ML20206T019

Responds to Violation Noted in Insp Rept 70-0687/86-02. Corrective Actions:Technician Counseled Re Posting of Correct Amount of U-235 Stored in Feed Cabinet 4

ML20206T019
Person / Time
Site:	05000054, 07000687
Issue date:	05/29/1986
From:	Thelin CINTICHEM, INC.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20206T016	List: IR 05000054/1986001 ML20206T019
References
NUDOCS 8609230078
Download: ML20206T019 (3)

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~ l CINTICHEM, INC.

e wholly owned subsidiary of Medi-Physics, Inc. P.O. BOX 818. rWXEDO NEW YORK 10987 [9141 351-2131 May 29, 1986 l U. S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19706 Attention: Thomas T. Martin, Director

SUBJECT:

Inspection No. 70-687/86-01 License SNH-639 Gentlemen:

This is our reply to your routine safety inspection report for an inspection of this f acil Ity conducted by Mr. Jerry Roth on February 10-14, 1986. We have Iisted our responses in the order that they are lIsted in l Appendix A of that report. Also included is the violation as sent.

A. Section 4.1.5, " Posting Requirements," of Part 1 (criteria) of your NRC-approved lIcense appiIcation, dated July 16, 1984, states, in part, that the current inventory shalI be posted in areas where SNM is used or stored.

Contrary to the above, on Februahy 10, 1986, the current inventory was not posted on Feed Cabinet No. 4 in that the inventory log for the feed cabinet Indicated that 319 grams of U-235 were stored in the cabinet, and the cabinet was empty.

For some period of time on February 10, 1986, the Inventory of Feed Cabinet No. 4 was over estimated by 319 grams. The technician removed 319 grams of U-235 in oxide form to the solution make-up lab and made a 319 gram addition to the lab inventory log book. He dissolved the uranium with acid and moved the solution back to Feed Cabinet #4. Finally, he logged out 319 grams from the solution make-up isb.

For the period of time that the uranium was in the solution make-up lab, the posting on Feed Cabinet #4 was over estimated. Although his error was a conservative one and actually restricted material from an already empty cabinet, it was an incorrect posting.

Therefore, we have reinstructed the technician in the requirement for correct postings. Although thero was no criticality safety issue in this instance, we have emphasized the importance of updated postings to criticality safety. We ,

believe that this error will not occur again.

B. Section 3.2.5.5, " Fire Protection," Part 1 (criteria) of your NRC-approved iIcense application, dated June 6,1984, states that no loose combustibles are stored in the fan room.

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Contrary to the above, on February 10, 1986, loose combustibles consisting of several sheets of plywood and packaging material were found stored in the supply fan room by the inspector.

There were approximately three sheets of plywood temporarily placed in the intake f an room of buildings 1 and 2. Although we agree that it is not good practice to store combustibles in a non-sprinkled area, we note that this was temporary storage. The plywood was put there just to get it out of the way before disposal. As noted in your report, it was removed immediately after the inspector discovered the problem.

Our Intent in writing the license requirement had actually been to limit combustibles in the exhaust fan room located on the first floor of the hot lab. The exhaust fans are a more important safety feature than the intake fans. An exhaust fan fire would more adversely affect the safe operation of the facIIIty.

Regardless, we have placed a "NO C0060STIBLES" sign at the entrance to each fan room. We believe this will prevent a recurrence of storage of plywood in these areas.

C. Section 3.2.3.2, " Instrumentation," of Part 1 (criteria) of your NRC-approved iIcense appiIcation, dated June 6, 1984, states that calibrated alpha survey instruments shalI be made available to employees ~ working with unencapsulated, unirradiated special nuclear material. Section 3.2.3.9 specifies the calibration frequency for survey Instrumentr, as three months (not exceeding 4 months).

Contrary to the above, between July 31, 1984 and January 10, 1986, al pha survey instruments were calibrated every nine months which is in excess of the required calibration frequency.

We note that the particular portable alpha survey meter used to measure uranium target surface contamination levels is calibrated approximately once per week. All other portable alpha survey meters have traditionally been calibrated once per year. The yearly schedule is justifiable since these 4

meters are only used to detect contamination rather than measure it, if alpha skin contamination Is noted by an employee wIth one of these meters, he calIs Health Physics to make a quantitative evaluation. Regardless, we will change to a quarter 1y schedule.

I in the switch over to the "new" SDSH39 license (July 16, 1984), the quarterly requirement was overlooked. In order to prevent a recurrence we have placed portable alpha meters on a quarterly cal!bration frequency. We have included the alpha instrument calibration check sheets in the same log book as those other Instruments presently on a quarterly calibration schedule. As of this date, the portable alpha meters are on the new schedule and will remain so.

D. Section 2.5, " Personnel Education and Evperience Requirements," of Part 1 (criteria) of your NRC-approved license application, dated June 6,1984, states, in part, that the minimum complement of I ine and staf f management personnel is shown in Figure 2.1. Position titles are as follows: Site Manager, Nuclear Operations Manager, Heal th, Safety and Environmental Af f airs Manager, Radiochemical Production Manager, Reactor Supervisor,

Facility Services Engineer, Reactor Project Engineer and Health Physics Supervisor include a B.S. Degree in science or physics and at least five years experience in radiological health and safety. Reporting to the Site Manger is the Nuclear Safeguards Committee.

Contrary to the above, on February 14, 1986, the inspector found that between November 1,1985 and February 14, 1986, the minimum complement of IIne and staf f management personnel did not correspond to Figure 2.1 in that the organization no longer included the position of Manager, Health, Safety and Env ironmental Affairs, a new position of Radiation Safety Officer had been established, the incumbent Health Physics Supervisor did not have a B.S. degree in science or physics and the Nuclear Safeguards Committee no longer reported to the Site Manager.

There really is no problem here. We have the same staff as we have always had in recent years. The new titles just do not match up with the titles in the license application. Functionally, the Figure 2.1 organization chart retains its personnel as follows:

Site Manger - Jaeos McGovern Manager Health, Safety, and Environmental Af fairs - Cliff Konnerth Health Physics Supervisor - Lowell Thelin We will,however, make appropriate changes in our next license revision.

Should you have any questions on our reply, please contact me at (914) 351-2131 extension 258.

Y y truly yours,

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Lowell C. Thel in Radiation Safety Officer LCTimag l

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CINTICHEM, INC.

o whoey owned - W of Mecfi-Physics, Inc. p.a. sox e,s. Tuxeoo. New vonx ,osev Is,41 as,.e,3, May 13, 1986 Mr. Thomas T. Martin Division of Radiation Saf ety and Safeguards United States Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

The folIorIng 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.

APPE21X A - ITEM A in our Fundamental Nuctear Material Control Pian we have four specific Material Bal ance Areas. These were selected based on functional responsibiiIty for the matertal durIng our process. The specific arcas chosen were:

EA #1 All activities with the incoming feed material.

MA #2 All activities involved in preparing a target.

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

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

The material ref erred 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 food cabinet. The EA #1 Custodian has always been responsible for this l 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 belleve that our procedure for handling this part of our process is in agreemer.t with our approved FlWC plan. Since there was no transfer out of MA #1, there was no need for an internal transaction report.

Our program has several areas where material from different EAs may exist in the same physical area. The criticality 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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m. W APPEWlX A - ITEM B The ten barrels of low level 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 reanalyzed. 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 bef ore they are submitted for analyses. If a drum has to be repackaged, we will void the original seal and reseal it immediately af ter canpletion of a second analysis. We believe that with this change in procedure, we are currently in compl iance with Paragraph 2b.

APPEmlX A - ITEM C The three low l evel waste t arrels identified in this alleged violation were not normal waste barrels 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 believe that this procedure is a violation of Section 4.2.1.4.f. of our FNMC plan.

b APPEmiX,A - ITEM A (a, b W )

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 will be lef t with the receptionist. In spite of the f act that we no longer have a receptionist in Bullding 2, we do have a receptionist for the entire site who signs in alI yIsitors and fulfIlIs the requirement of this section. It is our .

contention that no change to our Physical Security Plan was necessary because "

of the retirement of our Building 2 receptionist.

The reorganization on November 1, 1985 resulted in changes to some job titles but only one change in personnel fili Ing these positions. We wIII submit a revised organizational chart within 60 days of your response to this l etter. We request this time period so that we can include any other minor changes that may be necessary to update our plan.

APPEElX 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 ciearly document compilance we have dedicated a section of our visitor log book to keep track of package entry into co'ntrolled access areas.

APPE m iX 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 abt e to document f ulI compi Iance wIth SectIon 4.4.

This combined inspection was conducted at the same time as inspection number 70-687/86-01. Although we appreclate all ef forts made to improve our programs, we feel that with our limited staff it woufd be more ef fective if you could avoid scheduling three inspections at the same time. We believe that if we had been able to spend more time explaining our program to the inspector, we could have el lainated some of these Items.

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

Very truly yours, A ..

. J. Konnerth Manager, Site Operations CJK amag cc: D. Grogan J. McGovern W. Ruzicka L. Thelin e

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