ML20245J434
| ML20245J434 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 04/26/1989 |
| From: | Nimitz R, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245J396 | List: |
| References | |
| 50-054-89-02, 70-0687-89-02, CAL-88-15, NUDOCS 8905040127 | |
| Download: ML20245J434 (9) | |
See also: IR 05000054/1989002
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U. S. NUCLEAR REGUIATORY OCNMISSION
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REGION I
50-54/89-02
Report Nos.
70-687/89-02
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50-54
5
Eocket Nos.70-687
R-81
License Nos.
Priority
Category
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Licensee:
Cintichem, Incorporated
P. O. Box 324
Tuxedo, New York
Fhcility Name:
Hot laboratory and Reactor
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Inspection At:
Tuxedo, New York
Inspection Conducted:
March 28-3L 1989
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M/ E/87
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Inspector [: .
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/ R. L. Nimit2, Senior Radiation Specialist
date
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daAt
Apgraved dy:
M. Shanbaky, 011ef, Facilities Radiation
' ' dath
Prutection Section
Inspection Summary: Inspection Conducted on March 28-31, 1989 (Cambined_
Report Nos. 50-54/89-02; 70-687/89-02)
Areas Inspected: Routine unannounced radiological controls inspection of the
following: radiological controls; licensee action on previous findings and
licensee implementation of Confitu tory Action letter No. 88-15.
Results: One apparent violation was identified (failure of personnel to make
notifications of personnel contaminations as requitwi. Details in Section 5.) .
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Weaknesses were also identified in the areas of personnel contami. nation
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control, worker practices, and posting and barri:ading.
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8905040127 890427
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ADOCK 05000054
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DETAIIS
1.0 Persons Contacted
1.1 Cintidiem, Incorporated
+*J. McGovern, . Plant Manager
+*L. 'Ibelin, Staff Health Physicist
+J. Stewart, Radiation Protection Supervisor
+*W. Ruzicka, Manager, Nuclear Operations
- L. Babcock, Health Ihysics Tedinician
- 'Ihe above individuals atterded the exit meetirx3 on March 31, 1989.
+ Participated in the April 5,1989 telephone discussion.
'Ihe inspector also contacted other licensee personnel.
1.2 NRC
+P. Swetlard, Chief, Projects Section 2B
+N. Dudley, Project Engineer
+R. Bellamy, 011ef, Facilities Radiological Safety and Safeguards
Branch
+J. Roth, Project Engineer
+ Participated in the April 5,1989 telephone discussion.
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2.0 Purpose of Inspection
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This was a routine radiological controls inspection. 'Ibe following
matters were reviewed:
licensee action on previous NRC findings
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implementation of 11oensee commitments outlined in NRC Confirmatory
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Action letter (CAL) No. 88-15, dated June 30, 1989
routine radiological controls practi s
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3.0 Licensee Action on Previous Findings
3.1
(Closed) Violation (70-687/85-01-01)
Alpha haal and foot ccunter not available at entrance / exit to facility.
'Ihe licensee implemented the corrective action outlined in his ML% 29,
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1985 le';ter to NRC. An alpha hand ard foot monitm ves pla.ced at the
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entrance / exit of the facihty. An alpha survey meter is also available
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at the Plating lab and the CC Lab. This item is closed.
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3.2
(Closed) Inspector Follow-Up Item (70-687/85-02-01)
Paview licensee method of verification of C-14, 'Ib-99 and I-129 for 10 CFR Part 61.
he licensee performed a comprehensive review to determine
the quantities of these radionuclides contained in radwaste.
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Verification consisted of offsite analyses of representative samples and
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quantification using appropriately benchmarked computer codes. Wis item
is closed.
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3.3
(Closed) Violation (70-687/87-01-08)
Failure to post a high radiation area in accordance with 10 CFR 20.203 (c) (1) . m e licensee implemented the enrrective action outlined in
his April 23, 1987 letter to NRC. Inspector tos s during the inspection
and performance of irdepeMent radiation surveys did not identify any
problems. This item is clord.
3.4
(Closed) Violation (70-687/87-01-09)
Failure to lock a high radiation area in accordance with 10 CFR 20.203 (c) {2) (iii) . We licensee implemented the corrective action
outlined in his April 23, 1987 letter to NRC. A special high
radiation area access control procedure (HP-A-12) was developed to
provide guidance for access control. Inspector tours during the
inspection a M performance of independent radiation surveys did not
identify any concerns. W is item 1s closed.
We inspector did identify that the lock for the QC P-32 vault, located
on the reactor cperating floor, was broken. Access oculd easily be
gained to the vault. Be inspector noted this area was designated as a
locked High Radiation Area. The licensee's Radiation Protection
Supervisor was unaware of the broken lock. %e licensee immediately
initiated action to lock the vault. Although the area did not exhibit high
radiation, the fact that the lock was broken, the area was required to be
secured, and the licensee's radiation protection supervisor was unaware
of the broken lock indicates some apparent weaknesses in oversight of
3.5
(Closed) Violation (70-687/87-01-02)
Failure to make appropriate notifications follcuing an apparent
overexposure. W e licensee implemented the corrective action outlined in
his April 23, 1987 letter to NRC. A special procedure (HP-B-11)
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regarding notifications was dweloped. Special procedures were also
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developed to review anomalous exposure results. Appropriate
notifications are to be made if overexposure are identified. 21s item
is clesed.
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3.6
(Closed) Violation (70-687/87-01-04)
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Failure to evaluate potential exposures to hands. We licensee
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implemented the corrective action outlined in his April 23, 1987 letter
to NRC. W e licensee now provides finger ring TLD badges to monitor
exposure to the hands. Anomalous dosimetry readout results are
investigated. h is item is closed.
At the time of this inspection, procedures for use of licenseo supplied
ring TLDs were not in place. Procedures were in place for use of vendor
TID rings. W e licensee-supplied badges were being used to quickly check
exposures following a work activity in lieu of waiting for vendor
results. The use of the supplemental badge was a good licensee
initiative. This matter will be reviewed during a future inspection.
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3.7
(Closed) Violation (70-687/87-01-05)
Failure to document or maintain surveys for manipulator hand repair. We
licensee implemented the corrective action outlined in his April 23, 1987
letter to NRC. Special procedures requiring documentation of surveys
were established. Inspector review of recent manipulator repair
activities indicated th'mantation of surveys was performed. his item
is closed.
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3.8
(Closed) Violation (70-687/87-01-01)
An individual sustained an overexposure of the extremity while performing
manipulator repair. W e licensee implemented the corrective action
outlined in his April 23, 1987 letter to NRC. A special prtx:edure for
manipulator repair was established. Standard radiation work permits for
the task were established and allowable maximum exposure limits on
manipulator components handled was established. his item is closed.
3.9
(Closed) Unresolved Items (50-54/86-04-03; 70-687/86-05-03)
NRC to review adequacy of airborne radioactivity sampling during hot cell
operations. Airborne radioactivity sampling was reviewed during the
inspection and during NRC I
ion No. 70-687/88-02. A violation was
issued during the referenced
ion for inadequate air sampling
within the hot cells. W e licensee implemented. corrective actions for
the violation (refernnce NRC Item 70-687/88-02-03). Wese items are
closed.
3.10 (Closed) Inspector Follow-Up Item (70-687/86-05-02)
Licensee to review potential for plateout of radioactivity on the walls
of containers used to collect ccznposite waste samples. We licensee
performed an evaluation of plateout. Although none was found, the
licensee changed the type of container used and now acidifies composite
waste samples to minimize plateout. mis item is closed.
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3.11 (Closed) Unresolved Item (70-687/88-04-06)
Licensee to review adequacy of liquid effluent release limits. The
licensee was using a limit based on Sr-90 and no apparent evaluation of
concentrations of alpha emitters relative to applicable release limits
was made. The licensee's review indicated no significant release rates
to date have occurred. Release rates to date have met requirements of 10 CFR 20.106 using the release limits based on Sr-90.
Inspector review
irdicated release rates met 10 CFR 20.106 requirements. The licensee
revised procedures to incorporate release limits outlined in 10 CFR 20,
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Appendix B to account for other radionuclides. This item is closed.
3.12 (Closed) Unresolved Item (70-687/88-02-05)
Licensee to evaluate adequacy of maximum permissible concentration (MPC)
used for hot cell work. g e licensee conclud g the MPC should be lowered
by a factor of 10 (3 x 10
uCi/ml to 3 x 10
uCi/ml). Procedures were
changed to reflect the new MPC. No significant, apparent exposures had
occurred based on using the lower MPC value. This item is closed.
3.13 (Closed) Unresolved Item (70-687/88-02-03)
Licensee to complete skin dose evaluation for individual who was
contaminated on the lower left leg during hot cell work on March 3, 1988.
The licy completed the dose evalt.ation. Maximum exposure sustained
to 1 cm of skin was about 410 milliram. No overexposure occurred. This
item is closed.
3.14 (Closed) Violation (70-687/88-04-02)
Failure to monitor effluent releases from the hot cell emergency
ventilation system. The licensee implemented the corrective action
outlined in his August 12, 1988 letter to NRC. The licensee
installed a calibrated isokinetic particulate and iodine sampling
system on the exhaust. The exhaust was tied into the existing
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facility effluent release pathway (stack) which provides for
monitormg of noble gases. This item is closed.
At the time of this inspection, no procedures were in place for
performing periodic testing ard maintenance of the new particulate and
iodine monitoring system. 7his matter will be reviewed during a
subcequent inspection.
3.15 (Closed) Violation (70-687/8S-02-03)
Failure to Ironitor airborna radioactivity in tue hot cells. 3he licensee
implemented the corrective action outlined in his May 16, 1988 letter to
NRC. Special procedures were established to provide guidance for
monitoring airborne radioactivity in the hot cells. Special sampling
equipment has been purehased ad placed in service to collect air
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samples. This item is clescd.
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3.16 (Closed) Violation (70-687/88-02-01)
Licensee did not provide adequate instruction to a visitor regarding
personnel contamination nonitoring contrary to 10 CFR 19.
The licensee
implemented the corrective action outlined in his May 16, 1988 letter to
NRC. The licensee purchased a high sensitivity portable frisking
machine. All personnel were provided guidance on use of the equipment.
Visitor training has been upgraded to address contamination monitoring.
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Visitor escorts are required to sign-off at the end of each day
indicating the irdividual performed an adequate frisk. This item is
closai.
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3.17 (Closed) Unresolved Item (50-54/79-02-07)
Licensee to review the isokinetic sampling characteristics of particulate
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effluent sampling system. The licensee reviewed the sanpling
characteristics and ensured flow rate of the samples was camparable
with fan flow in early 1979. A re-review of this matter prompted by
NRC Inspection No. 70-687/88-04 found that the particulate sampling
velocities for the reactor building and hot lab were based on rated
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fan flow rather than actual exhaust flow from these two areas. The
sampling system flow rates were re-At in December 1988 to reflect
actual velocities encountered in the exhaust ducts. This item is
closed.
Preliminary inspector review,irdicated the particulate releases fram the
based strictly on sampler flow and stack
release effluent velocities,
reactor building may have been slightly underestimated while those from
the hot lab may have been overestimated. The need to update previous
effluent release information will be reviewed during a subsequent
inspection. No apparent significant particulate releases were noted.
3.18 (Closed) Violation (70-687/88-04-03)
Failure to perform quarterly testing of hot cell emergency exhaust
ventilation system. The licensee implemented the corrective action
outlined in his August 12, 1988 letter to IRC. This ventilation
system was added to the quarterly testing schedule. The charcoal
filter system was tested and found to perform below acceptance criteria.
Charcoal filters were replaced, tested and found to meet acceptance
criteria. This item is closed.
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4.0 Review of Confirmatory Action Intter Implementation
me inspector reviewed the implementation of licensee commitments
documented in NRC Confirmatory Action letter (CAL) No. 88-15, dated June
30, 1988. W e CAL dealt with unmonitored releases from the hot cells
via an unmonitored emergency ventilation system.
Prelimina?'r review of implementation was made during NRC Combined
Inspection Nos. 50-54/88-02; 70-687/88-06.
Se inspector evaluated implementation via review of on-going hot lab
operations, review of riev'n=ntation, and discussion with personnel.
Inspector review indicated the licensee implemented the commitments
documented in the CAL.
We following matters were identified as needirg further licensee
attention:
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At the time of the inspection, no procedures Imd been
established for periodic surveillance aM maintenance of the Hot
Cell Emergency Ventilation System particulate and iodine effluent
sampling equipment.
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The Reactor Building Emergency Ventilation System, which is not
routinely used, was found to tie into the plant release point
(stack) down stream of the particulate and iodine effluent monitors
that have been deternuned to collect samples in an isokinetic
manner.
We above matters will be reviewed during a subsecpent inspection. Se
licensee irdicated the above matters would be reviewed
5.0 Routine Radiological Controls Review
he inspector toured the facility durirg the inspection. We following
matters were reviewed.
organization, staffiry, trainire ard qualification of the
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radiological control organization
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cxternal expocure control including posting, barricading and lockirg
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of high rac11ation areas
internal expos.ure controls ir:ltrlirn air sampling and use of
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respiratory prottction equipment
radioactive and contaminated natvial control including control of
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contaminated areas
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Evaluation of licensee perfomance was based on review of on-going
activities ard discussions with personnel.
Within the scope of this mview the following observations were made:
Numerous individuals were identified as sustaining personnel
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contamination, primarily on the foot areas, when exiting the main
access / egress point of the reactor buildig ard hot cell area. 3he
contamination rarged from 1000 dpnV100 cm to 300,000 dp3100 cm .
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The inspector ard a licensee Radiation Protection Supervisor
estimated that 20% of the individuals simply washed their shoes off
at a nearby hot sink and exited the facility. Them was no apparent
follcw-up to identify sources of the routine personnel contamination
ard initiate action to preclude recurrence.
The irepector noted that SNM License No. 639 requires in Section
3.2.1.1, that hard ard foot counters capable of detecting altlia ard
or beta-gamma radiation as appropriate shall be provided at the
routine exits of the facility. Employees shall be required to
monitor themselves and report contammation levels above the alarm
set points. Contrary to the above requirement, numerous individuals
sustained personnel contamination above the alarm set points and
nade no notification of the event. Rather, the individuals cleaned
their shoes and simply left the facility. This is an apparent
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violation of SNM-639 Section 3.2.1.1 (70-687/89-02-01).
Contamination zones ard bouIdaries were posted in a haphazard
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';anner. It was unclear in some instances where the clean zone ended
a d the contaminated zone began.
1:usannel exhibited poor practices when removing protective clothing
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ed exiting contaminated areas.
Fealth Ihysics Technicians, irdicated as fully qualified to monitor
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safety significant activities (e.g. manipulator repair) did not have
complete qualification record sign-offs.
Personnel were using the incorrect instrimient when surveying fe,;
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alpha contamination in the QC lab area.
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Potentially contaminated protective boots were left on the reactor
bridge in a clean zone.
The licensee indicated the above matters would be reviewed. The inspector
irdicated that the number of poor work practices observed appeared to
irdicate weaknesses in oversight of facility activities.
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'Ihe. licensee indicated an Action Plan would be devel
to address the
inspector concerns. 'Ihe licensee indicated the follow
areas would be
addressed as a minimum:
inprovirg management of NFC inspection findings aM
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documentation to chc= Late appropriate closure action
enhancement of
rvisory and management oversight of facility.
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activities includ
worker practices
enhancement of audits
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contaminai. ion control
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adeguacy ot radiation protection personnel staffing levels
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training and . qualification of radlation protection personnel
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'Ihe licensee indicated the Action Plan would be submitted by April 31,
1989.
6.0 Exit Meetirn
'Ihe inspector met with licensee representatives (denoted in Section 1.0)
at the conclusion of the inspection on March 31, 1989. 'Ibe inspector
sunmarized the purpose, scope and findings of the inspector.
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