ML20003A674
| ML20003A674 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 11/05/1980 |
| From: | Mcgovern J UNION CARBIDE CORP. |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20003A561 | List: |
| References | |
| NUDOCS 8102040684 | |
| Download: ML20003A674 (2) | |
Text
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M UNION CARBIDE CORPORATION k
dE MEDICAL PRODUCTS DIVISION P.O. BO X 324, TUX E DO. N EW V O R K 10987 TELEPHONE: 914-351-2131 November 5,1980 U. S. Nuclear Regulatory Commiss ion Region 1 631 Park Avenue King of Prussia, PA 19406 Attn:
Mr. George H. Smith Chief Fuel Facility &
Materials Safety Branch subj:
INSPECTION 70-687/80-04 Gentlemen:
This letter is in response to the subject inspection report to present our position on the items of apparent non-compliance mentioned in the report and also to state what actions have been taken or will be taken to correct deficiencies.
1.
The criticality alarm system must comply with the design requirements of 70.24 (a) (2) since our operations predate 12/6/74.
It is our assessment that all the 70.24 (a) requirements are satisfied in that; (a) the alarm set points of our area monitors are within the specified limits, (b) our procedures for both the reactor and hot laboratory require that the building evacuation alarm be sounded in either the reactor or the hot laboratory whenever two or more area gamma radia-tion alarns sound, (c) the normal set points on all alarms covering areas where SNM is handled or stored are capable of detecting a criti-cality which generates 300 rem /hr. one foot f rom the source, (d) each area where SNM is handled, or stored is covered by a minimum of 2 monitors (except where material is packaged for shipment in quan-tities less than 15 gms each), and that (e) each monitor has a clearly audible signal.
Since radioactive materials other than SNM are also handled in the reactor and hot laboratory, the building avacuation is required at the sounding of 2 area monitors instead of one to eliminate the-pos-
~
sibility of false evacuation alarms.
This system is deemed to be adequate for all areas, except the second level of the hot l abo ra to ry,
because all SNM in these locations (except for small assay samples) is in dry solid oxide form and our total facility possession limit H 0go40 N
U.S.N:R.C.
, 'LNSPECTION 70-687/80-04 Novcmber 5, 1980 is less than the single parameter mass limit for this form of SNM.
The second level of the hot laboratory is of more concern because there are three adjacent laboratories and three storage cabinets where SNM in aqueous solutions are handled or stored. The two monitors in this area are capable of initiating the evacuation alarm automatically.
To prevent false evacuation alarms, the cir-cult is arranged so that both monitors must trip before an evacu-ation alarm will sound but each monitor is capable of detecting a cri ticali ty inciden t in any laboratory or storage cabinet.
The de-ficiency noted about monitor failure not resulting in an alarm state has been corrected.
If either of these monitors fails, it will re-sult in a trip condition and initiation of the evaculation alarm in the event of criticality or other hi radiation indication by the redundant monitor.
The monitoring system in the reactor is the same as that in the hot laboratory and the procedures governing its use have the same cri teria for sounding the evacuation alarm. Those areas where SNM is handled and stored in the reactor building were described in our letter to the Commission dated 11/17/78.
The alarm system was not specifically described but the same design and operating parameters as those that had been already approved for the hot laboratory were in effect.
An application for license amendme.mt to grant exemption f rom the requirements of 70.24 for many of the areas discussed will be made by 12/31/80. We bell' eve good cause exists for such exemptions parti-cularly in those areas where the SNM is limited to small quantities and is in a form such that there is a great margin of safety below the single parameter mass limi*..
2.
The area where primary targets are sealed into secondary containment by welding has been posted with a criticality safety sign.
This area will also be described in the application for license amendment men-tioned above.
3 The target plating laboratories are areas where daily work with SNM is conducted. These laboratories are cleaned f requently but it is not practical to maintain removable a contamination levels below 2
100 dpm/100 cm.
This is not considered hazardous since continuous air sampiing is performed in these laboratories and we have never detected airbone Uranium originating f rom floor contamination.
Per-sonnel are required to wear anti-C clothing while they are working in these areas. The ingestion and inhalation hazard is under control In this work space. A request to change the allowable contamination levels in these laboratories will be made in the application for license amendment mentioned above.
Thank yoe for your consideration in extending the response period for this inspection report.
Very truly yours,
A.--
l Ja s
. McGovern Business Manager l
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