NRC Generic Letter 1981-34

NRC Generic Letter 1981-034: Safety Concerns Associated with Pipe Breaks in the BWR Scram System

ML031110042
Person / Time
Issue date:	08/31/1981
From:	Eisenhut D G Office of Nuclear Reactor Regulation
To:
References
GL-81-034, NUDOCS 8110150121
Download: ML031110042 (2)

e I 1 IT39iXAven tisAventis PasteurApril 7, 2003US Nuclear Regulatory CommissionRegion 1475 Allendale RoadKing of Prussia, PA 19406Attn: Ms. Judith Joustrare: Inspection response, Byproduct Material License Number 37-17938-01,Docket Number 030-13723Dear Ms. Joustra:This is in response to your additional questions regarding the termination of activities in formerly usedrooms and buildings.With respect to disposal via the sanitary sewers, the Swiftwater Aventis site and its predecessor,Connaught Laboratories had a policy of not disposing any form of waste (radioactive, biological, orchemical) via the sanitary sewers. This was a policy based on the fact that the facility had its owntreatment plant that discharged into the creek running through the property and did not want to introduceany hazardous materials into the stream, even in permitted quantities.Building 2:Three rooms were listed in NRC files: 103, 104 and 108. Room 103 is a general lab inwhich a small corner was sectioned off and labeled as Room 104. A small bench-toplaminar flow hood, rated for biological preparations, was used in 103/104 for incubatingand drying antigen preparations. The hood was later moved to room 108, adjacent to 103and the walls enclosing 104 were removed creating a single rectangular 103. This hoodnever had a water supply or a drain. All radiological samples were prepared in Building 4and sealed vials were carried to the adjacent Building 2. The sealed vials were placed in theincubator in the hood. Following drying, the sealed vials were returned to Building 4 foranalysis. The only radioactive materials used in this building were tritium and chlorine 36.The hood was last used on February 9, 2002 according to lab notebook entries. It was onour routine monthly wipe SOP and was last wiped on March 27, 2002. No contaminationwas found (62 dpm/100 cm2 compared to a blank of 65 dpm/100 cm2). Wipe analyses weremade in one of the liquid scintillation counters which have a 50 percent efficiency. A copyof the last wipe results was submitted in our October 10, 2002 response. On February 25,2003 wipes were taken of the hood and its exhaust. The hood interior again showed non-detectable removable radiological contamination (123 dpm compared to a blank of 108dpm). The exhaust vents also showed non-detectable removable radiological contamination(114 dpm compared to a blank of 108 dpm). Based on the historical lack of contamination,this hood and room was removed from our wipe testing SOPs and is considered acceptablefor release for unrestricted (radiological) uses.t23~S!wNI MATERIALS W2Aventis Pasteur Inc Discovery Drive* Swiftwater PA 18370-0187 www.aventis.comTelephone 570-839-7187 Aventis Pasteur Aven tisBuilding 6: Rooms 1 IA was a small room that contained a single counter. Sealed samples werecarried from the preparation labs and placed in the counter for analysis. The counter andbench top were routinely wiped and had a history of not showing detectable radioactivecontamination. Room 11 OB was a small room in which a freezer and refrigerator werelocated. These were not the primary freezer and refrigerator for radiological storage in thisbuilding and were used only in the case of excess samples or radioactive supplies. Theywere on the routine wipe schedule and had a history of not showing detectable radioactivecontamination. No preparations were performed in these two areas.Building 38:(former waste storage room): There were actually two Building 38 designations and thewaste storage rooms in both were designated Room 126. Neither room had floor drains.We have no information of a Room 116 being associated with radioactive materials. Theold Building 38 was attached to Building 37, a manufacturing building. This Building 38housed a spare parts warehouse, some offices, and a storage room (126) used by theenvironmental people for storage of hazardous waste prior to shipment. Radioactive wasteheld for decay (iodine 125) and waste packaged for disposal were also stored in this room.There is a Room 116 in this building but it is a women's rest room in the center of thebuilding, well removed from Room 126. Sometime in late 1998 or early 1999 time frame, anew Building 38 was constructed to house the warehouse and all waste handling (hazardousand non-hazardous) and a new Room 126 was constructed to house both radioactive andother hazardous waste prior to shipment. The storage rooms in both buildings, had bareconcrete floors and epoxy coated concrete block walls. The radioactive waste was stored inplastic lined steel drums placed in "bathtub pallets" (the same pallets were used in bothbuildings). Both buildings were included in the routine wipe tests and had a history of notshowing significant removable contamination. We cannot locate data from the old Building38; however, there is no recollection that radiological contamination was ever found. Acopy of the termination survey wipe results for the new Building 38 was submitted in ourOctober 10, 2002 response. The analyses of wipes were made on the same liquidscintillation counter described for Building 2 and has a 50% efficiency. The areacomprising the former Building 38 now houses a vaccine packaging line and all surfacesare new. Wipes were made on February 25, 2003 of the floor and the empty pallets whichare still present in the new Building 38 waste storage room. A low area on the floor waswiped and showed a net activity of 288 dpm and the pallets had net activities of 69, 76 and64 dpm compared to the blank (108 dpm). The wipes were below the action level of 500dpm and this room was released for unrestricted use.Should there be any questions regarding the application, please contact me at (570) 839-5651 or Mr.LaMastra at (610) 756-4153.Sincerely,John J. Podczasy, Ph.D.Platform Leader, Clinical Immunology2