ML20235U454

Insp Rept 70-0687/89-01 on 890109-12.Violations Noted.Major Areas Inspected:Organization,Criticality Safety,Operations, Transportation & Actions Taken in Response to Confirmatory Action Ltr

ML20235U454
Person / Time
Site:	07000687
Issue date:	02/24/1989
From:	Pasciak W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20235U410	List: ML20235U407 ML20235U433 ML20235U454
References
70-0687-89-01, 70-687-89-1, CAL-88-15, NUDOCS 8903090203
Download: ML20235U454 (9)

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-687/89-01 Docket No.70-687 License No. SNM-639 Priority 1 Category UHBR Licensee: Cintichem, Incorporate _d P. O. Box 816 Tuxedo, New York 10987 Facility Name: Hot Laboratories Inspection At: Tuxedo, New York Inspection Conducted: January 9-12, 1989 Inspector:

J. Rot 11 roject Engineer 2h j

date Accompanied by: G. Comfort, Licensing Project Manager, NMSS Approved by: -

1. -? u YM '

W. J. Pa ak, Chief, Effluents Radiation Protecti Section, FRS&SB, DRSS /date/

Inspection Summary: Inspection on January 9-12, 1989 (Inspection Report No. 70-687/89-01)

Areas Inspected: Routine, unannounced inspection by one region-based inspector of: organization, criticality safety, operations, transportation and actions taken in response to a confirmatory action letter.

Results: Five violations were identified. Violations: failure to post a radiation area and a radioactive material storage area in accordance with 10 CFR 20.203 (paragraph 26); failure to post all the documents required by 10 CFR 21.6 (paragraph 2b); failure to follow contamination control requirements posted in accordance with Section 3.2.1.2 of the license application (paragraph 2.c); failure to analyze waste solutions to assure they meet the concentration limit of Section 4.2.5.2.a of the license application (paragraph 3b); failure to maintain documentation of the 7A Type A container e9030%$$N PDR f

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- tests on Model B-25-90-4' packages as required by 49 CFR 173.415 (paragraph 6a).

' The licensee also committed to complete the actions required by Item l' of the CAL dated June 30, 1988 by March 1, 1989 (paragraph 8). One unresolved item was identif.ied relating to the storage of waste containers (paragraph-3.c).

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DETAILS 1.0. Persons Contacted

• J. J. McGovern, Plant Manager

• L. C. Thelin, Staff Health Physicist

• J. Stewart, Supervisor, Health Physics

• T. Vaughn, Manager, Health, Safety and Environmental Affairs

• W. Ruzicka, Manager, Nuclear Operations J. Ditton, Health Physics Technician

• present at the exit interview 2.0 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. Housekeeping During examination 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 During examination of the facilities, the licensee determined at the request of the inspector, that the. radiation level within four feet-of the east entrance of the south charcoal filter bay was in excess of 20 millirem / hour and the area was not posted with Caution-Radia-tion Area signs. It was also noted that a new plastic shield had been installed into the QC Laboratory hood. This hood was located on the east side of the QC Laboratory on the lower level of the reactor-building. As a result of'this installation, that hood was no longer.

visibly posted with Caution-Radioactive Material signs even though the hood contained radioactive materials in excess of ten times 10 CFR 20, Appendix C quantities. Lack of the postings indicated above was identified as an apparent violation of the posting requirements specified in 10 CFR 20.203. Each area was properly posted prior to the end of this inspection (70-687/89-01-01).

While examining the bulletin board containing the postings required  !

by 10 CFR 19 and 21 located at the main entrance to the Hot Labora-tory / Reactor buildings, the inspector noted that all the documents required by 10 CFR 21.6 were not present in that Section 206 of the l

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4 Energy Reorganization Act of 1974 had apparently been removed from the bulletin board. This was identified as an apparent violation of 10 CFR 21.6 (70-687/89-01-02) which was corrected prior to the end of this inspection.

c. Contamination Control During a tour of the facility the inspector observed several instances of failure to follow posted contamination control requirements as follows:

--A sign posted at the Hot Cell Conveyor work station required operators in the area to wear shoe covers, safety glasses, labcoat, sleeve covers and gloves. The inspector observed an lll[\ ,

individual working in the area and he was not wearing sleeve covers. The inspector observed another individual walking through the conveyor work station area while wearing only shoe covers. On a third occasion, the inspector observed an indivi-dual handle potentially contaminated parts of the trash compactor, which was located in the conveyor work station area, without wearing gloves. These instances of failure to follow posted contamination control requirements were identified as an apparent violation of section 3.2.1.2 of the NRC-approved license application and the requirements of the Cintichem Radiation / General Safety Manual (70-687/89-01-03).

--The inspector also observed that containers, located at change lines and used for the disposal of potentially contaminated items (gloves, shoe covers, etc.), were equipped with flip tops.

Personnel disposing of these items could contaminate their hands while placing these contaminated items into the container by inadvertently touching the potentially contaminated flip top.

This was discussed with licensee representatives who indicated that the flip tops would be removed from these disposal containers.

d. Storage of Non-radioactive Materials

--During examination of the machine shop, the inspector observed that four five gallon containers of trichloromethane were being stored in the area. These containers were not protected from l possible damage from puncture hazards. Since trichoroethane was identified as a non-radioactive hazardous material, the licensee indicated that the containers would be moved from the machine shop and would be properly protected from potential damage.

--The inspector observed that approximately one dozen containers of flammable spray paint and penetrating oil were improperly stored above the offices on the reactor third floor level.

Licensee representatives stated that the storage of these

5 flammable materials in this area would be re-evaluated and these ,

materials would be either removed from the area or stored in proper storage cabinets as required.

--The inspector also observed that large quantities of combustible materials (paper and plastics) were being stored on top of ventilation system ducts over the reactor building third floor Quality Control laboratory. Licensee representatives I

acknowledged that storage of combustibles in this area was poor practice and indicated that these materials would be removed and properly stored.

e. Water Fountains During examination of the facilities, the inspector observed the presence of two water fountains in potentially contaminated areas, one was located in the hot cell operating area and the other was located on the third level of the reactor building.

The use of these water fountains in potentially contaminated areas was identified by the inspector as a poor practice.

Subsequent to this inspection, the inspector was notified by licensee representatives that these water fountains were being moved into contamination free areas of the facilities.

3.0 Nuclear Criticality 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 authorized by the facility licenses.

b. Unmeasured Solutions of Uranium -

During examination of the Hot Cell No. 4 isotope processing opera-tion, the inspector observed several bottles of raw fission waste and Mo-99 precipitate acid washes which did not contain Raschig rings.

Upon questioning of the licensee, the inspector determined that these acid washes were not routinely measured to determine the uranium-235 content. Section 4.2.5.2.a of the NRC-approved license application limits the concentration of U-235 in these bottle to less that 0.250 gms/ml. Failure to analyze these waste solutions to assure that they meet the concentration limit specified in Section 4.2.5.2.a of the license application was identified as an apparent violation (70-687/89-01-04). At the request of the inspector the solutions were analyzed by the licensee and were found to contain up to 4 grams of U-235 per liter of solution,

c. Storage of Uranium-235 in the Gamma Pit During examination of .the Gamma Pit located at the Hot Cell end of the canal from the reactor facility, the inspector observed that the l -m.

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6 NRC authorized array of waste storage containers was full and that there was another array of spent reactor fuel assemblies located within four feet of the array of full waste storage containers. The second array was found to be non-coplanar with the first array. Upon l identification of this condition the licensee immediately separated the two arrays even farther (by about 20 feet). Through subsequent investigation, the licensee provided the inspector with evaluations that showed that each individual array, was safe. However, no evaluation was found which specifically indicated that each array would not interact with each other under the storage conditions l identified. As a result, it is necessary that the licensee evaluate the criticality safety of the arrays. including interactions between the arrays, under the specific storage conditions. The results of this assessment and its supporting data should be supplied to NRC, Region I. Pending completion of this assessment this was identified as an unresolved item (70-687/89-01-05).

d. Criticality Monitor Calibration Through examination of licensee records, the inspector determined that the criticality monitors, located throughout the facilities, had been calibrated as required between March 1986 and May 1988. No inadequacies were identified.

4. Safety Committees

a. Nuclear Safeguards Committee The inspector examined the records of ten meetings (Nos. 129-138) of the Nuclear Safeguards Committee held between August 19, 1987 and October 17, 1988. Review actions and recommendations made by the committee were generally adequately documented. Included in these records were supporting documents used by the committee to develop the recommendations. In addition, implementation of these recommendations was adequately documented in the committee minutes.

During examination of the meeting minutes, the inspector determined that the safety committee, during meeting 130 (August 20,1987),

approved a handwritten procedure which contained no detailed steps.

This procedure did not contain sufficient information to allow the operation (an experiment to be run in the reactor) to be conducted without further instructions from management. Approval of handwritten cryptic procedures was identified as a poor practice by the inspector. Licensee representatives stated that this had also been identified during a previous internal audit and actions had been taken to correct this poor practice.

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b. General Safecy Committee The inspector examined the records of six meetings of the General Safety Committee held between February 24, 1988 and December 21, 1988. 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. The inspector noted that during the meeting held on October 26, 1988, installation of a washer and dryer to clean contaminated protective clothing was discussed.

The inspector stated that th's installation should be discussed with NRC to determine if a license amendment will be needed to authorize this new operation. Licensee representatives stated that installa-tion of the washer and dryer would be discussed with NRC prior to installation and use.

5. 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.

6. Transportation Activities

a. Shipping Records The inspector examined records of uranium waste, reclaimed uranium LSA waste and spent fuel shipments made from February 26, 1988 to December 14, 1988. The inspector determined that radiation surveys were conducted and recorded, and all shipments were labeled, marked, placarded, inspected, and recorded, as required.

The inspector requested a copy of the 7A Type A package test results for the B-25-90-4 Type A container. Licensee representatives did not have the test results in their possession. This was identified as an apparent violation of 49 CFR 173.415(a) which requires maintenance of complete documentation of the tests and an engineering evaluation for one year following the latest shipment using this package. This apparent violation was corrected prior to the end of this inspection (70-687/89-01-06),

b. Packaging Tests The inspector determined through a review of licensee records that the routine quarterly, semiannual and annual tests required by the Certificates of Compliance for the Model B-3 and Model BMI-1 casks were conducted during 1986, 1987 and 1988 as required.

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7. Waste Storage Building During' Inspection No. 70-687/88-05, the inspector conducted a radiation-survey on the outside surface of the waste storage 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). During that inspection,-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, 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 (70-687/88-05-01).

In response to that apparent violation the licensee stated that "As an improvement in our site security program, Cintichem is in the process of securing our site grounds by fencing off the north and south sides of our.

property to reasonably control the potential of an individual gaining access to our restricted areas". No date was provided for completion of this action. Subsequent to that response dated September 14, 1988, the licensee decided not to secure the site grounds by fencing on the north side. The inspector was informed during this inspection that the corrective actions had been dropped. No new corrective actions were proposed to the inspector. This item will be reviewed during a future inspection. (70-687/89-01-07).

8. Confirmatory Action Letter No. 88-15 During this inspection, the inspector reviewed the licensee's actions with regard to the. commitments made in Confirmatory Action Letter No. 88-15, dated June 30, 1988. As a result of that review the inspector determined that the licensee has written but has not approved the effluent monitoring procedures required by Item No. 1. In the licensee's original response to the CAL there was not a commitment date for this item. However, during this inspection, the licensee committed to completion of the Item No. I requirements by March 1, 1989. Installation of the system exhaust ductwork into the pre-existing monitored main stack effluent discharge pathway was also expected to be completed by March 1, 1989.

9. Inspector Accompaniment The NRC Region I inspector was accompanied during this inspection by Mr. l G. Comfort from NRC-NMSS. Mr. Comfort assisted in the review of licensed  !

activities.

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10. Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at ti'e conclusion of' the inspection on January 12, 1989. The inspector summarized the scope of the inspection and the' findings. As stated in

. paragraph 8, the licensee committed to completing the actions specified in.

Item 1 of the Confirmatory Action Letter No. 88-15, dated June 30, 1988, by Me.rch 1, 1989.

At no time during this inspection was written material provided to the

-licensee by the' inspector.

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