ML20151Y514
| ML20151Y514 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 08/22/1988 |
| From: | Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20151Y506 | List: |
| References | |
| 70-0687-88-05, 70-687-88-5, NUDOCS 8808260426 | |
| Download: ML20151Y514 (7) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 88-05 Docket No.- 70-687 License No.
SNM-1067 Prior
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Category UHBR Licensee: Cintichem, Incorporated P. 0._. Box 816 Tdxedo, New York 10987 Facility Name: Cintichem, Incorporated.
Inspection At: Tuxedo, New York Inspectior. Conducted: June 28-30, 1988 Inspector:
1 ft 77-N J. Mth, aroject Engineer, Effluents Radiation
/ date'-
Phdtection Section, FRS&SB, DRSS Approved by:
6f 88 W. J. PaQc ak, Chief, Tf fluents Radiation
' datte Protect %n Section, FRS&SB, DRSS l
Inspection Summary:
Inspection on June 28-30, 1988 (Inspection Report No.
l 70-687/88-05)
Areas Inspected: Routine, unannounced inspection by one region-based inspector of: nuclear criticality safety; operations; radiation protection; 1
non-routine events; and followup on inspector identified problems.
[
j Results: Two violations were identified - Vio ations:
failure to maintain the radiation dose rate in km unrestricted area to less than 2 millirem / hour allowed by 10 CFR 20.105(b)(1)(paragraph 2.c); failure to follow the conditions specified on a ruclear criticality sign as required by Section 4.1.E of the NRC-approved license appl (cation and failure to accurately maintain a log 'af the running invratory of SNM in the reactor j
facility tunnel as required by Section 4.1.1 of the NRC-approved license s_
application (paragraphs 3.b and 3.c).
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l DETAILS 1.
Persons Contacted t
- J. J. McGovern, Plant Manager
- L. C. Thelin, Staff Health Physicist
- J. Stewart, Supervisor, Health Physics
- J. Ditton,. Health Physics Technician State of New York W. T. Varcasio, Department'of Fnvironmental Conservation S. Zobel, Department of Environmental Conservation
- present at the exit interview 2.
Review of Operations The inspector examined'all areas of the Hot Labccatory and reactor facilities to observe operations and activities in progress; to inspect the general state of cleanliness, housekeeping,.and adherence to fire protection rules; and, to assure that all areas in which SNM is handled or stored were properly posted with radiation safety or criticality safety signs as required by NRC regulations or license conditions.
l a.
Housekeeping I
Durins exanination of the second floor hot cell roof area, the inspector noted that the area had been cleaned and housekeeping had improved significantly. No inadequacies were identified.
b.
Postings l
Two nuclear criticality safety signs pos'ted at the waste storage l
building were observed. One sign posted on the~outside of.the rollup door authorized 700 grams U-235 in the building. Another sign posted inside the buildinc authorized a maximum of 650 grams U-235 in the building.
Between May 3 and June 10, 1988, the t
building contained from 678 to 690 grams U-235.
The NRC-approved license application authorized the licensee to storc up to 700 grams U-235 in any one location.
Therefore, since the inspector questioned the presence of signs containing two different limits, the licensee immediately removed the sign containing the lower, previously authorized limit (650 grams U-235).
The inspector had no further questions on these postings.
c.
Radiation Limits a
a.
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t During examination of the waste' storage building, the inspector conducted a radiation survey on the outside surface of the building.
It was noted that the radiation level on the outside east wall of the building, on contact, was eight (8) millirem / hour.
This radiation level is in excess of the two (2) millirem / hour allowed in unrestricted areas by 10 CFR 20.105(b)(1). The inspector verified that there was unimpeded access to this building from the north since there was no property line fence along the lake located to the north of the licensee's property. According to licensee representatives, the licensee's New York State License No. 729-0322 authorized up to 10 millirem / hour on the surface of the building.
However, the licensee could not provide the inspector with written verification of this limit during-the inspection.
In any case',
l since both special nuclear material.(476 grams U-235_on the date of this inspection) and byproduct material was being stored in this building, the requirements of 10 CFR 20 apply (in accordance with 10 CFR 20.1(b)). This was identified as an apparent violation i
(70-687/88-05-01).
i d.
Voluntary Use of Shoe Covers During examination of Building 2 (the Hot Laboratory), the inspector noted a sign at the main entrance which indicated that shoe covers should be used in the building if desired. Through discussions with licensee representatives, the inspector questioned the advisability of allowing personnel to decide if shoe covers were required. The inspector stated that the licensee should evaluate the need for the I
e general use of shoe covers throughout the facility and then should require their use, if necessary.
The licensee committed to re-evaluate the voluntary use of shoe covers by personnel.
This will be re-examined during a subsequent inspection, e.
Contamination __ Control l
During examination of the Hot Cell Conveyor Station area, the i
j inspector.noted that the area was being treated.as a contamination l
control zone. However, entry to this zone from the hot cell operating side was not restricted by means of a rope or other means l
eveopt for a posted sign to guard against inadvertent entry without l
arotective clothing. As a result of this observation, the licensee immediately restricted entry o the zone with a rope.
f.
Storage and Rquse of Laboratory Coats During examination of the Hot Laboratory second floor uranium processing area, the inspector observed that four potentially contaminated, (used) lab coats were being hung on a rack on top of one another, rather than side-by-side.
Subsequently, the inspector observed an individual enter the area and begin to don one of the lab coats without conducting a contamination survey of the inside. The individual i
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was stopped and was given a clean lab coat to wear. This was identified as a deviation from standard industry practice that does not permit co-mingling potentially radioactively contaminated clothing with cleanclothing(70-687/88-05-02).
S.
Nuclear Criticai 7.y Safety a.
SNM Inventory The inspector examined all areas of the plant and assured that the.
total inventory of unirradiated U-235 was not more than that l
authorized by the facility licenses.
t i
b.
Nuclear Criticality Safety Postings During examination of the nuclear criticality safety signs posted on the hot cells, the -inspector noted that the conditions for the storage and use of special nuclear material specified on the Hot Cell No. I sign did not allow the use and/or storage of solid material.
Contrary to the sign, one uranium oxide batch can containing 163.18 grams of U-235 as solid uranium oxide was observed in the h:t cell.
This was identified as an apparent violation of Section 4.1.5 of the NRC-approved license application l
(70-687/88-05-03).
This apparent violation was immediately i
corrected by the licensee.
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l c.
Inventory Logs During examination of the Reactor Fa-ility "Tunnel", the inspector noted that the inventory log posted on the wall uf the tunnel l
indicated the presente of 179.08 grams'U-235. However, through examination of a number of drums and an available list of drums l
located in the tunnel, the inspector determined that there was actually 635.04 grams U-235 present.
This value, as indicated above, was not shown on the Sg nor was it indicated on the master SNM log required for mainte.ining accountability of SNM in the area.
Failure to accurately maintain a log of the running inventory of SNM in the tunnel was identified as an apparent violation of Section 4.1.1 of the NRC-approved license application (70-687/88-05-03).
4.
Radiation hotection a.
Hood Velocity Checks The inspector determined through examination of 1 :ensee records that the air flow velocity on hoods was checkcd a least every three months, as required, between January 29 and Mey 15, 1988. However, there was no indiration in the records that corrective actions were taken, when nece sary The inspector was able to determine if
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cor ective actions were taken only through a sequantial review of air flow velocity check records.
The inspector stated that the licensee should maintain a record of da actions taken to correct air flow on hoods in order to deve N 4i operational history on l
-these hoods.
From that operational history, the_ licensee should be l
able to develop a preventive maintenance program.
Since a similar i
observation was made by the inspector during Inspection No.
70-687/86-06 with regard to smear survey results, the inspector l
stated that the system to be developed to document corrective actions l
on hood air flows should be expanded to include all areas of facility operations.
Licensee representatives stated that the-inspector's l
statement would be evaluated'and incorporated into the facility l
safety program, if appropriate.
L l
During examination of the hood air flow recerds, the inspector l
observed that air flow at the lower door on the conveyor station was low (routinely between 50 to 90. linear feet per minute). According to licensee representatives, the air flow was low because this area of the conveyor station was not equipped with an independent fan.
Instead, air flow was maintained by means of ta fan located in the upper part of the station. Air flow in the lower part of the station was low because there was a snlid plate separating the two parts of the station. However, normally, the lower door was opened l
only when the plate separating the two areas was raised out of the l
air path. The inspector stated that the procedures for use of the conveyor station should be modified to require that the plate be raised out of the way prior to opening the Iowar door.
Licensee representatives stated that the procedure would be modified, as indicated.
j b.
Radiation Monitor Tests, Checks and Calibration j
l The inspector verified by a review of= records that the licensee
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conducted and documented the daily operability tests and weekly i
alarm checks on each radiation / criticality monitor between May 16, 1988 and June 28, 1988.
Corrective actions were taken and completed when inadequacies were identified.
5.
Stack Sampling l
During Inspection No. 70-687/88-04; 50-54/88-01, the inspectors identifled l
two violations cancerned,with failure to survey (measure) effluent releases through the Hot Cell Emergency Ventilation System (Cells 2 and 4) exhaust to show compliance with 10 CFR 20.106 and failure to routinely perform quarterly ef ficiency testing on tFe Hot Cell Energency Ventilation Syst'm 1
Exhaust filters.
During the current inspection, the inspector noted that the licensee had installed measuring devices on the two exhaust systems previously i
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6 identified.
However, toe measuring devices were improperly installed in that there were numerous sharp bends in the sampling line, the sampling lines were tygon tubing and the sampling points were located at maximum turbulent flow locations within the ductwork. Also, no evaluation of the stack monitoring devices had been conducted in order to determine if they were representative of the stack releases.
In addition, the inspector conducted a radiation survey of the roof area under the stack release point for the Hot Cell No. 4 system and determined that the roof was contaminated up to abcut six times background.
Subsequent analysis by the licensee indicated that the contamination was Iodine-131. The inspector obtained samples of roofing material which were returned to the Region I laboratory for confirmatory analyses.
Results of those analyses will be provided in a subsequent inspection report.
As a result of the above observations, r Confirnatory Action Letter (CAL No. 88-15) was issued to the licensee on June 30, 1988 prior to the end of this inspection. The actions agreed to in the CAL by the licensee are as follows:
1.
Prior to further operation o) the Hot Cell Emergency Ventilation System, you will complete the following actions:
a)
Provide appropriate effluent monitoring equipment on the system (particulate, iodine, and noble gas) to assure compliance with 10 CFR 20.106 and applicable State and NRC regulations.
This monitoring may be accomplished by installing effluent monitoring equipment on the current system exhaust point or by l
directing the system exhaust into your pre-existing, monitored main stack effluent discharge pathway, b)
Establish and implement a surveillance and maintenance program for the system to assure syster operability.
The operability test should verify that the HEPA and charcoal filter removal efficiencies meet the requirements of SNM-639 Section 3.2.
c)
Establish written procedures (to be approved by the Nuclear Safeguards Committee) for system maintenance, testing and operation.
l d)
Provide training for appropriate personnel on system maintenance, testing, and operation.
This will include training on the newly established system procedures.
Full completion of the above requirements is not a necessary condition for operation of the above system in emergency situations I
(i.e., failure of your main backup ventilation fans EF-12 and EF-12A) where operation of the system is necessary to maintain negative pressure in the hot cells.
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4 2.
During the interim period when the Hot Cell Emergency Ventilattun System is isolated, you will usa other systems or methods to assure that negative pressure is maintained in the hot cells and_to minimize potential for airborrie radioactive material releases from the hot cells.
3.
Perform and complete comprehensive radiological surveys by July 3, 1988 to characterize the extent of contamination identified on roof tops and adjacent areas.
These surveys will include actual measurements of potentially released materials including alpha, beta, and gamma emitters. Complete decontamination and/or fix contamination-in the affected areas by July 8, 1988.
4.
Perform an evaluation to quantify potential releases from the system and update previously reported effluent release data as may be neces sa ry.
This evaluation should be completed by December 31, 1988.
5.
Perform a review of current facility design and operation to identify and correct other potential unmonitored release pathways by August 1, 1988.
Actions taken by the licensee to satisfy-the conditions of the CAL as discussed above will be followed by inspectors during subsequent inspections of the licensed program.
6.
Uranium Sampling The inspector observed as licensee representatives obtained duplicate samples of feed materials (F-872 and F-873) and waste solution (PW-2471) for analysis by the New Brunswick Laboratory (NBL) located at Argonne National Laboratory.
Subsequent to this inspection, the licenses sent the indicated samples to NBL for analysis. The results of that analysis and a comparison with licensee analysis results on the duplicate samples will be reported in a subsequent inspection report.
7.
Non-Routine Events Through discussions with licensee representatives and review of licensee records, the inspector determined that there had been no reportable or nonreportable non-routine events, within the scope of this inspection, since the last inspection of this facility.
8.
Exit Interview
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The inspector met with licensee representatives (danoted in paragraph 1)-
at the conclusion of the inspection on June 30, 1988. The inspector summarized the scope of the inspection and the findings.
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