ML20199G341

Insp Rept 70-1151/86-04 on 860224-28.Violations Noted: Improper Shipment of Radioactive Matls & Failure to Comply W/Posted Criticality Control Requirements

ML20199G341
Person / Time
Site:	Westinghouse
Issue date:	03/19/1986
From:	Hosey C, Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199G324	List: ML20199G319 ML20199G330 ML20199G341
References
70-1151-86-04, 70-1151-86-4, NUDOCS 8604090118
Download: ML20199G341 (7)

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4 9 * " * * ,o MAR 9 91996 1 Report No.: 70-1151/86-04 q Licensee: Westinghouse Electric Corporation Nuclear Fuel Division Columbia, SC 29250.

Docket No.: ~ 70-1151 (Fuel Division) License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection Conducted: F bru 4-28, 1986 Inspector: /* !t G G. L. Troup' " Date Signed

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- Date Sign'ed C. M. Ho'sdy, Sectilon Chief .

Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspecti,on entailed 34. inspector-hours onsite -

in the areas of transportation of radioactive materials, radiation protection

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including procedures, instruments and equ'i pme'nt ,~ ' external exposure control, /

posting, labeling and control, notifications' ~ and reports, training 'and

' retraining, radioactive waste management, and, followup of previously . identified .

items. 4 Results: Two violations were identified - (1.) impropet shipment of, radioactive materials; (2) failure to comply.with posted criticality control requirements.

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2 REPORT DETAILS

1. Persons Contacted Licensee Employees

• E. P. Loch, Plant Manager

• W. L. Goodwin, Manager, Regulatory Affairs

• E. K. Reitler, Manager, R&E Engineering

• J. W. Health, Manager, Health Physics Operations R. K. _Burklin, Senior R&E Engineer R. E. Fischer, Senior R&E Engineer R. D. Montgomery, R&E Engineer A. Ramirez, R&E Engineer H. Foster, Safeguards Specialist Other licensee enployees contacted included three technicians.

• Attended exit interview

2. Exit Interview The inspection scope and findings were summarized on February 28, 1986, with those persens indicated in Paragraph 1 above. Two violations concerning the transportation of radioactive material and adherence to criticality safety postings were discussed in detail.

These were acknowledged by licensee management. Licensee management did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters (Closed) 84-13-01, Chewing in the Contamination Control Area. The inspector reviewed the licensec's response to the Notice of Violation, dated December 4,1984, and the supplemental response dated January 31, 1985, and verified that the specified actions had been implemented. The inspector also reviewed the changes made to procedure RA-203, " General Health Physics Rules and Recommendations," and the memo from the Deputy Plant Manager to all Contamination Controlled Area Supervisors, dated January 24, 1985, to re-emphasize these requirements. The inspector informed licensee management that he had no further questions and that this item was closed.

4 Transportation of Radioactive Material (86740)

a. The licensee periodically receives shipments of uranyl nitrate solutions from a scrap recovery operation by cargo tank (tank trailer).

After emptying and flushing, the licensee ships the cargo tank back to the owner. In 1985, four shipments were made: two on May 14 and two

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'I on October 22. Each shipment was classified " Empty" on the shipping ,

-papers. The papers also contained the statement "(Last contained Uranyl Nitrate Hexydrate Solution) NA-9178."

b. 49 CFR 173.427 requires that any packaging which previously contained radioactive materials and has been emptied of contents is exempted from the marking and labeling requirements provided that it complies w;th the requirements of 49 CFR 173.421(b), (c), and (e), and the internal contamination does not exceed 100 times the limits specified in 49 CFR 173.443(a) (e.g. , 22,000 dpm/100cm2). 49 CFR 173.421(b), (c) and (e) specify limits for external radiation levels, external contamination levels, and residual U-235 internally, respectively. The inspector reviewed the shipping survey records for the four shipments and, although the surveys revealed conformance wi'.h the external radiation and contamination limits, it was noted that the survey records did not indicate conformance with the residual U-235 or internal contamination levels. Licensee representatives stated that after the tankers were drained and flushed, accessible areas were visually checked for residual liquid or residues; in the absence of such residues it was believed that the U-235 content was less than the limit. However, because of the limited access to the interior, no measurements were made to confirm the internal contamination levels on any of the four shipments.

c. 49 CFR 172.202(a) requires that the shipping description of a hazardous

. material include the proper shipping name prescribed for the material in-172.101 and the identification number. 49 CFR 172.203(c)(1) states that, in addition to basic description of tre hazardous material on the shipping paper, the description may include " EMPTY:" or " EMPTY: Last contained ..." The shipping papers for the tankers contained the proper shipping name but had an identification number of "NA 9178" listed. 40 CFR 172.101 does not include this number as a proper identification; the listed identification number for uranyl nitrate hexahydrate is UN 2980.

d. 10 CFR 71.5(a) requires that a l'.censee who transports licensed material outside the confine of his plant, or who delivers licensed material to a carrier for transport, shall comply with applicable requirements of the Department of Transportation for that mode of transportation contained in 49 CFR 170 through 189. Shipments of the tanker as " EMPTY" without verification of the internal contamination levels, and with an incorrect identification number was identified as an apparent violation of 10 CFR 71.5(a) (70-1151/86-04-01).

5. Radiation Protection (83822)

a. Procedures The inspector reviewed the changes made to eight Regulator) fairs procedures and three new procedures issued to establish polk s and

4 requirements. All appeared to be consistent with the facility license and the regulations, and were reviewed and approved as required.

No violations or deviations were identified.

'b. Instruments and Equipment During tours of areas of the facility, the inspector observed the radiation protection instruments in use or available for use. -The inspector verified that all of the instruments were in the current calibration period, and those instruments in use were operating-on the specified range scale. The inspector also ' checked certain instruments for adequate battery operation and response to check sources.

No violations or deviations were identified.

c. External Exposure Controls 10 CFR 20.101 specifies the radiation dose standard,10 CFR 20.102 specifies the requirement for prior dose history, and 10 CFR 20.104 specifies the exposure limits for minors, 10 CFR 20.401(a) specifies the requirements for maintaining exposure records.

The inspector reviewed the computer printout " Personnel External Radiation Exposure Report" (NRC Form 5 equivalent) and verified that records were being maintained as required, and that the exposures for selected ' individuals were within regulatory limits. The inspector reviewed the files for ten randomly selected individuals and verified that a completed Form NRC-4 was on file.

The inspector observed that personnel dosimetry devices and accident dosimetry were being utilized in accordance with the regulations and Section 2.2.3 of the license application.

No violations or deviations were identified.

d. Posting, Labeling and Control 10 CFR 20.203 specifies the requirements for posting of areas or containers based on radiation levels on the presence of radioactive materials. Section 3.2.2.4 of the license app'.ication provides an exemption to the labeling of containers specified in 10 CFR 20.203(f) and gives an alternate posting requirement. During tours of facility areas the inspector observed that the postings of entrances, fences and areas were in accordance with the requirements.

10 CFR 19.11 requires that certain forms and documents be posted at the entrances to areas containing licensed material. The inspector verified that the materials were posted at the entrance used by plant personnel and the entrance used by construction contractor personnel.

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No violations or. deviations were identified.

e. Notifications and Reports 10 CFR 420 requires that certain notifications or written reports be submitted to the NRC:

10 CFR 20.402 - Thsft or loss of licensed material 10 CFR 20.403 - Notification of incidents 10 CFR 20.405 - Overexposure 10 CFR 20.407 - Personnel monitoring reports 10 CFR 20.408 - Termination of employment Additionally, 10 CFR 19.13 requires that an exposure report be sent to the individual following termination of employment or work. ,

The inspector discussed the conditions or situations which would have required a report under 20.402, 20.403 or 20.405 with the cognizant licensee supervisors. No instances were known to the licensee which would have required.such reports.

The inspector also reviewed the exposure report and the anr.ual personnel monitoring report submitted to the NRC (20.407). No exposures were identified which would have required a report. The inspector also reviewed the records for ten individuals who were listed as " terminated" and verified that the required reports had been sent to the individual (19.13) and to the NRC (20.408).

No violations or deviations were identified.

f. Training and Retraining 10 CFR 19.12 requires that instruction be ;iven to individuals working in or frequenting a restricted area. Section 3.1.4 of the license application specified the initial training requirements for new employees and the general refresher training on a two year basis. The inspector selected ten individuals from the external exposure report and verified that the required training was current.

No violations or deviations were identified.

6. Plant Tour (83822)

a. During a tour on February 27, 1986, of plant areas where licensed materials are handled, the inspector observed stainless steel containers (geocon containers) containing licensed material on a storage rack with " poly paks." However, the Criticality Area posting for the storage rack listed authorized containers as " poly paks or fibrepaks." The posting did not authorize the Geocon containers.

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b. License' Condition No. 9 requires that licensed material be used in accordance with the statements, representations, and conditions contained in Chapters 2, 3, and 4 of the application. Section 2.3.1.9 of the application states that storage of licensed material shall be subject to one or more of the following controls: (1) nuclear criticality safety postings with applicable rules, (2) designated floor markings or devices, (3) physical constraints for individual containers or stacks of containers. The inspector noted that this storage was a violation of the license as material was not stored in accordance with the Criticality Area posting.

c. Licensee representatives acknowledged that the Geocon containers were not listed on the Criticality Area posting but attributed this to an incorrect posting. The rostings for other storage racks allowed the Geocon containers. The nuclear safety authorization for the installation and use of the storage rack included the storage of Geocon containers. A licensee representative also pointed out that the dimensions of the Geocen containers are less than the subcrit unit diameter listed in Figure 2.3.2.3 of the license application; this was acknowledged by the inspector. Licensee representatives replaced the posting on the same day.

d. The inspector acknowicdged that the subject containers were in accordance with subcrit dimensions. However, the principal concern was that a new installation had been released for use and no one (workers, supervisors or auditors) had reviewed the posting and ^ noted the discrepancy in authorized containers. Licensee representatives acknowledged this conccr.n and stated that the necessity of reviewing the requirements for new installations would be discussed with workers and supervisors. Failure to follow the criticality posting requirements was identifisd as a violation of License Condition 9 (70-1151/86-04-02).

7. Radioactive Waste Management (84850)

a. Management Controls Procedure RA-211, " Low-Lavel Waste Responsibilities" specifies the responsibility of various departments regarding the generation, segregation, decontamiration, sorting, packaging, labelling and shipping of low-level wastes. Procedures RA-212 and RA-216 specify the requirements for oversight inspection control checks and release of material for final packaging.

These procedures assign responsibility of operations and review / release to different departments.

b. Quality Control Procedure RA-212, " Low-Level Waste Over Inspection Program" specifies l the requirements for twice-monthly inspections of packaged drums to '

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7 verify that the contents meet the requirements for disposal, and six-month audits of the wooden boxes. The inspector reviewed the audit reports for the period July 1985 - February 1986, and verified that the audits were performed at the specified frequency, findings and_results were documented, and corrective actions if any, were initiated and verified. Audit criteria and findings for the waste classification and waste criteria appeared to be consistent with 10 CFR 61.55 and 10 CFR 51.56.

No violations or deviations were identified.

c. Waste Classification The inspector discussed the classification of wastes generated and shipped to the waste disposal site. Tne classification was determined to be in accordance with 10 CFR 61.55(a)(6).

No violations or deviations were identified.

d. Disposal Site License Conditions The inspector verified that the licensee has copies of the NRC and State of South Carolina licenses for the disposal site, and is provided with amendments as they are issued. An audit program has been implemented to assure that packaged wastes comply with the burial site

. criteria.

No violations or deviations were identified.

8. Inspector Followup Items (Closed) 84-02-01, SCBA Regulator Diaphragm Certification: This item dealt with the changes in vendor recommendations for verifying the integrity of the regulator diaphragm in SCBAs. The licensee has implemented an annual test by the vendor to inspect the regulator diaphragm and verify the flow rate of the regulator. Procedure RA-205, " Respiratory Protection" has been revised to include an annual review with the vendor of recommended inspections and tests, and implementation of same.

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