IR 05000054/1991001
| ML20029A907 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 02/22/1991 |
| From: | Austin M, Bores R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20029A900 | List: |
| References | |
| 50-054-91-01, 50-54-91-1, 70-0687-91-01, 70-687-91-1, NUDOCS 9103050089 | |
| Download: ML20029A907 (5) | |
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V. S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.
50-54/91-01 and 70-687/91-01 Docket Nos.
50-54 and 70-687 License Nos.
R-81 and SNM-639 P ri o ri ty _1_
Ca tegory UHBR Licensee:
Cintichem, Incorporated P.O. Box 816 Tuxedo, New York 10987 Facility Name:
Reactor and Hot Laboratory Inspection At: Tuxedo, New York Inspection Cnnducted: January 28-31, 1991 Inspector:
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Michael A. Austln, Radiation Specialist date
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Effluents Radiation Proter: tion Section (ERPS)
Facilities Radiological Safety and Safeguards Branch (F. SB)
Approved by:
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Robbt J. Bqres, Cnief, ERPS, FRSSB, date Division of Radiation Safety and Safeguards Inspection Summary:
Inspection on January 28-31,1991 (Inspection Report Numbers 50-54/91-01 and 70-687/91-01 Areas Inspected:
Inspection of licensee's activities to observe ongoing decontamination operations and to review the status of the licensee's plan for decommissioning.
Results: -No violations were identified.
Licensee had filled key positions in the organization described in the decommissioning plan.
Licensee was making various facility modifications necessary to implement the decommissioning plan.
Licensee was preparing detailed procedures in anticipation of performing a limited number of specific tasks from the decommissioning plan that could be completed while fuel remained on site.
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DETAILS 1.0 Individuals Contacted
- J. Adler, Co-Project Manager, Deccmmissioning S. Endsley, Superintendent, Decommissioning L. Glander, Health Physics Supervisor D. Grogan, Manager, Radiochemical Production
- J. McGovern, President and Plant Manager
- F. Morse, Manager, Decommissioning
- R. Strack, Acting Reactor Supervisor L. Thelin, Staff Health Physicist
- E. Truskowski, Manager, Health Safety and Environmental Affairs
- Denotes those present at the exit interview.
The inspector also interviewed other licensee employees during the inspection.
2.0 Organization Through interviews with licensee representatives, the inspector determined that the key positions in the decommissioning organization, described by the licensee as " Level I and 11 Management", were filled with qualified individuals. -Approximately a month prior to the current inspection, the licensee hired an individual for the position of Manager, Health Safety and Environmental Affairs. This new individual exceeds the educational and experience prerequisites for the position, as described in Appendix A of the proposed Decommissioning Plan, dated October 1990, (hereafter referred to as the "Decon Plan").
Licensee management had taken measures to provide reasonable assurance that the key individuals in the staff organization depicted in figure 1.13 of the Decon Plan would remain until completion of the decommissioning project.
No violations or deficiencies were identified in this area.
3.0 Decommissioning Plan The inspector met with the manager and co-manager of the Decommissioning Project to discuss various aspects of-the implementation of the Decon Plan.
The licensee organized the various tasks of the decommissioning project into two groups labelled " Phase 1" and " Phase II".
Phase I tasks included the remaining decontamination work described in the Decon Plan, which was submitted to NRC for approval.
The implementation of the Decon Plan was based upon the assumptions that the Phase 11 tasks would be started af ter all reactor fuel had been shipped of f site, and that Phase II would be completed by the end of calendar year 199 _.___.._.____.___.m___
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At the time of the current inspection, the licensee still had reactor fuel stored in Building 1, which prompted the licensee to re-evaluate the tasks in the Decon Plan in order to meet the scheduled 1992 completion date. As a result of this re-evaluation, the licensee developed two lists of Decon Plan tasks:
a " Pre-Plan Approval" list of those tasks that the licensee determined to actually be Phase I tasks that could be done under existing license conditions; and a " Post-Plan Approval" list of Phase 11 tasks that the licensee believed could be performed with reactor fuel on site without compromising safety or security, These " Pre-Plan" and " Post-Plan Approval" lists were submitted to the NRC for review in a letter, dated January 21, 1991.
The inspector reviewed the tasks included in these lists during tours of the licensee's facilities.
4.0 Facility Tour The inspector toured the reactor and hot laboratory f acilities, accompanied by the Acting Reactor Supervisor and the Decommissioning Superintendent to review those areas where decontamination tasks had been completed and the areas where future tasks were planned, and to observe ongoing tasks related to the decommissioning project.
The inspector observed that irradiated fuel elements were being stored in the west end of the reactor pool.
During previous reactor operation, the reactor fuel core had been located in the east end of the reactor pool.
l The inspector examined an underwater apparatus located in the east end of the reactor pool, which utilized circular saw equipment to remotely cut of f the two (non-fuel) aluminum end pieces from the irradiated fuel elements.
The Acting Reactor Supervisor stated that all the aluminum end pieces had been cut of f so that the fuel elements could fit into the BMI-1 shipping
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cask (see paragraph 7.0).
The inspector observed that the-licensee had i
used tarps to surround the underwater apparatus to minimize the dispersal l
of metal shavings throughout the pool during the cutting operation.
The inspector observed various waste metal (e.g., primary waste can racks)
being removed from the west end of the-pool for placement in a B-25 waste container. Waste metals removed frot the pool were first allowed to dry, then were cut up if practicable, before placement in a B-25 container.
The inspector observed that this waste loading area around the pool was properly delineated with a magenta yellow rope barrier and shoecovers were
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required for entry into the area.
The inspector examined each of the areas in which the tasks from the
" Pre-Plan Approval" and " Post-Plan Approval" lists were proposed to be done with fuel on site (see paragraph 3.0).
Each task was discussed in detail during the tour with the Decommissioning Superintendent and the l
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Acting Reactor Supervisor.
During these discussions, the licensee representatives demonstrated a good understanding of the potential problems associated with each task, and they satisfactorily responded to all saftty-related questions raised by the inspector.
No violations or deficiencies were identified in these areas.
5.0 Procedures The inspector reviewed the document system that the licensee planned to use for Phase 11 of the decommissioning project.
The document system is a three-tiered hierarchy consisting of Program Plans, General Work Procedures (GWPs), and Detailed Work Procedures (DWPs).
The inspector observed that each GWP containod task-specific safety requirements and radiological controls, and it had a quality control section that required individual signatures to confirm that the key steps of the procedure were performed.
The inspector observed that these sign-off lists were incorporated into the DWP that was related to the particular GWP.
The inspector noted that this was an effective way to assure that the procedures were followed and properly completed.
6.0 Radiological Controls 6.1 Respiratory Protection Program The inspector reviewed selected records and procedures pertaining to the licensee's respiratory protection program.
The inspector confirmed that the licensee's program satisfied the requirements of 10 CFR 20.103(c), and that the licensee had notified the NRL via letter, dated July 18, 1988, of its intent to utilize the program in compliance with 10 CFR 20.103(g). No siolations or dericiencies were identified in this area.
6.2 Radiation Work Permits (RWPs)
The inspector examined the inside of the Butler Building used by the licensee to store equipment and other materials that were surveyed and released from contaminated areas for unrestricted use.
The inspector used a licensee portable instrument to perform direct radiation surveys of several itemt in the Butler Building.
No readings distiomaishable from ambient background radiation levels were observed.
The inspector reviewed a log book maintained by the licensee to record the radiation survey results of items stored in the Butler Building.
No violations or deficiencies were identified in this are..
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7.0 Transportation-The inspector examined the exterior of the shipping cask, Model No.
BMI-1, which the licensee planned to use to ship irradiated fuel elements off site.
Licensee representrtives stated that they planned to load the cask with 24 fuel elcments for each shipment.
The inspector reviewed Certificate of Compliance No. 5957, Revision No. 17 to determine which conditions permitted the use of_this cask for this type of shipment.
After review of the conditions, the inspector determined that certificate Condition 5.(b)(2)(1) authorized the loading of 24 elements per cask shipment.
No violations or deficiencies were identified in this area.
'8. 0 Exit Interview The inspector met with the licensee representatives denoted in paragraph-1.0 at the conclusion of tha inspection on January 31, 1991.
The inspector summarized the secpc of the inspection and the findings.
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