4i (

C. 'Lcn No. SMB-179jif fin I nspec ion No.- 40-672

etts ~01742

inspection conducted ~by Mr, Jerlman f'nd 31, 1974 of activifties authorize A E9 anid~to ~the'discussionsl>6f~our findin hlMr. Tuffin and o'th~er mmbes of yoitr~staffof the inspecztion.

ing this inspection are described' in the Regulatoryion Rport which is enclosed~with this le~tter. Withnspectibn consisted 4 ~sectv examination ofresentative records, inevesTihpronlby the inspector, and observations. by the in~spector.

verified the' steps yoIuhd t~ae','o..cdrec the

.1974 following& our last. inspection.- TWe& hiaxe noregarding thedsejmatters.,~

f this inspection, nio violations or safety

d&.

Section 2.790 of the AEC'~s "Rules of Practice",

Nuclear Metals, Inc. -2-

No reply tot this letter is required; however, should you have anyquestions concerning this inspection, we will be pleased to discussthem with you.

Sincerely,

Paul R. Nelson, ChiefRadiological & EnvironmentalProtection Branch

Enclosure!RO Inspection Report No. 401-672/74-01

bcc (w/encls):RO Chief, FS&EB.RO:HQ (4)L:D/D for Fuels and Mat'lPDRNSICRO Files-DR Central FilesState of Massachusetts

U. S. ATOMIC ENERGY COMMISSION

DIRECTORATE OF REGULATORY OPERATIONS

.REGION I

RO Inspction Report No.: 40-672/74-01

Licenhee. Nuclear Metals. Incorporated

2229 Main. Street

, . 40-672 f,.,Docket No.:

License No.: SMB-179

3

Concord, Massachusetts..Locatio~n:

Type of Licensee: 'Product Manufacturer

.Type. of• hspectio: Routine, Unannounced

.... '.:-May 30-31, 1974Dates of Inspection:. y ..... ,.1974

Dateg Of Previous 1isp6ccion: December 27-28, 1973, Januaty 8-9, 1974

Reporting, Ins-pectror:j

Phý

Accompan yi'ng .1inspectiors:Date

.i.

Date'

Other Actomnpanying Personnel: _ ,_............._ __-

Reviewed By: 2 .

1-e., J. Knapp, enior, Facilities RadiologicalC .Protection Section

Date

Date

SUMMARY OF FINDINGS

Enforcement Action.

A. Violations

None

B. Safety Items,

None

Licensee Action onm.Previously Identified Enforcement Items'

The following items pertain to the Rgjion I letter dated February 15,. 1974and the licensee's letters dated March 27, 1974 and April 12, 1974, des'cribing.the corrective actions.

A., Enclosure 1, Item l.a. invo-lved failure to adequately evaluate handexposure. The inspector verified the licensee'S corrective, acttion.(Details, Section 3)

B. Enclosure 1, Item l.b. involved failure to measure alpha and beta"gamma, concentrations in worker's breathing air. The inspedct• vet-ified the licensee's corrective action. (Details, Section 4)

CI Enclosure 1, Item l.ci involved failure to survey stack releases forbeta-gamma activity. The inspector verified the licensee's correctiveaction. -(Details, Section 5)

N. Enclosure 1, item l.d. involved failure to survey liquid waste dis-posed to plant property for beta-gamma activity. The inspectorverified the licensee's corrective action, (Details, Section 6)

Ei Enclosure 1, Item 2 involved failure to analyZe environmental waterand soil samples for beta-gamma activity. The inspector verifiedthe licensee's corrective action. (Details, Section 7)

F. Enclosure 2 involved failure to identify and control beta-gamma con-tamination associated with the depleted uranium operation. Theinspector verified the licensee's corrective actions. (Details,Sections 8, 9, 10 and 11)

Unusual Occurrences

None

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4"

Other Significant findings

A. Current Findings

R. Robie, Comptrolier and, Director of Administtation, resigned onMay 1, 1974.

B. Status of Previousl)y Rported nnr•1.Oled Items

Not applicable

Management Interview

At the conclusion of the inspection, a management, meeting was held withthe following persons in attendance:

Nuclear Metals

W. B.' Tuffin, PresidentB. MacKay,. Director, ManufacturingA. Gilman, Director, Quality Assurance and Industrial and Radiation SafetyR. Franks, Safety Officer

Atomic Energy Commission.

P. C. Jerman

The inspector reviewed the scope of the inspection and stated that noviolations or safety items had been noted. The inspector discussed

the progress in the radiation control ptogram to date, and the need forcontinued efforts to sustain the program..

...... . ...

DETAILS

1. Persons Contacted'

A. Gilman, Director, Quality Assurance and Industrial and RadiationSafety

R. Frank, Safety Office r

2. Scope of Operations

A. A licensee representative stated the company no longer possessesspecial nuclear material. The licensee requested the Directorateof Licensing, in April, 1974 to terminate the SNM license.:

B. Under the source material license depleted uranium is cut, meiltedand molded into shields. Depleted uranium is also being extruded.into rods from which penetrators are machined..

3,.0 External Exposure

A. The inspector reviewed records of external exposure from December 1,1973 to the present. It was observed that the maximum exposuresreceived by employees during calendar year 1973 were 1230 mrems tothe whole body and 6400 mrems to the skin of the whole body. The,maximum exposures during the first quarter of 1974 were 90 mremsto the whole body and 1400 mrems to the skin of the whole body.The maximum exposures for April, 1974 were 40 mrems to the wholebody and 220 mrems to the skin of the whole body.

t. Records examined showed that five foundry employees were monitoredfor hand exposure during the'first quarter of 1974. The maximumhand dose received was. 2620 mrems. The maximum hand dose receivedby foundry employees during April, 1974 was 510 mrems.

C. The inspector substantiated statements in the last paragraph onpage 1 and the first paragraph on page 2 of the licensee's letterof March 27, 1974. Records examined showed that in April, 1973,four. foundry employees handling uranium were monitored for handexposure. The maximum dose received was 3,000 mrems. In June,1973, hand monitoring devices were provided to six foundry employees.The results showed that no employee received more than a minimumdetectable dose (less than 30 mrems). The licensee representativewas unable to explain why these results were so low.

4. Internal Exposure

A. Records examined showed that the air samples taken at the foundryfurnace since November 30, 1973 were counted for alpha and forbeta-gamma radiation. The filter paper for this sampler is

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changed and c'unted monthly. The beta-gamma is primarily dueto Th-234 for which the MPC for employee exposure is 3xlO- 3 uCi/mi..or 66,600 dpm/M 3 . The MPC for alpha is 1xl0-1 0 uCi/ml. The high#est monthly average concentrations were 33.7 dpm beta-gamma/M3

and 9xi0- 1 4 uCi/alpha/ml. The inspector observed that there wasrno fixed air sampler in the vicinity of a second foundry furnace.,Records showed that air samples were taken with a portable airsampler during the first half of February, 1974 at variouslocations in the building including the foundry, weld shop, 1400ton press, fabrication shop, and the machine shop. The maximumresults were 16.9 dpm beta-gamma/M3 and 1.4x10-13 uCi alpha/ml.

B.' Records examined showed that use of a lapel air sampler-was init-iated on April 8, 1974. During April it was used on four occas-ions by employees in the foundry area during furnace melts andwhile cleaning crucibles. It was used on one occasion in themachine shop while machining penetrators. The maximum result was1558.7 dpm beta-gamma/M3 . The record showed that four additionalsamples were taken during-May. The results of these had not beenreceived from the vendor who counts the samples. A licenseerepresentative stated that in the future, an employee would wearthe lapel air sampler almost every work day.

5. Stack Air Monitoring

A licensee representative stated that filter papers in samplers satm'pling exhaust air emitted from 16 roof exhaust stacks were changedand counted monthly to determine activity concentrations. The recordsexamined by the inspector showed that the air samples collected sinceNovember 28, 1973 were counted for beta-gamma and alpha activity.The applicable maximum permissible concentrations are 1x10-9 uCi beta-gamma/ml (2220 dpm/M 3 ) and 4xlO-1 2 uCi alpha/ml. The "left housevacuum cleaner exhaust" stack showed the highest beta-gamma concentra-tions, ranging from 111 to 1335 dpm/M 3 for the five month period fromDecember through April. The next highest beta-gamma concentration was27 dpm/M 3 for the machine shop stack for the month of January. Themaximum alpha concentration was 3.5xi0- 1 2 uCi/ml for the machine shopstack during January. The "left house vacuum exhaust" stack showed2.9xI0-1 2 uCiU alpha/ml during the month of December.

6. Liquid Waste

A licensee representative stated that liquid waste from the process isdrained to a tank in the acid house on the property. The waste isneutralized, stirred and sampled. Records examined showed that liquiddumped from the acid house to a bog on the property on March 20, 1974showed 6.25 ugm U alpha/ml. The MPCGis 4x10-5 uU alpha/ml (120 ugmsU/ml). With respect to the beta-gamma concentration, a licenseerepresentative produced the purchase requisition for the analyticalwork which specified that the sample supplied to the vendor was to be

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analyzed for beth alpha and beta-gamma activity. The vendor hadneglected to perform the beta-gamma analysis. The liceasee repre-sentative stated that not all of the sample taken was supplied to

<the vendor. The residual had been saved and was sent to the vendor

for beta-gamma analysis. The analysis results had not yet been

received from the vendor.

7L Environmental Monitoring

A licensee representative stated that environmental water and soil

samples were taken during May 1974 and that the samples were sent toa vendor for beta-gamma and alpha analysis. The analytical.resultslhad not been received.

8. In Vivo Counting

The inspector examined records which showed that five foundry employeeswho worked with depleted uranium were lung counted on January 18, 1974.

Each individual showed a normal spectrum with no indicated activity

above background.

9. Uranium Processing Areas

A. The inspector visited the foundry area and noted that it had beenmade an isolated area. Entry was by way of the foundry changeroom. Workers don plant issue trousers, shirts and shoes in theplant's main change room upon reporting to work. Those who workin the foundry put on rubbers and a lab coat in the foundry

change room. Gloves are also required. Upon exiting the foundryarea, the rubbers and lab coat are removed in the foundry changeroom. The workers check their persons with an Eberline RM-14*

beta-gamma monitor located in the change room. Gloves are changeddaily and monitored routinely during use. A licensee representa-tive stated that they planned to install a wash basin and a toiletin the foundry change room. A permanent barrier in the form ofan iron fence had been placed at all access points to the foundryarea. Prominent signs were displayed which designated the foundryarea as a radiation area.

B. The inspector observed in the machine shop that each machine used

for machining uranium was marked off by yellow and magenta rope.

The operators working at these machines wore lab coats and rubbersover plant issue clothing and shoes. Gloves were also worn. Alicensee representative stated that the operators removed the labcoats, gloves and rubbers before leaving the restricted zone iso-lating the machines. An Eberline RM-14 beta-gamma monitor was

used for self-contamination checks.

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C. The inspector observed that a room was set up for the cutting.of uranium rod stock into penetrator lengths. Upon enteringthe room, Tubbers and lab coats are donned and are removedprior to exit. An Eberline RM-14 beta-gamma monitor in theroom is used for self-contamination surveys.

P. A licensee representative stated and records of surveys examined,verified that all areas in which uranium is processed were cleanedto a maximum of 0.07 mR/hr at 1 cm. Following this the floor ofthe foundry was painted with an epoxy paint.

E.• The inspector noted that seamless trays are used to containuranium products and that metal equipment had replaced woodenequipment to facilitate decontamination. Plastic bags.are usedto contain uranium when stored between processing operations.Additional sucker hoses are installed at the furnace stations.A licensee representative stated that they planned to move thecrucible cleaning hood to a furnace platform. Uranium is nolonger placed in the stock room. When received, the containersare surveyed for surface contamination and placed in a designatedarea in the Butler Building. The containers are removed to. the L

foundry area as needed for processing.

10. Controls

A. A licensee representative stated that cleanup of the entire plantwas completed. All areas were cleaned to a level not exceedinga 0.07 mR/hr reading at 1 cm. through the thin window of the GMdetector attached to the portable survey instrument. An expan-sion joint in the concrete floor of C Building (passageway toShipping and Receiving) was found to show 0.15 mR/hr at 1 cm.The joint was jack hammered and the level reduced to less than0.05 mR/hr at 1 cm before the floor was patched. All entrancesto the building and outside areas within 7 feet of the entranceswere surveyed and found to show less than 0.05 mR/hr at 1 cm.Survey reports reviewed by the inspector verified these state-ments. Wipes of outside areas showed no more than 10 dpm beta-gamma/100 cm2 . The inspector noted in reviewing records thatwipes were taken monthly at 19 locations in the building. Thewipes were counted for beta-gamma and alpha since January 1, 1974.and none showed in excess of 50 dpm/l00 cm2 . Janitor mops weresurveyed routinely by the licensee and no readings in excess of0.025 mR/hr at 1 cm were foundi The inspector surveyed 5 janitormops that had been used in various parts of the building exclud-ing the shop areas. The maximum reading found was 0.15 mR/hr at1 cm (background was 0.10 mR/hr). The inspector noted that bothbeta-gamma and alpha monitoring instruments were located at therear exit hall of the building, which exit allows access to theemployee's parking lot.

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11. Training

The inspector reviewed written procedures which had been-implemented I

to establish the radiation protection program. These procedurescovered the following subjects:

Foundry change room layout and procedures for use.Area assignments for housekeeping activities.Procedures for visits to the foundry.Procedures for handling uranium.Procedures for control of uranium contamination.Procedures for use of-work clothing and safety shoes:.Uranium exclusion from stock room.Changes in foundry procedures and equiptentiControl of personal uranium contamination.

The employees were instructed in these procedures by supervision.A series of formal meetings were conducted by Industria! and Radifatio0nSafety during February and May, 1974.. The inspector reoviewed the min-utes of these meetings.

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P.' J. Knapp, Senior, Facilities Raiological Protection Section

INSPECTOR EVALUATION'

Nuclear Metals, Inc..2229 Main StreetConcord, Massachusetts 01742License No. SMB-179

I was favorably impressed with the progress this licensee has-made inestablishing an acceptable radiation control program. The licenseeclaims they are spending $40,000 to establish this control. The foundryis isolated with entry and exit through a change room. Other locations Iwhere uranium is processed have some degree of isolation and appear to.be adequately controlled. I was surveyed upon arrival and upon leavingthe plant.

The poor control which this licensee previously maintained over hisdepleted uranium operation dictates that he be kept under close inspectionsurveillance until he demonstrates that he cat sustain an adequate controlprogram.

This licensee is currently classified E-3. I believe the activities underthis-license are in the real% of major processing, and that the, classificaation:should be changed to B-l. In any event, the next inspection should

be scheduled in six months, November 1974.

. Phi ip C. JermanRadiation Specialist

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