ML20245L389

Responds to NRC Re Violations Noted in Insp Rept 50-054/88-03.Corrective Actions:Policy Manual on Contamination Control Prepared & Will Be Distributed to Employees Routinely Working in Controlled Areas

ML20245L389
Person / Time
Site:	05000054
Issue date:	04/28/1989
From:	Mcgovern J CINTICHEM, INC.
To:	Wenzinger E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8905080023
Download: ML20245L389 (5)

Text

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e CINTICHEM, INC.

a wholly owned subsidiary of Medi-Physics, Inc. P.O. BOX 818, TUXEDO, NEW YORK 10987 [914] 351-2131 April 28, 1989 U.S. Nuclear Regulatory Commission Region 1 475 Allendale Road King of Prussia, PA 19406 Attention: Mr. E. Wenzinger, Branch Chief Division of Reactor Projects

SUBJECT:

U.S. NRC. Region I Letter dated January 3, 1989 pertaining to Inspection 50-54/88-03 '

I This letter is submitted in preparation for our scheduled meeting at your offices on May 11, 1989. It presents actions we have taken or plan to take regarding three of the five general issues mentioned in your above referenced letter; namely, the Nuclear Safeguards Committee's responsibilities, the contamination 1 control program, and the response to the CAL of June 30, 1988. I We would like to discuss the remaining two items in order to have a clear understanding of the NRC's expectations on the issues before we can adequately respond.

Cintichem management has been aware of improvements that could be made to certain operations and physical facilities. P.t oj e cts have been initiated for evaluating appropriate corrective measures, budgeting and final implementation for planned improvements. Where measures were required to correct deficiencies with regard to regulatory or license requirements, corrective measures were accelerated, by-passing the normal planning and budgeting process.

A brief report on the status of our progress to date follows:

o Nuclear Safeguards Committee (NSC) Responsibilities

a. The charter of the NSC is defined in both the R-81 and SNM-639 licenses. The NSC's responsibility under each license was reviewed with all members and operating groups at the facility during the third quarter of 1988. During the fourth quarter of last year a guideline for preparing and reviewing submissions to the NSC to provide assurance that reviews are complete with regard to safety was initiated.

This guideline was drawn from former NSC proceedings and a review of current operational requirements. It is intended that this guideline be an active working document of the committee to be revised according to concomitant experience.

. JJM/73.89B 8905080023 890428

{DR ADOCK 03000054 PDC /\

< USNRC INSPECTION 50-54/88-03 i

-APRIL 28, 1989 PAGE 2 1

o Nuclear Safeguards Committee (NSC) Responsibilities (continued) 1

b. A new audit program has been initiated whereby proposals have been solicited from individuals and organizations outside of the Cintichem and Medi-Physics organization who are dedicated to performing audits in the various technical areas where audits are required either by license condition or by internal corporate policy. A draf t charter has been written for the proposed Audit Committee. Interviews of j candidates will have been completed in June. All 1989 -

audits will be conducted by new auditors in the following areas:

o Reactor Operations, Operator Requalifications o Radiation Health and Safety / Environmental Surveillance o Hot Lab Operations o SNM Measurement QA o SNM MCA o SNM Criticality Safety o Security o Packaging QA Individual audit reports will be submitted to Cintichem and Medi-Physics top management as well as to the NSC. A consolidated annual summary report will be prepared by the Audit Committee to recommend programmatic changes as deemed necessary or advisable.

o Contamination Control (Program Changes)

a. There has been an ongoing program for more than a year to remove unnecessary equipment and stores from the Reactor and Hot Laboratory buildings to improve our ability for routine cleaning. As an adjunct of this program we have decided to remove from these buildings certain operations associated with radiochemical manufacturing and facility operations that do not involve work with radioactive materials. These clean out programs are more than 50% completed. Final completion is scheduled for mid-summer.

b. A survey of all operations within the Reactor and Hot i Laboratory was conducted by Health Physics and functional operating groups to identify common sources of l

contamination. Several permanent controlled areas were established to improve control on these contamination sources. This is an ongoing program with the objective of improving processes and facilities so that the number of permanent controlled areas would be minimized or eliminated entirely.

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, USNRC INSPECTION 50-54/88-03 APRIL 28, 1989 PAGE 3 o Contamination Control (Program Changes) (continued)

c. The janitorial staff for the Reactor and Hot Laboratory buildings was increased last year and a routine preventative '

cleaning program was established which concentrates on those areas that have high risk for contamination. This is a continuing program that will be continually adjusted according to changing conditions,

d. Management has been conducting more frequent audits of routine operations to assure compliance with procedures and to identify potential improvements in operations particularly with regard to improving contamination control.

Frequent checks of personnel frisking procedures by managers ,

and supervisors have been conducted to assure that employees  !

comply with internal regulations.

e. Weekly tours of the Reactor and Hot Laboratory by the Plant Manager have been conducted over the past two months to monitor progress of program improvements and identify potential added improvements.

f. Random audits of operations by Health Physics to assure compliance with health and safety SOP's and RWP's have been initiated.

g. Specific refresher training of personnel was conducted at the Hot Cell conveyor station as follows:  ;

1. Routine for sending process materials into the Hot Cell. j

2. Routine for removing product from the hot cells for packaging and shipment.

3. Routine for removing samples of product from the hot cells for quality control assay.

4. Routine for cleaning contaminated areas by janitorial staff.

h. A policy manual on contamination control has been prepared i that will be distribt:ted among all employees who routinely I work in controlled arecs witb the objective of all pertinent personnel acknowledging thcj : understanding and acceptance of policies regarding responsibilities, limits, corrective actions and preventative actions regarding contamination control. This program should be promulgated by June 30,  !

1989.

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JJM/73.89B l

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USNRC INSPECTION 50-54/88-03 l

A#RIL 28, 1989 I

PAGE 4 i o Contamination Control (Facility Changes) l

, a. A master-slave manipulator repair facility has been planned l and funds have been provided in the 1989 budget. The design objectives include:

1. Easier decontamination 1

l 2. Better ventilation

3. More convenient working conditions

4. Less interference with other operations in the Hot Laboratory

5. Less radiation exposure to personnel This project was started during the fourth quarter of 1988.

It is an integral part of a general Hot Lab facilities improvement program in which several projects are interrelated. The overall project schedule should be completed by the end of May. The rate limiting step in this part of the program will probably be the exhaust ventilation changes that are anticipated.

b. A segregated area will be constructed in the Hot Laboratory for processing Class A Waste. This area will include facilities for compacting sclids, solidifying liquids, and decontaminating shipping and storage containers. This area Will also include facilities for janitorial equipment. The design is still conceptual. Firm plans will start in May.

Installation will be coordinated closely with the manipulator repair area because of common ventilation requirements.

c. The contaminated liquid waste treatment system will be improved as follows:

1. Increase evaporator capacity

2. Increase contaminated waste water storage capacity.

Funds have been approved for expenditure in 1989. The work in Step 1 is about 50% complete, while design has just started in Step 2. Completion will be scheduled in conjunction with other projects included in this Hot Lab facilities improvement program. J JJM/73.89B I

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. USNRC INSPECTION 50-54/88-03

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'AbRIL 28,1989 PAGE 5 o Contamination Control (Facility Changes) (continued)

d. The physical layout of personnel frisking and clothing change facilities is being reviewed with the objective of rearranging these facilities to facilitate the movement of people in and out of the facility so that cross-contamination can be controlled' progressively. A new layout of the personnel clothing change facilities, shower and sanitation facilities and interim personnel frisking ,

facilities has been completed. Feasibility of the '

mechanical and electrical modifications that would be necessary are ongoing. Local Planning Board approval of a small building extension may be required prior to completion of this design. This project will be incorporated in the aforementioned facility modification program and schedule.

The general plan for all of these facility modifications is as follows:

1. Project Definition Completed

2. Capital Funds Approval June 30, 1989

3. Incremental Schedule June 30,1989

4. Final Design July 31, 1989

5. Site Plan Approval August 31, 1989

~(if required)

6. Procurement December 31, 1989

7. Completion To be determined per the incremental schedule o 6/30/88 Confirmatory Action Letter The action items contained in the letter were completed on j schedule. The modifications to the exhaust fan which included i ducting to the main effluent stack and automatic monitoring j while the system is actuered were fully operational in the l first quarter of 1989. J

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We are looking forward to our meeting on May lith. Please let me )

know if you would 11:e additional information for the meeting. l f Sincerely,

/ \

'/A YA k ,

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'J. J./McGovern Plant Manager c .hflamy,NRC-KingofPrussia, PA Document Control Desk, Washington DC

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