ML20245J434

Radiological Controls Insp Repts 50-054/89-02 & 70-0687/89-02 on 890328-31.Violations Noted.Major Areas Inspected:Radiological Controls,Licensee Actions on Previous Findings & Implementation of Confirmatory Action Ltr 88-15

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: ML20245J392 ML20245J411 ML20245J434
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 l

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. SNM-639 Priority -

Category -

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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Inspector [: /. R. L. Nimit2, Senior Radiation Specialist date

Apgraved dy: ah

M. Shanbaky, 011ef, Facilities Radiation

daAt

' ' 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.) . 4

Weaknesses were also identified in the areas of personnel contami. nation I

control, worker practices, and posting and barri:ading.

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8905040127 890427 '

gDR ADOCK 05000054

PDC

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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:

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licensee action on previous NRC findings

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implementation of 11oensee commitments outlined in NRC Confirmatory

Action letter (CAL) No. 88-15, dated June 30, 1989

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routine radiological controls practi s

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, J

1985 le';ter to NRC. An alpha hand ard foot monitm ves pla.ced at the j

entrance / exit of the facihty. An alpha survey meter is also available J

at the Plating lab and the CC Lab. This item is closed. l

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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 l

CFR Part 61. he licensee performed a comprehensive review to determine l

the quantities of these radionuclides contained in radwaste. 1

Verification consisted of offsite analyses of representative samples and I

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

locked high radiation areas.

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) (

regarding notifications was dweloped. Special procedures were also i

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 '

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. ,

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. j

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, I

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 i

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

) samples. This item is clescd.

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3.16 (Closed) Violation (70-687/88-02-01) I

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. ,

Visitor escorts are required to sign-off at the end of each day l

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 '

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 i

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.

based strictly on sampler flow and stack

Preliminary

release inspector

effluent review,irdicated

velocities, the particulate releases fram the

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.

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organization, staffiry, trainire ard qualification of the

radiological control organization i

- cxternal expocure control including posting, barricading and lockirg

of high rac11ation areas

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internal expos.ure controls ir:ltrlirn air sampling and use of

l respiratory prottction equipment

- radioactive and contaminated natvial control including control of

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:

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Numerous individuals were identified as sustaining personnel

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 .

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  !

violation of SNM-639 Section 3.2.1.1 (70-687/89-02-01).

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Contamination zones ard bouIdaries were posted in a haphazard

';anner. It was unclear in some instances where the clean zone ended

a d the contaminated zone began.

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1:usannel exhibited poor practices when removing protective clothing

ed exiting contaminated areas.

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Fealth Ihysics Technicians, irdicated as fully qualified to monitor

safety significant activities (e.g. manipulator repair) did not have

complete qualification record sign-offs.

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Personnel were using the incorrect instrimient when surveying fe,;

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:

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inprovirg management of NFC inspection findings aM

documentation to chc= Late appropriate closure action

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enhancement of rvisory and management oversight of facility.

activities includ worker practices

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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

'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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