ML19261C830
| ML19261C830 | |
| Person / Time | |
|---|---|
| Issue date: | 01/22/1979 |
| From: | Jennifer Davis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19261C829 | List: |
| References | |
| SECY-79-047, SECY-79-047-01, SECY-79-47, SECY-79-47-1, NUDOCS 7904100524 | |
| Download: ML19261C830 (52) | |
Text
.,Y.q umTso sraras SECY-79 47 jM 2 2 @
NUCLEAR REGULATORY Commission INFORMATION REPORT For:
Ine ccamissioners From:
John G. Davis, Acting Director Office of Inspection and Enforcement Thru:
Executive Director for Operations
Subject:
REPLACEMENT OF BROKEN SEALS ON FOUR CONTAINERS OF HIGHLY ENRICHED URANIUM EXPORTED TO ROMANIA Purmse:
To inform the Commissioners, in response to a Ccmmission request for briefing *, concerning the replacement by the Office of Inspection and Enforcement (IE) of broken seals on four containers of highly enriched uranium exported to Romania, without examination of the centainer contents.
Discussion:
1.
Introduction This Information Paper discusses the initial shipment of four containers of highly enriched uranium (total quantity of less than 5 Kg U-235) as TRIGA reactor fuel from General Atomic, San Diego, California, to Romania under Export License XSNM-835.
A considera-tion for this export was the affixing of U.S. Government seals to each container of highly enriched uranium exported under the license.
For the first of several shipments the sealing in California of the four containers -- which constituted the initial shipment --
'lnen these seals was observed by an NRC inspector.
subsequently were examined oy an NRC inspector at Kennedy Airport, New York, prior.
export, all were found to be broken.
Based on his examination of the four containers at Kennedy Aircort, the JRC inspector decided that the contents of the containers had not been disturbed.
Consequently, he resealed the con-tainers -- without inspecting the contents -- and the containers were exported.
When the containers arrived in Rccania, the seals affixed at Kennedy Airport were intact.
Later, the International Atcmic E;1ergy Agency (IAEA) inspected the contents of the containers and verified that the contents were as shipped from California.
790410052'(
E. Morris Howard, IE 19-27650
'SECY NOTE:
Thispayercertajnstoa.Ccmcissicnbrieficg,dichis current y scnecutec tor.uescay, January ca, i n e.
.I
. The NRC general procedure used for the inspection at Kennedy Airport states that containers with broken or missing seals "...should be carefully inspected to verify that the contents have not been disturbed."
The procedure does not specifically call for opening the container to perform the verifica-tion.
The procedure -- by omission of instructions to open containers -- recognizes that under some circumstances opening of the container may not be necessary.
However, the degree of judiciousness expected to be exercised by IE was not exercised in this case. The inspector's judgment that the contents of the containers had not been disturbed later was con-finned by the IAEA inspection.
Even though the inspector's judgment was substantiated, the absence of the more judicious act of verifying the contents of the containers by opening the containers prior to resealing placed the agency in a position for some days of having lower confidence that the contents of the containers had not been disturbed.
2.
Description of Shipment The total content of the shipment consisted of 100 fuel elements for a TRIGA reactor.
The fuel shipped contained 4479 grams of 93.15% enriched uranium as uranium-zirconium ailoy (10% uranium).
Each of the 100 cylindrical fuel elements (shipped 25 fuel elements per container) is one-half inch in diameter and 30 inches long.
Each alloy element is clad with stainless steel.
A unique serial number is imprinted in each element.
Each element is within a plastic envelope.
The outermost shipping container consists of a modified 55-gallon metal drum with lid.
Fixed within the center of the drum is a metal pipe, fitted with cap, approximately six inches in diameter.
Inside the metal pipe are seven card-board tubes, five of which hold five fuel elements each (two of the tubes are spacers) within their plastic envelopes.
(A sketch of the container is Attachment A).
The lid on the outermost container is held in place by a retainer ring.
The ring, which can be opened for placement around the container and lid, has two
. lugs at the point of opening with holes to accept a closure bolt. One of the lug holes is threaded.
The lid is secured by drawing the retainer ring tight by a bolt through the lugs.
On the threaded portion of the bolt -- which extends beyond the lug when tightened -- is a drilled hole for insertion of a container security seal.
In this case, the security seal consists of wire passing through the hole in the bolt and joined within a seal button.
The seal must be broken to remove the retainer ring in the normal manner.
(A sketch of the closure and security seal is Attachment B).
3.
The Event a.
Backaround On December 21, 1978, the Commissioners were informed that the Office of Inspection and Enforcement had replaced broken U.S. Government seals on four containers of highly enriched uranium (containing a total of less than 5 kilograms of U-235) without first verifying the contents of the containers by opening the con-tainers.
The containers had been exported on December 16.
The containers constituted initial shipment under License XStiM-885 of highly enriched uranium in the form of fuel for a TRIGA reactor from General Atomic, San Diego, California, to Romania (a copy of the written notification to the Commission is Attachment C).
b.
General Descriotion of the Event For the purposes of this export, the NRC was to super-vise the affixing of U.S. Government seals to containers (drums) of highly enriched uranium so that the integrity of the container contents could be verified.
(A chronology pertinent to the orovision for affixing of the government seals is Attachment D).
IIRC inspectors observed the affixing of seals at the General Atomic facility in California.
Although there was no require-ment either in the rules and regulations or license for examination of the seals at the point of debarka-tion, IE -- because of the U.S. Government seals --
decided that inspection at the point of debarkation was prudent.
-4 Upon examination of the seals by an NRC inspector at Kennedy Airport, New York, prior to export, the seals on all four containers were found to be broken.
The NRC inspector, after his examination of the con-tainers, concluded that the containers had not been opened. This conclusion was based on the following:
(1) The seal wire was, in each case, found still to be through the hole provided for the seal wire in the container closure bolt.
(2) The wire ends appeared to be frayed and uneven and appeared to have been broken or pulled out of the seal button rather than cleanly cut.
(3) The seals had not been protected from damage.
(4) The drum lids, retainer rings, and closure bolts and nuts were tight and did not appear to have been disturbed.
(5)
External low level radiation readings were con-sistent with the readings taken by General Atomic prior to shipment.
(Note:
This was not an accurate measure of radioactive contents but indicated the presence of generally the same amount of low level radioactivity emanating from the containers.)
(6) When the inspector lifted the drums by tilting along one edge in order to reposition them, he noted by their weight they contained other than packing material.
The containers were not opened to verify the contents.
The inspector affixed new seals and the four containers were exported.
The following day, a Sunday, the inspector informed his Regional supervision of his actions.
Regional supervision concurred with his actions.
On the next day, the Region, upon inquiry from Headquarters at the staff level concerning the status of the shipment informed Headquarters of the broken seals and the replacement of the broken seals and provided new seal numbers.
Headquarters, at the staff level, raised no objection to the matter.
Three days later (December 21,1978) the matter came to the attention of the Director, Division of Safeguards Inspec-tion, IE, from review of a staff memorandum to the file.
IE management contacted management of the Office of International Programs.
IP subsequently discussed with the Department of State (State) the verification of the contents of the containers by the IAEA, the problems associated with an unplanned inspection, and the necessity for early verification.
State was also requested by IP to determine the earliest date an IAEA inspection could be made. On that date, the Office of Nuclear Materials Safety and Safeguards, the Executive Director for Operations and the Commissioners were informed of this matter. The Commissioners were briefed on this matter on December 22. At that time, it was known only that the IAEA planned to send an inspector sometime in January.
(This was later clarified to be January 15 with State seeking to move the inspection up to January 10 or soon thereafter.) Late on December 22, IP informed State of the outcome of the Commission meeting.
Following further discussions involving officials of NRC, State, the U.S. Mission to IAEA in Vienna and the Romanian Government, the IAEA inspection and verification was performed on January 5,1979.
The IAEA inspector confirmed that the contents of the containers were as described at the time of shipment.
It should be noted that although this incident involved an export shipment, it was a matter of domestic safeguards interest.
The IAEA inspection, originally planned by January 15, was advanced in order to assist the NRC in resolving this domestic safeguards matter.
c.
Use of Seals for this Shioment The application of U.S. Government seals to such shipments is currently not a normal practice of NRC.
In view of the large total quantity of highly enriched uranium involved in the multiple shipments of fuel to be made to Romania and the length of time large quantities of material would be on site before being loaded into the reactor, the NRC required seals on drums of all shipments of the highly en-iched uranium in accordance with arrangements made through the Department of State with the IAEA.
Their pur-pose is to provide assurance of the integrity of all
- the containers and to assist inspectors from the IAEA on subsequent inspections of the fuel in Romania.
The research reactor and its fuel are subject to IAEA safeguards inspections.
Hence, although each shipment was below the quantity requiring the measures of 10 CFR 73.30 (sealing by the licensee is one of the measures) the use of the seals for this " segmented" shipment did provide essential information concerning the integrity of the entire shipment.
d.
IE Use of Seals IE's more usual interest in seals is to determine the integrity of seals affixed by licensees in meeting requirements placed upon them.
The use of government seals by the flRC as a provision of export is unusual.
The AEC -- and AEC Regulatory prior to flRC -- did affix seals for various purposes, and there exists a 1966 memorandum setting forth sealing procedures within the AEC.
f1RC inspectors have used seals to indicate tampering of samples sent to laboratories as a part of the f4RC independent measurement pro-gram. As an inspection aid, inspectors may affix seals to cargo doors of trucks during the inspection of domestic shipments.
IE has developed no specific instruction speaking to the method of affixing seals.
e.
IE General Instructions on Seals IE has no general instruction on the application of seals.
With regard to exports, it does have a general instruction on inspection of seals.
This instruction, Procedure flo. 85300B issued October 1, 1976, states, in part, the following:
"2.
Port of Export a.
Examine and identify all containers and their seals against shipping documentation to assure that the shipment is complete and external containers and seals are intact.
i a b.
Containers with broken or miss..g seals should be carefully inspected to verify that the contents have not been disturbed.
If undisturbed, reseal the container using NRC seals, and notify the licensee of the action taken providing the new seal numbers, and release the containers for ship-ment.
Damaged containers are to be placed c.
in protective custody and withheld from further shipment until the licensee can inspect the container (s),
determine that there has been no loss of SNM, and if necessary, repackage the SNM."
A copy of this instruction is Attachment E.
It should be noted that this procedure does not specifically state that the container is to be opened to verify its contents in the event of broken seals, nor does it include prompt notification of the Regional Office by the inspector upon the finding of a broken seal.
The conditions which would necessi-tate opening a container and attendent arrangements associated with such opening would be highly location specific and dependent on the shipment.
This general instruction does not deal at this level of specificity.
By not providing specific instructions to open con-tainers for content verification, the procedure recognizes under some circumstances -- for example, an escorted shipment under constant surveillance --
opening of the container may not be necessary, f.
IE Instructions for This Shipment Specific information concerning this transfer of nuclear materials was prepared by IE in the form of a mercrandum from IE Headquarters to the Chief, Safeguards Branch, Region V (San Francisco).
A copy of this information is attached as Attachment F.
This specific information related primarily to
. the inspection to be conducted by Region V and noted that seals were to be applied.
However, no specific instructions were given regarding the application of seals.
In addition, no specific written instructions were given to Region I (Philadelphia) with regard to the inspection of the seals at the transfer point.
However, general verbal instructions were given, and it was expected that the inspection would be conducted under the existing procedure for inspecting exports.
The inspector acknowledges that he conslaered that he inspected under this procedure although it is not clear that he was specifically instructed to do so.
In correspondence prior to the approval of this export license, caution had been expressed on two occasions that care should be exercised to prevent accidental breakage of seals; however, this information was not relayed to the Regional Offices.
4.
Chronology Directly Pertinent to Resealing Event This unclassified chronology (Attachment G) har been prepared by the Office of Inspection and Enforcement from many classified and unclassified documents and reports wi.th the cooperation of the Offices of International Programs and Nuclear Materials Safety and Safeguards. Where conversations and transfer of documents are shown in the chronology, the dates have been reconstructed and represent the collective memory of the individuals involved.
5.
Lessons Learned a.
Communications on matters which are not routine must be done at a sufficiently high level within NRC to assure proper attention.
b.
Unusual events must be specifically con-sidered for handling as incidents (with use of the Incident Response Plan).
Incident response planning must embrace international aspects as appropriate.
This HEU seals event presented an unprecedented c.
and complex problem at the time of two long holiday weekends.
Verification of the shipment contents by the IAEA occurred two weeks after the first NRC approach to State Department
-g-seeking early assistance from the IAEA in resolving this domestic problem.
In the light of experience gained in dealing with this matter, procedures for responding to any future problems similar to this should be considered to ensure that responses are prompt, effective, and appro-priate to the uncertainties or threats that are presented.
d.
Lessons specific to IE:
(1) Communications flow within IE on nonroutine matters must be improved both upward and downward.
(2) Added attention must be given to evalu-ation of needed action in preparation for nonroutine matters.
This should include provisions for development of special specific procedures for nonrecurring matters.
(3) Tne ongoing systematic review of existing safeguards inspection pro-cedures must be accelerated and procedures promptly modified as needed.
Procedures should identify, as practicable, the limits of authority for exercise of inspector or Regional judgment.
(4) A uniform system must be established for supplemental procedure develop-ment at the Regional level for situa-tions which are location specific and which cannot be fully covered by the office general procedures.
Insofar as practicable, the general procedure should designate where the supplemental procedures are needed.
Contingencies must be considered in both general and supplemental procedures.
(5) A general procedure for seals must be developed covering such matters as:
Situations where government seals are to be used and
. specific instructions for application and protection of seals.
Control of seals.
Procurement of seals and sealing equipment and supplies.
Specific actions for broken seals.
(6) A procedure must be developed covering the remaining shipments to Romania under License No. XSNM-885.
6.
Actions Taken or Planned a.
By a memorandum of December 27, 1978, from the Executive Director for Operations, appropriate Office Directors were instructed to assure appropriate staff notification of nonroutine export shipments.
(Attachment H) b.
The proposed amendment to 10 CFR 73, PHYSICAL PROTECTION OF CATEGORY II AND III MATERIAL, was modified to require seals and Regional notification for Category II material ship-ments.
The staff paper concerning this amendment was forwarded by ED0 on January 16, 1979, for Commission consideration, c.
NRC will initiate discussions with State to explore with IAEA and other countries the possibility of establishing procedures and arrangements for mutual assistance for prompt response in case of incidents similar to the Romardan seals problem involving international transfers of nuclear material.
d.
The procedure has been developed covering the remaining shipments under License No.
XSNM-885, e.
Actions responsive to all other items under lessons learned are be ng planned and scheduled.
_11 Coordination:
The Office of Nuclear Material Safety and Safeguards and the Office of International Programs concur in this paper. The Office of the Executive Legal Director has no legal objection.
o b;
/b
[/ John G. Davis Acting Director Office of Inspection and Enforcement Attachments:
See next page DISTRIBUTION:
Commissioners Commission Staff Offices Exec. Dir. for Opers.
Secretariat
ATTACHMENTS:
A - Sketch of Shipping Container B - Sketch of Closure and Security Seal C - Notice to Commissioners D - Chronology of Container Sealing Provisions Under License XSNM-885 E - IE Procedure 85300B F - Memorandum Instructing Inspectors G - Chronology Directly Pertinent to Resealing Event with attachment (Note to Editor)
H - EDO Memorandum - Staff Notification On Nonroutine Export Shipments
4 ATTACHMENT A
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6 ATTACHMENT C e
NOTICE TO COMMISSIONERS g hn af Cg**
UNITED STATES f
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'%.N' December 22, 1973 MEMORANDUM FOR:
The Commissioners THRU:
Lee V. Gossick Executive Director for Operations FROM:
John G. Davis, Acting Director Office of Inspection and Enforce. Tent
SUBJECT:
SHIPMENT TO'RCMANIA FROM GENERAL ATOMIC CO.(XSNM-385)
Enclosed for your information is a discussion of the events surrounding the identification of broken seals on drums containing highly enriched uranium being exported to Romania.
New seals were affixed to the drums prior to their shipment frCa the U.S.
If any additional infccmation is required, please advise.
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- ~f >'h g John G. Davis Acting Director Office of Inspection and Enforcement
Enclosure:
As Stated Above cc w/enci:
Chairman Hendrie Comissioner Gilinsky Commissioner Kennedy Comissioner Bradford Comissicner Ahearne p.
JTTACmENT C
Subject:
SHIPMENT OF SNM TO RCMANIA FROM GENEPAL ATOMIC CO., SAN DIEGO CALIFORflIA (XShM-885)
Discussion:
On December 15, 1978, General Atcmic Co. made the first of several shipments of highly enriched uranium (in the form of fuel elements for a Triga reactor) to Romania.
The shipment was of less than 5 kg and hence, did not come under 10 CFR 7 shipment safeguards requirements.
Thir shipment was contain in 4 drums.
The packaging of the drums was witnessed on December 6, 1978 by NRC Region V-(San Francisco) inspectors and NRC seals were applied at the Office of International Program's directions to each drum.
The seals were checked b'
. Region I (Philadelphia) inspectors at New York's Kennedy Airport (U. S. port of embarkation)on December 16, 1978 and all four seals were found to be broken.
Broken seal wires s were in place in the seal holes of each drum.
New seals wer affixed to the drums.
The drams were not opened to verify t, contents of the inner containers.
IP was notified by IE on December 18, 1978 that the seals were fcund to be broken on the drums and that new seals were affixed to the drums at Kennedy Airport.
The shipment left New York on December 16, 1978, and arrived in Rcmania on December 21, 1978.
The application of the U. S. seals to a licensed shipment of SNM is not a normal practice.
Export license XSNM-885 conta a special license condition requiring the licensee to af ford the NRC sufficient notification to allow for inspection and sealing of the drums.
The purpose of the seals is to assure the integrity of shipping containers while enroute and to assist IAEA on subsequent inspecticns in Rcmania.
The seals are not to be removed by Romania.
IAEA will verif that the seals are in place and unbroken.
IAEA will replace U. S. seals with IAEA seals and will inspect the fuel at the time the IAEA seals are removed.
Future shipments by GA wil not be made until notification of arrival of the prior. shipm to Rcmania.
International Programs has requested the Department of State to detemine if IAEA could expeditiously inspect the content of the four drums and to provide the excected date for the inspection.
charest b6" State Department notified U. S. Mi.,icn in
/
ATTACHMENT C
e 9
9 ATTACHMENT D Gm
CHR0tiOLOGY PERTIrlEtiT TO C0tiTAINER SEALItiG PROVISI0 tis UtiDER LICEtiSE XSNM-885 JUNE 29, 1978 Office of International Programs (IP) sent to Commission a Staff Paper SECY 78-360 analyzing proposed Export License XSilM-885 for highly enriched uranium (HEU) to Romania for initial fuel for a TRIGA research reactor, and recomending approval of the license.
JULY 28, 1978 Commissioner Gilinsky by letter to the Executive Director for Operations asked various questions regarding the safeguards and physical secur'.~ t" aspects of the HEU shipments under Export License XSNM-885.
AUGUST 15, 1978 IP sent to Comission Staff Paper SECY 78-360B to respond to Commissioner Gilinsky's questions in the July 28, 1978 letter.
AUGUST 21, 1978 IP sent to Commission Staff Paper SECY 78-360C proposing a lettcr to the Department of State (State) asking for further information about safeguards arrangements prior to fueling the reactor.
AUGUST 25, 1978 In Staff Paper SECY 18-360E, IP forwarded for the Commission's information a letter from State acknowledging their understanding that the Commission was awaiting clarifying information.
S_EPTEMBER 5, 1978 Chairman Hendrie wrote State asking about several matters, including status of the facility attachment and the planned International Atomic Energy Agei cy (IAEA) inspection and verification measures, along lines of SECY 78-360C.
ATTACH!!EtiT D
. OCTOBER 12, 1978 State letter responded to Chairman Hendrie's September 5,1978 letter, stating that the IAEA-Romanian facility attschment had beca completed and that two alternative sealing arrangements for the HEU were under discussion with the IAEA.
The alternative sealing arrang:ments were either (Procedure A) to affix IAEA seals at the General Atomic (GA) shipping facility, or (Procedure B) to affix U. S. Government seals at GA prior to shipment, then to replace U. S. Government seals with IAEA seals when IAEA inspected after arrival in Romania.
OCTOBER 16, 1978 IP sent to the Office of Nuclear Material Safety and Safeguards (NMSS) and the Office of Inspection and Enforcement (It.: a draft Staff Paper SECY 78-360F, discussing the question of IAEA versus U. S. Government seals. The alternatives were discussed at the staff level between NMSS and IE.
OCTOBER 26, 1978 IP forwarded to the Commission Staff Paper SECY 78-360F requesting Commission approval to issue License XSNM-885, with the recomendation thct the license be conditioned upon affixing U. S. Government seals to the containers under NRC supervision prior to shipment from GA.
Paper said either U.S. or IAEA seals would be acceptable, but expressed slight preference for IAEA seals.
NOVEMBER 2, 1978 IP, at the Commission's direction, wrote to State, saying that either sealing procedure would be acceptable (see October 12, above).
NOVEMBER 9,1978 Cable from V. S. Mission, Vienna, to State which was forwarded to NRC, stated IAEA staff had cautioned that seal wire should be strong since seal location appears to leave seals vulnerable to breaking during handling.
ATTACHMENT D
. NOVEMBER 20, 1978 State wrote to IP that IAEA had agreed to affixing U.S. Government seals at GA and replacing U. S. Government seals at a future date with IAEA seals (Procedure B).
This letter, received November 22, also confirmed execution of the Facility Agreement for the reactor, and advised use of strong seals, due to possibility of accidental breakage.
NOVEMBER 21, 1978 An IE staff member contacted a staff member at State, who said that State and IAEA had decided to use U.S. seals and that seal " fingerprinting" was not required.
This information was telephoned to the flRC Region V Office (San Francisco).
Other details were discussed between IE Headquarters, and Region V.
NOVEMBER 22, 1978 IP issued Export License XSilM-885.
State, IE and the Commission were notified of the license issuance and that it was conditioned on affixing of U. S. Government seals prior to shipment of material.
(Procedure B)
IP sent a memorandum to the Commission advising that License XSNM-885 had been issued, enclosing copies of State letter of flovember 20 and a Vienna Cable of November 9.
A copy of this memorandum with enclosure and a copy of the export license were delivered to an IE staff member.
IE, by memorandum to IP, stated that IE understood that U.S. seals were to be affixed to each fuel container by Region V inspectors and requested that IE be advised of the procedure to be used in notifying IAEA of seal numbers.
NOVEMBER 1978 During the latter part of November, the. staffs of State, IP, IE and GA conferred frequently in considering the inspection and affixing of seals.
ATTACHMENT D
. tiOVEMBER 27, 1978 IE sent letter to Region V to set forth procedures to be followed for XSNM-885, which included the following:
1.
Observation of loading.
2.
Recording the serial number of each fuel element in each container.
3.
Nondestructive assay of selected fuel elements.
4.
Application of Type E seals to each container and recording of serial numbers.
ATTACHMENT D
0 5
ATTACHMENT E 4
Material Control and Accounting - (mfg Verification of Imports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76 SECTION I INSPECTION OBJECTIVES To assure, through inspection and monitoring of import and export ship-ments that licensees have established and maintained a caterial control and accounting program in accordance with Regulatory requirenents to:
(1) protect the health and safety of the public, (2) protect against the diversion of SNM fro = authorized use, and (3) provide the NRC with timely infor=ation regarding these shipments.
/
ATTACHMENT E 7_
(Note:
Fertinent information is o.n Page II-3)
Material Control and Accounting - (afg)
Verification of I= ports and Exports of SNM Procedure No:
85300B Issue Date:
10-1-76 SECTION II INSPECTION REQUIREMENTS A.
Import Shiements 1.
Port of Entry Examine, identify and verify the integrity of incoming shipment.
The proper number of shipping containers, identification numbers, seals, and their condition are to be checked and inspected against shipping documents.
Unda= aged containers having =issing or da= aged seals are to be resealed, using NRC seals.
Damaged containers are to be placed in protective custody for licensee action.
They are not to be released for further ship =ent until the receiving licensee, or his authorized agent, has verified that no SNM is =issing and has repackaged or repaired the da= aged container (s).
Report i==ediately to the receiving licensee, Regional Office, and Headquarters Regional Coordina-tor (duty officer if af ter working hours and applicable) all pertinent facts and actions taken.
2.
Licensee Facility During nor=al inspection of licensee, ascertain that the licensee has followed his established program to assure that all SNM received is accurately accounted for (MC 852083, " Material Con-trol and Accounting - Shipping and Receiving").
B.
Excort Shittents 1.
Licensee Facility Review specific export license authorizing licensee to export SNM and his schedule for production, packaging, and shipment.
Set up an inspection program, depending upon type of caterial being shipped:
Bulk Material - UF, U oxides, pug, mixed oxides, and/or a.
6 2
other U or Pu co= pounds for fabrication overseas 11-1
Material Control and Accounting - (=fg)
Verification of I= ports and Exports of SNM Procedure No:
853003 Issue Date:
10'-1-76 (1)
Review export license as to material type, quantity, and dates.
(2)
Obtain fro = licensee schedule for producing and packaging SNM for export and plan for inspection.
(3)
Review licensee's =easure=ent progra: (Procedure 85206B).
(4)
Perfor= rando= unannounced inspections to deter =ine if procedures are being followed.
(5)
Inspect quality of =easure=ents made by licensee (scale and balance, calibrations, etc.).
(6)
Verify licensee =easure=ents during production and/or sa=pling, taking sa=ples for destructive or nondestruc-tive analysis.
(7)
Observe =ethod of packaging and weighing SNM, weighing a statistically representative nu=ber of containers to verify licensee's data.
(8)
Observe the tamper-safing operation which takes place at the time of weighing and packaging.
Review and inspect licensee's procedures for tamper-safing, e.g.:
controls, application, docu=entation, and records (Procedure No. 85212B).
b.
Fabricated Fuel - Ele =ents or asse=blies containing U and/or Pu.
(1)
Perfor NDA ressure=ents on rando= selection or -fuel elements or.sse=blies.
(2)
If unable to perfor= =easure=ents, during normal inspections.
Review and evaluate licensee's =aterial and quality control progra=s to assure that SNM con-tent is known.
i (3)
Observe the operation of the =easure=ent control pro-gra= during the fuel fabrication, and assure that the licensee's practices for determining and controlling the quantity of SNM follow VRC accepted precedures.
II-2 ATTACHMENT E
Material Control and Accounting - (mfg Verification of I= ports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76 (4)
Verify that the licensee is c= ploying tamper-safing precedures on accepted fuel assembly material for verification of SNM content of fuel.
2.
Port of Export Examine and identify all containers and their seals against a.
shipping documentation to assure that the shipment is com-plete and external containers and seals are intact.
b.
Containers with broken or missing seals should be carefully inspected to verify that the contents have not been dis-turbed.
If undisturbed, reseal the container using NRC seals, and notify the licensee of the action taken providing the new seal numbers, and release the containers for ship-cent.
Damaged containers are to be placed in protective custody c.
and withheld fro: further shipment until the licensee can inspect the container (s), determine that there has been no loss of SNM, and if necessary, repackage the SNM.
C.
Monitoring Imports and Exports of SNM
~~~
1.
External Radiation Levels Monitor all packages and containers for external radiation by directly measuring the radiation level outside each package or container at the surface and at three feet from the surface using appropriate instru=entation for detecting tlpha, beta, and ga::a radiation.
If the survey shows radiation levels below 10 crc =/hr at ti.ree feet and below 200 mrem /hr at the surface, the ship =ent can be relaased.
2.
External Surface Contamination Monitor all packages and containers for external contamination through the use of a wipe test.
The wipe test is a two step procedure.
First, using one or more representative sections of the outer surface of the package, rub a filter paper or other absorbent material over a mini =uc of 100 cs2 (16 in.2) of the package surface usf f strong finger pressure.
Second, the absorbent caterial 1<, moved to an area where the radiation level is at or near background, and any activity on the absorbent material is measured with appropriately calibrated instruments.
Il-3 ATTACHMENT e
Material control and Accounting - (=fg)
Verification of I= ports and Exports of SNM Procedure No:
853003 Issue Date:
10-l'-76 Re=ovable radioactive contamination is not significant if the average amount of radioactive conta=ination which can be re=oved by wiping does not exceed 10 11 C1/c=2 Beta-Ga==a (2,200 dp=/100 c=2), and C1/c=2 Alpha (220.dp=/100 c=2), and the ship =ent can be released.
3.
Action to be Taken if External Radiation.or Radioactive Conta=ination is Excessive If the external radiation or radioactive contamination is in excess of limits specified above, control the area to prevent access and to protect personnel frc= radiation and/or conta=ina-tion.
Then, confir= that high radiation or conta=ination levels do exist by checking the operation of the measuring insert =ent, that radiation =easure=ents, by rewiping the package surf ace, by counting for a longer ti=c period, or by whatever confir=ation
=eans that see=s appropriate for the procedure being used.
Upon confirmation that high radiation or contamination levels do exist, i==ediately notify the delivering carrier, the shipper (in exports) and the intended receiver to initiate corrective action.
If necessary, the nearest Radiological Assistance E=ergency Tea = should be alerted.
Ensure that the carrier who delivered the package (s) takes the required action to involve the consignor and the Depart =ent of Transportation (DOT) in response to the incident, i.e, isolate any equip =ent, personnel, and facilities that have been in con-tact with the contaminated package (s) and notification of botn the DOT (202 426-1830) and the shipper of the package (s).
DOT will take the initiative and, upon deter =ining whether widespread contamination is likely, will work with the consignor and other carriers involved to take whatever action is necessary to control the spread of contamination and to properly deal with the con-ta=inated vehicles, personnel, facilities, and property.
/
II-4 ATTACHMENT E
Material Control and Accounting - (mfg Verification of Imports and Exports of SNM Procedure No:
85300B lssue Date:
10-1-76 4.
Acolicability Regional offices are to inspect (1) all exports and i= ports of strategic
- quantities of SNM; (2) exports of 1 effective kilogram or more of uranium-235 contained in uranium enriched to less (<) than 20% in the U-235 isotope from licensed facilities also possesing stragetic* quantities of SNM; and (3) 20% of.all exports of 1 effective kilogram or more of SNM from licensees possessing on?;
low enriched (<20% U-235) SNM.
- Uranium-235 (contained in uranium enriched to 20 percent or more in the U-235 isotope), uraniu=-233, or plutoniu=, or any combina-tion of these =aterials, which is more than 5,000 grams, computed by the formula:
Grams = (grams contained U-235 + 2.5 (grams U-233
+ grams Pu)).
II-5 ATTACHMENT E
Material Control and Accounting - (afg)
Verification of Imports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76 SECTION III INSPECTION GUIDANCE a.
Applicable Regulations 70.1; 70.3; 70.20; 70.22(c); 70.31(e); 70.32(b) 70.42; 70.51(b)(3) and (4); 70.54; 73.30 through 73.36; 73.72 49 CFR 173.397.
b.
Guidance References WASH 1163 Export and I= port of Materials and Facilities Controlled by the Atocic Energy Co= mission.
Regulatory Guide 5.10 Selection and Use of Pressure-Sensitive Seals on Containers for Onsite Storage of SNM.
Regulatory Guide 5.12 General Use of Locks in the Protection and Control of SNM.
Regulatory Guide 5.15 Security Seals for the Protection and Control of SNM.
Regulatory Guide 5.28 Evaluation of Shipper-Receiver Differences in the Transfer of SNM.
Regulatory Guide 7.3 Procedures for Picking Up and Receiving Packages of Radioactive Material.
Regulatory Guides in Progress:
Measurement Control Program for SNM Control and Accounting Shipping and Receiving Control of SNM.
Monitoring Transfers of SNM.
c.
Guidance Licensee's are required to apply for a specific export license authorizing an export of SNM.
They have been requested to notify their Regional III-l ATTACHMENT E
Material Control and Accounting - (mfg)
Verification of Imports and Exports of SNM Procedure No:
85300B Issue Date:
10,1-76 Office of all exports of SNM which exceed one effective kilogram.
This notification should contain the licensee's schedule for production, packaging, and shipment.
The Regional Office should review the licensee's processes and procedures that will be used in producing the SNM for export, paying particular attention to the qual.ity and quantity of measurements F.ie.icensee plans to use.
If the inspector cannot witness all casurements made by the licensee he should take statistically selected samples of the total population (in pro-cess material and final product) and verify the SNM content using destructive or nondestructive =casurements.
If nondestruc-tive measurement methods and standards are available, the SNM content of the shipment should be determined at the time of final packaging.
Shipments of low-enriched uranium frca those licensee's processing high enriched uranium and/or plutonium, are to be verified as if they were high enriched uranium or plutonium exports to assure thar no high-enriched uranium or plutonium is being surrepitiously exported as low enriched uranium.
Licensees importing SNM must first obtain an import license from the NRC, providing the same information as that required to obtain an export license, plus identification of the port of entry, mode of transport, the provision of a statement from the consigness as to the end use of the SNM, and whether the SNM is to be exported when work on it has been completed.
In addition, the following license conditions are applicable to licensees authorized to import 350 grams or more of U-233, plutonium, and/or U-235 contained in uranium enriched in the U-235 isotope U-235 20% or above, and for import shipments of 5 kilograms or more of U-235 contained in uraniu= enriched in the U-235 isotope below 20%:
Condition 1:
The licensee shall obtain all information f rom the foreign exporter necessary to complete the shipper's portion of Form NRC-741, " Nuclear Material Transfer Report."
If the licensee is III-2 ATTACHMENT E
Material Control and Accounting - (=fg)
I Verification of Imports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76, the receiver of the =aterial, he shall record the shipper's infor=ation on the copy of the For: NRC-741 co=pleted and sent to NRC pursuant to Section 70.54 of 10 CFR Part 70.
If the-licensee is not the receiver of the caterial, he shall provide the shipper's infor=ation to the receiver of the =aterial for inclusion on the receiver's For: NRC-741.
The licensee should also =ake arrange-
=ents with the foreign exporter to assure that transfer indicative seals are placed on the shipping containers.
~
Condition 2:
The licensee shall notify the Approp-iate Regional Office of Inspection and Enforce-ment, i==ediately, by telephone or telegra=,
if entry of any i= port ship =ent authorized by this license is refused by the U.S.
Bureau of Customs, t
Condition 3:
Each ti=e material is i= ported, the licensee shall show the original of the license to U.S. Customs as authority for the import.
The original of the license showing the i=perted quantity shall be surrendered to U.S. Custo=s when the final transaction under the license is cc=pleted.
Except for the final transaction, a copy of the license showing the i= ported quantity shall be surrendered to U.S. Custa=s for each shipment.
All surrendered docu=ents shall be carked for i==ediate trans=ittal to the proper NRC Regional Office.
Condition 4:
For import ship =ent of 350 gra=s or core of U-233 plutoniu=, anc/or U-235 contained in uraniu enriched in the U-235 isotope 20% or above, and for i= port ship =ents of 5 kilogra=s or more of U-235 contained in uraniu: enriched in the U-235 isotope below 20%, the< licensee shall promptly notify the NRL Regional Office having responsibility for the sh ent by tele-phone, telegra=, or teletype, upon receiving III-3 ATTACHMENT E
Material Control and Accounting - (mfg)
Verification of I= ports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76 notification that an i= port shipment has entered the country, giving the date and place the i= port entered, and the estimated time of arrival at that stated destination.
Condition 5:
The licensee shall assure that any shipment of plutonium, U-233, or U-235 (contained in uranium enriched to 20% or = ore in the U-235 isotope),
shall be protected in transit after it arrives in this country in accordance with the provisions of 10 CFR Part 73.
Monitoring of packages for external radi? ion levels involves the direct ceasurement of the radiation levels outL1de the package (1) at the surface, and (2) at 3 feet frc= the package using a Beta-Ca==a detector.
If the survey indicates an excess of 10 =re=/ hour at three feet, or an excess of 200 =rea/ hour at the package surface, an i==ediate re=easure-ment of the radiation levels is necessary.
The levels should be accurately =easured (1) at the surface (i.e., by placing the detector as close as is physically possible to the external surface of the package), and (2) three (3) feet from the surface in all directions from the package.
Monitoring of packages for external conta=ination involves using a two-step procedure.
First, a wipe test is =ade using one or = ore represen-tative sections of the outer surface of the package.
The wipe test is made by rubbing a filter paper or other absorbent caterial over a 2 (16 in.2) of the package surface using strong finger minimum of 100 cm pressure.
Second, the absorbent caterial is =oved to an area where the radiation level is at or near background, and any activity on the absorbent =aterial is ceasured with appropriately calibrated instruments.
Removable radioacti"e contamination is not significant if the average a=ount of radioactive contamination which can be re=oved by wiping does not exceed 10-11 C1/c=2 Beta-Ca==a (2,200 dp=/100 c=2) and 10-12 Ci/cm2 2
Alpha (220 dpa/100 cm ),
If the external radi,. tion of radioactive contamination is in excess of that specified above, the inspector should i==ediately cordon off the are, using a rope and placards (to be carried as part of the inspection kit) to prevent accesc and to protect personnel from radiation and/or contamination.
He then should confirm the presence of high radiation or contamination by checking the operation of the =easuring instrument, III-4 ATTACHMENT
Material Control and Accounting - (=fg)
Verification of != ports and Exports of SNM Procedure No:
853003 Issue Date:
10-1-76 by checking the radiation measurements, by rewiping the package surfaces, by counting for a longer period of ti=e, or by whatever confirmation means that sees to be appropriate for the procedure being used.
The inspector should also be prepared to call in the nearest Radiological Assistance E=ergency Team, if he believes it necessary.
The inspector should =ake sure that the carrier that brought the shipment to the area takes the necessary action to involve the consignor and the Department of Transportation (DOT) in response to the incident; i.e.,
isolate any equipment, personnel, and facilities that have been in contact with the contaminated package (s) and notification of both the DOT [(202) 426-1830] and the shipper of the package (s).
DOT will take the initiative and, upon determining whether widespread conta=ination is likely, will work with the consignor and other carriers involved to take whatever action is necessary to control the spread of contanination and to properly deal with the conta=inated vehicles, personnel, facilities, and property.
l III-5
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As each dr.c is closed, Regicn V will a;:ly *:RC seals to ea:h ccnta;ner.
The serial number cn each ty;e E seal will be listed cn the schedule pre;2 red in procecure i.
Finger printir.g of the seal is n:t 'ecuired.
4 The listinc will then be sent to IE-Headquarters for subnission to the IAEA and pbssibly to Region I should each shipment go to the East Coast for transhipment to Rcmania.
The IAEA is to return the seals to the U.S. for NRC cis;csition.
IE-Headcuar:ers c;uld check the serial numbers upon return frcn Ecmania.
ATTACFMENT F
L. Nordarhaug.
Please keep IE-Headquarters informed of shipping dates and any problems you may encounter viith the above procedures.
00 /h
~ l' *.' '
-;;[.Qc/--l D. R. Chappil', Acting Assis tant Director Divisien of Safe;uards Inspection Office of Inspecticn & Enforcement Cc r.t a c t :
J. V. Catania (49-27650) cc:
E. L..May E.
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9 8
ATTACHMENT G e
CHRONOLOGY DIRECTLY PERTINENT TO RESEALING EVENT DECEMBER 1, 1978 GA notified Region V staff that License No. XSNM-885 had been approved, and informed Region V that they wanted to start shipping during the latter part of the week of December 3.
DECEMBER 5,1978 GA notified Region V that the first shipment was delayed, since Lufthansa decided not to accept the shipment.
DECEMBER 6, 1978 Region V inspector observed loading, serial number recording, non-destructive assay, and sealing of the shipping ccntainers by GA personnel at the GA facility.
DECEMBER 13, 1978 GA notified Region V that the first shipment was scheduled for December 14.
Region V notified Region I that the shipment was scheduled to reach New York (Kennedy Airport) on December 15.
Region V contacted IE Headquarters to express concerns about the use of a three-strand seal wire as opposed to the nineteen-strand described in Reg. Guide 5.15, indicating GA had been cited for using the three-strand.
Region V stated the three-strand was as strong as the nineteen-strand, but that nineteen would be used in future shipments.
It was agreed that it was too late to change seal wires on the initial ship-ment.
DECEMBER 14, 1978 Region V provided Region I with drum numbers and seal numbers.
Region I requested specific flight information, which was obtained from GA and provided to Region I.
ATTACHMENT G
DECEMBER 14, 1978 (Cont'd)
GA informed Region V that the material had been returned to an inter-mediate trucking terminal in San Diego.
Flying Tigers Airline had refused the shipment due to a misunderstanding.
(Freight manager had not been instructed to receive hazardous materials.)
The Region I duty officer was advised of the postponement.
IE notified IP of drum and seal numbers.
IP provided information to State.
DECEMBER 15, 1978 IE notified Region I that the shipment was postponed.
Region V verified that Region I was aware of the postponement.
Region I queried IE staff concerning information about the shipment (approximately 10:00 a.m. PST).
Region I called Region V to obtain current status of the shipment (approximately 11:45 a.m. PST) and was informed of the departure and expected arrival time.
The inspector requested external radiation readings of each container, which were provided.
GA notified Region V at approximately 12:00 Noon PST that shipment departed Los Angeles at 6:00 a.m. PST.
Region I called British Airways (BAC) and determined that the scheduled departure time from New York to London was 1:30 p.m., December 16, 1978.
Region I inspectors departed Region I Office and arrived in New York.
ATTACHMENT G
DCCEMBER 20, 1978 Material due to arrive in Romania.
IE/DSI staff member prepared Memorandum to File on this event and a memorandum to staff member counterpart in IP confirming new seal numbers.
DECEMBER 21, 1978 The Director, DSI, received a copy of the Memorandum to File covering this event dated December 20,1978, (as is usual practice) and notified the Acting Office Director, IE, Assistant Director for Exports and Imports, IP, and Deputy Director, IP.
Deputy Director, IP, concurred in preliminary statement to Commissioners.
It was agreed (about 6:45 p.m.)
that IE would inform ED0 and the Commissioners.
Acting Director, IE, notified EDO and Commission.
IP advised Department of State that an early inspection would be needed.
State agreed to determine the earliest date at which IAEA could make an inspection.
State noted several pnssible, practical problems (implications of GA - customer financial warranty responsibilities; possible charges by IAEA for a special inspection; holiday weekend pending; lack of right of U.S. either to require or to make an inspection; need to determine what the planned IAEA inspection would include).
IP began to explore with State other ad hoc arrangements if early IAEA inspection was not possible.
The substantial problems involved with inspections by other than IAEA inspectors (e.g., U.S. nationals) were noted.
DECEMBER 22, 1978 IP advised State of the serial numbers of the fuel elements.
State said that the U.S. Mission to the IAEA had reported that the IAEA planned to send an inspector to Romania sometime in January but that the Mission would see if the visit could be made sooner rather than later.
DECEMBER 16, 1978 Region I inspectors found that the seals on all four containers were broken.
Three seals were attached to one end of the seal wire and the fourth seal was missing, although the seal wire was still attached.
Inspector measured the low-level external radiation from the drums and found it to be similar to that measured at time of shipment from GA.
He checked the closure _ bolt.on each drum and.found no indication of tampering.
In_ moving _the drums, he noted they contained more than packing. _0n the basis of these checks, and the appearance of the breaks, the inspector affixed new seals to each drum.
He did not open the drums.
DECEMBER 17, 1978 The Region I inspector notified his supervisor about the broken seals and of his action in resealing.
The Region I supervisor concurred in this action.
DECEMBER 18, 1978 IE staff member queried Region I concerning the status of the shipment and was informed of the seal breakage and replacement at approximately 8:20 a.m. EST.
IE staff member notified IP staff member of the seal breakage and resealing by the Region I inspectors.
New seal numbers were given to IP for trans-mission to State and IAEA.
The IE staff member receiving the notification of the broken seals notified several other staff members in the IE Division of Safeguards Inspection (DSI) and the Assistant Director, DSI.
The IE staff member documented the conversation with Region I in a Memorandum to the File, which was typed and distributed on December 20.
DECEMBER 19, 1978 IP transmitted new seal numbers to State.
State informed U.S. Mission to IAEA Vienna, by cable that seals had been found broken in New York and new seals affixed.
- ew.c.,
e
DECEMBER 22, 1978 (Cont'd)
Congressional Oversight Staffs notified by IE.
NRC Staff briefed Commission 5 C
,e in the incident.
The Commission directed the staff to seek to asse _ inat IAEA would verify contents of containers as soon as possible.
Late afternoon, IP phoned report of Commission meeting to high State official, requested State to try to arrange for inspection of material by IAEA as soon as possible, to notify Romanians, and to formalize communications on this subject.
State agreed.
GA advised IP that the shipment had arrived in Romania on December 21.
DECEMBER 26, 1978 State and IP staff discussed matter, awaiting word from Vienna, which had national holidays December 25 and 26.
DECEMBER 27, 1978 DSI directed its investigator to investigate and provide a complete chronology of the Headquarters staff's actions, to be completed on or before January 4, 1979.
State advised IP that the verification procedures planned by IAEA would include content verification.
IP notified IE, which confirmed that these procedures were very similar to NRC practice.
State advised IP that the planned date of the IAEA inspection was January 15, 1979.
State noted that GA anticipated having a representative in Romania for a week beginning January 10, and that, if possible, GA preferred having its employee present when the containers were opened.
State was there-fore attempting to move the IAEA inspection date up to January 10 or as soon thereafter as possible.
GA notified Region V of their intent to make the second shipment on Saturday, January 6, 1979.
DECEMBER 28, 1978 IP informed by State that new seals had been reported by Romanians to be intact upon arrival in Romania.
EDO instructed staff to ask State to further expedite inspection.
State sent immediate cable to Vienna requesting expedited inspection.
IE/DSI directed Regions I and V to investigate and provide a camplete chronology of the Regional staff's actions, to be completed on or before January 4, 1979.
DECEMBER 29, 1978 State advised IP IAEA inspector could ar.-ive Bucharest January 4-5 at earliest, with the need to obtain visas the pacing factor.
State.
made several efforts (some at high level) to expedite visas and inspection.
IE, in coordination with IP, NMSS and ELD, notified GA by letter that additional HEU shipments should not be made until License Condition 11, which requires confirmation that the material has been received by the consignee, had been met.
JANUARY 2, 1979 State advised IP that inspector visas were expected to be issued January 3, making possible January 4 arrival in Bucharest and inspection January 4-5.
IE directed Regions I and V to notify the FBI and develop an investigation plan.
JANUARY 3, 1979 State advised IP that visas had been issued.
ATTACHMENT G
JANUARY 5,1979 IAEA made its inspection.
NRC requested results of inspection as soon as possible.
State advised NRC by phone that, as a result of this inspection, the contents of the shipment were determined to be intact in Romania, and that the result would be confirmed later.
JANUARY 8, 1979 State confirmed results of IAEA inspection.
JANUARY 9, 1979 NRC dispatched Note to Editors (enclosed) concerning this matter.
,c,
.=,.-
UNITED STATES
+
0
! Y.~<
. ',i, NUCLEAR REGULATORY COMMISSION 3(.
S.
OFFICE OF PUBLIC AFFAIRS, REG lON V
\\
1990 N. California Boulevard, Suite 202, Walnut Cree!<, Ca. 94596 flRC:V-0379 FORIkkDIATERELEASE
Contact:
Jim Hanchett (Mailed - January 9,1979)
Bus:
415 932-8300 Hcme 415 820-3840 fl0TE TO EDITORS:
The Department of State has advised the t;uclear Regulatory Corrnission that the contents of containers with high enriched uranium shipped to Rumania have been determined to be intact.
The wire seals on these containers had been found to be broken or to have pulled out of the button holdina the wires when the shipment was checked by an ?!RC inspector at Kennedy Ai? ort in flew York on December 16 af ter arrival frem San Diego.
Detailed information on this shipment is attached.
- e Attachment ENCLOSURE TO ATTACHMEt4T G
flRC:V-0379 January 9, 1979 On December 15, 1978, General Atomic Company made the first shipment under an itRC export license of metal fuel rods containing high enriched uranium from its San Diego facility to Rumania for use as initial fuel in a newlybuilt research reactor.
This shipment was less than five kilograms and did not require special t<RC afeguards measures.
These special measures--such as armed guards and secure vehicles--are required only for shipments of five kilograms or more of high enriched uranium because of the relatively lower safeguards concerns for lesser quantities.
Packaging of the four drums in this shipment was witnessed by an NRC inspector at the San Diego facility.
A three-strand wire seal without special protection was applied to each drum while the inspector observed.
The shipment then was trucked to Los Angeles where it was flown by cargo aircraft to Kennedy Airport in tiew York.
The wire seals were checked by an flRC inspector at Kennedy Airport on December 16 and all of the wires that made up each of the four seals were found either to be broken or to have pulled out of the button holding the wires.
The wires were still within the seal holes in the closure bolts.
The inspector measured the low level external radiation from the drums and found it to be similar to that measured when the shipment originated at San Diego.
He also checked the closure bolt on each drum and found no indication of tampering.
On the basis of these checks, the inspector affixed new wire seals to each drum.
However, the drums were not opened, as they should have been in this :ase, to verify that the high eniriched uranium was still in the drums.
The shipment left flew York on December 16 and after stopping in London it arrived in Rumania on December 21.
The application of seals to such shipments is currently not a normal requirement of itRC.
In view of the large total quantity of high enriched uranium involved in the multiple shipments of fuel to be made to Rumania and the length of time large quantities of material would be onsite before being loaded into the reactor, the !!RC required seals on the drums of all shipments in accordance with arrangements made through the Department of State with the International Atomic Energy Agency.
Their purpose is to assure the integrity of all the containers and to assist inspectors from the International Atomic Energy Agency on subsequent inspections of the fuel in Rumania. The research reactor and its fuel are subject to IAEA safeguards inspections.
The flRC staff advised the Department of State of its view that an early inspection of the shipment would be needed, and asked the Department to determine the earliest date on which the IAEA could made an inspection.
The inspection initially had been planned for sometime in January.
On December 22 the Commission was briefed on the matter and it directed the o
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NRC:V-0379 January 9,1979 staff to seek to assure that IAEA would verify the contents of the containers as soon as possible.
The Department of State has advised the NRC that as a result of the IAEA inspection ccmpleted on January 5, the contents of the containers have been determined to be intact.
The Commission has directed its staff to review the precedures used to make inspections of shipments of special nuclear materials so that incidents of this type will not occur again.
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- o UNITED STATES NUCLEAR REGULATORY COMMISSION
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a C WASHINGTON. D. C. 20555 a -r-nsY c
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DEC 2 71U78 MEMORANDUM FOR:
William J. Dircks, Director, NMSS John G. Davis, Acting Director, I&E James R. Shea, Director, IP FROM:
Lee V..Gossick Executive Director for Operations
SUBJECT:
STAFF NOTIFICATION ON NONROUTINE EXPORT SHIPMENTS From time to time special arr ngements may be required for certain nuclear export licenses, for example license conditions raiatinc to the safeguarding of special nuclear material.
Please ensure that, whenever such nonroutine export licenses are issued, all NRC staff personnel concerned with these exports, including inspector forces, are alerted to the special arrangements and sensitivities involved and that appropriate measures are taken to ensure that materials are fully accounted for and pratectec at all stages of handling.
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h f lee V. Gossick Executive Director for Operations CC:
Chairman Hendrie Comissioner Gilinsky Comissioner Kennedy Corrc.is sioner Bradford Commissioner Ahearne
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