ML20147F794
| ML20147F794 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/06/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20147F764 | List: |
| References | |
| 70-1151-97-01, 70-1151-97-1, NUDOCS 9703270208 | |
| Download: ML20147F794 (20) | |
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j U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70 1151 License: No.: SNM 1107 Report No.: 70-1151/97-01 l
Licensee: Westinghouse Electric Corporation l Facility: Commercial Nuclear Fuel Division Location: Columbia. SC 29250 Inspection Conducted: February 3 6, 1997 I
Inspectors: W. Gloersen. Senior Radiation Specialist A. Gooden. Radiation Specialist i B. A. Parker Radiation Specialist l I
Approved by: E. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety ;
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i Enclosure 2 l 9703270208 970306 PDR ADOCK 07001151 C PDR
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EXECUTIVE
SUMMARY
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Commercial Nuclear Fuel Division NRC Inspection Report 70 1151/97 01 l
The primary focus of this unannounced inspection was the observation and i evaluation of the licensee's radiation protection, waste management, and '
i radioactive materials shipping programs. The report includes inspection efforts of three regional inspectors. The inspection identified the following ;
j aspects of the licensee programs as outlined below: !
BADIATION PROTECTION ,
e Although the observed radiological work and exposure control practices were acceptable, a violation was identified for failure to follow 3
i contamination control procedures in procedure RA 203, General HP Rules )
and Recommendations, e All exposures were less than 10 CFR Part 20 limits. j e The licensee's policy regarding a declared pregnant woman (DPW) was mo.o i restrictive than the definition of DPW in 10 CFR Part 20 and potentially '
inconsistent with other federal laws outside of NRC jurisdiction.
1 e The respiratory protection program lacked a tracking mechanism for l preventing untrained or unauthorized users from donning equipment.
i WASTE MANAGEMENT l e The waste shipping program was acceptable and capable of accomplishing j its safety objectives. .
e The control and tracking of waste shipments were adequate.
l TRANSPORTATION OF RADI0 ACTIVE MATERIALS i e Inconsistencies and lack of the proper regulatory references in the MCC ;
package pre)aration procedures indicated that more thorough technical review of t1e procedures was warranted.
e A non cited violation was identified by the licensee for failure to aroperly prepare a package for shipment to ensure that the removable ;
3 eta / gamma surface contamination was less than the applicable Department of Transportation (DOT) limits.
e Management and quality controls to remove from service fuel shipping containers with expired certifications were less than adequate, resulting in a violation for the failure to reins)ect two model MCC new fuel shipping container.s (M140 and H230) within t1e five year frequency in accordance with the Maintenance Program specified in the supplement to the Certificate of Compliance (CoC).
httachment: ;
Persons Contacted and Exit Meeting t List of Items Opened. Closed, and Discussed List of Acronyms
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l Report Details I. Radioloaical Controls l
A. Radiation Protection (R1) (83822) i l
1.
Radiation Protection Proaram Procedures (R1.021
- a. Insoection Scoog The inspector reviewed the licensee's program for development and implementation of Radiation Chemical Mrk Permits (RCWPs). Safety
- Condition S-1 of License No. SNM 1107 renewal requires the licensee to comply with the statements, representations, and conditions contained in Chapters 1 through 8 of the Application dated April 30, 1995, and supplements thereto.
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Chapter 5, Section 5.2.1 of the License Application specifies the l j conditions for issuing a radiation work permit (RWP). Specific requirements for the RCWP program were documented in Procedure RA-207 " Radiation Chemical Work Permit," Revision (Rev.) 15, dated i January 16. 1997.
- b. Observations and Findinas 4 The inspector reviewed the licensee's procedures for issuing RCWPs and several examples of RCWPs issued in 1996 and 1997. The RCWPs l reviewed involved work activities in Conversion, Integrated Fuel !
Burnable Absorber (IFBA), and Advanced Waste Water Treatment
, building areas. The health and safety limits and conditions noted on the RCWPs-were acceptable and clearly specified, The inspector noted that three of the RCWPs selected were considered open, but :
l no activity associated with the open RCWPs transpired during the i
- period of the inspection.
- c. Conclusions Based on the review of documentation and tours of the controlled area, the inspector determined that the RCWPs were requested and generated in accordance with procedures. The approariate reviews,
, check-lists, and forms were executed by Regulatory Engineering and Operations (RE0) personnel.
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- 2. Radiation Protection Proaram Eouioment (R1.03)
- a. Insoection ScoDe The inspector toured the main process areas in addition to the outside controlled areas of the facility.
Included were chemical conversion, powder preparation / pellet pressing, rod loading, UF6
- cylinder recertification facility, uranium recovery, men's change 4
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i room, the IFBA facility, whole-body counting lab, and the 1 respiratory protection facility, to verify that radiation i protection equipment and controlled area survey equipment was
- calibrated and operational.
) b. Observations and Findinos Instruments used for frisking were checked at several step off pad !
locations for operability and current calibration stickers. In 4
addition.- controlled area survey instruments and fixed air samples l
! were also checked for operability and calibration. The inspector '
did not identify any concerns with inoperable instruments. Fixed I air sampling locations were examined and found operational and flow rates were within set points. Selected survey instruments and the whole body counting equipment were found operational and survey instruments were within calibration dates.
- c. Conclusions Based on the response of instruments and calibration dates, the administrative controls appeared to be effective in ensuring that instruments were operable and calibrated at the required frequency in accordance with license requirements and procedures.
- 3. External Exposure Control (R1.04)
- a. Inspection Scope !
The inspector reviewed personnel exposure data based on the results from three quarters of thermoluminescent dosimeters (TLDs) and estimated external exposures for October through December 1996, to determine if exposures were in compliance with 10 CFR Part 20 limits.
- b. Observations and Findinas According to the records reviewed and an interview with a member of the licensee's staff, the highest total effective dose equivalent (TEDE) assigned during 1996 was 3.49 Rem to an ammonium diuranate (ADU) Conversion employee. In 1995, fifty-six workers exceeded the TEDE ALARA goal of two rem. During 1996, there were twenty six employees who exceeded the two rem ALARA goal. The collective dose for 1996 was 301 person rem as compared to 374 person rem for 1995. Personnel assigned to the ADU Conversion area were the maximally exposed with a collective dose of 95.73 person rem, followed by personnel assigned to pelleting with a collective dose of 83.20 person rem. Based on three quarters of data for 1996, the maximum assigned deep dose equivalent (DDE) was 1 0.518 rem and was assigned to a worker in fuel bundle final assembly area.
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i The inspector reviewed general employee training documentation and l interviewed a member of the licensee's staff regarding the licensee's exposure control program for declared pregnancies. The review disclosed a procedurally formalized )rogram was not in i pl ace. However, the inspector noted that tie company policy l
regarding declared pregnancies was detailed in the training ;
manual. According to the company policy on this matter, an i employee must notify the licensee and provide medical l documentation confirming pregnancy. In response to the licensee's '
policy, the inspector indicated that the current policy was inconsistent with the definition of declared pregnant woman (DPW) and the intent of 10 CFR 20.1003 regarding a woman voluntarily declaring her pregnancy rather than being coerced or required by the licensee. The inspector briefly discussed the civil rights aspect of the licensee's policy and the potential impact on female employees. In response, a licensee representative informed the inspector that based on a review of the current policy statement, i it appears to be inconsistent with company practices and training associated with DPW and required additional reviews by the staff.
The inspector indicated that actions taken by the licensee in response to the DPW policy would be tracked as an inspector followup item (IFI 70 1151/97 01 01: Review licensee actions in response to DPW policy).
- c. Conclusions 1 Based on the records review and interviews, the inspector determined that the licensee's external exposure control program was adequate for evaluating and monitoring personnel exposures.
The inspector also noted that all assigned exposures were less ,
than the licensee's restriction limit (4 Rem) and regulatory '
limits.
- 4. Internal Exposure Control (R1.05)
- a. Inspection Scope The inspector reviewed exposure data based on air sampling results covering the period January through December 1996, and routine bioassay results to determine if exposures were in compliance with 10 CFR Part 20 limits.
- b. Observations and Findinas The licensee's primary method of assigning internal exposures to i personnel was based on fixed air sample results. In addition to l the air sampling program, employees that were assigned to i
>otentially contaminated and/or airborne areas participated in the ;
aioassay program for exposure verification. The inspector reviewed the licensee's internal exposure results for the period l l
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, , l 4 i January through December 1996. During 1996, the maximum assigned I
Committed Effective Dose Equivalent (CEDE) was 3.068 rem and was ,
assigned to an ADU Conversion employee. The next highest l (2.016 rem) was assigned to a worker in the Pelleting area. !
According to licensee documentation, the average CEDE for ADV '
Conversion and Pelleting was 1.676 and 1.243 rem, respectively.
1 The inspector discussed with a member of the licensee's staff the bioassay program and the administrative program governing the collection and processing of samples. As a verification that the administrative program was working, names were randomly selected from unusual incident reports (activities resulting in airborne release, or the potential for inhalation or ingestion of material) l covering the period November 4, 1996 to January 4, 1997, to determine if personnel had submitted urine samples and/or in vivo counts at the required frequency during the wriod. No problems were noted. The ins)ector also toured the w1 ole body counting facility and noted t1at the equipment had been calibrated and was ,
operational. ;
On an annual basis, the licensee conducted an assessment to I determine which employees or categories of workers are expected to i exceed an internal dose of 500 millirem CEDE. For assessment parameters, the licensee reviewed the employees internal dose data, airborne radioactivity concentration data, and the employee bioassay results for January through December 1996 to determine if 1 changes were necessary to internal exposure monitoring I requirements. The aforementioned assessment was documented in correspondence dated February 3, 1997. <
- c. Conclusions Based on the records review and interviews, the inspector ,
determined that the licensee's 1nternal exposure control program l was adequate for evaluating and monitoring personnel exposures.
All assigned exposures were within regulatory limits. Workers in the Uranium Recycle and Recovery Services (URRS) continue to be l assigned the maximum exposure. !
- 5. Resoiratory Protection (R).06) I
- a. Inspection Scope i The requirements for and the implementation of the respiratory protection training program were reviewed to determine if the program provided for the safety of individuals assigned to the controlled area and that various RCWP activities were in compliance with procedures and license conditions.
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- b. Observations and Findinas The inspector reviewed the procedure governing respiratory protection training (RA 205 entitled Respiratory Protection), and training records was reviewed for several individuals assigned to the controlled area. No problems were noted. The training for randomly selected individuals was current and up to date.
The inspector toured several areas of the facility including the face masks cleaning and laundering facility and noted that the full face cartridge respirators were cleaned and properly stored.
One aspect of the licensee's program which was discussed in detail involved the lack of a formal mechanism for dispensing and tracking respirators. The current program is based on an honor system where only employees with current training should remove respirators from storage locations for use. However, no mechanism was in place to prevent unauthorized users. As evidenced during the tour, at any given time an individual may retrieve a full face cartridge type respirator without challenge regarding the individual's certification status (i.e., the last training and fit test).
- c. Conclusions Based on the records review and interviews, the inspector determined that the training for those individuals selected was current and consistent with procedural requirements. In response to the inspector's comments regarding the lack of a tracking mechanism for preventing untrained or unauthorized users from donning equipment, the licensee indicated that this matter will be reviewed for considering additional controls.
- 6. Surveys (RI.08)
- a. Inspection Scope The licensee's contamination control survey program was reviewed to determine if the 3rogram was adequate and implemented in accordance with 10 C R Part 20, license conditions, and procedures.
- b. Observations and Findinas The inspector accompanied a Rad Control Technician during the performance of bi weekly contamination surveys, and observed the collection of smear samples from the following chemical conversion areas: URRS, va)orization, pellet loading, and bulk blender. In addition, the IF3A facility was toured to collect contamination smears. During the plant tour, the inspector collected independent smear samples from the following areas: drinking water fountain near the scrap recovery area (dock 4); a hard hat and telephone equipment inside the bulk blender room; the main step
6 off pad: conversion area hard hat; and the badge storage rack located inside the men's change room. Slightly elevated results were obtained from the remaining two locations. The maximum smearable activity for the drinking water fountain and hard hat were 900 dpm/100 cm' alpha, and 648 d)m/100 cm2 alpha, respectively. The action limits for )oth the water fountain and hard hat were 200 dpm/100 cm8 The area of most concern, however, was the results from the drinking water fountain. Immediate actions were initiated by the licensee to decontaminate the fountain to within acceptable limits. A member of the licensee's staff with responsibility in contamination control indicated that the fountain would be cleaned and placed on the routine smear survey schedule as were the other fountains.
In addition to the above observations, documerr tion in support of periodic surveys were reviewed as follows:
e Daily surveys for the period December 1996 February 1997 covering the main step off pad, maintenance step off pad, and the southeast expansion-step off pad e Bi weekly surveys for the period October 1996 - January 1997 covering waste treatment, respirator facility, chem lab, and MET lab e Monthly surveys for the >eriod October 1996 - January 1997 covering the gadolinium aay, docks 1-4, and UF 6 cylinder recertification The documentation for randomly selected areas disclosed that the surveys were performed at the required frequency in acccrdance with procedure R0P 05 014 (Performing Contamination Surveys of the Westinghouse Facility Rev. 20. dated May 23, 1996). Further, documentation showed that in the event area smear results exceeded the action limits, actions were taken to decontaminate area of smear to acceptable limits.
During the performance of surveys discussed above, the inspector did not identify any significant weaknesses in the licensee's program to maintain and control radioactive materials, nor with area postings. However. the inspector observed two examples of discarded candy wrappers on the floor in the chemical area and one example of discarded bubble gum was found at the entrance / exit to the men's change room from the chemical area. Actual consumption or chewing was not observed. Procedure RA 203, General HP Rules and Recommendations, prohibits the use of chewing gum, food products, and tobacco products in all chemical areas as well as outside production areas where uranium bearing materials and/or containers may be handled, and on the roof. The ins)ector discussed with licensee representatives that althoug1 numerous examples were not observed, the presence of such material did indicate employee disregard for area postings and exposure
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controls. During the exit meeting, the inspector stated that the significance of this matter would be further reviewed with regional management. The licensee acknowledged the inspector's concerns, and also indicated that they did not condone eating and drinking in controlled areas. In addition, a licensee representative stated that Regulatory Compliance audits had also documented isolated examples of gum and candy wrappers found inside the chemical area. The inspector informed the licensee that notification regarding the categorization of this matter would be provided via telephone following additional review with regional management.
- c. Conclusions No concerns were noted with the licensee's surveys. Smears were effective in contamination control. The program was implemented in accordance with procedures, license conditions, and requirements in 10 CFR 20.1501. Following a review of the inspection details and details associated with a previous NRC inspection (IR No. 70-1151/94 05), the licensee was contacted telephonically on February 18, 1997, and informed that the examples of candy wrappers and gum found in the control area were a violation for failure to follow procedure RA 203. In response, licensee representatives requested that the Regulatory Compliance inspections and corrective actions associated with inspections be provided to NRC for review and consideration as a non cited j violation (NCV). Based on the additional details and the ;
licensee's Regulatory Compliance inspections covering the period l October 1996 to February 1997, the NRC determined that the l violation did not meet the NRC Enforcement Policy for a NCV. The information presented by the licensee confirmed that internal j audits had continued to find examples of the violation and the i licensee had failed to take effective corrective action. On !
February 24, 1997, the Manager of RE0 was informed via telephone .
that a cited violation was identified for failure to follow I procedure RA 203 (VIO 70-1151/97-01 02).
- 7. Manaaement Oversicht of Proaram (R1.11)
- a. Inspection Scope The inspector reviewed the adequacy cf management controls for ensuring the investigation and followup of events or activities resulting from significant elevated airborne concentrations, or acute internal exposures to personnel.
- b. Observations and Findinas The inspector reviewed the licensee's Unusual Incident log book.
Randomly selected incidents were reviewed to determine if the licensee was taking actions in response to incidents consistent with procedural requirements. Form RAF-215 1, Health Physics
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4 Unusual Incident Investigation Form, were submitted by Operations personnel to Regulatory Engineering Operations personnel to report .
any unusual occurrence involving radiation safety requiring management attention. It appeared that forms for the selected incidents were issued and followed up in accordance with procedures. In the event personnel exposure exceeded the action level for percent derived air concentration (DAC)-hours, the ,
inspector noted that personnel were placed on bioassay >
restrictions.
- c. Conclusions The inspector determined that the Unusual Incidents reporting system appeared to be working in providing a mechanism for followup on events resulting from elevated airborne concentrations and internal exposures.
B. Radioactive Waste Management (R3) (84850)
- 1. Solid Waste Shiopina (R3.08)
- a. Insoection Scope The inspector reviewed and discussed with licensee representatives activities associated with the transfer of low level radioactive waste (LLRW) generated from onsite operations to a licensed waste !
processor for disposal. Specifically, the inspector reviewed the ,
licensee's program as it pertained to the requirements of !
10 CFR 20.2006 and Appendix F to 10 CFR Part Part 20.
- b. Observations and Findinos !
From a review of the records for solid waste dis)osals made from August 1996 to January 1997, it was noted that t1e licensee predominantly transferred its waste to a licensed waste processor.
The licensee shipped the LLRW as a radioactive materials shipment to the waste processor, who subsequently segregated, processed, and reanalyzed the material to determine the appropriate quantities of radionuclides. The inspector verified that the licensee provided an acceptable level of information in the shipping papers to determine the quantities of individual radionuclides shipped.
The inspector reviewed manifest records of three shipments of radioactive waste made from December 1, 1996 to January 31, 1997.
These waste shiments involved the transfer of radioactive materials to a licensed waste processor for treatment and repackaging. The manifests were complete and met the applicable requirements of the regulation.
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- c. Conclusions The inspector concluded that the licensee's waste shipping program was acceptable and capable of accomplishing its safety objectives.
- 2. Trackina of Waste Shipments (R3.09)
- a. Inspection Scope The inspector reviewed and discussed with licensee representatives activities associated with the notification of receipt of LLRW shipped to a licensed waste processor for disposal. Appendix F to 10 CFR Part Part 20 specifies the requirements for LLRW transfer for disposal at land disposal facilities, including the control and tracking of waste shipments.
- b. Observations and Findinas The inspector reviewed the licensee's procedures and shipping records to determine if a system had been established to verify that acknowledgement of receipt of the manifest from the waste processor had been received and that procedures were in place to effect an investigation in any instances wherein acknowledgement of receipt of the shipment had not been received within the time period specified in 10 CFR Part 20, Appendix F. For seven waste shipments made between August 1996 and January 1997, the inspector verified that the licensee had received an acknowledgement of receipt from the waste processor within the required time frame.
The licensee's records were orderly and well maintained,
- c. Conclusions The licensee's program for the control and tracking of waste shipments was adequate. The records were readily available and well maintained.
l C. Transportation (R4) (86740)
The inspector reviewed the licensee's program for both routine and non- .
routine radioactive materials shipments, including waste shipments, to !
determine whether the licensee had established and was maintaining an effective management controlled program, to ensure radiological and nuclear safety in the receipt, packaging, and delivery to a carrier of l licensed radioactive materials, and to determine whether transportation activities were in compliance with the applicable NRC and DOT transport regulations noted below. During the inspection, trans)ortation ;
activities associated with LLRW and fissile material slipments, l including procedural guidance, quality control (QC) activities, and record completeness conducted in accordance with 10 CFR Part 71, and .
49 CFR Parts 171-178 were reviewed. j I
I 10 10 CFR 71.5(a) requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivers
. licensed material to a carrier for transport, shall comply with the t 4
applicable requirements of the regulations appropriate to the mode of transport of the DOT in 49 CFR Parts 170 through 189.
l 1. Preparation and Delivery of Comoleted Packaaes for Shioment (R4.01 & 02)
- a. Inspection Scope The inspector examined the licensee's written procedures and shipment records related to the preparation and delivery of completed packages for shipment of licensed material.
- b. Observations and Find 1nas I (1) Procedures l
The inspector verified that the licensee had procedures for the preparation of shipping packages and delivery of the packages to the carrier for shi: ment. The inspector reviewed selected portions of t1e following procedures and informed the licensee of the comments following each procedure. ;
1 e M0P-755706 Clean Shipping Container, Rev. 7, dated l October 20, 1994 Step 5 did not make reference to NRC CoC 9239.
Ste) 7 did not address the inspection for water lea (s in the flange area as specified in the CoC, e M0P-755707 Refurbishing Shipping Containers, Rev. 29, dated June 20, 1996 Step 5 did not make reference to NRC CoC 9239.
Step 11.a made an incorrect reference to the obsolete RCC shipping container.
The procedure did not specify the use of Dupont Imron paint (which is specified in the CoC) for the painting of repaired and damaged paint areas.
e M0P-730703 Prepare Container for Loading Fuel Assemblies, Rev. 18. dated August 20, 1996 j Step 14 made an incorrect reference to the l obsolete RCC shipping container. ;
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e M0P 730713 Load Fuel Assembly into Shiaping !
Containers, Rev. 46, dated Mcember 12, 1996 Step 5 did not make reference to NRC CoC 9239. ,
Step 14 made an incorrect reference to the obsolete RCC shipping container.
e M0P-730706 Close Shipping Containers, Rev. 14, dated April 29, 1993
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Step 5 did not make reference to NRC CoC 9239. j e M0P 755708 Fuel Assembly Shipping Container Inspection Checklist (CF-75B 002), Rev. 7 dated October 20, 1994 Numerous references were made to the obsolete RCC shipping container.
Step 17 should be clarified to include quality control discrepancies (QCDNs) and f.ald operation reports (FORs) as specified in the license application for NRC CoC 9239, when 3 verifying that all field discrepancy reports -
(FDRs) have been cleared for each container file.
(2) Records On October 2, 1996, the licensee made a courtesy notification to the NRC RII Office detailing a report of an apparent excessive removable radioactive surface l contamination on two Model 30B UF 6 cylinders that were shipped from the licensee's Westinghouse facility to Siemens l Power Corporation. The inspector reviewed the rceport written by Siemens, the licensee's written assessment of the event, procedures for package preparation and radiological surveys, and the shipping records.
On September 25, 1996. the licensee was notified by Siemens that three out of 38 Model 30B UF6 cylinders appeared to _
have elevated beta / gamma removable surface contamination i that exceeded the Department of Transportation (DOT) limits l specified in 49 CFR 173.443 (Tcble 10). The estimated level l of removable beta / gamma contamination was 23,000 dpm/100cm .
! In comparison, the DOT limit was 22,000 dpm/100cm2. Siemens personnel estimated the contamination level by using mazzelin cloths that were smeared over most of the surface
! area of the 30B cylinders. The mazzelin cloths were l disposed of as radioactive waste follcwing the surveys and I
12 were later retrieved from the waste and re evaluated after the initial survey data were reviewed. It was assumed that -
the mazzelin cloths were not contaminated further during the :
time they were in contact with the radioactive waste. The !
contamination was reportedly located near the valves and rust stains of the cylinders. The transport vehicle was not contaminated.
Prior to this event, the licensee had been surveying cylinders for removable and direct alpha and direct beta / gamma activity prior to removal from the chemical area.
The cylinders were re surveyed after being loaded on the transporter for direct beta / gamma and removable alpha and beta / gamma. In addition, radiation surveys of the packages measured at contact and at one meter and of the vehicle were 3erformed. Procedure RP-02-004 did not require a removable
> eta / gamma survey of the cylinder prior to removal from the chemical area. Although the over check surveys after the cylinders were loaded on to the transport trailer included a removable beta / gamma survey, surveying a re)resentative area of the cylinders was not reasonably achievaale since the cylinders were loaded in a close packed array.
The licensee took prompt actions to correct the identified problem. As followup, comprehensive surveys were performed on 31 cylinders on inventory to determine whether elevated areas of contamination could be identified. The surveys were performed by using a mazzelin cloth to wipe the entire surface area of the cylinders, including the valve area.
The maximum removable beta / gamma activity indicated a total of 333 dpm per mazzelin cloth. Smear surveys were also performed on the tops, sides, and bottom of the cylinders and the following maximum results were noted:
(1) 21 dpm/100cm' (removable a1)ha) and (2) 33 dpm/100cm' (removable beta / gamma). In adcition, the RE0 Technicians were instructed to perform beta / gamma smears surveys before releasing the cylinders from the chemical area. During the onsite inspection, the inspector observed an RE0 Technician perform the required fixed and removable contamination surveys en four 30B cylinders prior to their removal from the chemical area. The technician performed the surveys in an acceptable manner and in accordance with approved procedures.
The actions taken to prevent recurrence included revising procedure R0P-02-005 Surveillance of UF6 Cylinders, Rev. 5, November 5, 199( +o clarify the requirement for performing beta / gamma surv the cylinders arior to removal from the chemical area. The survey form 10F 02 005 1 was revised to include documentation of removable beta / gamma survey .
data. In addition, administrative limits for the heel I cylinder surveys were specified on sketch ROS 02 0051:
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(1) removable beta / gamma <2200 dpm//100cm : (2) removable 2
l alpha- <200 dpm//100cm: (3) direct alpha- <500 cpm; (4) contact dose rate <200 mrem /hr: and (5) dose rate at one meter- <10 mrem /hr.
The inspector reviewed UFs survey records for the period November 1996 to January 1997. During that time period, one cylinder (#1092) was not released from the chemical area on i December 3,1996, due to removable beta / gamma contamination exceeding the administrative limit. The survey results for i the other cylinders were well below the administrative .
! limits specified in R0P-02 005. Ty)ically, the smear r surveys of the cylinders included tie valves top near the l valves, top, sides and bottom. During the survey record ;
review, the inspector noted that seven survey forms did not 1 specify the survey locations. The licensee agreed that RP- :
l 02 005 should be revised to provide additional guidance to ;
better document the survey locations.
The failure to properly prepare a package for shipment to :
ensure that the removable beta / gamma surface contamination was less than the limits specified in 49 CFR 173.443 (Table 10) was identified as a violation of 10 CFR 71.5(a) l requirements. However, this violation will not be subject ,
l to enforcement action because the licensee's efforts in ;
l identifying and correcting the violation met the criteria l l specified in Section VII.B of the NRC Enforcement Policy l l (NCV 70 1151/97 01-03).
I c. Conclusions The procedures related to the refurbishment, package preparation, loading, operating, and maintenance of the MCC packages generally implemented the requirements of the CoC, however the inconsistencies and lack of the proper regulatory references indicate that more thorough technical review of the procedures was l warranted.
l Although an NCV was identified for failure to 3roperly prepare a ,
l package for shipment to ensure that the removaale beta / gamma )
! surface contamination was less than the applicable D0T limits, the !
licensee's corrective actions were prompt and acceptable. As a !'
result, the revised survey program was improved and appeared capable of accomplishing its safety objective.
- 2. Certificates of Compliance (R4.04) '
- a. Insoection Scope The inspector reviewed selected NRC Certificates of Compliance i (CoCs) for packages used by the licensee to ship fissile materials.
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l 10 CFR 71.12(a) requires, in part, that a general license is I issued to any licensee of the Commission to deliver to a carrier for transport, licensed material in a package for which a license, l CoC, or other approval has been issued by the NRC.
The general license specified in 10 CFR 71.12 applies to a licensee who (1) has a copy of the certificate of compliance and the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging and to the actions to be taken prior to shipment: and (2) complies with the terms and conditions of the license, certificate, or other
! ap3roval, as applicable, and the applicable requirements of <
Su) parts A G, and H of this part.
- b. Observations and Findings l
The inspector reviewed the following two NRC CoCs for packages used by'the licensee to ship licensed material:
e NRC CoC 9239 Rev. 4. USA /9239/AF, Model Nos. MCC 3, MCC 4, ;
and MCC 5, expiration November 30, 1996.
e NRC CoC 9196, Rev. 9, USA /9196/AF, Model No. UX 30, expiration February 28, 2001. )
l The inspector noted that for the NRC CoC 9239 package, the 1 licensee submitted to NRC/ Spent Fuel Project Office (SFP0) on l October 1, 1996, a request to renew and change the MCC CoC. The ^
NRC responded by letter dated October 3,1996, indicating that the current NRC CoC was under timely renewal. In addition, the inspector verified that the licensee maintained current copies of the NRC CoCs and that the licensee had registered with the NRC as a user of the applicable NRC-certified packages. In addition, the inspector verified that the licensee had management approved procedures and controls for the use and maintenance of the MCC fuel shipping packages.
The inspector noted that the licensee's maintenance program for the MCC shipping containers consisted of a routine refurbishment i
program after each use and a detailed verification program that was to be conducted on a >eriodic basis (every five years). The inspector verified that t1e details of the routine refurbishment t l program as specified in the Maintenance Program specified in the l supplement to the CoC dated May 12, 1992, were included within approved operating procedures. However, through discussions with !
! licensee representatives and a review of internal memos, the l inspector determined that the licensee had implemented a plan to phase out the detailed five year recertification program for the l MCC shipping containers. The initial certification and verification process of the MCC containers occurred during the i 4
period December 1991 to December 1993.
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l Specifically, the detailed reinspection program required that the fuel shipping containers be inspected periodically (every five years) for the following: (1) verify the existing configuration
- to drawing requirements and (2) conduct a detailed visual l inspection on the gadolinium absorber plates to verify that (a) no l more than seven square inches total area of coating is missing
(b) no single area greater than one square inch of coating is missing; and (c) the coating is not flaking off or blistering. In contrast, the routine refurbishment activities only recuired a ;
visual inspection of the gadolinium absorber plates anc corresponding tamper seal after each use.
At the conclusion of the onsite inspection, the inspector identified this issue as an unresolved item (URI) since the i licensee was still in the process of gathering the information to determine if any of the MCC packages in use had fallen outside of i the five year reinspection window and whether any of those l containers had been used to ship fuel. During telephone l conversations on February 18 and 25, 1997, with the licensee, it I was determined that 17 model MCC packages, which re) resented less !
than 10% of the fleet, had not been reinspected wit 1in the five year window. The licensee indicated that by the end of March 1997, a total of 28 MCC packages will fall outside of the five year reinspection window. The licensee had placed a quality l control hold tag on the containers with an expired recertification date to prevent their use for transporting fuel.
In addition, the licensee informed the inspector that on February 3, 1997, two MCC containers which had not been re-ins >ected (M140 and M230) had been used to ship fuel to the Sea) rook facility. On February 26, 1997, the inspector informed the licensee that the failure to reinspect the two model MCC new fuel shipping containers (M140 and M230) within the five year frequency in accordance with the Maintenance Program specified in the supplement dated May 12, 1992, was a violation of Condition 10(d) of NRC Certificate Number 9239. Rev. 4 for package Model Nos. MCC 3, MCC 4, and MCC-5 (VIO 70 1151/97 01 04).
- c. Conclusions The implementation of the licensee's routine refurbishment program for the MCC shipping containers was acceatable and met the requirements of the NRC CoC. However, tie management and quality j i controls to remove from service several model MCC fuel shipping :
containers with expired certifications were less than adequate resulting in a violation for the failure to reinspect the two l model MCC new fuel shipping containers (M140 and M230) within the
- five year frequency in accordance with the Maintenance Program l specified in the CoC.
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16 II. Manaoement Meetinos A. Exit Interview (M1)
The inspection scope and results were summarized on February 6,1997, with those persons indicated in the Attachment. The inspector described the areas examined and discussed the inspection results, including the IFI and URI and the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report.
In the area of radiation protection, the ins >ector indicated that although numerous examples were not found, t1e significance of finding gum and candy wrappers within the chemical area would be further reviewed with regional management. The licensee acknowledged the inspector's concerns, and also indicated that they did not condone eating and drinking in controlled areas. In addition, a licensee representative stated that Regulatory Comoliance audits had also l documented isolated examples cf gum and c'andy wrappers found inside the l chemical area. The inspector informed the licensee that notification regarding the categorization of this finding would be provided via telephone following additional review with regional management.
During teleconferences on February 18, 24, 25 and 26 1997, the inspector discussed the issues regarding candy and gum wrappers in radiation control area (RCA) and the use of MCC fuel shipping containers that had not been reinspected in accordance with the maintenance requirements of the CoC. The licensee was contacted telephonically on February 18, 1997, and informed that the examples of candy wrappers and gum found in the control area was a violation for failure to follow procedure RA-203. In response, licensee representatives requested that i the Regulatory Compliance inspections and corrective actions associated with inspections be provided to NRC for review and consideration of the finding as a non cited violation (NCV). Based on the additional details the NRC determined that the violation did not meet the NRC Enforcement Policy for a NCV. On February 24, 1997, the Manager of RE0 was informed via telephone that a cited violation was identified for failure to follow procedure RA 203. During a subsequent teleconference on February 26, 1997, the licensee expressed dissenting comments due to the apparent low safety significance and the use of circumstantial evidence as a basis for the violation for failure to follow procedure RA-203.
In addition, during a teleconference on February 18, 1997, with the licensee, it was determined that two MCC containers which had not been I re inspected within the five year frequency requirement had been used to ship fuel to the Seabrook facility. On February 26, 1997, the inspector informed the licensee that the failure to re ins)ect the two model MCC new fuel shipping containers that were used to slip fuel would be identified as a violation. Dissenting comments were not made by the i licensee. l l
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ATTACHMENT
- 1. PERSONS CONTACTED Licensee Personnel ;
K. Bartsch, Technician, Regulatory Engineering
- J. Bush, Manager, Manufacturing W. Dougherty, Team Manager, WSS '
- J. Fici. Plant Manager
- R. Fischer, Regulatory Engineer
- S. Gantt, Regulatory Engineer
- W. Garvin, Team Manager
- W. Goodwin, Manager, Regulatory Affairs H. Green, Technician, Regulatory Engineering i
- J. Heath, Manager, Regulatory Engineering and Operations ,
J. Hooper, Senior Regulatory Engineer
- E. Keelen, Manager, Product Assurance N. Kent, Senior Regulatory Engineer
- R. Likes Senior Regulatory Engineer <
- F. Moorer. Transportation Specialist t
- E. Reitler, Fellow Engineer
- T. Ross, Manager Transportation
- T. Shannon, Regulatory Affairs Technician D. Trevett, Manager, Component Services
- W. Ward, Manager, Chemical Manufacturing
- R. Williams, Advisory Engineer Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
- Denotes those present at the exit meeting on Feb,uary 6, 1997 l
- 2. INSPECTION PROCEDURES USED i
IP 83822 Radiation Protection IP 84850 Radioactive Solid Waste Management IP 86740 Inspection of Transportation Activities
- 3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Description 70 1151/97 01 01 Open IFI - Review licensee actions in response to DPW policy.
70 1151/97-01 02 Open VIO Failure to follow procedure RA 203.
70 1151/97-01-03 Closed NCV Failure to properly prepare a package for shipment to ensure that the removable beta / gamma surface contamination was less than the limits specified in 49 CFR 173.443 (Table 10).
70-1151/97 01 04 Open VIO - Failure to re inspect the two model MCC new fuel shipping containers (M140 and M230) within the five year frequency in accordance with the Maintenance Program specified in the supplement to the CoC.
- 4. LIST OF ACRONYMS ALARA As Low as is Reasonably Achievable ADU Ammonium Diuranate cm2 Centimeters Squared CoC Certificate of Compliance DAC Derived Air Concentration DDE Deep Dose Equivalent DOT Department of Transportation dpm Disintegrations Per Minute DPW Declared Pregnant Woman FDR Field Discrepancy Report FOR Field Operation Report IFBA Integrated Fuel Burnable Absorber IR Inspection Report LLRW Low Level Radioactive Waste NCV Non Cited Violation NMSS Nuclear Material Safety and Safeguards NRC Nuclear Regulatory Commission QC Ouality Control QCDN Quality Control Discrepancies RCA Radiation Control Area RCWP Radiation Chemical Work Permit RE0 Regulatory Engineering and Operations RG Reguletory Guide RWP Radiation Work Permit SFP0 Spent Fuel Project Office TEDE Total Effective Dose Equivalent TLD Thermoluminescent Dosimeter UF Uranium Hexafluoride URI Unresolved Item URRS Uranium Recycle and Recovery Services VIO Violation