ML20198D065

Responds to NRC Re Violation Noted in Insp Repts 50-054/86-01 & 70-0687/86-02.Corrective Actions:Procedure Changed to Require That Waste Drums Be tamper-safed Prior to Analysis

ML20198D065
Person / Time
Site:	05000054, 07000687
Issue date:	05/13/1986
From:	Konnerth C CINTICHEM, INC.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8605230126
Download: ML20198D065 (3)

Text

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, T, CINTICHEM, INC.

a wholly owned subsidiary of Medi-Physics, Im. P.O. BOX 818. TUXEDO NEW YORK 10987 [914] 351-2131 May 13, 1986 Mr. Thomas T. Martin Division of Radiation Safety and Safeguards United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

The f ol low ing is submitted in response to the report for combined inspection numbers 50-54/86-01 and 70-687/86-02. The response is organized to agree with the headings in the inspection report dated April 14, 1986.

APPEElX A - ITEM A in our Fundamental Nuclear Material Control Plan we have four specific Material Balance Areas. These were selected based on functional responsibility for the material during our process. The specific areas chosen were:

E A #1 All activities with the incoming f eed material.

EA #2 All activities involved in preparing a target.

EA#3 All activities involved in irradiating a target in the reactor.

EA #4 All activities involved in processing the irradiated target.

The material referred to in this alleged violation had just been received on site and was being put into solution prior to initial assay and storage in the feed cabinet. The EA #1 Custodian has always been responsible for this part of our process. Since this single designated Individual was responsible and had custody of the material for the entire process we never Intended, nor do we see the need to , divide this process between two EAs. We bel leve that our- procedure for handling this part of our process is in agreement wIth our approved FNMC plan. Sir.ce there was no transfer out of EA #1, there was no need for an Internal transaction report.

Our program has several areas where material from dif ferent EAs may exist in the same physical area. The critical Ity control logs for each area are Independent of the EA logbooks and are maintained for a dif ferent purpose.

in this case, the EA #1 logbook correctly indicated that there had been no transfer of this material.

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APPE WlX A - ITEM B The ten barrels of low l evel waste were not tamper-safed immediately because several of the drums contained more than 15 grams of U-235 and were going to be repackaged and then reenalyzed. Shipping regulations limit the uranium content of these drums to less than 15 grams U-235. In order to avoid f uture violations of this type, we have changed our procedure so that waste drums will now be tamper-safed before they are submitted for analyses, if a drum has to be repackaged, we wIlI void the original seal and reseal it immediately af ter completion of a second analysis. We believe that with this change in procedure, we are currently in compliance with Paragraph 2b.

APPEWlX A - ITEM C The three Iow Ievel w aste barrels Identifled in this alIeged vloiation were not normal waste barrel s in that each of them had to be repackaged because it exceeded the DOT lImit for uranium. Af ter removal of the excess uranium, the barrels were reassayed using reference standards representative of the f ull range of the normal waste barrels. We do not belleve that this procedure is a violation of Section 4.2.1.4.f. of our FNMC plan.

APPEWlX A - ITEM A (a, b)

Section 2.2 of our physical security pl an is a description of our controlled access area. The reference to the receptionists office was used only to identify which door is considered to be the " main entrance".

In Section 3.6 we state that packages which have not been searched v Ill be lef t with the receptionist. In spite of the f act that we no longer hava a receptionist in Building 2, we do have a receptionist for the entire site who signs in all visitors and f ulfills the requirement of this section. It is our contention that no change to our Physical Security Plan was necessary b,cause of the retirement of our Bullding 2 receptionist.

The reorganization on November 1, 1985 resulted in changes to some Job

, tities but oniy one change in personnel f111Ing these positions. We wIlI i submit a revised organizational chart within 60 days of your response to this l

letter. We request this time period so that we can include any other minor changes that may be necessary to update our plan.

APPE WlX B - ITEM B Because of the physical construction of our plant, no vehicles have access to our controlled areas.

We have a policy of allowing packages in a controlled area only if they are necessary for the purpose of the visit. We also have a policy requiring ,

Health Physics monitoring of all packages being removed from a controlled area. I believe that a Health Physics survey is equivalent to a search and at least accompl ishes the intent of Section 3.6

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In order to more clearly document compliance we have dedicated a section of our visitor log book to keep track of package entry into controlled access areas.

APPEPolX B - ITEM C We have reemphasized, verbally and in writing, the need to maintain complete log entries to both the watchmen and the reactor operators. We are now able to document f ul l compl iance w ith Section 4.4.

This combined inspection was conducted at the same time as inspection number 70-687/86-01. Although we appreciate all efforts made to improve our programs, we f eel that with our l imited staf f it would be more ef fective if you could avoid schedul ing three inspections at the same time. We bel ieve that if we had been able to spend more time explaining our program to the inspector, we could have el iminated some of these items.

Should you need additional Information, give me a call at (914) 351-2131.

Very truly yours,

-c7d

. J. Konnerth Manager, Site Operations CJK mag cc: D. Grogan J. McGovern W. Ruzicka L. Thel in N.

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