ML20235Y245
| ML20235Y245 | |
| Person / Time | |
|---|---|
| Site: | Armed Forces Radiobiology Research Institute |
| Issue date: | 07/09/1987 |
| From: | Loesch R, Shanbaky M, Weadock A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20235Y216 | List: |
| References | |
| 50-170-87-02, 50-170-87-2, NUDOCS 8707250168 | |
| Download: ML20235Y245 (11) | |
See also: IR 05000170/1987002
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( U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-170/87-02
Docket No. 50-170
License No. R-84 Priority --
Category --
-Licensee: Defense Nuclear Agency
Bethesda, Maryland 20814-5145
Facility Name: Armed Forces Radiobiology Research Institute (AFRRI)
Inspection Ati Bethesda, Maryland
Inspection Conducted: _ June 1 - 5, 1987
Inspectors- M M. M 1///f7
,
A. Weado'ck, Radiation $pecialist ~da~te
& W- MdC/- 1lEl??
R. Loe~sch, Radiatiori Specialist 'da'te
Approved by: ~
j 9/4 f e -
M. ShaiiFa ief g' ' ~ 'date
Facilities iation Protection Section
Inspection Summary: Inspection on June 1 - 5, 1987 (Report No. 50-170/87-02).
Areas Inspected: Routine, unannounced inspection to review radiation protec-
tion activities in support of the reactor license. Areas inspected included
posting and labeling, training, audits, surveys, instrument calibration, and
exposure records.
.Results: One apparent violation, concerning a failure to properly label
containers of :adioactive material, was identified (Section 8.0).
8707250168%$h$70
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DETAILS
1.0 Persons Contacted
- Col. G. Irving, III Director, AFRRI
- M. Moore Reactor Facility Director
- Dr. N. Chawla Chairman, Radiation Safety Department
- Cpt. K. Hodgdon Reactor Operations Supervisor
- Cpt. J. Felty Nuclear Research Officer
- T. O'Brien Chief, Radiation Health Physics Division
- A. Kirkwood Chief, Radiation, Radioanalysis and
Dosimetry Division
Sgt. S. Holmes Health Physicist
J. Bond Health Physicist
- W. Ting Reactor Facility Staff
T. Essig Batelle Pacific Northwest
C. Heidel Argonne National Lab.
- Attended the exit interview on June 5, 1987.
2.0 Purpose
The purpose of this routine inspection was to review radiation protection
activities conducted in association with the AFRRI reactor facility.
Areas inspected included:
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training, ;
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audits,
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routine surveys,
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exposure control,
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environmental monitoring,
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posting and labeling,
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instrument calibration.
3.0 Training
The licensee's implementation of a training program for workers entering
the reactor facility's restricted areas was reviewed against criteria
contained in 10 CFR 19.12, " Instructions to Workers." Scope and content
of the licensee's program was evaluated by the following methods:
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review of the reactor facility initial training videotape,
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review of AFRRI M85-1, " Radiological Safety Manual", and
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discussion with licensee personnel.
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Initial radiation safety training is provided to individuals who will be
working in. the reactor facility restricted area. Training is in the form
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of a videotape and a supplemental Radiological Safety Manual. Individuals
then sign-off to indicate they have viewed the film, and are encouraged to
ask questions concerning the subject matter. Additional-training is sub-
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sequently provided to individuals who will be performing experimental
investigations in the facility.
The inspector viewed the videotape and noted that it did not discuss all
topics required by 10 CFR 19.12. Specifically, the following material was .j
not adequately presented:
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precautions or procedures to minimize exposure,
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purposes and functions of protective devices,
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worker responsibility to report conditions leading to potential
violations,
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availability of radiation exposure reports.
l Additional weaknesses were noted in the videotape, including the !
l following:
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various alarms (CAM, ARM, fire) were mentioned but not actually
sounded in the tape, l
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the section on health effects did nc+. include a discussion of )
l- material included in the NRC Regulatory Guide 8.13, 1
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use and limitations of personnel dosimetry were not discussed,
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although pictured, appropriate personnel actions in response to
various radiological postings were not discussed.
The inspector then reviewed the Radiological Safety Manual and noted ,
that the above omissions were discussed in the manual, and that, taken
together, the videotape and manual provided the full scope of training
required by 10 CFR 19.12.
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The inspector noted, however, that the manual was presented in a fashion
that did not encourage subsequent review by the worker. Specifically, in
a session observed by the inspector, the worker viewed the tape, signed-
off that he had viewed it, was asked if he had questions, and was then-
handed a copy of the manual.
When the inspector discussed this with the licensee, they indicated that
l radiological training was not considered a one step process is workers
I were specifically encouraged to review the manual and return with any
questions they might have. However, to improve the training process,
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the licensee committed to upgrading the radiation safety videotape to
insure the tape, in a stand-alone capacity, provided all necessary
instruction as required by 10 CFR 19.12. Improvements in the initial
-radiation safety training videotape will be reviewed in a subsequent
inspection (170/87-02-01).
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4.0 Audits
Licensee Technical Specifications (TS) Section 6.0, " Administrative i
Controls," requires that independent audits of reactor facility activ- !
ities be performed annually. The TS also require that the audits
encompass several specific areas, including the reactor facility ALARA
program. No specific requirement is included in the TS for auditing
other radiation protection activities.
Audits of the reactor facility were performed by the Defense Nuclear
Agency Inspector General's (IG) Office during 1985 and 1986 and are used
by the licensee to fulfill the TS audit requirement. Inspector review of
these audits determined that they discussed only identified findings and
recommendations; no formal audit scope was presented to demonstrate that
all TS required areas had been reviewed. Further review of the specific
findings in the 1985 and 1986 audits indicated that the areas of Health
Physics and Environmental Monitoring had received review; however, no
findings, recommendations, or evidence was provided to demonstrate that
the reactor facility ALARA program had been audited.
The inspector subsequently contacted both of the auditors included in
the 1986 IG audit team with responsibility for the Health Physics area.
Discussion with the auditors indicated that compliance with ALARA prin-
ciples was included as pert of the scope of the IG audit and that this
area had received specific review. The licensee also showed the
inspector a specific audit finding in a Department of Defense IG audit,
performed in 1987, that dealt specifically with ALARA. The inspector
determined that the ALARA program was receiving review and had no further
questions in this area.
5.0 Surveys
Routine and job related radiological surveys at the AFRRI reactor facility
are performed by ths Radiological Safety staff. The inspector reviewed
licensee performanu of these surveys by the following methods:
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discussion with licensee personnel,
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observation of performance of surveys during a Core Experiment Tube
(CET) and Exposure Room (ER) irradiation,
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review of selected facility surveys performed during 1987,
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review of the ER entry and reactor experiment logs,
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review of the following procedures:
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HPP 2-4, " Airborne Radioactivity Sampling,"
HPP 3-2, "In-Plant Reactor Surveys and Samplea.i.,"
HPP 8-1, " Radiological Survey Techniques."
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5.1 Routine Surveys
The inspector reviewed selected routine air, radiation, and contam-
ination surveys performed during 1987. Surveys were being performed
as required and received supervisory review. Appropriate actions
were taken when unusual survey results were noted.
5.2 Job-Related Surveys
The inspector determined by review of ER entry and reactor logs
that radiation surveys were routinely performed iar all irradiations
involving removal of an experiment from the core or entry to an ER.
The ER room entry procedure also requires that the continuous area
monitor reading must be below a pre-determined value prior to ER
entry. The inspector observed the performance of such surveys and
noted gamma dose rates were adequately monitored. A concern does
exist with the licensee's monitoring of beta dose rates however,
which is discussed below.
On June 3, 1987, the inspector observed operations for the opening
of reactor exposure room ER-2 and the retrieval of experimental
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samples. Upon opening of the door plug, a survey was performed by a
Health Physics representative utilizing an extended probe teletector.
Dose rates at the experiment were approximately 7 R/hr. The Reactor
Facility director stated that the fields in ER-2 were primarily due
to the fast neutron activation of the aluminum tank wall according to
the reaction Al-27 (n,p) Mg-27. Although Mg-27 decays by both photon
and beta particle emission, the Health Physics representative did not
perform a beta survey of the exposure room prior to allowing person- i
nel entry. Subsequent discussions with Health Physics supervision l
revealed that the routine surveys of both exposure rooms included I
gamma, but not beta measurements. The inspector informed the licen- I
see that the potential for beta exposures could exist. Following
this discussion, the licensee stated that he will perform a beta
radiation survey in one of the ERs after an irradiation to determine i
if significant beta dose rates do exist. The licensee also stated l
that he will forward a summary of the methods used and the survey
results to the Region I staff for review. This item is being left 3
unresolved and will be reviewed in a subsequent inspection 1
(50-170/87-02-02). I
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6.0 Exposure Control j
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The inspector reviewed the licensee's program for controlling and
monitoring personnel exposuie by the following methods:
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review of selected dosimetry records, from 1985 to present,
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review of reactor experiment and ER entry logbooks,
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review of ER pocket dosimater logs,
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observation of a CET and ER irradiation,
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discussion with licensee personnel,
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. review of the following procedures:
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HPP 0-2,." Health Physics Action Levels,"
HPP 3-1, "Reacter Exposure Room Entry."
Exposure Records
The inspector reviewed results of selected personnel monitoring records
from 1985 to the present. Exposures for the reactor staff and Radiation
Safety (SAF) personnel were noted to be quite low, typically less than
5'4 of regulatory limits. The inspector verified that dosimetry reports
from the licensee's dosimetry vendor received review and that exposures
above pre-determined action levels were investigated.
L 6.1 Job Control-
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Although radiological conditions - sghout the majority of the
reactor facility are typically ii. .uous, significant dose rates can
develop after irradiation and removal of a sample from the core or
use of the ER. The inspector determined, by review of procedures,
various logs, and the observation of two experimental irradiations,
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. activities. Procedures controlling these operations were in place
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and. typically specified dosimetry, required protective clothing,
radiological hold points, and required the presence of SAF personnel.
The inspector observed a sample extraction from the Core Experi-
ment Tube (CET) on June 2,1987. . No problems were noted during
the operation. SAF personnel responded appropriately when
questioned concerning their responses to potential radiological
accidents that might occur during the operation. Prior to the
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actual sample extraction, the licensee performed a complete walk-
through to familiarize personnel with the procedures.
Procedure HPP 3.1 requires personnel to record pocket dosimeter
readings on a logsheet after entry to the ERs. The inspector
observed an ER entry on June 3, 1987 and noted that SAF personnel
maintained effective control and complied with all procedural
requirements. The inspector reviewed the ER entry logbook against
the pocket dosimeter log and noted that on at least three occasions
in the previous thirty days, individuals had made entry to the ERs
without logging their final pocket dos 1 meter reading. Discussion
l with licensee personnel and review of the ER 'ogbook indicated,
however, that SAF personnel had been in attendance for any high- '
radiation area entries and that the above concern was a result of
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poor record-keeping. The licensee-indicated additional attention
would be directed towards insuring pocket dosimeter readings were
correctly logged.
6.2 Personnel Dosimetry Incident
On May 18, 1987, an experimenter at the AFRRI facility knowingly used
another individual's wrist (extremity) dosimeter to gain access to an
l Exposure Room (ER). Although not required by-procedure, the reactor
staff had routinely required extremity monitoring during ER entries.
l The experimenter-also wore her own, permanently assigned whole body
l dosimeter during the entry.
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l Earlier the same day, the experimenter had made an ef fort to legit-
imately procure her own wrist dosimetry from the SAF gicup. After
l' consideration, the SAF group declined to provide the wrist badge,
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as radiological conditions did not warrant it per the licensee's
procedures. The SAF group later indicated that they were not aware
of the reactor. staff's policy requiring wrist dosimetry for work in
the ERs.
The inspector's review of the incident determined that actual
radiological concerns were minor; area dose rates were relatively
low and the individual's pocket dosimeter showed no exposure after
the entry. However, as a precaution, the wrist badge used during
the entry was sent to the dosimetry vendor for immediate processing.
Af ter investigation of the above incident, the licensee's completed
and proposed corrective actinns included the following:
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1. The experimenter was restricted from use of the reactor
facilities for 30 days.
2. A memo, dated June 1, 1987, was issued to SAF by the reactor
- staff, stating that extremity dosimetry would be required for
any work in the prep and exposure rooms that required reaching
into radiation fields or handling radioactive material.
3. A memo was issued to SAF from the AFRRI Director indicating
that dosimetry shall be issued upon request by any staff member.
4. In a memo dated June 2, 1987, the reactor facility Director
i indicated the following steps would be completed:
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the controlling procedure for ER entry would be revised to
reflect extremity dosimetry requirements,
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a sign describing dosimetry requirements would be posted
in the prep area,
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The licensee also committed to the following additional actions:
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upgrades of the radiation safety training videotape.(see !
Section 3.0) will include a discussion of individual
responsibilities concerning correct dosimetry use;
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any future changes in reactor facility policy that might
affect' or change the level of support provided by the SAF
group cill be formally communicated by memo from the
reactor facility staff to the SAF group. ,
The inspector reviewed the licensee's investigation into and !
proposed corrective actions associated with the dosimetry misuse ;
incident. Adequacy of the licensee's corrective actions for this '
incident remains unresolved pending implementation and will be.
reviewed during a subsequent inspection (170/87-02-03)
7.0 Environmental Monitoring U
The licensee's Technical Specifications (TS) section 3.5.2 requires that ,
an environmental monitoring program be maintained to-determine the l
effects of facility operation on the environment. The reactor's primary
ef fluent is argon-41.
The inspector reviewed the licensee's implementation of their environ- ;
mental-monitoring program by the following methods- 1
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discussion with licensee personnel, !
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review of selected environmental data and data analysis summary
sheets for 1986 and 1987, !
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review of the following procedures:
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HPP 2-1, " Environmental Monitoring Program,"
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HPP 2-2, " Environmental Sampling and Analysis."
Within the scope of the above review, no violations were identified.
The licensee appears to be satisfactorily implementing the environmental
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monitoring program. The responsible individual appeared familiar with !
monitoring locations, procedural requirements, and historical monitoring i
results. Data received appropriate review; procedural action levels were
in place for the review of data. No results were noted which would
require restriction of reactor operation.
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8.0 Posting and labeling of Areas and Materials !
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The posting and labeling of radiation areas and radioactive material were !
reviewed with respect to criteria contained in 10 CFR 20.203, " Caution '
signs, labels, signals and controls," and IE Notice 84-82, " Guidance for
Posting Radiation Areas." Various areas under control of the Reactor
License were inspected, including Rm. 3161 (reactor deck), Rm. 3152 (upper
equipment room), Rm. 2158 (lower equipment room), and Rm.1105 (reactor
prep area).
Inspector review of these areas found most radiation areas and radioactive !
materials to be properly identified and well controlled. However, within
the scope of this inspection, the following apparent violation was
identified:
l 10 CFR 20.203 (f)(1) and (2) requires that "each container of licensed
material shall bear a durable, clearly visible label identifying the
radioactive contents." In addition, the label " thall bear the radiation
caution symbol and the words ' Caution, Radioactive Material.'"
An inspector tour of Rm.1105, the reactor prep area, on June 2,1987, j
revealed 19 55 gallon drums of packaged radioactive waste without radio- '
active material labels. Two of the containers were unbanded (open) and
were identified by the licensee to contain spent resins. Inspector review
of the " Radioactive Waste Documentation Cards," maintained by the licensee
for the various containers, indicated that six containers (S-6, S-11, S-14,
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L-5, L-7 and L-9) contained licensed quantities of H-3 and C-14 in excess
of the limits as specified in 10 CFR 20, Appendix C. The licensee stated l
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that' the containers were awaiting completion of a new radwaste contract.
Prompt corrective action was taken and all containers were properly
labeled as radioactive material.
This is an apparent violation of 10 CFR 20.203(f)(1) and (2). 3
(50-170/87-02-04). l
During the course of the inspection, the inspector had the opportunity to l
observe a 20 min, 1 MW irradiation of samples. Extended high power runs, !
such as this, may result in elevated dose rates in the vicinity of the ;
pool surface that exceed the threshold levels for classification as a high !
radiation area. The reactor deck, normally posted as a radiation area and
radioactive materials area, was reposted as a high radiation area by the
reactor staff prior to reactor operations in anticipation of possible '
elevated dose rates. The samples, removed from the Core Experiment Tube
(CET), were properly labeled by the Health physics staff prior to removal
of the material.
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9.0 Instrument Calibration Program
The ltcensee's program for calibration of radiation monitoring instru-
mentation was reviewed against criteria contained in the following:
.' 10 CFR 20.201, Surveys
AFRRI Technical Specifications
ANSI N323-1978 "American National Standard Radiation Protection
Instrumentation Test and Calibration"
Licensee Procedures:
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HPP 2-3, " Reactor Stack Gas Monitoring System"
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HPP 7-2, " Radiation Area Monitors"
- HPP 7-3, " Continuous Air Monitors"
Performance relative to the above criteria was evaluated by:
Discussions with cognizant personnel
Tour of the reactor deck, Rm. 3161
Tour of the upper equipment room, Rm. 3152
Review of quarterly calibration records for CY86 and CY87
Review of daily instrument checks for May,1987
Tour of Reactor Prep Area, Rm. 1105
Within the scope of. this inspection, no violations were identified.
All instrumentation required by Technical Specifications was calibrated
and operational. However, some programmatic weaknesses were observed
and brought to the licensee's attention. These weaknesses are discussed
below.
During a tour of the Reactor Prep Area (Rm.1105) on June 1,1987, a
survey instrument used to monitor personnel leaving the area was found to
be past due for calibration. The licensee took prompt corrective action
and removed the instrument from service. All other portable survey
instruments examined by the inspector were found to be in calibration.
Continuous Air Monitors (CAMS) are located on the reactor deck and in the
Prep Area. The CAM located on the reactor deck monitors particulate over
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the pool and upon alarm initiates a reactor room ventilation isolation.
Calibration of the CAMS is performed both by an outside vendor for
electronic calibrations and by the Health Physics staff for detector
calibrations. Although the licensee indicated that the electronic cali-
brations were being performed correctly, no documentation was being
provided by the contractor. The licensee agreer' to upgrade the documen-
tation of electronic calibrations. This will be reviewed in a subsequent
inspection (170/87-02-05).
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'The inspector also noted that the CAM calibration procedure does not
. specify acceptance criteria for the detector linearity check. Review of
calibration data indicated that linearity is normally within the 75-125%
range; however, acceptance is currently at the. option.of the technician
performing the. calibration The licensee stated that acceptance. criteria
will be established for the linearity checks performed by their staff.
A new Radiation Area Monitoring (RAM) system is being installed in the
facility. Although initiated over five years ago, the system is not yet
operational. Calibration of the current system was reviewed and the
following areas for improvement were identified:
clarification of procedure HPP 7-2, " Radiation Area Monitors," as
to the monitor acceptance criteria. This procedure currently states
calibrations are to be within a factor of 1.5; interviewed tech- !
nicians had difficulty in calculating the t.ctual upper and lower '
bounds.
use of a calibrated NBS traceable source rather than mathematical'
calculation of the dose rates. j
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improvements in the methods for determination of calibration i
distances. Current use of a frayed cord with tape markings could
lead to significant errors when the source is close to the detector
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center point.
The above items were discussed with the licensee who' agreed to evaluate
improvements to their program. The instrument calibration program will I
be reviewed in a future inspection- <
10. Exit Meeting
The inspector met with licensee representatives denoted in section 1.0 of
this report at the conclusion of the inspection on June 5, 3987. The
inspector summarized the purpose, scope, and findings of the inspection ;
at that time. 1
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