ML20005D647
| ML20005D647 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 03/13/1989 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20005D646 | List: |
| References | |
| NUDOCS 8912130435 | |
| Download: ML20005D647 (4) | |
Text
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b March 13, 1989 4
United States ~ Nuclear Regulatory Commission Region I-475 Allendale Road King of4 Prussia, PA 19406 Attention:
Mr. Ronald R. Bellamy,-Chief Facilities Radiological Safety and Safeguards Branch, Division of Radiation Safety and Safeguards
Dear Mr. Bellamy:
Subject:
Cintichem, Inc. Reply to Inspection Report
- 70-687/89-01 Pursuant to the Notice of Violation Docket No.70-687 this correspondence details the actions taken by Cintichem, Inc. to-correct the two apparent violations from the-routine safety inspection conducted by Mr.
J. Roth on January 9 - 12, 1989.
Section 3.2.1.2 " Access Control" of Part 1 - Criteria of the NRC-approved license application states -that -areas' requiring special protective clothing will be posted by Health Physics.
Section 5
" Personnel Protective Equipment / Clothing" of the Cintichem Radiation / General Safety Manual states that it is the responsibility of the individual and his supervisor.to see that appropriate protective clothing-is worn whenever contamination-with radioactive material is possible.
A sign posted pursuant to Section. 3.2.1.2 at the Hot Cell Conveyor Work
- Station, a
potentially contaminated location, required individuals to wear shoe covers, safety glasses, labcoat, sleeve covers and gloves while in the area.
Contrary to the above on January 9 11, 1989 an individual working in the vicinity of the Hot Cell Conveyor Station, a
potentially contaminated area, was not wearing the required sleeve covers, another individual was observed walking through this area wearing only shoe covers and a third individual was observed handling potentially contaminated parts of a
trash compactor, located in the area, without wearing gloves to protect his hands from being contaminated.
8912130435 891100 REG 1 LIC70 SNM-0639 PDR i
i JJM/40.89B l
I 4,.
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MR. RONALD R.
BELLAMY, NRC MARCH 13, 1989 PAGE 2 CINTICHEM RESPONSE:
It is our contention that the sign posted at the hot cell conveyor work station may have been unclear to some employees who work in this area.
Cintichem has issued standing radiation work permits clearly. outlining the requirements for working in this area.
These radiation work permits have been reviewed with the employees who work in this area and have been signed off by their department manager.
In addition, these radiation work permits are posted at the entrances of the hot cell conveyor work station area for review by all employees who may enter and/or work in this area.
Section 4.2.5.2.(a) of Part 1 Criteria of the NRC-approved licensee application states, in part, that the quantity of SNM in an isotope processing cell shall not exceed 650 gms U-235.
The 650 gms. U-235 can be exceeded provided SNM in excess of 100 gms is. contained in borosilicate glass containers meeting specific criteria and the concentration of U-235 shall be less than 0.250 grams per milliliter.
Contrary to the above on January 9,
1989, Hot Cell No.
4, an isotope processing cell, contained in excess of 1300 grams of U-235 in'borosilicate glass containers meeting specific criteria.
- However, analyses of rinse solutions containing U-235 was not conducted to assure that the solution concentration of U-235 was less than 0.250 grams per milliliter.
CINTICHEM RESPONSE:
We believe that the license conditions for handling U-235 in a processing hot cell were met.
We believe that the 250 g/l limit in concentration could not have been exceeded even in the unlikely event that all of the dissolved U-235 from a target were inadvertently placed in a rinse bottle.
The practical limit for U-235 to be contained in a
target is less than 25 gms.
Therefore, the concentration in the 100 ml rinse would be less than 250 gm/l.
Although specific assays had not been done on the rinse solutions that were in Hot Cell #4, assays for the concentration of U-235 in rinse solutions had been performed in the past.
The uranium content in these rinse solutions had been measured to be insignificant during the initial product development.
Measurements were again made during the waste form process development in 1981 with similar results.
In addition, samples were immediately assayed during the inspection and these assays confirmed previous results of insignificant concentrations of i
JJM/40.89B e.
t MR. RONALD R. BELLAMY, NRC MARCH 13, 1989 PAGE 3 U-235.
Two samples from two different rinse solutions were assayed with sample #1 showing.0039 gms/ml and sample #2 showing
.00063 gms/ml.
In both
- assays, these were the highest concentration found in each of four replicate samples that were analyzed in each batch (the average concentrations were.0021 and
.0004 gm/ml respectively).
The total volume in each rinse solution is limited to 100 ml.
Assuming rinse solutions were accumulated for a
week or approximately 22 bottles each containing.39 gms per bottle, this amounts to 8.58 gms total in all rinse solutions in the-cell.
These quantities do not exceed either the concentration limits of 0.25 gms/ml or the 100 gm base limit above which specific storage conditions apply.
The number of targets that are processed at any time in a processing cell is two.
The maximum amount of U-235 that can practically be contained at any time in two targets is 50 gms
(< 25 gms each batch).
In the unlikely event that any increment is doubled (i.e.
25 gm/ process batch, 0.39 gms/ acid rinse) the L
100 gram limit is not exceeded.
l Routine assays of rinse solutions were not performed because of the improbability of exceeding the 100 gm limit for material in l
process and also in the interest of avoiding the radiation exposure that would result.
l A procedure will be implemented whereby up to 2% of the original
- U-235 content of each target is assumed to be included in the acid rinse and that the total amount of U-235 contained in rinse bottles will be limited to 25 gms per processing cell thereby providing a more positive control on the maximum of the allowable l
100 gms per cell that can be in process without special storage conditions.
This new procedure will be implemented by April-30, l
1989.
l In response to the concern related to our Waste Storage Building, Cintichem has erected a fence surrounding the waste storage building to restrict access to the surfaces of the building and to assure that the radiation dose on the external surfaces of the fence is limited to less than two millirem in one hour and less than 100 millirem in seven consecutive days.
This corrective action has been taken in lieu of installing a fence on the north side of our property indicated in my letter dated September 14, 1988.
A response is forthcoming (within 45 days of your request) regarding our evaluation and supporting data for the waste storage container array arrangement observed in our gamma pit by Mr. Roth, JJM/40.89B
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MR. RONALD R. BELLAMY, NRC i
MARCH 13, 1989 PAGE 4 The 'above ' responses to the two v'iolations have been implemented -
as of the date of this correspondence and will prevent further violations in these areas.-
If any further information is necessary at - this time, please' don't hesitate to contact me.
Sincerely, 1
M s<- )
J. J. McGovern Plant Manager CINTICHEM, INC.
l JJMcG/bjc t
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JJM/40.89B
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