ML20210C172

Responds to NRC Re Violations Noted in Insp Repts 50-083/87-01 & 50-083/87-02.Corrective Actions:Produced New Policy Requiring Licensed Shipper & New Procedure to Control Shipment of Waste.No Shipments Until Procedure in Effect

ML20210C172
Person / Time
Site:	05000083
Issue date:	04/23/1987
From:	Vernetson W FLORIDA, UNIV. OF, GAINESVILLE, FL
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8705060099
Download: ML20210C172 (4)

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• T*' M8 April 23,1987 United States Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Atlanta, GA 30323 Attention: J. Nelson Grace Regional Administrator Re: Inspection Report No. 50-83/87-01 (Inspector B.K. Revsin)

Inspection Report No. 50-83/87-02 Notice of Violation Dated 26 March 1987

Dear Mr. Grace:

This response addresses the Notice of Violation dated 26 March 1987 rela-tive to Inspection Report No. 50-83/87-11 and a subsequent Inspection Report N o. 50-83/87-02 transmitted to us follouing an Enforcement Conference held at the University of Florida on February 26, 1987. The Notice of Violation dated 26 March 1987 citee the R-56 licensee for having transported two 55-gallon drums containing licensed material outside the confines of its plant over roads accessible to the public and not complying with DOT requirements in that:

1 A radioactive materials shipping manifest containing the proper shipping name, hazard class, UN' number, and quantity of material was not prepared.

2. The vehicle transporting the Yellow-Label III radioactive material across campus from the reactor cell to the Radiation Control Building was not placarded.

3. The two 55-gallon drums arrived at their destination with dose rates in excess of 200 millirem per hour (i.e., 210 millirem per hour and greater than 1000 milirem per hour) on the external surface of the drums. The exemptions provided by 49 CPR 173.441 ( b) did not apply.

The following paragraphs contain the statements and explanations in reoly to five areas essentially as presented at the Enforcement Conference on February 26, 1987 with updates where applicable.

1. Admission or Denial of the Violation All three items in the violation are admitted except that the date of the shipments is not December 9,1985 but December 10, 1985 as cited at the Enforcement Conference on February 26, 1987 and in Inspection Report No.

50-83/87-01.

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2. Reasons for the Violations The failure to comply with the requirements of 10 CFR 71.5 and 49 CFR  !

172.200, 172.504 and 173.441(a) was unintentional and occurred because of a misinterpretation of what constituted the R-56 licensee site boundary and hence what constituted a radioactive waste shipment. Because of this misinterpretation, the movement of the two waste drums to the central campus waste handling facility and subsequent return of one drum to the reactor cell was not considered a shipment as such. Because there was no citation by the State Inspector present for the shipment at the central facility, there was no sWbsequent consideration given to the waste move-ments as having violated NRC or DOT requirements. The fact this violation was not intentional is further ' supported by the fact there was no problem noted with a later February,1986 shipment of high enriched uranium from the reactor site (R-56 license), essentially because its movement within our facility in controlled by internal plans and procedures.

As explained at the Enforcement Conference, all the violations cited de-rive from the misinterpretation of the site boundary for such waste transfers. This misinterpretation derived from the fact that waste ship- -

ments occur rarely from the R-56 licensee site; the last shipment was a-bout four years previous.to 1985. To date there has been no specific pro-

- cedure to address waste shipments from the R-56 facility as existing ra- '

diation control procedures were considered adequate to control prepara-tion and shipment of reactor waste. Therefore, the University of Florida Radiation Control Office was relied upon to control the transfer of the two drums of waste from the reactor cell to the central processing fa-cility from which one was then shipped. These transfers were not con-sidered shipments at the time in December,1985 but were considered to be prudent practice because of the prior scheduling of a waste shipment from the central facility for December 10, 1985 and the desire to avoid move-ment of a large truck in the central area of campus.

3. Corrective Steps Taken/Results Achieved This occurrence has been evaluated extensively by the Reactor Safety Re-l view Subcommittee and others at the University of Florida including the Chairman of the University Radiation Control Committee and the Director of Environmental Health and Safety. Three meetings were held in this re-gard prior to the Enforcement Conference on February 26, 1987. All in-dividuals represented agree that the occurrence is considered to have in-volved no health and safety consequences to the public or to University employees. The transfer to the central waste handling facility was direct and under constant control of qualified personnel. The unshipped drum was returned to the reacter cell in less than three (3) hours on December 10, 1985 and was never unattended while away from tha reactor cell. In addi-tion, the higher radiation levels on each drum were only at localized

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points as the average level on either drum was well below the upper i

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e Nuclear Regulatory Commission April 23,1987 Page Three levels quoted on the inspection forms. Therefore, other than this exten-sive evaluation process, no other corrective steps are considered neces-sary at this point. One drum has been disposed; the contents of the re-maining drum remain at the reactor f acility under proper control but at considerably reduced radiation levels due to decay since December, 1985.

As indicated at the Enforcement Conference, no waste will be shipped from the UFTR facility until a controlling waste shipment procedure has been approved and implemented. This step assures the violation will not recur.

4. Corrective Steps To Be Taken To Avoid Further Violations Since reactor radioactive waste is shipped so seldom and transfers to the central facility are not allowed because of being considered shipments, several preventive measures have been or are being implemented to assure compliance with all NRC and DOT requiremants for all future waste ship-ments.

First, a policy statement on UFTR Reactor Waste has been produced. This policy statement was approved by the Reactor Safety Review Subcommittee at its regular monthly meeting on April 9, 1987. Essentially the policy statement states that all transfers of reactor waste "shall be made di-rectly to a licensed shipper within the UFTR site assuring the require-ments of 10 CFR 71.5 are met." The policy statement has been officially signed by all cognizant authorities. This policy statement assures the violation cited in the Notice of Violation dated 26 March 1987 will not recur.

Second, a new procedure to control the shipment of waste at all steps from preparation of drums to transfer to a licensed carrier for shipment-is being developed. Specific attention is being directed to assure 10 CFR 71.5 and 49 DOT requirements are included by reference in the procedure.

When completed, this new procedure will also contain the information and conditions in the policy statement. A draft of this procedure (UFTR SOP-D.5) has undergone preliminary internal review and revision by Reactor Facility personnel and has been distributed to the members of the Reactor Safety Review Subcommittee with copies to tha Director of the University of Florida Environmental Health and Safety Division and the Chairman of the University of Florida Radiation Control Committee for review and sub-mission of comments. Final RSRS approval is expected at the next regular RSRS meeting scheduled for May 21, 1987.

Third, no waste shipments will be made from the UFTR R-56 license until this procedure (UFTR SOP-D.5, "UFTP Reactor Waste Shipments: Preparations and Transfer") is fully reviewed and approved by the Reactor Safety Re-view Subcommittee and by NRC Region II.

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Finally, no waste shipments will be made until UFTR technical staff in-cluding management personnel have received training and passed a written i)~*+* .

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examination on this new SOP. In addition, no waste shipments will be made until training has been conducted for. UFTR and Radiation Control Manage-

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ment Personnel relative to interfaces for implementation of this SOP.

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Y y 5. Date When Full' Compliance Will Be Achieved

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Full compliance has been achieved since Inspector Revsin noted the poten-O . tial violation during the inspection in that no waste shipments have been -

made since December,1985. In addition, none are expected for the re-

- mainder of'this calendar year.

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Full compliance with all commitments of Section 4 to include generation of an approved Reactor Waste Shipment procedure submitted to NRC Region II and conducting of the training for UFTR technical staff as well as UPTR and Radiation Control management personnel will be achieved by June 15, 1987. . Full implementation of all canmitments is being tracked in a v commitments file to assure timely action on all open items in Section 4.

t I y We trust this response satisfies the requirements dalineated in the No-d;'

tice of' Violation dated 26 March 1987. If' there are further questions, please advise.

Sincerely, M . E William G. Vernetson Director of Nuclear Facilities WGV/ps cc: Reactor Safety Review Subcommittee J.S. Tulenko, Chairman, Nuclear Engineering Sciences Department W.S. Properzio, Director, Environmental Health and Safety C.E. Roessler, Chairman, University Radiation Control Committee P.M. Whaley, Acting Reactor Manager L