ML19290E016
| ML19290E016 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 01/09/1980 |
| From: | Voth M UNION CARBIDE CORP. |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19290E010 | List: |
| References | |
| NUDOCS 8003040010 | |
| Download: ML19290E016 (4) | |
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UNION CARBlDE CORPORATION I#L 0 S '[
MEDICAL PRODUCTS DIVISION P.O. BO X 324, T UXEDO, NEW YO R K 10987 TELEPHONE: 914351-2131 January 9, 1980 U.
S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attn:
George H.
Smith, Chief Fuel Facility & Materials Safety Branch Subj:
INSPECTION 70-687/79-05
Dear Sir:
Your December 14, 1979 report of the above referenced inspection identified certain activities that were allegedly not conducted in full compliance with NRC requirements.
Our comments cn these inspection findings are stated below after an exerpt from your report which identifies each concern.
A.
"On October 29, 1979, the Nuclear Safeguards Committee did not ascertain that procedures are being properly followed in that air velocity measurements taken on a hood located in the Plating Laboratory showed that under conditions of use, at the time of this inspection, the air velocity in the operator's breathing zone was 50-75 linear feet per minute rather than the required 100 to 150 linear feet per minute."
Response: At the time of the inspection there were in-structions on the hood in question stating the maximum allowable opening of the hood based on adequate venti-lation air flow.
However, the instruction was not being followed.
Since that time a mechanical stop has been installed which restricts the window opening.
8 0 03 0 40,(), c) :
Inspection 70-687/79-05 January 9, 1980 B.
"No evacuation drills were scheduled and conducted semi-annually during the time period October, 1978 to October 31, 1979."
Response: Contrary to the above, drills were conducted during the time period in question; however, the in-spector questioned the documentation and the nature of the drills.
In mid-1979 the file folder containing records of eva-cuation drills was found missing from our central filing system.
We could therefore not produce documentation showing that drills had been performed.
An extensive search has not produced the records.
A new file has been created to document future drills.
Our June 13, 1973 letter referenced in Condition 9 of license SNM-639 states, " Drills of the Hot Laboratory evacuation procedure will be conducted semi-annually."
followed by the procedure which addresses radiation monitoring, notification of offsite agencies, care for injured, etc.
The inspection report references a May 3, 1977 letter to the licensee on this matter, presumed to be a May 13, 1977 inspection report wherein the required drills are interpreted to be preplanned simulations of accidents.
Be that as it may, we have reconstructed the following record of drills done in compliance with the requirement for semi-annual drills during the interval in question:
Date Nature of Drill Site fire drill 8 N "- u / h e O d 10/11/78
[k 11/27/78 M04M Simulated Hot Lab fan room fire
,24, dad /
02/27/79 hM t
Simulated personnel injury with.g p, y gross contamination 06/29/79' fid Site fire drill
/a h.
7/79 or 8/79 Scheduled Hot Lab evacuation drill (exact date not recorded, personal recollection only) 09/04/79 Demonstration of Scott Air Pack operation during an unscheduled Hot Lab evacuation
Inspe'ction 70-687/79-05 January 9, 1980 While the last entry can be challenged as to its appli-cability to the license requirement under the Region I interpretation, the remaining drills listed constitute compliance well in excess of the minimum requirements.
C.
"On October 29-30, 1979 the storage of unirradiated U-235 contaminated waste in drums was not posted with criti-cality safety signs which indicc.e the maximum quantity of special nuclear material thst is authorized and the actual amount that is present in the target makeup area on the second floor, outside the Quality Control Laboratory or in the tunnel at the drum counting station."
Response: Trace quantities of enriched uranium appear as wastes in our operation.
Wastes are packaged in 55 gallon drums having an average of five to ten grams of U-235 essentially uniformly distributed throughout each drum.
For comparison note that the accepted single parameter lLmit for aqueous solutions is 11.5 grams U-235 per liter, more than 200 times the concentration of our drums.
Because of the large volume involved relative to space limitations, drums of uranium-contaminated wastes have been stored outside of the individual laboratories which are posted as storage areas.
To correct the situation, storage areas are being expanded to encompass those areas where drums are stored.
Specifi-cally, the #2 Makeup Lab storage area will include waste collection drums and waste drums in storage on the second floor and liquid waste drums awaiting processing on the first floor.
Likewise, the Quality Control Lab storage area will include the area outside the lab and the tunnel.
While the quantities involved are miniscule, this move is in the conservative direction since SNM is dispersed, in-creasing the margin of sub-criticality.
Existing signs are being modified to indicate the revised boundaries of the storage areas; the posted maximum SNM will remain the same.
The newly designated additions to storage areas will be posted as such.
For example, "SNM Storage Area, and Extension of the #2 Make-up Lab Storage Area, subject to the SNM limit posted thereon."
Since the material in waste drums is already inventoried as part of the designated storage areas, there will be no changes to the inventory procedures.
The new signs will be posted within 30 days.
Inspection 70-687/79-05 January 9, 1980 D.
"On October 31, 1979, it was determined that the two Model B-3 shipping casks used to transport irradiated U-235 waste to burial, were not constructed in accordance with Battelle Memorial Institute (BMI) Drawing No. 9958-8501-000E, Revision B or C, specified in Certificate of Compliance No. 6058, Revision 4, dated April 27, 1979.
The two casks were built in accordance with Protective Packaging Incorporated (PPI) Drawing D-35136."
Response: The PPI construction drawings were necessary for fabrication of the casks because the BMI drawing re-ferenced in the license provided inadequate detail for shop fabrication.
Since the discrepancies between draw-ings identified by the inspector were non-safety related and were not critical assumptions in the safety analysis, we. sought the position of the Transportation Certification Branch of the NRC Division of Fuel Cycle and Materials Safety.
We were informed that the casks were considered out-of-specification and should be removed from service until the license was amended.
The casks were taken out of service while a complete design review was performed.
The items noted by the inspector along with additional trivial discrepancies were identified.
Certificate of Compliance No. 6058, Revision 5 was issued on November 8, 1979, approving the as-built casks.
They were returned to service immediately.
Yours very truly, W
Marcus H. Voth Manager Nuclear Operations MHV:js
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