ML19312E904
| ML19312E904 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 04/28/1980 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19312E903 | List: |
| References | |
| 70-0371-80-04, 70-371-80-4, NUDOCS 8006180114 | |
| Download: ML19312E904 (5) | |
Text
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O U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 710-371/80-04 Docket No.70-371 License No. SNM-368 Priority 1
Category UR Licensee:
United Nuclear Corporation 67 Sandy Desert Road Uncasville, Connecticut 06382 Facility Name:
UNC Naval Products Inspection at:
Montville, Connecticut Inspection conducted: A il 2-3, 1980 Inspectors:
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Projects S(ction, FF&MS Branch Inspection Summary:
Inspection on April 2-3, 1980 (Report No. 70-371/80-04)
Area Inspected: Routine unannounced inspection by a region-based inspector of the licensee's program for packagir of low-level radioactive waste for transport and burial. The inspection involved 11 inspector-hours onsite by one NRC region-based inspector.
Results:
No items of noncompliance or deviations were identified l
e Region I Form 12
]
(Rev. April 77) 8006180114
]
i
DETAILS 1.
Persons Contacted
- D. E. Ganley - President, UNC Naval Products J. F. Earp - Manager, Plant Maintenance and Services
- W. F. Kirk - Manager, Nuclear and Industrial Safety A. Wolvendyk - Foreman, Nuclear Materials Control D. Luster - Health Physics Specialist The inspector also interviewed a nuclear material accounting technician during the inspection.
- Denoted those present at the exit interview.
2.
Licensee's Report Required by IE Bulletin 79-19 The licensee had not yet reported their plan of action and schedule with regard to items 1 through 8 of IE Bulletin 79-19 at the time of the inspection.
The licensee indicated they were having problems getting pertinent information from Nuclear Engineering Company, Inc.
The inspector indicated that they should respond to the items, and, when when their information. ras incomplete, so indicate in the report.
The licensee indicated they would provide their response by April 11, 1978.
3.
Copies of Regulations, Licenses, and Requirements The licensee had current copies of the NRC and DOT regulations for the packaging and transport of low-level radioactive waste material.
The licensee has copies of Amendments 10 and 11 of Washington State License No. WN-1019-2 issued to Nuclear Engineering Company, Inc.
(NECO) for the operation of the burial site near Richland, Washington.
The licensee does not.have a copy of NRC License No. 16-19204-01 which was issued to Nuclear Engineering Company on December 14, 1979.
According to the licensee, NECO is not receiving and burying waste bearing special nuclear material (SNM) at the Richland, Washington, burial site; therefore, they must send the SNM-bearing waste to the NECO burial site in Beatty, Nevada, in the future.
The licensee had the documents NEC0 had sent to them and represented to them as the documents the licensee must have prior to shipping waste to the Beatty, Nevada, burial site for burial.
The documents included:
Nevada State License No. 13-11-0042-02; Amendments, 1, 2, and 4 to License No. 13-11-0042-02; Excerpts from the NECO Site Operations Manual for Beatty, Nevada;
3 Nevada Nuclear Center License Limits and Requirements; An Executive Order by the Governor of Nevada Relating to Transport of Comercial Low-Level Radioactive Waste; Low-Level Radioactive Waste Shipment Certification; Radioactive Material Checklist; and State Users Permit.
After reviewing the above documents, the licensee requested additional documents referred to in the documents from NECO. As yet, the licensee has not received the requested documents from NECO.
4.
Procedures The licensee has an SNM Shipping Guide which provides guidance for the performance of packaging activities in a manner which will meet NRC and D0T regulations. This guide also has a section which estab-lishes and defines areas of responsibility for the administration of a program to assure compliance with regulatory requirements for packaging and transporting radioactive material.
The guide has a section with the subject, UNC-NPD Packaging, Labeling, Inspection and Release for Shipping, which provides the procedure to be followed in packaging, labeling, inspecting, and releasing packaged special nuclear material for shipment.
Sections of this procedure apply to the packaging of radioactive waste for shipment.
The licensee also has a " route card" entitled " Outgoing SNM Shipment (Other Than Final Product)." This " route card" outlines the operations to be performed in preparing packages cf special nuclear material for shipment. This route card includes preparation of DOT 17H and LSA exclusive use (r.o specific container) containers. The route card calls for the Fa-tory' Shipping Order and Bill of Lading to be filled out. However, the route card does not call for the completion of the Radioactive Waste Shipment and Disposal Form, which is required for waste packages being shipped for burial and buried.
The inspector asked if Health Physics p(erforms surveys of vehicles to assure compliance with 49 CFR 173.393 j) requirements.
Health Physics said they did perform such surveys and provided the inspector vith a form entitled, Health Physics Release of Outgoing Final
, Product Containing SNM.
Even though the form refers to final product, the licensee indicated they performed such radiological surveys on all outgoing SNM shipments.
4 The licensee is currently preparing a " Procedure For Controlling and Minimizing Radioactive Waste." This procedure addresses the collection, segregation, preparation of wastes for packaging, and packaging of the waste.
5.
Training The licensee is instituting a program to reduce radioactive waste to burial from B-South. The licensee is going to hold special documented discussions with each of their B-South employees, or employees other taan B-South who could cause material to be brought into B-South.
These discussions will cover such items as assuring that no liquids are put into solid waste.
The licensee does not have formal training for personnel involved in the packaging of low-level waste for burial.
6.
Audit Program According to the SNM Shipping Guide, the NIS Department is required to perform audits to assure that procedures are followed.
The new
" Procedure For Controlling and Minimizing Radioactive Waste" requires under Responsibilities that Nuclear and Industrial Safety perform audits of radioactive waste operations.
The licensee indicated that this audit program will be emphasized when waste is again prepared for shipment.
The Quality Assurance Department has not made any audits of the packaging and transportation of low-level radioactive waste.
7.
Management Audit The licensee has not conducted a management type audit of the activities associated with the packaging and transport of low-level radioactive waste. The President of UNC Naval Products has ordered thrt no waste packages are to be shipped to a burial site until they art ssured that they are in compliance with all regulations concerned with packaging and transport of waste material. As a result, the licensee has not shipped any low-level radioactive waste to a burial site since September 24, 1979, and the licensee is reviewing the entire program and preparing new procedures.
8.
Examination of a Package The inspector requested that the licensee open a 55 gallon barrel containing waste for burial. The drum contained compacted dry waste.
There was an absorbent material on top of the waste. There was no gasket between the barrel and the cover. The barrel was labeled as containing LSA radioactive waste.
v 5
The inspector informed the licensee that LSA radioactive waste packaged in drums such as this and labeled as this drum was labeled would have to be shipped in an " exclusive use" vehicle in accordance with 49 CFR 173.392 (b) and (c), since the drum and its present labeling would not meet the requirements of 49 CFR 173.392 (a).
9.
Exit Interview The inspector met with licensee representatives (denoted in paragraph
- 1) at the conclusion of the inspection on April 3,1980.
The scope of the inspection was presented, and the following items were discussed.
The inspector noted that the licensee had agreed to having their response to IE Bulletin 79-19 sent to the NRC by April 11, 1980.
(Paragraph 2)
The inspector noted that the training of personnel on waste handling which is to be done prior to putting the new procedure entitled,
" Procedure For Controlling and Minimizing Radioactive Waste," in effect should be done thoroughly.
(Paragraph 5)
The inspector observed that Quality Assurance might also audit the packaging of low-level radioactive waste for transport and burial in addition to the auditing performed by Nuclear and Industrial Safety.
(Paragraph 6)
The inspector informea the licensee that the drums containing low specific activity (LSA) radioactive waste which they have on hand must be shipped on an " exclusive use" vehicle under CFR 173.392(b) and (c) because the drums and the labeling of the drums would not meet the requirements of 49 CFR 173.392 (a).
(Paragraph 8) i
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