ML20058C010
| ML20058C010 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 07/04/1982 |
| From: | Clemons P, Greenman E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058B982 | List: |
| References | |
| 70-0687-82-03, 70-687-82-3, NUDOCS 8207260225 | |
| Download: ML20058C010 (6) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
70-687/82-03 Docket No.70-687 License No. SNM-639 Priority 1
Category A
Licensee:
Union Carbide Corporation P.O. Box 324 4
Tuxedo, New York 10987 Facility Name: Sterling Forest Research Center Inspection at: Tuxedo, New York Inspection conducted: April 28-30, 1982 Inspector: I 7
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~F. Clemons, Radiation Specialist dith signed date signed date signed Approved by:
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E. G. Greeriman, 'CTiief, Fadilities Radiation
'daTe signed Protection Section, Technical Programs Branch Inspection Summary:
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Inspection on April 28-30,1982 (Report No. 70-687/82-03)
Areas Inspected: Routine, unannounced safety inspection by a region based inspector of the Radiation Protection Program including:
field inspection-shipping packages, training, bioassay, surveys, outstanding items, source leak test, liquid waste, ventilation, receipt of radioactive material and absolute filter changes.
Shortly after arrival, areas where work was being conducted were examined to review radia-tion control procedures and practices. The inspection involved 22 inspector hours onsite by one region based inspector.
Results: One violation was identified (failure to comply with the terms and conditions of the certificate of compliance paragraph 4).
8207260225 820709 PDR ADOCK 07000687 C
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l DETAILS 1.
Persons Contacted Mr. D. Grogan, Manager, Radiochemical Production Mr. C. Konnerth, Manager, Health, Safety and Environmental Affairs Mr. R. Thompson, Senior Health Physics Technician Mr. M. Voth, Manager, Nuclear Operations l
The inspector also interviewed other licensee employees including technicians and a custodian.
denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Violation (687/81-06-01) Special nuclear material storage area was not posted as to the amount of uranium contained in the area.
The inspector verified that the licensee has properly posted the area.
An estimated uranium content for each drum is posted.
This estimate is then corrected after actual content is determined.
Corrective action was verified as described in the licensees-letter to the NRC Region I dated March 18, 1982.
3.
Field Inspection On April 28, 1982, the inspector toured the facilities at the Tuxedo, New York site to observe ongoing work and operations in progress.
Areas examined incluoed a transfer of uranium from the special nuclear material storage cabinet and verification that the cabinet could only store one container.
I No violations were identified.
1 4.
Shipping Packages On April 29, 1982, the inspector reviewed shipping documents associated with two shipments of licensed material that were made during 1982. On i
1 January 12, 1982, a shipment was made to Savannah River, South Carolina using the BMI-1 shipping package, Certificate of Compliance No. 5957.
i The package contained irradiated uranium oxide waste (3,406 grams of i
U-235 and 18,586 curies of mixed fission products). On March 17, 1982, a second shipment of irradiated uranium oxide waste was made to the same destination, and using the same shipping package. This time the package contained 3,356 grams of U-235 and 25,868 curies of mixed fission products.
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Union Carbide Corporation 3
Revision 7 of Certificate of Compliance No. 5957, Condition No.
5(b)(1)(xi), states the contents of the package may be " Irradiated uranium oxide waste enriched in the U-235 isotope (&90 w/o) which are thermally stable up to 800'F".
During previous inspections at this facility the inspector had determined that only fully enriched uranium (c93 weight percent U-235) was used in the irradiation process.
Shipping documentation indicated that post irradiation enrichment is 93.1 weight percent U-235.
The Manager, Health, 4
Safety and Environmental Affairs also confirmed that the material shipped in the package was enriched in the U-235 isotope to greater than 93 weight percent.
10 CFR 71.12(b)(ii) requires a person using a shipping package to comply with the terms and conditions of the Certificate of Compliance for the package.
Shipping irradiated uranium that was enriched to greater than 90 w/o in the isotope U-235 represents a violation of 10 CFR 71.12 and 4
2 the terms and conditions of the Certificate of Compliance.
(82-03-01) l 5.
Source Leak Test License Condition 12 governs sealed plutonium source leak checks and 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 testing conducted April 14, July 9, September 29, and December 30, 1981 to verify that the license 4
condition was satisfied.
The licensee has one sealed plutonium source.
No violations were identified.
6.
Training 4
Condition No. 9 of License No. SNM-639 incorporates a letter dated April 28, 1969.
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 determined that one female was newly hired in the Health Physics Department in January 1982. The inspector reviewed training documents that indicated that the employee had received required training and that the training included prenatal radiation exposure information.
I No violations were identified.
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Union Carbide Corporation 4
7.
Bioassay Condition No. 9 of Special Nuclear Material License No. SNM-639 incor-porates 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.
The inspector noted that urine sample collection bottles were distributed to six employees, who work with unencapsulated uranium, on June 17, 1981.
The inspector also noted that documentation showed that the urine samples from the six employees were returned to Health Physics over the period of June 30, 1981 to December 8, 1981. The samples were submitted to an outside vendor for analysis.
The vendor's records indicated that the samples were received (by the vend s) on March 19, 1982.
The inspector discussed the length of time between issuance of collection bottles, their return to the licensee (about six months) and the results of the analyses which were not received by the licensee until April 12, 1982, a period in excess of four months from the time the last sample was returned to the site. Of the six samples analyzed,two reported a positive result. The maximum value was 1.6 picocuries per liter of urine,which was not significant with respect to uptake. The predominant isotope was U-235. The inspector's review indicated that in this case no significant error fraction was created.
The inspector advised the licensee that the distribution, analysis and review cycle was not considered timely. A cognizant licensee representative committed to investigate and evaluate this area. This item will be followed up during subsequent inspections.
(82-03-02)
The inspector noted that a seventh uranium " spiked" sample was also among the samples sent to the vendor for analysis. The activity included in the " spiked" sample was 220 DPM/ liter. The inspector reviewed the sample analyses results and noted that the vendor had reported an activity of 7.69 + 1.04 DPM/ liter for the spiked sample.
On June 28, 1982, the inspector was informed by a licensee representative that a procedure for the bioassay program was being developed.
The procedure will provide direction for such things as sample bottle issuance, sample collection and return, sample analyses, and action limits. 'The p.'ocedures will be implemented by September 30, 1982. Additionally, the inspector determined " hat a quality assurance program would also be included in the procedure to monitor the bioassay program activities, and immediately effect resolution of discrepancies in performance testing.
No violations were identified.
I Union Carbide Corporation 5
8.
Liquid Waste All liquid waste from the uranium plating operation is evaporated and solidified. The inspector verified that waste generated is not dis-charged to the environs. Air sample results, from an air sampler that is located adjacent to the evaporator,were reviewed for the period January -
April, 1982.
The results were all within regulatory limits. No signifi-cant levels above background readings were identified. The inspector, also verified that all waste generated in the irradiation process is solidified.
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No violations were identified.
9.
Receipt of Radioactive Material 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 ten shipments received by the licensee during 1982 to 2
veri fy compliance. All results were less than 100 DPM/100 Cm.
No violations were identified.
i 10.
Ventilation i
Condition No. 9 of License No. SNM-639 incorporates a letter dated April 28, 1969.
The April 28, 1969 letter, Page 10, Item 1, Ventilation System, states "... ventilation system is pressure regulated to insure a continuous, positive flow of air from nonradioactive areas to contaminated or radiation areas".
The license condition specifies that flow must be from nonradioactive areas to contaminated areas. No flow rate is specified.
The inspector verified that flow was in the proper direction and that linear velocity was adequate.
Temporary work on the ventilation system in the Hot Lab Building resulted in air flow conditions in a Walk-In-Hood of 50-75 CFM.
The industry standard is 100 CFM. The inspector determined that this condition was temporary, was carried out under approved procedures and supervision and caused no air flow problems with respect to license conditions.
No violations were identified.
11.
Filter Change j
Condition No. 9 of License No. SNM-639 incorporates a letter dated June 13, 1973.
The June 13, 1973 letter has a statement that reads as follows:
" Operations with SNM in chemistry laboratories can result in scrap material of both solid and liquid forms. Material of solid form (UO ) is recycled into the process carried on in a particular laboratory.
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Union Carbide Corporation 6
Some solid material (milligram quantities) may accumulate on filters in the exhaust ventilation system.
However, in the normal course of events these filters are changed at maximum intervals of one year".
The inspector reviewed a log book that indicated that roughing and absolute filters had been changed in the Solution Lab and the Plating Lab of the Hot Lab Facility during January 1981. These are areas in which the largest quantities of unencapsulated uranium are routinely handled.
No violations were identified.
12.
Surveys I
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 i
representative, wipes are taken from certain areas daily, and other areas i
monthly. The inspector reviewed smear survey records for clean areas for j
the period January through April 1982. All results were less than 300 2
j DPM/100cm.
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The inspector reviewed air sample data for the period January through j
April 1982 to determine that the samples were being taken and to verify
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that regulatory requirements were satisfied.
1 The inspector reviewed stack sample records for the period January-I April 1982.
The data for all samples indicated that the air concentra-j tions were within the regulatory limits specified in 10 CFR 20, Appendix B.
No violations were identified.
13.
Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on April 30, 1982. The inspector summarized the purpose and the scope of the inspection, and the findings as presented in this report.
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