review of the HP logbook, dated July 9,1984 to present,

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review of selected job-specific surveys from the "Special Survey

File."

In addition to radiological survey results, the job-specific HP survey

form includes information detailing protective clothing and dosimetry

requirements for the workers. The inspectors reviewed completed surveys

against HP logbook entries and verified radiological surveys were com-

pleted in support of radiological work activities. In general, radiolo-

gical controls implemented during work activities appeared appropriate.

However, a concern regarding the adequacy of the licensee's air sampling

methodology in association with specific work activities was identified;.

Workers are occasionally required to enter the highly contaminated hot

cell areas (approximately 15' x 15' x 10') to perform maintenance activi-

ties. Entry to the cell is through a shielded doorway at the rear of the

cell. Ventilation during such entries is provided by the normal hot cell

ventilation system, which takes a suction at the floor level of the front

of the cell. During such entries, workers wear air-supplied hoods.

Ventilation air-flow through the cell is significant; inward flow rates

measured at the rear access of the hot cell can exceed 500 fpm.

The inspector determined by conversation with the licensee and review of

job-specific surveys that no breathing zone type air samples, taken in

the immediate vicinity of the worker, are routinely taken during hot cell

entries. Instead, the licensee positions an air-sampler at the rear

access of the hot cell to provide sampling for the air activity. The

inspector noted that, due to the suction of outside air into the hot

cell, this positioning practice would result in the air sampler only

sampling outside facility air as it is drawn into the hot cell. The air

in the workers immediate vicinity, however, will not be sampled.

The licensee indicated that, due to the tremendous ventilation flow rates

during hot cell entries, airborne activity is not a serious concern.

The licensee also indicated that thyroid count results of personnel

involved in such activities do no show uptakes, and breathing zone

sampling for hot cell entries was performed several years ago and indi-

cated airborne activity was not generated.

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The inspector reviewed thyroid count data for selected workers performing

hot cell maintenance activities and verified these workers showed no

thyroid burden. Due to time constraints, a review of early licensee air

sampling results was not completed during this inspection. Adequacy of

licensee air-sampling during hot cell operations will remain unresolved

pending review of early licensee air-sampling data and intercomparisons

between breathing-zone and area air-sampling records (687/86-05-03;

54/86-04-03).

The inspector also noted inconsistencies and examples of missing informa-

tion on the completed job-type survey forms. Sections requiring signa-

tures by authorizing or requesting individuals or containing blanks for

specific survey information were often not completed. Air-sampling

results sections were variously filled in with a "NA", "ND", or left

blank; causing some confusion as to whether air samples showed no activity

or simoly were not taken. The licensee indicated steps would be taken to

improve consistency and completeness of surveys forms.

10.0 Exit Interview

The inspector met with licensee personnel denoted in section 1.0 at.the

conclusion of the inspection December 5, 1986. At no time during the .

inspection was written material provided to the licensee by the inspector.