ML20212E030
| ML20212E030 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/16/1997 |
| From: | Femreite B SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 70-1257-97-04, 70-1257-97-4, BNF:97:101, NUDOCS 9711030032 | |
| Download: ML20212E030 (4) | |
Text
r SiEMENS D
0c7 October 18,1997 ig/p j
i BNF:97:101 gj U.S. Nuclear Regulatory Commission Region IV Attn: E. W. Merschoff, Regiorial Administrator 611 Ryan Plaza Drive, Suite 400 4 -/357 Arlington, TX 76011 8004 I
Dear _Mr. Merschoff:
As you know, during routine inspection No. 97-04 in April 1997,I Siemens Power Corporation (SPC) advised NRC inspector C.A. Hooker that SPC had recently discovered that it had
- inadvertently made two shipments of enriched UO, powder to Japan which exceeded the weight lina.s allowed for the enrichment levels involved in those shipments under Revision 4 of the DOT revalidation of the Japanese Certificate of Competent Authority for the NT IX container that was used for those shipments. Revision 4 of the DOT version of the certificate, which was issued on August 27,1996, lowered the permissible shipping weights below those previously t
allowed under Revision 3. Because SPC administratively controls the maximum amount of UO, that can be loaded into such containers, the shipping weights permitted by SPC for lower enrichment levels (i.e., below 3.0% U 235) remained the same.
SPC conducted an internalinvestigation into these overweight shipments, including a root cause analysis, and advised the NRC of the results of this investigation. A description of the preventive and corrective actions that SPC has taken to ensure that such incidents do not occur again was provided to the NRC Office of Investigations (01) during the interviews of the SPC employees conducted by Ol in connection with its investigation of this matter.
On September 30,1997 during an interview of J.B. Edgar, a Staff Engineer in the SPC Regulatory Compliance Section, by P.V. Joukoff, a senior investigator from 01, Mr. Joukoff asked Mr. Edgar whether the first shipment that was made under Revision 4 in August 1996 complied with the new weight restrictions. Mr. Fdgar indicated that he did not know for certain, but he assumed that it did since SPC's earlier investigation determined that there were only two overweight shipments, which occurred in December 1996 and February 1997. At Mr.
Joukoff's request, Mr. Edgar agreed to confirm this information during a break in his interview.
M. L. Koontz, a Senior Technician in the Traffic and Warehousing organization and the individual who is the most knowledgeable about the contents of these shipments, was unavailable at the time, so Mr. Edgar consulted with M.A. Jaeger, the SPC Project Manager for Japan and Korea, Mridaeger inictmed Mr. Edgar that the August shipment involved UO, for pressurized water
{h reactors (PWRs) enriched at a' lower enrichment level (i.e. 2.5% U 235) which could not be I
overloaded based upon his understanding of the capacity of the shipping pails.- Mr. Edgar concluded _that the August shipment was not overweight because the pails could not physically
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E.' W. M;rschof f BNF:97:101 October 16,1997 Page 2 hold more uranium dioxide powder than the weight limits allowed foi these enrichment levels under either Revision 3 or Revision 4 of the DOT Certificate. Mr. Edgar also spoke with Mr.
Nortnan, Traffic and Warehousing General Supervisor, who agreed that this shipment must have been acceptable, otherwise it would hr.ve been identified as an overweight shipment at the time SPC identified the previously reported overweight shiprnents. Mr. Edgar relayed this information to Mr. Joukoff when his interview resumed.
On October 1,1997, Mr. Edgar conferred with Messrs. Norman and Koontz to confirm the information which he had provided to Mr. Joukoff about the August 1996 shipment. Mr.
Knontz checked his records and indicated that the August 1996 shipment involved higher enrichment levels and may have exceeded the weight limits set forth in Revision 4. Additional investigation confirmed that this shipment was also overweight and this information wes provided to Messrs. Hooker and Joukoff by telephone on October 2,1997. Mr. Joukoff requested that this updated information be provided to tha NRC in written form, During this investigation, SPC determined that Mr. Jaeger thought that the " August shipment" which Mr. Edgar had asked him about on September 30,1997 was the August 1997 shipment, rather than the August 1996 rihipment. Mr. Jaeger provided Mr. Edgar with correct information concerning the August 1997 shipment. Mr. Edgar, mistakenly believing that this information pertained to the August 1993 shipment, provided this information to Mr. Joukoff. The inaccurate infonoation that was provided to the NRC on September 30 resulted from a combination of factors, including Mr. Edgar's attempt to get an answer for Mr. Joukoff as promptly as possible, the unavailability of Mr. Koontz at that time, and the miscommunication between Mr. Edgar and Mr. Jaeger. There was clearly no intent to mislead the NRC or provide the NRC with incomplete or inaccurate information about the August 1996 shipment.
SPC also attempted to detemine why the fact that the August 1996 shipment was overweight was tsot discovered durino Sns determination of the number of overweight shipments in April 1997. The packing of the conteners used in the August 1996 shipment had commenced in June 1996 using the weight limits contained in Revision 3 of the DOT certificate and the underlying Japanese certificate. When Revision 3 of the DOT certificate expired, the actual shipment of these containers was delayed pending the extension or revalidation of the DOT certificate. As indicated in the SPC/ DOT correspondence leviewed by Mr. Edgar in his interview, DOT's revalidation and extension of the certificate was being delayed by the f act that the permissible shipping weights in the Japanese certificate for the higher enrichment levels did not match the weight levels used in the nuclear crite:ality analysis supplied by the Japanese.
DOT had been awcre of the f act that the criticality analysis was based upon lower weight levels for some time, and had previously provided SPC with an interim six month extension of the DOT certificate (i.e., Revision 3) authorizing continued use of the higher weight levels in the l
underlying Japanese certificate pending further review. While SPC had agreed to a reduction in the weight levels in order to expedite DOT issuance of a new certificate, there was a possibility that DOT would simply provide another interim extension based upon the weight levels in the Japanese certificate, in any event, the P. ant Operations Department personnel who load the UO powder into the pails, the Traffic end Warehousing personnel who pack the pails into the l
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4 E. W. M:rschof f BNF:97:101 October 10,1997 Page 3 shipping containers, and the Logistics personnel who prepare the shipping doeurnentation and make the actual shipping arrangements were not aware of the ongoing discussions between SPC Regulatory Compliar ce and DOT about a possible reduction in weight limits. The August 1990 shipment had already been packed, loaded, and prepared for shipment pending receipt of the new certificate from DOT. DOT faxed the new certificate to SPC on August 27,1996. As Mr. Edgar stated in his 11terview, and the markings on the f acsimile pages indicatt the DOT f ax did not include Appendl4 A, the table containing the revised weight limits, and the version of Revision 4 which was initially circulated at SPC did not include this table. Consequently, when the Logistics group was notified that the certificate had been issuod, it completed the shipping documentation and proceeded with the shipment without realizing that there had boon a reduction in the weigat limits.
When SPC initiated its initial investigation into possible overweight shipments in March 1997, it focused on a review of documentation related to all of the shipments which had been packed after Revision 4 of the DOT certificata was issued on August 27,1996. Since SPC had started packing the August 1990 shipment prior to the issuance of Revision 4, the documentation associated with this shipment was not reviewed to determine whether this shipment was overweight. This was a mistake since the shipment was actually shipped under Revision 4, despite having been pecked prior to the issuance of Revision 4.
In order to put the level of SPC's shipping activity and licensing responsibilities in this area in perspective, it is luportant to note that during the nine month period from June 30,1996, the expiration date of Revision 3 of the DOT rav'.slidation of the NT lX container, until March 30, 1997, the approximate time of discover l of the overweight shipments, SPC made nearly 200 separate shipments of radioactive mxerial. Of these shipments, approximately two thirds were made in containers requiring NRC and/or DOT Certificates. SPC uses ten different containers covered by certificates issued by various regulatory agencies in the normal course of business and is responsiSto for the U.S. licensing for five of these certificates, in the course of conducting this level of radioactive materials shipping operations, SPC has maintained a solid history of compliance with regulations and a proactive approach to improving its operations.
Subsequent to its previous investigation of this matter, SPC had undertaken the following actions to improve the distribution and processin;, of revisions to certificates and promulgation of change noticas related to these certificates:
The Manuf acturing Quality Team (MOT) on fuel assembly shipping containers had its charter expanded to include powder and pellet containers. The MOT provides support to Traffic and Warehousing on revising and updating container drawings and resolution of shipping container problems, The MOT also now reviews now or revised container certificates for containerr. routinely a
used by SPC.
A check sheet for important shipment information is to be developed by the Customer Projects organization for each project.
e E. W. M:rschof f BNF:97:101 i
October 16,1997 Page 4 The appendix to chapter 5, Radioactive Materials Shipping Standards, of SPC's Safety Manual has been revised to list current certificate revisions for containers routinely used by SPC. It also lists locations where a copy of any such certificate may be viewed or obtained, in addition to those corrective and preventive actions, SPC is taking further steps to formalize 1
responsibilities for the timely dissemination of appropriate information on shipping container compliance issues to parties within SPC who need access te this information. This will be accomplished by expanding and clarifying the responsibilities cssigned to Regulatory Compliance and Traffic and Warehousing described in SPC's Radioactive Materials Shipping Standard.
Regulatory Compliance's added responsibilities will include keeping interested parties in SPC apprised of the current status of shipping container licenses as well as up to date on prolacted outcomes of licensing actions. To Traffic and Warehousing's responsibilities will be added the
'ormal requirement for review of revised container certificates and the provision to interssted parties of a description of the revisions to the certificates and their effects on operations.
These incidents of nc7 compliance with the shipping container certificate for the NT-IX container have been subjected to a formal SPC Incident Investigation Board and significant management review. While the investigation revealed a number of personnel errors that contributed to the non compliant shipments, the investigation and our reviews did not indicate that the actions of any one individual were solely or primarily at f ault. We did, howsver, identify systemic weaknesses in the manner in which key shipping conta'ner compliance information is received and then conveyed to plant personnel. As described above, we have instituted corrective and preventive measures to make our operations and communications in this area m<ve robust from a compliance standpoint. We are confident that these actions wil:
prevent future occurrences of this kind.
If you have any additional questions about this matter, please call me at (509) 375 8191.
Very truly yours, B. N eft Vice Preside t, Manuf acturing cc:
P. V. Joukoff, NRC Region IV Office of Investigations F. A. Wenslawski, NRC Region IV, Walnut Creek Field Office E. L. Williamson, NRC Region IV, Office of Investigations l
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