ML20203P569

Insp Rept 70-0687/86-01 on 860210-14.Violation Noted:Failure to Accurately Post Current Inventory of SNM on Feed Cabinet 4,storage of Combustible Matl in Supply Fan Room & Failure to Calibr Portable Alpha Meters

ML20203P569
Person / Time
Site:	07000687
Issue date:	04/25/1986
From:	Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203P554	List: ML20203P553 ML20203P556 ML20203P569
References
70-0687-86-01, 70-687-86-1, NUDOCS 8605070470
Download: ML20203P569 (11)

Text

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i U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-687/86-01 Docket No.70-687 License No. SNM-639 Priority 1 Category UHBR Licensee: Cintichem, Incorporated P.O. Box 324 Tuxedo, New York 10987 Facility Name: Hot Laboratories Inspection At: Tuxedo, New York Inspection Conducted: February 10-14, 1986 Inspector:

J.

h, Project Engineer L D N

' ddte Accompanied by: A. W. Grella Senior Health Physicist (Transportation), IE:HQ

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Approved by:

R. Kei g, C p

• f, Safeguards Section,

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[thM date Inspection Summary: Inspection on February 10-14,1986 (Report No.

70-687/86-01)

Areas Inspected: Routine, unannounced inspection by a region-based inspector of: organization; nuclear criticality safety; operations; radiation protec-tion; radioactive waste management; transportation activities; 10 CFR Part 61; nonroutine events; and licensee action on previously identified enforcement items.

Results: Four violations and an unresolved item were identified. Violations:

failure to accurately post the current inventory of SNM on Feed Cabinet No. 4 (paragraph 3a); storage of combustible material in the supply fan room (paragraph 3b); failure to calibrate portable alpha survey meters at three month intervals (paragraph 5f), and failure to maintain the plant organiza-tional structure and qualifications of HP Supervisor in accordance with the NRC approved facility license (paragraph 8). Unresolved item: techniques to be used to verify the computer generated distribution of radionuclides in waste and the establishment of intervals between required confirmatory analyses of radionuclides in waste (paragraph 99 ).

8605070470 860430 7 DR ADOCK 0700

DETAILS

1. Person Contacted

• J. J. McGovern, Plant Manager

• C. J. Konnerth, Manager, Site Operations

• L. C. Thelin, Radiation Safety Officer

• W. G. Ruzicka, Manager, Nuclear Operations J. Ditton, Health Physics Supervisor H. C. Hart, Supervisor, Hot Lab Operations

• present at the exit interview

2. Licensee Action on Previously Identified Enforcement Items (Closed) Inspector Follow-up Item (687/85-01-04): Investigate reasons i for low air flow in the QA Laboratory west hood. Subsequent to Inspection 70-687/85-01, the licensee checked the pressure differential across the absolute filter in the hood ventilation system. As a result of this check, the filter was changed on February 27, 1985. The-air flow increased to required levels.

(Closed) Inspector Follow-up Item (687/85-04-01): Verify samples analyzed as required by Part 61. Subsequent to Inspection 70-687/85-04, the licensee submitted requests to two vendors to analyze the facility waste for C-14, Tc-99, I-129 and H-3. Each vendor indicated that it could not perform the analyses because the high activity waste could not be i

handled in their facilities. Fu.rther attempts by the licensee to find a vendor that could analyze the waste were unsuccessful. In order to

! resolve this matter, the inspector requested the licensee to discuss available options with NRC's NMSS-Waste Management personnel. Pending resolution, this will be classified as an unresolved item as discussed in paragraph 9g.

(Closed) Inspector Followup Item (687/85-05-01): Assure' removal of the

vacuum cleaner from the solution makeup laboratory. During examination of the facility, the inspector verified that the unsafe geometry vacuum 4

cleaner was removed from the solution makeup laboratory.

(Closed) Violation (687/85-07-01): Two instances of failure to label radioactive material. During Inspection 70-687/85-07, the two instances of failure to label radioactive material were immediately corrected.

During this inspection, the inspector did not identify any instances of failure to properly label radioactive materials. The inspector also veri-fied that Health Physics technicians were reinstructed to ensure that all waste containers were properly labeled. Corrective actions have been completed on this violation.

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3. Review of Operations The inspector examined all areas of the Hot Laboratory 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,

a. Criticality Control Loqs During examination of che facility, the inspector determined that criticality control logs located in each criticality control area (storage areas and work stations) were properly completed except for the Feed Cabinet #4 storage area. The criticality control log for Feed Cabinet #4 indicated that 319 grams of U-235 were stored in the cabinet. The cabinet was opened, at the request of the inspector, and was found to be empty. According to licensee representatives, the U-235 had been transferred to the solution makeup laboratory and was logged into the criticality control log for that laboratory.

This was verified by the inspector. Failure to accurately post the inventory of SNM for the Feed Cabinet #4 was identified as a vio-lation of Section 4.1.5 of the NRC-approved license application (687/86-01-01).

b. Fire Protection During examination of the supply fan room, the inspector observed several sheets of plywood and packaging material stored in the room.

The supply fan room was not equipped with a water sprinkler system.

The storage of combustible material in the supply fan room was identified as a violation of Section 3.2.5 of the NRC-approved license application (687/86-01-02). Upon identification of this violation, the licensee immediately removed the combustible material from the supply fan room.

c. Housekeeping During examination of the second floor hot cell roof area, the inspector noted that housekeeping was inadequate. The area was in disarray in that tools, packages, equipment and containers were scattered throughout the area. However, it was noted that emergency escape routes out of the area were clear. According to licensee representatives, a project, to clean out cell 5, has been in progress during weekend shutdowns. The materials identified by the inspector were to be used by the licensee during the cell 5 clean out activity on the next weekend.

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4. Nuclear Criticality Safety l

a. SNM Inventory-The inspector examined all areas of.the plant and assured that the i total inventony of unirradiated U-235 was not more than that authorized by the facility licenses.

b. Facility Changes and Modifications The inspector noted that the licensee was cleaning out Cell 5.

According to licensee representatives, upon completion of the Cell 5

clean out, the Cell I waste handling operations will be transferred to Cell 5 so that Cell I can be refurbished. This refurbishment will include repair or replacement of one of the Cell I windows.

c. Bi-monthly Criticality Inspections Licensee records examined by the inspector indicated that bi-monthly criticality inspections of all SNM criticality control areas had been conducted between May 1985 and January 1986, as required by license conditions.

5. Radiation Protection

a. Air Sampling The inspector reviewed in plant air sampling data for-the period July 5, 1985, to December 20, 1985, and verified that NRC regulatory requirements were satisfied.

The inspector reviewed stack air sampling data for the period July 1, 1985, through November 1, 1985. The data indicated that the air concentrations were within the NRC regulatory limits specified in 10 CFR 20, Appendix B.

b. Smear Surveys r

The inspector reviewed smear survey records for all areas of the Hot Laboratory and Reactor facilities and equipment for the period July 1, 1985, to December 27, 1985. When necessary, corrective actions were taken as required by license conditions. However, it was noted that the corrective actions taken were not routinely docu-l mented after about October 15, 1985. This was discussed with i licensee representatives who agreed and stated that documentation will be improved. This is an Inspector Follow-up Item (IFI 687/86-01-03).

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c. Annual Fixed Alpha Contamination Survey The inspector determined that the annual fixed alpha contamination survey was conducted on December 4, 1985, within twelve months of the last survey, as required by license conditions. No fixed alpha contamination was found outside the uranium solution make-up and plating laboratories.

d. Hood Velocity Checks The inspector determined through examination of licensee records that the air flow velocity on hoods was checked at least every three months, as required, between January 22, and December 30, 1985.

e. Radiation Monitor Tests, Checks and Calibration The 'nspector verified by a review of records that the licensee conducted and documented the daily operability tests and weekly alarm checks on each radiation / criticality monitor between March 28, 1985 and December 27, 1985. Corrective actions were taken and com-pleted when inadequacies were identified.

f. Portable Instrument Calibration The inspector reviewed records of portable survey instrument cali-bration conducted between March 2, 1984 and January 10, 1986. The inspector determined that beta gamma portable survey instruments were calibrated at the intervals required by license conditions, or following repair. However, licensee records indicated that alpha portable survey instruments were calibrated at nine month intervals l between July 31, 1984 and January 10, 1986. Section 3.2.3 of the  !

NRC-approved license application requires that all lab equipment and survey meters are calibrated at 3 month intervals (not exceeding 4 months). This was identified as a violation (687/86-01-04).

g. Carbon Filter Efficiency Tests l Through a review of licensee records, the inspector determined that the licensee had conducted carbon filter efficiency tests at least quarterly between November, 1978 and December, 1985. The efficiency I of these filters, which were a part of the hot cell exhaust ventila-tion system, was determined to be at least 99.5 percent, as required by license conditions.

6. Safety Committees

a. Nuclear Safeouards Committee The inspector examined the records of three meetings (Nos. 117-119) of the Nuclear Safeguards Committee held between July 10, 1985 and December 6, 1985. Review actions and recommendations made by the

6 committee were adequately documented. Included in these records were supporting documents used by the committee to develop the recommendations. In addition, implementation of these recommenda-  ;

tions was adequately documented in the committee minutes.

b. General Safety Committee 4

The inspector examined the records of three bimonthly meetings of the General Safety Committee held between June 27, 1985 and January

, 9, 1986. This committee reviews the general safety and operational radiation safety aspects of the facility. Inspections of buildings, outside areas and vehicles are conducted for housekeeping, fire hazards, and use of safety equipment. Corrective actions were 4

initiated or completed as required.

7. Nonroutine Events Through discussions with licensee representatives and review of licensee records, the inspector determined that there had been no reportable or nonreportable nonroutine events, within the scope of this license and/or inspection, since the last inspection of this facility.

8. Organization i

Through a review of licensee records and discussions with licensee representatives, the inspector determined that the licensee had modified the facility organizational structure, effective November 1,1985.

Reporting to Mr. J. J. McGovern, Plant Manager, are the following:

C. J. Konnerth, Manager, Site Operations P. Quackenbush, Manager, Radiopharmaceutical Production and Distribution D. D. Grogan, Manager, Radiochemical Production and Material Control C. Anderson, Manager, Quality Control and Analytical Services

, F. Morse, Manager, Engineering and Technological Sales J. Jones, Manager, Human Resources Nuclear Safeguards Committee Reporting to Mr. C. J. Konnerth, Manager, Site Operations, are:

4 W. Ruzicka, Manager, Nuclear Operations L. C. Thelin, Radiation Safety Officer

G. Nardella, Site Operations Supervisor I

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7 Reporting to Mr. D. D. Grogan, Manager, Radiochemical Production and Material Control, are:

G. W. Wright, Production-Inventory Control Supervisor S. M. Sokolofsky, Hot Cell Production Supervisor D. P. Donnelly, Material Control Supervisor Reporting to Mr. L. C. Thelin, Radiation Safety Officer, are:

J. L. Ditton, Health Physics Supervisor R. A. Johnston, Safety Coordinator This organizational structure was compared with the facility organiza-tional chart depicted in Figure 2.1 of the NRC-approved license applica-tion. This comparison indicated the following:

(1) There is no Manager, Health, Safety and Environmental Affairs and, therefore, there is no Health Safety and Environmental Affairs group.

This group had primary responsibility for monitoring the safety of operations.

(2) The Nuclear Safeguards Committee reports to the Plant Manager and not to the Manager, Site Operations, as depicted in Figure 2.1.

(3) There is a Radiation Safety Officer who is not described in the facility license.

l (4) The incumbent of the Health Physics Supervisor position, does not meet the qualifications for the position as described in Section 2.5 of Part 1 of the NRC-approved license application in that he does not have a B.S. degree in science or physics.

Failure to maintain the organizational structure of the facility in accordance with the organizational chart depicted in the NRC-approved license application and failure of the incumbent Health Physics Super-visor to have a B.S. degree was identified as a violation (687/86-01-05).

9. Transportation Activities

a. Receiving The inspector examined the receipt records of packages containing SNM for the period July 9, 1985 through January 15, 1986. The licensee maintained records of monitoring, upon receipt of packages of radioactive material, as required by 10 CFR 20.205(b)(1). No inadequacies were identified.

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b. Shipping Records

. The inspector examined records of. uranium waste, reclaimed uranium,

LSA waste and spent fuel shipments made from July 24, 1985 to

, December 14, 1985. The inspector determined that radiation surveys l were made and recorded, and all shipments were labeled, marked, i

placarded, inspected and recorded, as required.

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c. Shipping Containers l Through a review of licensee records and discussions with licensee i representatives, the inspector determined that the licensee routinely a uses the following radioactive material shipping containers: Model i B-3 shipping cask (Certificate of Compliance No. 6058), Model BMI-1 j shipping cask (Certificate of Compliance No. 5957), NUS Barrier 55 j High Integrity Container (HIC), Model UCC-20WC-2 and UCC-20WC-2A ,

1 (Certificate of Compliance No. 909fs) and 17 H DOT specification drums.

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I The NUS Barrier 55 HIC container has been approved for use by the State of South Carolina. This approval expires on March 1, 1986, unless the containers are modified through the installation of a gas-relief vent. Licensee representatives stated that the containers will be modified, as required. This is an Inspector

Followup Item (IFI 86-01-06).

l l d. Packaging OA Program i

The inspector verified through review of records that the licensee  ;

j had an NRC-approved Quality Assurance Program for Radioactive Material Packages. This program was reviewed and approved by

NRC-NMSS by letter dated November 18, 1985.

j e. Packaging 0A Program Audit '

The inspector determined through review of records that the licensee

! conducted the annual Packaging QA Program audit on August 21, 1985.

As a result of this audit, recommendations were made to improve the .

shielding on the waste transfer cask, to-reduce radiation exposure to workers, and, to devise new HIC lifting techniques in order to eliminate j the current need to remove the HIC lifting bail. The waste transfer i cask is used routinely to move the HIC containers from the hot cells ,

to the waste storage facility. Implementation of these recommenda- l i

tions will be reviewed during subsequent inspections. This is an  !

j Inspector Follow-up Item (IFI 86-01-07).  ;

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f. Waste Transfer The inspector observed as the licensee removed a HIC container from Cell 1, placed the container into the waste transfer cask, transferred tne cask to the waste storage facility and lowered the container into one of 100 waste storage pits. The transfer was made in accordance with approved licensee procedures. No inadequacies were identified.

g. Implementation of 10 CFR Part 61 During Inspection 70-687/85-04, the inspector examined the licensee's implementation of 10 CFR 61.55(a)(8). 10 CFR 61.55(a)(8), " Waste Classification," requires that measurements be made to determine the concentrations of nuclides in wastes. The Low Level Waste Licensing Branch Technical Position on radioactive waste classification recom-mends 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.

The licensee has a copy of an Interim Report that was issued by

' Brookhaven National Laboratory during July 1982, entitled "Charac-terization 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 theo-retical evaluation of radionuclide content in waste produced and was used to identify the isotopic contents for numerous waste shipments that have been made to the burial site in Barnwell, South Carolina.

It identified the need to verify the quantity of Cs-137, Sr-90 and Pu-239 in the waste. As a result of a letter from the State of South Carolina to the NRC, dated December 7, 1979, a study of the radio-isotope content of the licensee's waste was undertaken by NRC Region I. The results of this study, which included quantification of the Cs-137, Sr-90 and Pu-239 isotopes, was previously reported in Inspection Report No. 70-687/82-05. However, the concentrations of C-14, Tc-99, H-3 and I-129 in the waste were not verified during this study. In a letter dated May 21, 1985, the licensee stated that Union Carbide Corporation (now Cintichem), Sterling Forest Laboratory would have measurements 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.

Subsequent to Inspection No. 70-687/85-04, the licensee attempted to have these concentrations verified by two vendors, Science Applica-tions International Corporation and EAL Corporation. Each vendor indicated that it could not analyze the waste because of the high radioactivity level.

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the results of the NRC study (reported in Inspection Report No.

j 70-687/82-05) should be sufficient verification of the computerized distribution of radionuclide concentrations currently used by the licensee and previously used in the Brookhaven study. In addition, i because of the inherent difficulties encountered in analyzing their j waste, the licensee requested relief from the annual confirmatory

analysis specified in the Branch Technical Position. The inspector stated that NRC Region I could not grant the licensee the relief requested. The relief would have to be discussed with the NRC-NMSS, Waste Management Branch. The licensee stated that a letter would be

, written to NRC-NMSS stating its position on the required analytical verification required by 10 CFR Part 61 and annual analysis require-

! ments specified in the Branch Technical Position. This was identi-

{ fied as an Unresolved Item (UNR 86-01-08).

l Unresolved items are matters about which more inf;rmation is required

) in order to ascertain whether they are acceptable items, violations

! or deviations.

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10. Topaz Irradiations At the request of NRC-NMSS, the inspector examined the status of topaz gem i

stone irradiations conducted at the research reactor.

Irradiation of topaz was discussed during a Nuclear Safeguards Committee meeting held on October 9, 1985. The irradiation facility, activated on October 3,1985, included the installation of a cadmium shield to reduce neutron activation of impurities in the gems. No gems will be released to any customer with greater than exempt quantities of radioisotopes i unless the customer is licensed to handle the measured types and levels

{ of activity present. The licensee estimates that cooling times of at least six to nine months will be required prior to release of the gems for

, unrestricted use. The licensee's policy for release of the gems will be i

specified in a letter to each customer. The criteria for release identi-fied in a letter from the State of New York to Union Carbide Corporation, dated January 13, 1970, included a specific activity of less than 300 picocuries per gram of long lived nuclides, and an overall radiation i

reading of less than 0.25 mR/hr on each gem. The initial irradiations

' were performed on October 10, 1985 and, as of the date of this inspection, no gems were released for unrestricted use by the licensee.

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11. Inspector Accompaniment The inspector was accompanied during a portion of this inspection by Mr. A. W. Grella from NRC-IE. Mr. Grella assisted in the review of

licensee transportation activities and implementation of 10 CFR Part 61.

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12. Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 14, 1986. 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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