ML20207N197
| 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: |
| 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
i I rl 9.1
M. Shanbaky, Chief,4 acilit.ies Radiation
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
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
response to the Notice of Violation were reviewed and found to be
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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
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monthly channel test on the stack monitor. The licensee has
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instituted a formal radiation source check of instrument response
for the stack monitor system.
This source check has been included
on the monthly "HP checklist" sheet designating activities to be
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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
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identifying the radioactive contents.
The label is required to bear the
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radiation caution symbol and the words " Danger" or " Caution", " Radioactive
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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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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
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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:
None of the drums had any markings giving contact dose rates prior
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to the technicians surveys and marking of drums on that day.
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:
The licensee was cited for failure to label radioactive material
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in 1985 (NRC Combined Report No. 54/85-04,687/85-07).
The remarks of the facility engineer indicate that radioactive
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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:
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
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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:
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:
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1986 land use census,
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1985, 1986 environmental sample results,
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1986 monthly hold-up tank analysis,
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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:
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
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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.