IR 07100958/2023201
| ML23325A047 | |
| Person / Time | |
|---|---|
| Site: | 07100958 |
| Issue date: | 12/01/2023 |
| From: | Aida Rivera-Varona Division of Fuel Management |
| To: | Davis S US Dept of Defense, Defense Threat Reduction Agency |
| Jeremy Tapp, NMSS/IOB 415-8047 | |
| References | |
| EA-18-046 IR 2023201 | |
| Download: ML23325A047 (9) | |
Text
December 1, 2023
SUBJECT:
DEFENSE THREAT REDUCTION AGENCY - U.S. NUCLEAR REGULATORY COMMISSION INSPECTION REPORT NO. 710958/2023201
Dear Sherry Davis:
On October 17, 2023, the U.S. Nuclear Regulatory Commission (NRC) staff conducted an announced onsite inspection at the Defense Threat Reduction Agency (DTRA) facility in Fort Belvoir, Virginia. The purpose of the inspection was to verify and assess the adequacy of DTRAs activities associated with the transportation of radioactive material to determine if they were performed in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of Radioactive Material, and DTRAs NRC-approved quality assurance program (QAP). The inspection scope was focused primarily on the review of corrective actions from the Severity Level III Notice of Violation from a previous inspection conducted from April 17-19, 2018.
The inspection examined activities conducted under your NRC-approved QAP as they relate to public health and safety, and to confirm compliance with the Commissions rules and regulations. Within these areas, the inspection consisted of selected examination of procedures and representative records and interviews with personnel. The enclosed report presents the results of this inspection.
No violations of more than minor significance were identified during this inspection. In accordance with 10 CFR 2.390, Public inspections, exemptions, requests for withholding, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRCs ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.gov or call 1800-3974209 or 301415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays.
Sincerely, Signed by Rivera-Varona, Aida on 12/01/23 Aida Rivera-Varona, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 710958
Enclosure:
Inspection Report No. 710958/2023201
Inspection Report
Docket No.: 710958 Report No.: 710958/2023201 Enterprise Identifier: I20232010056 Licensee: Defense Threat Reduction Agency Facility: Defense Threat Reduction Center Location: Ft. Belvoir, VA Inspection Date: October 17, 2023 Inspectors: Jeremy Tapp, Transportation and Storage Safety Inspector, Team Leader Raju Patel, Transportation and Storage Safety Inspector Tomeka Terry, Project Manager (Observer)
Approved by: Aida Rivera-Varona, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Enclosure
U.S. NUCLEAR REGULATORY COMMISSION Office of Nuclear Material Safety and Safeguards Division of Fuel Management
EXECUTIVE SUMMARY
Defense Threat Reduction Agency
NRC Inspection Report 710958/2023201 This limited scope follow-up inspection performed at the Defense Threat Reduction Agency (DTRA) facility in Ft. Belvoir, Virginia on October 17, 2023, evaluated the corrective actions taken for the Severity Level (SL) III Notice of Violation (NOV) from a previous U.S. Nuclear Regulatory Commission (NRC) inspection conducted April 17-19, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML18152A558 and ML18187A225). The focus of the inspection was to determine whether DTRAs corrective action activities were in accordance with commitments and requirements specified in DTRAs June 29, 2023, response to apparent violations in inspection report no. 710958/2018201 letter to the NRC (ADAMS Accession No. ML23292A240), NRC-approved quality assurance program (QAP)for transportation of radioactive material, and Title 10 of the Code of Federal Regulations (10 CFR) Part 71.
Management Controls The team concluded that DTRA took effective corrective actions in response to the SL III NOV and developed adequate procedures to implement their 10 CFR Part 71 QAP.
REPORT DETAILS
1. Management Controls
1.1 Corrective Actions Controls
a. Inspection Scope
The team reviewed selected records and interviewed personnel to verify that DTRA performed adequate corrective actions in accordance with the NRC-approved QAP and the requirements of 10 CFR Part 71. Specifically, the team reviewed DTRAs NRC-approved QAP, DTRAI 4540.01, Quality Assurance Program for Shipping Special Nuclear Material, dated February 7, 2023, and letter dated June 29, 2023, which contained DTRAs completed corrective actions in response to the SL III NOV as discussed in NRCs previous inspection report (IR) no. 710958/2018201. The team verified the completed corrective actions as discussed in the June 29, 2023, letter was consistent with the corrective actions described in IR 710958/2018201 and adequate to resolve the issues. The team reviewed the supporting documentation for each of the completed corrective actions and interviewed personnel to verify proper implementation and understanding.
The team reviewed the following implementing procedures for each required aspect of the QAP to determine if they were adequate to implement each QAP requirement:
- QAP2SOP001, Quality Assurance Program Level II Standard Operating Procedure, version 2
- QAP3SOP001, Quality Assurance Program Standard Operating Procedure for Control of Measuring and Test Equipment, version 0
- QAP3SOP002, Quality Assurance Program Standard Operating Procedure for Inspection of New or Repaired Shipping Containers, version 3
- QAP3SOP005, Quality Assurance Program Standard Operating Procedure for Shipping 25 kg Highly Enriched Uranium Equivalent Radiation Signature Training Devices, version 1
- QAP3SOP007, Quality Assurance Program Standard Operating Procedure for Shipping 2.5 kg Highly Enriched Uranium Equivalent Radiation Signature Training Devices, version 1
- QAP3SOP009, Quality Assurance Program Standard Operating Procedure for Conducting Program Audits, version 0
- DTRA-QAP3010 SOP, Quality Assurance Program Standard Operating Procedure for Conducting Quality Control Technician and Quality Assurance Inspector Training and Qualification Course, version 0
- DTRA-QAP3SOP012, Quality Assurance Program Standard Operating Procedure for Personnel Qualification, version 0
- DTRA-QAP3013 SOP, Quality Assurance Program (QAP) Standard Operating Procedure (SOP) Sharepoint Operations, version 1.0
- DTRA-QAP3016 SOP, Quality Assurance Program (QAP) Standard Operating Procedure (SOP) for Administrative Controls, version 0
- QAP-QT004, Skolnik CQ0502Q 5 Gal Drum Info, revision 0 The team reviewed the training and qualifications for a selection of DTRA personnel that perform QAP related work, along with the training and qualification program for its adequacy and conformance to the quality procedure requirements. The team also reviewed the training and qualifications of a DTRA lead auditor and verified attendance at an American Society of Mechanical Engineers Nuclear Quality Assurance lead auditor training course. The team reviewed DTRAs audit program to determine if DTRA scheduled, planned, and performed internal audits in accordance with their QAP. The team selected the last internal audit performed for review and discussed the internal audit schedule with DTRA personnel.
The team also reviewed DTRAs implementation of their nonconformance program and corrective action program (CAP). The team requested a list of nonconformance reports and corrective actions for review. No nonconformances have been generated since implementation of the QAP resumed in June 2023. A list of corrective actions related to current QAP issues was reviewed for conformance with quality procedures and adequacy and timeliness of corrective actions.
In addition, since DTRA performed its first shipment under the QAP in September 2023, the team toured the areas designated for storage and handling of shipping containers at the Ft. Belvoir facility. The team verified the shipping containers were stored in the proper location and marked or labeled as appropriate, depending on their approval status for use. A sample of shipping containers were observed to look for damage and defects. The team also reviewed the completed shipment documentation to determine if the documentation was adequately completed and met all applicable QAP requirements.
b. Observations and Findings
The team noted that DTRAs corrective actions in response to the SL III NOV were adequate and completed before implementation of the QAP resumed and a shipment was performed in September 2023. The CAP was found to be adequate and tracks issues to completion. The team found the shipping containers adequately stored, labeled, and segregated as required based on their approval status for use. For the sample of shipping containers observed for damage and defects, no issues were identified. In addition, the team determined that the shipment documentation reviewed was completed adequately.
No findings of significance were identified.
c. Conclusions
The team concluded that DTRA took effective corrective actions in response to the SL III NOV and developed adequate procedures to implement their 10 CFR Part 71 QAP.
2. Entrance and Exit Meeting
On October 17, 2023, the NRC inspection team discussed the scope of the inspection during an entrance meeting with Sherry Davis and other members of DTRA staff. On October 17, 2023, the NRC inspection team presented the inspection results and observations during an onsite exit meeting with Sherry Davis and other members of DTRA staff. Section 1 of the attachment to this report shows the attendance for the entrance and exit meetings.
ATTACHMENT
1. ENTRANCE/EXIT MEETING ATTENDEES AND INDIVIDUALS INTERVIEWED
Name Title Affiliation Entrance Exit Jeremy Tapp Inspection Team NRC X X Leader Raju Patel Inspector NRC X X Tomeka Terry Project Manager NRC X X Sherry Davis Director, ESOH DTRA X X Tim Hart QAP Manager DTRA X X Dan Sowers Radiation Safety DTRA X X Officer (RSO)
Alex Hunt Radiation Safety DTRA X X Training Manager/Quality Assurance Inspector Geena Quinones Assistant RSO DTRA X X
2. INSPECTION PROCEDURES USED
IP 86001 Design, Fabrication, Testing, and Maintenance of Transportation Packagings NUREG/CR 6314 Quality Assurance Inspections for Shipping and Storage Containers
3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Item Number Status Type Description None None None None
4. LIST OF ACRONYMS USED
10 CFR Title 10 Code of Federal Regulations ADAMS Agencywide Documents Access and Management System CAP Corrective Action Program DTRA Defense Threat Reduction Agency IP Inspection Procedure NRC Nuclear Regulatory Commission NOV Notice of Violation PDR Public Document Room QAP Quality Assurance Program SL Severity Level SOP Standard Operating Procedure
5.
DOCUMENTS REVIEWED
Certificate holder documents reviewed during the inspection were specifically identified in the
Report Details above.
Attachment