ML19320D279
| ML19320D279 | |
| Person / Time | |
|---|---|
| Site: | 07000033 |
| Issue date: | 05/22/1980 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19320D264 | List: |
| References | |
| 70-0033-80-06, 70-33-80-6, NUDOCS 8007210195 | |
| Download: ML19320D279 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 1
Region I Report No. 70-33/80-06 Docket No. 70-33 License No. SNM-23 Priority 1
Category UR Licensee:
Texas Instruments Incorporated 34 Forest Street Attleboro, Massachusetts Facility Na'e:
HFIR Project Inspection at:
Attleboro, Massachusetts Inspection conducted:
A il 21
,1980
. Inspectors:
//
f7d Yd jn W.W.Kinney,/rojectInspctor date' signed date signed date signed Approved by:
,/
i f/2A/Pd H.
Cr6cker, Chief, Fuel Facilities d' ate signed Pr et Section, FF&MS Branch Inspection Summary:
Inspection on' April 21-25, 1980 (Report No. 70-33/80-06)
Areas Inspected:. Routine, unannounced inspection by a region-based inspector of l
organization; nuclear safety; and the licensee's program for packaging of low--
level radioactive waste for transport and burial.
The inspector also parti-cipated in a meeting between NRC Licensing and the licensee concerning the licensee's license renewal application.
The inspection involved 35 inspector-h0Jrs onsite by one NRC region-based inspector.
Rasults: Of the three areas inspected, no items of noncompliance or deviations were noted in two areas; one apparent item of noncompliance was identified in nuclear safety (infraction - failure to follow posted MSQ at a work station -
paragraph 3.a).
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l Region I Form 12-l (Rev. April 77)
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DETAILS 1.
Persons Contacted
- W. K. Goetz, Metal Systems Department Manufacturing Ilanager
- F. L. Sheman, HFIR Project Manager
- R. J. Schwensfeir Jr., Nuclear Safety Manager The inspector also contacted an engineer during the course of the inspec-tion.
- denotes those present at the exit interview.
2.
Organization The organizations concerned with the licensed activities have been changed and now include HFIR Project, Metal Systems Department (MSD) Parts Manu-facturing(new),andQualityAssurance.
Organizationally, the first level of organization to which both the resoonsible manufacturing manager and the responsible quality assurance mananer report is a vice president as shown below.
Vice Prasident, Material and Electrical Projects Group - W. Sick Assistant Vice President, Metallurgical Materials Division - W. George Manager, Metal Systems Department (M5D) - W. Quimby Manufacturing Manager, MSD - W. Goetz Assistant Vice President, Operating Services Division - T. Snyder Manager, Quality Assurance - D. Conroy Manager Quality, MSD - G. Nilsson The Metals Systems Department Manufacturing Manager has both the HFIR Project Manager and the Metals Systems Department Parts Manufacturing Superintendent reporting to him as shown below.
(Previously the Manu-facturing Foreman reported to the HFIR Project Manager).
Manufacturing Manager, MSD - W. Goetz HFIR Project Manager - F. Sherman Manager, Nuclear Safety - R. Schwensfeir, Jr.
Nuclear Materials and Safety Officer - Vacant Manager, Nuclear Materials - R. Schwensfeir, Jr.
Engineering Group --D. Collins
- W. Daft
- A. Robl MSD Parts Manufacturing Superintendent - S. Hartley Manufacturing Foreman - F. Campbell 15 Manufacturing Operators
3 The quality assurance organization reporting to the MSD Quality Manager is shown below.
Manager Quality, MSD - G. Nilsson HFIR Quality Engineer - G. Woodbine QA Technician - H. Vickers Product Acceptance Supervisor - G. Gesner HFIR Inspection Group Leader - C. Wallace 5 HFIR Inspectors The above organization shows that the HFIR Project Manager has the safety and engineering personnel reporting to him.
However, the HFIR Project Manager does not have direct authority over either the Manufacturing or Quality Assurance functions and associated personnel.
The licensee has hired a person who will graduate from college in June as the nuclear materials and safety officer. The former encumbent of that position left Texas Instruments at the end of March 1980.
Until this person is in the position and trained, Mr. Schwensfeir, the Nuclear Safety Manager and Nuclear Materials Manager has a heavy work load; especially because of the effort required in making the final revisions to their license application.
3.
Nuclear Safety a.
Conformance with Posted MSQ's (Maximum Safe Quality)
The initial part of the inspection was the inspection of the work area. The inspector noted that each work station and storage array had a MSQ posting. These postings listed the nuclear safety limits for the work station or storage area. The inspector noted that the items in location 13, waste drum press in the furnace room, exceeded the posted MSQ. There were two drums at the work station and each of the drums could contain 24 grams of U-235, according to the route cards with the drums.
The MSQ posting allowed < 24 grams U-235 and <~
one drum. This is an item of noncompliance (80706-01).
b.
Criticality Monitors The inspector noted the location of the criticality monitors. The monitors were located as shown on Attachment A in the approved license application. The green light on each monitor was lighted indicating the monitor was receiving power.
Each monitor was pre-set to alarm at 15 mR/hr.
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-The inspector reviewed the records of the testing and calibration of the monitors. During the period of January 1979 -March 1980, the weekly source checks of the operability of the monitors were performed except for two weeks in July 1979 and two weeks in December 1980, when the HFIR facility was down for vacation and holiday time.
According to the record,an October 2,1979, a monitor was found to be inoperable.
The licensee replaced the unit with a spare unit, and sent the in-operable unit out for repair. The sirens were tested for operability each quarter. The monitors were 61brated quarterly, c.
' Nuclear Safety Evaluations The inspector reviewed the Requests for Criticality Safety Analysis and the resulting Criticality Safety Analyses and Approvals prepared by the Nuclear Safety Manager which were done since Inspection 70-33/79-03. - There were 17 requests, Request Nos.14-30, which were considered. All of the requests were considered promptly.
Changes in MSQ postings or equipment changes with accompanying criticality safety evaluations were authorized by the Nuclear Safety Manager and approved by the HFIR Project Manager. All changes were within the constraints of the license.
d.
Monthly Criticality Safety Audits The inspector reviewed the reports of audits made for the months of March 1979 - March 1980.
During the March 1979, September 1979, and October 1979 audits, the auditor found either the material at a work station did not conform to the MSQ posting or the MSQ postings were inadequate. Appropriate action was taken immediately, according to the licensee records.
During the other months, the auditor found that the work stations, storage areas, and transfer devices were properly posted with the MSQ postings, the MSQ postings were proper, and the postings were being followed.
4.
Packaging of Low--Level Radioactive Waste The inspector inspected the licensee's program for the packaging of low-level r.adioactive waste for transport and burial.
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Regulations and Licenses The licensee had copies of the pertinent Department of Transportation and Nuclear Regulatory Commission Regulations.
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5 Texas Instruments was shipping low-level radioactive waste containing special nuclear material (SNM) to the Nuclear Engineering Company (NECO) burial site near Richland, Washington.
However, NECO has not been accepting waste bearing SNM at the Richland burial site for burial since early December 1979.
Burial of SNM-bearing waste at the Richland burial site is authorized by an NRC license.
The Washington State license, License No. WN-I019-2, does not authorize the burial of waste containing SNM. The NRC issued License N0. 16-19204-01 on December 4, 1979, to NEC0 authorizing the receipt and disposal of special nuclear material at the Richland burial site.
Up to the time of this inspection, NEC0 has not received and disposed of any SNM-bearing waste under NRC License No. 16-19204-01.
Should NEC0 resume receiving and disposing of SNM-bearing wastes at the Richland burial site, Texas Instruments should take care to obtain copies of all pertinent licenses and requirements for the packaging of waste for burial at the Richland burial site from NECO.
The licensee had copies of the following documents for the NEC0 burial site at Beatty, Nevada.
Nevada State License No. 13-11-0043-02, and Amendments 1, 2 and 4 Excerpts from NEC0's 3ite Operation Manual Executive Order from Oavernor of Nevada Requirements fo 3.ua State User Permit Filed with NECO Radioactive Material Checklist b.
Operating Procedures The licensee has two route cards which provide instructions to per-sonnel involved in the packing of low-level radioactive waste for transport and burial. These route cards are:
Process Waste or Measured Discard Drums with Assay, and Process Waste Drums with Metal Only.
-These documents are prepared by.an engineer in the HFIR Project Engineering G~roup and are approved by Quality Assurance.
Each page of the route card bears the typed name of the engineer and quality
6 assurance representative involved. The effective date and revision letter of the page are also typed on each page. The documents are not fonnally reviewed and approved by any member manufacturing management to demonstrate:
(1) the operability of the procedures, and (2) the requirement of manufacturing personnel to follow the Manufacturing -
authorized procedures.
The procedures call for all waste to be dry.
The procedures call for inspection of the Sipping drums.
The procedures appear to be adequate to provide for pru,ar packaging of the waste material.
c.
Training The licensee has a " Standard Operation", S0115, entitled, " Waste or MD Transfer (Loading) and Packaging Regulatory Requirements Training".
The licensee requires that operators read this Standard Operation as they perform the work outlined by the route card entitled, " Process Waste or Measured Discard Drums with Assay".
In this document the licensee indicated that Nuclear Engineering Company (NECO) transport the waste drums within an exlusive use vehicle.
It was also stated that NECO is responsible for compliance with para-graphs (5), (7) and (9) of 49 CFR 173.392(c).
The inspector pointed out to the licensee that: (1) an " exclusive use" vehicle must be under the control of a single consignor; (2) all loadir.g and unloading of the exclusive use vehicle must be carried out by or under the direc-tion of the consigner, consignee, or his designated agent.
The shipping papers made out by Texas Instruments show that Texas Instru-ments is the consignor for the shipment of waste from their facility.
As the consignor, they are required tc :::cet all the conoitions of 49 CFR 173.392(c), when an exclusive use vehicle is being used.
If NECO were to be the single consignor for the exclusive use vehicle, NECO would have to be the single consignor of record on the shipping papers for all the material on the exclusive use vehicle and NEC0 would have to provide direction of all loading activities.
Of course, Texas Instruments could packa 173.392(a) ge the LSA radioactive material in accordance with ? CM requirements instead of 173.392(b) and (c) requirements.
The " Standard Operation" for training contained mainly information concerning D0T regulations.
This Standard Operation document did not appear to be readily comprehensible. The dv vent should either be rewritten for comprehensiveness or training a scussions with the operators to assure comprenension of the pertinent parts of the document to operations should be performed.
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7 d.
Audit Program The licensee's audit program of the packaging of low-level radioactive waste is performed by Quality Assurance.
The inspector reviewed the report for the latest audit, Audit No. 159, which was performed on April 3, 1980. The audit was of the operations described in the route card entitled, " Process Waste or Measured Discard Drums with Assay."
The audit assessed whether or not operators performed the packaging in accordance with the sequences given on the route card. The audit report did not indicate that the audit was a management type audit which assesses the adequacy of the entire waste packaging program.
For instance, the audit did not include assessing conformance to NRC and DOT regulations; preparation of shipping papers, and the perfor-mance of radiation surveys of packages and transport vehicles.
The situation of the audit not assessing the adequacy of the entire waste packaging and transport program was discussed with the HFIR Quality Engineer. This individual has been recently assigned to the HFIR Project activities.
He indicated they would look into enlargirg the scope of the audit of the program for packaging and transporti...
low-level radioactive waste.
e.
Examinat'on of Packages The inspector examined the outsides of the loaded 55 gallon specifi-cation 17H drums which the licensee filled with low-level radioactive waste. The drums were labeled as containing Radioactive-LSA waste, as required by 49 CFR 173.392(c)(8) for package of low specific activity waste to be transported in an" exclusive use" vehicle. The inspector requested that drum #238 be opened.
The drum contained miscellaneous pieces of equipment. There was no liquid in the drum. The gasket of the drum was good and was in place. The licensee reclosed the drum satisfactorily, resurveyed the outside of the drum, and applied new tamper-safe seals to the drum, f.
Shipping Papers and Records The inspector exr.tn i the r cords maintained for the packaging and shipment of tSe low. cel rt.ioactive waste.
The licensee had a copy of the completed routi card ':n each of the packaged drums. For each shipment the licensea tad 1 e following completed forms.
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741 Form
-SS Material Shipping List Radioactive Material Shipment Approval Shipping Order to NECO Straight Bill of Lading Radioactive Waste Shipment and Disposal Form The bill of lading form used by the licensee was a form used by another group of Texas Instruments. This form had a certificate that the t
fiber boxes used in the shipment met 00T requirements.
The shipping containers were actually specification 17H steel drums. The other forms appeared to be filled out satisfactorily.
5.
Meeting of NRC Licensing and Licensee The inspector participated 'in a two day meeting of HFIR Project management, a consultant from Oak Ridge National Laboratory, and the licensing project ma' nager for the Texas Instruments license from the NRC Divisior, of Fuel l
Cycle and Material r fety.' The informal NRC comments on the Texas Instru-a ments license renewcl application, which were based on the initial safety review of the applicattog were discussed in detail. As a result of this meeting: (1) the licensing project manager will formally subnit the NRC comments on the license application to the licensee; and (2) the licensee will modify their license application to satisfy the NRC comments.
6.
. Exit Interview The inspector and the licensing project manager met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on April 25, 1980. The licensing project manager discussed the schedule for.the' licensee to submit their modified license renewal application with the licensee. The. inspector presented the scope and findings of the in-spection.
The item of noncompliance wnich involved the failure of the man"facturing-group to follow the MSQ posting at the waste compactor work locacion was
. discussed. The licensee indicated that they would probably change the MSQ
~for the process waste drums with metal only to' indicate tt special nuclear material is not allowed to be placed in the drum. This approach is questior-able because this would tend to indicate that the metal wasia was completel,y i
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clean with absolutel'y no residual uranium present on the waste. The I
inspector pointed out during the discussion that the operating procedures for the waste' compactor called for having a waste drum at.the compactor work location only when the waste was being compacted in the drum. Other-wise, the drum was to be located at a storage location.
(Paragraph 3) 1 The inspector pointed out to the licensee that, if they wish to ship their low specific activity (LSA) radioactive waste using an exclusive use vehicle under the requirements of DOT regulation 49 CFR 173.392(b) and (c) and be the consignor for the shipment, they must meet all the requirements of 49 CFR173.392(c). The inspector noted that they could ship their waste under i
the conditions of 49 CFR 173.392(a) and the vehicle they used would not have to be an exclusive use vehicle. Of course, they would have to meet the more vi (Para-graph 4.c) gorous packaging requirenents under this circumstance.
The inspector noted that the new organization structure with the manu-facturing foreman reporting to the MSD Parts Manufacturing Superintendent instead of the HFIR Project Manager gave rise to the point that Manufacturing might'also review and approve the route cards and standard operations.from an operability standpoint. The licensee indicated they would consider this point.
(Paragraph 4.b)
I The inspector noted that Standard Operation 115 did not appear to be readily canprehensible to operating people.
(Paragraph 4.c)
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