ML19350E412
| ML19350E412 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 05/05/1981 |
| From: | Book H, Cooley W, Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19350E409 | List: |
| References | |
| 70-0025-81-03, 70-25-81-3, NUDOCS 8106230017 | |
| Download: ML19350E412 (9) | |
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- U. S. NUCLEAR-REGULSTORY COMMISSION (f
OFFICE OF INSPECTION AND ENFORCEMENT REGION V
-Report No.-
70-25/81 I SNM-21.
Safeguards croup Docket No.
70-25 treen3e gn, Licensee:
Energy Systems Group Rockwell International Corporation Canoga Park,' California 91304 Facility Name:
Headquarters Site, and Santa Susanna Field Laboratory -
Inspection at:
lieadquarters Site, and Santa Susanna Field Laboratory -
Inspection conducted:
March 3-6, 1981 Mk,,i dI 4//,/y/f/
Inspactors:
W. J. Cooley', Fue Facilities Inspector
/Date Signed Date Signed kS W
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Approved by:
R. D. T o as, Chief Materials Radiological Protection /
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Approved By:
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- 11. E. Book, Chief, Radiological Safety Branch Date Signed Sumary:
Inspection on March 3-6, 1981 (Report No. 70-25/81-03)
Areas Inspected: Transportation activities; radiation and criticality safety audits and reviews; criticality studies; and restricted access area entry permi ts.
The inspection involved 26 inspector-hours onsite by one NRC inspector.
Results: No apparent items of noncompliance were identified within the subject areas inspected. One deviation from accepted practices was observed within the subject area of transportation activities.
u RV Form 219 (2)
- 8106 23 00 l7
DETAlt.S 1.
Persons Contacted
- M. E. Remley, Manager, Health, Safety and Radiation Services Department
- R. J. Tuttle, Manager, Radiation and Nuclear Safety Unit D.- C. Allen, Nuclear Materials Management Unit J. D._ Moore, Engineer, Radiation and fluclear Safety Unit J. A. Kucinskas, Shipping Coordinator, Traffic Department J. H. Wallace, Health Physics Technician, Building 001 H. Farrer, Physicist
- Denotes those attending the exit interview.
2.
Transportation Activities During this' inspection a review was made of written policy statements and procedures addressed to the control of receipt and transfer of radioactive materials.
Following is a listing of standard operating policies along with the identification number and title of each and a brief summary of its contents.
a.
S0P J-22 Procurement and Receiving of Radioactive Materials and Radiation Producing Devices (excludes source and special nuclearmaterials).
Describes requisition forms required for the procurement of radioactive materials along with the required approvals and reviews.
Details the responsibilities of Health, Safety and Radiation Services (HSRS) Department, Purchasing Department, and Traffic and Warehousing.
Requires monitoring and storage of incoming packages and details of actions to be taken if there has been obvious damage-to any package. Addresses the procurement of radiation producing devices and the acquisition of internally produced radioactive material.
b.
50P J-24 Source and Special Nuclear Materials - Forecasting, Procurement and Receiving.
Similar to S0P J-22 (above), accept that it is addressed to Source and Special Nuclear Material including irradiated materials.
Includes the responsibilities of the Nuclear Material Management Unit of HSRS, Traffic and Warehousing and Purchasing Departments.
Gives details of the handling, delivery and storage of the material includirj the requirements of monitoring radiation levels and surface contaminatian and reporting any obvious damage to any package.
Provides for the aid of the Industrial Security Departraent for overdue shipments and the Quality Assurance Department for the performance of required tests and inspections on the incoming materials.
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'50P-K-12l Disposition of Nuclear Material Scrap and Waste'and' other-Radioactive Waste.
L-Directs the_ scrap generating departments to follow the instructions -
' of the Nuclear. Materials Management Unit in the' segregation, l
- collection, and. packaging.of scrap source and special nuclear material. Requires the generating departments to contact HSRS.
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for radiation monitoring services and applicable criticality t.
l safety procedures,(by reference to Standard Operating Policy. B-16).
Details the responsibility.of _the Nuclear Materials' Management
. Unit including the packaging and shipment of recoverable material.
Addresses the responsibilities of.. scrap generating departments,
. Nuclear Material. Management,. Radiation and Nuclear Safety, -in similar operations involving non-source and special nuclear material radioactive waste.
d.-
. 50P K-14 Shipping Radioactive Materials Addresses all shipments of radioactive materials including source.
and. special nuclear. material from the licensee's Santa Susanna,
'De Soto Avenue, and other business area sites.
Addresses, i
as-special cases, shipments by mail, collection and disposition of radioactive scrap and waste by reference to S0P K-12 (above) and the packaging of contaminated protective clothing.
Requires the department requesting a shipment to gather information regarding applicable regulations and the availability of existing shipping < container designs.
Requires that department-to -
verify thru HSRS that the consignee is authorized to receive the material. The requesting department is required to request the preparation of new shipping container designs, specifications, and procedures with the help of the Packaging Engineering Unit and to submit those.new plans and designs and procedures for approval through HSRS and Traffic and Warehousing Departments.
Requesting department initiates requisition for the fabrication of new shipping containers and notifies the Quality Assurance Department for their inclusion in quality verification requirements.
The requesting department initiates any special transportation services required through the Traffic and Warehousing Department.
The standard operation policy details the shipping form and approval signatures required for the shipment. Approvals c
I are required by supervision of HSRS, Fire Protection, Safety, Nuclear Materials Management, Criticality Safeguards, Criticality Control, and Packaging Engineering.
Actual-packaging for shipment is performed by Traffic and Warehousing Department or by the department requesting the shipment.
In either case that department is required to coordinate with the Quality Assurance Department, Packaging Engineering Unit, HSRS Department, and Traffic and Warehousing -
to determine that the packaging is performed correctly.
S0P K-14
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goes on to detail the responsibilities of the Packaging Engineering -
1 Unit, HSRS, Quality Assurance, and Traffic.and Warehousing.
It is interesting to note that the reords required to be executed ~
and retained include shipping documents; Bills of Lading; shipping-instructions; packaging operation and inspection records;;
packa'ge curie content and radiation and contamination: level-records; container and shipping licenses and permits; shipping -
incidents reports;1 hipping-plans; package designs; and shipping protection procedures'. Those. records.are maintained by Traffic and Warehousing Department. Quality Assurance is required to retain Packaging Nonconformance Reports; Corrective Action Reports;.and Procurement Inspection Feports.
e.
S0P K-17 ' Audits of Special Nuclear Material-Control and Radioactive Material Shipping' Systems
~ Requires-audits by the Quality Assurance Department of the
-special nuclear material accountability control system and the special nuclear mat. rial physical protection system.' ' Requires an 6
annual audit-by the Ouality Assurance Department of the licensee's radioactive material shipping and receiving system. -A written report of the audit findings and recommendations is directed to the Vice President and Controller-Finance and Administration.
Requires'the Quality Assurance Department to conduct quarterly selected audits of shipping and receiving operations with noncon-formances reported to the concerned supervision and corrective action initiated according to Quality Assurance Departments procedures.
The above standard operating policios are the primary documents by which the licensee management controls the receipt and shipment.of radioactive materials.
Individuals are not designated, although authorizational responsibility is designated in those S0Ps.
They include a documented program of periodic of audits.
Audits of packagings and loaded packages are performed by the Quality Assurance Department. The Quality Assurance Department has developed a number of procedures addressed to the inspection, maintenance, 'and quality assurance verification of the adequacy of shipping containers. Documents of that type include:
- a..
Receiving and Maintenance Inspection of Fuel Element Catainers, QAP-065-302-023.
b.
Shipping Inspection of ATR Fuel Elements, QAP-065-302-014.
c.
Packaging and Inspection Procedures for Shipping University of Missouri Fuel Elements, N263-QAP-14.
d.
Packaging and Inspection Procedures for Shipping University of Michigan Fuel Elements, N263-QAP-14.
e.
0A Program for Packaging License Radioactive Material for Shipment, N00lPP000002 (QA Program required by 10 CFR 71.51).
f.
QA Program for Packaging License Radioactive Material for Shipment, N001QFP810001 (QA Program required by 10 Cf R 71).
- 9 Radioactive Dry Waste Disposal--QA Assurance, MBA 08 NQ650AL302015 (procedure applies to dry contaminated waste from the Quality Assurance Laboratory).
Other operating and service departments have also developed procedures for the shipment of radioactive materials.
Documents of that type include:
a.
Solidification of Radioactive Liquids at NMDF ho710P270079.
b.
Procedure for Measuring, Packaging, and Shipping SNM and Non-SNM Radioactively Contaminated rrotective Clothing, N0010P240040.
c.
Shipment of Radioactive Waste, N0010P16003.
d.
Solidification of Radioactive Liquid and/or Sludge in Weir Box, N7040P990012.
e.
Solidification of Radioactive Liquids, ';7040P990008.
f.
Packaging Radioactive Waste, Low Level, N0010P160002.
h.
Packaging Radioactive Dirt and Concrete, N0010P160001 (LSA Material generated from the decommissioning of DOE facilities),
i.
Procedure for Unpackaging Radioactive Materials, OP-001-140-005.
Additional, more detailed procedures exist in the area of shipping and receiving radioactive materials. An example includes an internal letter from the Manager, HSRS giving instructions for the inspection of reusable shippii.J containers for damage and their repair and reer.try into the shipping cycle. A second example is the list of instructions for executing Form 710-S-1, Hazardous Material Shipping Instructions, which calls for required inspections and approvals before a shipment of hazardous material may be made.
A similar review of management controls of transport activities was reported in NRC Inspection Report 70-25/79-03 for an inspection conducted on March 26-30, 1979.
That report also included a review of the shipping container models and associated Certificates of Compliance used by the licensee.
Also included was a review of the licensee's files with respect to reference material appearing in the Certificate of Compliance forms. The March,1979 inspection also included a review of four Shipping Fonns 710-S-1 as they apply to shipments of fissile material from the licensee's premises.
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The' presently 1 reported inspection: included a -review'of one
- 2 Form 71_0-S-2, Receiving and Mainte' nance ' Inspection of Hazardous Ma'terial Shipping Containers.for the repair and recycle of a Certificate' of; Compliance No. 5088 shipping container.. This form indicated the evaluation cf the damaged container by Traffic Department and HSRS and its delivery to Manufacturing' for. repair.
'This inspection-included a review of all 710-S-1 forms associated 2 with shipments made during January and February,1981. -
NRC' Inspection Report 7C-25/80-04 presented %e results of a review of
'the licensee.'s Quality Assurance Program w' espect to the licensee's transportation activities. That report alt.ncluded results of.an
' inspection-of a number of low level radioactive waste containers awaiting; shipment to a 1icensed land burial site.
Quality Assurance procedures require the inspection of-DOT Model-17H reusable-shipping drums. The loaded shipping drums described above were of that type and appeared to be' in' good condition.
Similarily moderators and neutron absorbers which are used in the ATR shipping container. (Certificate of Compliance Number 5905) are determined to be inplace by the Quality Assurance Department at the time of the shipment. Those containers are also inspected for damage upon empty return by the Traffic'and Shipping Department.-
The licensee has made no foreign shipments for several years and has-never made any plutonium shipments by aircraft according to 1.icensee representatives..The licensee does not rely upon special form in shipping radioactive materials possessed by authority of his NRC license.
The licensee' routinely applios security seals to packages to provide evidence that the package has not been illicitly opened.
The only -liquid shipped by the licensee over the past several years has-been fuel from the licensee's L77 reactor. The licensee is contemplating shipping fuel from a similar reactor designated as the Model L85 at some time in the future.
Instructions for opening packages accompany shipments of licensed material only in the case of plutonium.
In that cue a diagram showing the container, its internal structures, and-the location of the fuel accompany the shipment.
The licensee conducted a training session in the shipment of hazardous materials in February 1979 which was attended by approximately 150 employees who were associated in some way with those shipments. That training course has not been repeated. The Hazardous Material Shipping Instructions Form 710-S-1 (mentioned above) serves as an instruction, a recorsi, and an approval fonn for shipments of licensed material.
It indicates, among other matters, the name and address of the consignee; the type of hazard; special shipping instructions required by the requestor; the package and type of transport used as
-indicated by the packaging engineer; a record that shipping
-inspections have been made by operations and quality assurance personnel for material verification, packaging loading, and package integrity; and approvals by Fire Protection, Industrial Safety, Nuclear Material Management and Criticality Safeguards personnel.
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q At the beginning of this inspection on March 3,1981 the NRC inspector wae informed by the licensee of a shipment of Cobalt 60 and Magtnese 54 from Mol, Belgium. The shipment was picked u the Los Angeles Airport by Castelazo and Associates (Brokers)p at on February ?0, 1981.
The licensee was notified on February 20, 1981 and picked up the shipn.ent using a licensee truck.
That truck arrived at the licensee premises at about 3:15 PM.
Relying upon the Radioactive III label which indicated 41/2 mr/hr at 3 feet and container contents of 30 millicuries Cobalt 60, the licensee, without making a radiation survey or surface contamination evaluation, transported the container to the De Soto Avenue radioactive materials storage vault and placed it in storage there.
It was not until a radiation and contamination survey was made on the morning of March 3,1981 that the licensee determined a radiation level of approximately 475 mr/hr at the cylindrical surface and 15 mr/hr at three feet from the shipping container.
No detectable, removable alpha or beta-gamma activity was determined in the contamination survey.
The fact that no radiation or contamination survey was made of the container at the time of its arrival at the licensee's premises is contrary (1)to the licensee's internal procedures as indicated in Section VII-B 1.b.
of the licensee's application and the licensee's procedures as expressed in 50P J-24,Section III.
The shipment consisted of less than a Type A quantity of radioactive material which was in special form (encapsulated).
This matter is regarded as a deviation from the ' licensee's internal procedures.
No exposure in excess 10 CFR 20 limits occurred and no rule or regulation of the NRC or D0T occurred on the part of the subject licensee.
The two persons who handled the container in question on February 20, 1981 were wearing film badge dosimeters which, when subsequently processed, indicated ten mrem or less total exposure for the first quarter of 1981.
During the inspection the NRC inspector viewed the unopened shipping container, verified the radiation readings at the surface and at 3 feet from the container and subsequently witnessed the opening of the shipping container. The container and contents weighed approximately 65 pounds.
The container was similar to a 10 gallon, metal paint can and appeared virtually undamaged.
It exhibited a Radioactive III label indicating contents of 30 millicures Cobalt 60 and a transport index of 4.5.
External marking also indicated " Type A".
The container was sealed with a lead and wire seal and its lid was crimped to the body of the container with metal fasteners.
The open container exhibited an inner container which was centered in the paint can by use of cardboard spacers which in turn were backed up by plastic packing ma terial.
Lead sheet had been fomed to provide shielding in the radial and vertical, axial directions.
The inner container was provided with top and bottom lead shielding and rested upon a circular lead shield at its bottom. fio particular defortnation of any of the internal parts were observed although it was possible for the inner container to move about an inch in the radial direction.
It was concluded that the observed surface radiation level was due to inadequate shielding.
The container and contents were reassembled and delivered to the researcher who had ordered the irradiation at liol, Belgium.
The materials being irradiated were doubly encapsulated in a welded 304 stainless steel capsule. All irradiated materials were elemental metals, alloys or oxides and were non-fissile with the exception of 1.01 milligrams of uranium-235. That uranium-235 was also encapsulated in a gas tight vanadium capsule. Licensee representatives indicated that af ter radiation the material had " cooled" for about one year. A gamma scan of the radiation emanating from the container indicated the presence Cobalt 60. The itinerary of the shipment from the Mol laboratory to the licensee's facilities in Canoga Park is available in the Region V files.
3.
Radiation Safety Audits and Studies This inspection included a review of the licensee's radiation safety audits and reviews dating to the last inspection.
They included quarterly radiation safety reviews-for the Fuel Manufacturing Building tiumber 001 and i.he !!at Cell Facility Building 020; annual checks on air sample locations at both the De Soto Avenue and Santa Susanna Facilities; revaluation of the maximum permissible lung burden for uranium due to an increase in the uranium-234 content of starting material in use; publication of additional preccutions to be taken during 00P tests of filters; updating of the emergency telephone call lists; a Quality Assurance Department Audit of the Criticality Safeguards Program; and a radiation exposure summary of data acquired during the EBR-1 decladding project.
4.
Criticality Studies Calculations made by the licensee since the last inspection indicate that it is virtually impossible to flood the De Soto Avenue fuel storage vault with the 12 available sprinkler heads delivering 300 gallons per minute. Those calculations show that a flow of approximately 70 gallons per minute would occur under the vault door at a one foot head of water within the vault. An additional flow of 354 gallons per minute through a 31/2 inch diameter pipe at ground level would occur through the rear wall of the vault.
An approximate equilibrium between the sprinkler head flow and the flow of water from the vault would occur at a 6 inch head of water.
Fissile material is stored no closer than 18 inches above the vault floor level.
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5.
' Restricted Access Area Entry Permits This inspection included:a review of all Restricted Access Area Entry Permits issued from January thru February 1981.
Fif ty-nine access permits were issued over that period time. Those permits appeared to be properly executed with respect' to health and '
safety precautions required 'and.were neat and legible.
The required
. approvals;of supervision.and representatives of HSRS appeared on the
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permits in all cases. Quite'often the signature of the manager.of the' fuel manufacturing areas did not appear 'od the fonns.
6.
Management Interview The scope and the.results of this inspectionLwere discussed with
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licensee management at the. conclusion of the inspection on March 6,1981.,
Licensee representatives were informed that the failure to make a' survey of the. package received from Mol, Belgitm, while not a violation of NRC rules and regulations nor contrary to the guidance of Regulatory Guide 7.3, Procedures for Picking Up snd Receiving Packages-of Radioactive Material, was nonetheless. a deviation' from their-internal procedures for handling incoming shipmr.nts.
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