ML19318A250
| ML19318A250 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 04/28/1980 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19318A249 | List: |
| References | |
| 70-0820-80-03, 70-820-80-3, NUDOCS 8006190088 | |
| Download: ML19318A250 (7) | |
Text
i I
r'd U. S. NUCLEAR REGULATORY Co m ISSION l
OFFICE OF INSPECTION AND ENFORCEMENT REGION I Report No.
70-820/80-03 Docket No.70-820 License No.
SNM-777 Priority 1
Category UR Licensee:
United Nuclear Corporation UNC Recovery Systems Wood River Junction, Rhode Island 02894 Facility Name:
Fuel Recovery Operation Inspection At:
Wood River Junction, Rhode Island Inspection Conducte :
March 31-April 2, 1980 Inspectors:
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W.~W. Kinney oject }(ispector
' dat'e date date Approved by:
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H. W. Crocker, fhief, Fjer Facility Project
'date' Section, FF&MS Branch Inspection Summary:
Inspection on March 31-April 2, 1980 (Report No. 70-820/530-03)
Area Inspected:
Routine, unannounced inspection by a region-based inspector of the licensee's program for packaging of low-level radioactive waste for trans-port and burial.
The inspection involved 14 inspector-hours onsite by one NRC region-based inspectors.
Results:
No items of noncompliance or deviations were identified.
8 0 0 619 0 06'$'
Region I Form 12 (Rev. April 1977)
i DETAILS 1.
Persons Contacted
- C. E. Bowers, General Manager
- R. J. Gregg, Manager, Quality Assurance
- K. A. Helgeson, Manager, Nuclear and Industrial Safety
- D. M. Schultz, Manager, Compliance J. L'Heureux, Manager, Nuclear Materials Control The inspector also interviwed the Purchasing Manager.and a Compliance Engi-neer during the course of the inspection.
- Denotes those present at the exit interview.
2.
Licensee Possession of Regulations and Licenses The licensee had current copies of the NRC and DOT requirements for the packaging and preparations for shipment of low-level radioactive waste material. The licensee ships its waste to the Barnwell, South Carolina, burial site operated by Chem-Nuclear Systems, Inc.
The licensee had a copy of Amendment No. 18 to NRC License No. 46-13536-01 issued to Chem-Nuclear i
for burial of waste at the Barnwell burial site.
The licensee also had a copy of Amendment No. 26 to State of South Carolina Radioactive Material License No. 097 issued to Chem Nuclear for burial of waste at the Barnwell burial site.
The licensee also had copies of the Barnwell Site Disposal Criteria.
3.
Operating Procedures 3
The licensee has the following procedures (SOP's) and Engineering Change Notices which pertain to the collection, packaging, and preparing shipments l
of radioactive waste.
~
SOP III-C, Revision II, dated January 3,1980, Procedure for Packaging Containers and Documenting Outgoing SNM SOP X-A, Revision IV, dated June, 13, 1977, Waste Disposal Procedure SOP X-8, Revision IV, dated June 2,1976, Disposal of Contaminated Combustible Waste 50P X-E, Revision III, dated January 25, 1974, Contaminated Non-Combustible Waste i
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3 S0P X-G, Revision 4, dated December 10, 1979, Residue Materials for Discard / Storage 50P X-H, Revision II, dated January 2, 1974, Disposal of Organic Low-Level Waste Solution 50P X-L, Revision I, dated March 5,1930, Trash Compactor Engineering Change Notice No. 1419, effective February 10, 1980-April 10, 1980, Drum Burial Preparation Engineering Change Notice No. 1422, effective February 6, 1980-April 2, 1980, Solidification of Organic Drums The Procedure for Packaging Containers and Documenting Outgoing SNM is a procedure used for packaging all special nuclear material for shipment.
The procedure calls for the inspecting, loading, and closing the containers and filling out the pertinent Container Specification and Inspection Report (CSIR) forms.
Included in these forms are CSIR forms for D0T specification 17H drums and 55 gallon burial drums. When a waste drum contains more than 15 grams of U-235, the licensee uses a 00T 17H 55 gallon steel drum in accord-ance with 49 CFR 173.396(b)(7). When a waste drum contains 15 grams or less U-235, the licensee uses a 00T 17H 55 gallon steel drum which does not have the four 1/2 inch diameter vent holes required in 49 CFR 173.396(b)(7).
The CSIR forms call for the operator to mark down the results of the inspec-tions of each container on the form and to initial that the work or inspec-tion activity was performed.
It appeared to the inspector that the procedures in the X series could be improved by consolidation and revision.
The licensee indicated they would assess this situation.
Engineering Change Notice No. 1419 pertained to many of the operations specific to the present requirements for waste to be buried.
For instance, this document calls for no free standing liquid to be allowed in any waste.
The procedures were prepared, reviewed and approved in accordance with the licensee's policy and requirements.
4.
Training The licensee does not have a formal training program for personnel involved in the packaging of low-level waste for transport and burial.
According to the licensee, they have a relatively small well experienced work force, and they rely upon supervision to assure that the operators do the work in accordance with the SOP's.
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4 5.
Audit Program The licensee does not have a formal program for auditing of activities associated with the packaging and transport of low-level radioactive waste.
However, auditing activities are performed.
A Compliance Engineer, who is well versed in the operations, audits the performance of operations involved in the packaging of the low-level radioactive waste.
If he notes problems, the situation is corrected immediately.
He prepares a monthly report of his audit activities, which may include a statement of problems noted and corrected.
The Manager of Compliance inspects every package of waste which is to be transported to the burial site.
He inspects for quality of the package, labeling, marking, and seals.
A security guard and a representative from Operations verify the number of the seals on the packages prior to shipment.
6.
Management Audit The Manager of Nuclear Materials Control performed a management type audit of packaging and transport of low-level radioactive waste on October 18, 1979.
The audit included examining shipping papers, labeling and marking of containers, seals, and inspection of containers to be shipped.
The audit disclosed three items requiring correction.
The licensee corrected these items prior to making the next shipment of the packaged waste.
7.
Preparations of Packages. for Shipment The licensee was performing the final checking of containers for a shipment to the Chem Nuclear Barnwell burial site, when the inspector arrived onsite.
The lic.ensee had twenty-four 55 gallon drums containing low specific activity (LSA) radioactive material; eleven DOT specification 17H 55 gallon drums containing fissile radioactive material requiring RADIOACTIVE-YELLOW II labels; one DOT specification 17H 55 gallon drum containing radioactive mate ;al requiring a RADI0 ACTIVE-WHITE I label; and 1 wooden box containing
)
LSA radioactive material.
i The inspector noted that two of the eleven drums labeled with the RADI0 ACTIVE-YELLOW II labels did not have the letter A of the Type A marking as required.
The licensee marked the two drums with the complete Type A marking.
The inspector noted that the licensee listed the curie content of the packages incorrectly on the RADIOACTIVE-YELLOW II labels.
The licensee listed the millicuries of radioactivity as curies, thereby overstating the radioactivity in the packages by a factor of 1000.
This was pointed out to the licensee, and they indicated they would list the values correctly in the future.
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5 The inspector noted that the drums containing the LSA material were not marked as a USA DOT 7A Type A package as required by 49 CFR 178.350-3 (see 49 CFR 173.392(a); 49 CFR 173.395(a)(1); 49 CFR 178.350).
Instead they were marked as " Radioactive-LSA" as required by 49 CFR 173.392(c)(9).
The inspector determined that the licensee was not intending to designate the vehicle being used as an " exclusive use" vehicle, even though the vehicle would by carrying only their waste material.
The inspector informed the licensee that they either had to designate the vehicle as an " exclusive use" vehicle and meet all the requirements of 49 CFR 173.392(c), or they had to have the packages meet the requirements of 49 CFR 173.392(a).
The licensee decided to designate the vehicle as an " exclusive use" vehicle and meet the requirements of 49 CFR 173.392(c).
The inspector noted that each of the non-LSA containers were sealed as required by 49 CFR 173.393(b).
j The inspector noted that each of the 55 gallon drums were closed with a 12 gauge bolted ring with a threaded lug and a 5/8 inch bolt and lock nut as required by 49 CFR 178.118-8, closure for 17H steel drums.
The inspector requested that a drum designated as containing solid process residues and labeled with a RADI0 ACTIVE-YELLOW II label be opened.
The licensee transferred the material to the process building from the ware-house, removed the seal, and opened the drum.
The drum contained dry solid process residue as listed on the Radioactive Shipment Record form.
The i
drum had a gasket, and the closure appeared to be proper.
The licensee i
replaced the cover on the drum and closed the drum with the bolted ring.
The bolted ring was positioned and tightened properly.
The licensee applied a new seal to the drum.
The licensee smeared the drum.
After the smear survey results were found to be within limits, the drum was transferred back to the warehouse.
8.
Loading of Packages on Trailer for Transport The licensee covered the floor of the trailer with brown kraft paper and filter cloth over the kraft paper.
The licensee then removed the drums from.the warehouse and placed the drums in the trailer.
As the drums were removed an Operations representative and a security guard verified the seal numbers.
Another security guard searched the forklift truck and the driver for special nuclear material other than that in the rirums, when the loaded forklift was removed from the warehouse.
The individual drums were placed in the front of the trailer.
Then, 3 pal-lets, each with 6 drums banded together on each pallets were placed in the trailer.
Finally, the wooden box was placed in the trailer next to the drums.
The licensee shored the box in place by nailing a 2" x 4" piece of lumber to the floor immediately behind the box.
6 The licensee took smear surveys of the floor of the trailer.
The Itcensee also took radiation readings from the underneath surface of the vehicle and in the cab of the tractor.
The inspector informed the licensee that DOT specifications 49 CFR 173.393(j)(2) and (3) give radiation level limits at all surfaces of the transport vehicle and six feet from the outer lateral surfaces of the vehicle, and it would be good practice to measure these radiation levels to assure compliance with the specifications.
The licensee and the driver placarded the vehicle showing it contained radioactive material.
The driver locked the trailer closed using his padlock.
The licensee provided the driver with the pertinent shipping papers.
9.
Shipping Papers The licensee made out the following papers for the shipment of radioactive waste to Barnwell, South Carolina.
Bill of Lading Tri-State Motor Transit Company Memorandum Factory Shipping Order Barnwell Waste Management Facility Radioactive Shipment Record Form The bill of lading showed that the tractor-trailer was an " Exclusive Use Vehicle".
The Special Instruction section of the form stated, "Do not open in transit shipment to be unloaded by consignee from.this vehicle."
The Radioactive Shipment Record Form was filled out completely.
The licens-ee listed the chemical form of the material to be " solidified waste".
This is not a description of chemical form.
The chemical form of the radionu-clide was probably a salt or oxide.
10.
Exit Interview The inspector met with the licensee representatives { denoted in Paragraph 1) at the conclusion of the inspection on April 2, 1980.
The inspector pre-sented the scope and findings of the inspection.
The inspector noted that it appeared that the procedures in their X series pertaining to processing of low-level radioactive waste and packaging the waste for transport and burial could be improved by consolidation of the procedures and revision.
The licensee indicated they would assess this situation (Paragraph 3).
7 The inspector noted that units for the curie content listed on the labels of the waste drums shipped on April 1, 1980, were overstated by a factor of 1000, since mil 11 curies were listed as curies.
The licensee indicated they would correct this situation (Paragraph 7).
The inspector noted that the licensee had elected to meet the requirements of 49 CFR 173.392(a) rather than 49 CFR 173.392(b) and (c) in the packag-ing of the LSA radioactive waste for transport (Paragraph 7).
The inspector noted that it would be good practice to survey the transport vehicle in a manner that would provide radiation level values at the loca-tions given in 49 CFR 173.393(g).
The licensee indicated they would take appropriate action (Paragraph 8).
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