ML19037A271
| ML19037A271 | |
| Person / Time | |
|---|---|
| Issue date: | 02/01/2019 |
| From: | NRC/OCIO |
| To: | |
| Shared Package | |
| ML19037A273 | List: |
| References | |
| FOIA, NRC-2018-000571 | |
| Download: ML19037A271 (102) | |
Text
Received !(b )(7)(C) I Entered 07/16/2013 Closed 10/21/4013 CLOSED CASE CHRONOLOGY I Total Dar,f Ope11 Rll-2013-A-0100 I CONCERN I ACTION I PERSON I NO.
NO.
ASSIGNED Non Responsive Record DATE I
ASSIGNED DATE I DUE DATE I
COMPLETE 104 DAYS TO COMPLETE Wednesd(ly, November 06, 2013 Page 1 of 3
Received!(b )(7)(C) I Entered 07/16/2013 Closed 10/21/2013 CONCERN I ACTION NO.
_ NO.
2 5
4 3
2 l 1 I CLOSED CASE CHRONOLOGY I Total Davs Ope11 Rll-2013-A-0100 I PERSON ASSIGNED HICKEY Status Letter HICKEY Review Submittal DATE ASSIGNED 10/03/2013 09/30/2013 DATE DUE 10/30/2013 10/30/2013 DATE COMPLETE 10/21/2013 10/03/2013 104 DAYS TO COMPLETE 18 3
Review the Ucensee response, complete an RF/ checklist and prepare closure documentation as appropriate.
HICKEY 08/01/2013 09/30/2013 09/27/2013 57 Response to Referral On 8/23 Uc called to request a 30 day extension to respond to allegation R/1-2013-A-0100. The licensee reported that many of the records requiring review are 30 years old so the process for locating, obtaining and reviewing will be very time consuming. The licensee infonned that they have a letter in route to the NRG making the request and including the circumstances involved. The licensee request for 30 day extension was granted.
HICKEY 08/01/2013 08/15/2013 08/02/2013 1
Licensee RFI Callbaclc HICKEY Referral Letter RF/
07/23/2013 08/06/2013 08/01/2013 9
Non Responsive Record Wednesday, November 06, 2013 Page 2 of 3
Received !(b )(7)(C I Entered 07/16/2013 Closed 10/21/2013 CLOSED CASE CHRONOLOGY I Total Dal's Open Rll-2013-A-0100 I CONCERN I ACTION I PERSON I NO.
NO.
ASSIGNED DATE I
ASSIGNED Non Responsive Record DATE I DUE DATE I
COMPLETE 1()4 DAYS TO I COMPLETE Wednesday, November 06, 2013 Page 3 of 3
Non Responsive Record INDEX OF CONCERNS I Wednesday, November 06, 2013 Rll-2013-A-0100 I
Page 1 of 3
INDEX OF CONCERNS I Rll-2013-A-0100 I
Wednesday, November 06, 2013 CONCERN:
2 Training/Qualifications Fuel Facility Former licensee Employee NMSS
)"toRKFP, DID NOT RECEIVE PROPER TRAINING OR PROTECTION WHILE HANDUNd"'"(,.;.;b.1.)(... 4~)----i I
(b )( 4)
_ FROM RUSSIA TO BE CONVERTED INTO UF6.
SUBSTANTIATED: L N I ENF: No EA NO~
OT CLSD: 10/21/2013 Response to Concern:
(b)l4)
. The ore concentrates are still, however, classified a \\b)(4)
~iµu.,~u.1:.¥JS:.Ja1,'ed records and interviewed personnel and determined that the ore concentrates from the ffl""i'~...... --.,_
_ __, do not require additional worker training or safety measures to ensure proper handling. As
__,, the activity concentrations of ore concentrates from the former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MTW.
==
Conclusion:==
The NRC has not observed an roblems with Hone ell?s workers receivin ro er training or protection while handlingi.;.{b..:.l(;...4J~------------------------- The NRC inspector was unable to substantiate the concern.
Non Responsive Record Page 2 of 3
Non Responsive Record INDEX OF CONCERNS I Wednesday, November 06, 2013 Rll-2013-A-0100 I
Page 3 of 3
REGION II ALLEGATION RECEIPT FORM Allegation Number: Rll-2013-A-0100
- <bJ(?J(CJ I Date Received: I r
Received By; Nicholas Peterka Allegation Received Via:
D Telephone l:8l In person 0Email D Letter D 01 Transcript#
Prepared By: Nicholas Peterka Is there a otential overrldin Note: (b)(?)(C Non Responsive Record l Concern #: 2 Facility: Honeywell 0
Fax Docket No: 40-3392 0 DOL Complaint Date Prepared: 7/11/2013 N
Concern
Description:
l(b)(4l I
Workers did not receive proper training or protection while handling from Russia to be converted into UF6.
Concern Background Information:
The Cls stated that workers were exposed to!(bJ(
4J
!when they began processing drums of material from Russia. The Cls stated they did not received additional training or per.sonal protection equipment to handle the (bJ(4J (The following information is supplemental to the concern) In addition, the Cls stated due to the (bJ(4J war ers were told to only dump one drum per shift.
Did the alleger raise the concern to management? Unknown If so, what actions have been taken, and when? If no why not?*
Comments: This specific allegation was taken j'b)(7)(G) and the individual stated that he had to leave. This question was not asked.
Non Responsive Record
Non Responsive Record Alie er's lnforma
- Allegation Source: fb)(7J(C)
Alleger's Name: [8J..,.M.,..r-. _..,.....s _____
Alleger's Employer: NA A
Alleger's Home Address: (b)(7)(C)
,,;;,,.-.~.,..,,.,.-............--,....,...... --------'
Home Phone Number b 7 C Work Phone Number.
Email Address: NA Preferences for method and time of contact:
Method: D Letter OEmall
[81 Telephone - Which number?!(b)(7)(C)
I Alleger's Information - Cl#2 Allegation Source: Former Lic~nsee Empiov; e Alleger's Name: [81 Mr. D Ms.((b)(7)(C)
Cell Phone Number: NA Time:
DAM 0PM Allege r's Employer: NA..,.,..,~~w' !U!rui.l.lll9DLJJWW :s.B. ______ _
Alleger's Home Address: (b)(7)(C)
Home Phone Number*r.(~b)~(7~)~(C~)----n=l".""Fl=~==~
n"ll"---,"'"="'""":"".!one Number: NA Email Address: NA Preferences for method and time of contact:
Method: D Letter D Email
~ (b)(?)(C)
[81 Telephone - Which numbe,,.... ____
j Identity Protection Policy/Confidentiality Was the alle er Informed of ID Protection Policy?: No Comments: (b)(7)(CJ (b)(4)
Was Confidentiality Comments: NA I RFI Considerations Alleger Ob'ects to RFI?: No
- (b)(4)
Is the alleger concerne a out eing I entified to the licensee?: No If so, why?
Does the alleger object to having his/her identity released?: No If so, why?
Time: DAM 0PM
I Discrimination/ Harassment & Intimidation (H&I) - to be discussed only if the alleger brings it up Is the alleger asserting discrimination (i.e. alleged retaliation for raising a safety concern)?: No Was alleger informed of DOL rights?: No J No further contact requests - to be discussed only If the alleger brings It up Did the alleger request no further contact with the NRC?: No Were the benefits of continued process involvement discussed?: Select
- If more than 3 concerns were received, please fill out a separate form. Only the concern section needs to be completed.
ALLEGATION REVIEW BOARD
SUMMARY
Tuesday, July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Allegation Number: Rll-2013-A-0100 ARB Type: Initial Facility: Honeywell ARB Date: 7/16/2013 Responsible Branch: DFFI/FFB2 ARB
Purpose:
Tn...
,ine course of action
- (b)(7)(CJ I
(b)l7)(C)
Received pa~e~
I Allegation Source: I I
30-Days = (bJ{ l<
Total# Concerns: 4 150-Days 180-Days Non Responsive Record
ALLEGATION REVIEW BOARD
SUMMARY
Tuesday, July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Estimated Completion Time: 14 DAYS Concern#: 2 Concern Type: Allegation Discipline: Select Training/Qualifications {Select Only One)
Concern
Description:
l(bJ(4J WORKERS DID NOT RECEIVE PROPER TRAINING OR PROTECTION WHILE HANDLING..__ __
(b)(4)
Follow-Up ARB Input: (if applicable)
Safety Impact and Applicable Regulation:
Safety Significance: Low Describe potential safety Impact, assuming concern is true : Potential exposure to workers not accounted for and exposure records not documented.
Applica.ble Reg~lat~on:.
J CbJ(?J(C)
When did potential v1olat1on occur (date)?!,_ __
Concern Disposition Method/Branch Input and Comments:
0 Transfer to:
(NRC Internal Exchange to another region/NRR/NMSS, etc.)
181 Request for Additional Information (RFI): Letter to licensee for additional information.
Branch to review the licensee response to the RFI:
0 Provide to Licensee for Information Only:
0 Referral to Select :
0 Inspection Follow-Up:
(Provide information on what is to be Inspected, inspection schedule, etc.)
0 ADR:
(For discrimination cases. after prima facie has been established) 0 Office of Investigations (01):
(Provide draft NOV to Allegations Office)
D Too General/Need More Details:
(Provide recommendation, e.g. Inspector contact alleger for details, etc.)
D Closure in acknowledgment letter:
D Closure Letter or Memo to File:
D Other:
Specify recommendation (e.g. Contact licensee, chilling effect letter etc.)
D EICS Close FIie Administratively:
Prompt notification of SRI/RI or region-based inspector required: Already Notified Related previous allegation number:
NIA [81 Related 01 Case Number:
NIA [81 Is this a response after closure?: Select To be filled out at the ARB ARB Assigned Actions:
RFI Assigned Branch/Individual: DFFI/FFB2 Estimated Completion Time: 14 DAYS
ALLEGATION REVIEW BOARD
SUMMARY
Tuesday, July 23, 2013 ARB MINUTES ARE REVJEWEO AND APPROVED BY THE ARB CHAJR AT THE ARB I\\Jon Responsive Record
ALLEGATION REVIEW BOARD
SUMMARY
Tuesday, July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Non Responsive Record RF1 Considerations Applicable Concern(s): 4 Does the concern(s) present an Overriding Safety Issue? YO N (gi If yes, an RFI. will nonnally be issued to the licensee (verbally first, then in writing)
Notes/Comments:
Conditions Inhibiting RFI:
D Will compromise alleger identity protection D Will compromise investigation or inspection D Against management that would review RFI 0 Fed or State agency disapproves of RFI Other RFI Considerations ff Inhibiting Conditions Do Not Apply D Release could bring harm to alleger. Describe:
D Alleger Objects to RFI. Describe:
D Alleger objects to releasing their identity in RFI, when necessary for adequate follow-up. Describe:
D Alleger is concerned about being identified to the licensee. Describe:
D Alleger has raised concern to licensee w/ unsatisfactory results. Describe:
D Recent NRG concerns w/ licensee RFI responses. Describe:
Other Items Potentially Affecting RFI Response Quality:
0 Recent Inspection findings? Last Pl&R? Describe:
I
ALLEGATION REVIEW BOARD
SUMMARY
Tuesday, July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB D Substantive Cross-Cutting Issue? Describe:
D Allegation history issues? Describe:
D Licensee policy/process issues? Describe:
D Resource issues? Describe:
D Other? Describe:
ts RFI an Acceptable Option? Y 15<1 N O Summarize mason; Both Cls do not object,o an RFI nor to being identified to the licensee. 1 (b-l(7-l(_ci ________________ __.J I
ARB Attendees Chairs: C. CHRISTENSEN, W JONES, T. GODY EICS: 0. DEMIRANDA, M. CHECKLE, A ALLEN 01:Hb )(7)(C) I OGC/Counsel: C. EVANS Branch Chiefs: J. HICKEY Other Attendees: J. DODSON, R. PATTERSON, L HALL, J. BROWN
CHECKLIST FOR NRC STAFF REVIEW OF LICENSEE RESPONSE TO AN ALLEGATION REQUEST FOR INFORMATION The purpose of this checklist is to assist the staff in evaluating the adequacy of a licensee's response to an allegation Request for Information (RFI), independently verifying aspects of the information provided by the licensee, and to support the development of the proposed basis for additional staff actions if it is determined that the licensee's response is inadequate, inaccurate, or otherwise unacceptable.
Note: The term "licensee" in the worksheet refers to any NRC licensee, certificate holder, license or certificate applicant, or vendor that may be the subject of an allegation concern.
ALLEGATION NUMBER: Rll-2013-A-0100 AFFECTED CONCERN($): Concerns 1 - 4 FACILITY: Honeywell A: Determining the Adequacy of the Licensee=s Response to an Allegation RFI Note: Yes" answers normally indicate that the licensee's response to an RFI is adequate, while "No" answers indicate additional action may be necessary.
Evaluator Independence Yes [8J No O Does the relationship between the individual(s) chosen by the licensee to evaluate the concem(s) and the concern(s) being evaluated allow for appropriate objectivity (e.g., thir.d party or internal evaluator, but not in the same management chain as those involved in concern(s))?
Note: Use best judgment for smaller organizations when clear management chain independence may not be possible.
Comments: The Independent Investigator is an outside counsel.
Evaluator Competence Yes~ No D Based on the information provided, is the evaluator competent in related functional area?
C
,t)J,,,c, omments: He has (01711(
Depth and Scope of Evaluation Yes [8J No D Yes~ NoD Yes 1:8:J No D Are all RFl-related concerns addressed?
Is the evaluation rigor commensurate with the level of concern detail provided? For example, if appropriate, did evaluation include extent of condition review, root/apparent cause assessment, or generic considerations?
Are the conclusions provided by the licensee supported by the evaluation?
Yes t8J No D Are all affected personnel/groups/departments considered in the evaluation?
For example, if interviews were conducted, did the licensee describe the basis for the number and cross section of individuals interviewed and is basis adequate? Were the interview questions appropriate?
Yes t8J No D N/A D If the NRC asked additional specific questions, are they answered satisfactorily?
Yes t8J No D N/A D If the names of specific individuals were referenced in the RFI, did the licensee contact those individuals and/or appropriately consider their involvement in the allegation concern?
Yes~ No D NIA D If specific documentation was referenced in the RFI, did the licensee evaluate that documentation and/or appropriately consider it in the evaluation of the allegation concern?
Yes~ No D N/A D If the licensee reviewed a sample of related documentation and/or potentially affected structures, systems, and components, did the licensee describe the sample and provide the basis for determining that the sample size was appropriately representative?
Comments: __
Effectiveness of Corrective Actions YesO NoO N/A181 Yes D NoO N/A181 Yes D No D N/A 181 Yes D No D N/A t8J Comments: __
If applicable, were appropriate immediate corrective actions taken by the licensee?
If applicable, were operability and reportability determinations appropriate?
If applicable, were appropriate corrective actions proposed?
If applicable, were issues entered into the corrective action program?
NRC Violations (substantiated concerns only)
Yes D No D N/A 181 If the substantiated concern represents a violation, did the licensee appropriately acknowledge and articulate the violation in response to the RFI? Comments: __
B: NRC Independent Review Effort NRC staff evaluating licensee RFI response should attempt to independently validate aspects of the information provided by the licensee. Indicate any of the following that apply:
D Additional questions posed to the licensee.
D Performed or coordinated an independent inspection or technical review activity to verify a condition indicated in the response.
D Reviewed the results of recently conducted NRC inspections in the functional area related to the allegation concerns.
181 Verified the existence and applicability of technical references noted in the response.
D Verified the existence and applicability of procedures referenced in the response.
Ensured revision number referenced is appropriate.
D Verified the existence and content of corrective action program documentation referenced in the response.
D Checked calculations noted in the response.
D Other. Describe: --
Comments: --
C: CONCLUSION
[81 Adequate RFI Response D Inadequate RFI Response Basis: The licensee has an adequate response to the requested information in the RFI.
Note: Notify the responsible Branch Chief and the OAC of the results of this review.
PREPARED BY: R-~ r; <J;j BRANCH CHIEF: r DATE PREPARED: 10/2/2013 DATE REVIEWED: 1PJk~/ 3
Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 September 27, 2013 CERTIFIED 7010 0290 0001 5998 0229 Mr. Oscar DeMiranda Senior Allegation Coordinator, EICS Office of the Regional Administrator, Region II U.S. Nuclear Regulatory Commission P.O. Box 56274 Atlanta, GA 30343 Docket No. 40-3392 License No. SUB-526 RE:
HONEYWELL METROPOLIS WORKS' RESPONSE TO ALLEGATION NO. Rll-2013-A-0100 Honeywell This letter forwards the report of the investigation performed by an Independent Investigator to evaluate the concerns identified in the NRC's August 1, 2013 letter transmitting Allegation Rll-2013-A--0100. The Independent Investigator is outside counsel from Winston & Strawn LLP. with more than ten years of experience in nuclear regulatory matters.
Upon evaluating the concerns set forth in the NRC's letter, Honeywell determined that it needed additional time to finalize the investigation, and requested that the reply date be extended to 60 days from the date of the NRC's letter. This extension was granted by you via telephone on August 23, 2013, and documented in Honeywell's letter to Mr. James A Hickey on that same date.
The Independent Investigator found that the four concerns in the Alleo::1tionwere unsubstantiated. Specifically: (1 INon Responsive Record I
Non Responsive Record 1(2) While material froml<bl14l I
(b)(4) aaamonal training and protections are not warranted; (3 J Non Responsive Record Non Responsive Record Non Responsive Record I and ( 4 ) jNoo Responsive Record I
Non Responsive Recorct Supporting documentation is attached to the Independent Investigator's report.
MTW intends to ensure that all concerns expressed by MTW employees and contractors are received and resolved in an effort to continue to improve our safety and performance.
Enclosures 2
Honeywell Metropolis Works (MTW)
Review of Nuclear Regulatory Commission (NRC)
Allegation No. Rll-2013-A-0100 Dated August 1, 2013 Independent Investigator 1-Outside Counsel (Winston & Strawn LLP)
Washington, DC September 27, 2013 1
BACKGROUND By letter dated August 1, 2013, 1 the U.S. Nuclear Regulatory Commission (NRG) forwarded to Honeywell International Inc. (Honeywell) four concerns regarding activities at the Honeywell Metropolis Works (MTW) facility in Metropolis, Illinois.
The NRG requested that Honeywell evaluate the information described in the letter's enclosure and provide the results to the NRG RII Allegations Coordinator. This report presents the results of an independent investigation of the concerns forwarded by the NRG.
ISSUES INVESTIGATED Non Responsive Record Concern 2:
(b)(4)
Did the material from Russia hflve._!'b...,,1(4... ) ----'~ And if so, did it require additional training to ensure proper handling?
Non Responsive Record INVESTIGATION APPROACH (t,)(7/(CJ These allegations were evaluated by an independent inve.,;s:;..t.,.i,;;a...
to_r..._ ____
__......__......J
{b)(7)(C.
is outside counsel from Winston & Strawn LLP.
(b)(7){Cl (b)(7J(Cj Letter, J. Hickey to f bl(?l(C)
- l. "Allegation No. Rll-2013-A-0100," Aug. 1, 2013.
The enclosure is marked as.. ~,et fe'er P1,1eliG Oi~clo&* 4i "
2
l (b)f7l(C) matters..
(b)(7}(C
!(b)(7)(C)
He has al The investigation began with a review of current and historical documents relevant to the concerns identified by the NRG.
The investlgator also obtained MTW procedures relating to the issues addressed in this report. The relevant documents reviewed by the investigator are listed for each concern. In additionJbJ(T)(s,
!questioned subject matter experts at MTW, also identified below, who had knowledge of events or responsibilities in functional areas relevant to the concerns.
From the review of the original concerns, the documents identified during the investigation, and the interviews with subject matter experts. the investigator assembled a list of incidents or examples that are encompassed by the concerns. The investigator evaluated each incident or example to the extent practicable given the nature of the matter, and also evaluated the overall timeline in assessing the overarching issues raised in the allegations.
FINDINGS OF FACT Non Responsive Record 3
Non Responsive Recort1 4
Non Responsive Record
Non Responsive Record Concern 2 - Unsubstantiated The investigator reviewed the requirements of NRC license SUB-526 issued to Hone well for the MTW facilit and obtained information and documentation re ardin (b)(4J The investigator also interviewed l(bl(T!(C1 I the MTW (blC7HCl
, to obtain back round information on MTW processes for receipt and sampling of incomin
,:i(~)~~~ial. (b)/7)( J has worked r MTW fo8 ears_ arlc:i isre$ponsiblefor the (b)(7)(C)
Honeywell's license authorizes it to possess up to 68 million kg (150 million lbs) of natural uranium in the form of '
1yellow cake," U30s, U02, U03, UF4, UFa, and chemical intermediates of these compounds.
The license does not impose any specific restrictions on the "activity," "specific activity," or activity concentration" of natural uranium ore concentrates received by Honeywell.
Honeywell receives uranium ore concentrates in 55-gallon drums via common carrier from uranium mills throughout the world.3 Each shipment is unloaded at the Sampling Plant.
Each lot of concentrates is weighed and stored on storage pads until accountability procedures and uranium and impurity analyses are completed.
The uranium ore concentrates. are sampled in the Sampling Plant (except for hard or wet ore) to obtain statistically-significant analytical samples in accordance with ASTM standards.
Th~ sampling results confirm that the material is natural uranium ore concentrates, as defined in ASTM standards. In addition, MTW sampling procedures ensure that any material that deviates from the range of acceptable ore concentrates is identified and appropriate steps taken to address any safety concerns.
According to l(bl{7J(Ci
( MTW does not currently receive ore froft ~1,:;sja rTW does, however, receive ore from former Soviet republics, including! n <cJ and l<bi<71(c, l Shipments from these countries are often referred to colloquially as "Russian" ore. For the purpose of this report, the investigator assumes that the concern relates to ore concentrates from the former Soviet republics, rather than ore concentrates from Russia itself.
A
- d.
l(b){7)(C)
I h'
II d d
h ccor rng to
, uranium ore s 1pments are typ1ca y esigne to max1m1ze t e amount of ore in a sinale shipment in order to minimize transportation costs. Because
{b)(4J (b)(4)
I. According to l(b>C7HC.:J I material from the former 3
According to 10 CFR 71.4, the natural uranium ore concentrates at MTW are low specific activity materials. The International Atomic Energy Agency (IAEA) also defines natural uranium as a low specific activity material.
6 (b)(7)(C)
(b)(4)
A review of shipment manifests addressing uranium from multiole locations indicates (b)(4) 4 5
6 Country of Origin I Total Activity I # Drums I Activity/drum6 (b):4 I-USA I -344 GBq I 43 I 8.0 GBq/drum (b)(4\\
According to !(b)l7)(Cl I. the samples listed are broadly representative of the range of material received by MTW.
For natural ore concentrates, activity is proportional to the quantity of uranium.
The term "activity concentration is used to indicate the activity per unit mass (or volume) of material and is similar to specific activity." Specific activity, however, is typically reserved for use in reference to a pure sample of a radionuclide, while activity concentration is used when referring to a material that contains radionuclides.
This represents the average activity concentration for drums of ore concentrates.
7
Country of Origin u (%)
U-234
$04(%)'81 Na (%)<al
{b)(4)
I USA 76.21 46.12 ppm 0.99 0.44 USA 78.92 51.47 ppm 0.44 0.5.2 USA 81.02 54.28 ppm 3.04 0.48 USA 81.29 53.81 ppm 1.89 0.54 (b )(4)
Sulfur and sodium are just two of many elements that may be found in uranium ore concentrates.
They are listed here to help illumlnate the reasons for differences in uranium concentrations among material from different regions.
Althou h the ore concentrates from former Soviet re ublics !{b}(4)
I (b)(4) the material still meets the e in 10n o natural uranium ore concentrates per ASTM standards e.. ASTM C967 Standard S ecification for Uranium Ore Concentrate).
The._(b_,1_71_1c_, _____
(b}(4) etween a drum of material from a former Soviet republic an..._ _ _,
ano er ocat,on 1s not si nificant from f
to (b)(7)(CJ j<bl(7J{C)
J the (bl(7)(C1 at MTW, no s ec,al r ecessary o accoun or (, l L:----,,---~~~---=-~---:-'
(b)(4) between ore concentrates from former Soviet republics and ore concentrates rom ot er locations. No additional training or safety measures beyond those already in place at MTW are necessary because MTW's Radiation Protection and ALARA programs are designed to provide protection for a wide range of radiological materials, including natural uranium ore concentrates j(b}(4)
I
!(b)(4)
I Response to NRC questions regarding Concern No. 2:
- 1. Did the material from Russia have higher activity?
(b )(4)
{b)(4)
I The ore concentrates are still, however, classified as natural uranium ore concentrates.
- 2. And if so, did it require additional training to ensure proper handling?
Ore concentrates from former Soviet republics do not require additional training or safety measures to ensure proper handling. As natural uranium, the activity concentrations of ore concentrates from former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MTW. In addition, MTW sampling procedures ensure that material that could pose additional safety concerns is identified and addressed.
8
Actions Planned No additional actions are considered necessary at this time.
Actions Taken This investigation was conducted and a response was prepared as directed in the NRC's letter dated August. 1, 2013.
l~on Responsive Record 9
Non Responsive Record Actions Planned No additional actions are considered necessary at this time.
Actions Taken This investigation was conducted and a response was prepared as directed in the NRC's letter dated August 1, 2013.
CONCLUSION After reviewing the evidence, the independent investigator concludes that:
Concern 2: "Workers did not receive proper training or protection while handling
!(bl(4l I from Russia to be converted into uranium hexafluoride (UF6)" is unsubstantiated. While material from former Soviet republics!(b)(4) I l{b)(4)
I additional training and protections are not warranted.
Non Responsive Record 12
ATTACHMENTS List of Attachments Non Responsive Record List of Persons Interviewed (b)(7)(C) 13
ATTACHMENT 1 Letter from !(b)(?)(C)
! Allied Signal, to NRG, "Retraction of Request for License Amendment," dated July 17, 1998.
- 411iedSignal CHEMICALS July 17, 1998 Director Office of Nuclear Material and Safeguards, U.S. Nuclear Regulatory Commission A TIN: Document Control Desk, Washington, D.C. 20555 AllkdSignal Inc.
Nm:h::ir/ Fluorim: Spn:ialtics Routt'.; 5 North P.O. llox 4W Metropolis, II. 62')6() l 'SA
()185242111 61 H 524 6239 Fax Certified Mail:
P-218-965-303 Re:
Retraction of Request for License Amendment Source Material License SUB-526 Docket 40-3392 TAC No. L31076
Dear Sir:
AlliedSignal has previously requested a license amendment dated May 8, 1998 to include receiving, possessing, processing and converting unirradiated material potentially contaminated with plutonium-239 to uranium hexafluoride. This request was initiated due to extremely low but allegedly detectable levels of Pu-238 and Pu-239 reported in this material.
In conjunction with the request for license amendment, AlliedSignal has requested further analysis of the material in question from two different laboratories.
Nine duplicate samples were prepared and forwarded to FluorDaniel Fernald and to Thermo NuT ech laboratories for independent analyses. The samples were selected from lots that indicated relatively moderate to high concentrations of plutonium. based on the original analyses by FluorDaniel. Lots showing low values were not retested.
Included with these samples were four samples of natural uranium tetrafluoride produced at Metropolis Works for comparison.
We have received the results from both laboratories and the results are consistent with natural material. Nine lots were analyzed for Pu-238 and Pu-239. Seven of the nine lots tested showed less than minimum detectable concentration (MDC) of plutonium by both laboratories.
One lot, #2641, tested slightly above the minimum detectable concentration by Thermo Nu Tech for Pu-238 at 0.100 pCi/g. The MDC for this analysis VoiaS 0.060 with an error of 0.054. One lot, #2562, tested slightly above the minir.ium detectable concentration (MOC) by FluorDaniel for Pu-239 at 0.032 pCi/g. The lv10C for this analysis was 0.031 with an error of 0.028.
In both of these cases, the other laboratory showed less than MDC quantities for the respective isotopes.
Director, Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Page 2 Four samples of natural uranium tetrafluoride produced at Metropolis works were included for comparison.
Thermo NuTech showed Pu-238 slightly greater than detectable in three of the four samples. FluorDaniel showed slightly greater than MDC in the other sample. Once again, no sample tested positive for any plutonium isotope by both laboratories.
Analysis of the data indicates that in every case where a laboratory yielded a positive result for either Pu-238 or Pu-239, the laboratory counting error was sufficient to cause the value to be above the MDC. It is our feeling that we are dealing with an analytical method that is so sensitive and minimum detectable quantities that are so low that any noise, counting error, or background interference may calculate to a value near or above the MDC. Although we do not propose dilution as an acceptable method to reduce the analytical results, we do realize that commingling with the material in our existing process would certainly reduce the concentrations well below the detection limit making any further analysis a moot point. It is likely that we would get similar analytical results hovering around and mostly below the minimum detectable concentration.
Once again, interference, counting error and background may calculate to some positive but meaningless result.
When comparing plutonium levels in the Metropolis natural material to the "contaminated' material, it was found that the levels were very similar. This would confirm the original contention that the uranium tetrafluoride purchased from Fermco is indeed not contaminated with plutonium. Any indication of plutonium contamination could be due to a variety of factors including: a) reporting of results that are below the MDC; b) laboratory error that would make an analytical value that should be below the MDC slightly higher than the MDC; c) performing analyses at such low levels that background or other interference may yield false positive results.
We also believe that the positive plutonium results reported in the Metropolis Works UF4 are a result of a similar phenomenon and that there has been no contamination of our facility. Work room air sampling has been performed and there is no evidence of plutonium contamination in the samples.
It is our intention to perform additional sampling during and upon completion of the processing of the UF 4 to verify these results.
Furthermore, the analytical results for this material were compared to the IAEA definition of unirradiated uranium as defined in paragraph 245 of IAEA ST-1,
Regulations for the Safe Transport of Radioactive Material, 1996 Edition.
This paragraph defines unirradiated material using 3 parameters: total plutonium. fission product activity, and U236 concentration.
Th8 following tcible compa.res the Nnnes_!
val1..:e of tile analyses for either laboratory to tne IAEA standard:
- Director, Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Page 3 Analytical Units Lot Laboratory Parameter Number Plutonium Bq/g LJ235 2565 Thermo NuTech Fission Bq/g u 235 2639 Fluor Daniel Products u 23a
-9 u236 / g u 23s I
Alt Fluor Daniel Highest IAEA Laboratory Standard Result 2.266 2,000 629 9,000,000
<0.000140 0.005 For each parameter, the analyzed value is several orders of magnitude below the IAEA definition.
Based upon these concurring results by independent laboratories and the fact that no parameter approaches the IAEA definition of unirradiated uranium, it is our contention that the uranium tetrafluoride in question meets the requirements of our existing operating license and that no amendment is required to possess or process this material. These laboratory results also indicate that the plutonium in the UF 4 is at or below the laboratory counting error and therefore, this facility is not contaminated with plutonium.
We respectfully request that the request for license amendment be retracted. We apologize for any inconvenience that you may have incurred as a result of our initial request.
We will appreciate your prompt review of this submittal. If our have an uestions or need more information, please call (b)(7)(C) or l (b)(7)(C)
I*
Sincerely, (b )(7)(C)
PGG/sm cc.
(b )(7)(C)
Mr. Mike Lamastra Div. of Fuel Cycle Safety & Safeguards US NRC Wasl1ington. D C 20555 Mr. Pat HHand NRC - Region Ill 801 Warrenville Rd.
Lisle, IL 60532-4351
ATIACHMENT2 l (b)(7}(C)
I.,
Letter from M. Lamastra, NRC, to Allied Signal,,;Amendment Request to Process Pu~239 Contaminated Material," dated August 5, 1998.
Mr. P. G.Gaperinl lrurim Plal'lt Manager AlliedSignll, Inc.
P.O. Box 430 Metropolit, lllinoil 82960 August 5, 1998
SUBJECT:
AMENDMENT REQUEST TO PROCESS Pu-239 CONT AM1NA Ti.;O MATERIAL (TAC No. L31078)
DNr Mr. Gape,ini:
Thie~ to your applic:ation dlltad May 8, 1998, requnting an amendment to Matenall Uc:enM SUB-528 for approval lo prooeaa material d\\at ii contaminlt9d With Pu-239, and your
,My 17. 1988, reqiN to withdraw the amendmwrt. Baed on the new information llJbmtttad t,r Y04/I Jut, 17, 1981, laaar that the Pu-238 and Pu-238 11 at minimum ~
concerlb'ltionl and ia ~
wllh nanl maeen.. we agree thal the material may be pn,caeNd under yow CUfflN1t aulhoriZlltion wtlh no amendment reqund. ~.
no fur1hlr ICtiOl'l 11 ~.
and TAC No. L31078 i9 oonaider doMd.
If you ~
qu111k)M rega,dinO tit mdlt. plow oantact me It (301) 415-1138.
~.
D:erbfon (Controt 'No. 3006)
Ortg1~1 signed by:
Mk:haal A. Lamattra Ucwine Section 2 Uceneing Branch OMliorl r:I Fuel Cyae 8*y and U.guarda. NUSS Doclllt 40-3382 PU8UC NRC File c.r.-
NMSS R/F FCLB R/F FC88 M Region Ill O:\\allwlt O,C FCLB
£:,
- ... **,py
"(J"' '#!
/vflJ.;
UNtTED STATES HL'CLEAP. RECULATORY COMMISSION WAIHtHGTON. D.C. : OIH ODD1 Avgu st S, l 998 (b)(7)(C)
SUBJECT:
AMENDMENT AeQUEST TO PROCESS Pu-239 CONTAMINATED MATERIAL (TAC No. l31078)
Dear!(b )(7)(C)
Thia rwfefl to your appticltion dated May 8. 1998; ~
an amendment to Materiatt Uoenee SUB-526 for epproval to proofft meterial that* contaminated With Pu-230. and your
~
- 17. 1991, request to wrthdrN Che 8mendment. Baled on the new lnform.ttior, submttted by your,My 17. 1998,,-., that Che f'u.238 ~
Pu-238 ta.t minimum dlltectable c:onceutnttion. and II conliatant with nltunll material, we agree lhlt the material may be procetNd under,out* current tutt.orization '1With no amendment required. Accordingty, no further action Ill rwquired, atw.t TAC No. L31078 it consider doled.
If you h8Y9 ~
rwprd.ng thlt mattrr. pleaN contact me ac (301) 415-8139.
Slnelt'efy.
,A41* '. -------
Michaet A. Lam*"-
lk:ilnting Section 2 Licensing Bnndl 2 C Dtv'8ton of Fuel Cycle Snty lnd~. NMSS
..;...-----------~-*--*.... --
ATTACHMENT 3 Representative Rai/car Stenciling
DOT 112SSOOW
~
FUJORl)E, ANHYDROUS INHALATION HAZARD
,~~~~~
DOT P111.51 ~~Oi!!j5
ATTACHMENT 4 Representative Railcar ID Plate
6ass24638!>
Safety Trailer 02:02:20 p.m.
09 2013 2 /28 Honeywell Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 September 27. 2013 CERTIFIED 7010 0290 000159980229 Mr. Oscar DeMiranda Senior Allegation Coordinator, EICS Office of the Regional Administrator, Region II U.S. Nuclear Regulatory Commission P.O. Box 56274 Atlanta, GA 30343 Docket No. 40-3392 License No. SUB-526 RE:
HONEYWELL METROPOLIS WORKS' RESPONSE TO ALLEGATION NO. Rll-2013-A-0100 This letter forwards the report of the investigation performed by an Independent Investigator to evaluate the concerns identified in the NRC's August 1, 2013 letter transmitting Allegation Rll-2013-A-0100. The Independent Investigator is outside counsel from Winston & Strawn LLP, with more than ten years of experience in nuclear regulatory matters.
Upon evaluating the concerns set forth in the NRC's letter, HoneyweU detennined that it needed additional time to finalize the Investigation, and requested that the reply date be extended to 60 days from the date of the NRC's letter. This extension was granted by you via telephone on August 23, 2013, and documented in Honeywell's letter to Mr. James A.
Hickey on that same date.
The Independent Investigator found that the four concerns in the Allegation were unsubstantiated. Specifically: (1) Green salt from Fernald did not contain plutonium or neptunium in analytically significant quantities; (2) While material from former Soviet republics sometimes has a higher activity concentration than material from other locations, additional training and protections are not warranted; (3) Railcars used to store anhydrous hydrofluoric acid (AHF) contain pressure relief valves with appropriate set points. and no scrubber system is necessary given the substantial margin between the vapor pressure of AHF and the relief valve set point; and (4) While Metropolis Works (MlW) at one time required exit monitoring only for personnel working in process areas, by the mid-1990s all persons leaving the restricted area were required to perform exit monitoring, and no records were found of off site contamination during the period of interest.
Supporting documentation Is attached to the Independent Investigator's report.
MTW intends to ensure that all concerns expressed by MlW employees and contractors are received and resolved in an effort to continue to improve our safety and performance.
,6185246~85 safety Trailer 02:03:23 p.m.
09-27-2013 If there are any questions regarding the enclosed information, please call Mark Wolf, Nuclear Compliance Director, et (618) 309-5013.
Sincerely, :::::~~~f ~
Plant Manager J.g H. $'.,....r, Enclosures 2
3 /28
6J8524638!i SafetyTraller 02:03:47 p.m.
09-27-2013 Honeywell Metropolis Works (MTW)
Review of Nuclear Regulatory Commission (NRC)
Allegation No. Rll-2013-A-0100 Dated August 1, 2013 IDd@PIQdent Investigator Tyson Smith - Outside Counsel (Winston & Strawn LLP)
Washington, DC September27, 2013 1
4 /28
, 618524ti385 SafetyTraller 02:04: 15 p.m.
09-27-2013 BACKGROUND By letter dated August 1, 2013, 1 the U.S. Nuclear Regulatory Commission (NRC) forwarded to Honeywell International Inc. (Honeywell) four concerns regarding activities at the Honeywell Metropolis Works (MlW} facility In Metropofis, Illinois. The NRC requested that Honeywell evaluate the Information described in the letter's enclosure and provide the results to the NRC RII AUegations Coordinator. This report presents the results of an Independent Investigation of the concems forwarded by the NRC.
ISSUES INVESTIGA TEO Concern 1: In the mid 90s, workers were unknowingly exposed to Plutonium and Neptunium while processing green salt from the Fernald Department of Energy (DOE) facility.
Determine If a Plutonium and Neptunium hazard resulted from processing green salt from the Fernald DOE facility. If so, wem worlcers properly trained for those hazards'? Were there any exposum events Involving Plutonium and Neptunium?
If so, what were the levels and resufts?
Concem 2: Workers d;d not receive proper training or protection while handling higher actiVlty material from Russia to be converted Into uranium hexafluoride (UFe),
Did the material from Russia h~ve higher actrlity? And if so, did It require additional training to ensure proper handling?
Conoem 3: The railcars stored on-site for transfer of anhydrous hydrofluoric acid (AHF} to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization and are not connected to a scrubber system.
What features are n,quired and/or available for rail cars stored onsite which may be subject to an over-pressurization event?
Conoem 4: In the mid 90s, individuals wera not required to monitor out of the facJ/lty and could have bsen spreading c;ontaminatlon offslte. One lnrf,vidual was noted to hava gone home contaminated.
Provide information regarding offsite contamination 9Vent(s) and correct actions resulting from any event(s) which occu"ed In the mid 90s.
INYESJJGA TION APPROACH These allegations were evaluated by an independent lnves11gator, Tyson R. Smith. Mr.
Smith is outside counsel from Winston & Strawn LLP. Mr. Smith has more than ten years of experience In NRC regulatory matters, including investigations and enforcement Letter, J. Hickey to L. Smith, "Allegation No. Rll-201~A-0100," Aug. 1, 2013.
The enclosure is marked as "Not For Public Disclosure."
2 5/28
6385246385 Safety Trailer 02:05:17 p.m.
09 2013 matters. Mr. Smith was employed by the NRC from 2003*2005. He has a B.S. in Civil and Environmental Engineering from Vanderbilt University, an M.S. In Civil and Environmental Engineering from Stanford University, and a J.D. from Lewis & Clark Law School.
The investigation began with a review of current and historical documents relevant to the concerns identified by the NRC. The Investigator also obtained MlW procedures relating to the Issues addressed In this report. The relevant documents reviewed by the investigator are listed for each concern. In addition, Mr. Smith questioned subjed matter experts at MTW, also Identified below, who had knowledge of events or reaponslbllltles In functional areas relevant to the concerns.
From the review of the original concerns, the documents identified during the investigation, and the interviews with subject matter experts, the Investigator assembled a list of incidents or examples that are encompassed by the concerns. The Investigator evaluated each Incident or example to the extent practicable given the nature of the matter, and also evaluated the overall timeline In assessing the overarching Issues raised in the allegations.
FINDING§ OF FACT Concern 1 - Unsub§tanU.ted Through a review of historical documents, Including correspondence with the NRC, the investigator compiled a regulatory history relating to shipments of green salt from the Fernald DOE facility.2 The available documentation supports the conclusion that MTW workers were not exposed to plutonium or neptunium while processing green salt from Fernald. Additionally, the documents confirm that no plutonium or neptunium hazard resulted from processing this green salt, and that workers therefore needed no special training.
The following chronology of events provides detailed background regarding green salt received at MTW, which at the time was operated by AlliedSlgnal, from the Fernald DOE facility.
2 November 1995: Allie<fSignal receives shipment of uranium tetrafluoride (UF")
green salt from FERMCO (Fernald, Ohio).
November 1996: Five lots of potentially contaminated UF" from FERMCO are Identified for the first time during a review of material for sale.
February 1997: FERMCO green salt Is tested for contaminants by two separate laboratories. All lots except one show nor,..ctetectable levels of plutonium.
Neptunium contamination was not detected in any samples.
Uranium tetrafluoride (UF.. ) is a green crystalline solid.known as green salt.
Green salt Is an Intermediate compound In the conversion of uranium oxides to uranium hexafluoride.
3 6 /28
- 6185246385 Safety Trailer 02:06:23 p.m.
09-27-2013 March 17, 1997: AllledSlgnal requests a license amendment from the NRC that would authorize possession of UF,. contaminated with plutonium (for the one lot showing detectable level of plutonium}.
April 2 and 16, 1997:
AliedSlgnal responds to NRC Staff requests for information regarding the license amendment request.
May 6, 1997:
NRC grants license amendment authorizing AJliedSlgnel to possess the contaminated FERMCO UF4.
May 8, 1998: AltiedSignal requests Hoense amendment to authorize proce86ing and conversion of contaminated FERMCO UF,..
June 17, 1998: NRC issues request for additional Information regarding ficense amendment request.
July 17, 1998: AllledSignal withdraws request for license amendment. Based on subsequent analysis, MlW determined that the FERMCO green salt In fact met the requirements of the MTW operati'll llcellN at that time. As a result, no amendment was necessary to possess or process that green salt.
According to the July 17, 1998 letter, analyses of nine lots of the green salt by two separate laboratories showed results consistent with natural (unirradlated}
green salt. Seven lots had less than the minimum detectable concentrations
{MDC) of plutonium based on results from both laboratories. One lot ahowed sHghtty above MOC by one laboratory, and a different lot showed slightly above MOC by the other laboratory.
In both of these cases, the other laboratory showed Jess than MDC quantities. AJso, in both of these cases the laboratory counting error alone was sufficient to cause the value to be above MDC.
AllledSlgnal therefore concluded that UF 4 from FERM CO was not in fact contaminated with plutonium, and that any Indication of contamination was likely the result of laboratory error or other analytical issue.
AlliedSignal also affirmatively stated that there was no contamination of the facility.
August 5, 1998: NRC agreed that, based on the Information In AJliedSlgnal's July 17, 1998 letter, the plutonium was at minlmLrn detectable concentrations in the FERMCO green salt. The NRC concluded that the green salt material analyses were consistent with natural material and that the FERMCO green salt could be processed under the MTW license without amendment Present day: Seven drums of the FERMCO green salt remain onslte. The drums are Individually identified and marked.
No special procedures or supplemental protections relating to the storage or handling of the green salt are in place or necessary.
4 7 /28
6l85246385 Safety Trailer 02:07:27 p.m.
09-27-2013 Response to NRC questions regarding Concern No. 1:
- 1. Determine If a plutonium and neptunium hazard resulted from processing green salt from the Fernald DOE facility.
Based on a review of MTW correspondence with the NRC, there were (and are) no plutonium or neptunium hazards resulting from green salt received from the Fernald facility.
Extensive laboratory testing indicated that green salt from Fernald dld not contain plutonium or neptunium In anatytlcally ~gniflcant quantities. As a result, the green salt could be processed under the then-existing MTW license. The FERMCO green salt has been and wlll be processed In accordance with the MTW license and applicable procechxes. In adcition and as documented in the letter from the NRC to AllledSlgnal on August 5, 1998, the NRC speclflca(ly agreed with AlliedSlgnal that there was no special hazard associated with the FERMCO green salt.
Honeywell has attached the followlng documents to support this conc\\ualon:
Latter from P.G. Gasperini, Allied Signal, to NRC, "Retraction of Request for License Amendment,* dated July 17, 1998.
Letter from M. Lamastra, NRC, to P.G. Gasperini, AIUed Slgnal, "Amendment Request to Prooess Pu-239 Contaminated Material," dated August 5, 1998.
- 2. If so, were workers property trained for those hazards?
A5 noted above, there was (and Is) no special hazard associated with the Fernald green salt.
Since there were no pkrtonium or neptunium hazards resulting from green salt from the Femald fa<::ility, workers needed no special training for processing end handling the green salt (i.e., no additional training Is necessary beyond that normally required for site workers handling radiological materials).
No.
The investigation identified no exposure events Involving plutonium or neptunium.
- 4. If so, what were the levels and resuls?
Not applicable.
The investigation Identified no exposure events involving plutonium or neptunium.
Actions Planned No additional actions are considered necessary at this time.
5 8 /28
, 6185246385 Safety Trailer 02:08:23 p.m.
09 2013 Actions Taken This Investigation was conducted end a response was prepared as directed in the NRC's letter daed August 1, 2013. No further action is necessary.
Concern 2 - Unsubstantiated The Investigator reviewed the requirements of NRC license SUB-526 Issued to Honeywell ror the MTW facility and obtained Information and documentation regarding the activity of shipments of uranium, including those from Kazakhstan and Uzbekistan.
The investigator also interviewed Jason Cybulski, the MlW Site Services Manager, to obtain background information on MTW processes for receipt and sampling of incoming material. Mr. Cybulski has worked at MTW for 17 years and Is responslble for the supply chain and uranium Inventory control.
Honeywell's license authorizes It to possess up to 68 mHlion kg (150 mlHlon lbs} of natural uranium In the form of "yeHow cake,* u,o,. U02, UO,, UF4, UF,, and chemical intermediates of these compounds.
The license does not Impose any specific restrictions on the "activity: "specific activity," or "activity concentration* of natural uranium ore concentrates received by Honeywell.
Honeywell receives uranium ore concentrates in 55--gallon drums via common carrier from uranium mills throughout the world.' Each shipment Is unloaded at the Sampling Plant.
Each lot of concentrates Is weighed and stored on storage pads untll accountability procedures and uranium and impurity analyses are completed.
The uranium ore concentrates are sampled in the Sampling Pll!lnt (except for hard or wet ore) to obtain statlstically-slgnlflcant analytical samples In accordance with ASTM standards. T~ sampling results confirm that the material is natural uranium ore conoentrates, as defined In ASTM standards. In addition, MTW sampting procedures ensure that any material that deviates from the range of acoeptable ore concentrates is Identified and appropriate steps taken to address any safety concerns.
According to Mr. Cybulski, MTW does not currently receive ore from Russia. MTW does. however, receive ore from former Soviet republics, Including Kazakhstan and Uzbekistan.
Shipments from these countries are often referred lo colloqulally as
- Russian" ore. For the purpose of this report, the investigator assumes that the concern relates to ore concentrates from the former Soviet republics, rather than ore concentrates from Russia itself.
According to Mr. Cybulskl, uranium ore shipments are typically designed to maximize the amount of ore in a single shipment in order to minimize transportation costs. Because uranium concentrates sent from former Soviet republics may have a higher percentage of uranium relative to other elements or Impurities, shipments of ores from these locations often consist of fewer drums (with more weight per drum) In order to remain within acceptable transport limits. According to Mr. Cybulski, material from the former 3
According to 10 CFR 71.4, the natural uranium ore concentrates at MlW are low specific activity materials. The International Atomic Energy Agency (IAEA) also defines natural uranium as a low specific activity material.
6 9 /28
6]8524638~
Safety Trailer 02:09:37 p.m.
09 2013 Soviet republics is sometimes referred to internally as "the good stutr In reference to the fact that the concentrates typically have e higher peroentage of uranium on a per drum basis. The relatively higher percentage of uranium in the ore concentrates is also taken into account when blending various drums of material at the start of the UFa production process.
A review of shipment manifests addressing uranium from multiple locations Indicates that the total activity of a ahipmert of ore concentrates from former Soviet republic is comparable to that of ore concentrates sent from other locations. 4 However, ore concentrates from former Soviet republics may have a higher "activity concentration" than material from other locations If there ls more ur:anlum per drum.
6 4
5 6
Country of Origin Total Activity
- Drums Activity/drum*
Namibia 299 GBq 54 5.5 GBq/drum Australia 356 GBq 48 7.4 GBq/drum USA
- 344G8q 43 8.0 GBq/drum Namibia 388 GBq 46 8.4 GBq/drum Australia 440 GBq 48 9.2 GBq/drum Uzbekistan 322GBq 35 9.2 GBq/drum Kazakhstan 360 GBq 36 10.0 GBq/drum According to Mr. Cybulski, the samples listed are broadly representative of the range of material received by MTW.
For natural ore concentrates, activity is proportional to the quantity of uranium.
The term "activity concentration" is used to Indicate the activity per unit mass {or volume) of material and is simtlar to "specific activity." Specffic activity, however, Is typically reserved for use in reference to a pure sample of a radionuclide, while activity concentration Is used when referring to a material that contains radionuclides.
This represents the average activty concentration for drums of ore concentrates.
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, 618524.6385 Safety Trailer 02: 10:29 p.m.
09-27-2013 Country of Origin U(%)
U-234 so.. (%}(I)
Na(%)'.,
Namibla 73.22 54.10 ppm 2.27 1.83 USA 76.21 46.12 ppm 0.99 0.44 USA 78.92 51.47 ppm 0.44 0.52 USA 81.02 54.28 ppm 3.04 0.48 USA 81.29 53.81 ppm 1.89 0.54 Kazakhstan 83.30 54.08ppm 0.79 0.24 Australia 84.05 53.96 ppm 0.59 0.06 Uzbekistan 86.89 60.36 ppm 0.01
<0.01 (a)
SUifur and ICd.m n just &>No of many elements that may be b.M In 1nn11.1m ant ooncenlrates.
Thay are latld hll't lo help lllumlnlte the re.. one for dlfferencM In ul'91ium coneenlrl1lon*
among Mllllrial from dlffllrenl raglona.
Although the ore concentrates from former Soviet republics typlcaly have a higher activity concentration than material from other locations, the material stlll meets the definltfon of natural uranium ore concentrates per ASTM standards (e.g., ASiM C967, Standard Specification 'for Uranium Ore Concentrate).
The difference In activity concentration levels between a drum of material from a former Soviet republic and from another location is not significant from a safety perspective.
According to Sean Patterson, the Regulatory Affairs Manager (former1y Health Physics Supervisor) at MlW, no spacial precautions are necessary to account for the relatively small differences Jn activity concentration levels between ore concentrates from former Soviet republics and 01'8 concentrates from other locations. No addltlonal training or safety measures beyond those already In place at MlW are necessary because M1Ws Radiation Protection and ALARA programs are designed to provide protection for a wide range of radiological materials, including natural uranium ore concentrates with relatively higher activity concentrations.
Response to NRC questlona regardf ng Con cam No. 2:
- 1. Did the material from Russia have higher activity?
As discussed above, shipments of ore concentrates from the former Soviet republics typlcaffy have activity levels that are comparable to shipments from other locations. However, ore concentrates from the former Soviet republics often have a higher activity concentrations due to the relatively higher percentage of uranium In the concentrates.
The ore concentrates are stil, however, classified as natural uranium ore concentrates.
- 2. And If so, did it require additional training to ensure proper handling?
Ore concentrates from former Soviet republics do not require additional training or safety measures to ensure proper handling. As natural uranium, the activity concentrations of ore concentrates from former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MTW. In addition, MlW sampling procedures ensure that material that could pose additional safety concerns is identified and addressed.
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09-27-2013 Actions Planned No additional actlons are considered necessary at this time.
Actions Taken This investigation was conducted and a response was prepared as directed in the NRC's letter dated August 1, 2013.
concern 3 - unsubstantiated At MTW, anhydrous hydrofluoric acid (AHF) is brought onto the site via railcar. After the railcar containing the AHF Is brought into the Restricted Area of the site, the rallcar is stored on site until it is connected to the process line at the Feed Materials Buffding. The aUegation reiates specifically to the safety of the AHF rallcars stored at the site prior to being connected to the process line.7 To investigate the allegation, the Investigator reviewed the specifications and safety features of rallcars that contain AHF when stored onslte and conducted interviews with personnel regarding AHF storage.
AHF is shipped in railcars that meet or exceed DOT specifications, Including specffications requiring relief valves.1 RaHcars approved for the transport of AHF have relief valves set at a pressure that ensures a substantial margin between the pressure relief valve and the vapor pressure of the AHF in the railcar. 9 While being stored at MTW, the railcar is not connected to a scrubber system. However, a scrubber system is not necessary because the railcar is designed to withstand pressures significantly If'!
excess of the vapor pressure of the AHF in the railcar.
1 8
The Investigation did not specifically address the safety of rallcars once they are connected to the process lines et MTW because this Issue is outside the seope of the concern.
According to 49 CFR 173.244, AHF must be transported In tank cars having a test pressure of 300 psig or greater and conform to DOT Classes 105, 112, 114, or 120. The railcar ID data plate for one AHF railcar at MTW identifies the railcar as type DOT 112A500W.
This railcar type satisfies DOT requirements for shipment of AHF (see 49 CFR 173.244). The stenciling on the railcar identifies It as type DOT 112SSOOW. According to the GATX manual, rallcar type DOT 112SSOOW is the same railcar as DOT 112A500W, but equipped with head shields. According to the rallcar stenciling, the railcar is fitted with a safety valve set at 375 psig. Railcars of this type have a bursting pressure of at least 1250 psig. See49 CFR 179.101-1.
According to Jon Price, Technical Manager at MTW, the vapor pressure of AHF at the maximum reasonable ambient temperature at M1W, which is 100 degrees F, is approximately 13 pslg.
9 12 /28
6185246385 Safety Trailer 02:12:43 p.m.
09-27-2013 RNponse to NRC questions regarding Concern No. 3:
- 1. What features are required and/or available for rail cars stored onslte which may be subjected to an over pressurization event?
Railcars coraining AHF are required to meet DOT specifications. including specifications regarding relief valve presaure set polnw. The vapor pressure of AHF at the maximum reasonable ambient temperature at MlW Is approximately 13 psg.
Raicars designed to DOT specifications have rellef valves set at pressures significantly beyond those expected to occur at MTW. A scrubber system is not necessary In light of the significant differential between the vapor pressure of AHF end the relief valve set point.
Action* Planned No additional actions are consrdered necessary at this time.
Actions Taken This investigation was conducted and a response was prepared as directed In the NRC's letter dated August 1, 2013.
Concern 4 - unsubstantiated According to the concern, in the mld-1990s Individuals were not required to monitor out of the facility and could have been spreading contamination offsite. The concern states that one individual went home contaminated.
To respond lo this concern, the investigator reviewed records related to hletorfcal plant practices and any Incidents of offslte contamination during the period discussed In the concern. The investigator also conducted an interview with Sean Patterson, Regulatory Affairs Manager (fonnerly Health Phyaics Supervisor) at MTW.
Mr. Patterson was In the Health Physics department at MTW for 20 years.
During the Interview with Mr. Patterson, he explalned that, at least as far back as 1986, the license requirements for MTW required that persons workJng in *controlled" (I.e., UFe process) areas perform exit monitoring. Persons who did not work in process areas were not required to perform exit monitoring.
This is reflected In health physics prooodures In use at the time, as well as the NRC license for MTW, Issued on November 10, 1993, which states (at License Condition 17) that exit* monitoring Is required for persons exiting contamination controlled areas.
In the mld-1990s, MTW changed practices to require that all persons exiting the Restricted Area (I.e., the area within the inner security fence) perform exit monitoring.
The MTW license renewal application, dated July 11, 1994, state8 In Section 3.2.1 that visitors and employees who have worked in, or visited, the Restricted Area at the site must perform personal exit monitoring upon leaving the Restricted Area.
That requirement, which was Incorporated by reference into the renewed M1W license, was also reflected in the Health Physics Procedure for Contamination Control no later than 1996.
10 13 /28
61852463,85 Safety Trailer 02:13:SOp.m.
09-27-2013 The Investigation did not reveal any specfflc incident that led to the change in procedure.
And, the precise date of the change in practice at MTW could not be ascertained because of the manner in which MlW license documentation was maintained. At the time, changes to the license were incorporated by removing a page and replacing it with a new page. Based on the interview with Mr. Patterson, the change in practice was likely made sometime in the mid-1990s, which would be consistent with the license renewal application filed in 1994. The current MlW license renewal application (Section 3.2.1), which is also incorporated Into the current MlW llcense, continues to require exit monitoring for all persons leaving the Restricted Area. 10 The license application also states that Honeywell shall not permit an individual to exit the Restricted Area with skin or clothing contamination at levels exceeding the guidanoe provided in Section 2.6 of Regulatory Guide 8.30 without specffic Health Physics approval.
With respect to offsite contamination events, MTW reported that records reviewed to respond to the request for information did not reveal any Instances of offslte contamination during the period of time discussed in the concern. Based on a review of personnel exit survey reports from January 1991 through April 1992, all personnel were documented as performing exit monitoring correctly. These reports, however, appear to be a random sampling of employee exit monitoring practices, not formal dally documentation of employee exit records. Health Physie& technician log books for the period between February 1995 and October 1999 identified 45 contamination events at the exit monitor. However, In all cases the employee was decontaminated prior to leaving the facility. Based on a review of Incident & Spill Reports from 1996 through 1999, there was one report regarding an instance of PPE being worn outside the Restricted Area. Upon Investigation, It was determined that the employee's street clothes, which were being worn under his plant overalls, had been contaminated while at the plant. Before leaving the site, the employee dressed In a new pair of coveralls, was monitored and found clean, and then left the plant wearing the coveralls. There was no offsite contamination.
Mr. Patterson also recalled one Instance in 2000 In which an employee's home and personal vehicle were surveyed following a urine sample result that showed relatively high amounts of uranium. According to contemporaneous documentation,* follow-up urine samples did not show the same high levels. of uranium. Nevertheless, MTW personnel perfonned surveys of the employee's home, including steps and sidewalk, as well as the employee's personal vehicle. No survey readings were above background levels.
Response to NRC questions regarding Concern No. 4:
10
- 1. Provide information regarding offsite contamination event(s) and corrective actions resulting from any event(s) which occurred In the mid 90s.
The investigation did not reveal any records or reports of offsite contamination In the 1990s. There was a change in MTW practices related to exit monitoring that occurred in the mid~ 1990s. Speclflcally, M1W transitioned from requiring exit monitoring only for persons working In process areas to requiring exit monitoring MTW-SOP-HP-0112, "Release of Personnel, Materials, Equipment, and Transport Vehicles from the Restricted Area."
11 14 /28
6.185246385 Safety Tr a lier 02:15:11 p.m.
09 2013 for all persons exiting the Restricted Area of the site. A review of available documentation did not Indicate whether the change was made as a corrective action foUowing a particular incident, In conjunction with license renewal, or as part of site continuous improvement or ALARA efforts.
Actions Planned No additional actions are considered necessary at this time.
Actions Taken This Investigation was conducted and a response was prepared as directed In the NRC's letter dated August 1, 2013.
CONCLUSION After reviewing the evidence. the Independent Investigator concludes that:
Concern 1: *in the mid 90s, worl<ers were unknowingly exposed to Plutonium and Neptunium while processing green salt from the Fernald Department of Energy (DOE) facility is unsub&tantJated. Green salt from Fernald did net contain plutonium or neptunium in analytically slgnlflcant quantities.
Concern 2: "Wor1<'ers did not receive proper training or protection while handlfng higher sctivlty material from Russia to be oonverted Into uranium hexsfluortde (UFJ" Is unsubstantiated. While material from former Soviet republics typically has a higher activity concentration than material from other locations, additional training and protections are not warranted.
Concam 3: "The rsilcsrs stored on-site for transfer of anhydrous hydroffuorlc acid (AHF) to Iha Feed Materials Bui/ding sre not properly configured with a relief system In the event of an over-pressurization and are not connected to a scrubber system" ls unsubstantiated. Rallcars used to store AHF are required to have pressure relier valves with appropriate set points. Although the rallcars are not connected to a scrubber system while being stored at the site, no scrubber system is necessary given the substantial margin between the vapor pressure of AHF and the relief valve set point.
Concern 4: *in the mid 90s, individuals were not required to monitor out of the facility and could have been spreading contamination offslte. One individual was noted to have gone home contaminated" ls unsubstantiated. Whlle MlW at one time required exit monitoring only for personnel working In process areas, by the mld-1990s all persons leaving the Restricted Area of the site were required to perform exit monitoring. In addition, no records or reports were found of offsite contamination during the period of interest.
12 15 / 28
61852463.85 Safety Trailer AUACl1MENTS List of Attachments 02:16:11 p.m.
09-27-2013
- 1. Letter from P.G. Gasperini, Allied Signal. to NRC, "Retraction of Request for License Amendment," dated July 17, 1998.
- 2. Letter from M. Lamastra, NRC, to P.G. Gasperini, Allied Signal, *Amendment Request to Process Pu-239 Contaminated Material," dated August 5, 1998.
- 3. Representative rancar stenciling
- 4. Representative railcar ID plate Ust of Persons lntervieW&d J. Cybulski J. Price S. Patterson 13 16 /28
Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 August23,2013 CERTIFIED...
r_)(-?)-(C_) _____
James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 DocketNo.40-3392 License No. SUB-526 RE:
HONEYWELL METROPOLIS WORKS' REQUEST TO EXTEND RESPONSE PERIOD TO ALLEGATION Rll-2013-A-0100 Honeywell This communication Is with regard to Honeywell Metropolis Works' response to the Allegation Rll-2013-A-0100 requested in the NRC letter dated August 11 2013. The NRC asked that Honeywell evaluate the information described in the enclosure to the letter and submit the results of that evaluation to Region II within 30 days of the date of the letter.
Evaluating the concerns identified in the subject NRC letter, Honeywell determined that it needs additional time to finalize the findings related to the validity of the Allegation Rll-2013-A-0100. Consequently, Honeywell requests to extend the response period to sixty (60) days of the date of the NRC letter transmitting the Allegation Rll-2013-A-0100.
If you have questions, or wish to discuss this matter, please contact _!(b_)(7_ )_cc_) ___
!(b )(7)(C)
~
Mr. Oscar de Miranda, Senior Allegation Coordinator Enforcement and Investigations Coordination Staff Office of the Regional Administrator, Region II U.S. Nuclear Regulatory Commission 245 Peachtree Center Avenue NE, Suite 1200 Atlanta. GA 30303-1257
l El
- COMPLETE TJ-115 SECTION COMPLETE T/1/S SECTION ON DELIVERY
- Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired.
- Print your name and address on the reverse so that we can return the card to you.
- Attach this card to the back of the mail piece or on the front If space permits.
- 1. Article Addressed to:
(b)(?)(C)
Honeywell Metropolis works P.O. Box 430 Metropolis, IL 62960
- 2. t N~mber (11..,,:;re, from service label) t PS Form 3811, February 2004 (b)(?)(C)
(b)(?)(C) 0 Agent 0 Addressee C. Date of Delivery D. Is dellve,y address different from Item 1? D Yes If YES, enter dellve,y address below:
D No
- 3. SSrvlceType ~/ -~101',- *r olcertilled Mau D Express Mail D Registered D Return Receipt for Merchandise 0 Insured Man O C.0.0.
- 4. Res1rlcted Deliveiy? {8(tra Fee) 0 Yes 102695-02-M-1540
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION It 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA. GEORGIA 30303-1257 r b)(7)(C)
Honeywell International Inc.
P.O. BOX 430 Metropolis, IL 62960 August 1, 2013
SUBJECT:
ALLEGATION NO. Rll-2013-A-0100 Dear!(b )(?)(C) l The U.S. Nuclear Regulatory Commission (NRC) recently received information concerning activities at the Honeywell Metropolis Works facility in Metropolis, Illinois. We request that Honeywell evaluate the information described in the Enclosure to this letter and submit the results of that evaluation to Region II. Within 30 days of the date of this letter, we ask that you inform Mr. Oscar DeMiranda, in writing, the details of your evaluation and your findings related to the validity of the information provided. If Honeywell determines a concern to be substantiated, please discuss Honeywell's consideration of appropriate root or apparent causes and generic implications of the substantiated concern. and the appropriateness of corrective actions taken or planned commensurate with the significance of the issue. Additionally, if your evaluation identifies any compliance issue with regard to NRC regulatory requirements or NRC commitments, please inform us regarding the requirement or commitment that was violated, the corrective actions taken or planned, and the corrective action documentation that addressed the issue. We ask that you reference our tracking number (Rll-2013-A-0100) in your written response and, also, make any records of your evaluation available for possible NRC inspection.
The NRC will review your response to determine whether: (a) the individual conducting the investigation was independent of the organization with responsibility for the related functional area; (b) the evaluator has sufficient knowledge and experience to conduct a review in the related functional area; and (c) the evaluation was of sufficient depth and scope. Your response should describe how each of these attributes was satisfied. If individuals were interviewed as part of your review, your response should include the basis for determining that the number and cross section of individuals interviewed was appropriate to obtain the information necessary to fully evaluate the concern(s), and the interview questions used. If your evaluation included a sample review of related documentation and/or potentially affected structures, systems. and components, your response should include the basis for determining that the selected sample size was appropriately representative and adequate to obtain the information necessary to fully evaluate the concern(s)" The NRC will consider these factors in reviewing the adequacy of your evaluation of this/these issue(s) and in developing our conclusions with regard to the concerns provided in the Enclosure.
CERTIFIED MAIL NUMBER._!tb_H_7}_tc_1 _____
RETURN RECEIPT REQUIRED
2 Rll-2013-A-0100 We request that your response only be sent to Mr. Oscar DeMiranda, Senior Allegation Coordinator. EICS, Office of the Regional Administrator, Region II, at the following address:
P. 0. Box 56274. Atlanta, GA 30343, and fax him a copy at 404-997-4903. No other copies should be sent to the NRC, i.e., your response should not be docketed or otherwise submitted to the NRC Document Control Desk. We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response. please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld, and provide in detail the.bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
This letter and its Enclosure should be controlled and distribution limited to personnel with a "need to know." The response requested by this letter and the accompanying Enclosure are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L.96-511.
Lastly, we ask that you contact the NRC as your review effort begins, to assure a common understanding of the issues discussed in the Enclosure, and the NRC's expectations for follow-up and response, and to discuss your plan to evaluate the issues. Please contact James Hickey at 404-997-4628 with this information. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424.
Enclosure:
As stated James. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection
~,OT FOR PUBLIC DISCLOSURE HONEYWELL METROPOLIS WORKS WORKERS UNKNOWINGLY EXPOSED TO LICENSED MATERIALS ALLEGATION NUMBER Rll-2013-A-0100 The NRC has received information that:
Non Responsive Record Concern No. 2:
Workers did not receive proper training or protection while handling higher activity material from Russia to be converted into uranium hexafluoride (UF5).
l (b)(4)
L Did the material from Russia have
- v And if so, did it require additional training to ensure proper handling?
Non Responsive Record f'40T FOR PUBLIC DISCLOSURE Enclosure
(b)(?)(C) 2 Rll-2013-A-0100 We request that your response only be sent to Mr. Oscar DeMiranda, Senior Allegation Coordinator, EICS, Office of the Regional Administrator, Region II, at the following address:
P. 0. Box 56274, Atlanta, GA 30343, and fax him a copy at 404-997-4903. No other copies should be sent to the NRG, i.e., your response should not be docketed or otherwise submitted to the NRC Document Control Desk. We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld, and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personaJ privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
This letter and its Enclosure should be controlled and distribution limited to personnel with a "need to know.~ The response requested by this letter and the accompanying Enclosure are not subject to the* clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L.96-511.
Lastly, we ask that you contact the NRC as your review effort begins, to assure a common understanding of the issues discussed in the Enclosure, and the NRC's* expectations for follow-up and response, and to discuss your plan to evaluate the issues. Please contact James Hickey at 404-997-4628 with this information. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424.
OFFICE
~Rll:DFFI SIGNATURE
~
NAME RGibson DATE 7/3 I /2gJ..:l E-MAIL COPY YES l!W' Rll:EICS vf,L_
ODeMiranda fit J /2013 YES NO Sincerely, James A Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection e,..-._OffJ.
Ai,[_ A
- s'~,t..,µ;;:.{
~J,j u,~
,,Jo OFFICIAL RECORD COPY DOCUMENT NAME.
G.\\PROTECTED\\ALLEGATIONS\\DFFI\\BRANCH 2\\HONEYWELL RFI LETIER Rll-2013-A-0100.DOCX
RFI LICENSEE CALLBACK RECORD OF CONVERSATION Allegation Number: Rll-2013-A- -0100 Responsible Branch: DFFI/FFB2
Background:
AGM 2008*001 requires that the licensee contact the responsible branch chief, or other appropriate staff, to ensure common understanding of the scope of the allegation and the staff's expectations for follow-up and response. During this discussion, the staff should be mindful not to dictate specific requirements that may restrict or limit the licensee's response. Rather, this discussion is intended to ensure that the actions proposed by the licensee to evaluate the allegation concern(s) appear likely to result in a product that meets the NRC's stated expectations and thoroughly addresses the concern(s) raised. If upon completion of this or subsequent discussions, it is determined that the licensee's plan of action is unlikely to be successful, the responsible Branch Chief will reconvene the ARB to consider a follow-up telephone call with senior licensee management, or NRC inspection activity. A record of the conversation with the licensee shall be included in the allegation file.
Date of Phone Call: 08/02/2013 (b)(7)(C)
Name of Licensee
Contact:
Summary of Conversation: Confirmed understanding of RFI concerns licensee's plan of action sounded reasonable: ~ Y D N If no, please state Why:
Describe any additional actions needed: NIA Re*ARB required: D Y [8J N Prepared by: Jim Hickey
Title:
Branch Chief Date Prepared: 8/2/2013 Please return this to EICS (R2EICSA11eg@nrc.gov) along with any supporting documentation available (e.g. e-mail from licensee, etc.), if any.
UNITED ST ATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 August 1, 2013 Mr. Larry Smith Plant Manager Honeywell International Inc.
P.O. BOX430 Metropolis, IL 62960
SUBJECT:
ALLEGATION NO. Rll-2013-A-0100
Dear Mr. Smith:
The U.S. Nuclear Regulatory Commission (NRC) recently received information concerning activities at the Honeywell Metropolis Works facility in Metropolis, Illinois. We request that Honeywell evaluate the, information described in the Enclosure to this letter and submit the results of that evaluation to Region II. Within 30 days of the date of this letter, we ask that you inform Mr. Oscar DeMiranda, in writing, the details of your evaluation and your findings related to the validity of the information provided. If Honeywell determines a concern to be substantiated, please discuss Honeywell's consideration of appropriate root or apparent causes and generic implications of the substantiated concern, and the appropriateness of corrective actions taken or planned commensurate with the significance of the issue. Additionally, if your evaluation identifies any compliance issue with regard to NRC regulatory requirements or NRC commitments, please inform us regarding the requirement or commitment that was violated, the corrective actions taken or planned, and the corrective action documentation that addressed the issue. We ask that you reference our tracking number (Rll-2013-A-0100) in your written response and, also, make any records of your evaluation available for possible NRC inspection.
The NRC will review your response to determine whether: (a) the individual conducting the investigation was independent of the organization with responsibility for the related functional area; (b) the evaluator has sufficient knowledge and experience to conduct a review in the related functional area; and (c) the evaluation was of sufficient depth and scope. Your response should describe how each of these attributes was satisfied. If individuals were interviewed as part of your review, your response should include the basis for determining that the number and cross section of individuals interviewed was appropriate to obtain the information necessary to fully evaluate the concern(s), and the interview questions used. If your evaluation included a sample review of related documentation and/or potentially affected structures, systems, and components, your response should include the basis for determining that the selected sample size was appropriately representative and adequate to obtain the information necessary to fully evaluate the concern(s). The NRC will consider these factors in reviewing the adequacy of your evaluation of this/these issue(s) and in developing our conclusions with regard to the concerns provided in the Enclosure.
CERTIFIED MAIL NUMBER 7011 2000 0001 0083 4597 RETURN RECEIPT REQUIRED
(b)(7)(C) 2 Rll-2013-A-0100 We request that your response only be sent to Mr. Oscar DeMiranda, Senior Allegation Coordinator, EICS, Office of the Regional Administrator, Region II, at the following address:
P. 0. Box 56274, Atlanta, GA 30343, and fax him a copy at 404-997-4903. No other copies should be sent to the NRC, i.e.. your response should not be docketed or otherwise submitted to the NRC Document Control Desk. We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response. please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld, and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information wlll create an unwarranted invasion of personal privacy or provide the information requlred by 1 O CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21 This letter and its Enclosure should be controlled and distribution limited to personnel with a "need to know. The response requested by this letter and the accompanying Enclosure are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L.96-511 Lastly, we ask that you contact the NRC as your review effort begins, to assure a common understanding of the issues discussed in the Enclosure. and the NRC's expectations for follow-up and response, and to discuss your plan to evaluate the issues. Please contact James Hickey at 404-997-4628 with this information. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424.
Enclosure:
As stated Sincerely,
/RAJ James A Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection
, I (b)(7)(C) 2 Rll-2013-A-0100 We request that your response only be sent to Mr_ Oscar DeMiranda, Senior Allegation Coordinator, EICS, Office of the Regional Administrator, Region 11, at the following address:
P. 0. Box 56274, Atlanta, GA 30343, and fax him a copy at 404-997-4903. No other copies stiould be sent to the NRC, i.e.* your response should not be docketed or otherwise submitted to the NRC Document Control Desk. We also request that your response contain no personal privacy, proprietary, or safeguards information. If personal privacy or proprietary information is necessary to provide an acceptable response, please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld, and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
This letter and its Enclosure should be controlled and distribution limited to personnel with a "need to know." The response requested by this letter and the accompanying Enclosure are not subject to the clearance procedures of the Office of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L.96-511.
Lastly, we ask that you contact the NRC as your review effort begins, to assure a common understanding of the issues discussed in the Enclosure, and the NRC's expectations for follow-up and response, and to discuss your plan to evaluate the issues. Please contact James Hickey at 404-997-4628 with this information. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424 OFFICE Rll:OFFI SIGNATURE IRA/
NAME RGibson DATE 7/ 31
/2013 E-MAIL COPY YES NO Rll:EICS CEvans for ODeMlranda 8/1/2013 YES NO Sincerely, IRA/
James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection OFFICIAL RECORD COPY DOCUMENT NAME_
G:\\PROTECTED\\ALLEGATIONS\\DFFI\\BRANCH 2\\HONEYWELL RFI LETTER Rll-2013-A-0100.DOCX
NOT FOR PUBLIC DISCLOSURE HONEYWELL METROPOLIS WORKS WORKERS UNKNOWINGLY EXPOSED TO LICENSED MATERIALS ALLEGATION NUMBER Rll-2013-A-0100 The NRC has received information that:
Concern No. 1:
In the mid 90's workers were unknowingly exposed to Plutonium and Neptunium while processing green salt from the Fernald Department of Energy (DOE) facility.
Determine if a Plutonium and Neptunium hazard resulted from processing green salt from the Fernald DOE facility. If so, were workers properly trained for those hazards? Were there any exposure events involving Plutonium and Neptunium? If so, what were the levels and results?
Concern No. 2:
Workers did not receive proper training or protection while handling higher activity material from Russia to be converted into uranium hexafluoride (UFa).
Did the material from Russia have higher activity? And if so, did it require additional training to ensure proper handling?
Concern No. 3:
The railcars stored on-site for transfer of anhydrous hydrofluoric acid (AHF) to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization and are not connected to a scrubber system.
What features are required and/or available for rail cars stored onsite which may be subjected to an over pressurization event?
Concern No. 4:
In the mid 90's individuals were not required to monitor out of the facility and could have been spreading contamination offsite. One individual was noted to have gone home contaminated.
Provide information regarding offsite contamination event(s) and corrective actions resulting from any event(s) which occurred in the mid 90's.
NOT FOR PUBLIC DISCLOSURE Enclosure
,.. -100 Checkle, Melanie (b)(5) 1
CheckJe, Melanie lb)(5) 13,too
~~
{~!Ji James Hickey Chief, Fuel Facility Inspection Branch 2 Region II 404-997-4628 l(b)(7)(C)
I James.Hickey@nrc.gov 2
\\j -\\00 Checkle, Melanie From:
Hickey, James Sent:
Wednesday, December 04, 2013 6:52 AM To:
R2Allegations Resource; (heckle, Melanie
\\OO
Subject:
Update: Voicemail from O regarding closure letter. Ril-2013-A~~
~
(b}(7)(C)
I received two voicemails from the Cl while I was out of the office on 12/4. I will give the Cl my cell phone# to call me when he gets off work.
- Regards, Jim From: Hickey, James Sent: Monday, December 02, 2013 2:59 PM To: R2ALLEGATIONS@NRC.GOV; Checkle, Melanie
Subject:
Voicemail from a regarding closure letter. RII-2013-A-2013 I received a voicemail on 11/29/2013 from the Cl. It appears he has questions regarding our closure letter.
attempted a callback this morning and left a voice message.
- Regards, Jim James Hickey Chief, Fuel Facility Inspection Branch 2 Region II 404-99 7 -4628 l(b)(7)(C)
I James.Hickey@nrc.gov l
Checkle, Melanie From:
Sent:
To:
Subject:
Gibson, Richard Thursday, August 22, 2013 2:01 PM (heckle, Melanie RE: Ril-2013-A-0100 (Sensitive Allegation Material I've just called him, and he was appreciative.
Richard From: Checkle, Melanie Sent: Thursday, August 22, 2013 1:57 PM To: Gibson, Richard
Subject:
Re: Ril-2013-A-0100 (Sensitive Allegation Material If you know the status, you can give him a call. All you have to tell him is that the concerns are still under review and that we are awaiting the response to our request for information from the licensee. That's pretty much all we can tell him at this point. Thanks.
Melanie, (b)(7)(C) called me and left a message. He wanted to know the status of his concerns. He can be con ac e at:
Do you wish to contact hrm? Or, do you want me to contact him? We have an RFI to the licensee that is due by August 30, 2013.
ran Responsive Record Concern 2: Workers did not receive proper training or protection while handling._!(b-)(
4_l ______ _.L.
f
°" R~po,oi" R~o,d Richard 1
Checkle, Melanie From:
Checkle, Melanie Sent:
Thursday, August 01, 2013 1:26 PM To:
Cc:
Hickey, James; Peterka, Nicholas; Gibson, Richard; DeMiranda, Oscar Evans, Carolyn
Subject:
RE: 13-100 Concern 4 - Phone Call from Q #1 *SENSIDVE INFORMATION*
Thanks Jim. When closing Concern 4 with Cl #1, please make reference to my conversation with him yesterday and what I explained to him (that we would review the information but would make a determination of whether or not we needed to followup). I just don't want him to feel like we just ignored his request.
Jrt.e[anie <M.. CliecfiJe Allegation Coordinator Enforcement and Investigation Coordination Staff U.S. Nuclear Regulatory Commission 404.997.4426
- If this email contains sensitive allegation information, please delete when no longer needed.*
From: Hickey, James Sent: Thursday, August 01, 2013 7:16 AM To: Peterka, Nicholas; Checkle, Melanie; Gibson, Richard; DeMiranda, Oscar Cc: Evans, Carolyn
Subject:
RE: 13-100 Concern 4 - Phone Call from CI #1 *SENSffiVE I NFORMATION*
We will include concern #4 in our RFI.
From: Peterka, Nicholas Sent: Wednesday, July 31, 2013 11:07 AM To: Checkle, Melanie; Hickey, James; Gibson, Richard; DeMiranda, Oscar Cc: Evans, Carolyn
Subject:
RE: 13-100 Concern 4 - Phone Call from Q #1 *SENSITIVE INFORMATION*
- Melanie, r i(7i(CJ Nick From: Checkle, Melanie Sent: Wednesday, July 31, 2013 10:48 AM To: Hickey, James; Gibson, Richard; DeMiranda, Oscar Cc: Evans, Carolyn; Peterka, Nicholas
Subject:
13-100 Concern 4 - Phone Call from CT # 1 *SENSI11VE INFORMATION*
FFB2 and Oscar, l
Non Responsive Record 2
Checkle, Melanie From:
Gibson, Richard Sent:
To:
Friday, July 12, 2013 10:09 AM Checkle, Melanie
Subject:
RE: !!!!!WARNING - S~f4.!!Ffh'E ALLE6A"FIOP4 P.V.;;i;:EFY,.O.b!!!!!
Yes. {bJ(7)(C)
Richard From: Checkle, Melanie Sent: Friday, July 12, 2013 9:54 AM To: Gibson, Richard
Subject:
RE: !!!!!WARNING. SENSR=I'IE ALL[GA.+.[Q~I MA+ilaYAI..!!!!!
H~H. C!Wd.t A~~
~MJ.k-l/~~~
U.S. N<<dl#> R~ ~
404.1fl.4426 "If this email contains sensitive allegation information, please delete when no longer needed.*'
From: Gibson, Richard Sent: Thursday, July 11, 2013 3:30 PM To: R2EICS Cc: Checkle, Melanie
Subject:
FW: !!!!!WARNING- ~-~l~Wl'E Al I FGAJTQN MAJFRTAU!!!!
Let me know if you need additional info.
From: Peterka, Nicholas sent: Thursday, July 11, 2013 3:05 PM To: Gibson, Richard
Subject:
! ! ! ! !WARNING - ~NSl I IVE ALLE6,;i;JQ~I MAIER JAL I.LJ.! !
- Richard, As discussed, lease see the attached documents. The Part 1 and 2 documents capture the concerns and the last document (b)(7)(Ci contact information. Thanks for submitting it and reviewing the concerns.
Nick Peterka Nicholas Peterka USNRC Region It Division of Fuel Facility Inspection Fuel Facility Inspector, Branch 3 1
404-997-4556 2
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- 1. Article Addressed to:
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Number ft,_..,7bf' from service label)
COMPLETE rHIS SECTION ON DELIVERY D. Is delivery address different from item 1?
If YES, enter deliveiy address below:
- 3. Serl9C8lype
- c92)l3--:. -c G,1'6ertlfled Mall O Express Mell D Regist81'8d O Return ReceJpt for Mffl:handlse 0 Insured Mail O C.O.D.
- 4. Restricted OeUveiy? (Extra Fee) 0 Yes
- PS Form 3811, February 2004 1
Domestic Return Receipt 102595-02-M-1640 ;
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 21, 2013
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100
Dear!(b)(7)(C) I:
The Nuclear Regulatory Commission (NRC) has com leted its follow u se to Concern brought to o~u~r.!;:a~tt~e!.!.nt~io~n~(~bJ~( :;.
J c..:.1 ___________
......_._1 (b)( )( )
re rding: Non Responsive Record r.;..,=~---~~------------.,..
e enc osure o 1s etter restates your concerns and describes the NRC's review and conclusions with regard to those concerns.
Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call me toll-free at 1-800-577-8510 ext. 4628 or you may provideinformation to me in writing at P.O. Box 56274, Atlanta, GA 30343.
- 7
Enclosure:
As stated CERTIFIED MAIL NUMBER 1...l(b_l(_,,_(c_, _____
RETURN RECEIPT REQUESTED
(
Non Responsive Recoro RESPONSE TO CONCERN HONEYWELL METROPOLIS WORKS ALLEGATION NO. RU-2013-A-0100 Enclosure
2 Rll-2013-A-0100 Non Responsive Record Concern 2:
Workers did not receive proper training or protection while handling Ll(b_Jc_4' ______ ___.!from Russia to be converted into UFa.
Background Information:
You stated that workers were exposed to!(b~(4;
!when they began processing drums of material from Russia. You also s a ed that the workers did not received additional training or personal protection equipment to handle the!Cb)C4l I
Response to Concern:
The NRC requested that MTW evaluate and respond to the concern, and the NRC inspector reviewed the response. Honeywell selected an Jndependent lnvesti ator which erform d interviews with the MTW b) 7 (C) i.:.(b.:.:.)(7..:.)(:_C;..J --------r-~------'
(bJ(7J(CJ
. According to the (b)(7)(C) shipments of ore concentrates from the former So, iet republics c;Cb~l(~4l:._ _______________
!(b)(4J J However, ore concentrates from the former S v*
can have (b)(4J (b)(4J e ore concentrates are still, however, classified as natural uranium.
The investigator reviewed records and interviewed personnel and determined that the ore concentrates from the former Soviet republics do not require additional worker training or safety measures to ensure proper handling. As natural uranium, the activity concentrations of ore concentrates from the former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MTW.
==
Conclusion:==
The NRC has not observed a~y problems wjth 1 oneywell's workers receiving proper training or protection while handling !(bJt7J(cJ from the former Soviet republics to be converted into UFs. The NRC inspector was unable to substantiate the concern.
Non Responsive Record Enclosure
3 Rll-2013-A-0100 Non Responsive Rec,rrd Enclosure
I f
4 Rll-2013-A-0100 Non Responsive Record Enclosure
OFFICE October 21, 2013
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS - ALLEGATION Rll-2013-A-0100 Dearj!b)(7)(C) j:
Non Responsive Record Non Responsive Record The enclosure to this letter restates your concerns and describes the NRC's review and conclusions with regard to those concerns.
Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call me toll-free at 1-800-577-8510 ext. 4628 or you may provide information to me in writing at P.O. Box 56274, Atlanta, GA 30343.
Enclosure:
As stated 5/t}J,Y, James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER....
!lb_}(_7)_(c_, _____ __
RETURN RECEIPT REQUESTED RII: DFFI Rll; EICS tt,~fr SIGNATURE
//1/-;,d NAME RGibson DATE 10/
/2012 E-MAIL COPY?
YES NO OFFICIAL RECORD COPY 2 Rll-2013-A-0100.DOCX ODeMiranda 13' r-r.,.., _1.c/
10/ /2012 101-i, /2013' 10/
/2013 10/
/2013 10/
/2013 10/
YES NO YES NO YES NO YES NO YES NO YES DOCUMENT NAME: G:\\PROTECTED\\ALLEGATIONS\\DFFI\\BRANCH 2\\LETIER TO ALLEGER
/2013 NO
OFFICE r b)(7)(C)
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS - ALLEGATION Rll-2013-A-0100
Dear!(b){7)(C) I:
The Nuclear Regulatory Commission (NRC) has completed its follow u review in response to Concerns 1-4 ou initially brought to our attention {bl(7l(Cl
{b){ )(C) re ardin '. ""'N-on..,.R.-es-p-011...,.
siv-e""'R-ec-or""'
d ----------------.
Non Responsive Record
- 2) workers did not receive proper training or protection while handling (b)(4)
~~---""'--i from Russia to be converted into UFe, Non Responsive Record Non Responsive Record Non Responsive Record e enc OSUre O IS e er res a es your concerns an describes the NRC's review and conclusions with regard to those concerns.
Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call rne toll-free at 1-800-577-8510 ext. 4628 or you mqy provide information to me in writing at P.O. Box 56274, Atlanta, GA 30343.
Enclosure:
As stated Sincerely, James A Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER~ )(?)(C1 RETURN RECEIPT REQUEs-=.,r"""e--0-------....
RII* DFFI RII: EICS SIGNATURE iD t725Y1 NAME RGlbson DATE 10/2)/2012 E-MAIL COPY?
YES fN97 OFFJCIAL RECORD COPY 2 Rll-2013-A--0100.00CX OOeMlranda 10/lf/2012 10/
/2013 10/
/2013 10/
/2013 10/
/2013 10/
YES NO YES NO YES NO YES NO YES NO YES DOCUMENT NAME: G:\\PROTECTEDIALLEGATIONS\\DFFI\\BRANCH 2\\LEn ER TO ALLEGER
/2013 NO
II
- COMPLETE THIS SECTION
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- Print your name and address on the reverse so that we can return the card to you.
- Attach thls card to the back of the mallpiece, or on the front If space permits.
- 1. Artlcle Addressed to:
2 i
~,.. _...__
COMPLETE THIS SECnON ON DELIVERY D Agent D Addressee 1
- Date of Delivery '
D. Is delvery address different from Item 1? D Yes If YES, enter dellvery address below:
D No
- 3. sepl(ce lype ef' Oertllled Ma11 a Express Ma11 D Reg181ie,&d a Return Receipt for Merchandise I 0 lnsun,d Mail Cl C.O.D.
- 4. Restricted Dellvery? (Extra Fee) 0 Yes PS Form 3811. February 2004 Domestic Return Receipt
)ll.259S-02*M*1540
r b)(7)(CI UNITED STA TES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 25, 2013
SUBJECT:
Concerns You Raised to the NRC Regarding Honeywell -
Allegation Report Rll-2013-A-0100 Dead(b)(7)(C) !:
This letter ref r to
- sion (NRG staff members (bl(7l(C Ourin (bl(7l(Cl (b)(7)(CJ you expressed concerns related to several issues at Honeywell. (b)(7)(CJ (b)(7)(C)
(b)(7)(C) to this letter documents your concerns as we understand them. We have initiated actions to evaluate your concerns and will inform you of our findings. The NRG normally conducts an evaluation of a concern within six months, although complex issues may taKe longer. If the description of any of your concerns. identified as Concerns 1. 2, 3 and 4, as noted in Enclosure 1 is not accurate, please contact me so that we can assure that your concerns are appropriately described and adequate\\y addressed prior to the completion of our review, As part of our response to Concern 1, 2, 3, and 4, we intend to request Honeywell to perform an evaluation and provide a written response to the NRC. Your name and any other identifying information w,11 be excluded from the information that is provided to Honeywell in the request for information. We will request that Honeywell's evaluation be thorough, obiective, and that the evaluator be independent of Honeywell management responsible for oversight of the functional area related to your concerns. We will evaluate Honeywell's response, and consider it in developing our conclusions regarding your concerns. We will inform you of our disposition once we have evaluated Honeywell's response and taken any additional actions, if necessary, to address your concerns. In your conversation with Mr. Nicholas Peterka, NRC staff member, on
!(b)(7lCCJ
- l. you indicated that you would not object to the NRC requesting information from the licensee with regard to your concerns.
Enclosed with this letter is a brochure entitled "Reporting Safety Concerns to the NRG," which includes an important discussion of the identity protection provided by the NRG regarding these matters as well as those circumstances that limit the NRC's ability to protect an alleger's identity, such as this case. Please read that section of the brochure.
If a request is filed under the Freedom of Information Act (FOlA} related to your areas of concern, the inforn:iation provided will, to the extent consistent with that act, be purged of names CERTIFIED MAIL:l[b)(?)(C)
RETURN RECEIP""T"""'R"""'E...
Q..... U"""E.....
S...
TE.,....D------------------
2 Rll-2013-A-0100 and other potential identifiers. Further, you should be aware you are not considered a confidential source unless confidentiality has been formally granted in writing.
Thank you for notifying us of your concerns. We will advise you when we have completed our review of Concerns1, 2, 3 and 4. Should you have any additional questions, or if the NRC can be of further assistance, please call me at the regional office toll-free number 1-800-577-8510 extension 4426 or you may provide information to me in writing at P. 0. Box 56274, Atlanta, GA 30343. You may also communicate with me by electronic mail, if you so choose. However, when doing so. please call me in advance or provide your phone number in your e-mail message so that she can confirm that you are the source of the information. Also. please be advised that the NRC cannot protect the information during transmission on the Internet and there is a possibility that someone could read your response while it is in transit. My e-mail address is Melanie.Checkle@nrc.gov
Enclosures:
As stated Sin~1[elr,
~
?--z., _
Melanie M. Checkle Allegations Coordinator Enforcement and Investigations Coordination Staff Rll-2013-A-0100 HONEYWELL STATEMENT OF CONCERNS Non Responsive Record Concern 2:
Workers did not receive proper training or protection while handling!(b)(
4
)
I from Russia to be converted into UF6.
Non Responsive Record
Er
- COMPLETE THIS SECTION
- Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired.
- Print your name and address on the reverse so that we can return the card to you.
- Attach this card to the back of the mailpiece, or on the front if space permits.
- 1. Article Addressed to:
(b)(?)(C)
- 2. {
Number (b)(?)(C)
(i....,,'er from service label)
COMPLETE THIS SECTION ON DELIVERY B. Received by ( Printed Name)
D. Is delivery address different from Item 1?
If YES, enter dellvery address below:
- 3. ~Cl;? Type
- c)Q/.j-jl- - <..
Q.Cei-tifled Mall O Express Mail D Registered O Aetum Receipt for Merchandise D Insured Man D c.o.o.
- 4. Restricted Delivery? (Extra Fee)
D Yes
- PS Form 3811, February 2004 Domestic Return Receipt 102695-02-M-1540 ]
(b)(7)(C)
UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE. SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 21, 2013
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS - ALLEGATION Rll-2013-A-0100 Dear (b)(7)(C)
The Nuclear Regulatory Commission (NRC) has com leted its follow u review in res onse to Concerns 1-4 ou initial! brought to o *..::u:.:.r.;;;a:.:.:tt:.:::e.:.:.nt.:.:.:io::.:n.:.1,...(b_l(7-l(_c ___________
(b)(7)(C regarding: Non Responsive Record Non Responsive Record Non Responsive Record The Enclosure to this letter restates your concerns and describes the NRC's review and conclusions with regard to those concerns.
Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call me toll-free at 1-800-577-8510 ext. 4628 or you may A :evti i~formation to me in writing at P.O. Box 56274, Atlanta, GA 30343.
Enclosure:
As stated CERTIFIED MAIL NUMBERl1-~b_)(_7)_(C_) --------'
RETURN RECEIPT REQUESTED
Concern 1:
RESPONSE TO CONCERN ALLEGATION NO. Rll-2013-A-0100 Workers were unknowingly exposed to Plutonium and Neptunium in the mid-90's while processing green salt from the Fernald Department of Energy (DOE) facility.
Background Information:
You stated that during the mid-90s, Honeywell or at the time AlliedSignal. processed green salt from the Fernald DOE site which was contaminated with plutonium and neptunium. The.
workers were not informed they were processing anything other than normal green salt and were told by the analytical lab they were handling green salt contaminated with traces of plutonium and neptunium. You also stated that you confronted management and demanded to be tested, but was told you would have to go to Oak Ridge National Lab (ORNL) for the testing, and you were never sent for testing.
Response to Concern:
The NRC requested that the Honeywell Metropolis Works (MlW} evaluate and respond to the concern, and the NRC inspector reviewed the response. Honeywell selected an Independent Investigator who, through reviews of historical documents, including correspondence with the NRC, compiled a regulatory history relating to shipments of green salt from the Fernald DOE facility. The investigator determined that according to AJliedSignal's July 17, 1998 letter, analyses of nine lots of green salt by two separate laboratories showed results consistent with natural (un-irradiated) green salt. Seven lots had less than the minimum detectable concentrations (MDC) of plutonium based on results from both laboratories. Therefore, AlliedSignal concluded that UF4 (green salt) from FERMCO (Fernald, Ohio), was not contaminated with plutonium and that any indication of contamination was likely the result of laboratory error or other analytical issues. AlliedSignal also affirmatively stated that there was no contamination of the facility.
In an NRC August 5, 1998 letter, the NRC agreed that based on the information in AlliedSignal's July 17, 1998 letter, the plutonium was at minimum detectable concentrations in the FERMCO green salt. The NRC concluded that the green salt material analyses were consistent with natural material and that the FERMCO green salt could be processed under the MTW license without amendment.
Based on a review of the MTW correspondence, the NRC concludes that there were no plutonium or neptunium hazards resulting from green salt received from the Fernald facility.
Extensive laboratory testing indicated that green salt from Fernald did not contain plutonium or neptunium in analytically significant quantities. The NRC agreed with AlliedSignal in the August 5th letter that there were no special hazards associated with the FERMCO green salt, no additional training was needed, and nor were there any exposure events.
==
Conclusion:==
The NRC has not observed any problems with Honeywell processing green sa,lt from the Fernald DOE facility in the mid-90s. The NRC inspector was unable to substantiate the concern that workers were unknowingly exposed to plutonium and neptunium in the mid-90s while processing green salt from the Fernald Department of Energy facility.
Enclosure
2 Rll-2013-A-0100 Concern 2:
Workers did not receive proper training or protection while handling higher activity material from Russia to be converted into UF6.
Background Information:
You stated that workers were exposed to higher activity material when they began processing drums of material from Russia. You also stated that the workers did not received additional training or personal protection equipment to handle the higher activity material.
Response to Concern:
The NRC requested that MlW ev~luate and respond to the concern, and the NRC inspector reviewed the response. Honeywell selected an Independent Investigator which performed interviews with the MlW Site Services Manager responsible for the process for receiving and sampling of incoming material. According to the Site Services Manager, shipments of ore concentrates from the former Soviet republics typically have activity levels that are comparable to shipments from other locations. However, ore concentrates from the former Soviet republics can have higher activity concentrations due to the relatively higher percentage of uranium in the concentrates. The ore concentrates are still, however, classified as natural uranium.
The investigator reviewed records and interviewed personnel and determined that the ore concentrates from the former Soviet republics do not require additional worker training or safety measures to ensure proper handling. As natural uranium, the activity concentrations of ore concentrates from the former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MlW.
==
Conclusion:==
The NRC has not observed any problems with Honeywell's workers receiving proper training or protection while handling higher activity material from the former Soviet republics to be converted into UFs. The NRC inspector was unable to substantiate the concern.
Concern 3:
The railcars stored onsite for transfer of Hydrogen Fluoride to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization and are not connected to a scrubber system.
Background Information:
You stated that you were concerned that the railcars containing Hydrogen Fluoride stored onsite are not properly configured with an over-pressurization relief system. You further stated that your concern is that during a fire or other event which could result in the pressurization of the tank car, the pressure within the car would build to the point of rupturing resulting in an uncontrolled release of material.
3 Rll-2013-A-0100 Respgnse to Concern:
The NRC requested that MTW evaluate and respond to the concern, and the NRC inspector reviewed the response. Honeywell selected an Independent Investigator which reviewed the specifications and safety features of railcars that contain Anhydrous Hydrogen Fluoride (AHF) when stored onsite and conducted interviews with personnel regarding AHF storage.
The investigator determined from interviews and reviews that AHF is shipped in railcars that meet or exceed the Department of Transportation specifications, including specifications requiring relief valves. Railcars approved for the transport of AHF have relief valves set at a pressure that ensures a substantial margin between the pressure relief valve and the vapor pressure of the AHF in the railcar. While being stored at MTW. the railcar is not connected to a scrubber system. However, a scrubber system is not necessary because the railcar is designed to withstand pressure significantly in excess of the vapor pressure of the AHF in the railcar.
==
Conclusion:==
The NRC has not observed any problems with AHF railcars onsite for storage and transfer of AHF to the Feed Materials Building. The NRC inspector was unable to substantiate the concern that raifcars stored onsite for transfer of AHF to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization arid need to be connected to a scrubber system.
Concern 4:
In the mid~90's, individuals were not required to monitor out-of the facility and could have been spreading contamination offsite. Cl knows of one individual who went home contaminated.
Response to Concern:
The NRC requested that MTW evaluate and respond to the concern, and the NRC inspector reviewed the response. Honeywell selected an lndepender:it Investigator who reviewed records related to historical plant practices and any incidents of offsite contamination during the mid-90s. The investigator also conducted an interview with the Regulatory Affairs Manager, formerty the Health Physics Supervisor at MTW.
The investigator determined from interviews and reviews that as far back as 1986, MTW license required that persons working in controlled UF8 process areas perform exit monitoring. Persons who did not work in process areas were not required to perform exit monitoring. However, in the mid-90s, MTW changed practices to require that all persons exiting the Restricted Area (i.e.,
the area within the inner security fence) perform exit monitoring. This was required in Section 3.2.1 of the ficense application, dated July 11, 1994. The investigator also determined from the Health Physics technician log books for the period between February 1995 and October 1999 identified 45 contamination events at the exit monitor. In all cases, the employee was decontaminated prior to leaving the facility.
While MTW at one time required exit monitoring only for personnel working in process areas, by the mid-90s all persons leaving the Restricted Area of the site were required to perform exit monitoring. Also, no records or reports were found by the investigator of offsite contamination during the mid-90s.
4 Rll-2013-A-0100
==
Conclusion:==
The NRC has not observed any problems with the personnel monitoring requirements at MTW.
The NRC inspector was unable to substantiate the concern that, in the mid-90's, individuals were not required to monitor out of the facility and could have been spreading contamination offsite.
t TF
OFFICE r b)(7)1CJ October 21, 2013 SUBJECT~
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100 Dearj(b)(7)(C) t
~~---...i;;;,, workers d1 not receive proper training or protection while handlin (bl(4i from Russia to be converted into UF5, Non Responsive Record Non Responsive Record describes the NRC's review an Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call me toll-free at 1-800-577-8510 ext. 4628 or you may provide information to me in writing at P.O. Box 56274, Atlanta, GA 30343.
Enclosure:
As stated Sincerely, J,mckey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER ~ )(/)(C)
RETURN RECEIPT REQUES°T
~ E""'b,__ ______
Rll:DFFI Rll:EICS Rll:DFFI SIGNATURE NAME RGibson DATE 10/
/2013 E-MAIL COPY?
YES NO OFFICIAL RECORD COPY Rll-2013-A-0100.DOCX ODeMiranda JHickey 10/ /2013 10/ /2013 10/ /2013 10/ /2013 10/ /2013 10/
YES NO YES NO YES NO YES NO YES NO YES DOCUMENT NAME: G*\\PROTECTEOIALLEGATIONS\\DFFI\\BRANCH 2\\LETIER TO ALLEGER
/2013 NO
OFFICE
SUBJECT:
CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100 Oead(b)(7)(C) l:
The Nuclear Regulatory Commission (NRC) has completed its follow up review in response to Concerns 1-4 ou initially brought to our attention!(b)(7)(CJ I
(b)(7)(C) re ardin : Non Responsive Record Non Responsive Record
~
il,l_l,j,l..---1,..;2;..{ workers did not receive proper trainin or protection while handlin (bJ(4) rom Russia to be converte_d into UFs, Non Responsive Record Non Responsive Record he Enc OSUre to IS et er restates your concerns and describes the NRC's review and conclusions with regard to those concerns.
Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new information. Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsibility to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional information that suggests that our conclusions should be altered, we plan no further action on this matter.
Should you have any additional questions or if I can be of further assistance in this matter, please call me toll-free at 1-800-577-851 O ext. 4628 or you may provide information to me in writing at P.O. Box 56274, Atlanta, GA 30343.
Enclosure:
As stated Sincerely, James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER!(b)~7J(C1 RETURN RECEIPT REQUES
'!::o.TE
= o---------'
/'
R!l:DFFI Rll:ElCS Rll:¢J1, SIGNATURE
_If\\
/JDl'f J (7 /~
NAME RGibson DATE 10ft.l /2013 E-MAIL COPY?
YES ( FIO -
OFFICIAL RECORD COPY Rll-201 3-A-0100.DOCX ODeMiranda
,)fllitt<er 10/<) /2013 10/ /2013 10/ /201 3 10/
/2013 10/ /2013 10/
YES NO YES NO YES NO YES NO YES NO YES DOCUMENT NAME: G:IPROTECTEDIALLEGATIONS\\OFFI\\BRANCH 2\\LETTER TO ALLEGER
/201 3 NO
- Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Oellvery rs des/Md.
- Print your name and address on the reverse so that we can return th.e card to you.
- Attach this card to the back of the mallplece, or on the front if space pe,mlts.
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(b)(7)(C) 2 (_ l(b.)(?)(C)
COMPLETE THIS SECTION ON DELIVERY
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a Express Mall 0 Retum Reoelpt for Merchandise
- DYes PS Fomt 3811, February 2004 i::>omes1lc Return Receipt 102595-02-M*1S40
1a-100'D J
Mr. Howard Cook 4628 Orchard Road Metropolis, IL 62960 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 25, 2013
SUBJECT:
Concerns You Raised to the NRC Regarding Honeywell -
Allegation Report Rll-2013-A-0100
Dear Mr. Cook:
This letter refers to your conversation with U.S. Nuclear Regulatory Commission (NRC) staff members while at a public meeting conducted at Honeywell on July 9, 2013. During the meeting, you expressed concerns related to several issues at Honeywell. In that you provided your concerns during a public meeting, in front of members of the licensee, the NRC will be unable to protect your identity with regard to these concerns. to this letter documents your concerns as we understand them. We have initiated actions to evaluate your concerns and will inform you of our findings. The NRC normally conducts an evaluation of a concern within six months, although complex issues may take longer. If the description of any of your concerns, identified as Concerns 1, 2, 3 and 4, as noted 1n Enclosure 1 is not accurate, please contact me so that we can assure that your concerns are appropriately described and adequately addressed prior to the completion of our review.
As part of our response to Concerns 1, 2, 3, and 4, we Intend to request Honeywell to perform an evaluation and provide a written response to the NRC. Your name and any other identifying information will be excluded from the information that is provided to Honeywell in the request for information. We will request that Honeywell's evaluation be thorough, objective, and that the evaluator be independent of Honeywell management responsible for oversight of the functional area related to your concerns. We will evaluate Honeywell's response, and consider it in developing our conclusions regarding your concerns. We will inform you of our disposition once we have evaluated Honeywell's response and taken an additional actions, if necessary, to address your concerns. In your conversation with (bJ(7)(cJ NRC staff member, on July 9, 2013, you indicated that you would not object to the NRC requesting information from the licensee with regard to your concerns.
Enclosed with this letter is a brochure entitled "Reporting Safety Concerns to the NRC," which includes an important discussion of the identity protection provided by the NRC regarding these matters as well as those circumstances that limit the NRC's ability to protect an alleger's identity, such as this case. Please read that section of the brochure.
If a request is filed under the Freedom of Information Act (FOIA) related to your areas of concern, the information provided will, to the extent consistent with that act, be purged of names CERTIFIED MAIL: 7012 1010 0002 6821 4438 RETURN RECEIPT REQUESTED
1:-i. Cook 2
RI 1-2013-A-0100 and other potential identifiers. Further, you should be aware you are not considered a confidential source unless confidentiality has been formally granted in writing.
Thank you for notifying us of your concerns. We will advise you when we have completed our review of Concerns1, 2, 3 and 4. Should you have any additional questions, or if the NRC can be of further assistance, please call me at the regional office toll-free number 1-800-577-8510 extension 4426 or you may provide information to me in writing at P. 0. Box 56274, Atlanta, GA 30343. You may also communicate with me by electronic mail, if you so choose. However, when doing so, please call me in advance or provide your phone number in your e-mail message so that she can confirm that you are the source of the information. Also, please be advised that the NRC cannot protect the information during transmission on the Internet and there is a possibility that someone could read your response while it is in transit. My e-mail address is Melanie.Checkle@nrc.gov.
Enclosures:
As stated
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Melanie M. Checkle Allegations Coordinator Enforcement and Investigations Coordination Staff Concern 1:
HONEYWELL Rll-2013-A-0100 STATEMENT OF CONCERNS Rll-2013-A-0100 Workers were unknowingly exposed to Plutonium and Neptunium in the mid-90s while processing green salt from the Fernald Department of Energy (DOE) Facility.
Concern 2:
Workers did not receive proper training or protection while handling higher activity material from Russia to be converted into UF6.
Concern 3:
The railcars stored on-site for transfer of Hydrogen Fluoride to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization and are not connected to a scrubber system.
Concern 4:
In the Mid-90s, individuals were not required to monitor out of the facility and could have been spreading contamination offsite. You know of one individual who went home contaminated.