~, , I I b ,(No. 2) ! POST-INSPECTION COVER SHEET (Region I Work Form) h From: Principal Inspector To Senior $, /1 V Subj:__ INSPECTION OF /e , Z, X OfA .4A/ •, 4 Ž ~ A /. 2 Id. ON t+-•/7 0 C (Dates) (Facility or License #) Draft'inspection report completed and attached. field notes completed ,eder daTrached. -List: 2. /V Draft documentation letter completed and attached (a standard form with new or modified paragraphs desired) - List of updated outstanding items completed and attached.. • t-" /f " " ~ (list will .be with- it). Inspector.'s evaluation memo attached with assist inspector's• memo attached thereto. evaluation Standard Data Sheet '' Additional Comments: (Principý'!' Ins c6~ File: Senior's File (Cover Slheet Only) NOTE: Cross out and initial sections not applicable. V.0 FEB 15 1974 License No. SM-65 7Nuclear Metale, Inc. Actention: Mr. W. B. Tuffin President 2229 Main Street Concord, iassachusetts 01742 SMB-179 Inspection Lo. 70-02173-05 40-672173-02 Centlemen: This refers to the inspection conducted by Mr. Jerman of this office on Decermber 27-28, 1973 and January 8-9, 1974 of activities authorized by AE, License Nos. S10-1-65 and S?43-179 and to the discussions of our findigs held by Mr. Jerman with Mr. Tuffin and to subsequent telephone discussions between Mr. Knapp and Mr. Gilman on January 18, 1974 and between Nr. Jerran and Mr. Tuffin on January 21, 1974. Areas examined during this inspection are described in the Regulatory Operations Inspection Report wvhjW.4 is dnelosed with this letter. Within these areas, the inspection consisted of selective emin-lations of procedures and reprasentative records, interviews with personnel, measurements made by the inspector, and observations by the inspector. In addition, your activities in response to telephone conversations on January 4 and 7 as confirmed by our letter to you dated January 7, 10974, were reviewed. Our inspector also verified the steps you had taken to correct the vioitioirr brought to your attention in our letters dated April 23, 1973 and December 12, 1973. lie have no further questions regarding Items l.a, 1.b, l.c, and l.e of Enclosure I and Items l.c, 2, 3, and 4 of Enclosure 2 to the April 23, 1973 letter;land Item 2 of the Enclosure to the December 12, 1973 letter. With regard to Items l.b, l.c, 1.d and 2 of Enclosure I to this letter, we note that you had taken stepa to correct these violations but your evaluations were inadequate in that they failed to include provisions to cover beta and gamma radiation.. During this inspection, it was found that certain of your activities appeared to be in violation of A.ZC requirements, and another activity appeared to ralse a question concerning the safety of operations. The items and references to the pertinent requirements and to generally accepted guidance are listed in the enclosure to this letter. This letter constitutes a notice sent to you pursuant to the provisions of Section 2.201 of the AEC's 'Rules of Practice", Part 2, Title .0, Code of Federal Regulations. Section 2.201 requires you to submit to this office twithin 20 days of your receipt of this notice, a written statement of explanation in reply, including: (1)*steps which have -Knapp 21 /74 Nelson 2/ /74 Jerman 2/ /74 Crocker 2/ /74 77-1. . O'Reilly 2/ /74 at -Nuclelar'.Metal s,. Inc. ;-2- '3 '3 ,rdat-de withS~ectibit. 2.7900 of. t-hAeC! M 'I Rues-6f ?racdtice'~, Til O..Cd of Fedlr Regi1at ions., A -Copy this letter .enc o~sed msp~ction' report wiU be pace in t AECs Fýublie ~t ~Q~i.f--this report donta ns any ipf~rbi~tion tha~t yu(or intacor)beiee-,6 e!pi~~et~at~jv~ it is nessry tzt r) I, -~r bý1i -", toy't I thý o~k ,tM yo ~p i catpion within 20d A00itt ;Athl rmt f p pb cdisclo'sure. Any suhqp~i inms Ia full3'statemneit of 'here onhs on the ba~sis'f wbtcb. it~ is Ithbat the iinfoimation is' proc'ri-etary, and shu~- e preparedý so, 'bpretary in~formtion identified in the ap-0plicadtion. is contained .,art part of the docuit If we- do not' hear fiom you in this withiin the 9 -ecif~ied 'period,,,the, ~ ot wll, be placgd int the Documient Room. Should you ýhavei any'qu'stjtjos- concetning this, insoeto~w hmiiyu ple4~edto, di4cs 'V ilb j-ame~s P. OReilIy tnclopureý: Ds crpipn lof 0.V1~1&tldns RO 112 ectio Reot No-.7O8/3O 4O72o3O appa /74 2/ 'V anld Crocke21/1 /74 ,2Ael/ /._1-7-7 s 66fi-i 4 //1 // /74 3', ENICLOSUlR k• N. DPSCRTPTIlV OF VIO! a 14&:U jig Are- eoýisider .4, b of p 4 a.ý b.4 c. o~i.7rrj~ to, tde e~u~ iaut yoiu oa1d -t.iik si~ was nTe pp SW p r YtIassure, 9VE thh'atteffluents veIeasdpe fri rveys yoz tý 10 Cfl ' "d. et ud* -ifrestrieted, areAs' t . ii~ciad an~ysi res~iltiBig '4 'a Spsceifflclly, ' f~ setagami qý,egit iwoi san _ompoes~Ti norc~ e oain 4 4 d. Contrary, 'totliis! requirement, you failed to mike sluth sUkVeys as Oere n4cessary to asure' compliaiieeiuith 10' CYR 20,.106, "onetr ations in eflinst n~tttdareas'" a regulation radioativemteria1 eontalined'ini~i Iics dtcagd rmyu pleaito th -urstitd ra Specifically, tbe.ýsurveys chih you4di 4<condukt, of your liquid vasti, iesultig froni the6 dissolotion of copper f rom ujranui -238,, prior? to it dispos al to. abg nyu property,, .#4 not: includsemeagurement lof betq:7s~iia emitting materilsv4ich maW aebnpeet 2.. condition 18 of, theý license requiires, that muaterial piossessed 'and used In& ac o rdani&e wi th~ pcd 8ubm -tte ' with -yo. r:tcs, se plidato dite4 6~ruay 26, 19,69. Setion II of ths prcedlurqi~s entitled Realth S & afety"'. It "c0ifi5 az Ors, the rquirement, show-A belowEnvironmental water aMi &oil sAMplp a ~lyzed annually, il be ollected a, d Contrary to this requiremenit, the envirvonmntal *ater -ndd. soil, samples collected were not anayzed for the concentration of beta-gauna emitting materials wohich mnay haeve been preseut.ý Wei is 4n uncorrected Violation. ENCLOSURE NO. 2 DESCRIP1ON OF, $AkthTY ITU4 .ear Metals,, Inc. ManStreet ~r;Ma ssachusetts 01744 te: d-radiologi"al safety practices dictate that r.dioa.tive :amintitoZn bo&4Qnro~ld toN the lowest level-pAccaliFo aple# the NainlCuni .ts' Report 30' "Safe ".nd"in nRdation rotection azid Measuremebts, Adia""tive te..lsclearly .. Contrary to, thia generally accepted practiceN, yoju f4i1ledtoietf an 6ontfrblontait an -priual tha due:t bet an identi emitting radionucides associa with Y ....... ., This failure~ leadN to the spread of contamination ouitside th corifiteis o f the immediate work area into off ide and o~ther non-.manufacturing. areas. In few cases, contdmihtion was carried out of th plarit on~ the personial clothing of emiployees. Aiong other things+, you failed to ro utne survey in.dividuals to determine that they were free of alpha, beta And gamma co~Iitamiinatibn upoin leavting the~ work area arid before un~der~taking such activities as eating or smoking." This zituatioii was nioted on our last inspection. To ap#4-te aig Adc4ept4:b1O Contomioation control program,, oneý M'UIt; 1 tot Ublihatt area of,control. 2., 1iplemeznt procedures. (including, the. useb of protectiVe clothing and instruments) for enitering, conduticý,ng operatiqps, an~d gxiting from the controlled area. 3i. Routinely monitor uncontrolled areasý at a freqouey adequate to detect significant contamination spread.-4ý 4. nbbtor by appropriate methods and freuec euiplopkp Lgest ion, is not or.cur r iing t ssr thati FEB 15 1974 P. J. Knapp, Senior, Facilities Radiation Protection Section, RO:I INSPECTOR EVALUATION Nuclear Metals, Inc. 2229 Main Street Concord, Massachusetts 01742 License Nos. SNM-65' and SMB-179: The licensee's SNM program is being deactivated. It may be reactivated in about seven years. No significant problems were apparent. An inspection conducted in March 1973 indicated a beta-gamma contamination problem in associationwith the depleted uranium program. Apparently, we failed to impress the licensee concerning the problem and it was not 'brought under control. Consequently, the licensee is again being cited for the whole gamet of survey violations. I blame the safety office (Franks) primarily for the deplorable situation of this plant., He was made well aware of beta-gamma contamination problems on the previous inspection. Either he ignored it or he' didn't get the message. Until about a year ago he was. a technician with no knowledge of health physics and he doesn't appear to have improved his knowledge since he'was made Safety Officer. A. Gilman appears to be quite knowledgeable but was not directly involved in the previous inspection. He is now Manager, Health and Safety and also Manager, Quality Control. I get the impression he doesn't want to be bothered with radiation safety. Both he'and Sam Levin, Consultant from MIT, were aware that :uranium-238 daughter products were concentrated in the impurities resulting from melting the uranium. It will take more than Franks to straighten out this operation. He can't conduct a decent survey'. Let's give the licensee a-month to straighten' things out and then inspect them again to see how well they have done.