ML20141K579

Insp Rept 70-1257/97-04 on 970414-18,23,24 & 0501.Violations Noted.Major Areas Inspected:Operations,Radioactive Effluent Discharges,Environ Protection,Solid Radioactive Waste Mgt & Transportation of Radioactive Matls

ML20141K579
Person / Time
Site:	Framatome ANP Richland
Issue date:	05/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20141K569	List: ML20141K566 ML20141K578 ML20141K579
References
70-1257-97-04, 70-1257-97-4, NUDOCS 9705290224
Download: ML20141K579 (30)

Text

- . . . _ _ . _ . . _ . . _ . . . . _ . . . _ _ . _ .. _ ._._ _ _ _ _ _ _. . _ _ _ .

l ENCLOSURE 2 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No.: 70-1257.

License No.: SNM-1227 Report No.: 70-1257/97-04 l Licensee: Siemens Power Corporation (SPC)

Facility: Siemens Power Corporation

- Location: Richland, Washington Dates: April 14-18, 23, 24 and May 1,1997 l

Inspectors: C. A. Hooker, Senior Fuel Facility inspector H. D. Chaney, Fuel Facility / Decommissioning Inspector Approved By: Frank A. Wenslawski, Chief Materials Branch

Attachment:

Supplemental Inspection Information r

L 1

9705290224 970523 9

~

PDR ADOCK 07001257 C PDR .

l s

l 1

l EXECUTIVE

SUMMARY

Siemens Power Corporation NRC Inspection Report 70-1257/97-04 This routine, announced inspection included the areas of operations review, radioactive effluent discharges, environmental protection, solid radioactive waste management, transportation of radioactive materials, followup on licensee events, and followup on open items.

Operations 1

-

• Licensee oversight of contractor activities has continued to be good (Section 1.1).

• The licensee had taken appropriate actions to investigate and preclude the use of a

defective valve used on uranium hexafluoride (UF.) cylinders (Section 1.2).

• The licensee's response to and actions taken during an electrical fire appeared appropriate (Section 1.3).

Radioactive Effluents j l

• The licensee was effectively controlling radioactive liquid and gaseous effluent I releases and these releases appeared as low as is reasonably achievable (ALARA)

(Section 2.1).

Environmental Protection

• The licensee was effectively implementing its environmental monitoring program and offsite releases did not appear to have any adverse impact on the environment  !

(Section 3.1).  !

• The license's investigation and corrective actions for an incident involving a high lagoon level appeared appropriate (Section 3.2).

l Solid Radioactive Waste Manaaement and Storaae

[

'

• Although the licensee was below its anticipated waste reduction goal, the licensee l was effectively implementing its waste minimization and volume reduction program l (Section 5.1).

• The licensee's waste packaging and shipping activities were consistent with the

applicable regulatory requirements and licensee procedures (Section 5.3).

• The licensee was adequately managing its onsite waste storage program (Section 5.4).

8 Transportation of Radioactive Materials

• The licensee's transportation program was well documented. However, collectively, several matters indicate a need for increased management involvement and oversight for shipping fissile material. These matters involve delays in updating applicable procedures to reflect current regulatory requirements and inclusion of updated shipping container certifications (Section 6.1), the licensee's identification of two foreign shipments that exceeded uranium mass limit for the package (this issue remains as an unresolved item) (Section 6.2), a violation involving the licensee's failure to include cushioning materialin a shipping package (Section 6.2),

and the failure of the licensee's audit programs to identify significant deficiencies in the radioactive materials shipping program (Section 6.3).

• The licensee was adequately implementing its shipping container maintenance program (Section 6.3).

l 1

i

l

~

[

4 l

I* Beport Details I

Summarv of Plant Status l

l The plant was operating both of its wet chemical conversion lines and the existing pilot dry conversion process. Fuel pellet production was also in progress. There was no fuel rod fabrication or fuel bundle assembly operations in progress. Ongoing building construction l consisted of continuing with the new Dry Conversion Facility (DCF) and the addition to the s Lagoon Uranium Recovery process, i

l 1 Plant Operations 1.1 DCF l a. insoection Scone (88020) l l

The inspectors toured the DCF with cognizant licensee personnel to observe the general status of equipment installation and discussed the licensee's plans for startup testing.

b. Observations and Findinas The inspectors noted that the progress of equipment installation appeared

! consistent with the licensee's plans for startup testing of the Line 1 conversion l process in early May 1997. The licensee's plans were to conduct startup testing in accordance with the engineering change notice (ECN) process using either natural or depleted uranium which is regulated by the State of Washington. Enriched uranium will not be introduced until after qualification of the process and completion of the criticality safety analyses.

The inspectors noted that the responsible system engineer and project management were actively observing and inspecting the installation of process equipment and systems being installed by the contractors.

Inspection Report 70-1257/97-03, dated April 4,1997, described the need for improved housekeeping and protection of open process systems and vessels from dust and construction debris. The inspectors noted that the licensee had taken actions to alleviate these concerns, j c. Conclusions

)

Licensee oversight of contractor activities continues to be good. Housekeeping appeared adequate relative to the amount of construction activity in progress.

i

5 1.2 UF, Cylinder Valves

a. Insoection Scope (88020)

The inspectors reviewed and discussed the licensee's actions related to a Part 21 Report (NRC Event 31954, dated March 14,1997) from the U. S. Enrichment Corporation (USEC) gaseous diffusion facility at Paducah, Kentuc'Ky concerning a stress corrosion cracking problem with a UF, cylinder packing nut (636-alloy) for valves supplied by the Hunt Valve Company. In one case, the USEC had i experienced a UF, release from a cracked packing nut. l

b. Observations and Findinas Immediately following the report, the licensee discussed the matter with the l Region IV Walnut Creek Field Office and contacted the USEC and the valve manufacturer. From information collected by the licensee, the cracking problem appeared to be lirnited to the Hunt 636-alloy valve and not that of other I manufacturers. At the time of the notification, the facility was shut down for its annual inventory and maintenance outage; therefore, no processing operations were j in progress. The licensee had identified 31 UFs cylinders onsite with the 636-alloy Hunt valve. Other valves made of the 636-alloy in cylinders at the facility were l

either made by Superior or Descote. Of the 31 cylinders,16 were full and 5 had been processed. Prior to the processing, the licensee changed the 636-alloy valves to another approved valve (monel or 613-alloy). The inspectors also noted that the licensee had posted signs at each of the vaporization chests instructing personnel to inspect all cylinders for Hunt valves and not to process any cylinders with the Hunt 636-alloy valve. At the time of the inspection, no other additional information had been disseminated by the menufacturer to licensees regarding Hunt 636-alloy valves. However, the licensu was continuing its pursuit of the matter.

c. Conclusions The licensee had taken appropriate actions to investigate and preclude the use of the Hunt 636-alloy valve.

l 1.3 Review of Operational Events (90712 and 88020)

LQlosed) Licensee Event Report No. 31975: Electrical fire and partial power outage.

On March 19,1997, the licensee notified the NRC of the event for informational purposes in that the event resulted in an electrical outage in some of the office buildings, the ammonia recovery facility, the UF, storage pad scale house, and the uranyl nitrate hexchydrate warehouse.

At approximately 2:35 p.m. on March 1997, two electrical 12,000 volt conduit elbows in an underground vault failed and resulted in ignition of the electrical insulating materials. The licensee responded to the event using dry chemical fire i

l

t 6-extinguishers to combat the fire from above the vault. The underground vault is owned and maintained by the City of Richland. Within 9 minutes, a Richland electrical maintenance crew responded to the scene and de-energized the electrical power to the vault. The City of Richland Fire Department arrived on the scene in approximately 12 minutes and declared the fire out at 2:49 p.m. The City's maintenance crew repaired the failed connectors and restored the power within an hour.

The cause of the fire was the failure of the ceramics in the electrical connector.

The fire did not result in a threat to, or release of, radioactive materials or hazardous chemicals, or provide cause for the license to initiate its emergency plan (fire was extinguished within 15 minutes). The licermee's investigation of the matter included discussions with the City relative to preventative maintenance and/or tests to prevent recurrence of such events. According to the licensee (internal memorandum dated April 10,1997), the City's response was that any testing of the system would cause power interruptions and there were no effective tests that could determine when such failures may occur. The licensee noted that they have 18 electrical vaults,21 transformers, and 6 switch cabinets owned and maintained by the City that have the potential for similar events. Related to this matter, the licensee inspected each of the locations to assure there was no combustible materials in the immediate area of the units.

The inspectors concluded that the licensee's response to, and actions taken during the event appeared appropriate. Although no specific actions were established to prevent recurrence of similar events, the licensee had adequately reviewed the matter with the City of Richland.

Non-Reportable Operational Events (88020)

At the onset of the inspection, the licensee informed the inspectors of their initiation of an investigation into a matter involving an individual placing a rubber glove over an air sampler while transferring residual low-enriched uranium powder remaining in an emptied bucket into another container outside of a ventilated hood. Since the licensee was currently investigating the matter it was decided, after consultation with the regional office, to await the licensee's report on the matter before NRC would do its review.

The NRC's review of the licensee's investigation will be documented in a subsequent inspection report and is considered as an unresolved item (URI 70-1257/9704-01).

1

l. \

7 i

I 2 Radioactive Effluents 2.1 Radioactive Liquid Effluents

a. Insoection Scoce (88035)

The inspection included a review of liquid effluent sampling data, selected licensee

! procedures, and a tour of the liquid effluent sampling station to observe the status of the sampling and effluent measurement equipment,

b. Observations and Findinas The inspectors noted that composite samples of discharges from Lagoon SA to the onsite sewer system line for the past year continue to indicate that uranium l

concentrations are typically less than 0.1 parts per million (ppm). Composite

! samples of the retention tank from the laundry facility were typically less than 0.2 ppm uranium. Daily composite samples of the combined site effluents ir'dicated i uranium concentrations were typically less than the licensee's detection leve of I O.05 ppm. On one occasion in March 1997, the licensee noted a concentration of l 0.06 ppm in the site effluent. This was caused by depletion of the ion exchange (IX) column on the Lagoon SA discharge system. Typically the licensee j regenerates (elutes) the IX column every 6 months. In response to the finding, the licensee initiated a program to evaluate the uranium concentration in and out of the IX column to better evaluate depletion and when regeneration was needed.

During a tour of the licensee's liquid effluent sampling station, the inspector noted that the liquid effluent flow measurement system (pressure bubbler type), the in-line

! pH measurement system and automatic composite sampling system were fully operational and currently calibrated. A view of inside the manhole for the sampling equipment and effluent flow fiume indicated that the effluent stream was free of any debris that could have a negative impact on the sampling system.

The inspectors noted that there had been no changes in the licensee's analytical program during the past year. The licensee continues to use a nitrogen ion laser kinetic phosphorescence analyzer (KPA) to determine the total uranium concentration released in liquid effluents. As currently used, the KPA's detection limit about 0.05 ppm uranium which corresponds to approximately 8.8E-8 microcuries (uCi) per milliliter, based on an average specific activity related to an average of ~3.0 wt.% U-235 in the licensee's onsite waste streams as determined from mass spectrometry analysis. The performance of the KPA unit is

monitored by plotting daily standards against a weekly generated calibration curve.

The inspectors also noted that the licensee maintains an accreditation by the State of Washington Department of Ecology to perform analysis on several chemical elements and uranium.

d

c. Conclusions Liquid effluent releases to the sanitary sewer system were well below the limits specified in 10 CFR Part 20 and appeared ALARA.

2.2 Gaseous Effluent Releases

a. Insoection Scoce (88035)

The inspectors toured licensee facilities to observe operations associated with gaseous effluent sampling equiprnent and reviewed selected gaseous effluent sampling data for the past year.

b. Observations During facility tours, the inspectors noted that stack sampling equipment appeared fully operational. Current calibration stickers for the flow meters and a tag that showed the calibrated sample flow rates and corresponding sample flowmeter readings were appropriately located at each sample collection station. Inspection Report 70-1257/97-03, dated April 4,1997, described a problem concerning considerable liquid in the exhaust stack air sample flowmeter, down stream of the sample filter for the licensee's incinerator facility. During this inspection, the inspectors noted that the licensee had corrected the problem. The heat tracing system had been repaired, and the flow meter and sample filter assembly were placed in a temperature controlled heat box to eliminate any moisture buildup.

The licensee's sample data and evaluation of gaseous effluent releases at the site boundary indicated that releases of radioactive materials were well below the limits specified in 10 CFR Part 20 and the reporting level in Part I, Section 5.1.1 of the license.

The inspectors noted that the licensee's calculated annual dose for 1996 gaseous effluent discharges was less than 0.011 millirem to the maximally exposed person living at the nearest site boundary. This dose was calculated using Environmental Protection Agency " COMPLY" computer code,

c. Conclusions Tb licensee was adequately controlling radioactive gaseous effluent releases and the data indicated that releases were being maintained ALARA.

r . .

1 l

2.3 Effluent Reports

a. inspection Scoce (88035)

The licensee's semiannual effluent reports for 1996, dated August 22,1996,and l l

February 5,1997, were reviewed.

b. Observations and Findinas l

) The reports provided a summary of the radioactive gaseous and liquid effluents

! released from the licensee's facility. The reports also provided a summary of

! radioactive solid waste sent for burial. The licensee's reports indicated that a total l l

- of 8.6 uCi of low enriched uranium had been released from gaseous effluent

! discharges in 1996. This was a slight increase from 5.5 uCi released in 1995 when the waste incinerator was in a shutdown status. Regarding liquid effluents, the l licensee's data for 1996 indicated that 0.008 curies of low enriched uranium had l been released to the sanitary sewer (composite samples from Lagoon SA and i laundry retention tank) which was less than the 0.014 curies released in 1995.

l c. Conclusions l

The inspectors concluded that the reports were submitted in accordance with the l

requirements of 10 CFR 70.59, and no apparent errors or anomalies were identified.

Liquid and gaseous effluent releases appeared minimal.

3 Environmental Protection l

l 3.1 Environmental Proaram a, insoection Scoce (88045) i The inspectors reviewed the licensee's implementation of its environmental control program which included facility tours and review of licensee procedures, selected records of environmental sampling results for the past year, and licensee internal environmental audits.

b. Observations and Findinas Responsibilities, controls, and the environmental surveillance program were adequately described in Chapter 4.0, " Environmental Standards," of the licensee's safety manual (EMF-30). Controls for liquid and gaseous effluent releases,

- described above, were also included in this standard. Collection and treatment of each type of sample were provided in lower tier radiological and operating l procedures.

I l

The inspectors noted that monthly inter-liner samples taken from the lagoons indicated no lagoon leakage. During the past two years, no measurable liquid had been observed from the lagoon leak detection system.

The licensee's sample results of water samples from nearby test wells (GM-1 up-gradient and down-gradient GM 5-8, and TW 6-7 and 21) have shown no significant impact from lagoon operations in the groundwater (non-drinking water).

The licensee's trending of vendor-supplied analytical results of 1996 quarterly groundwater well water samples continue to indicate a slight decrease in gross alpha and beta concentrations in down gradient well water sample results. As an example, for well GM-5 immediately down-gradient of Lagoon 1, the average 1995 gross alpha activity was approximately 110 picocuries per liter (pCi/l). The 1996 average was 78.8 pCi/l.

There were similar overall decreases and/or leveling trends for chemical constituents. Trichloroethane ranged from 2.0 micrograms per liter (ug/l) to 7.0 ug/l. Test well GM-8 had the highest concentration of trichloroethane with a 1996 average of 5.7 ug/l, slightly above the Environmental Protection Agency's drinking water standard of 5.0 ug/l. Nitrate was detected in all of the wells sampled during 1996 and ranged in concentration from 11.0 to 33.73 milligrams per liter (mg/l) which showed a slight increase from 1995, but lower than in previous years.

Ammonia was only detected in Wells GM-5 and 8 and ranged in concentrations from 5.44 to 19.24 mg/l ammonia (as nitrate). Ammonia levels continued to show a decreasing trend. Fluoride was detected in all wells sampled and ranged in concentrations from 0.28 mg/l to 12.0 mg/l, with the highest concentration in Well GM-5 (from 4.9 mg/l to 12.0 mg/l). These values have been generally constant from 1994 to 1996.

The inspectors noted that analytical results of quarterly soil samples indicated uranium concentrations of less than 1 picocurie per gram (pCi/g). Sample data for fluoride in air and forage continue to indicate values slightly above or less than the respective detection limit.

Related to liquid effluent releases to the sanitary sewer system, the licensee's analytical results of monthly sewer sludge samples taken at the Richland sanitary treatment f acility continue to indicate an average of less than 10.0 pCi/g, which represents a steady downward trend during the past few years.

The licensee's environmental audit program was consistent with Section 2.7.5,

" Environmental Protection Inspections," Part 1, of the license. These quarterly audits were effective in finding deficiencies that were tracked to resolution, and corrective actions appeared adequate.

l

l

c. Conclusions The inspectors concluded that the licensee's sampling program was consistent with Section 5.2, Part I, of the license application and licensee procedures. The licensee's audits appeared effective in identifying deficiencies and corrective actions appeared adequate to prevent recurrence. The licensee's overall environmental monitoring program appeared adequate, and offsite releases did not appear to have any adverse effect on the environment.

3.2 Licensee Investiaation (88035 and 88045)

The inspectors reviewed an Incident Investigation Board (118) Report, " Lagoon #2 High Level 118," issued on March 27,1997. This incident involved an event that occurred on Friday, March 14,1997, at approximately 4:15 p.m., when a maintenance engineer walking near the lagoon at the end of the working day noted that the level of the lagoon appeared abnormally high and warned Plant Operations of the observation. Operations stopped a pumping operation from Lagoon 1 and began to process Lagoon 2 to reduce the level. Both of these lagoons are covered to prevent ammonia (concentrated) from evaporating to the atmosphere. Lagoon 1 is normally the backup lagoon and is seldom used and normally maintained empty.

Lagoon 1 is occasionally used to keep the system active. The licensee was using the Lagoon 2 pump to feed Lagoon 1 to the Ammonia Recovery Facility with an abnormal valving arrangement between operations and engineering. The licensee identified that the valving lineup allowed approximately 15 gallons per minute (gpm) to be pumped from Lagoon 1 to the Ammonia Recovery Facility and 15 gpm to Lagoon 2 through a recirculation line.

The inspectors concluded that the licensee took prompt actions to prevent an overflow, the incident was adequately investigated, causes were identified, and corrective actions appeared appropriate. The inspectors had no further questions related to this matter.

4 Engineering (92702)

LClosed) Violation 70-1257/9704-01: Failure to follow the engineering change notice process related to field changes during the installation of two new air sampling vacuum pumps. Based on discussions with cognizant licensee personnel, and a review of training records and revised Engineering Procedure, EMF-858, No.1.13, " Engineering Change Notice (ECN)," Revision 17, dated March 7,1997, the inspectors verified that the licensee had completed the corrective actions described in the licensee's letter dated February 27,1997. No additional concerns were identified by the inspectors.

5 Solid Radioactive Waste (RW) Management and Waste Storage 5.1 Solid RW Manaaement (88035 and 84850)

a. inspection Scoce The inspectors reviewed the effectiveness of the licensee's RW management program to determine whether the licensee has established and is maintaining adequate management controls and an effective quality assurance program to reasonably ensure that RW is properly handled, characterized, classified, and processed to ensure compliance with the requirements of 10 CFR 61. The inspection included discussions with cognizant licensee personnel, observations made during facility tours and a review of the waste management organization, records of training, the amount and types of RW on hand, licensee procedures, and the RW assay and characterization processes. The following licensee procedures were reviewed:

• Chapter 5, " Radioactive Material Shipping Standard," of the licensee's Safety Manual (EMF 30), Rev. 23.

• EMF-30-P94,102, " General Waste Management," Rev. 2.

• EMF-22-P66,803, " Class A Waste Generator Requirements," Rev.15.

• EMF-22-P66,1055, " Wet Waste Uranium Recovery Station," Rev.1.

• EMF-22-P66,937, " Waste Assay Operation," Rev. 4.

• EMF-10-P69,096, " Inspection and Certification of Waste for Land Disposal,"

Rev.3.

b. Observations and Findinas The inspectors observed the licensee had in place an organization consisting of one manager and five staff engineers to run the waste processing and storage operations. Waste is collected from specific waste stream sites throughout the plant and in various forms (liquid and solid). Dry solid waste is also received from Germany that is specific to SPC operations supplying uranium fuel feed materials to a sister plant in Germany. The licensee's program is well documented and managed. Each type of waste processed is documented and it characterizations are manifested.

Within the licensee's current inventory of RW, a large portion of the waste has been classified as mixed waste with high uranium concentrations that will require special processing prior to authorized disposal. Additionally, the licensee has a large l number of high uranium content high-efficiency particulate air (HEPA) filters that

l l

need further processing so they are acceptable for burial. The licensee entered into a contract with an outside vendor to develop and install on site a special mobile facility for processing dry active waste and recovery of the uranium. The licensee had planned to have this new facility operational in early 1997. The licensee's .

processing plans and waste reduction goals were previously discussed in NRC l Inspection Report No. 70-1257/96-02. j The inspectors noted that the licensee's April 1997 inventory of onsite RW was l approximately 60,000 ft a, which was about 34,000 ft over the licensee's reduction goal for this time and date, as discussed in the licensee's Waste Engineering Plan and NRC Policy issue SECY-94-098,

Subject:

Management of Radioactive Waste Inventory at Siemens Power Corporation, dated April 8,1994. The licensee's plans for reducing the waste inventory to less than 26,000 ft 8has been set back due to delays with the manufacturer of the new mobile processing facility. The licensee discussed its intention to send the NRC a revised waste management reduction goal plan that recognizes the setbacks they have encountered.

l Licensee waste characterization and classification procedures were found to be in agreement with NRC Branch Technical Position, " Radioactive Waste Classification,"

dated May 1983, and the requirements of 10 CFR Part 61.

1 Waste minimization has been effectively communicated to employees through I licensee procedures and personnel training, based on inspector observations.

Additionally, the licensee's waste management engineering staff were actively involved in evaluating engineering controls for waste minimization. The inspectors noted that the licensee had provided training on its waste minimization procedures to all waste handlers and waste generators. No active RW packaging was ongoing during inspector tours. During facility tours, the inspectors noted that instructions were provided on waste collection receptacles throughout the plant to aid in segregation of waste prior to final segregation and packaging. Personnel performing waste handling operations appeared very knowledgeable of their assigned tasks.

Good housekeeping practices were noted in all areas toured.

Based on observations during facility tours and discussions with waste handing l personnel, the inspectors noted that waste handling operations were consistent l with licensee procedures and regulatory requirements. The inspectors also noted that these tasks were performed by individuals who had been trained and qualified

! for the work being performed.

c. Conclusions T he inspectors concluded that although the licensee was not meeting its anticipated onite waste volume reduction goal at the time of the inspection, the licensee was effecuvely implernenting its waste minimization program throughout the plant. The program was adequately documented and personnel adequately trained in waste handling operations.

1

, e 5.2 Radioactive Waste Packaaina and Shioment to Land Discosal

a. Insoection Scoce (84850)

The licensee's program for shipment of RW was reviewed to determine whether the requirements of 10 CFR Parts 20.2006 and Appendix F, and 10 CFR Part 61.55 and 61.56 were being met. The following licensee documents and procedures were reviewed during this portion of the inspection:

• EMF-1812, " Regulatory and Quality Requirements for Land Disposal of l Radioactive Waste," Rev.1.

• Radioactive waste shipments records for shipments since January 1,1997.

• EMF-22, P66,1080, "LLRW Packaging Procedure," Rev.1.

• EMF-696, P43,086, " Shipment of Low-Level Radioactive Waste to Disposal Sites," Rev.11.

• EMF-22-P66,933, " Preparation of Stored Waste Containers for Off Site Shipment," Rev. 2.

l

b. Observations and Findinas All shipments since January 1997, have been sent to a waste processor for volume reduction. No problems were noted with the shipments or the content of the documentation. RW sent for disposal was being classified pursuant to 10 CFR 61.55 and chara:terized in accordance with the requirements of I CFR 61.56. RW manifesa and licensee retained documentation satisfy 10 CFR l Part 20, Appendix F requirements,

c. Conclusions The inspectors concluded that the licensee waste packaging and shipping activities were consistent with the applicable regulatory requirements and licensee procedures.

! 5.3 RW Storaae

a. Inspection Scope (84900)

The inspectors reviewed the licensee's storage of low-level RW and the following licensee procedures:

• EMF-22, P66,1080, "LLRW Packaging Procedure," R-1, dated March 17, 1997.

• EMF-22, PCo,942, " Temporary Storage of HEPA and Pre-filters," R-2, dated August 18,1905.

• EMF-695-P43,129, "LLRW and Ash Package Handling, Storage and Shipping," R-1, dated March 27,1997.

b. Observations and Findinas The licensee's waste management program closely monitors waste genc ation and storage. Waste is stored in industry approved receptacles (DOT shippire ;ontainer and Environmental Protection Agency approved hazardous waste containers). The inspectors also noted that the licensee maintains an excellent computerized data base accountability system for each container of waste located in the storage yard.

Segregation of specific wastes was well controlled for ease of retrieval and processing.

l The containers were arranged relative to their contents for further processing and

! ultimate disposal. Each storage row of containers was numbered and each l container was identified by an easily identifiable serial number. Although the l licensee's waste is stored outside, the inspector did not see any container deterioration that reprewnted a safety concern. The containers are stored off the ground on pallets and rcJtinely inspected by the licensee. The licensee has no onsite buried waste. The inspectors validated several containers and their location  !

as noted in the data base.

c. Conclusions The inspectors concluded that while the licensee has maintained a large inventory of packaged waste, the waste was being properly managed and stored safely.

6 Transportation of Radioactive Materials 6.1 Imolementina Procedures. Shionina Pacers. and Trainina l a. Inspection Scope (86740)

I

! The inspectors reviewed records of several selected domestic and overseas fuel  !

l shipments for 1996 and 1997, to determine the licensee's compUance with NRC and DOT transportation requirements for fissile and low-level radioactive waste l shipments, including the proper use of International System of Units (SI) units.

Records of personnel training were also reviewed. Specific procedures reviewed were:

• EMF-30, " Safety Manual," Chapter 5, " Radioactive Material Shipping S*.andard," Revision 23.

i

• EMF-695-P43,106, " Records Retention," Revision 2.

• EMF-22,P66,1080, "LLRW Packaging Procedure," Revision 1.

• EMF-695-P43,109, " Packing, Shipp'ng.....BW-2901 and DHTF Shipping Containers," Revision 12.

• EMF 695-P43,100, " Shipping........SP-1/SP-2 Shipping Containers,"

Revision 16.

)

• EMF-695-P43,107, " Packing and Shipping....RBU Shipping Containers," l Revision 9.

• EMF-695-P43,085, " Packing and Shipping.... ANF-250 Containers,"

Revision 25.

• EMF-695-P43,102, " Packaging, Shipping.....UF 30B Cylinders...,"

Revision 12.

• EMF-695-P43,128, " Radioactive Materials Shipment and Truck inspection."

b. Observations and Findinas Procedures and Shionina Pacers The licensee was found to maintain detailed procedures for shipment of each type of package used. However, the inspectors noted that applicable procedures had not I

been revised to reflect the use of SI units for activity as required in 49 CFR Part 172.203(d)(4), effective April 1,1997. Most procedures either referenced the l

' use of customary units (dpm, curie, etc.,) alone, did not indicate the units to use, or were silent on the radiological units to use in completing shipping documents. This matter was also identif'ed during a transportation audit performed by the safety l department on Decer.iber 12-16,1996. However, the licensee subsequently interpreted the requirement incorrectly and believed that use of SI units was not fully in effect until October 1997. Although the procedures had not been updated, the inspectors noted that the licensee had initiated the use of Si units on the " Bill of Lading" for all shipments since April 1,1997.

The inspectors also noted that a combination of approximately 15 of NRC Certificate of Compliance (COC) certifications and/or DOT Co'mpetent Authority Certifications (CACs) for package design of foreign Competent Authority Certificates in Chapter 5 of EMF-30 had either expired or were not the current revision. EMF-30 is maintained in " mini-libraries" throughout the site, including the shipping warehouse, with other specific controlled documents and procedures that are used as control documents by the plant staff. The inspectors noted that

ll l

l.

i l

1 l

although EMF-30 did not contain updated COCs or CACs, the current certifications for packages in use were available in separate files at the shipping warehouse.

The inspectors' observation of the need to update transportation procedures and 1 safety standards was acknowledged by the licensee. The licensee's action related l l to this matter will be reviewed in a subsequent inspection and is an inspection followup item (IFl 70-1257/9704-02). l l

The inspectors noted that the licensee performed receipt surveys pursuant to i 10 CFR 20.1906, and transfers of special nuclear material were conducted in accordance with the requirements delineated in 10 CFR 70.42. With the exception  !

l

' of the licensee not updating its procedures to include the use of SI units, the new regulatory requirements of 10 CFR Part 71 and 49 CFR Parts 171 through 189 were being met. The licensee also maintained current copies of export and import licenses issued under the provisions of 10 CFR Part 110.

Trainina  ;

The review of training records for selecter; workers indicated that these individuals I

had received adequate initial and recurrent training for their functional assignment and duties associated with radioactive waste processing, packaging and loading, package maintenance, and shipment receipt inspections. The licensee had maintained a radiation protection program and employee training program that met the requirements of Subparts H and I to 49 CFR 172.

c. Conclusions The licensee's program was well documented. However, the failure to ensure that the applicable procedures reflect current regulatory requirements and the maintenance of certifications in the safety standards represents a need for management attention to its procedural control process.

6.2 Precaration of Packaaes for Shioment

a. Inspection Scoce (86740) i l

The inspectors reviewed a licensee identified incident involving two shipments that exceeded the fissile limit of a DOT CAC revalidation of a foreign Competent l

Authority Certificate (J/113/AF-85). The inspectors also observed the licensee's preparation of a Nuclear Fuel Industries (NFI) shipping packages. In addition to the procedures reviewed in Sections 6.1 above, the following documents were also reviewed:

• DOT CAC USA /0442/AF, Rev. 3, dated January 17,1996.

• DOT CAC USA /0442/AF, Rev. 4, dated August 27,1996.

a

I

• DOT CAC USA /0442/AF, Rev. 5, dated March 6,1997.

• NFI, Safety Analysis Report on Tyr e NT-IX Nuclear Fuel Package, dated July 1993.

• NFI, Packing Procedure NFK-MM-930426-2, April 10,1996.

• SPC Procedure EMF-695/P43,108, " Packing, Shipping and Receiving UO2 Powder in NT-IX Shipping Containers," Rev. 6, dated April 23,1996.

b. Observations and Findinas Licensee identified Incident i At the onset of the inspection, the licensee informed the inspectors of two recent l shipments of UO2 powder to NFI, a Japanese fuel manufacturer, that exceeded the branium mass limits of the DOT CAC revalidation for the respective shipping package. The two shipments (December 4,1996 and February 12,1997) involved 594 NFl NT-lX packages that were shipped to NFl using previously approved fissile mess limits under Revision 3 of the DOT CAC. The licensee became aware of the metter on or about March 24,1997, after a worker at the shipping warehouse noted that Rev. 5 of the DOT CAC included a restriction that reduced the mass of UC2 allowed in each package. According to the licensee, Revision 4 of the DOT t

CAC received earlier contained the same reduced uranium mass limit restrictions, l but the change was not recognized by the licensee. At the time of the inspection l the licensee was conducting a self assessment to determine the root cause and define corrective actions to prevent recurrence.

l On April 29,1997, the license forwarded to the NRC (Region IV) the results of its l

investigation. This issue and the inspectors' review of the licensee's corrective actions remain an unresolved item (URI 70-1257/9704-03).

NFl NT-IX Packaae - Confiauration During observations made of staged NFl NT-IX packages being loading with pressurized water reactor (PWR) UO2 powder containers, the inspectors noted that the resultant package configuration would not match the configuration shown in the Japanese Competent Authority Certificate (J/113/AF-85) approved by the DOT.

Specifically, the package configuration used by SPC did not include cushioning materials as depicted in the Japanese certificate (J/13/AF-85) or as described in the

NFl NT-lX Safety Analysis Report (SAR) and respective handling procedures

maintained by the licensee. Without the cushioning material, there was approximately a 9-inch gap (measured) between the inner UO2 two powder

^

containers and the inner lid of the shipping package.

I. ,

l The inspector noted that the licensee had modified its loading procedure (EMF-695- l P43,108) on April 23,1996, based on receipt of a revised loading procedure from l

NFl. During discussions with the SPC Senior Licensing Engineer, it was the j licensee's interpretation that the SAR and the procedure sent by NFl supported the ,

exclusion of cushioning material. Specifically, the vertical vibration analysis in the l SAR package stated that the inner containers would not have any mechanical l damage without the cushioning material. During the onsite inspection the licensee contacted NFl relative to this matter. By facsimile on April 18,1997, NFl sent SPC l a memorandum stating, in part, that the new procedure of excluding the inner cushioning material for PWR projects was for the convenience of loading and  :

unloading the package at Japanese facility and reiterated the results of the vibration I analysis in the SAR. l

The inspectors acknowledged the statement related to results of the vibration l analysis. However, Section A.1.1, " Fuel Loading," Chapter IV, " Handling ,

l Procedures and Maintenance of Packages including Nuclear Fuel Materials," of the l safety analysis for the NFl NT-IX Package, dated July 1993, approved under the current DOT CAC, states that " cushioning materials are put in the surrounding and  ;

upper surface of the container to receive impact of force and to prevent shifting of content during transport." in addition, the loading diagram (Figure I-3) and the loading flow sheet text contained in Chapter IV of the SAR described the use of the cushioning material. Also, the new loading procedure provided by NFl had not been )

sent to the DOT for approval.

The inspectors noted that the licensee currently had packaged several hundred PWR project NFl NT-lX shipping containers that were loaded into sea land containers awaiting shipment. According to the licensee, none of these containers had been packaged with cushioning material. The inspeers subsequently determined that on June 3,1996, the licensee shipped 405 NFl NT-lX packages loaded with PWR I

UO2 powder containers to NFl that did not include the cushioning materialin the package.

C.; Aoril 22,1997, the inspectors contacted appropriate personnel in the office of ,

l I Research and Special Programs Administration of the DOT where CACs are issued l

i for revalidated foreign CACs. The requirement relative to cushioning material for shipping the PWR containers in NFl NT-lX packages was discussed. The DOT personnel agreed with the inspectors that cushioning material was clearly intended to be placed in the package during loading and closure of the package.

Furthermore, the DOT representative stated that the revised NFl procedure used by the licensee was not part of the SAR and handling procedures approved by the DOT CAC for subject NFl package.

By telephone on April 23,1997, the SPC Senior Licensing Engineer informed the inspectors that he had also discussed the cushioning matter with the DOT. He also stated that even though he believed the SAR supported the exclusion of cushioning material, the DOT was in agreement with the inspectors conclusions that the

_. m _ ._ _ _ . . _ . - . - . _ ._ _ _ _ _ _ ____ _ _ _ _ . _

l..

t i cushioning material was required for the shipping package. Therefore, he stated i that SPC would repackage all existing loaded NT-IX packages and add the cushioning material, prior to their shipment to NFl.

10 CFR 71.16 (a) and (d)(2) require, in part, that the licensee comply with the terms  ;

of the certificate of revalidation by the DOT of a foreign national competent authority certificate.

Item a., Section 4," General Conditions," of Competent Authoriiy Certification Certificate USA /0442/AF-85, Revision 3, dated January 17,1996, (in effect at the time) required each user of this certificate to maintain this certificate and all documents necessary to properly prepare the package for transportation with the endorsed certificate.

I l The inspectors determined that the failure to include the cushioning materialin the 405 NT-IX packages shipped on June 3,1996, was a violation of 10 CFR 71.16 (VIO 70-1257/9704-04).

c. ' Conclusions The violation involving the failure to install the cushioning material and the unresolved item involving the over mass limit shipments of the NX-IX packages indicate a need for increased management involvement and oversight with the shipping of fissile material.

6.3 Quality Assurance (OA) and Maintenance Proarams for Shiopina Packaaes

a. Insoection Scope (86740)

The inspectors reviewed the licensee's QA program, licensee audits, and maintenance program to determine if the licensee was effectively implementing the requirements of 10 CFR Part 71. The following documents and procedures were reviewed and discussed with licensee personnel:

• EMF-439, " Quality Assurance Program For Nuclear Fuel Shipping i Containers," Rev.11.

[

!

• QA Audit Schedule - January through December 1997, Rev. O.

i 1 * " Internal Quality Assurance Audit of Shipping Container Quality Assurance I

Program implementation (Audit No. 96:44)," dated January 7,1997.

l

• Gafety Department, " Shipping Audit," dated March 1,1996.

I

^

• Safety Department, " Shipping and Receiving Audit," January 8,1997, t

t s _ -

i

• Procedure EMF-695-P43,101, " Shipping Container Niaintenance and Repair," l Rev.11.

• Procedure EMF 696-P43,125, " Quality inspection for BWR/PWR Shipping Containers," Revision 1.

• EMF 695-P43,121, "Re-certification Inspection of UF Protective l Overpacks," Revision O.

l l b. Observations and Findinas QA Proaram SPC QA Audit No. 96:44 was conducted by a four-person QA department team in i December 1996, to verify the requirements defined in the licensee's NRC-approved l QA program (EMF-439, Rev.11), which is based on the requirements of Subpart H j to 10 CFR Part 71. The audit identified one finding and ten observations that i required corrective actions. The inspectors noted that the audit included the use of NFl NT-IX packages. The audit did not identify any deficiencies relating to the manner in which the packages were being loaded or that the CAC in effect was not consistent with procedures used for the activity, as described in Section 6.2 above.

1

! The annual audits by the safety department were conducted to verify that the requiremento for waste shipments, fissile material shipments and receipt of radioactive material packages were being performed in accordance with regulatory requirements and licensee procedures. These checklist type audits were generally effective in identification of deficiencies, with the exceptions as noted above, and recommended corrective actions appeared appropriate.

The inspectors noted that findings from the QA and safety department audits appeared administrative in nature.

j Packaae Maintenance Proaram The inspectors noted that the licensee maintained updated procedures for inspection, maintenance, and repair for each certified container used. The procedures provided a detailed container maintenance / repair matrix consistent with the requirements of the applicable container certification and industry standards.

Maintenance items requiring quality control inspections were also included in the matrix. Individuals performing these activities had been adequately trained on the i

procedures and qualified for their assigned tasks. The inspectors observed licensee

' personnel inspecting a fuel assembly shipping container (SP-1/SP-2, USA /9248/AF) 4 wooden overpack. No concerns were identified by the inspectors.

l l

l l

-2 2-

c. Conclusions The inspectors concluded that although the licensee's audit program was effective, it failed to identify inconsistent deficiencies in the radioactive materials transportation program. The licensee's package maintenance program was well documented and procedures were of sufficient detail to allow the licensee to effect appropriate maintenance on packages.

Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the onsite inspection on April 18,1997. The licensee acknowledged the

- findings presented. The Vice President, Engineering and Manufacturing, committed to provide the Region IV office a report of the results by May 9,1997, of SPC's investigation and corrective actions related to the matter involving an individual placing a rubber glove over an air sampler.

The violation involving the failure to provide cushioning materialin the NFl NT-IX shipping packages was discussed with the licensee on May 1,1997, in a subsequent telephone call.

Although proprietary information was reviewed d" ring this inspection, such information is not knowingly described in this report.

I I

I I

e l

1.

l.*

l l

1 l \

H i

ATTACHMENT I l

SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED j Licensee

• B. F. Bentley, Manager, Plant Operations

'J. B. Edgar, Senior Engineer, Licensing B. N. Femreite, Vice President, Engineering R. L. Feuerbacher, Manager, Materials and Scheduling l D. G. Hill, Manager, Quality Engineering J. W. Helton, Manager, Plant Engineering D. C. Kilian, Manager, Process Engineering ]

S. S. Koegler, Manager, Waste management Engineering l

~

M. L. Koontz, Senior Technician, Traffic and Warehousing l

• L. J. Maas, Manager, Regulatory Compliance D. G. McAlees, Senior Vive President & General Manager  ;

• R. D. Norman, Supervisor, Traffic and Warehousing C. M. Powers, Director, Quality T. C. Probasco, Manager, Safety K. H. Tanaka, Environmental Engineer R. E. Vaughan, Manager, Safety, Security and Licensing l G. N. Ward, Manager, Manufacturing Engineering i

• Denotes telephone conversation on May 1,1997.

l NRC Frank A. Wenslawski, Chief, Materials Branch, Region IV, Walnut Creek Field Office (accompanied the inspectors on April 17 and 18,1997).

INSPECTION PROCEDURES USED IP 88020: Operations Review IP 88035: Radioactive Waste Management IP 88045: Environmental Protection IP 84850: Waste Generator Requirements IP 84900: Low-Level-Waste Storage IP 86740: Inspection of Transportation Activities IP 90712: In-Office Review of Licensee Events IP 92702: Followup on Corrective Actions for Violations and Deviations i

i I

. i 1

l ITEMS OPENED, CLOSED, AND DISCUSSED i O'oened 70-1257/9704-01 URI improper transfer of uranium powder 70-1257/9704-02 IFl Update shipping procedures and safety standards l

l 70-1257/9704-03 URI Foreign shipment exceeding the uranium mass limits 70 1257/9704-04 VIO Failure to follow transportation packaging requirements.

l - Closed 70-1257/9701-01 VIO Failure to follow ECN procedure l 70-1257/31975 LER No. 31975 Electrical Fire and Partialloss of Power ,

LIST OF ACRONYMS USED ALARA As Low as is Reasonably Achievable CAC Competent Authority Certification l COC Certificate of Compliance DCF Dry Conversion Facility l DOT Department of Transportation ECN engineering change notice gpm gallons per minute HEPA high-efficiency particulate air l

HST health and safety technician llB Incident Investigation Board IX ion exchange KPA kinetic phosphorescence analyzer mg/l milligrams per liter NFl Nuclear Fuel Industries pCi/l picocuries per liter pCi/g picocuries per gram ppm parts per million l PWR pressurized water reactor i QA Quality Assurance RW radioactive waste SAR Safety Analysis Report l SI International System of Units

! SPC Siem. ens Power Corporation

! uCi microcuries l UFe uranium hexafluoride l ug/l micrograms per liter l UO 2 uranium dioxide USEC U. S. Enrichment Corporation l

l-l re+ +

~

A UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE 10F NUCLEAR MATERIAL SAFETY AND SAfEGUA'ROS WASHINGTON, D.C. 20555 May 1, 1996 NRC INFORMATION NOTICE 96-28: SUGGESTED GUIDANCE RELATING TO DEVELOPMENT AND IMPLEMENTATION OF CORRECTIVE ACTION Addressees i 1

All material and fuel cycle licensees. .

Purposg The U.S. Nuclear Regulatory Commission (NRC) is issuing this information I!

notice to provide addressees with guidance relating to development and implementation of corrective actions that should be considered after identification of violation (s) of NRC reouirements. it is expected that recipients will review this information for applicability to their facilities and consider actions, as appropriate, to avoid similar problems. However,  !

suggestions contained in this information notice are not new NRC requirements; therefore, no specific action nor written response is required.

Backaround On June 30, 1995, NRC revised its Enforcement Policy (NUREG-1600)' 60 FR 34381, te clarify the enforcement program's focus by, in part, emphasizing the importa .e of identifying problems before events occur, and of taking prompt, comprc',;ensive corrective action when problems are identified. Consistent with the revised Enforcement Policy, NRC encourages and expects identification and

prompt, comprehensive correction of violations.

in many cases, licensees who identify and promptly correct non-recurring

! Severity level IV violations, without NRC involvement, will not be subject to i formal enforcement action. Such violations will be characterized as "non-cited" violations as provided in Section VII.B.1 of the Enforcement Policy.

Minor violations are not subject to formal enforcement action. Nevertheless, the root cause(s) of minor violations must be identified and appropr'iate corrective action must be taken to prevent recurrence.

If violations of more than a minor concern are identified by the NRC during an inspection, licensees will be subject to a Notice of Violation and may need to i provide a written response, as required by 10 CFR 2.201, addressing the causes i

of the violations and corrective actions taken to prevent recurrence. In some

! cases, such violations are documented on Form 591 (for materials licensees) 9604290193

' Copies of NUREG-1600 can be obtained by calling the contacts listed at

._. thn a nel n f the infnemstinn Nntien

, .__ . . - . _ _ . . . . . . ....-..-.-.- .- _-.~- -.~. -.-.----

A IN 96-28 May 1, 1996 Page 2 of 6 which constitutes a notice of violation that requires corrective action but does not require a written response. If a significant violation is involved, ,

a predecisional enforcement conference may be held to discuss those actions. l The quality of a licensee's root cause analysis and plans for corrective  ;

actions may affect the NRC's decision regarding both the need to hold a predecisional enforcement conference with the licensee and the level of sanction proposed or imposed.

Discussion Comprehensive corrective action is required for all violations. In most cases, NRC does not propose imposition of a civil penalty where the licer.see promptly identifies and comprehensively corrects violations. However,'r.

Severity Level III violation will almost always result in a civil penalty if a licensee does not take prompt and comprehensive corrective actions to address the violation.

It is important for licensees, upon identification of a violation, to take the necessary corrective action to address the noncompliant condition and to prcyc..t recLerence vf U.e viulation and (ne occurrence of similar violations. I Prompt comprehensive action to improve safety is not only in the public l interest, but is also in the interest of licensees and their employees. In addition, it will lessen the likelihood of receiving a civil penalty. Compre-hensive corrective action cannot be developed without a full understanding of 1 the root causes of the violation.

Therefore, to assist licensees, the NRC staff has prepared the following guidance, that may be used for developing and implementing corrective action.

Corrective action should be appropriately comprehensive to not only prevent recurrence of the violation at issue, but also to prevent occurrence of similar violations. The guidance should help in focusing corrective actions broadly to the general area of concern rather than narrowly to the specific violations. The actions that need to be taken are dependent on the facts and circumstances of the particular case.

The corrective action process should involve the following three steps:

l 1. Conduct a complete and thorouah review of the circumstances that led to l the violation. Typically, such reviews include:

l l

- Interviews with individuals who are either directly or indirectly involved in the violation, including management personnel and those responsible for training or procedure development / guidance.

Particular attention should be paid to lines of communication between supervisors and workers.

e

, IN 96-28 May 1, 1996 Page 3 of 6 1

- Tours and observations of the area where the violation occurred, particularly when those reviewing the incident do not have day-to-day contact with the operation under review. During the tour, individuals should look for items that may have contributed to the violation as well as those items that may result in future violations. Reenactments (without use of radiation sources, if they were involved in the original incident) may be warranted to better understand what actually occurred. ,

- Review of programs, procedures, audits, and records that relate directly or indirectly to the violation. The program should be reviewed to ensure that its overall objectives and requirements are

~

clearly stated and implemented. Procedures should be reviewed to ,

- determine whether they are complete, logical, understandable, and meet their objectives (i.e., they should ensure compliance with the current requirements). Records should be reviewed to determine whether there is sufficient documentation of necessary tasks to provide an auditable record and to determine whether similar i violations have occurred previously. Particular attention should be l paid to training and qualification records of individuals involved ,

with the violation.

2. Identify the root cause of the violation.

Corrective action is not comprehensive unless it addresses the root cause(s) of the violation, it is essential, therefore, that the root cause(s) of a violation be identified so that appropriate action can be taken to prevent further noncompliance in this area, as well as other potentially affected areas. Violations typically have direct and indirect cause(s). As each cause is identified, ask what other factors l

could have contributed to the cause. When it is no longer possible to identify other contributing factors, the root causes probably have been identified. For example, the direct cause of a violation may be a failure to follow procedures; the indirect causes may be inadequate l

' training, lack of attention to detail, and inadequate time to carry out an activity. These factors may have been caused by a lack of staff  ;

resources that, in turn, are indicative of lack of management support.

Each of these factors must be addressed before corrective action is considered to be comprehensive.

l e

IN 96-28 May 1, 1996 Page 4 of 6

3. Take prompt and comorehensive corrective action that will address the immediate concerns and prevent recurrence of the violatiom It is important to take immediate corrective action to address the specific findings of the violation. For example, if the violation was issued because radioactive material was found in an unrestricted area, immediate corrective action must be taken to place the material under licensee control in authorized locations. After the immediate safety concerns have been addressed, timely action must be taken to prevent i future recurrence of the violation. Corrective action is sufficiently j comprehensive when corrective action is broad enough to reasonably l prevent recurrence of the specific violation as well as prevent timilar i violations.

In evaluating the root causes of a violation and developing ef fective i corrective action, consider the following: 1 1

1. Has management been informed of the violation (s)? j

2. Have the programmatic implications of the cited violation (s) and the potential presence of similar weaknesses in other program areas been considered in formulating corrective actions so that both areas are adequately addressed? l 1

3. Have precursor events been considered and factored into the corrective actions?

4. In the event of loss of radioactive material, should security of radioactive material be enhanced?

5. Has your staff been adequately trained on the applicable requirements?

6. Should personnel be re-tested to determine whether re-training should be emphasized for a given area? Is testing adequate to ensure understanding of requirements and procedures?

7. Has your staff been notified of the violation and of the applicable corrective action?

8. Are audits sufficiently detailed and frequently performed? Should the frequency of periodic audits be increased?

l l

4

, - --- y

~

ld i IN 96-28 Hay 1, 1996 '

l Page 5 of 6 i

9. Is there a need for retaining an independent technical consultant to  !

i audit the area of concern or revise your procedures?

10. Are the procedures consistent with current NRf. requirements, should they ]

be clarified, or should new procedures be developed?

11. Is a system in place for keeping abreast of new or modified NRC l

requirements? 4 j

12. Does your staff appreciate the need to consider safety in approaching daily assignments? , l l 13. Are resources adequate to perform, and maintain control over, the licensed activities? Has the radiation safety officer been provided l sufficient time and resources to perform his or her oversight duties?

i 14. Have work hours affected the employees' ability to safely perform the job?  !

15. Should organizational changes be made (e.g., changing the reporting relationship of the radiation safety officer to provide increased- i independence)?

16. Are management and the radiation safety officer adequately involved in oversight and implementation of the licensed activities? Do supervisors l

adequately observe new employees and difficult. unique, or new l

operations?

17. Has management established a work environment that encourages employees I to raise safety and compliance concerns?

Has management placed a premium on production over compliance and  !

18. i safety? Does management demonstrate a commitment to compliance and safety?

19. Has management communicated its expectations for safety and compliance?

20. Is there a published discipline policy for safety violations, and are employees aware of it? Is it being followed?

I I

l

n IN 96-28 May 1, 1996 Page 6 of 6 -

This information notice requires no specific action nor written response. If you have'any questions about the information in this notice, please contact one of the technical contacts listed below.

j

. h fg f . M 'f' h'.. .

l Eliza eth Q. n Eyck, Dirkctor Donald A. Cool, Director Div ion of fuel Cycle Safety Division of Industrial and Safeguards and Medical Safety Office of Nuclear Material Safety Office of Nuclear Material Safety I and Safeguards and Safeguards .

Technical contacts: Nader L. Mamish, OE Daniel J. Holody, R1 J (301) 415-2740 (610) 337-5312 Internet:nimenrc. gov internet:djh0nrc. gov l

L Bruno Uryc, Jr., Ril Bruce L. Burgess, Rill (404) 331-5505 (708) 829-9666 Internet:bxu0nrc. gov I n t e rr.c t : b i b?r.rc . ;:: .

! Gary F. Sanborn, RIV (817) 860-8222 Internet:gfsenrc. gov Attachments:

' 1. List of Recently issued HMSS Information Notices

2. List of Recently issued NRC Information Notices l

l l

l l

l t.