ML19290E028
| ML19290E028 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 11/28/1979 |
| From: | Crocker H, Kinney W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19290E010 | List: |
| References | |
| 70-0687-79-05, 70-687-79-5, NUDOCS 8003040026 | |
| Download: ML19290E028 (12) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-687/79-05 Docket No.70-687 License No. SNM-639 Priority 1
Category UR Licensee: Union Carbide Corocration P. O. Box 324 Tuxedo, New York 10987 Facility Name: Sterlina Forest Research Center (Hot Laboratories)
Inspection at: Tuxedo, New York Inspection conducted: October 29-31, 1979
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Inspectors:
J.~'Roth, Prpject Igspector
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'M, W. W. Kinney,/ Project' Inspector
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f 6 Approved by:
un H. W. Crocker,4hief, F0el Facility Projects cate-signed Section, FFSMS Branch Inspection Summary:
Inspection on October 29-31, 1979 (Report No. 70-687/79-05)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the licensed program including:
10 CFR Part 21; organization; facility changes and modifications; internal review and audit; safety committees; procedure control; review of operations; nuclear criticality safety; emergency planning-drills; initial use of packagings; and, licensee actions on previously identified enforcement items.
The inspection was conducted during regular working hours and involved 32 inspector-hours onsite by two NRC regional based inspectors.
Results:
Of the 11 areas inspected, no items of noncompliance were identified in 7 areas; 5 items of noncompliance were identified in 4 areas (Infraction -
failure to maintain a contaminated hood face velocity at 100-150 lfpm in the Plating Laboratory (79-05-01), Paragraph 4a; Deficiency - Failure to post unclear safety signs in drum storage areas (79-05-02), Paragraph 4b(3); In-Region I Form 12 (Rev. April 77) 80030400 %
fraction - failure to conduct two scheduled evacuation drills between October, 1978 and October, 1979 (79-05-03), Paragraph 8; Deficiency - failure to construct model B-3 shipping casks in accordance with the drawing specified in Certificate of compliance (79-05-04), Paragraph 9).
DETAILS 1.
Persons Contacted
- C. S. Konnerth, Manager, Health, Safety and Environmental Affairs
- L. Thelin, Supervisor, Health Physics
- J. J. McGovern, Business Manager, Radiochemical Products M. H. Voth, Manager, Nuclear Operations
- denotes those present at the exit interview.
The inspector also interviewed other licensee employees during the course of this inspection.
They included MBA custodians, health physics technicians, hot cell operators, reactor and hot cell operations supervisors, and general office personnel.
2.
Licensee Action on Previousiv Identified Enforcement Items (Closed) Infraction (687/78-02-05):
Failure to conduct a nuclear safety audit of the hot laboratory facilities each 12 months.
The inspector verified that the Nuclear Safeguards Committee had established a frequency for the conduct of 9 internal audits of the hot laboratory and reactor operations.
An audit of the hot laboratory nuc. ear safety was conducted as required on August 31, 1979.
Results of this audit are discussed in Paragraph 5.b of this report.
Corrective actions have been completed on this item of noncompliance.
(Closed) Deficiency (687/79-02-01):
Failure to maintain an array of 17H drums in the waste storage hot cells as authorized by Amendment No. 2.
The inspector verified through discussions with operations personnel that the licensee is not stacking 17H drums containing Uranium 235 and instructions have been issued to operators which pruhibit this practice.
These procedures are being followed in lieu of amending the facility license to allow stacking.
Corrective actions have been completed on this item of noncompli-ance.
(Closed) Infraction (687/79-02-02):
Failure to survey for alpha contamin-ation as required by 10 CFR 20.201(b).
The inspector verified that the licensee has issued instructions to all personnel working with radioactive material to monitor when leaving these areas.
These instructions have been given during work place meetings and have been posted on a bulletin board which is available to all personnel.
The inspector also noted that individuals leaving the target make-up area surveyed for contamination prior to leaving this area.
Corrective actions have been completed on this item of noncompliance.
4 (Closed) Deficiency (687/79-02-03):
Failure to maintain a running inventory log of U-235 in the welding laboratory, the solution make-up laboratory, the plating laboratory, the waste solution storage laboratory, and the five hot cells as required by License Condition 15.
The inspector verified that running inventory records had been established for the welding laboratory, the solution make-up laboratory, the plating laboratory, the waste solution storage laboratory, and the five hot cells.
Corrective actions have been completed on this item of noncompliance.
(Closed) Deficiency (687/7S-02-04):
Failure to post Caution - Radioactive Materials signs on the QC laboratory and a U-235 containing storage drawer in the QC laboratory as required by 10 CFR 20.203(e)(1).
The Caution -
Radioactive Materials signs had been posted as required prior to the end of inspection 70-687/79-02.
The inspector verified that a memorandum had been issued to all personnel asking personnel to identify unmarked storage areas so that they may be properly posted.
Corrective actions have been completed on this item of noncompliance.
(Closed) Infraction (687/79-03-01):
Failure to post the amount of U-235 present in the solution laboratory and a fuel storage cabinet as required by License Condition 14.
The inspector verified that the licensee had posted the fuel storage cabinet with a log sheet which indicated the current U-235 contents of the cabinet and that the solution make-up laboratory had been posted with a running inventory sheet to indicate the current U-235 contents of the laboratory.
Corrective actions have been completed on this item of noncompliance.
3.
Organization The following is the current organization of the UCC-Sterling Forest Medical Products Division effective October 1,1979. The Site Manager is R. E. Bollinger, Vice President / General Manager, Nuclear Products Reporting to Mr. Bollinger are:
M. W. Sowa, Director, Administration J. J. McGovern, Business Manager, Radiochemicals D. B. Holtzgraf, Business Manager, Radiodiagnostics M. J. Liberta, Plant Manager H. E. Fritz, Project Manager Reporting to Mr. Sowa are:
C. J. Konnerth, Manager, Health, Safety and Environmental Affairs W. D. Walton, Manager, Employee Relations J. Resetar, Manager, Accounting Office
5 Reporting to Mr. McGovern are:
K. D. George, Senior Scientist J. C. Perhanch, Business Analyst F. S. Morse, Process Engineer E. P. O' Gull, Manager, Materials W. W. Leinheiser, Supervisor, QC M. H. Voth, Manager, Nuclear Operations D. D. Grogan, Hot Lab Supervisor
, Reactor Supervisor (Vacant)
H. C. Hart, Facilities Engineering Reporting to Mr. Konnerth is:
L. Thelin, Supervisor, Health Physics 4.
Review of Operations The inspectors examined all areas of the hot laboratory facility to observe operations and activities in progress, to inspect the nuclear safety aspects of the facility and to check the general state of cleanli-ness, housekeeping, and adherence to fire protection rules.
a.
Plating Laboratory Hoods During examination of the plating laboratory, the inspector observed an operator working in a contaminated hood with the hood door full open.
There were markings on each side of the hood, at about 8 to 9 inches below fully open which stated " keep hood at this level,"
which was signed "HP."
The inspector requested that hood face air velocity readings to be taken by a licensee representative with the hood open fully and at the indicated level.
Readings taken showed that with the hood door fully open, the air velocity in the operator's breathing zone was about 50 to 75 linear feet per minute.
With the hood door closed to the indicated level, the air velocity in the operator's breathing zone was about 100 to 125 linear feet per minute.
An untitled procedure located in a manual of health physics procedures in the Health Physics Office stated that " hoods and dry boxes are protective devices used to confine radioactive materials.
The rate of intake of air into hoods should be sufficiently high to keep contaminated air out of the room; yet, it must not be too high so that small light articles are upset by moving air.
A hood face velocity of 100-150 linear feet per minute is required..." Failure to maintain the contaminated hood face velocity at 100-150 lfpm in the plating laboratory was identified as an item of noncompliance (79-05-01).
6 b.
Nuclear Safety Signs (1) General The inspector noted that the licensee had posted nuclear safety signs for all the laboratories, hot cells, and raw fuel storage cabinets.
However, it was observed th:t the signs posted at the solution make-up lab, the plating laa, the waste solution lab, the welding lab, and the QA lab contained the following nuclear safety limits:
650 grams U-235 as a solid, 350 grams U-235 as solution or solid + solution = 1.
4 o50 350 There was no indication as to which of the three limits was being used in any of these areas.
Examination of the running inventory logs maintained at each location indicated that the licensee seldom exceeded the most restrictive limit of 350 grams U-235.
In the one instance when the 350 gram limit was exceeded in the solution make-up lab, the entry in the running inventory log indicated that oxide was taken into the lab.
The inspector noted to licensee representatives that a more reliant means should be devised to indicate the form of U-235 being transferred into or out of these areas so that the operator when making a transfer, would be easily capable of determining t.e nuclear safety limit in use at the time of the transfer.
(2) Post U-235 Balance The inspector observed that the nuclear safety signs posted at the Health Physics lab and the QC lab did not indicate the current U-235 balance in the area as required by License Condition 14.
Licensee representatives stated that the balance in the individual labs was being kept in a log book maintained in the lab.
(3) Drum Storage Areas The inspector noted that areas used for the storage or unir-radiated contcminated waste were not posted with nuclear safety signs as required by License Condition 14.
Drums loaded with nonirradiated contaminated waste were observed stored in the target make-up area on the second floor, outside the QC laboratory and in the tunnel at the drum counting station.
This was identified as an instance of noncompliance (79-05-02).
7 (4) Health Physics Area Log Book The inspector observed that the Health Physics Area was posted with a 650 gram U-235 nuclear safety limit.
The licensee transfers primary encapsulated unassayed target tubes into this area for contamination level checks.
Through discussions with licensee representatives and health physics technicians, it was determined that a value of 20 grams U-235 has been assigned to each target tube coming into the area and that no more than 32 target tubes enter the area at any one time.
Examination of the inventory log for the area indicated that between October 25 and October 29, 1979, 32 tubes were located in the area in addition to approximately 36.5 grams of U-235 in standards kept in the area.
This would have indicated a total of 676.5 grams based on assay values obtained for target tubes.
It appears that the historical maximum quantity of U-235 in a target tube would be closer to 17 to 18 grams instead of 20 grams.
If this were the case as it appears to be there would have been a maximum of 612.5 grams of U-235 in the area at the time.
- Thus, indicating that the assignad 20 gram quantity is a conservative estimate of U-235 content in each target tube.
The inspector also noted that the technique used by the licensee for maintaining a running balance in the Health Physics Laboratory is batch oriented rather than time oriented which makes it difficult at best to determine the actual balance of U-235 in the area at any one time.
This was discussed with licensee representatives who indicated that an item count technique to maintain a running balance of U-235 in this area will be investi-gated.
c.
Contamination Control The inspectors observed that the alpha contamination survey instrument used for the foot counter located at the exit to the target make-up area was set on the 10x scale.
The posted instructions indicated that if a contamination level of 40 counts per minute above background was observed, the individual should notify Health and Safety.
It was noted that with the instrument set on the 10x scale, 40 counts per minute above background could not be observed.
Discussions with licensee representatives indicated that the instrument continued to alarm if set on the lx scale, thus, it was set on the 10x scale.
The inspectors commented that the instrument as observed could not be used as intended. The licensee representative immediately reset this instrument on the IX scale and found that it was operating properly.
8 5.
Nuclear Criticality Safety a.
Radiation Monitors The inspector verified that all facility area radiation and criticality monitors appeared to be operating properly.
Each monitor was provided with a remote readout meter located on a control panel which was located in the hot cell operating area.
All monitors were set to alarm between 5 and 10 mr/hr with the exception of the monitor located in the filter room.
The inspector examined calibration records for the radiation monitors for the time period April, 1977 through April, 1979.
The radiation monitors had been calibrated at least once each 12 months.
The licensee also conducts a daily check on these monitors with an internal check source to check meter response and a monthly check for operation of the alarm system.
Daily monitor check records for the time period January 8, 1979 through October 29, 1979 were examined by the inspector.
When problem areas were identified, immediate corrective action was taken by the licensee.
b.
Criticality Safety Audits The inspector questioned licensee representatives regarding the conduct of internal audits during the time period August 25, 1978 through October 30, 1979.
The inspector reviewed the reports of audits conducted during this time period.
The license requires that a nuclear safety audit be conducted once every 12 months.
The nuclear safety audit was conducted on August 31, 1979, by an individual assigned by the Nuclear Safeguards Committee.
The items examined during this audit include SNM limits, posting of laboratory SNM contents, the establishment of running totals of SNM in each laboratory, incoming U-235 shipping records, total inventory of SNM, and, cabinet locking systems.
Areas of weakness were identified in this report and corrective actions have been taken by the licensee.
c.
Nuclear Safeguards Committee The inspector examined the records of one meeting of the Nuclear Safeguards Committee held between March 20, 1979 and October 29, 1979.
The meeting was held on September 11, 1979.
Review actions and recommendations made by the Committee were adequately documented.
Included with these records were supporting documents used by the Committee to develop the recommendations made.
In addition, the implementation of these recommendations was documented in the Committee minutes.
The next meeting of the Committee was scheduled for Novamber 14, 1979.
9 d.
Facility Changes and Modifications During examination of the facility, and through discussions with licensee representatives, the inspector determined that the licensee is considering moving the waste solution storage laboratory from its current location next to the plating laboratory to a half walled, partitioned enclosure located at the north end of the target make-up area.
Additional target tuoe plating systems would then be installed into the current waste solution storage laboratory.
Work on this facility and equipment modifications had not been initiated at the time of this inspection.
6.
10 CFR Part 21 The inspector verified that the licensee had posted the notice with the information required by 10 CFR 21.6 and that the licensee had developed the procedures required by 10 CFR 21.21 to implement the requirements of 10 CFR Part 21.
These procedures are available for use by facility personnel if required.
7.
Procedure Control Procedures are written by members of the staff ano submitted to the Nuclear Safeguards Committee for review and approval.
This Committee controls the maintenance and issuance of all procedures.
The facility Procedure Manual was examined by the inspector.
This manual contains procedures relative to operations in both the hot laboratories and the research reactor.
Procedure No. AD-01 is an administrative procedure which specifies the techniques to be used to write, approve, and modify operational procedures.
The inspector noted that a revision of this procedure dated September 17, 1979, referred only to reactor procedures and did not address hot laboratory procedures.
This was discussed with licensee management and the inspector was informed that this procedure will be revised to include hot laboratory procedures.
It was also noted that procedure AD-01 indicated that a series of Health Physics procedures designated "HS-
" were to be in the Procedures Manual.
However, no procedures with this designation had been incorporated into the manual.
This was also discussed with licensee representatives who indicated that this series of procedures had not been written.
Hot laboratory procedures reviewed by the inspector included:
H0-1 dated May 15, 1975, " Hot Lab Operations Manual" H02 dated May 15, 1975, " General Regulations" H0-3 dated May 15, 1975, " Regulations for Working with Radioactive Material Outside of Hot Cells"
10 HO-4 dated May 15, 1975, ' Iodine Dispensing Procedure" H0-5 dated May 15,1975, " Operation of the Inter-Cell Conveyor" H0-6 dated May 15, 1975, "Use of Hoods" HO-7 dated May 15, 1975, " Handling of Manipulators" H0-8 dated May 15, 1975, " Operations with Radioactive Materials Outside of Hot Cells" H0-9 dated May 15, 1975, "Radicchemical Assays" In addition, the inspector reviewed an unapproved draft of Procedure HO-10 dated October 1, 1979, " Plating Lab Function."
As indicated during inspection 70-687/79-02, the inspector determined that these procedures were not found to be readily available to operators for reference in that the procedures were maintained in the receptionist's office which was not conveniently located with respect to the work areas which covered four floors of the facility.
In addition, it was determined that none of the procedures discussed nuclear safety, nuclear safety criteria, radiological safety, or the administrative controls required to maintain nuclear or radiological safety other than SNM accountability requirements.
This was discussed with licensee representatives who stated that each operator was aware of the established location for maintaining copies of the procedures and that the operators leave the work area to review the procedures if necessary.
The inspector also noted that these procedures had not been revised since May, 1975.
Licensee representatives indicated that substantial changes have not been made in procedural details.
8.
Evacuation Drills The inspector questioned licensee representatives and examined records concerning evacuation drills and unscheduled evacuations which occurred at this facility between October 10, 1978 and October 29, 1979.
During this time period the licensee did not conduct any scheduled evacuation drills as required by license conditions.
However, during one unscheduled power outage on September 4, 1979, the licensee instructed all personnel present in evacuation procedures and held a Scott Air Pack drill during which personnel were instructed in how to put on and operate the equipment.
The licensee had misplaced the records relating to unscheduled evacuations for the time period prior to May, 1979.
Thus, these records could not be examined.
The licensee indicated that they were utilizing the unscheduled evacuations in lieu of scheduled evacuations in order to comply with the requirement to hold 2 scheduled drills each year.
As indicated in a
11 letter to the licensee dated May 3, 1977, " unscheduled (false alarm) evacuations cannot be substituted for required scheduled evacuation drills.
Unscheduled evacuations are not preplanned simulations of ac-cidents testing the adequacy of timing, the adequacy of emergency procedures, and the adequacy and operability of emergency equipment and facilities.
Failure to conduct 2 scheduled evacuation drills between October, 1978 and October, 1979, was identified as an item of noncompliance (79-05-03).
9.
Initial Use of Packages This facility is an authorized user of the Model B-3 shipping cask (Certifi-cate of Compliance 6058).
Prior to the last inspection (70-687/79-02) the licensee had informed NRC-NMSS that the Model B-3 casks had been removed from service because of licensee identified manufacturing defects.
During that inspection, the inspector examined documentation related to the defects and physically examined the modifications being made to the casks.
Subsequent of inspection 70-687/79-02, the licensee placed the casks back into service.
During this inspection, the inspector examined the documentation maintained by the licensee relative to the Model B-3 shipping casks and determined that the licensee had a cnpy of the latest revision of the Certificate of Compliance for the B3-1 cask, Certificate of Compliance No. 6058, Revision 4, dated April 27, 1979.
The inspector reviewed the certificate and the licensee's copies of the drawing and letters referred to in the certificate.
The licensee had copies of all the drawings and referenced letters.
The inspector reviewed the information supplied by the supplier for the casks for the two B3-1 casks the licensee owns and uses.
This information stated that the casks were built in accordance with Protective Packaging, Inc. (PPI), Drawing D 35136, " Cask Ass'y B-3."
However, Certificate of Compliance No. 6058 in Section 5(a)(3), Drawing, states that, "The packaging is as described and constructed in accordance with Battelle Memorial Institute (BMI) Drawing No. 9958-8501-0001E, Revision B or Revision C."
Review of PPI Drawing D 35136 and the drawings referred to on this drawing showed discrepancies between the Protective Packaging, Inc. drawings and the BMI drawing, which are discussed below.
The PPI drawings called for the steel components of the cask to be stainless steel, and the BMI Drawing No. 9958-8501-0001, Revision B, called for the steel components to be mild steel.
Also, the PPI drawings called for the outer shell to be 1/2 inch thick plate material, and the BMI drawing called for the outer shell to be a laminated steel construction with the inner laminate being 1/2 inch plate material and the outer laminate being 1/4 inch plate material.
As indicated above, the licensee recognized
12 this problem early in 1979, and the licensee installed the 1/4 inch stainless steel plate laminate on the outside of their 83-1 casks.
The licensee also requestec;, with appropriate justification, that the Certi-ficate of Compliance be revised to allow the use of stainless steel rather than mild steel as the material of construction of the cask.
The BMI Drawing No. 9958-8501-0001E was revised to Revision C to specify that the material of construction was stainless steel.
The casks were out of service until the casks were modified and the Certificate of Compliance was revised.
The PPI drawings called for the gasket used to seal the lid to the body of the cask be a silastic 0-Ring 32.64 I.D. x 1/4" diameter, and the BMI drawing called for this gasket to be a silastic 0-Ring 32 1/2 I.D. x 3/16" diameter.
The groove on the lid to hold the gasket in place were also designed for the different gaskets specified.
The PPI drawings called for washers to be used under the bolts holding the lid in place on the body of the cask, and the BMI drawing showed no washers being used.
The PPI drawings called for the cask cavity to be 43.25 inches deep, and the BMI drawing called for the cavity to be 43.00 inches deep.
The fact that the casks were not constructed in accordance with the drawing specified in the Certificate of Compliance is an item of noncompliance (79-05-04).
In this instance it appears that the drawings should be revised to show the actual "as built" configuration and the Certificate of Compliance revised to refer to these corrected drawings.
10.
Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection at 3:00 p.m. on October 31, 1979.
The inspector summarized the scope and findings of the inspection.
The licensee was notified telephonically on November 8, 1979, that the item relative to the failure to hold scheduled evacuation drills (Paragraph 8), and the nonconformance of the B-3 shipping casks to the drawings specified in the Certificate of Compliance, would be issued as items of noncompliance.