ML20235V578

Combined Insp Repts 50-054/87-04 & 70-0687/87-05 on 870810-13.Violation Noted.Major Areas Inspected:Licensee Actions in Response to Confirmatory Action Ltr CAL-87-01 & Status of Radiological Controls Program Upgrades

ML20235V578
Person / Time
Site:	05000054, 07000687
Issue date:	10/02/1987
From:	Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235V556	List: ML20235V554 ML20235V578
References
50-054-87-04, 50-54-87-4, 70-0687-87-05, 70-687-87-5, CAL-87-01, CAL-87-1, NUDOCS 8710150229
Download: ML20235V578 (11)

See also: IR 05000054/1987004

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

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Report Nos. 50-54/87-04

70-687/87-05

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Docket Nos. 50-54

70-687

License Nos.- R-81 Priority 1 Category UHBR

371F639

Licensee: Cintichem, Incorporated

P. O. Box 324

Tuxedo, New York 10987

Facility Name: Research Reactor / Hot Laboratory

Inspection Conducted: August 10-13, 1987

Inspectors: b- /0 Q

A. Weadock, Radiation Specialist Date

FRPS, EP&RPB, DRSS

Approved by: s-777 *=5 ^ ,4)/

M. Shanbaky, Chief, FRPS, EP&RPB, DRSS

/o/2f/9f]

Date

Inspection Summary: Inspection on August 10-13, 1987 (Combined Inspection Re-

port Nos. 50-54/87-04; 70-687/87-05)

Areas Inspected: Health Physics inspection conducted to review two areas: (a)

licensee actions in response to NRC Confirmatory Action Letter (CAL) No.

87-01, dated January 20, 1987; and, (b) status of radiological controls

. program' upgrades.

Results: Improvements were evident in the licensee's control of the

manipulator hand repair operation. The licensee's overall upgrade of the

radiological controls program is ongoing, however specific improvements,

reflecting an increase in management attention, were noted. One

licensee-identified violation, concerning a failure to post an airborne area,

was identified and is discussed in Section 4.0.

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.1.0. Persons Contacted-' l

' During:the courseLof this routine inspection, the following personnel

were contacted or'i'nterviewed:

M J. Ditton, Health Physics Supervisor

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- *D. Gallaher, President, Cintichem, Inc.

LL..'McClean,;RSO,Medi-Physics,Inc.

• J. McGovern Plant Manager .

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L. Puccini,-Assistant General Counsel, Hoffman LaRoche

T. Rice, Health Physi _cs Technician.II -

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'J. Stewart, Health Physics Associate

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• L. Thelin, Staff Health Physicist j

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• T. Vaughn, Manager, Health, Safety, and Environmental Affairs

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• Attended the exit interview on August 13, 1987

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Other licensee personnel were also contacted during the course of this

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2.0 Purpose

This Health Physics (HP) inspection was conducted to ' review two areas: i

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- a )' licensee' actions'in response to requirements outlined in NRC  !

Confirmatory Action Letter (CAL) No. 87-01, dated January 20, 1987;

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b) status of licensee upgrades to their radiation protection program. 1

3.0 Response to Co'nfirmatory Action Letter l

An NRC inspection conducted in January,1987 (NRC Report No.

70-687/87-01) . identified a worker extremity (hand) overexposure and

several related violations associated with a specific work task. This

task was the manual repair of highly contaminated remote manipulator

!' hands" . NRC Confirmatory Action Letter (CAL) No. 87-01, issued to the 1

licensee as a result of those findings, req 91 red sev.eral specific

licensee actions. Required actions relating specifically to the

manipulator hand repair operation included:

- modify the operation as' necessary to reduce exposyre, j

- provide documented training to involved workers,

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develop procedures specific to the operation,

- develop a radiation work permit for the operation,

-- ensure adequate instrumentation, with appropriate beta correction

factors, is used;

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- ensure surveys are documented.

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The inspector evaluated licensee completion of the above actions by.the {

'following methods: 1

- discussion with the Health Physics staff,

- interview of two workers who had performed or are performing the f

manipulator. hand requirements,

- review of the-following material: 1

1987 wrist and extremity exposure for the two workers involved

with the hand repairs

licensee document titled " Radiation Dose Reduction Instructions

for Manipulator Hand Repair"

" Procedure for Transfer of Repaired Hands to Conveyor Outside

of Hot Cell" 1

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work permit titled " Repair Manipulator Hands" 1

results of R0-2 and CS-40 (portable survey instruments)

calibration and beta response data. -

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

Specific training, procedures and a . Health Physics Work Permit were

developed and in-place prior to resumption of the manipulator hand repair

operation. Specific modifications to the actual process included the

inclusion of an additional ultrasonic cleaning step, the re-arrangement

of the laboratory hood work area, and the use of additional shielding

during the transport and storage of manipulator hands. The inspector

noted that these controls have been effective in significantly reducing i

worker hand exposure.during this operation.

The inspector noted the licensee is now maintaining an Extremity

Monitoring Exposure book, which lists all cumulative extremity exposures

(wristandhand)forallindividualssomonitored. The licensee's

previous' method was to record all extremity exposures directly in each

individual's file; no cumulative records for all individuals were kept.

The new system is viewed as a licensee improvement, allowing easy access

and overall review of cumulative extremity exposures by HP supervision.  !

The licensee stated additionai improvements in this area are being

planned. The licensee is currently evaluating the development of a clamp

or holding device to be used to hold the manipulator hand during repair.

Funds have been budgeted for the development of a separate manipulator

repair room, where both manipulator hands and the manipulators themselves

enn be warked on, away from the general work areas. The NRC will

contir,ue to review developments and licensee improvements in this area.

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The licensee has also contracted with T61edyne to provide a new extremity j

! monitoring TLD to improve monitoring of extremity doses. The TLD 2  !

raterial used in the ring is extremely thin (1.3 mm, providing 32 mg/cm a

shielding including ring covering). The licensee stated that this should 4

provide for an improvement in beta monitoring capability. Currently, the

licensee has no experiments 1 evidence or. vendor documentation to

demonstrate beta resnonse of the Teledynt Dadge; however,.the licensee

has arranged to have the badges exposed to a calibrated Sr-90 source in

October. The licensee stated the results of this analysis would be sent

to Region I for review.

One concern was identified during the above review. In response to the

CAL, the licensee developed beta correction factors for the instruments

(CS-40 and R0-2) routinaly used to survey the manipulator hands. The ,

licensee made measurements of the dose rates emanating from an actual i

contaminated manipulator hand using TLD chips. These dose rate

measurements were then raticed with R0-2 and CS-40 instrument readings

made at the same locations to arrive at instrument correction factors.

The inspector noted the above methodology was deficient in that: 1) beta

energies emanating from the manipulator hands were not characterized,

and, 2) TLD chip response to beta energy was unknown and consequently TLD

values could not be assumed to be correct. The inspector notad that

there did not appear to be an imn,ediate concern, as the correction

factors the licensee had calculated for contact dose rate measurements

with the R0-2 and CS-40 were 10 and 20 3 respectively (the instrument

reading is multiplied by the correction factor to obtain the corrected

instrumentreading). These values are higher than those seen in the 1

industry (typically 4 for the R0-2), The licensee subsequently

committed, however, to characterize the beta energies emanating from the

manipulator hands and to identify TLD response to that energy. 1his will

be reviewed during a subsequent inspection (50-54/87-04-01;

70-687/87-05-01)

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In response to NRC Confirmatory Action !.etter No. 87-01, the licensee

completed a TLD study to evaluate extremity exposures received by workers

performing the manipulator hand operation. The inspector discussed this

study with the licensee, who stated that additional licensee analysis in

this area had been requested by the New York Department of Lebar,

Division of Safety and Health. The licensee committed tc senaing the

results of this additional analysis to the NRC Region I upon completion.

During a telephone convers'ation with the licensee on September 22, 1987,

the inspector stated that a comprehensive review of the licensee's l

intitial TLD study would be performed after the additionel exposure study ,

fcr the New York State Division of Safety and Health had been completed l;

and subsequently reviewed by the NRC. This NRC review will 61so include

the results of the licensee's beta energy response study discussed above

and will be completed during a subsequent special inspection I

(70-687/87-05-02). l

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4.01 Radiological Control Program Upgrade

Subsequent to the identification of specific problem areas as detailed in

NRC Inspection Report No. 70-687/87-01, the licensee initiated an

improvement program in the area of radiological controls. Modifications

'and improvements have been-made and are continuing.in the areas of

H personnel, procedures and equipment. The status of program improvements

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was reviewed during this inspection and is discussed below. )

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4.1 Organization and Management Controls  !

Several changes were noted in the Health' Physics organizational ]

structure since the previous inspection in this area. A new. manager' l

for the Heal _th, Safety and Environmental Affairs Department has been

appointed; .this individual is also the site Radiation Safety Officer

(RS0). The previous RSO now holds the position of Staff Health

Physicist, and provides technical support direct to the Manager /RS0.

Previously, the department included five Health Physics (HP)

technicians, one;of whom spent approximately 50% of the time on

non-radiological, industrial safety concerns. That individual has

since been shifted 'to the' area of industrial safety on a full-time 3

basis. A new HP' technician was brought in to the department to

replace this individual.

The inspector noted that the above organizational changes reflect an i'

increased ma_nagement concern to safety. As part of continuing staff

. upgrades, the licensee stated that funding to hire an additional HP .

technician'in 1988 had been requested. l

The inspector also. determined that the HP Supervisor / Assistant RSO

had plans to retire at the end of 1988. Licensee management

indicated actions had already begun to identify a suitable

replacement and is hoping to do this in a timely enough fashion to

ensure a suitable transition and turnover period.

4.2 Audits

The licensee performs audits of Health Physics (HP) activities to

fulfill a requirement of their SNM license. In response to NRC .

Inspection 70-687/87-01, conducted in January, 1987, two additional I

audits of HP activities were also recently performed. ' One of these

additional audits, performed in March, 1987, was conducted by a

Radiation Safety Officer (RS0) employed at another of the licensee's

facilities. The second audit, performed in April,1987, was

conducted by on outside contractor organization.

The inspector reviewed the above audits to evaluate effectiveness of

the audit program. The SNM license-required audit was noted to be .

somewhat superficial; findings were limited and the scope of the )

audit report did not indicate that all significant radiation

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protection program areas received review. The March, 1987 audit,

conducted by the licensee's RS0, included several constructive

recommendations; however, this audit was limited in scope due to

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time constraints and could not be considered a programmatic review.

The April, 1987 audit performed by the outside contractor was quite 1

extensive and provided a more programmatic review of the HP program. ]

The licensee indicated that the March, 1987 audit performed by the

licensee's RSO was intended to be a focused rather than programmatic

review, concentrating on radiciogical centrols associated with the

n manipulator hand repair operation. The licensee stated an

additional audit-, to be performed by the same RSO, will be conducted

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during the fall,1987, and will provide a more comprehensive review. l

The licensee acknowledged inspector comments concerning the scope of

the SNM license audit and indicated they would be evaluated. t

One recommendation included in the March,1987 RS0 audit is that the

internal HP staff perform routine audits of their o'wn activities and

work areas. The inspector discussed this recommendation with the

licensee.  ;

The licensee indicated tours and audits of work areas were routinely

done, however no documentation of these tours was maintained. The

licensee committed to establishing routine, documented supervisory

tours of the work areas, which will be performed to identify

deficiencies-in radiological controls, by the end of the year.

Implementation will be reviewed during a subsequent inspection

(50-54/87-04-03;70-687/87-05-02).

4.3 Training

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Several modifh'ations were made in the training area which were

discussed with the licensee. The licensee has developed a radiation

safety requalification training session, which each employee will

receive in addition to their initial radiation safety training.

The inspecter did identify through discussions with the licensee

that no " qualification card" type system exists to formally identify

which procedures, instruments, and activities an HP technician is

qualified to use and perform. Such a system is particularly useful

when making work assignments for new technicians, who are not

qualified in some areas or tasks but are qualified for others.

The licensee committed to developing a formal system for documenting

the qualification status for new technicians by the end of the year.

This specific area, in conjunction with the training / qualification

program, will be reviewed in a subsequent inspection (50-54/87-04-03;

70-687/87-05-04).

4.4 Procedures

The licensee is currently in the process of reviewing and expanding

their HP procedures manual. The licensee indicated all existing

procedures have been reviewed; revisions and development of new

procedures is ongoing and is scheduled to be completed by the end of

the year.

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- The inspector reviewed' selected procedures and discussed procedural

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R, upgrades with the licensee. The licensee indicated that an

L; , " Employee. Radiation Safety and General Safety Manual" is being-

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- developed concurrent with the procedure upgrade, and when complete,

will-be provided to each worker. Sections of this manual' clearly-

, ' explain worker radiation safety requirements and. responsibilities.

This represents a' licensee improvement; the c'urrent licensee

procedures on personnel radiation protection are not well' organized

and appear.merely to compile in one location all SNM' license HP'

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requirements.

A _ comprehensive NRC review of the licensee's HP procedures.will be: i

performed.at.the completion of the upgrade. However,' specific i

concerns'with the content and implementation of two procedures were

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identified and are discussed below.

L The licensee has developed a " Dosimetry Action Limits" procedure ~

which requires.HP review of whole body exposures over certain daily

administrative limits. The inspector noted several shortcomings

with'the procedure:

- ' investigations were required for exposure problems only; other

concerns.(personnel contamination,. spills) were not addressed;

- no methodology was given as to how the investigation'should be j

conducted'or who should be providing HP review; 1

- 'no time requirements were included as to when the investigation

should be completed.

The inspector reviewed the licensee's completed investigation file

and noted the following concerns:  !

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four investigation sheets had been filed without being signed

as required on the form by an HP reviewer;

- investigations detailing significant concerns and suggested

corrective actions were being reviewed by HP technicians,  !

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rather than by an appropriate level of management;

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- signed-off investigations were not always complete. For

example, in cases where a workers dosimeter went off-scale, the i

final TLD readout dose was not included as part of the.

completed package.

In response to the above concerns, the licensee committed to

revising the " Dosimetry Action Limits" procedure to:

- address other HP concerns and deficiencies, as well as

administrative overexposure,

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- prescribe appropriate methodology for performing the d

investigation, 1

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- establish time limits for completion of the investigation. j

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The licensee indicated that the above revisions would be completed j

and in piece by the end of the year. The licensee also stated that

the investigation file would immediately be reviewed and that the-

four unsigned investigation reports would be closed out within 30

days.

Licensee completion of the above commitments will be reviewed during

a subsequent inspection (50-54/87-04-04; 70-687/87-05-05)

The inspector noted that several of the filed investigation reports

described incidents where individuals received greater than

anticipated exposure due to handling unfamiliar isotopes, handling

quantities greater than those typically handled, or handling process

equipment that the individual was not fully familiar with. No a'

exposures in excess of regulatory limits were identified.

In the'above instances, the inspector noted that the source arose i

from byproduct materials, and that these instances are consequently }

under the jurisdiction of the New York State byproduct license 1

rather than the NRC reactor or special nuclear material license.

The inspector indicated to the iicensee, however, that such

incidents describe a breakdown in radiological controls; the HP

staff should be aware of changes to routine radiological work i

practices prior to, rather than after the fact. Corrective actions

are discussed in Section 4.5. Subsequent to the conclusion of the

inspection, the inspector also communicated details regarding the

above incidents to the cognizant representative from the New York

State Department of Labor Division of Safety and Healthi during a  ;

telephone conversation on September 9, 1987.

During review of the incident file, the inspector noted that on

March 20, 1987, radiciodine airborne activity was detected in the ]

waste pit building and in portions of the packaging area. The

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airborne activity was being generated by a High Integrity Container

(HIC) which was filled with waste and located on the floor of the

waste pit building. Typically, PICS were lowered into vented pits

in the floor of the building, and then covered with a shield plug.

However, during transfers the night before, the transfer crane broke

and it was decided to leave the shielded HIC out overnight. A

continuousairmonitor(CAM)waslocatedinthewastepitbuilding

and should have responded by alarming to the airborne condition

(later determined by portable air-sampling to be 8-12 MPC); however

the licensee's investigation indicated the air filter head may not

have been correctly placed on the sampler, and the sample air flow

may have bypassed the filter,

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Identification of the airborne condition was made after the routine

changeout and analysis of the "V" filter from the Waste Pit

Building. This well-mounted, fixed filter continuously samples the

Waste Pit Building air and is changed-out and analyzed daily. The

"V" filter only samples air and includes no built-in alarm

capability.

This incident led to the unplanned intake of airborne radiciodine by I

several licensee personnel. Subsequent thyroid cov1 ting of i

personnel in the area identified measurable thyroid activity in

three individuals; maximum exposure was calculated as 4,2 MPC-hours,

well below the regulatory exposure limits of 520 MPC-hours per

calendar quarter. j

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The airborne area generated in the packaging area and behind the

hot cells (approximately 2 MPC iodine) was consequently not noted

nor posted as an airborne activity area as required by 10 CFR

20.203(d). However, in an effort to' promote licunsee

identification cf violations,10 CFR 2 Appendix C allows mitigation

of violations in instances where certain specific criteria are met,

one of which requires that suitable corrective actions are taken to

prevent occurrence. !.icensee corrective actions in this area appear  !

comprehensive, and include the following: f

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a) instruction to technicians concerning filter head placement, i

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b) modification of the HIC transfer precedures to require l

appropriate respiratory protection and air sampling, and ensure i

the HIC is in a properly ventilated condition. l

The above apparent violation will be considered licensee identified

'and will be carried as unresolved pending review of the

effectiveness of the licensee's corrective actions (70-687/87-05-06).

The waste pit building has no independent overhead ventilation; the j

only specific ventilation is provided to the floor pits the HICs are

stored in. In consideration of the above incident, the inspector

questioned the licensee concerning air flow paths in the waste pit I

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building, particularly when the main doors to the packaging area

were closed and when all waste pits were covered. The inspector

questioned whether a procedure had been developed to provide I

negative ventilation ir the waste pit building air space in case of

an accident with airborne generating potential, i.e., a dropped cask j

l' cr HIC. The licensee indicated no procedure or prctocci 1

existed. The licensee also indicated air flow studies had been done l

l in the past but the results we:re not available and the staff was not

i currently fa:niliar with the results. The licenree subsequently

! committed tc evaluating both air flows and appropriate emergency f

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response in the waste pit building. This will be reviewed in a 2

subsequent insper. tion (/0-687/87-05-07).

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4.5 Health Physics Wor PermitPbcedure

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The inspector reviewed the licensee's HP work permit procedure and

noted several deficiencies. Specifically /, the procedure did not:

- identify specific instances or radiological conditions.where

work permits would be required,

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identify who was authorized to generate and approve a work

permit,

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define terms and requirements used on the work permit to incure

workers and the HP staff had consistent understanding. l

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The inspector also noted that the use of the work permit as.a means  !

of providing stetion HP coverage was somewhat limited and could be

expanded. Specific isotopes, isotope activity limits, br lists of

authorized personnel could be given on the work permit and would

prevent the losses of control described in Section 4.4 above.

The licensee acknowledged the above concern and indicated that the

use of HP work permits would be expanded, particularly to cover

-routine process activities typically not requiring constant HP

coverage. The licensee indicated survey requirements would be

included as needed on the work permits to insure' proper documenta-

tion of surveys by workers. The licensee also committed to revising l;

the work pcrmit procedure to address the concerns listed above.

This will be rwiewed in a subsequent inspection (50-54/87-04-05;

70-687/87-05-08).

During review of several surveys associated with work permits, the

inspector noted technicians do not always list survey instrument

type, serial number, and calibration date on completed survey forms. )

This information is necessary to demonstrate survey instruments were

calibrated at the time of the survey.. The licensee committed to

revising survey forms to include specific blanks requiring this

information. This will be reviewed in a subsequent inspection j

(50-54/87-04-06; 70-687/87-05-09).

4.6 Facilities and Equipment ,

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The inspector discesed resource allocations for tre Health Physics {

area with licensec nanagement. Increased funding has been awarded i

for 1987, and is being used to upgrade HP instrumentation and for l

modifying specific systems or processes to reduce exposure. j

L Specific packages include portable survey instrumentation, a new j

multi-channel analyzer, and a TLD reader. Planned 1988 improvements l

which should redor.e exposure include upgrades to the conveyor 1

station and the construction of a manipulator repair room. The  ;

inspector noted the above increased allocation of resources i

indicates increased management commitment to improvement in the l

radiological controls area. ]

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The inspector noted one_ potential area for equipment upgrade. The

licensee currently assigns pocket ionization chambers (PICS) to

individuals entering the controlled area. These are an cider model

.than those typically used in the industry and cannot be read out by

the individual user to monitor accruing exposure. Instead,

' they must be inserted into a specific reader and are read by Health

Physics staff at the end of the day. The inspector noted that

self-readingdosimeters(SRDs).wouldbemoreeffectivein

heightening worker awarenest, of and responsibility for their own

exposure. The licensee indicated during the exit interview that the

. procurement of SRDs would be evaluated. During a subsequent phone

call on August 19, 1987, the licensee indicated they would be

purchasing SRDs and phasing out the use of PICS.

The inspector toured the reactor building and hot laboratory to '

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observe radiological conditions and postings. No violations were

noted. One potential area for improvement was noted. The licensee

currently posts contaminated areas with the use of a sign on a small

stanchion. The inspector noted this might cause some confusion, as

the actual boundaries of the area are not delineated and have to be

assumed by the worker.

The licensee acknowledged this concern and steted that the HP staff

would begin using tape and/or rope to delineate the boundaries of

contaminated areas.

l The inspector had no further questions in this area.

4.7 Exit Interview

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The inspector met with licensee representatives (denoted in

paragreph 1) at the conclusion of the inspection on August 13, 1987. j

At the time the inspector summarized the scope and findings of the )

inspectinn. l

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