ML19256E121

Responds to NRC 790815 Ltr Re Violations Noted in IE Insp Rept 50-054/79-02.Corrective Actions:No Gaps in Exposure Record Will Be Permitted for Any Unusual Length of Time. Estimate of Exposure Based on Daily Dosimeter Readings

ML19256E121
Person / Time
Site:	05000054
Issue date:	09/11/1979
From:	Mcgovern J UNION CARBIDE CORP.
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19256E120	List: ML19256E121
References
NUDOCS 7910290132
Download: ML19256E121 (2)

Text

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O UNION CARBIDE CORPORATION MEDICAL PRODUCTS DIVISION P.O. BO X 324, TU XEDO, NEW YO RK 10987 TELEPHONE: 914 351 2131 September 11, 1979 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attn: George H. Smith, Chief Fuel Facility & Materials Safaty Branch Subj: Inspection 50-54/79-02

Dear Sir:

The report of the above referenced inspection identified certain activities that allegedly were not conducted in full compliance with NRC requirements. Our comments on these inspection findings are respectively as follows:

ITEM A:

The 55 gallon drum referenced in your letter has been posted with a " Caution-Radioactive Materials" label as a prei aution for individuals working in the vicinity of the drum. lo that further deficiencies of this type will not occur in ene future, the Health Physics group has completed a search of licensed areas to verify correct labeling and tc update worn or faded postings.

More importantly, & memorandum has been issued to all personnel reminding them to be on the alert for unmarked storage of radioactive materials on site and to label these areas or bring them to a supervisor's attention so that they may be properly posted.

I'?/ 051

, g 10 290 i15 1-

NRC-

• Inspection 50-54/79-02 September 11, 1979 ITEM B:

The Operations group has been reinstructed in the requirements for maintaining radiation areas properly. This training emphasized the importance of maintaining the proper posting of radiation warnings, including posting of the cautions for con-taminated areas. In addition, the heat exchanger hallway as well as the entire upper level of the pump room has recently been decontaminated and pa.'.nted so as to help cut back on re-movable contamination in the pump room area.

The license representative who entered the heat exchanger hall-way trusted that the reversed contamination posting was, indeed, correct. Although this was not the case, the consequences of entering the area without benefit of protective shoe covers was trivial. This was evidenced by the negative test for shce con-Famination for the licensee representative and NRC inspector upon leaving the reactor building.

Nevertheless, we do not consider incorrect posting of ratiation warnings te be a minor matter and our retraining effort; have emphasized this concern.

ITEM C:

While it is true that an air grab sample was not taken during the ion exchange filter replacement job cited, the operation was benefited by a continuous air sample. This particular air sampler in the pump room is just one of twenty-one located at strategic locations throughout the reactor and hot lab buildings which sample 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.

The pump room air sample for 12 March 1979 indicated no de-tectable activity. Assuming that the work in the pump room took one-half hour, the exposure to the employee changing the filter would be less than 1/20 MPC-Hour assuming iodine-131 to be the isotope of concern. This quantity represents approxi-mately 1/10000 of the permitted quarter year intake of 520 MPC-Ecurs (i.e. 13 weeks x 40 MPC-Hours / week) and is therefore, insignificant.

In addition to this avidence, all grab air samples taken for this particular job in the past have shown negligible airborne radioactivity. The most recent evaluation in May 1979 taken with a high volume air sampler indicated an airborne iodine-131 exposure of approximately 1/100 MPC-Hour to the individual per-forming the job.

!9'/ 052

NRC '

Inspe ction 50-54/79-02 September 11, 1979 ITEM D:

Upon further investigation of the exposure received to the re-ferenced employee for December 26, 1977 through January 8, 1978, a Landauer film badge report was located which indicated che employee's exposure to be 20 mrem for this period of time.

Apparently, this particular film badge result had been over-looked in the process of transferring the film processor values to this individual's exposure record.

In order to prevent a reoccurence of such record keeping errors, we have instituted a policy that no gaps in the exposure record will be permitted for any unusual length of time. In lieu of a film result, an estimate of the exposure will be based on daily dusimeter readings and the results immediately logged.

ITEM E:

The frequency of urineanalysis for radiation employees has been annual in the past, as noted. However, because of the vast quantity of negative urineanalysis and air sampling data col-lected over the rears, we feel that a continued formal urine-analysis program for the reactor facility is unwarranted.

We will cor.cinue to request bioassay analyses (either body count-ing or urineanalysis techniques) for persons who have been exposed to significant airborne radioactivity. However, these analyses will be performed on a case by case basis since our routine continuous air sampling program indicates exposures significantly below 25% of the airborne radioactivity concentration guidelines.

The new Technical Specifications for the reactor facility (effective September 1979) reflect this philosophy and do not impose a periodic urineanalysis requirement.

ITEM F:

An evaluation of the percentage of I-133 released is presently being performed and documented. The evaluation had not been formally documented previously although measurements addressing this concern have been performed in the past. The experimental results should be completed this week, and the results will be available for your next inspection or earlier if desired.

! / OI)3

NRC', ',

Inspection 50-54/79-02 September 11, 1979 In order to prevent a recurrence of an oversight in a forma-lized follow-up on an unresolved item, each future unresolved item will be assigned to a specific individual who will have responsibility for carrying it through to completion.

All of the above corrective actions either have been or will have been accomplished within one week after this response.

V,ery truly yours, k bG James J. McGovern Business Manager Radiochemicals LCT:js cc: Dr. R. E. Bollinger C. B. Holzgraf C. J. Konnerth L. C. Thelin M. H. Voth

97/ 054