ML19263B136
| ML19263B136 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 12/21/1978 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Fritz H UNION CARBIDE CORP. |
| Shared Package | |
| ML19263B137 | List: |
| References | |
| NUDOCS 7901050381 | |
| Download: ML19263B136 (1) | |
Text
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s fy UNITED STATES
-t NUCLEAR REGULATORY COMMiss10N f f)*b o
REGION I h
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$31 PARK AVENUE vggi KING OF PRUS$1 A. PENNSYLV ANI A 19406 DEC 21 1973 Docket No.70-687 Union Carbide Corporation ATTN: Mr. H. E. Fritz, Operating Manager Sterling Forest Laboratory P. O. Box 324 Tuxedo, New York 10987 Gentlemen:
Subject:
Inspection 70-687/78-02 This refers to your letter dated December 8,1978, in response to our letter dated November 14, 1978.
Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a subsequent inspection of your licensed program.
Thank you for the additional infonnation concerning the signs posted in the area above cell 1 in the Solution Makeup Area. The audit schedules formu-lated by the Nuclear Safeguards Committee and the requested changes to the facility license which were submitted to NRC-NMSS by letter dated November 17, 1978, will be examined during a subsequent inspection.
Your cooperation with us is appreciated.
Sincerely, LG Y
eorge H. Smith, Chief
~.'
Fuel Facility and Matert is Safety Branch 7 9010 503%l
UsNRIC December 8, 1978
~
the regulations and notices more conspicuous, we have installed a third bulletin board so these regulations can be spread out more.
The above corrective measures should prevent a recurrence of future similar non-compliance items.
The alleged deviation with industry standard practices, in that solutions of various concentrations of SNM are contained and handled in vessels that have not been analyzed for criticality safety, was not apparent to us.
The bases for insuring criticality safety was to maintain inventories of SNM in specific well defined areas of the facility to quantities less than tne singie para-meter mass limits stipulated in ANSI Standard N16.1.
The margin below the single parameter mass limits by which each process quantity was maintained in each area were considered adequate to prevent inadverrent breech of limit.
The justification for setting the mass limits in each area was presented in our letter of 11/17B8 which was in support of tne specifications of the license.
Since this last inspection, all operations with SNM possessed under this license were reviewed and certain changes to the license have been requested to fu _her clarify the bases for the mass limits established for eadi location where SNM is processed.
A copy of this request fer anandment is enclosed.
Thank you for your considerarion.
Very truly yours, c/
Ja.aes J.
McGovern Manacer Radiochemical Producrien JJMcG:js Enclosure (UCC Ltr. dated 11/17/78)
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- J4RATORY November 17, 19'8 U.
S. Nuclear Regulatory Commission Fuel Reprocessing & Fabrication Branch Division of Fuel Cycle & Material Safety Washington, D. C.
20555 Attn:
Leland C. Rause, Chief Subj:
PROPOSED AMENDMENT TO SPECIAL NUCLEAR MATERIAL (SNM) LICENSE No. 639.
Dear Sir:
In a recent review of our subject license, it was noted that provisions exist that are inconsistent with current practice and that lack continuity with other provisions in the license.
It is desirable to amend the license to make it easier to administer, make it compatible with current practice, and, in one case, provide a combined limit for SNM in the target plating process.
The following proposed changes will not reduce the safety margins that now exist under the license.
1.
The current license conditions regarding ordering or purchasing SNM are stated in Union Carbide Corporation (UCC) letter of 2/8/73 para. A.l..
The quantity of SNM that may be ordered for delivery at any one time is limited to 650 grams U-235 (as UO2 or U 0 ).
3 8 In order to make the provisions of this section more descriptive of current practice in receiving, assaying and storing such material, it is requested that the wording of this paragraph be changed to read as follows:
NRC - Proposed Amendment to SNM November 17, 1978 "A.1.
All purchases of special nuclear material shall be approved by the SNM Accountability Officer and also the custodian of the Master Log -(App. I).
The quantity of SNM that can be ordered for delivery at any one time shall be limited to 650 grams (as UO2 or 0 0s).
Furthermore, the 3
quantity of SNM that is to be contained in any single primary container shall be < 350 grams."
2.
The current license conditions regarding the quantity limits for storing SNM in solution prior to use in electroplating isotope targets or other laboratcry use are stated in UCC letters 2/8/73 para. A.2. and 2/11/75 (revision of UCC letter 6/13/78 para. B.
(a) para. 1.)
These sections should be changed to clarify the limits and make the storage limits compatible with delivery and other process limits.
These sections should read as follows:
"A.2.
All unirradiated SNM when not in use, shall be kept in locked steel cabinets which are located within a restricted area of the hot laboratory.
The amount of U-235 in a single cabinet shall be limited to 350 grams in solu-tion or 650 grams as UO2 or U 0s.
The spacing 3
between SNM storage cabinets shall be a minimum
~
of three feet and each cabinet shall be fastened to prevent inadvertent movement.
SNM in liquid form shall be doubly contained."
"B.a.
para. 1 Criticality Control In Storage Areas Uranium is stored in storage cabinets in the upper level of the hot laboratory (Fig. lA).
Material in liquid form is doubly contained.
Storage cabinets are of fireproof construction, are separated by a minimum distance of three feet and are fastened to prevent inadvertent movement.
All cabinets are locked and keys are in the custody of the SNM custodian for the area.
Criticality control is implemented by limiting the quantity of SNM in solution to 350 grams per storage cabinet.
This limit allows a safe margin below the single parameter limit of i60 grams U-235 in uniform aqueous solutions specified in the ANSI N16.1-1969 standard even
NRC - Proposed Amendment to SNM November 17, 1978 if " double batching" were to occur.
The storage space within each cainet is large enough for only one 350 gram batch of material in solution and therefore it is unlikely that double batching could occur but in the event that it did the 760 gram single parameter mass limit would not be exceeded.
In the event it is necessary to store.SNM as UO2 or U 0, the quantity limit for 3 8 this form of material shall be 650 grams of SNM.
This quantity is not likely to be exceeded be-cause of the 650 gram order limit previously discussed.
The quantity is well below the 29.6 Kg or 43.5 Kg subcritical mass limits stated for dry U02 or U 08 respectively as presented in 3
Table 3.1 of Nuclear Safety Guide TID 7016 Rev. 2,
- p. 71.
Due to the location of the storage facilities, it is not credible that this material would be contacted by water or other moderating material."
3.
The current license conditions regarding the quantity limits for SNM in process in a laboratory are stated in UCC letter 2/8/73 para. A.
3 & 4 and 6/13/73 para. B.b.
In order to make these provisions compatible with current practice and other sections of this license, and also to better define the limits allowed in the plating pro-cess, the wording of these sections should be changed to read as follows:
"A.3.
Unirradiated SNM in solution shall not exceed 350 grams in a single laboratory."
"A.4.
SNM, as an oxide, encapsulated for irradiation shall not exceed 650 grams in a single laboratory.
When SNM is in process in the plating lab (Fig. lA), it can be either as a solid (oxide) or in solution (electrolyte 15 gms/ liter, H:U.
1500) and the quantity of either form shall be governed by the formula:
U-235 Oxide Forb9"8b-235 Electrolyte Solution '(gms) < l."
650 350
.NRC'- Proposed Amendment to SNM November 17, 1978 "B.b.
para. 2 Criticality Control In Chemistry Laboratory Criticality control is effected through limit-ing the quantity of SNM in solution that is permitted in a single laboratory to 350 grams or less.
This is less than half the single parameter limit of 760 grams stated in the ANSI N16.1-1969 standard.
The material in pro-cess in the plating laboratory may be either as an oxide or as an electrolyte in solution depending upon the stage of the electroplating process.
If the respective quantities are limited by the formula; SNM As Oxide (gms),SNM In Solution (gms) < 1, and 650 350 the concentration of U-235 in the electroly+.e is less than 15 gms/ liter (H:U. 1500), criticality limits for these materials wilf not be breached even if double batching were to occur.
The criticality limits that apply are as follows:
Form Of Mat'l Limit Reference U02 Dry 29.6 Kg Nuclear Safety Guide TID 7016, Table 3.1,p.71, U08 Dry 43.5 Kg Nuclear Safety Guide 3
TID 7016, Table 3.1,p.71.
U in Solution 2 Kg Nuclear Safety Guide
<l5 gms/ liter (Sphere)
TID 7016, Fig. 2.1,p.28.
4.
The current license, item 6D, allows possession of 400 grams U-235 in a fodl assembly to be brought into a hot cell from the reactor.
This is to allow close inspection of such irradiated fuel in the event it is deemed desirable.
Since such an inspection is out of the ordinary, it would be advantageous to allow this quantity of material to be added to that allowable under item 6B (4600 gm vs the current 4200 gm).
It is proposed that the following note be added to item 6 of the license.
NRC - Proposed Amendment to SNM November 17, 1978 "When it is not required to have reactor fuel elements in the hot laboratory, the 400 grams of U-235 allowed under item 6D may be added to that material that is alloked under 6B, thereby increasing it from 4200 to 4600 grams."
Revised ficor plans are included to reflect the current storage locations and processing laboratories.
A check in the amount of $150.00 is enclosed to cover the administrativ-fee re-quirements of 10 CFR 170.31.
These changes are desired to more clearly define criticality limits and allow easier administration of license conditions in the production of medical radioisotopes.
The granting of these changes will not reduce the safety margins currently existing under this license and therefore, will not endanger life or property and is in the public interest.
Thank you for your consideration.
Very truly yours,
/
/ wM<
J es J. McGovern Manager Radiochemical Prodtmtion JJMcG:js Enclosures (1) Check (2) Figure 1 (3) Figure 1A bec:
Mr. K. D.
George Mr.
C. J. Konnerth Mr. J. C. Perhauch Mr. M. H. Voth
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FIGURE lA 100' s g t 4 4 SUPPLY SOLIITION PLATING PLATING FAN HAKE-UP ROOM O. e-e -e i SAFETY Si!0WER 't g T _1 ~ l ROOF PLUCS(6) / Pl.ATING i [ WASTE 1 1 l2 3 4 5 REccVERY l m R. , R, R. STORAGE CABINETS (3) w*w !!0T LABORATORY - FLOOR PLAN - ilPPER LEVEL SK1389 n, nt ou.',8}}