DEPARTMENT OF THE NAVY NAVAL SEA SYSTEMS COMMAND DETACHMENT RADIOLOGICAL AFFAIRS SUPPORT OFFICE (RASO) IN REPLY REFER TO YORKTOWN. VA 23691-5098 Ser 01/510 1 5 From: Officer in Charge To: Comanding Officer, Naval Technical Training Center, Treasure Island, San Francisco, CA 94130 Subj: NAVSEADET RASO TECHNICAL ASSISTANCE VISIT Ref: OPNAVINST 6470.3; Navy Radiation Safety Comittee OPNAV 8128 Ser 455/50395245 of 3 Sep 85 (NOTAL) OPNAVINST 5l00.8F; Navy Safety and Occupational Health Program; Implementation of CNTECHTRA MILLINGTON TN 101301Z JAN 86 NAVSEADET RASO Report No. 1483 of 21 Mar 80 Encl: NAVSEADET RASO Report No. 326l.9A4 1. In accordance with references and and as requested by reference Mr. Roy H. Smith of RASO conducted a technical assistance visit at the Naval Technical Training Center, Treasure Island, San Francisco, California during the period 3-5 February 1986. The purpose of the visit was to evaluate safe use of sources of ionizing radiation, associated records, reports and training, and to review implementation of previous recommendations of reference 2. Department of the Navy activities possessing or using sources of ionizing radiation are required to comply with pertinent Naval directives, codes of Federal Regulations, public laws, and when applicable, Nuclear Regulatory Commission licenses including all procedures specified in the application. Compliance with other recommendations extracted from publications of nationally recognized radiation advisory groups is necessary to ensure success of the "As Low As Reasonably Achievable" (ALARA) philosophy. 3. Current findings and recommendations to improve your radiological safety program are provided as enclosure (1). Clarification of specific included items or assistance for implementing recommendations may be obtained by contacting NAVSEADET-RASO, ABTOVON 953-4692, or Commercial (804) 887-4692. 4. It is requested that NAVSEADET RASO be notified within 30 days of the receipt of this letter of actions taken or planned on all ommendations. P. J. DURFEE Copy to: CNTECHIRA (31) NAVAL SEA COMMAND DETACHMENT RADIOLOGICAL AFFAIRS suproar OFFICE YORKTOWN, VIRGINIA 23691-5098 DATE: 1986 1 FILE NO.: 3261.9A RASO REPORT NO.: 3261.9A4 RADIOLOGICAL AFFAIRS SUPPORT OFFICE REPORT OF TECHNICAL ASSISTANCE VISIT TO NAVAL TECHNICAL TRAINING CENTER, TREASURE ISLAND SAN FRANCISCO, CALIFORNIA 3-5 FEBRUARY 1986 PREPARED BY: . ROY H. ITH TECHNICAL DIRECTOR EXECUTIVE SUMARY The Naval Sea Systems Command Detachment, Radiological Affairs Support Office (RASO) conducted a technical assistance visit at the Naval Technical Training Center, Treasure Island, San Francisco, California during the period 3-5 February 1986. The purpose of the visit was to review the ionizing radiation safety program for compliance with current radiation safety criteria. The major discrepancies and identified problem areas were: 1. There had been a lack of effective action to correct deficiencies in essential elements of the radiation safety program previously identified by inspectors and surveyors. 2. Significant conditions of Nuclear Regulatory Commission Licenses were not being met, including: a. Radiac instruments were not calibrated at prescribed frequencies. b. NRC licensed sealed sources were not leak tested at least every six months before use. c. Required daily testing of alarms, safety devices and interlocks was not documented. d. Various internal inspections important to safety were not documented. e. Verifications of emergency response equipment and radiac instruments were not documented. f. Inadequate training and erroneous and/or incomplete information provided for fire and security emergency response personnel. 3. Radiation areas were not accurately delineated and were not correctly posted. 4. A qualified Assistant Radiation Safety Officer had not been designated. 5. There was a need to upgrade the technical training of the Radiac School training staff. 6. Radiac School students had been occupationally exposed to ionizing radiation prior to completing required radiation medical examinations. II. IV- TABLE OF CONTENTS DISCUSSION FINDINGS AND RECOMMENDATIONS RADIATION HEALTH PROGRAM REFERENCES FIGURE 1. Perimeter Survey, NAVTECHTRACEN Treasure Island I. DISCUSSION A. In accordance with references and and as requested by reference Mr. Roy H. Smith of RASO conducted a technical assistance visit at the Naval Technical Training Center (NAVTECHTRACEN), Treasure Island, San Francisco, California during the period 3-5 February 1986. B. The ionizing radiation program included the possession and use of radioactive materials authorized by two Nuclear Regulatory Commission (NRC) Materials Licenses (one issued to NAVTECHTRACEN and one issued to the Space and Naval Warfare Systems Comand Washington, DC), and special nuclear material transferred to the US Navy under the provisions of Article 9l.b of the Atomic Energy Act of 1954. C. The following personnel were contacted during the visit: CDR M. Evans, USN Comanding Officer LCDR C. Arsta, USN CNTECHTRA, Code N31 LCDR T. Fulham, USN . Executive Officer LCDR Braswell, USN Director of Training MAJ J. Wagner, USA Radiation Safety Officer LT D. G. Dunn, USN, MSC Radiation Health Officer ETC J. Droesch, USN Director, Radiac School An entrance interview and an exit briefing, which included a discussion of findings and recommendations, was presented to CDR Evans and selected members of the NAVTECHTRACEN staff and to LCDR Arsta, Code N31, CNTECHTRA. D. The most recent previous RASO technical assistance visit to NAVTECHTRACEN was during the period 27-28 February 1980, reference Several recommendations contained in reference to correct deficiencies in essential elements of the radiation safety program had not been implemented at the time of this assistance visit. These items are identified in Section II as repeat findings. E. A representative from the NRC Region V, Inspection and Enforcement Office conducted an inspection on 7 August 1984 of the activities authorized by reference one item of noncompliance, failure to leak test sealed sources at the prescribed six month interval, was noted. Similiar NRC findings of failure to leak test at prescribed intervals and maintain prescribed records were noted in a 10 March 1978 compliance inspection. Deficiencies in the leak test program were also noted during this technical assistance visit and are detailed in Section II. F. During the period 5-7 November 1985 a technical training audit, reference was performed at NAVTECHTRACEN. As a result of the deficiencies noted during subject audit, and the lack of a qualified Radiation Safety Officer (RSO), all NRC licensed sources were secured and classes in Radiac Instrument Maintenance Course (A-670-0020) were suspended pending correction of all safety related deficiencies, and accomplishment of a detailed RASO technical assistance visit to verify to ability of the NAVTECHTRACEN to safely use ionizing radiation source in accordance with applicable licenses, rules, and regulations. G. Radiation detection and measuring equipment used by the RASO surveyor consisted of an (Eberline Model R0-2) ionization survey instrument, serial number 1327, calibrated 27 November 1985 and reverified on 21 February 1986, and a calibrated serial number A-10 provided by NAVTECHTRACEN. II. FINDINGS AND RECOMMENDATIONS A. General 1. MAJ John F. Wagner, USA, was designated by name as the RSO in item 7 of reference His appointment as RSO was intended as an interim action until LT D. G. Dunn, MSG, USN, the prospective RSO had completed the Radiation Safety Officer Course conducted by RASO. An Assistant Radiation Safety Officer (ARSO) had not been designated. RECOMMENDATION: Designate the Director/Senior Instructor, Radiac Instrument Maintenance School as ARSO subsequent to completion of the Radiation Safety Officer Course conducted by RASO. 2. Survey instrument maintenance and calibration was provided by the Radiac Repair Facility, Vallejo, California. Available instrumentation included and beta-gamma survey meters, neutron survey meters, alpha survey meters, RM-3C3 count rate monitor and IM-9 3. The laboratory instrument used to assay sealed-source leak test samples consisted of a lead enclosure containing an end-window Geiger-Mueller counter, connected to a standard Navy scaler, timer, and high voltage supply. B. Facilities and Operations 1. The possession, utilization, and disposition of radioactive material at NAVTECHTRACEN were regulated by: a. NRC Materials License No. 04-04346-O2 issued to the NAVTECHTRACEN, reference and locally promulgated safety and operating instructions, reference b. NRC Material License No. 08-00038-12 issued to the Naval Electronic Systems Command (currently reference (1). c. NAVELEXINST Procedures Governing the Possession and Use of Radiac Calibrators Containing Plutonium (NAVELEX RCS 9673~8), reference d. NAVELEXINST 9673.5D, Maintenance, Possession, and Use Responsibilities for Radiac Equipment (NRC Materials License No. 08-00038-12), reference e. NAVELEXINST Procedures for Labeling, Leak Testing, and Disposing of Operational Check Sources of Radioactive Material Used in Radiac Sets, reference (1). f. Title 10, Code of Federal Regulations- Energy, reference 2. In addition to the and TS-1216B radiac calibrators authorized by reference containing 63.2 and 19.7 curies respectively of cesium~137, the following radiation sources_were located at the Radiac Instrument Maintenance School at the time of the assistance visit: 2 a. One Radiac Detector Test Chamber containing 0.70 millicuries of cesium-137 authorized by reference (1). b. One Slow Neutron Flux Generator containing 80 grams of plutonium-239 in a plutonium-beryllium source, and three Alpha Radiac Calibration Sets, each containing 808 micrograms of plutonium-239, authorized by Article 91.b of the Atomic Energy Act of 1954. c. Approximately 240 microcuries of hydrogren-3 in one CL-1 tritium calibrator, authorized as an exempt quantity by reference d. Assorted check sources contained in various radiac calibrators. 3. A detailed radiation survey of the Calibration Range in Building 343 was performed. The survey included the normally occupied areas inside the Calibration Range, and the entire radiation area perimeter. The and TS--1216B calibration sources were simultaneously exposed under conditions of maximum intensity, with radiac instruments placed in the normal calibration positions, to provide maximum radiation fields encountered during normal operations. Survey results (see Figure 1) indicated a need to perform a careful resurvey, remapping, and repainting of the high radiation, radiation and restricted area boundaries. A review of the radiation area perimeter survey results indicated that the extension of the fenced area immediately adjacent to the north west corner of Building 343 to encompass an area of approximately 200-300 square feet would result in totally enclosing the restricted area (2 mR in one hour) boundary. RECOMMENDATION: Extend the chain link fence as indicated on Figure 1. Perform a careful resurvey, remapping, and repainting of the high radiation, radiation and restricted area boundaries and submit a formal amendment to change reference to reflect all changes in boundaries and posting requirements. 4. Discussions with operating personnel, and observations of auditors as reflected in Comment 012 of reference demonstrate a need for immediate remedial training of the Radiac School training staff in basic radiation physics and radiation safety to ensure that information imparted to students attending the school is correct. RECOMMENDATION: Provide immediate remedial training in basic radiation physics and radiation safety for the Radiac School training staff. Ensure that the R80, or other technically qualified personnel, periodically monitor classes to evaluate technical accuracy and the need for remedial training. 5. Findings made by an audit team member in Comment 012 of reference after observing actual laboratory training in radioactive source leak testing, indicate that consideration should be given to procuring an additional with a dummy source for demonstration and practice purposes before students are permitted to conduct leak test and perform other operations with a live source. 6. Contrary to the conditions of reference radiac instruments used for health and safety monitoring were on a one year calibration cycle. RECOMMENDATION: Ensure that all radiac instruents used for health and safety monitoring are calibrated every six months as required by item 1l.a of the 16 August 1985 application for reference 7. The entrance to the Calibration Range was not posted with a "Caution- Entering Radiation Area" sign. It was also noted that various chain link fences in the vicinty of Buildings 342 and 343 either had or, under the conditions of the current application for reference were required to have radiation area warning signs posted. The results of the detailed radiation survey performed by the RASO surveyor, see Figure 1, demonstrated that the restricted area boundary was contained within a well defined area inside the indicated chain link fence and thus other fences in the area did not require posting with radiation area warning signs. RECOMMENDATION: Post the entrance to the Calibration Range with a "Caution - Entering Radiation Area" sign. Post the chain link fence immediately adjacent to Building 343 as a radiation area as indicated on Figure 1 whenever using the Calibrator. 8. Records were not available to demonstrate that radiation shields, interlocking switches, and other facility safety devices are inspected by competent personnel at least every six months. Ensure that devices important to safety are inspected by competent personnel at least every six months and appropriate records are maintained as recommended by paragraph 7.7 of reference 9. surveys for radioactive contamination do not include the sunken concrete vault (Building 344) which is used to store radioactive sources. Reference established the previous existence of removable contamination. (Repeat Finding) RECOMMENDATION: Include Building 344 in the radioactive contamination monitoring program and make necessary changes to enclosure (1) to reference C. Records, Surveys and Training 1. Contrary to the conditions of references and leak tests were not performed at least every six months prior to use. This is a repeat RASO finding, and is in addition to and separate from similiar findings by a NRC inspector on 7 August 1984. RECOMMENDATION: Leak test NRC licensed calibration sources at least every six months in strict compliance with NRC license conditions. 2. and calibrators were not leak tested at required intervals. (Repeat Finding) RECOMMENDATION: Leak test and calibrators at six month and three month intervals, respectively, in accordance with the requirements of reference (J). 3. Pocket dosimeter logs were maintained, however there was no documentation of quarterly reviews. RECOMENDATION: Perform and document the personnel dosimetry evaluations required by paragraph of Supplement 15-1 to reference 4. Records were not available to document daily testing of alarms, safety devices, and interlocks. RECOMMENDATION: Document the daily testing of alarms, safety devices and interlocks required by paragraph of Supplement 15-1 to reference 5. There was no current written designation of personnel authorized access to the and calibrators by the Commanding Officer RECOMMENDATION: Ensure that only personnel specifically designated in writing by the Comanding Officer are permitted access to and calibrators and that designations are current in accordance with paragraph 4.c of reference 6. Records were not available to docuent the accomplishement of various internal inspections important to health and safety. RECOMMENDATION: Ensure that internal inspections required by paragraph 3 of Supplement 15-1 to reference are accomplished and documented. 7. Records were not available to verify that radiac instruments and other equipment in emergency lockers were checked weekly. RECOMMENDATION: Ensure that radiac instruments and other equipment in emergency lockers are checked for completeness and proper operating condition weekly as required by paragraph 2.f.3(i) of Supplement 15-1 to reference Maintain a log verifying accomplishment of this important action. 8. Records were not available to document training of Fire Department and Security personnel in the proper use of radiac instruments. It was also noted that paragraphs 6.a and of Supplement 15-1 to reference erroneously state that airborne and surface contamination are unlikely in a fire emergency, and fail to alert emergency response personnel to the probable presence of intense radiation fields in the vicinity of the TS-1216 calibrator due to the loss of mecury used for shielding as a result of involvement in a fire, as discussed in paragraph 2.2 of reference (0). RECOMMENDATION: Institute an adequate training protocol for Fire Department and Security personnel and make appropriate revisions to references and RADIATION HEALTH PROGRAM A. The Radiation Health Program was administered by the Branch Medical Clinic. Radiation medical examinations were being conducted and lithium fluoride thermoluminescent dosimeters (TLDs) were being issued to personnel who were occupationally exposed to ionizing radiation. A cursory review indicated that essential elements were being accomplished. Radiation medical examinations were not in full compliance with the requirements of reference However, corrective actions were being aggressively pursued by the Radiation Health Officer (RHO). B. In addition to the TLDs, pocket dosimeters were worn by personnel performing duties in a radiation areas. Pocket dosimeters were also issued to visitors at the Radiac Maintenance Division. C. Paragraph 5 of Supplement 15-1 to reference authorizes military personnel to enroll in the Radiac Maintenance Course prior to completing radiation medical examinations, provided the examinations are completed prior to graduation. This procedure is contrary to the requirements of reference RECOMMENDATION: Comply with the provisions of paragraph 2-3 of reference which requires that personnel have a radiation medical examination prior to being occupationally exposed to ionizing radiation or handling radioactive material. K. L. M. IV. REFERENCES OPNAVINST 6470.3; Navy Radiation Safety Committee opuav 3123 Ser.455/5U395245 of 3 Sep as (norar) OPNAVINST Navy Safety and Occupational Health Program; Implementation of CNTECHTRA 1013012 JAN 86 NAVSEADET RASO Report No. 1483 of 21 Mar 80 Nuclear Regulatory Commission License No. 04-04346-02 Memorandum for SPAWARSIT, of 26 Nov 85, Subj: Technical Training Audit Report for Audit at NAVTECHTRACEN Treasure Island, San Francisco, California, 5-7 Nov 85 NAVTECHTRACENINST 5100.58; Radioactive Sources; Safety and Operating Regulations Nuclear Regulatory Commission License O8-00038-12 NAVELEXINST 9673.l4A; Procedures Governing the Possession and Use of Radiac Calibrators Containing Plutonium (NAVELEX RCS-9673-8) NAVELEXINST Maintenance, Possession, and Use Responsiblities for for Radiac Equipment (NRC Materials License No. 08-00038-12) NAVELEXINST Procedures for Labeling, Leak Testing, and Disposing of Operational Check Sources of Radioactive Material Used in Radiac Sets Title 10, Code of Federal Regulations -- Energy NBS Handbook 114; General Safety Standard for Installations Usings NonrMedical X-Ray and Sealed Gama-Ray Sources, Engeries up to 10 NAVSHIPS 0967-077-6010; Technical Manual for Radiac Calibrator TS-1216 NAVMED Radiation Health Protection Manual PERIHETFR suavsv nu:-PERIMETER SURVEY (all readings 1.01. 13. I Install new 3_ o_5 %19, 32 chain link 9 4_ o_5 20, fence 7.015. 0.5 31. 16. 0.6 32. .13" 124 Post as Radiation Area when using NAVTECHTRACEN Ereasure Island