ML20035G201
| ML20035G201 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 04/23/1993 |
| From: | Carr C FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9304260296 | |
| Download: ML20035G201 (5) | |
Text
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~'%dd An Amencen Company with Worldwude Resources PD. Box 11646 Lynchbuty VA 24506-1646 Telephone:B04-522-6000 April 23, 1993 U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington D.C.
20555
REFERENCE:
NRC Inspection Report No. 70-1201/93-01, Reply to a Notice of Violation.
Gentlemen:
This letter provides the written explanation and corrective action taken for the violations that resulted from Inspection No.
70-1201/93-01.
Attachment I addresses the violations in detail.
If questions should arise during your review, please feel free to contact either Kathryn Knapp (804-522-6202) or myself.
Sincerely, B&W FUEL COMPANY
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Carr, Manager Commercial Nuclear Fuel Plant cc:
Stewart D.
Ebneter Regional Administrator, Region II USNRC 101 Marietta Street, N.W.
Atlanta, Georgia 30323 260107 gjpg i 9304260296 930423 PDR ADOCK 07001202
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I ATTACHMENT I A
VIOLATION A:
10 CFR 71.5(a) requires each licensee who trans-4 ports licensed material outside the confines of i
j its plant or other place of use, or who dri2ver.)
licensed material to a carrier for transpo:
comply with the applicable requirements.? 'he regulations appropriate to the mode of transport i
of the Department of Transportation (DOT) in 49 l
CFR Parts 170-189.
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49 CFR 172,201(a) (4) requires that a shipping paper may contain additional information concern-ing the material provided thr> information is not Inconsistent with the requi-d description.
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49 CFR 172.201(c) requires Lnipping papers con-sisting of more than one page to be consecutively l
numbered and the first page to bear a notation j
specifying the total number of pages included in t
the shipping paper.
i 4 9 CFR 172.203 (d) (iii) requires that a shipment of i
j radioactive material must include the activity l
j contained in each package of the shipment in terms l
of curies, millicuries, or microcuries.
i contrary to the above, the licensee failed to meet l
DOT regulations for the shipment of hazardous l
waste in that:
l (1)
For a November 19, 1992 shipment of radioac-tive material, the additional description of the hazardous material as " Fissile Exempt" was inconsistent in that the shipment con-l tained no fissile material.
(2)
For the records reviewed between March 9, t
1992 through March 3, 1993, regarding radio-l active materials shipments, shipping paper documentation pages were not numbered consec-1 utively nor notated to indicate the total j
number of pages included.
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(3)
From March 9, 1992 through November 19, 1992, shipping paper descriptions for three radioa-ctive material shipments made to an approved waste broker did not include estimates of the non-gamma emitting radionuclide of Iron-55 (Fe-55) in quantifying the activity contained in the packages associated with each consign-1 ment.
This is a Severity Level IV violation.
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RESPONSE
Admission or Denial of the Alleced Deviation i
l We acknowledge the validity of the facts contained
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i in the no* ice of violation.
I Reason for Violation
-i (1)
The words " Fissile Exempt" was inadvertently included on a shipment that clearly did not contain fissile material.
We do require that shipping papers be independently reviewed l
prior to release for shipment.
- However, there were two shipments made on November 19, 1992 and one of them was " Fissile Exempt" and I
must have caused some confusion as both the j
preparer and the reviewer did not catch the jj error.
i (2)
For most radioactive material shipments, CNFP uses the bill of lading (BOL) and a radioac-tive shipping record (RSR) to meet DOT regu-i lations.
During the time of the inspection, l
the BOL did cross-reference the RSR and the RSR did have consecutive page numbers but the BOL was not included.
Since the BOL was used to meet the DOT requirements, it should have been included in the consecutive page num-bers.
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(3)
For quantifying activity for a radioactive material shipment, CNFP conducts an isotopic analysis and a dose rate conversion calcula-tion that relies solely on gamma emission.
J This method does not account for the activity that is contributed by non-gamma emitters such as Fe-55.
The activity of Fe-55 should j
have been evaluated and accounted for as incoming shipments had identified Fe-55 as being present.
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Corrective Steps Taken and Results Achieved I
1 (1)
Personnel conducting independent reviews for shipping papers has been instructed to pay closer attention to identify mistakes prior-to the release of the shipment.
I (2)
Starting April 26, 1993, the BOL and RSR will have consecutive page numbers.
l (3)
A complete isotopic analysis to include non-i j
gamma emitters is being performed on gross samples collected from botn SERF-1 and SERF-l 1
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The results of the analysis has not been t
received.
Corrective Steos that will be Taken and Results Achieved (1)
This item is complete.
(2)
Revisions are currently being made to RP-007 to instruct the preparer of shipping papers to use continuation pages.
(3)
Upon receipt of the analytical results, the activity of gamma emitters will be calculated using the former method.
The activity con-tributed by Fe-55 can be determined by using the percent abundance ratios reported in the isotopic analysis, i
The Date of Full Compliance (1)
We are in full compliance at this time.
(2)
Revisions to RP-007 shall be complete by l
l August 1, 1993.
(3)
The isotopic results should be available by May 15, 1993.
The evaluation to determine Fe-55 activity in radioactive material ship-j ments should be complete by May 31, 1993.
i VIOLATION B:
License Condition No. 9 of Special Nuclear Materi-als License No. 1168 (SNM-1168) requires the li-censee to use licensed material in accordance with the statements, representations, and conditions of Part I of the licensee's application dated June f
22, 1990.
f Part I, Chapter 3, Section 3.1.4 of the License l
Application dated June 22, 1990, requires the licensee to conduct all activities related to radiation protection in accordance with written and approved procedures.
Certificate of Compliance (COC) No. 9203, Revision (Rev.)
2, dated January 23, 1991, for Model No.
DHTF package requires that the marimum H/U ratio, considering all sources of hydror,enous material l
within the containment vessel must not exceed 1.3 Contrary to the above for the period of September 9,
1992 through March 5, 1993, the licensee ship-ping procedure for the use of DHTF containers to transport fissile material was inadequate in that
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1 the H/U ratio was not required to be calculated as specified by the applicable COC.
i This is a Severity Level IV violation.
RESPONS2:
Admission or Denial of the Alleced Deviation We acknowledge the validity of the facts contained i
in the notice of violation.
Reacon for Violation CNFP uses both the DHTF and the 2901 container for I
the transport of fuel pellets.
The container are similar in design and used interchangeably.
In September of 1992, the COC for the 2901 was amend-j ed which included the exemption of performing the H/U ratio.
When the procedure was changed to support the amendment, it was inadvertently changed for both the 2901 and the DHTF packaging.
Corrective Steps Taken and Results Achieved j
l The instructions to perform the H/U ratio and to
.I ensure that it does not exceed 1.3 for the DHTF l
container has been added to the procedure.
j Corrective Steps that will be Taken and Results l
f Achieved
.f The steps taken above have corrected the finding.
l The Date of Full Compliance i
i We are in full compliance at this time.
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