ML20043C423
| ML20043C423 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 04/17/1981 |
| From: | Bissett P, Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20043C415 | List: |
| References | |
| FOIA-90-97 70-0687-81-02-0, 70-687-81-2, NUDOCS 9006050168 | |
| Download: ML20043C423 (4) | |
Text
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Details a
1.
Persons Contacted
- J. McGovern, Business Manager, Radiochemicals
- C. Konnerth, Manager, Health, Safety and Environmental Affairs L. Thelin, Health Physics Supervisor G. Wright, Plating Lab Supervisor J. Stuart, Hot Lab Technician
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings Previous items of noncompliance were not reviewed by the inspector.
3.
Exit Interview The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 20, 1981.
The inspector summarized the purpose and scope of the inspection and the findings.
4.
Unresolved Items There were no unresolved items resulting from this inspection.
5.
Independent Inspection Effort There was no independent inspection effort during this inspection.
6.
MC85202B Facility Organization 4
No items of noncompliance were noted.
The inspection results were attained through discussions with licensee management and review of the licensee's Fundamental Nuclear Material Control Plan (FNMCP) and operating procedures.
The licensee submitted a consolidated and revised FNMC Plan, dated May 15, 1980 which was approved by the Material Control Licensing Branch on January 19, 1981.
7.
MC85204B Facility Operation No items of noncompliance were noted.
The licensee's operations consist of (a) dissolving received uranium oxide in nitric acid to create uranyl nitrate which is used to plate uranium on target 900605016e 900330 PDR FOIA HALL,90-97
- PDR,
3 tubes; (b) irradiation of these uranium target tubes in the reactor; (c) operation of the reactor; (d) separation of selected radio-isotopes from irradiated targets for pharmaceutical purposes; and (e) conversion of radioactive waste solutions to uranium oxide for recycling or solidification of waste for burial.
The inspector toured the operational areas and observed the licensee's operations and activities. There were no instances observed by the inspector for which the possession, use or location of special nuclear material.(SNM) were contrary to the license.
8.
MC85208 Shipping and Receiving No items of noncompliance were noted.
The licensee has established and is maintaining a program to assure that all SNM received and shipped is accurately accounted for.
Also, the site accountability officer (SAO) coordinates efforts to insure that licen:e (SNM-639) possession limits are not exceeded.
Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, all receipts of SNM are confirmed through examin-
'ation of related documentation and weight verification. Usually, within five (5) working days, measurement of the uranium content is confirmed.
The' licensee has not experienced any significant shipper /-
receiver differences (S/Rs) on this material since the receipts typically involve only small quantities of uranium (average of 680 grams per receipt).
Until recently, all SNM shipments from the facility have consisted of small quantities of either nonirradiated waste or irradiated i
waste containing essentially all of the uranium in the targets (resulting from the separation of the desired radioisotopes from I
the irradiated targets).
The licensee is now, however, shipping the majority of irradiated waste to Savannah River for recovery.
Two shipments have occurred thus far but no recovery results have been received.
Material transaction reports (Form NRC-741) for all receipts were l
acknowledged and returned within 10 days. Material transaction L
reports for all shipments were prepared as required by the printed instructions for completing Form NRC-741.
9.
MC85210 Storage and Internal Control No items of noncompliance were noted.
The licensee has established l
a system of storage and internal control which provides for current knowledge of the quantity, identity and location of all SNM within l
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4 the facility, in accordance with the licensee's FNMCP and appli-cable license conditions.
The controls include the master log, subsidiary logs for each material balance area (MBA), and support-ing internal transfer documents for transfers between MBAs.
The licensee has the following MBAs:
MBAs Description 1
Feed Area 2
Plating Operation 3
Reactor 4
Radiochemistry Area (Hot Cells)
The inspector selected a representative number of postings in the master log and subsidiary logs and verified that they were supported by either material transaction reports (Form NRC-741), or internal transfer documents, as applicable.
- 10. MC85212-physical Inventory No items of. noncompliance were noted.
The inspector reviewed the results of the licensee's last eleven inventories dating back to April 26, 1979.
These inventories were conducted in accordance with approved physical inventory procedures.
The inspector also determined that, for each inventory, the master log and the MBA logs were reconciled and adjusted to the inventory results within 30 days. The inspector also verified the presence of the licensee's PuBe neutron source, -located in MBA-3 -and authorized under this license.
- 11. MC85214 Inventory Difference (10) and Its L
Associated Limit of Error (LEID)
No items of noncompliance were identified.
The licensee's inven-tory difference calculation was reviewed by the inspector for each of the eleven inventory periods covering. February 26, 1979 to December 30, 1980. 'The ids were accurately determined.
No addi-l tional loss mechanisms that could contribute to ID were identified.
The licensee had been granted relief from calculating the LEID L
whenever the ID is less than 150 grams.
However, with their submis-L sion of a revised FNMCP,as stated in paragraph 6,and its' sub-l sequent approval, the LEID now is to be calculated if the ID exceeds 300 grams, in accordance with 10 CFR 70.51(e)(5).
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- 12. MC85216 Records and Reports No items of noncompliance were identified.
In addition to the review of the master log, subsidiary logs, internal transfer documents, and inventory records, the inspector also reviewed all material transaction reports (Form NRC-741) and material status reports (Form NRC-742) for the three six-month reporting periods ending September 30, 1979, March 31, 1980,and September 30, 1980.
These were reviewed for timeliness, accuracy, and proper signatures.
The inspector discovered that the licensee had inadvertently omitted two Form-741 corrected copy receipts (ZWT-ZWN 187 cci and 191 cci) from their September 30, 1980 Form NRC-742 report. This resulted in a disagreement of 1 gram Uranium and (2) grams U-235 between Form NRC-742 and the master log.
The licensee agreed to correct-this ommission when the March 31, 1981 Form NRC-742 report is submitted.
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ATTN:
Mr. James J. McGovern d
s Business Manager, Radiochemicals p
P. O. Box 324 Tuxedo, New York-10987 s
Gentlemen:
Subject:
Combined Inspection Nos.
-54/81-02 and 70-687/81-04 s inspection conducted by Mr, H. Zibulsky This refers to the ro'+' m >4i %
of this office on Jul 13-6, 10 i activities authorized by NRC License Nos. R-81 and SNM-639 cou r.ne discussions of our findings held by Mr. H.
w Zibulsky with Mr. Fred Morse of your staff at the conclusion of the inspection and to subsequent telephone discussions between Mr. J. H. Joyner of this office and yourself on July 17 and 28,1981.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Our inspector also verified the steps you have taken to correct the item of noncompliance brought to your attention in a letter dated September 19, 1979.
We have no further questions regarding your action at this time.
Based on the results of this inspection, it appears that one of your activities was not conducted in full compliance with NRC requirements, as set j
forth in the Notice of Violation, enclosed herewith as Appendix A.
This item of noncompliance has been categorized into the levels described in the Federal L
Register Notice (45 FR 66754) dated October 7, 1980.
You are required to respond to this letter and in preparing your response, you should follow the i
instructions in Appendix A.
The -item of noncompliance in the Notice of Violation enclosed as Appendix A to l
this letter was identified during a previous inspection of your licensed activities'on June 6-9, 1978, and was documented in the enclosure to our l
letter dated July 13, 1978.
Your letter to this office dated August 9, 1978, L
indicated that an audit would be performed by October 3, 1978.
During a l
subsequent inspection of your licensed activities on April 24-27, 1979, a 1
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' deviation was identified for your failure to perform an audit by October 3, 1978, although an audit was subsequently performed.
The deviation was identified in our letter dated September 19, 1979.
Your letter to this office dated October 25, 1979, stated that a schedule of audits had been promulgated for all routine audits that were required under your facility license.
From our July 13-16, 1981 inspection it appears that the stated corrective actions were not effective since this item has recurred.
Recurrent and uncorrected items of noncompliance are given additional weight in the consideration and selection of appropriate enforcement action.
Therefore, in your response to this letter, you should give particular attention to those actions taken or planned to ensure that identified items of noncompliance will be completely corrected and will not recur.
In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, documentation of findings of your control and accounting procedures for safeguarding special nuclear materials and your facility security measures for physical protection are deemed to be commercial or financial information within the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12; therefore, the enclosures to this letter, and your response to this letter wil~1 nn be placed in the Public Document Room and will receive limited distribution.
Should you have any questions concerning this inspection, we will be pleased t0 utscuss them with you.
Sincerely,
.e j 1,c W. Starostecki, Director 01,ision of Resident and Project Inspection
Enclosures:
Appendix A, Notice of Violation (d Enforcement InspectionContains 2.790 Information 1.
Combined Office of Inspection an 2
Report Number 50-54/81-02 and 70-687/81-04 (Contains 2.790 Information) cc w/ report cover sheet only:
M. H. Voth, Manager, Nuclear Operations W. G. Ruzicka, Reactor Project Engineer i
C. Kennerth, Health Physicist R. Bollinger, Vice President, Medical Products Division Public Document Room (PDR)
Local Public Document Room (LPOR) i Nuclear Safety Information State of New York i
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