ML19341B727

Responds to NRC Ltr Re Violations Noted in IE Insp Rept 70-0008/80-02.Corrective Actions:Stricter Time Restraints During Operations Enforced & Remote Handling Techniques Used

ML19341B727
Person / Time
Site:	Battelle Memorial Institute, 07000008
Issue date:	12/29/1980
From:	Toy H Battelle Memorial Institute, COLUMBUS LABORATORIES
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML19341B725	List: ML19341B727 ML19341B728 ML19341B730
References
NUDOCS 8102270223
Download: ML19341B727 (2)

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. In 24.?.414 December 29, 1980 Mr. James G. Keppler, Director Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

Docket Nos.70-008, 30-5728, and 50-006; Inspection Report No. 70-008/80-02 This is in response to the subject inspection conducted by your Mr. Charles Peck on September 22-26, 1980.

The following information is provided in response to the two items of noncom-pliance identified in Appendix A, Notice of Violation of the inspection report.

Item (1) Infraction

. Contrary to regulations stipulated in 10 CFR Part 20.101(a) an employee received approximately 31 rems to the rignt hand on July 20, 1980.

This overexposure was formally reported to Region III on August 19,1980, in accordance with reporting requirements in 10 CFR Part 20.405. As indicated in the formal report, corrective actions to preclude further noncompliance include (1) enforcement of strict time restraints during such operations and (2) use of remote handling techniques to provide consistence with the ALARA policy. These corrective actions are currently in place and have been adopted as " standard

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operating procedures" in conducting similar cask flushing operations.

Full compliance-respecting this " infraction" has now been achieved.

Item (2) Deficiency Limits of radioactivity in the Hot Cell Laboratory storage pool exceeded License uCi/mlbeta-gammaand10jmits,asstipulatedbyLicense Radioactivity l Condition 18 of Licegse SNM-7.

pCi/ml alpha were exceeded Condition 18, of 10-during the unloading of a fai. led fuel assembly on May 3,1980.

50 Years Of Set,it e W

8102270Z M BEC 3 4

Mr. James G. Keppler 2

December 29, 1980 s

As indicated in your inspection report the peak levels of 4 E-l uCi/ml beta and 5 E 3 pCi/ml alpha were reduced to our regulatory levels following repeated recirculation of the pool water through our ion exchange resin beds.

Full com-pliance was achieved on September 16, 1980.

Anticipating future operations that could contribute to radioactive contamina-tion levels in excess of License Condition No.18 (10-3 pCi/ml and 10-4 uCi/ml alpha), we made formal application to NRC Headquarters for an amendment to our license to modify the upper limits of radioactivity to provide for routine and non-routine operatio.1s in the storage pool. A copy of our requested amendment is attached for your information.

You will note from the enclosed requested amendment we stipulate those actions to be taken during non-routine operations. Such strict health-physics monitoring and surveillance procedures during non-routine operations will assure a safe radiological environment.

NRC Headquarters responded to our requested amendment on December 8, 1980 (copy attached). As noted in the Headquarters response, the proposed non-routine limits will be incorporated in the renewal SNM-7 license.

We trust the above information and actions are responsive to the " infraction" and " deficiency" identified in your inspection report.

Should you require further information in order to meet our regulatory obligations, please call or. us.

Very truly yours, 7

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,,m Harley L. Toy NRC Licensing Coordinator HLT:lba Enc. (2)