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,(No. 2)

!h POST-INSPECTION COVER SHEET

(Region I Work Form)

From: Principal Inspector Z, X OfA .4A/

To Senior , , $ V /1 •,

Subj:__ INS PECTION OF /e 4 Ž ~ A /. 2 Id.(Facility or License #)

0 Draft'inspection report completed and attached.

ON t+-•/7 C(Dates)

,eder field notes completed daTrached.

2.

-List:

/V Draft documentation letter completed and attached (a standard form with newor modified paragraphs desired)

List of updated outstanding items completed and attached.. -t-" • " " ~ (list will .be with- it).

/f Inspector.'s evaluation memo attached with assist inspector's• evaluationmemo attached thereto.

Standard Data Sheet

Additional Comments: ''

(Principý'!' Ins c6~

V.0File:Senior's File (Cover Slheet Only)

NOTE: Cross out and initial sections not applicable.

FEB 15 1974

7Nuclear Metale, Inc. License No. SM-65Actention: Mr. W. B. Tuffin SMB-179

President Inspection Lo. 70-02173-052229 Main Street 40-672173-02Concord, iassachusetts 01742

Centlemen:

This refers to the inspection conducted by Mr. Jerman of this officeon Decermber 27-28, 1973 and January 8-9, 1974 of activities authorizedby AE, License Nos. S10-1-65 and S?43-179 and to the discussions of ourfindigs held by Mr. Jerman with Mr. Tuffin and to subsequent telephonediscussions between Mr. Knapp and Mr. Gilman on January 18, 1974 andbetween Nr. Jerran and Mr. Tuffin on January 21, 1974.

Areas examined during this inspection are described in the RegulatoryOperations Inspection Report wvhjW.4 is dnelosed with this letter. Withinthese areas, the inspection consisted of selective emin-lations ofprocedures and reprasentative records, interviews with personnel,measurements made by the inspector, and observations by the inspector.In addition, your activities in response to telephone conversationson January 4 and 7 as confirmed by our letter to you datedJanuary 7, 10974, were reviewed.

Our inspector also verified the steps you had taken to correct thevioitioirr brought to your attention in our letters dated April 23, 1973and December 12, 1973. lie have no further questions regarding Itemsl.a, 1.b, l.c, and l.e of Enclosure I and Items l.c, 2, 3, and 4 ofEnclosure 2 to the April 23, 1973 letter;land Item 2 of the Enclosureto the December 12, 1973 letter. With regard to Items l.b, l.c, 1.d and2 of Enclosure I to this letter, we note that you had taken stepa tocorrect these violations but your evaluations were inadequate in thatthey failed to include provisions to cover beta and gamma radiation..

During this inspection, it was found that certain of your activitiesappeared to be in violation of A.ZC requirements, and another activityappeared to ralse a question concerning the safety of operations.The items and references to the pertinent requirements and to generallyaccepted guidance are listed in the enclosure to this letter. Thisletter constitutes a notice sent to you pursuant to the provisionsof Section 2.201 of the AEC's 'Rules of Practice", Part 2, Title .0,Code of Federal Regulations. Section 2.201 requires you to submitto this office twithin 20 days of your receipt of this notice, a writtenstatement of explanation in reply, including: (1)*steps which have

-Knapp Jerman Crocker Nelson O'Reilly21 /74 2/ /74 2/ /74 2/ /74 2/ /74

77-1. . at

-Nuclelar'. Metal s,. Inc. ;-2- '3

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,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 -", I - -toy't thý o~k ,tM yoA00itt i ~p catpion within 20d ;Athlrmt f p pb cdisclo'sure. Any suhqp~i inms

Ia full3'statemneit of 'he re onhs on the ba~sis'f wbtcb. it~ isIthbat 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 thiswithiin the 9 -ecif~ied 'period,,, the, ~ ot wll, be placgd int theDocumient Room.

Should you ýhavei any' qu'stjtjos- concetning this, insoeto~w ilbple4~edto, di4cs hmiiyu

j-ame~s P. OReilIy

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ENICLOSUlR N.

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'a et "d. tý 10 Cfl 'ud* -ifrestrieted, areAs't . Spsceifflclly, ' e

ii~ciad an~ysi f~ setagami qý,egitres~iltiBig iwoi _ompoes~Ti san norc~ oain

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d. Contrary, 'to tliis! requirement, you failed to mike sluth sUkVeysas Oere n4cessary to asure' compliaiieeiuith 10' CYR 20,.106,"onetr ations in eflinst n~tttdareas'" a regulation

radioativemteria1 eontalined'ini~i Iics dtcagd rmyupleaito th -urstitd ra Specifically, tbe.ýsurveys

chih you4di 4<condukt, of your liquid vasti, iesultig froni the6dissolotion of copper f rom ujranui -238,, prior? to it dispos alto. abg nyu property,, .#4 not: includsemeagurement lofbetq:7s~iia emitting materilsv4ich maW aebnpeet

condition 18 of, theý license requiires, that muaterial piossessed 'and usedIn& ac o rdani&e wi th~ pcd se 8ubm -tte ' with -yo . r:tcs, plidatodite4 6~ruay 26, 19,69. Setion II of ths prcedlurqi~s entitledRealth S & afety"'. It "c0ifi5 az Ors, the rquirement,

show-A below-

Environmental water aMi &oil sAMplp il be ollected a, da ~lyzed annually,

Contrary to this requiremenit, the envirvonmntal *ater -ndd. soil,samples collected were not anayzed for the concentration of beta-gaunaemitting 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-pAccaliFoaple# the NainlCuni nRdation rotection azid Measuremebts,.ts' Report 30' "Safe ".nd"in A dia""tive ..te..lsclearly

Contrary to, thia generally accepted practiceN, yoju f4i1ledtoietfan 6ontfrblontait an -priual tha due:t bet an identiemitting radionucides associa with Y ....... .,This failure~ leadN to the spread of contamination ouitside th corifiteiso f the immediate work area into off ide and o~ther non-.manufacturing.areas. In few cases, contdmihtion was carried out of th plariton~ the personial clothing of emiployees.

Aiong other things+, you failed to ro utne survey in.dividuals todetermine that they were free of alpha, beta And gamma co~Iitamiinatibnupoin leavting the~ work area arid before un~der~taking such activitiesas 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 clothingand instruments) for enitering, conduticý,ng operatiqps, an~dgxiting from the controlled area.

3i. Routinely monitor uncontrolled areasý at a freqouey adequateto detect significant contamination spread.-4ý

4. nbbtor by appropriate methods and freuec t ssr thatieuiplopkp Lgest ion, is not or.cur r iing

FEB 15 1974P. J. Knapp, Senior, Facilities Radiation Protection Section, RO:I

INSPECTOR EVALUATION

Nuclear Metals, Inc.2229 Main StreetConcord, Massachusetts 01742License Nos. SNM-65' and SMB-179:

The licensee's SNM program is being deactivated. It may be reactivatedin about seven years. No significant problems were apparent.

An inspection conducted in March 1973 indicated a beta-gamma contaminationproblem 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 citedfor the whole gamet of survey violations.

I blame the safety office (Franks) primarily for the deplorable situationof this plant., He was made well aware of beta-gamma contaminationproblems on the previous inspection. Either he ignored it or he' didn'tget the message. Until about a year ago he was. a technician with noknowledge of health physics and he doesn't appear to have improved hisknowledge since he' was made Safety Officer. A. Gilman appears to bequite knowledgeable but was not directly involved in the previousinspection. He is now Manager, Health and Safety and also Manager,Quality Control. I get the impression he doesn't want to be botheredwith radiation safety. Both he' and Sam Levin, Consultant from MIT,were aware that :uranium-238 daughter products were concentrated in theimpurities resulting from melting the uranium.

It will take more than Franks to straighten out this operation. Hecan't conduct a decent survey'. Let's give the licensee a-month tostraighten' things out and then inspect them again to see how well theyhave done.