ML19351E941
| ML19351E941 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 10/14/1980 |
| From: | Clemons P, Knapp P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19351E936 | List: |
| References | |
| 70-0687-80-06, 70-687-80-6, NUDOCS 8012190553 | |
| Download: ML19351E941 (6) | |
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-687/80-06 Docket No.70-687 A
License No.
SNM-639 Priority 1
Category Licensee:
Union Carbide Corporation P. O. Box 234 Tuxedo, New York 10987 Facility Name:
Union Carbide Inspection at:
Tuxedo, New York Inspection conducted: September 17-19, 1980 Inspectors: I
/ o / /G [,fy 1
T-Clemons, Radiation Specialist date signed date signed date signed Approved by:
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l'/!Jd P. J. Knapp, ChiM, Radiation Support d&te ' signed Section, FF&MS Branch Inspection Summary:
Inspection on September 17-19, 1980 (Report No. 70-687/80-06)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector of the Radiation Protection Program including: outstanding _ items, bioassay, posting, dosimetry, annual report, leak test, ventilation, procedures, air samples, training, receiving radioactive material, audit, stack samples, drills, smears and shipping radioactive material.
Shcrtly after arrival, areas where work was being conducted were examined to review radiation control procedures and practices.
The inspection involved 19 inspector-hours on site by one regional based inspector.
Results: Of the 15 areas inspected, no items of noncompliance were identified in 14 areas.
One apparent item of noncompliance was identified in one area (Infraction -
failed to post cabinet containing uranium; paragraph 4).
Region I Form 12 (Rev. April 77) 8012390563
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DETAILS 1.
Persons Contacted C. Konnerth, Manager, Health, Safety and Environmental Affairs W. Ruzicka, Reactor Supervisor L. Thalin, Health Physics Supervisor M. Voth, Manager, Nuclear Operations The inspector also interviewed other licensee employees including Health Physics Technicians, the Manager of Radio-Chemistry Engineering, the Radio-Chemistry Production Supervisor, and the Materials Manager.
2.
Licensee Action on Previous Inspection Findings (Closed) Noncompliance (687/80-03-02): Records not maintained in the proper units. The inspector observed during this inspection that the air sample records are being maintained in the proper units.
3.
Bioassay Item A in the Notice of Violation enclosed with the letter dated April 23, 1980 sent to the licensee stated: " Condition 9 of Special Nuclear Material License No. SNM-639 incorporates a letter dated June 13, 1973.
On Page 1, Item 2, Personnel Monitoring, of the June 13, 1973 letter, it states,
" Urinalyses..on all personnel working with radioactive materials are made on a routine basis at least once each year.
Contrary to the above, urinalyses were not performed on at least eleven employees, for the presence of Uranium-235, during 1979."
The licensee's response to this item of noncompliance dated May 20, 1980 was as follows:
" Urinalyses were not performed on at least eleven employees, for the presence of Uranium-235, during 1979."
"In deference to this allegation, we wish to point out that gross gamma i
urinalyses were performed on the eleven employees referenced in your letter who worked with Uranium during 1979.
There are no license requirements to look specifically for any particular isotope including Uranium-235.
Therefore, we are meeting the obligation of the June 13, 1973 letter that you referenced stating " Urinalysis...on all personnel working with radio-active materials are made on a routine basis at least once per year."
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3 During this inspection the inspector asked a licensee representative if the gross gama urinalyses data had been evaluated to determine if there had been a significant uptake of uranium. The licensee representative informed the inspector that the data had not been evaluated to determine if an uptake of uranium had occurred.
The inspector noted that simply collecting urine samples and performing a gross gama count, without evaluating the results for the presence of uranium, does not constitute urinalysis.
Urinalysis is accomplished when it yields a detemination of the internal exposure status of a worker.
The item of noncompliance remains as originally submitted.
4.
Criticality Safety Sign As the inspector toured the Plating Area of the Hot Lab Building on September 17, 1980, he observed that there were four fuel storage cabinets in the area.
He noted that one of the cabinets, a four drawer black cabinet, was posted with a criticality sign which indicated the amount of special nuclear material permitted to be stored in the cabinet, and he also noted that there was no indication of the amount of special nuclear material stored in the cabinet.
Item 14 of Amcndment 1 to Special Nuclear Material License No. SNM-639 states, "...the licensee shall post all storage and use locations with criticality safety signs which indicate the maximum quantity of special nuclear material that is authorized at each location and the actual amount that is present at each location."
The inspector asked if the cabinet contained special nuclear material, and if so, how much?
The inspector was cold by a licensee representative that the cabinet contained approximately 325 grams of Uranium-235.
The inspector noted that failure to post the Uranium-235 contents of the cabinet represents noncompliance with Amendment 1 to the Special Nuclear Material License.
(80-06-01) 5.
Annual Report 10 CFR 20.407 requires that appropriate licensees submit, within the first quarter of each calendar year, to the Director of Management anc Program Analysis personnel monitoring infomation recorded by the licensee for individuals for whom personnel monitoring was either required or provided during the previous calendar year.
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4 The inspector reviewed a statistical sumaary report, dated March 27, 1980, that the licensee had submitted.
The report indicated that 54 individuals were monitored during 1979, with the maximum exposure being 3,580 millirem received by one employee.
No items of noncompliance were identified with regard to the report.
6.
Uranium Waste Fcrm Processina Operation Amendment No. 4 to License No. SNM-639, dated June 27, 1980, authorized the addition of a uranium waste form processing operation in accordance with the licensee's application dated June 2, 1980, as supplemented by License Conditions 18,19, and 20.
License Condition 18 requires the sampling of the offgas from the calcining step of the uranium waste form processing operation.
The samples are required to "be analyzed for gross beta-gamma, iodine-131, cesium-134, cesium-137, ruthenium-103 and ruthenium-106."
The inspector reviewed analytical data that indicated that the required analyses had been performed, and all results were within the regulatory requirements.
No items of noncompliance were identified.
7.
Ventilation Condition 9 of SNM-639 incorporates a letter dated April 28, 1969. On Page 10, Item 1, Ventilation System, of the April 28, 1969 letter, it states "... ventilation system is pressure regulated to insure a continuous, positive flow of air from nonradioactive areas to contaminated or radiation areas." At the inspector's request, a licensee representative performed velometer measurements on all hoods in which uranium is processed in the Plating Area, to detennine that the flow of air was in the proper direction, and that the linear velocity was adequate.
No items of noncompliance were identified.
8.
Smears On Page 3 of the April 28, 1969 letter, the licensee states that floor wipes shall be counted for alpha activity.
According to a licensee representative, wipes are taken from certain areas daily, and other areas monthly.
The inspector reviewed smear survey records for the p:-iod January through August 1980 to assure that the licensee was in canpliance with the license condition.
No items of noncompliance were identified.
5 9.
Air Samples The inspector reviewed air sample data for the period January through July 1980 to determine that the samples were being taken and to assure that the regulatory requirements were being observed.
No items of noncompliance were identified.
10.
Pos ting The inspector reviewed the facility posting and labelling against the requirements of 10 CFR 19 and 10 CFR 20, and observed that the licensee was in compliance with the regulations.
No items of noncompliance were identified.
11.
Leak Test The licensee has a license condition for leak testing sealed plutonium sodrces.
The condition states that "each plutonium source shall be tested for leakage at intervals not to exceed six (6) months."
The inspector reviewed leak test records for the period January - August 1980 which indicated that the licensee has one sealed plutonium source and this source is being leak tested at three (3) month intervals.
No items of noncompliance were identified.
- 12. _ Training On Page 15 of the April 28, 1969 letter, the licensee states, "All personnel working with radioactive material... receive basic radiation safety training."
The Inspector had.been told that a female employee had recently been added to the health physics staff.
The inspector asked what training the new employee had received.
He was informed that the employee had received basic training, and he was also shown a test that had been given to the employee after she had completed the required training.
The inspector was also shown documenta-tion that indicated that the employee had also received training in prenatal radiation exposure.
No items of noncompliance were identified.
- 13. Audit Condition 9 of SNM-639 incorporates a letter dated August 12, 1976. On Page 3 the letter states, "The Nuclear Safeguards Committee will appoint an individual who is not in the Nuclear Operations direct line organization to perform an audit of operations which are conducted under the SNM-639 license at least once every 12 months." The inspector reviewed the report of an audit that was conducted on July 31, 1980.
No items of noncompliance were identified.
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6 14.
Receipt of Radioactive flaterial 10 CFR 20,205(b)(1) requires that each licensee upon receipt of a package of radioactive material must monitor the external surface of the package for contamination.
The inspector reviewed the incoming shipment records for approximately twenty shipments received by the licensee during 1980 to determine compliance with the regulations.
No items of noncompliance were identified.
15.
Drills Condition 9 of SNM-639 incorporates a letter dated June 13, 1973.
The following statement appears in the June 13, 1973 letter.
Drills...will be conducted semi-annually."
The inspector reviewed documentation that indicated that drills have been performed approximately quarterly since Septemb,er 4,1979.
No items of noncompliance were identified.
16.
Stack Samples The inspector reviewed stack sample records for the period January-July 1980. The data for all samples indicated that the air concentrations were within the regulatory limits.
No items of noncompliance were identified.
17.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on September 19, 1980. The inspector summarized the purpose and the scope of the inspection, and the findings as presented in this report.
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