ML20210V205
| ML20210V205 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/13/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210V196 | List: |
| References | |
| 70-1113-99-03, NUDOCS 9908230073 | |
| Download: ML20210V205 (20) | |
Text
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l U.S. NUCLEAR REGULATORY COMMISSION
~
REGION 11 Docket No.:
70-1113 License No :
SNM-1097 Report No.:
70-1113/99-03
' Licensee:
General Electric Company Wilmington, NC 28402 Facility Name:
Nuclear Energy Production Dates:
July 12-16,1999 Inspector:
W. Gloersen, Senior Fuel Facility inspector R. Swatzell, Fuel Facility inspector Approved by:
E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 9908230073 990813 PDR ADOCK 07001113 C
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l EXECUTIVE
SUMMARY
l General Electric Nuclear Energy L
NRC Inspection Report 70-1113/99-03 l
The primary focus of this routine unannounced inspection was the evaluation of the licensee's conduct of the environmental monitoring program; the transportation program for radioactive materials and the radioactive waste management program, including liquid and airborne effluent controls; and the management of solid radioactive waste. The report covered a one week period and included the results of inspection efforts of one regional senior fuel facility inspector and one regional fuel facility inspector.
Environmental Protection The licensee had established and implemented an effective program for monitoring and 3
tracking radioactive contaminants in environmental media. No safety significant environmental problems were identified (Section 2.a(2)).
)
The licensee had maintained an aggressive approach to environmental monitoring by establishment of an automated data tracking system and by having environmental hydrogeological assessments performed to determine migrational pathways and characteristics of environmental contamination (Section 2.a(2)).
The licensee's preliminary final status survey results of the Northwest CaF, Storage Area indicated that three ten square meter grids had average total uranium soil concentrations greater than 30 pCi/ gram (Section 2.b(2)).
The licensee had completed the construction of two additional warehouses to process and temporarily hold the approximately one million cubic feet of de-watered CaF2 material from the fluoride lagoons (Section 2.b(2)).
- Waste Manaoement Liquid effluent radioactivity concentrations were below licensee action levels and 10 CFR Part 20 criteria. The total amount of radioactivity released in liquid effluents for 1998 had increased in comparison to 1997 levels (Section 3.a(2)).
Air effluent monitoring and radioactivity concentrations satisfied the criteria in license SNM-1097 and 10 CFR Part 20. The calculated offsite dose due to airbome releases in 1998 was within the constraint of 10 mrem /yr in 10 CFR Part 20.1101(d). Tctal radioactivity quantities in air effluents for 1998 had decreased in comparison to 1997 levels (Section 3.b(2)).
The effluent air sampling equipment was well maintained and had been properly calibrated. No significant degradation (i.e. corrosion, leaks, etc.) of the sampling equipment was noted (Section 3.b(2)).
l The licensee had made acceptable progress towards the completion of the restructuring program which included the reduction of the volume of recoverable waste, and the relocation of CaF. (Section 3.c(2)).
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g-2 Transoortation 1
The licensee's performance in the preparation and delivery of completed packages was acceptable, but the method used to complete UF. heel shipping papers was considered awkward (Section 4.a(2)).
The licensee's performance in fuel bundle packing operations was acceptable (Section 4.b(2)).
The licensee's performance in providing the required safety training was acceptable (Section 4.c(2)).
The licensee's identification and correction of an incident that violated package shipment requirements were acceptable and timely. The licensee's responses to the non-conforming conditions of certain packagings were appropriate (Section 4.d(2)).
I.
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REPORT DETAILS 1.
Summary of Plant Status This report covered the efforts of one regional senior fuel facility inspector and one regional fuel facility inspector for a one week period. One uranium hexafluoride (UF6) dry conversion line, pelleting and bundle assembly were currently operating. The east nitrate lagoon liner replacement was being completed. There were no unusual plant operational occurrences during the onsite inspection.
2.
Environmental Protection (88045) (R2) a.
Monitorina Procram imolementation and Results (R2.01. R2.02)
(1)
Inspection Scope The inspector reviewed the licensee's Environmental Protection Program to verify that program implementation and sample results were consistent with license requirements and to ensure that plant operations had not significantly increased radioactivity levels in environmental media.
(2)
Observations and Findinas The inspector reviewed selected results from soil, vegetation, surface water, groundwater, and environmental air samples and observed that gross alpha, gross beta, and uranium values consistently remained below licensee action levels for the majority of environmental media samples. It was observed that several environmental samples' radioactivity and uranium levels had exceeded licensee action levels for which the licensee had issued Environmental Action Level (EAL) investigation statements. The EALs had recommended appropriate corrective actions (i.e. re-sampling, trending, etc.).
It was noted that sample locations where licensee action levels were consistently
- exceeded (i.e. groundwater monitoring well PL-11 A, etc.) were areas where known contamination existed and no new areas of contaminated media were identified.
The inspector noted that the reported minimum detectable activities (MDAs) for multiple environmental analyses exceeded license specified routine MDAs. These reported MDAs were not considered safety significant since the values reported were below licensee action levels. However, it was noted that the third and fourth quarter 1998 reported MDA values for gross alpha of <20 and <60 pCi/L for the General Electric (GE)
Dock (river - downstream) were above the license MDA value of 5 pCi/L and the licensee action level of 15 pCi/L. The inspector discussed this with the analytical contract vendor, who indicated that high MDA values for aqueous samples, as noted above, result when increased suspended solids are present. The licensee provided corrections to the Environmental Compliance Data Environmental System (ECDMS) to automatically note and track future occurrences of exceeding MDA levels. The inspector observed that the subsequent first quarter 1999 gross alpha value (and thus the MDA) for the GE Dock sample was less than 5 pCi/L. The inspector also noted consistent elevated radioactivity levels (gross alpha of 1200 pCi/L maximum and gross beta of 380 pCi/L maximum) in groundwater monitoring well PL-11 A. The licensee had installed additional monitoring wells (PL-13, PL-14, and PL-15) downgradient of well PL-11 A in order to effectively monitor contaminant migration. Minimal radioactivity levels (<5 pCi/L) were observed in samples from wells PL-13, PL-14, and PL-15.
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2 (3)
Conclusion The licensee had established and implemented an effective program for monitoring and tracking radioactive contaminants in environmental media. In addition, the licensee had maintained an aggressive approach to environmental monitoring by establishment of an automated data tracking program (ECDMS) and by performing hydrogeological assessments to determine migrational pathways and characteristics of environmental contamination. Reported MDAs for multiple environmental media which exceeded license MDAs were observed, and the licensee implemented corrective actions to automatically track future occurrences. No significant environmental problems were observed.
b.
Decommissionina (R2.07)
,(1)-
Inspection Scope The inspector reviewed the status of the licensee's current decommissioning and remediation actions pursuant to 10 CFR 70.38.
(2)
Observations and Findings The inspector reviewed the status of the current decommissioning actions at the site.
These actions included the final decommissioning survey of the North West Storage Area and the removal and relocation of CaF material from the CaF Basins 1,2, and 3 2
2 to the warehouses.
During an NRC inspection conducted January 4-8,1999, the inspector observed the sampling of soil from the periphery of the Northwest CaF Storage Area in accordance with the NRC-approved CaF, Area Survey and Release Plan. During that inspection, the inspector requested and obtained ten (10) split samples that were from various locations around the periphery of the affected area. These samples were sent to the Oak Ridge Institute for Science and Education's laboratory for a comparative analysis. The comparison of those data are made in Section 2.c(2) of this report. The results of the ten split samples indicated total uranium concentrations below 30 pCi/ gram. In addition, the inspector reviewed the licensee's preliminary final status survey results of the Northwest CaF Storage Area and noted that three ten square meter grids had average 2
total uranium soil concentrations greater than 30 pCi/ gram. The average soil concentration and ranges of the three areas of concern are summarized below in Table 1.
Table 1:
Average Total Uranium Soil Concentrations for Three Areas of Concern located in the Northwest CaF Storage Area 2
~M9 68.9 12.1-139.0 (5 samples) 46.3 5.6-83.3 (5 samples) dut1.- t 44.1 10.3-77.7 (5 samples)
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The inspector discussed the results with the licensee. The licensee indicated that additional sampling will be performed in and around the areas of concern to better define the affected areas. After the affected areas are better derned, the licensee planned to perform additional remediation. As part of the inspection, the inspectors requested that the licensee split one soil sample that was greater than 30 pCi/ gram from one of the i
AOCs. The licensee agreed to mail the soil sample to the NRC's Region II office for analysis.
The inspector also reviewed the licensee's progress in the relocation of the CaF in 2
Basins 1,2, and 3. The licensee had completed the relocation and clean up of the CaF2 Basins 1,2, and 3 in October 1998. The CaF was relocated to Storage Warehouse 2
No.1. Since the basins were located adjacent to the aeration basin, which is still in operation, the licensee requested and received authorization from the NRC to delay the full ~ decommissioning and release of the area from licensed activity (see letter from NRC/ Weber to GE/Reda dated September 18,1997). The inspector reviewed the sampling results for the soil samples collected in October 1998. These data are summarized in Table 2 below.
Table 2:
Residual Total Uranium Concentrations Remaining After Relocation of CaF from Basins 1,2, and 3 2
ota[UrsiddiS611 ConEsintration (sicilghmN S
E 44 839.7 68.0 -2315.6 580.2 M
100 346.8 10.5-1437.5 314.8 6
31 651.6 76.9-1915.6 467.8 At the time of this inspection, the inspector n'oted that the soil sample results had not been placed in the facility's decommissioning file, however, the licensee indicated after the post CaF relocation sampling results are reviewed in detail, the sampling results and 2
other supporting data will be placed in the facility's decommissioning file in accordance with 10 CFR 70.25(g).
I in addition, the inspector observed that the licensee had completed the construction of two additional warehouses to process and hold (temporarily) the approximately one million cubic feet of de-watered CaF material from the fluoride lagoons. Warehouse 2
No. 2 was being used to de-water the CaF sludge being pumped from the CaF i
2 2
lagoons. After the de-watering process, the sludge was transferred to Warehouse No. 3 1
for temporary storage.
(3)
Conclusion The licensee's and NRC's results of the ten split samples indicated that the total uranium concentrations were below 30 pCi/ gram at the specified sample locations. The licensee's preliminary final status survey results of the Northwest CaF Storage Area 2
indicated that three ten square meter grids had average total uranium soil concentrations greater than 30 pCi/ gram. The licensee was making good progress towards removing I
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CaF material from the fluoride lagoons. The licensee had completed the construction of 2
two additional warehouses to process and temporarily hold the approximately one million cubic feet of de-watered CaF, material from the fluoride lagoons.
c.
Follow-up on Previousiv identified issues (92701 and 92702)
(1)
Insoection Scope (IFl) 70-113/98-02-02: Review license procedure EPl 0.80 to ensure the correct 1
sampling frequency for F-series wells is documented.
(IFI) 70-1113/98-02-03: Review the 1997 State of North Carolina Environmental Radiation Surveillance Report concerning the General Electric Uranium Fuel Fabrication Plant.
(IFl) 70-1113/99-02-03: Review analyses of split samples from the northwest CaF2 storage area decommissioning survey.
(2)
Observations and Findinas The inspector reviewed the final corrective actions associated with inspector Follow-up Item (IFI) 70-1113/98-02-02 involving the licensee's failure to obtain samples for radiochemical analyses on a quarterly frequency for three F-series wells according to licensee procedure Environmental Protection Instruction (EPI) 0.80. Per the licensee, the sampling for the F-series wells was changed to an annual frequency based upon a contractor evaluation. A revision to EPl 0.80 to reflect this change was inadvertently overlooked. The inspector observed that EPl 0.80 had now been revised to reflect the correct sampling frequency (annual) for the F-series wells. Therefore, IFl 70-1113/
98-02-02 is closed.
Per IFl 70-1113/98-02-03, NRC staff was to review the 1997 State of North Carolina Environmental Radiation Surveillance Report concerning the General Electric Uranium Fuel Fabrication Plant. The inspector reviewed the report and observed no significant deviations between GE and North Carolina environmental results. In addition, no additional environmental problems were identified in the North Carolina report.
Therefore, IFl 70-1113/ 98-02-03 is closed.
During an inspection conducted from January 4-8,1999, the inspectors noted that the licensee was sending samples to an independent laboratory for analysis. The inspectors requested and obtained ten (10) split samples that were from various locations around the periphery of the affected area. These samples were sent to the ORISE laboratory for a comparative analysis. The inspectors reviewed the licensee's results and compared them to the NRC results. The comparison of the data are summarized in the Table 3 below.
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Table 3:
Comparison of CaF, Soil Sample Alpha Spectrometry Analyses Collected at the Northwest CaF Storage Area 2
0 3.88 3.33 +/- 0.32 1.17 9.40 8.93 +/- 0.79 1.05 0.90 1.05 +/- 0.13 0.86 1.65 2.24 +/- 0.22 0.74 1.69 1.91 +/- 0.20 0.88 4.50 4.19 +/- 0.40 1.07 13.80 7.15 +/- 0.62 1.93 5.19 5.14 +/- 0.46 1.01 9.58 11.80 +/- 1.02 0.81 M
4.86 0.99 +/- 0.12 4.91 From a review of the data, it can be concluded that for the locations where the ten samples were collected, all analysis results indicated soil concentrations below 30 pCi/ gram. In addition, the data indicate that eight out of ten sample results were within at least +/- 26% of the NRC results. GE's analysis of the remaining two samples were higher (more conservative) than the NRC results. The inspectors concluded that the sample results were generally in good agreement considering the inherent difficulties in comparing soil sample resultc. IFl 70-1113/99-02-03 is considered closed.
(3)
Conclusion Corrective actions associated with IFl 70-1113/98-02-03, IFl 70-1113/98-02-03, and IFl 70-113/99-02-03 have been adequately completed and these IFis are closed.
3.
Waste Manacement (84850. 84900. and 88035) (R3) a.
Liauid Effluent Proaram Controls. Procedures. and Instrumentation and Liauid Effluent Monitorina Results (R3.01 and R3.02)
(1)
Inspection Scope The inspector reviewed the semiannual liquid effluent report for the second half of 1998 and selected 1999 data to determine if License SNM-1097 conditions for plant liquid effluents had been satisfied and to determine if liquid effluent releases met 10 CFR Part 20 requirements.
6 (2)
Observations and Findinas The inspector reviewed the Semiannual Effluent Release Report (SERR) for the second l
half of 1998 and observed that the amount of radioactivity released due to uranium l-isotopes was reported as 29.1 millicuries. This value was consistent with the radioactivity released for the first half of 1998 (30.5 millicuries). In addition, the inspector compared the total radioactivity in liquid effluent discharges released in 1998 with previous years. The data are summarized in Table 4 below.
Table 4:
Radioactivity in liquid effluents due to uranium isotopes (microcuries) 1995 1996L b 1997 l1998 M
M M
N The data shows an increase in the total quantity of radioactivity discharged in liquid effluents from 1997 to 1998 (approximately 34 percent) following a general decreasing trend for released activity from 1995 through 1997. This increasing trend continued for the available 1999 data reviewed. The licensee attributed the increase in activity released to the elimination of the fluoride waste stream, (a result of the shutdown of the Ammonium Diuranate (ADU) Process), which had a sufficient free hydroxide concentration to have aided in further uranium removal. The inspector noted that liquid effluent concentration levels in 1998 and 1999 were consistently below licensee action levels. The licensee liquid effluent radioactivity concentration of 8.2 E-08 uCi/mi( total uCi released / total effluent volume per second half 1998 SERR) was below 10 CFR Part 20 criteria (3 E-07 Ci/ml).
(3)
Conclusion The licensee was satisfying the conditions of license SNM-1097 for monitoring uranium concentrations in liquid effluents. Effluent uranium concentrations were below licensee action levels and 10 CFR Part 20 criteria. Total quantities of radioactivity released in liquid effluents for 1998 had risen in comparison to 1997 levels.
b.
6irborne Effluent Proaram Controls. Procedures. and Instrumentation and Effluent Monitorina Results (R3.03 and R3.04)
(1)
Inspection Scoce The inspector reviewed the licensee's airborne effluents program for compliance with the requirements imposed by 10 CFR Part 20, Appendix B, Table 2, Column 2, and the license requirements of SNM-1097. The inspector reviewed stack sampling data for the second half of 1998 and first half of 1999. In addition, the licensee's methodology for calculating off site dose due to airbome emissions was reviewed. The inspector also inspected selected individual sampling stations to ensure that representative samples were being obtained.
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(2)
Observations and Findinas The inspector compared the total activity levels due to uranium isotopes in airborne effluents released in 1998 with previous years. The data are summarized in Table 5 below.
Table 5:
Radioactivity in airborne effluents due to uranium isotopes (microcuries) ygggw p 3yyw
,q gyg(
-lm q,p m sammany summinese surr9 EMF]NMEmiME The data shows a significant decrease in activity levels (approximately 36 percent) in airborne effluents between 1997 and 1998 results. In addition, first half of 1999 data indicates radioactivity totals in airborne effluents was approximately half (approximately 30 microcuries) of that experienced during the first half of 1998. The inspector also noted that the quarterly activity level in airborne effluents was considerably below the NRC license SNM-1097 action level of 1250 microcuries. The inspector reviewed the licensee's dose methodology (EPA's COMPLY code) and various input parameters (i.e. stack height, etc.) to determine the validity of the calculated dose to offsite receptors due to airbome emissions. The inspector determined that input parameters such as stack heights, distances to offsite receptors, wind speed, etc. were reasonable and that assumed ingestion (receptor grows all vegetables, etc.) scenarios were conservative.
The licensee used the COMPLY code to calculate a 1998 offsite dose of 0.2 mrem /yr due to air emissions which is well below the as low as reasonably achievable (ALARA) i constraint criteria of 10 mrem /yr specified in 10 CFR 20.1101(d). In addition, the inspector observed the acquisition of particulate samples from four release stacks (Fuel Manufacturing Operations (FMO), Fuel Manufacturing Operations Extension (FMOX),
Hydrofluoric Acid, and Dry Conversion Process (DCP) buildings) and noted that the samples were properly acquired and appropriate information was recorded. In addition, the sampling equipment was well maintained (i.e flow meters properly calibrated, etc.)
and no equipment degradation (leaks, corrosion, etc.) were observed. The inspector observed that the sampling line for the hydrofluoric acid (HF) building stack was routed from a section of horizontal duct which could effect the representativeness of samples due to particle size and terminal velocity considerations. However, the inspector noted that existing process conditions (resulting in reduced particle size population) and the stack air flow velocity (based on one foot stack diameter and volumetric flow rate of 3000 cubic feet / minute) promoted good particle suspension and mixing characteristics.
(3)
Conclusion The licensee's program for monitoring radioactive constituents (uranium) in plant airbome effluents satisfied the criteria in license SNM-1097 and 10 CFR Part 20. In addition, the calculated offsite dose due to airborne releases in 1998 was significantly below the ALARA constraint of 10 mrem /yr required by 10 CFR Part 20.1101(d).
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8 c.
On Site Waste Storaae (R3.05)
(1)
Insoection Scoce The licensee's storage of low-level radioactive waste (LLRW) was reviewed, including management controls and surveys, adequacy of the storage area, and waste container integrity.
(2)
Observations and Findinos At the time of this inspection, the licensee was storing large quantities of residue material on-site in approximately 17,500 three or five gallon cans in their outside waste storage areas or " pads". The ads consisted of several graveled surfaces each surrounded by a fence. Although the fences were not locked, all of the waste was located within the controlled area of the facility. The waste containers were placed directly on the graveled surface.
As noted in the last inspection of this program area (see NRC inspection report No. 70-1113/97-07), the licensee had implemented a restructuring program to deal with the onsite waste. The program consisted of the following four phases: (1) Reduce the volume of recoverable waste by continuing operation of the uranium recovery facility; (2) Burial of non-recoverable residue waste; (3) Incinerator ash recovery project (5,300 1
cans); and (4) Calcium fluoride relocation from lagoons to warehouses (see Section 2.b(2)). The inspectors observed that the licensee had acted to reduce and/or relocate the onsite storage of waste. Before the restructuring program was initiated, the total inventory of waste and residue cans was approximately 24,600 in June 1997. In comparison, the totalinventory of waste and residue cans in January 1999 and July l
1999 was 19,600 and 17,500, respectively. The licensee was still analyzing processing options for the incinerator ash recovery project.
In November 1998, the licensee suspended its shipments of low level radioactive waste (predominantly the CaF material) to Envirocare. The suspension was primarily due to 2
I economic reasons its that the 350 gram limit for U-235 per conveyance resulted in partially loaded vehicles (15-20 at 55 gallon drums or solid residue packs (SRPs)). As of this inspection, the licensee had accumulated approximately 1700 SRPs which were waiting shipment to Envirocare.
On July 21,1999 Envirocare received a licensee amendment allowing the receipt of greater than 350 grams U-235 per conveyance under certain conditions.
At the time of this inspection, the licensee had completed a SNM Exemption Certification on July 7,1999 and transmitted it to Envirocare for review and approval. Since the type of waste the licensee will be shipping is (1) less than 10 percent U-235; (2) less than 20 percent MgO by weight; and (3) less than one percent beryllium by weight; the licensee could ship waste that contained less than or equal to 1900 pCi/ gram U-235 per l
individual waste container. As long as certain criteria specified in the order were met and the conditions of NRC Certificate of Compliance (CoC) 9285, Model SRP-1 were met, the licensee could ship the concentrations of waste noted above. Once the licensee receives authorization from Envirocare to resume the shipments, the licensee will begin shipping the 1700 SRP-s now stored at GE.
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9 (3)
Conclusion The licensee had made acceptable progress towards the completion of the restructuring program which included the reduction of the volume of recoverable waste, and the relocation of CaFr.. In November 1998, the licensee suspended its shipments of low level radioactive waste (predominantly the CaF material) to Envirocare. These 2
shipments were expected to resume upon authorization to ship more than 350 grams U-235 per conveyance.
d.
Follow-uo on Previously identified issues (92701 and 92702)
(1)
Insoection Scope (IFI) 70-1113/98-03-01: Review the licensee's and NRC's analyses of split soil samples collected from the CaF, soil mound stored in Warehouse No.1.
(2)
Observations and Findinas The inspectors had requested the licensee to collect and split a soil sample with the NRC from the CaF, soil mound in Warehouse No.1. The licensee analyzed the sample using their routine analytical methods. The NRC's analysis was performed by the Oak Ridge Institutes for Science and Education (ORISE). The NRC's analysis included uranium isotopic concenPations by gamma spectroscopy; and uranium isotopic concentrations by alpha spectroscopy. The licensee's results for U-235 and U-238 were within 4-6 percent of the NRC's gamma spectroscopy results. Similarly, the licensee's results were within a range from 16 percent to 22 percent of the NRC alpha spectroscopy results. The inspectors reviewed the results and concluded that there was acceptable analytical agreement. IFl 70-1113/98-03-01 will be closed.
(3)
Conclusion The licensee's actions associated with the items noted above have been adequately completed.
4.
Transooriation (86740 and 88010) (R4)
The inspector reviewed the licensee's program for routine radioactive materials shipments to determine whether the licensee had established and was maintaining an effective program, to ensure radiological and nuclear safety in the packaging and delivery to a carrier of licensed radioactive materials, and to determine whether transportation activities were in compliance with the applicable NRC and the Department of Transportation (DOT) transport regulations noted below. During the inspection, transportation activities associated with fissile material shipments, 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.
10 CFR 71.5(a) requires that licensees who transpcq 4 censed 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 applicable requirements of the regulations appropriate to the mode of transport of the DOT in 49 CFR Parts 170 through 189.
10 a.
Preparation and Delivery of Comoleted Packaoes for Shioment (R4.01)
(1)
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 LLRW and fissile material.
(2)
Observations and Findinas The inspector verified that the licensee had acceptable procedures for the preparation of shipping packages and delivery of the packages to the carrier for shipment. The inspector reviewed selected portions of the shipping procedures and noted that there were no significant changes to the procedures since the last inspection of this program The inspector also verified that the appropriate personnel in the traffic department area.
had current copies of the applicable DOT regulations.
During the onsite inspection, licensee transportation activities regarding shipments of unirradiated fuel, uranium dioxide powder, and UF heels were reviewed. Selected records covering the period December 1998 to July 1999 for those consignments were reviewed in detail. The inspector reviewed and discussed the documentation used, and subsequently maintained in the licensee's records for each radioactive material shipment, including, the Bill of Lading, Radioactive Material Shipment Record, Vehicle Inspection Report, Receipt and Loading Verification Checklist, Packing List (Fuel Assemblies / Component Assemblies), Fuel Shipment Information Form, Container Log Sheet, and Health Physics Survey Forms. The inspector noted that the shipping records were complete and the information supplied on the shipping papers was appropriate.
The inspector noted that completion of UF, heel shipping papers required the shipping personnel to manually calculate the total gross and net weights of the cylinders. The licensee then had to manually enter the following data for each cylinder shipped:
(1) heel (1 or 0); (2) number of bequerels; and (3) overpack number. In order to enter these data, the shipping personnel had to use labeling tape to cover three data fields on the form so that the data, as noted above, could be manually entered. The inspectors discussed this awkward data entry method for these forms with licensee representatives.
The licensee was reviewing ways to computerize this documentation.
(3)
Conclusion l
The licensee's performance in the preparation and delivery of completed packages was acceptable. The method used to complete UF. heel shipping papers was considered awkward.
l b.
Fuel Bundle Packina l
(1)
Inspection ScoDe l
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The inspectors reviewed the unirradiated fuel bundle packing operations with certified operators and the Bundle Assembly Team Leader.
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. (2)
Observations and Findinas The fuel bundle operators used operating procedure OP No. 1050.70, Fuel Bundle Packing, Revision 4, June 3,1999. The inspectors reviewed the procedure and noted that it was relatively easy to follow. In addition, the inspectors noted that the procedure for normal operations (packing fuel bundles as opposed to loose rods) contained 43 steps to pack an inner container, however, there were no check-offs to ensure appropriate completion of certain safety steps. In light of the BU-J event discussed in Section 4.d(2) of this report, Operating Procedure OP No. 1050.70 could be enhanced by incorporating a check-off list to verify that all safety related tasks are completed. The licensee was reviewing the possibility of producing a check-off list.
The licensee required that at least one certified operator be present on each shin for loading operations. On July 15,1999, the inspector observed three out of four operators were certified. The certified operator was trained to perform quality control checks to ensure each container was loaded properly, in addition, approximately once per week an independent QA auditor would audit container loading activities.
From a review of licensee event reports, reportable events, and interviews with the licensee, there have not been any recent incidents involving improperly packaged fuel bundle containers.
(3)
Conclusion The licensee's performance in the fuel bundle packing operations was acceptable.
c.
Trainina (88010)
(1)
Insoection Scoce The inspectors reviewed the licensee's training program for personnel involved in the shipment of radioactive materials to ensure that individuals received safety and function specific training in accordance with 49 CFR 172.704.
(2)
Observations and Findinas 49 CFR 172.704 specifies the training requirements for: (1) general awareness training; (2) function specific training; (3) safety training; and (4) hazards communication training.
The inspector noted that no new employees had been hired since the last inspection, so a review of the re-current training program was performed. The frequency for re-current training was once per three years.
There were six training modules which included a self-study video tape and an examination. The inspector verified that the six modules adequately covered the four training requirements noted above. There were 17 employees and one supervisor involved in shipping and receiving activities. The inspector reviewed the training record data base, and noted that all 17 employees had received the required re-training within the three year frequency specified in 49CFR 172.704(c)(2).
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12 in addition, the licensee provided specialized training in the area of Highway Transportation of Hazardous Waste. Six individuals, including the supervisor, had received this training within the last three years (3)
Conclusion The licensee's performance in providing the required safety training was acceptable.
d.
Review of Transoortation Unusual incidents (1)
Insoection Scope The inspector reviewed unusualincident reports (UIRs) and 30 day reports pursuant to 10 CFR 71.95 as they pertained to transportation of radioactive materials events. The inspector reviewed the events with licensee representatives and discussed the appropriate corrective actions that were taken.
s (2)
Observations and Findinos The inspector reviewed three incidents involving shipping activities or issues involving the material condition of packages that occurred since the last inspection. The three incidents pertained to the following: (1) a single BU-J container shipped to Japan Nuclear Fuels without its thermal insulator; (2) identification of a non-conforming condition involving a single BU-J container; and (3) identification of non-conforming conditions involving a fleet of BU-7 containers.
BU-J Container Shicoed to Japan Nuclear Fuels On November 30,1998, the licensee received notification that a single BU-J container shipped from the licensee's facility to Japan Nuclear Fuels was received without its thermalinsulator. The purpose of the thermalinsulator was to insulate the top portion of the inner container in the event of a fire. The insulator was made of light weight concrete and was approximately 2.5 inches thick and 22 inches in diameter. After the notification, the licensee suspended further BU-J packing operations pending the completion of a root cause investigation and implementation of corrective actions. The licensee re-inspected all of the BU-Js that were already packed to assure that the thermal insulator was in place. All of the packed and re-inspected BU-Js had the thermalinsulator properly installed. From discussions with the licensee, the inspector noted that the licensee had properly shipped approximately 6000 BU-Js in 1998 with the insulator in place before this event occurred.
The licensee conducted a root cause investigation and identified event causes. In a letter to the NRC ONMSS from the licensee dated December 29,1998, the licensee identified four corrective actions that were implemented. As a result of the actions, the licensee resumed BU-J packing operations on December 14,1998. The inspector reviewed the corrective actions and found them to be acceptable. Although this event resulted in a violation of the package loading requirements specified in the package's CoC and operating procedures, the inspector noted that this was a single and isolated event, involving no breach of package integrity. Therefore, this violation was considered as a minor violation and not subject to formal enforcement action.
13 Some of the corrective actions included revising the operating procedures to incorporate all steps required for verification by a certified operator; development of an item by item checklist of the verifications, and independent verification of proper drum loading by a Quality Control Organization certified inspector. The inspector discussed with licensee representatives as to whether the lessons learned from this event had been applied to other shipping activities at the facility. The licensee indicated that for UF. heel shipments there is no independent QC over-check process. The package loading verifications were performed by the operator. For fuel bundle loading activities (see also Section 3.b(2) of this report), at approximately once per week an independent QA auditor would audit the container ioading activities. However, the package loading verifications were peiformed by a certified operator trained to perform quality control checks to ensure each container was loaded properly. The licensee was reviewing the feasibility of applying any
)
applicable lessons learned to the other shipping activities at the facility.
Identification of a Non-Conformina Condition involvina a Sinale BU-J Container in a letter dated February 25,1999, the licensee provided the NRC a description of a deficiency identified during routine quality assurance inspections involving a single BU-J container (USA /0220/AF-85, Model No. BU-J Package). The licensee reviewed this issue and determined that it was not reportable under the requirements of 10 CFR 71.95.
However, the licensee considered the information to be of interest to the NRC and therefore provided the letter dated February 25,1999.
On January 27,1999, the licensee detected a single instance of through wall corrosion on the sidewall of an inner container of a BU-J package. This defect was detected during a routine inspection and refurbishment of BU-J packaging. The affected BU-J container was designated as non-conforming material in accordance with the licensee's quality assurance procedures and was removed from service. It should be emphasized that at the time of detection, the affected BU-J container did not contain product nor was it being loaded with product. The licensee destructively examined the container to better define the defect. The examination indicated that the through wall corrosion was unique.
Superficial rust was also indicated during the examination, however this did not impact the package's ability to perform its intended safety function of maintaining moderation exclusion within the inner container. The inspector also examined the affected BU-J container and observed the through wall corrosion. The licensee examined additional BU-J containers to evaluate the likelihood of similar issues in other containers. Although the additional examinations did indicate some superficial rust on the inner container, none of the examined BU-Js contained a through wall or near through wall condition. In addition, the licensee sent the through wall defect as well as samples from other drums to a contractor laboratory to attempt to determine the mechanism of the corrosion. The licensee has self-initiated a temporary moratorium on shipments using the BU-J packages pending evaluation of the corrosion testing. The licensee was also pursuing development of a new package for uranium dioxide shipments. The inspector determined that the licensee's actions were appropriate to ensure that the uranium dioxide shipments are conducted in a safe manner.
Identification of Non-Conformina Conditions involvina a Fleet of BU-7 Containers On January 12,1999, BWX Technologies (BWXT) informed the licensee that during a j
routine inspection of their BU-7 fleet, they discovered corrosion, paint peeling, and a i
white crystal formation. These conditions were observed in the area between the inner
r 14 container lid and the outer containcr lid. This was the area where the phenolic foam insulating plug was located. Technically, the reporting responsibility was on the shipper, not necessarily on the owner of the certificate. In this case, the shipper was BWXT and the owner of the certificate was the licensee (GE). It should also be noted that the licensee did not manufacture nor own or possess any BU-7's. However, after discussions with the shipper (BWXT) and NRC, the licensee took the responsibility and submitted a report pursuant to 10 CFR 71.95 and 10 CFR 21.
The licensee was unable to conclusively determine the cause of the white crystalline substance, corrosion, or paint blistering. There was evidence that the corrosion took place on ail closed packages, packed or unpacked. Due to the lack of information that would allow the development of a recovery and corrective action program, the licensee requested that the CoC be withdrawn until the root cause(s) and corrective actions can be Identified.. The NRC terminated the CoC in a letter dated March 26,1999.
'(3)
Conclusion The licensee's identification and correction of an incident that violated package shipment requirements was acceptable and timely. The licensee's responses to the non-conforming conditions of certain packagings were appropriate.
e.
Follow-uo on Previousiv Identified issues (92701 and 92702)
(1)
Insoection Scoce (IFI) 70-1113/98-03-03: Review the root cause(s) of the incident involving the receipt of three BU-J packages in a possible deficient condition.
(2)
Observations and Findinas The inspectors discussed this event with licensee representatives and determined that no additionalinformation was available since this event was reviewed by the NRC during August 17-21,1998. Therefore, an analysis of the root causes could not be made. Due to the iack of traceable information, IFl 70-1113198-03-03 will be closed.
(3)
Conclusion The licensee's actions associated with the item noted above have been adequately completed.
5.
Exit Interview The routine inspection scope and results were summarized on July 16,1999 with those persons indicated in the Attachment. The inspectors discussed in detail the routine program areas inspected and the identified findings. 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. No dissenting comments were expressed by the licensee.
ATTACHMENT 1.
PARTIAL LIST OF PERSONS CONTACTED Licensee Personnel
- E. Anderson, Technical Coordinator, Restructuring
- D. Brown, Team Leader, Environmental Programs T, Crawford, Sr. Environmental Engineer
- D. Dowker, Manager, Chemical Product Line
- T. Draffen, Manager, Dry Conversion Process
- R. Foleck, Senior Licensing Specialist
- S. Fuller, Fuel and Chemet Quality R. Keenan, Manager, Site Security and Emergency Preparedness
- J. Kline, Fuel Manufacturing
- G. Luciano, Area Manager, Fuel Support A. Mabry, Program Manager, Radiation Safety Engineering
'C. Monetta, Manager; Environment, Health & Safety
- S. Murray, Manager, Facility Licensing
- E. Palmer, Project Engineer
- L. Paulson, Manager, Nuclear Safety
- R. Reda, Manager, Fuel Fabrication H. Strickler, Manager, Site Environment, Health & Safety D. Tumer, Environmental Engineer; Environment, Health & Safety C. Vaughan, Manager, Strategic Regulatory Planning
- R, Yopp, Specialist, Shipping and Transportation
- R. Troilo, Sr. Engineer Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
- Denotes those present at the exit meeting on July 16,1999.
2.
INSPECTION PROCEDURES USED IP 84850 Radioactive Waste Management (10 CFR Parts 20 and 61)
IP 84900 Low-Level Radioactive Waste Storage IP 88740 Inspection of Transportation Activities IP 88035 Radioactive Waste Management IP 88045 Environmental Protection IP 88010 Operator Training / Retraining IP 92701 Follow up 3.
LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED Item Number Status Descriotion and Reference I
70-1113/98-02-02 Closed IFl: Inconsistency between actual sampling frequency and procedural sampling frequency for F series wells. Licensee revised EPl 0.80 to correctly reflect actual annual sampling frequency for F series wells. IFl is closed (Section 2.c(2)).
I i
1 I
n
.0
[
l 1
l 2
l 70-1113/98-02-03 Closed IFl: State of North Carolina 1997 Environmental Report for Nuclear Facilities j
had not been reviewed by NRC personnel.
The 1997 North Carolina Environmental i
Report was reviewed and no discrepancies between North Carolina and GE results were identified. In addition, no significant environmental concerns were noted in the I
state of North Carolina's report. IFlis l
closed (Section 2.c(2)).
70-1113/98-03-01 Closed IFl: Review the licensee's and NRC's l
analyses of split soil samples collected from the CaF soil mound stored in Warehouse 2
No.1 (Section 3.d(2)).
70-1113/98-03-03 Closed IFl: Review the root causes of the incident involving the receipt of three BU-J packages l
in a possible deficient condition (Section 4.e(2)).
70-1113/99-02-03 Closed IFl: Review analyses of split samples from the northwest CaF, storage area decommissioning survey (Section 2.c(2)).
l 4.
ACRONYMS ADU Ammonium Diuranate f
ALARA As Low As Reasonably Achievable AOC Area of Concern CaF Calcium Fluoride cc cubic centimeter DCP Dry Conversion Process DOT Department of Transportation EAL Environmental Action Level ECDMS Environmental Compliance Data Management System EPl Environmental Protection instruction FMO Fuel Manufacturing Operations FMOX Fuel Manufacturing Operations Extension GE General Electric IFl inspector Follow-up item IP inspection Procedure L
liter LLRW Low Level Radioactive Waste Ci Microcuries MDA Minimum Detectable Activities mrem millirem NMSS Office of Nuclear Materials Safety and Safeguards NRC Nuclear Regulatory Commission ORISE Oak Ridge Institutes for Science and Education pCi Picoeuries
i
-i 3
ppm Part Per Million SERR Semiannual Effluent Release Report
.SNM Special Nuclear Material SRPs-
' Solid Residue Packs UIR.
Unusualincident Report UF, Uranium Hexafluoride VIO
~ Violation 4
6 L
6 e-1 i
L'.
-