ML20043B393
| ML20043B393 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 04/19/1990 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Knapp M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 9005290262 | |
| Download: ML20043B393 (9) | |
Text
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ClNTICHEM, INC.
a wholly ownexi subsidiary of Medi-Physics, Inc.
p.a. sax e,s. Tuxsoa. NEW YORK 109e7 -
(914] 3 51-2131 L
April 19, 1990 Dr. Malcolm R. Knapp, Director Division of Radiation Safety and Safeguards U. S.-Nuclear Regulatory Commission
. Region I-t 475 Allendale Road i
King of Prussia, PA<l&406 Dear Dr. Knapp
SUBJECT:
Cintichem Response to NRC Inspection Report Nos.
70-687/89-80 and 50-54/89-80 This-correspondence details our response to the above referenced NRC Inspection Report dated January 23, 1990 which includes'our
-response to the six alleged violations, three management control items, and three unresolved iteme.
In addition, this response is
- being made pursuant to the sixty day extension granted in USNRC Region I letter dated February 23, 1990.
Section 3.2.4.12,
" Air Sampling and
. Internal' Radiation Protection", of Part 1 - Criteria of the NRC-approved license l'F application for License 'No.
SNM-639 states, in part, that fixed contamination action levels for alpha activity are 200 u
counts per minute /100 cm2 (maximum 1330 dpm/100 cm2).
Areas
.above-this-limit shall be cleaned or labeled with an L
identification mark.
1:
Contrary to the above, during the inspection on October 23 27, 1989, four areas on the floor, located on the second floor of the hot laboratory, had fixed alpha contamination levels ranging from 8,000 to 24,000 dpm/100 cm2 and these areas were-neither cleaned nor labeled with an identification mark.
These areas included the entrance to the plating laboratory, i.
the entrance to the waste laboratory,. the entrance to the L
solution laboratory, and the passageway outside the solution i-laboratory (70-687).
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- APRILL 19,>1990 PAGE 2 CINTICHEM RESPONSE:
As Jimmediate ' corrw
.v e action these identified areas were deJ ineated on the. floor by the use-of warning tape.
Within 30 days these areas were either cleaned to below our inhouse
' limits-or.
the-floors were removed and disposed of.as radioactive waste.
As a result of the recent decision to
' decommission buildings-1 and 2 at-the. Cintichem site these areas-shall-be slated for cleaning / removal to-allow unrestricted access.
10 CFR 50.54(q) and 10 CFR 70.32(1) require a
licensee authorized 'to possess and/or operate a research reactor or a fuel facility to follow and maintain, in effect, emergency plans'which meet the requirements in Appendix E to this part.
Appendix E Paragraph IV.F requires, in part "the training of employees
....to ensure that employees of the licensee are e
'f amiliar with their r specific emergency response duties.
This shall ' include a description of specialized initial training and periodic -retraining programs to be provided to emergency
' directors, personnel responsible for accident assessment, radiological monitoring teams, fire control teams, first aid and rescue teams", etc.
Contrary to the above, during 1989, the licensee's emergency plan training program did not provide for the. initial training of individuals who may be required to respond to an emergency to ensure.
that they_ were familiar with their specific emergency. duties.
In
- addition, the licensee's periodic retraining-program was not effective to~ assure that emergency directors, personnel responsible-for accident assessment and radiological '.nonitoring teams were familiar with their specific emergency response duties, in that they were not
. aware of many emergency plan changes which were described in a-July 1989 revision and their classification of emergencies were'not consistent with and often not in accordance with the classification tables contained in the plan.
(70-687; 50-54)
.CINTICHEM RESPONSE:
~ Corrective actions to -date to help improve the overall effectiveness of our Emergency Plan training program have included development of written training lesson
- plans, increased onsite training of personnel, and designation of specific duties of cereon--
e required to respond or u
v*-
support emergency itua
.Due to the recent
.m
- decision to decommission be u zu ad 2, these improvements shall continue during t i
rh cariod f rom defueling the reactor and removal of al. Sm u.
che site to the beginning LJJM/70.90B 1
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APRIL 19,-1990'-
PAGE 3-of: the -decommissioning.
As these plans _ progress Cintichem will revise and submit to the USNRC our Emergency Preparedness program as appropriate.
- NOTICE OF VIOLATION C:
Technical Specification 3.10 for License R-81 and Section b,
5.2.1 of Part 1
Criteria of the NRC-approved license
=
Ri application 1 for License SNM-639 incorporate-Tables 3.4 and.
L 5.2.1,,respectively, into the facility licenses and state that the' radiological environmental monitoring program shall _ be conducted as specified in the respective tables.
Technical Specification 3.11 requires the conduct of a land use census once each 12 months and requires - that the location of the
[
nearest milk animal, the nearest-residence - and the nearest i
garden greater 'than' 500 square feet be identified in each of E
the 16 meteorological sectors.
Tables. 3.4 and 5.2.1 require the performance of gamma isotopic analyses on particulate-composite - samples by location at least once per 92 days ' and the performance of I-131 analysis on-food products at.-
locations to be determined f rom the land use census.
m contrary to the above, during 1989 up to the inspection on October 23 - 27,-1989.
K
- 1. The licensee did.not perform gamma isotopic analyses on particulate composite samples for each location at least once per 92 days.
2.-The_ licensee did not perform I-131 analyses on milk at the locations determined from either the 1988 or 1989 land use census (70-687; 50-54).
CINTICHEM RESPONSE:
Contrary to the allegations in items 1 and 2 of the Notice of Violation C above, -Cintichem has performed _ gamma isotopic
-analyses on particulate composite samples - as requireC 5y our
~ R-81. and SNM-639 licenses and did _ perform I-131 ants ;es on milk from locations determined directly from the 1988 M 1989-land use census reports as required by our license conw_uions.
As in.cated by our internal documentation gamma _ isotopic analy: : is performed utilizing NaI/MCA system to identify any
' discernable photopeaks f rom 0 - 1.5 MeV.
This procedure has
- q been utilized for many years without previous regulatory concern.
Therefore, Cintichem contends that no violation 5
exists regarding this issue.
As an improvement in this area
- future particulate composite samples will be an9.lyzed on ' our i
newly established high purity germanium-lithium /MCA analyzer.
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'PAGE.4 1
On page ' 34 -of this NRC inspection report Section 9.4.6 Review i
~
W of Land Use census indicates that -"The inspector reviewed the
-1988 and availatble 1989 land-use census data.
The ' inspector--
-?
.noted that~ the licensee analyzed one - milk ; sample.. in : late
?
November, 1988 to.implecont Section 3.11, " Land Use Census",.
i of the Technical Specification requirements.
i
-As a result, the inspector stated that the failure to perform-I-131 analysis on milk samples during -1989 was an apparent -
. violation."
l It would appear from this inspection report that-the inspector j
acknowledges - that a 1988 milk sample was analyzed so no
~
violation for-1988. occurred.
In
- addition, as in 1988 Cintichem-perforraed the annual milk analysis in November 1989 j
to comply-with our current land use-census and license conditions.
Therefore, our contention is that the 1989 milk analysis 'was performed and therefore no violation occurred..
. Technical Specification 3.9.2 (2) for Lice ~nse R-81 states, in
- part, that the total body dose to any individual -in unrestricted areas due. to noble gases -- released in gaseous effluents shall-he limited >during any calendar quarter to 3.17 E-8. n;Mi(K/Q) ' 01 < 2.5 L mrem or equal = to' or ~ less 'than 5. mrem during each calendar year.
Mi is the cotal body dose factor f rom' gamma
' emissions for each-identified noble gas radionuclide.
Section 3.2.4.'4 of Part 1-Criteria of the-NRC-approved license application for License SNM-639 states,.
in part,- that the effluent stack air 'shall :be sampled continuously?,and analyzed weekly.for noble gas.
radioactivity.
Technical Specification 3.9.3. (3) for License <
R-81 states, in part that liquid waste shall not be released from the site-unless its activity concentration, including' dilution with non-radioactive waste water, is below that specified in 10 CFR 20, Appendix B, Table II, Column 2.
t Contrary to the above, during 1989.
~1.
The licensee did not analyze the gaseous effluent releases-weekly to. identify each noble gas radionuclide present so that the appropriate total body dose factors (Mf. ) could be assigned.
- 2. The analytical techniques used to analyze liquid waste released from the site were not appropriate to assure that its concentration, including dilution with non-radioactive wast? water was below that specified in 10 CFR 20, Appendix B, Table II, Column 2.
(70-687; 50-54)
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APRIL'19, 1990 PAGE 5-CINTICHEM RESPONSE:
=Por years Cintichem-has-monitored and evaluated doses from noble gases in the stack effluent pursuant to_ license conditions...The weekly noble gas releases are characterized.
as a fission product noble gas mixture ' decayed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> from the time. of removal from the reactor as calculated ' by the ORIGEN II computer -program.
The. decay time.i s directly..
J related to opening: of the uranium target capsules. in the hot--
cells.
The total body dose factors are applied for each radionuclide in the calculated mixture.
This method provides.
a -conservative approach to offsite dose projection which had previously been reviewed and apparently been accepted by the USNRC.
With the - recent decision to decommission the reactor and hot lab at Cintichem, this item will no longer be required for buildings'1 and 2.
Another long-standing and previously reviewed practice under license conditions is the analytical technique used to analyze liquid waste.
This technique was originally developed to test for gross' beta in liquid' effluents and has been performed this way for many years as an approved practice under this license condition.
It also must be noted that Technical Specification 3.9.3.(3) states that the radioactive concentration in the liquid waste released from the site shall be. determined at least once per month by an analysis of a composite sample of all tanks released during that period and [in 3.9.3.(4)] that the total radioactivity released in liquid-effluents shall not exceed 0.01 curies of Br-90 equivalent in any 12 consecutive month period.
Our program also utilized an MPCw of 3 x 10-8 uCi/cc gross beta in accordance with 10 CFR 20, Appendix B, Note-2.d.
This-program outlined in the above paragraph -meets the requirements of 10 CFR 20.106(b) which has been the basis of our program for many years.
Therefore we believe that wa have been complying witn license conditions and applicable regulations.
However, as observed by the NRC during.recent site-inspections our analytical techniques to-analyze radionctivity in water has been modified to identify.
individual radionuclides and has been verified by the NRC (NRC Inspection Report Nos.
50-54/90-80 and 70-687/90-80).
Cintichem will continue to utilize these improved analytical-techniques for release of all waste water f rom the site.
NOTICE OF VIOLATION E Technical Specification 3.9.3. (3) for License R-81 states, in part, that liquid waste shall not be released f rom the site unless its activity concentration, includ hg dilution with non-radioactive waste water, is below that specified in 10 CFR 20,' Appendix B, Table II, Column 2.
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Contrary to the above, during the inspection on October 23 -
27, 1989, water samples of liquid waste from the 001 outfall were' determined to contain (6.7 1 0.3) E-7 uCi/ml of I-131 which was-about twice the.10 CPR 20, Appendix B,
Table _ II,:
Column.2 limit of 3 E-7 uCi/ml for I-131 (50-54).
CINTICHEM RESPONSE:
~Our contenti'on'is that the NEO grab sample _'taken _ during the-27 inspection was not - representative of the OctoDer 23 actual requirements of our specific license conditions nor of the requirements of 10-CFR 20.106 and should not be considered a_ violation.
This position is based on Technical _ Speci-z fication-3.9.3.(3) which indicates - that "This activity concentration shall be determined at least once per month by an' analysis of a composite sample of all tanks released during that period."
Therefore, " dilution with non-radioactive waste water" and a " monthly analysis of a-composite sample of all tanks" is a less restrictive stipulation than that in 10 CFR 20.106' (a) which allows averagina over an entire-year, meets the criteria in 10 CFR 20.106'.)
as an allowable license condition.
In addition, 10 CPR 20.106(a' and (b) allow concentrations to be averaged over a period not greater than one year.
As an : ALARA concept Cintichem will. make every effort under-normal conditions to release waste water from the site that meets or is below that specified in 10 CFR 20, Appendix B,
Table II, Column ' 2.
Also, as stated above, Cintichem will continue to utilize our newly established analytical techniques - for analyzing - radioactivity in our waste water prior to release from the site.
-NOTICE OF VIOLATION F:
Technical. Specification 4.8 (2) of License R-81 requires, in
.part, that-reactor pool-water shall be ' analyzed for radioactive 't.sotope identification at semiannual-intervals.
Technical Specification 4.8.3' requires that the activity of the pool water shall be measured veekly.
. Contrary to the above, during 1989, the analytical techniques, used by the licensee to perform the weekly reactor pool water activity measurement and the mmiannual analysis for radioactive isotope identificatiot, were not appropriate to identify each radioactive isotole or the-total activity present, in that, ahort-lived radlonuclides were allowed - to decay prior to the analyses, and the volatile radionuclides were. permitted to evaporate from the samples during the sample preparation phase (50-54).
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- APRIL.19, 1990 PAGE 7 CINTICHEM RESPONSE
Cintichemi contends that it has complied with license conditions. pertaining to analysis.of reactor pool water..
The intent of Technical. Specification 4.8(2)- and (3) is not to identify or quantify all radioisotopes in the reactor pool for
- safety. or operational
- purposes, but as an indicator
-of.
possible changes ~ in the pool water system for appropriate followup.
The fine points described -in the second paragraph of the Notice of Violation F above. regarding short. lived ~and volatile radionuclide catection has; no relationship-to the-actual intent and/or purpose of this. license condition.
Due to the recent reactor water problems on site sampling of-the-reactor pool water is being performed as-a minimum once :per J
week.
Once def ueling of the reactor is ' performed Cintichem will request relief.from this license condition.
j i
UNRESOLVED ITEM Sr-90 EQUIVALENT 1
The: -NRC approvedf license condition concept of radioacti'rity based upon Sr-90 equivalent was developed for use with the gross beta waste water releases from the-site since St-90 has the most restrictive MPCw f or all the isotopes handled on site.
As an example of the use of the Sr-90 equivalent ~when compared to Cs-137 activity,-one would ratio the MPCw of Sr-90 1
to Cs-137:
5 Sr-90:MPCw 3x10-7 uCi/ml = 0.015 Csk137'MPCw 2 x 10-5 uCi/ml
^
Then, if 87.24. uCi of Cs-137 was detected in a waste water holding tank, then the Sr-90 equivalent would be 87,24 i 0.
1.31 u C1..
This = concept is less restrictive than
=
regule; ions, but does meet the criteria listed in 10 CW 2 0.105 (b ).
However,-Cintichem is no~ longer utilizing this:Sr-90 equivalent which was removed for the 1988 SNM-639 license.
P renewal application.
L" UNRESOLVED ITEM: COLLECTION EFFICIENCY FOR VENTILATION SYSTD1 CHARCOAL BEDS ~
After the October 1989 NRC inspection, followup discussions regarding this item were held with Dr. Jason Jang of the USNRC to exchange additional information and to help "iew NRC h..
expectations.-
For review please find enclosed a w
of'the Health Physics Procedure HP-F-11' used to perform sur filter bank efficiencies.
As you are aware, Cintichem will be decomtaissioning the reactor' and hot lab and the need for such efficiency determinations vill not be required and plans to M.
investigate / improve. procedurec have been
' canceled.
as a
. pr oj e c t.-
(Please note that this response is also submitted as requested in NRC: Inspection Nos. 50-54/90-80 ' and 70-687/90-80
~ dated March 19, 1990, o
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JAPRIL 19,11990 PAGE'BK i
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. UNRESOLVED ITRM EFFLUENT IODINE RELEASES /OFFSITE DOSE M
CALCULATION
.As an-immediate ' followup to this' NRC concern, Cintichem. re-evaluated the effluent charcoal cartridge results for the possibility. of radioivdine breakthrough.- From this study it was determined that -the percent collection : efficiency of - the CP-200- (SAIC) cartridges were in close agreement with the manuf acturer's. specifications and the iodine-quantities on: the SAIC versus the MSA cartridges were also in _close. agreement.
Further studies since October 1989 continue to show good-comparison of collection ef ficiency and quantities collected.
Theref ore, - no-re-evaluation of past dose assessments is being -
considered at -this time.
In., addition,. -due to our planned decommisFioning at the site no additionali special studies are planned regarding this ' item since ' the available production sources of radioactivity have been virtually eliminated.
. MANAGEMENT CONTROL SYSTEMS IMPROVEliENTS
- 1. Effluent / Environmental Neasurements Proartu_n As. indicated in the.NRC Inspection: Report Nos. 50-54/90-80 and 70-687/90-80 our - analytical-me'asurements program has been improved with the assistance of NRC Region I
personnel.
Sample measurement comparisons and verification test results have also been validated with USNRC.
In
- addition, a
measurements QA Specialist has been employed-at Cintichem to help develop, maintain, and expand the QA/QC program for the site _ effluent and environmental measurements programs at Cintichem.
- 2. Contamination control Program The two.
largest contributors to personnel
. clothing
. contamination-at Cintichem has been, due to the. reactor building airborne radioactivity from reactor operations and to the handling of large quantities of radioactivity in the -hot lab associated with the hot cells,. glove boxes, and the waste handling operations.
Due to the planned decommissioning of the reactor and hot lab and to the cessation of radioactive material production in buildings 1
and 2,
our site contamination control program has become easier to implement and maintain.
Prior to and during & commissioning emphasis regarding contamination control will continue to be a
. priority.
We have purchased and installed state-of-the-art
- contamination detection equipment, purchased protective
' equipment and
- clothing, continue to perform routine and special surveys, perf orr.: ng work under Health Physics issued radiation work permits, etc.
Cintichem 4
1 continue to maintain an adequate health physics and safet2 staff through 1
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APRIL 19, 1990 PAGE 9 decommissioning to help assure appropriate controls (including contamination control aspects) and compliance with regulatory requirements and expectations.
- 3. Emergency' Preparedness Trainino Program As.previously outlined above,. corrective actions to date to
- help improve the overall effectiveneas of our' Emergency Plan training program have included development of written training.
lesson. plans, increased onsite training of personnel, and-designati'on of. specific duties of' personnel who may be re. quired to respond or support emergency situations - on site..
Due to the recent decision to decommission buildings 1 and 2, these-improvements shall', continue during the-interim period f rom' defueling _
As these plans the reactor and ' removal of all SNM from the site-to the.beginning of the decommissioning.
progress 'Cintichem will revise and submit to:the USNRC our Emergency Preparedness program as-appropriate.
1n closing, this corresponcence details Cintichem's response, 1
corrective actions, and commitments regarding the October 23 27, 1989 NRC team inspection.1 If any ' further information is necessary, please. contact me'.
S erel,
. J. M G~overn &
M+
Plant Manager
.JJMcG/bjc cc:
T. Vaughn 3
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