ML20043A829

Responds to Violations Noted in Insp Rept 70-1201/90-02. Corrective Actions:Effective 900501,radioactive Matl Shipments Required to Have Independent Reviewer to Assure That Paperwork Addresses All Items

ML20043A829
Person / Time
Site:	07001201
Issue date:	05/14/1990
From:	Alto R BABCOCK & WILCOX CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005230169
Download: ML20043A829 (6)

Text

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B&W FuelCompany An Anwrican company with P.O. Box 11646 L

worldwloo Resourc** -

bi Lynchburg, VA 24506-1646 Hay 14, 1990 (804) s22 6000 U.S. Nuclear Regulatory Commission-ATTN:

Document Control Desk-Washington D.C.

20555

SUBJECT:

Reply To a Notice of. Violation

REFERENCE:

NRC. Inspection Report No. 70-1201/90-02 Gentlemen:

i Attachment I to this' letter provides the written explanation.and

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corrective action taken to each :of the four violations tha*

i resulted from Inspection No. 70-1201/90-02.

j In addition to the corrective' measures discussed in the attachment,-

I.have concluded that general training regarding transportation is-

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in order.

Chem-Nuclear-is recognized.as providing an excellent program of training for radioactive shipments.

We are presently examining -practicability of having' the Chem-Nuclear program provided in Lynchburg.

Failing that, we will be sending our key j}

people to the next available scheduled presentation.

If questions should'arise during your review, please.. feel free to contact either Kathryn Lester or myself.

Sincerely, B&W FUEL COMPANY 4

Richard A. Alto, Manager-Commercial Nuclear Fuel Plant

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Stewart D. Ebneter

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Regional Administrator, Region II l

USNRC l

101 Marietta Street, N.W.

j Atlanta, Georgia 30323 l

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3 9005230169.-900514 PDR :ADOCK 07001201 Ab'

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= ATTACHMENT I'

. VIOLATION A:-

110 CFR 20.311 (d)I requires that*a. shipment manifest -

be ~ oompleted forleach T radioactive; waste shipment sent to'a land l disposal' facility or a licensed waste processor. and that

_the-manifest

~ meet' 'the requirements _ of - 20.~311 (b) and (c) _

including

information concerning the total - radioactivityc in -

the shipment.

- Contrary to the - rJoove, this requirement was not met -

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in thati ;the' manifest prepared fori a shipmentT 'of!

radioactive waste sent tot a waste-processor on: June -

15, 1989,- did.not include the total-radioactivity

-in the shipment..

RESPONSE

Admission or Denialt of the' Alleged Viol'ation=

4 We! acknowledge the validity of-the facts; contained-in-the notice of. violation..

Reason for-Violation-The manifest used for theishipme'nt -on' June.15', 1989 Lwas Chem-Nuclear's: RadioactiveJ Shipment: Hanifest' Form.

The form -incorporates-_ two1 block' items,v six and seven,. where - the total: activity..should be reported. The reportable total activity,L: block _. item six, was inad,rertently left blank. LBlock item ~seven did, however, report the. total activity for all' isotopes as 54.7 mil 11 curies.

.Qgrrective Sten Taken an'd Results Achieved' At the time of E,he shipment in question,c radioactive-material-shipments.were being prepared by? one person.

As of.May.

1, 1990L-we' requirer that radioactive' material.shipmentsihave an independent L

reviewer: to assure.that the paperwork-addresse's f all -

items.

The -reviewer -indicates ~

concurrence 'by '

sinitialing the BOL and the RSR next to the signature l'

of-the preparer.

VIOLATION B:

.10 CFR 71.5 requires 'that -each licensee who 3

transports licensed material outside t-thel confines R

of its plant or other-place of use comply-with. thel l

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applicable requirements of the Department' of' l

Transportation'(DOT) 49 CFR 170 through1189.

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. ITEM 1:

T49 CFR1172.203 (d)- raquiraalthht thy chipping p;pera -

which-accompanyLa' shipment offradioactive. material '

specify, among other things, the activity contained in each packagelin: terms of, curies, millicuries-or 4

microcuries'and-a description of_the chemical and physion12 form of'the material being' shipped.

Contrary to the ' above, the a DOT requirements ; were

.not met in that,- the; shipping paperstforea' waste shipment made. on. June' 15,11989,1 did not include:the.

activity. in each - package,< and the shipping papers.

for'a shipment of fieldiservice_ equipment-(Bill'of-Lading Number _ 58752): made -on March 2,1990, did not-contain_the' physical form of the material.

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RESPONSE:- Admission or Deni'al of-the' Allested Violation' Wet acknowledge;the validity.of the' facts containedL in the! notice of; violation.

Reason for violation-To satisfy the : paperwork -. requirements Lof _-49.

CFR

'172.203,- a Bill of: Lading (BOL) and1a.' Radioactive Shipment Record'_(RSR)Lis'used.

The BOL furnishes 1

the basic description of'49 CFR 172.202'and' the RSR provides< the.' additional information of 49 CFR 172.203.

We"believe'this is acceptable:per the=49 CFR 171.8 definition of " shipping _ paper _".

49 CFR-171.8 states' " shipping paper. means:a shipping-order,.

billLof lading, ' manifest :or..other shipping document serving - a similar^ purpose' and'Lcontaining. the information: required.byL 172.202, 172.203 and 172.204."

' Corrective Sten Taken and-Results Achieved As of-May 9, 1990, the! BOL has been ! modified 'to.

refer, for clarification purposes,ctofthe manifest for the required information'for each package'.

In-l addition, the physicall form ' will be notedron the RSR for 'all shipments.

iPre-printed.tBOLs that 1

include this'information will be ordered-and will be available-to use by the end of-June 1990.

ITEM 2:-

49 CFR

.173.427-states that-l packaging

. hich j

w previously contained radioactive materialHand has i

been ' emptied. of-contents " as far.as practical', is' excepted from the : shipping paper and.certifibation, marking and labeling requirements provided that the j

internal contamination does not exceed 100 times the j

limit' ' in - 173.443 and the package is prepared for 1

shipment as specified in' 173.'421-1.

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49ECFR 173.421-l rsquirso that cxesptsd rzdioactiva L

materials packages be certified as.being ecceptable for transportation by':having: ainotice enclosed'in'-

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or -on the-package:; or otherwise forwarded:/with the:

b package which includes the.name of the _ consignor or

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consignee-and a; statement thati the package conforms.

to.the conditions andilimitations specifiedEin_49-CFR 173.427' for excepted radioactive material',-_' empty packages.'UN2908.

Contrarycto the 'above, the' DOT: requirements ' were not met, sin thati--'on June-12,"1989,_ five.shipmenteL tof. Uranium JHexafluoride (UF6) cylinders ~ (Bill: of

-Lading Nos'.'56742,-56748,;56748, and_.56749),Lwhich

previously! contained radioactive. materiali and'-had

been; emptied,-

were made.~and internal contamination-surveys were ;not. performed on any of thel cylinders.,

Also, the shipments, wereE:made f without -1 certifying -

thatn

'the _Lahipments. jwere

_ acceptable!

'for itransportation..becauseL tne; requiredl. statement 1 of conformance was,not included on :thel shipping

' paperwork..

. RESPONSE: Admission or Denial of the Allemed= Violation-L We acknowledge the validityioffthe factsTc'ntained o

in the notice;of violation.

Reason for~the Violation-Access to > the inside; of-the5cylihders ; requires ;"'

equipment:and facilities not-! normal tot a - storage condition, therefore. "an :internalo survey-ist not-

! feasible.

They were classified-asLempty packagings becau'se' oft. washing' certificates :on ~ file,that

-demonstrated that otheDcylinders were free; from,UF6.

Also, the-taref. seight'Lversus-the net' weight indicated that the uranium -content was zero. 149 CPR 173.443,- Contamination control,,..which seta - the 3

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specified -limits,: states L that 'other: methods; cf j

assessment 'of:. equal or greater efficiency Smay-be 1

used.

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Corrective-Sten Taken and Results Achievedu b

For future empty:shipmentsLoflUF6: cylinders. when i

internal' contamination ' survey 1is! not-/ feasible,-

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' c-an an assessment will" be made, documented and included -

as part of the paperwork.

We will: continue',~as we have in the past, to. conduct internal smear.: surveys -

on all other packagings classified as empty.

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Procedura. - AS-1111,'. Shipm*;nt i ofJ l

1 Radioactive Materials, will'be revised:to address empty-UF-8 shipments.

This wi'll be: complete by the j

end' of June 1990' 1

The lack of the ' ' certification 1 statement. - was " an oversight.on our' part r _' Health Safety Procedure : AS-j

' 1111,_.' Shipment ofi Radioactive j Materials,. requires-a certification statemention fthelbill ofa. lading.

We have: include'd such a istatement ' on all'" bills of u ladings Jin : the'. past for? empty fuelEcontainers and?

pelletLeontainers.. This kindiof. omission should be-eliminated'with the. use ' of an. independe'nt - reviewer; i

The pre-printed _ _BOLs.: will - also? include: :the-certification--statement.

ITEM.3:

49 CFRL173.475-requires that before eachashipment' I

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_of - anyi radioactive f materia 11 package, ~ the shipper.

ensure by>' appropriate 4 test that"Lthe external radiation.and contamination -levels are within-

. allowable': limits.

o 49 CFR: 173.443 'requirest that. >the-non-fixed--

(removable) radioactive contamination conL<the

.i external surfaces Lof' each packageV be. below 2200 -

disintegrations:

per minute 4 per.. 100.

4 square centimeters J(dpm/100cm2) beta-gamma and,220?dpm/100

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cm2 alpha-contamination.

'4 Contrary-to, the labove,- the ' DOT L.l requirements.were not1 met in.that,;on" October'12, 1989 LandJJanuary:

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1989, two fuel shipments (Bill ofLL'ading'Nos.

.01201 andJ01253, respectively) )-' were made Ewithout-performing.. non-fixed '. l beta-gamma

. contamination surveys. of the-external ' urfaces' of the~ shipping-s containers.. Also, one oflthefUF8. cylinders' shipped on June - 12, - 1989, had;no' radiation ' nd contamination a

level surveys performed on-thes extern'alo surfaces.-

RESPONSE: Admission or %snial'to<the Alleged'Violationu

~i We acknowledge the. validity of: the facts contained -

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L in the notice of violation.

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Reason for Violation-d We concur.that in ' order to meet!the intent 1of-49 h

CFR 173.443. smear-surveys for both alpha:and beta--

L gamma. contamination' need.ito be performed on(all d

I incoming and outgoing radioactive ~

material h

shipments.

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CorrectAya Sten ' Taken and -Restilte Achieved-i

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As - soon-as the..overeirght. was brought' to our intention, all'availablo containers were= surveyed for.

beta-gamma contamination with-acceptable results.

And-as of March 9, 1990, all shipments are monitored for both alpha and beta-gamma non-fixed contamination. Shipping survey forms, revised to include the results ; for removable beta-gamma contamination, were in place ~May 14. 1990.

The investigation. conducted by Mr. Bassett indicated. that:- our transportation program bad several weaknesses most in' which can be

i alleviated by

having 'the paperwork reviewed.-by. qualified j

individuals.

Previously,:.one individual _ prepared the': shipping.

j documents.

As-an-interim measure, a review is being conducted by-1

' individuals who-have had in-house training and are-familiar with.

l the shipping procedures.-

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