ML19280B441
| ML19280B441 | |
| Person / Time | |
|---|---|
| Issue date: | 11/06/1981 |
| From: | Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Haynes J JOHN C. HAYNES CO. |
| Shared Package | |
| ML19280B442 | List: |
| References | |
| FOIA-81-512, REF-SSINS-6025 EA-81-072, EA-81-72, NUDOCS 8112040619 | |
| Download: ML19280B441 (4) | |
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IJ07.,C1531c.JM John C. Haynes Company p
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J. C. Haynes, President pE' -
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- 800 Hebron Road
'F Heath, Ohio 43055 Gentlemen:
This will acknowledge receipt of your letters, dated October 2 and October 23, 1981, in response to our letter and Order to Modify License (Order), dated August 28, 1981.
This also corfirms matters discussed between you, R. H.
Wessman and J. R. Metzger, of my staff, in telephone conversations on October 26 and November 3, 1981, respectively.
During the telephone conver-sation on November 3 with Mr. Metzger, you described several aspects of your decontamination plan, instrumentation used at your facility and your discuss-ions with U. S. Ecology Services, Inc., regarding waste shipments.
Also dis-cussed were matters relating to your license renewal and the receiver appointed over the property on which you conducted licensed activities.
Your two letters and the telephone conversations were partially responsive to our questions regarding your surveys and proposed methods of packaging and shipping contsmi-nated waste.
However, there are additional matters which must be resolved.
The Order was issued because: (1) you failed to make required payments to the Commission; (2) you failed to complete a radiation survey and decontamination report incident to the conversion of your license to storage only; and, (3) a receiver had been appointed over the property on which you conducted your licensed activities, all of which led to the conclusion that you were unable to properly control licensed activities.
The required payment to the NRC was received on September 9, 1981.
Also, we have been advised by the Division of Materials Licensing, NMSS, that they have received a modified license application from you indicating a desire for a change from " storage only of material" to " irradiation of crystal material".
Matters relating to the conversion of your license to storage only and the receivorship have not been resolved.
Action on your license application is pending completion of review by NMSS. We understand, from the November 3, 1981 telephone conversation, that plans to resolve the issue of receivership have been discussed with your bank and efforts are underway to close your bank mortgage and be released from veceivership proceedings.
The Order of August 28, 1981 amended License Number 34-13774-31 to authorize only storage of americium-241 oxide and decontamination of the facility.
At this time, those provisions are still in effect. The NRC may, after approval of your plan, require that you decontaminate the facility and prepare the radioactive waste material for traoport.
In oroer for us to approve a 8112040619 821106 IE LIC30 34-13774-01 CF
J. C. Haynes decontamination and packaging plan, we require the additional information listed in the enclosure to this letter.
This information is required pursuant to Section 182 of the Atomic Energy Act of 1954 and should be submitted within 30 days of the date of this letter.
The NRC plans an inspecticn of your facility to confirm the results of your surveys.
Personnel from our Region III office plan to visit your facility on November 17-18, 1981.
Sincerely, Dudley Thompson, Director Enforcement and Investigations Staff Office of Inspection and Enforcemet.t
Enclosure:
as stated bcc:
J. Hickey, NMSS R. Meyer, SRSI A. Grella, SRSI K. Cyr, ELD C. Paperiello, RIII t
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c JMetzger/jh RHWes. an JLieberman DThompson 11/05/81 11/q/81 11/: 6/81 11/go/81
J. C. Haynes decontamination and packaging plan, we require the additional information listed in the enclosure to this letter.
This information is required pursuant to Section 182 of the Atomic Energy Act of 1954 and should be submitted within 30 days of the date of this letter.
The NRC plans an inspection of your facility to confirm tiie results of your surveys.
Personnel from our Region III office plan to visit your facility on November 17-18, 1981.
Sincerely, f
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0keyT,hkson, Director
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Enforcelniint and Investigations Staff Office of Inspection and Enforcement
Enclosure:
as stated
ENCLOSURL ADDITIONAL INFORMATION REGARDING DECONTAMINATION AND PACKAGING 1.
Provide the NRC with the type (s) of survey instruments used in your survey, including portable instrumentation, air sampling equipment (perscanel and stack-exhaust) and equipment used for counting samples.
During the November 3, 1981 telephone conversation. you stated that measurements on the glove boxes were surface contamination measurements for alpha activity and not radiation exposure levels. Confirm this with details on where the antamination is located.
2.
Your October 23rd letter states that all matcrials inside the glove boxes will be transferred to a 55 qallon drum (specification 17H) prior to glove box decontamination.
Confirm, in detail, your statements made en November 3, with respect to the use of plastic bags.
Describe what is to be placed inside them, and how they will be packaged.
3.
While you state that you will be protected from contamination by wearing protective clothinc and equipment (the implication being that you plan to open the glove boxes rather than using the glove box gloves to clean the boxes) you do not describe how the americium-241 contamination will be prevented from escaping the opened gicve boxes.
This could result in contamination of the facility.
Describe, in detail, those measures to be implemented to contain the contamination while performing clean-up of the glove boxes including provisions for air sampling for airborne radioactivity that were discussed by telephone on November 3, 1981.
4.
From the information provideJ in your October 23rd letter, it appears that you estimate contamination to be on the order of about 2 miiliceries.
Any amount of americium-241 exceeding 1 millicurie in a single package requires the use of Type B packaging and must meet the hypothetical accident condition testing specified in Appendix B of 10 CFR 71. The ].4 druni you propose would not likely meet those conditions.
If it is your intention to meet the Type A packaging for normal conditions for transport (10 CFR 71, Appendix A), specify if you intend to use several 17H drums, each containing less than 1 millicurie.
Also specify if you have evalu-ated the 17H container in terms of meeting the criteria for Type A oackaging provided in Appendix A to 10 CFR 71, and 49 CFR 173.395(a)(1) of DDT regulations.
In your Type A packaging evaluation, describe what bases were used, such as those studies performed by Mound Laboratories, to certify certain types of packages as DOT Specification 7A packages.
5.
You state that lead bricks will be loaded into the drum in order to achieve the desired specific activity of 10 nanocuries per gram of material for transuran cs.
The burial or commercial waste disposal firm i
that will receiva the material should be consulted on this approach, i.e.,
whether it is appropriate to consider the weignt of the nonradioactive mate rial.
This was discussed with you on November 3, but we request specific details concerning your discussions and understandings with U. S.
Ecology Services, Incorporated.
6.
In your October 23, 1981 1etter, you specify an efficiency factor of 0.4 for ycur radiation survey instrument.
However, we do not understand the use of the additional efficiency factor of 4.55 as stated in your letter.
Clarify the basis for this factor.
7.
YoustateinyourOctober23rdletterthattgeradioactivecontamination of the water in the storage tanks is 3.4x10 uCi/cc.
However, you say nothing about mixing or stirring the water to provide even dispersal of the radioactivity which may have settled on the bottom or sides of the tanks.
It is, therefore, not clear whether the sample taken is truly representative of the concentration in the water.
This should be clarified.
8.
You stated, during the November 3, 1981 telephone conversation, that you would obtain a record from Nuclear Engineering Company indicating the quantity of americium-241 buried at the Kentucky waste burial site as a result of your shipment of February 19, 1974.
Please provide us with a copy of that record.
.',lso, provide a copy of the original receipt record of the bulk americium obtained.