ML20127P646

Safety Insp Rept 70-0687/85-02 on 850515-17.No Violations Identified.Major Areas Inspected:Radioactive Matl Transportation Program,Including New Decontamination Process & Radwaste Classification

ML20127P646
Person / Time
Site:	07000687
Issue date:	06/21/1985
From:	Clemons P, Shanbaky M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127P395	List: ML20127P389 ML20127P646
References
70-0687-85-02-0, 70-687-85-2, NUDOCS 8507020479
Download: ML20127P646 (4)

Text

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9 U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-687/85-02 Docket No.70-687 License No. SNM-639 Priority 1 Category UHBR Licensee: Union Carbide Corp P.O. Box 324 Tuxedo, NY 10987 Facility Name: Hot Laboratory Inspection At: Tuxedo, New York Inspection Conducted: May 15-17, 1985 Inspectors: w.)

P. Clemons, Radiation Specialist

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/ Wate Approved by: W.h ,Z##

M. Shanbaky, Chief, PWR, Radiation d 2/

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1, Safety Section date Inspection Summary: Inspection on May 15-17, 1985 (Report No. 70-687/85-02)

Areas Inspected: A special, announced safety inspection of the radioactive material transportation program including: a new decontamination process and radioactive waste classification. The inspection involved 20 onsite inspection hours by one region-based inspector.

Results: No violations were identified.

8507020479 850625 PDR ADOCK 07000687 C PDR

Details 1.0 Persons Contacted 1.1 Licensee Personnel J. McGovern, Business Manager C. Konnerth, Manager, Health, Safety and Environmental Affairs Other licensee personnel were contacted and interviewed during this inspection.

2. Decontamination Process On April 1, 1985, Union Carbide delivered to a carrier for transport, about 140 Curies of radioactive material contained in high integrity containers (HIC) for delivery to the Chem-Nuclear Systems, Inc. burial site in Barnwell, South Carolina. The HIC's, in plastic bags, were shipped in the Model B-3 shipping casks.

On April 4, 1985, the shipment was inspected upon receipt at the burial site by a representative of the State of South Carolina. Upon offloading, the HIC's were surveyed for dose rates and contamination. The plastic bag containing one of the HIC's indicated a dose rate of 300 mr/hr on contact.

A smear from the inner surface of the cask indicated removeable contami-nation of 1,200,000 dpm/100 cm2 . The State of South Carolina representa-tive stated that these discrepancies violated the regulations of the State of South Carolina. There were no violations of DOT /NRC regulations.

On April 9,1985, South Carolina assessed a civil penalty of $5,000.00 against Union Carbide, and the State also suspended their Radioactive Waste Transport Permit.

On May 14, 1985, a Region I inspector was sent to the site to determine the cause of the excessive contamination problems, and to observe the development of the High Pressure Water Spray Decontamination Process to determine if it would be effective.

The inspector determined that the cause of the excessive contamina-tion levels found at the burial site was that once the HIC was removed from the Hot Cell where it was packaged, no further decontamination efforts were performed. No smear surveys were performed on the HIC once it left the Hot Cell and prior to loading it in a shipping cask.

On May 15-16,1985 the inspector observed several HIC's being decontami-nated using the new modified high pressure water spray system. The inspector noted that the licensee made several modifications to the high pressure water spray system to assure that the decontamination process

2 would meet the acceptance criterion for each HIC. The acceptance criterion for each HIC is:

1 50K dpm/100 cm2 > x + 2a. If this criterion 1 is not met, then the decontamination process must be repeated.

The inspector noted that HIC No. 2306-2 was decontaminated on May 15, 1985, and it did not meet the criterion. The upper spray ring nozzle was i

modified. After system modification HIC No. 2306-2 was decontaminated a second time and it met the criterion.

HIC No. 2306-16 was decontamination on May 16, 1985, and it met the criterion also.

L The licensee will modify the procedure to include the requirement that in the future all HICs must be decontaminated in the high pressure water spray system and the smear results must meet the acceptance :riterion prior to loading the HIC into a shipping cask.

Within the scope of this review, no violations were identified.

3. Waste Classification 10 CFR 61.55(a)(8), " Waste classification" requires that measurements be made to determine the concentrations of nuclides in wastes. The Low l Level Waste Licensing Branch Technical Position on radioactive waste classification recommends that for Class B and C waste types, the confirmatory analysis should be performed on at least an annual basis.

This analysis should provide for identification and quantification of radionuclides for the classification of waste streams.

It was determined that the licensee has never sampled and analyzed its waste stream. The licensee has a copy of an Interim Report that was issued by Brookhaven National Laboratory dated July 1982, entitled

" Characterization of the Radioactive Large Quantity Waste Package of the Union Carbide Corporation". This report was the apparent result of a study done in 1980-1981 to determine that the Union Carbide shipping cask was an acceptable Type B package. This study utilized a theoretical evaluation of radionuclide content in waste produced. This evaluation was used to identify the isotopic contents for numerous waste shipments that have been made to the burial site in Barnwell, South Carolina.

The licensee has committed to have the waste stream analyzed. In a letter dated May 21, 1985, the licensee stated, "This letter is to affirm that Union Carbide Corporation, Sterling Forest Laboratory will have measure-ments made to verify the concentration of C-14, Tc-99, and I-129 that is present in a typical waste batch that is routinely shipped for disposal."

,. This matter is considered as unresolved and it will be reviewe? n a sub-4 sequent inspection (85-02-01).

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3 Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations.

4. Exit Interview '

The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on May 17, 1985. The inspector summarized the scope of the inspection and the findings.

At no time during this inspection was written material provided to the licensee by the inspector.

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