ML19310A074
| ML19310A074 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 04/17/1980 |
| From: | Crocker H, Kinney W, Kottan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19310A072 | List: |
| References | |
| 70-0687-80-02, 70-687-80-2, NUDOCS 8006060041 | |
| Download: ML19310A074 (9) | |
Text
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U. S. NUCLEAR REGULATORY CO MISSION O
OreICe De INSeeCTION AND eNF0aceaeNT i
REGION I Report No.
70-687/80-02 Docket No.70-687 License No.
SNM-639 Priority 1
Category UR Licensee:
Union Carbide Corporation P.O. Box 324 Tuxedo, New York 10987 Facility Name:
Sterling Forest Research Center (Hot Laboratories)
Inspection At:
Tuxedo, New York Inspection Conducted:
January 29 - February 1, 1980 Inspectors:
A rs
/ /4 o
W. W. Kinne to ' ct/ Inspector
' date YN
/ 6fA J. 'J.1(ottan, fAadiatj6n Specialist
' date date Approved by:
C//#/$2'O a
H. W. CrockerMief, Fuel Facilities
' ' date' Projects Section, FF&MS Branch Inspection Summary:
Inspection on January 29-February 1, 1980 (Report No. 70-687/80-02)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector on the licensee's program for the packaging of low-level radioactive waste for transport and burial.
The inspection involved 32 inspector-hours onsite by two region-based inspectors.
Results:
No items of noncompliance or deviations w0re 3dentified.
Region I rorm 167 (August 1979) 8006060 M/
DETAILS 1.
Persons Contacted
- J. J. McGovern, Business Manager, Radiochemical Products
- M. H. Voth, Manager, Nuclear Operations H. C. Hart, Facilities Engineer
- L. Thelin, Supervisor, Health Physics
- Denotes those present at the exit interview.
2.
Scope of Inspection Part of this inspection on the packaging of low-level radioactive waste for transport and burial concerned the areas of concern listed in a letter from Heyward G. Shealy, Chief, Bureau of Radiological Health of the State of South Carolina to G. Wayne Kerr of the NRC Office of State Programs.
Mr.
Louis S. Cabasino of the State of New York Department of Labor participated in this part of the inspection.
The rest of the inspection concerned inspec-tion of the licensee's actions in response to IE Bulletin 79-19.
3.
State of South Carolina Concerns a.
Radioactive Content in Waste Shipments Union Carbide Corporation produces medical radioisotopes by irradiating highly enriched uranium targets for a short period of time.
The irra-diated material is chemically processed to separate the molybdenum-99 from the other fission products and the uranium.
The material other than the molybdenum is packaged for burial.
The licensee has charac-terized the distribution of the fission products produced by the irradiation process which is performed repeatedly.
The licensee mea-sures the gamma radiation from a drum containing the waste fission products, and calculates the amounts of the various fission products in the waste from the gamma radiation measurement.
The licensee keeps records on the amount of uranium in each component and process stream.
The amount of uranium in the waste is calculated by use of these records, b.
Transuranic Element Content of Waste The licensee considers the plutonium-239 produced from the n, y con-version of uranium-238 to be the only significant transuranic in the waste sent to the Barnwell burial site.
The licensee calculates the amount of plutonium-239 present in waste from the amount of uranium-238 l
1
3 initially present in material which was irradiated and processed to produce the waste and the neutron flux and irradiation time for the material in the reactor.
The licensee has determined from these cal-culations that the concentration of the plutonium in the aluminum cylinders used to incapsulate the liquid wastes solidified with con-crete is within the 10 nanocurie per gram limit.
Two of the aluminum cylinders containing 15 pounds of solidified waste are placed in 55 gallon drums which typically weigh 275 pounds.
The inspectors suggested that the licensee investigate the possibility of obtaining laboratory analyses of the plutonium content of the liquid waste containing the plutoniem.
The licensee indicated they would attempt to get actual analyses of the plutonium content of the waste.
c.
Solidification Process used on Liquid Waste The liquid waste destined for burial at the Barnwell facility is the liquid containing the uranium and fission products discussed in the foregoing section.
The liquid waste is mixed with cement inside a 5 inch diameter aluminum container approximately 12 inches high.
According to the licensee, they had bench tested the procedure and demonstrated that there was no free standing liquid using the cement to liquid ratio defined in their procedure.
The welded aluminum con-tainer has an aluminum pipe nipple welded on the top for introduction of the cement and liquid into the container.
An iron pipe cap is used to seal the container closed.
As indicated previously, this con-tainer is placed inside a 55 gallon drum.
d.
Radioactive Gases The licensee performed an experiment to determine the origin of the airborne radioactive material which was detected when sampling the air close to the waste drums.
The' licensee found that the radioactive iodine was contaminating the outside surfaces of the waste drums while the drums were in the hot cells.
The licensee also found that wash-ing the drums with a sodium hydroxide wash prior to removal from the hot cell was an effective way of removing the contamination.
The licensee also started to wash the inside of the 83-1 casks prior to loading the waste drums inside the cask.
e.
Description of Waste Type and Form The types of waste are the solidified liquids, described previously, and dry waste.
The dry waste is glass ware, glass filters, tubing, vycor crucibles, aluminum and stainless steel target capsules, resins, absorbent media, and syringes.
4 The licensee places the compressible dry waste inside gallon containers.
The containers are then crushed to approximately two-thirds the origi-nal volume.
The chemical constituents are compounds containing uranium, silicon, carbon, aluminum, iron, chromium, molybdenum, technetitm, and mixed fission products. Organic compounds are also present.
f.
Review of Process The process producing the waste was reviewed.
This process review is reflected in the information previously discussed.
The packaging of waste in B3-1 casks for shipment to the Barnwell burial facility was observed.
This is discussed in detail in section 8.a.
of this report.
4.
Copies of Licenses, Regulations, and Requirements The licensee has a current set of DOT and NRC regulations for the packag-ing and transport of low-level radioactive waste material.
The licensee had a copy of Wasington State License No. WN-1019-2 and the pertinent amendments for the Nuclear Engineering Company (NECO) burial site at Richland, Washington.
The licensee also had a letter from NECO dated January 18, 1980, which concerned Amendments 10 and 11 of the Washington State license and gave specific information on conditions of the license.
The licensee did not have a copy of the new NRC license issued to NECO for the Richland burial site.
They indicated they were expecting a copy from NECO in the near future.
The licensee also had a copy of an executive order by the governor of Washington relating to transport of commercial low-level waste.
The licensee had a copy of Nevada State License No. 13-11-00043-02 and its four amendments for the NECO burial site at Beally, Nevada.
The licensee also had a copy of an executive order by the governor of Nevada relating to transport of commerical low-level radioactive waste.
The licensee had a copy of Amendment No. 18 of NRC Materials License No.
46-13536-01 to Chem-Nuclear Systems, Inc., which amended the license in its entirety on August 28, 1979.
The licensee also had a copy of Amend-ment No. 19 to the license.
The licensee also had a copy of Amendment No. 26 to Chem-Nuclear Systems, Inc.
South Carolina Radioactive Material License No. 097, which amended the license in its entirety.
The license had copies of the Barnwell Disposal Site Criteria.
l l
5 5.
Operating P ocedures The licensee has three procedures for packaging of low-level radioactive waste and loading of the waste on vehicles for transport to the burial grounds.
These are:
SP-01 B3-1 Cask Loading and Shipping, dated September 30, 1976 (currently rewritten and being approved);
SP-02 Radioactive Waste Disposal Procedures (currently in last stages for approval); and Health Physics Low Level Waste Shipping Procedures.
The last two procedures were prepared as a result of the review the licensee made as a result of Statement No. 4 of IE Bulletin 79-19.
Procedure SP-01, 83-1 Cask Loading and Shipping,. addresses the inspection of the gasket on the lid of the cask and replacement of gasket if necessary.
Inspection and cleaning of the interior of the cask is called for.
After the waste drum is in the cask, the lid in place, the lid hold-down bolts are coated with an anti-sieze compound and torqued to 50 foot pounds.
The tie downs for holding the cask on the transport sehicle are inspected for damage, wear or corrosion.
The cask is tied down in accordance with a sketch provided in the procedure.
The procedure has places for the opera-tor v.o sign that the work has been completed.
Procedure SP-02, Radioactive Waste Disposal Procedure, provides the instruc-tions for (1) assuring that only that waste allowed for burial at the NECO burial sites in Richland, Washington, and Beatty, Nevada, are packaged for burial; and (2) packaging the waste properly for transport and burial.
The procedure addresses the packaging of the following radioactive waste.
Liquid Scintillation Vials Radioactive Biological Waste - other than Tc99m Non-Radioactive and Tc99m Contaminated Waste (to be disposed of as non-radioactive waste)
Dry Solid Radioactive Waste Radioactive Organic Liquids (Procedure applicable to Washington Burial Site Only)
Aqueous Radioactive Liquids
6 The Health Physics Low Level Waste Shipping Procedures address completing the data sheets, performing the required radiation measurements, labeling the packages, and surveying the transport vehicles after loading.
None of the procedures address the DOT requirements for packages with sur-face radiation levels above 200 mR/hr or 10 mR/hr at 3 feet.
Also the pro-cedures do not address the exclusive use vehicle requirements which must be met if packaging of low specific activity radioactive material is done in accordance with 49 CFR 173.392(b) and (c) rather than in accordance with 49 CFR 173.392(a).
The licensee is preparing a procedure covering the solidification of aqueous liquid radioactive waste.
However, it was not available for review at the time of the inspection.
6.
Training The licensee was preparing a training manual for use by personnel involved in the packaging of waste for transport and disposal.
All personnel involved in the waste packaging will be required to be trained according to the licensee.
As conceived, the personnel will mainly be "self-taught".
The licensee has provided some classroom lectures on waste handling for personnel.
The licensee does not plan to employ methods such as testing, close supervision, and/or periodic.suditing to assure that employees have sufficient familiarity with prccecures and packaging requirements.
7.
Audits The licensee uses the Nuclear Safeguards Committee to perform the auditing of the transfer, packaging, and transport of low-level radioactive wastes.
An audit of transfer, packaging, and transport of lcw-level radioactive waste was performed on October 3,1979, by the Manager of Health, Safety and Environmental Affairs.
This audit identified the need for written pro-cedures for waste disposal.
The licensee did not formally establish and implement an audit program of activities associated with the transfer packaging and transport of low-level radioactive wastes.
The above mentioned audit was the management type audit which was conducted within 60 days after IE Bulletin 70-19 was issued.
8.
Examination of Packages a.
83-1 Casks The inspector observed the activities involved in the preparation of 83-1 casks for loading, the loading of the casks, placement of the casks on the flat bed trailer, and surveying the transport vehicle.
I 1
The inspector inspected the condition of the two 63-1 casks which were to be loaded.
The casks belonged to NECO.
The sealing gaskets were present and appeared to have been in service for a long time.
The insides of the casks had been painted at one time.
Much of the paint was either worn off o' chipped off.
The gasket sealing surface on 1
each cask was rounded and dented from being hit during the loading and i
unloading of drums in the cask and the placing of the lid in place.
j The inspector placed a piece of paper on the sealing surface of the j
cask, and the licensee placed the lid on the cask.
Examination of the paper showed that the gasket was making contact with the sealing surface.
However, the general condition of the casks indicate the need for renovation of the casks by the owners of the casks.
The inspector noted that one of the casks did not have the model num-ber marked on it as required by 10 CFR 71.53(c).
The licensee con-tacted NECO cencerning this.
NECO sent a letter to the licensee cer-tifying that the cask had been fabricated in accordance with the design approved by the AEC (NRC).
NECO asked Union Carbide to mark the con-tainer with its model number, M00. NO. B3-1.
Union Carbide stamped l
the model number on the cask identification plate using 1/2 inch dies.
One of the casks had ice in it.
The licensee used alcohol to speed i
the melting of the ice.
The water-alcohol solution was mopped from the cask.
The mop rags soaked in alcohol and water were not placed in a metal container as required by the licensee's general safety rules.
1 The licensee washed the interior of the casks with a sodium hydroxide i
wash solution.
The inspector noted that the man wore only plastic protective gloves while using the caustic solution.
The licensee's general safety rules require that rubber aprons, gloves, and a full face shield are to be used when working with acid and caustic.
The licensee washed off the outside of an 55 gallon drum of waste using the manipulator while the drum was in the hot cell.
The licensee then evacuated the area where the casks were located, and opened the door to the cell.
A new 55 gallon waste drum was
)
placed on the pad of the door with a 1 1/2 ton crane.
The cleaned waste drum was hooked onto the crane. The drum was removed from the door pad by the crane and moved to the gamma counting position.
The gamma levels from the drum were recorded by Health Physics.
The drum was placed in the cask. The lid, which s Booked on a 10 ton crane, was placed on the cask.
The door to *'ic y tall was closed.
An operator wearing a lab coat, ;19 C+f s, and a half-mask went to the cask area and changed the hoor from sea lid of the loaded cask to the lid of the ocher empty cask; and removed the plastic cover from i
8 the top of the empty cask. When the man come back from performing the job, he removed his shoe covers and lab coat at a doorway and disposed of the clothing properly.
The inspector noted that no con-tamination survey was made of the individual before or after removal of the protective clothing.
The outside of another drum was cleaned while the drum was in the cell.
The door of the cell was again opened and the process described before was repeated and the drua of waste was loaded into the second cask.
Health Physics started an air sampler in the area where the cell door was opened and the waste was placed into the casks.
After the results from the air sample showed the airborne radioactivity within limits, personnel went in and marked off the zone where contamination may have fallen from the open door.
The lids of the casks were lifted about 1 foot and air samples were taken of the air between the lid and cask body.
The lids wera I
replaced on the casks.
The bolts, which had been lubricated, sere tightened using a 2 foot handle wrench.
The outside of the casks were sprayed with a decontaminant.
The outside of the casks were smear surveyed.
The casks were labeled with a Radioactive-Yellow III labels.
The curies and transport indexes for each cask were listed on the labels.
The casks were placed on the trailers and were securely tied down to the trailer.
The trailer was placarded with radioactive labels.
The licensee took radiation readings of the trailer and the cab of the vehicle.
The licensee finished filling out the shipping papers.
The Tri-State Motor Transit Company driver signed the papers appropriately.
b.
55 Gallon Drum The licensee opened a drum of waste at Building 4 at the request of the inspector.
The licensee had filled out the PACKAGE CERTIFICATION form for the drum.
The waste came from Lab C-7 of Building 4.
The waste was dry solid waste.
The drum had been surveyed by health physics.
The drum lid had a good sealing gasket.
The drum contained lab coats, empty boxes, and empty bottles.
There was no evidence of any liquid in the waste.
9 9.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 1,1980.
The scope of the inspection was presented, and the following items were discussed.
The inspector mentioned that the licensee should have actual analyses of plutonium content in the Raw Fission Waste if at all possible.
The licens-ee indicated they would attempt to obtain actual analyses of the plutonium content in this waste stream.
The condition of the NECO B3-1 casks was discussed.
The licensee indicated they would use these casks as sparingly as possible.
The failure of the operators to place the water-alcohol rags, which resulted from the removal of ice from the casks, in a metal container was pointed out.
The failure of the operator to wear prescribed safety equipment while using the caustic solution to wash the interior of the cask was pointed out.
And the failure of the operator to perform a personal survey after removing his protective clothing during the cask loading operation was pointed out.
The licensee indicated they would investigate these matters and take appro-priate action.
i
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