ML19267A320

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Responds to 781114 NRC Ltr Re Violations in Insp Rept 70-687/78-02.Corrective Actions:Waste Storage Area Sign Was Posted But Was Inconspicuous,Excess U-235 Eliminated & Rules Posted.W/Encl Ltr Re SNM Mass Limits Justification
ML19267A320
Person / Time
Site: 07000687
Issue date: 12/08/1978
From: Mcgovern J
UNION CARBIDE CORP.
To: Galen Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML19263B137 List:
References
NUDOCS 7901050383
Download: ML19267A320 (10)


Text

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r.5 %, p UNION CARBIDE CORPORATION d gi g e.o. sox u4. TuxEco. new voR x lo9er TE LEPHON E: 914-351 2131 CORfCAATE RESEA RCH LASORATORY December 8, 1978 U.

S. Nuclear Regulatory Commission Region I 631 Park Avenua King of Prussia, Pa.

19406 Attn:

George H.

Smith, Chief Fuel Facility & Materials Safety Branch Subj:

Inspection 70-687/78-02

Dear Sir:

Your inspection report, 70-687-78-02, dated 11/14/78 requested our statements of corrective measures and times when measures have been or will be accomplished on non-comoliance items tnat were sited in the report.

You also requested our comment on our alleged deviation from industry standard practices referred to in your recort.

The corrective actions regarcing the non-compliance items are as follows:

A.

Regarding the deficiencies in posting radiation areas with proper signs:

1.

The waste storage building actually was posted with the standard Caution-Radiation Area placard on tne dates of the inspection, and has been posted con-tinuously for a period several years back.

The sign is not particularly conspicuous due to weathering effects, however, it is still legible.

As noted in the inspection document, a new caution-Radiation Area sign was installed on October 13, 1978.

In the future we plan to be more vigilant concerning replacement of weathered signs and of posting requirements in general.

7901050363

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USNRC December 8, 1978 It should be noted that there is a lock and key control over access to the building so that an unsuspecting person could not enter the area.

2.

In addition to the sign observed by the inspector, thtr:

were three standard Caution-High Radiation Area signs located on the perimeter of the High Radiation area.

The cardboard sign referenced in the inspection report was installed to provide additional information for persons performing work in the area rather than as a substitute for the official sign.

Survey instructions were indicated on this hand written sign as well as the high radiation caution.

Also note that the high radiation designation was tem-parary and the area was reclassified as a Radiation Area within a few days following the inspection.

B.

Regarding t%e location of U-235 in excess of the 650 gram limit in our waste processing cell:

WeanticipatedsuchaprobleminDecember1977andon12/28/7j application was made for increasing the allowable quantity for SNM storage in hot cells as waste.

This application was modified on 5/3/78.

The license was amended to increase this limit on 10/30/78.

Occasions on which three or four drums containing up to 300 grams of solid U-235 each accumu-late prior to disposal are now,and in the future will be within the new license limit.

C.

Regarding the time interval between audits:

The Nuclear Safeguards Committee will formulate a schedule for this audit and others that are required by this license and others, thus insuring that audits are accomplished at the appointed times.

D.

Regarding the posting requirements of 19 CFR 21.6 :

The regulations in the ' referenced part and the procedures that were adopted to implement Part 19'were posted on a clipboard with other regulations that are required to be posted.

Section 206 of the Energy Reorganization Act was not posted.

These and other regulations are located on two Bulletin Boards in the central hallway on the main floor of the hot lab building.

Everyone occupying the Reactor and Hot Lab passes thru this hallway daily.

There are many regulations required to be posted and over the years this board has become somewhat crowded.

In an attempt to make