ML20133P811

Insp Repts 50-013/85-01 & 70-0824/85-05 on 850610-14. Violation Noted:Failure to Package Low Specific Activity Radioactive Matl in Strong Tight Package & Failure to Label Packages of Radioactive Matl Per Burial Facility License

ML20133P811
Person / Time
Site:	Lynchburg Research Center, 07000824
Issue date:	07/18/1985
From:	Albright R, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20133P738	List: ML20133P736 ML20133P787 ML20133P811
References
50-013-85-01, 50-13-85-1, 70-0824-85-05, 70-824-85-5, NUDOCS 8508140494
Download: ML20133P811 (5)

See also: IR 05000013/1985001

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Report Nos.:

70-824/85-05, 50-013/85-01

Licensee: Babcock and Wilcox Company

Lynchburg Research Center

Lynchburg, VA 24505

Docket Nos.:

70-824 and 50-013

License No.:

SNM-778 and

CX-10

Facility Name: Lynchburg Research Center

Inspection Conducted: June 10-14, 1985

Inspector:

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y R. H. AlbrigTt

Date signed

Approved by: M

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C. M. Hc'sey, Sect ion Chief

Date Signed

DivisionofRadia(tionSafetyandSafeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 17 inspector-hours on site

in the area of transportation of radioactive material.

Results:

Three violations - Failure to package low specific activity (LSA)

radioactive material in a strong tight package; failure to ensure that the

closure device on a package of Fissile Class II material was free of defects

prior to shipment and failure to ship Fissile Class II material in a tested,

approved package; failure to label packages of radioactive material as required

by the burial facility license.

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

• A. E. Wehrmeister, Manager, System Development Laboratory

• J. P. Doran, Manager, Accounting and Administrative Services

• G. Hoovier, Manager, Building A Decommissioning Project

• J. W. Cure, Supervisor, Health and Safety

• A. Olsen, Senior License Administrator

D. Harris, Health Physics Technician

• Attended Exit Interview.

2.

Exit Meeting

The inspection scope and findings were summarized on June 14, 1985, with

those persons indicated in paragraph 1 above.

The apparent violation of

10 CFR 71.87 for shipment of a package with a crack under a closure bracket,

violation of 10 CFR 70.42 for transferring special nuclear material to a

land disposal facility without the labels required by receiver's license and

violation of 10 CFR 71.5 for the shipment of a package of LSA radioactive

material which failed to meet the strong tight container requirement were

discussed in detail.

Licensee management acknowledged the violations.

The licensee was notified during a telephone conversation on June 19, 1985,

between J. B. Kahle of this office and A. Olsen of the licensee's staff that

failure to choose a package that was proper for the contents was another

example of a violation of 10 CFR 71.87.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3.

Licensee Action of Previous Enforcement Matters

This subject was not addressed in the inspection.

4.

Transportation of Radioactive Material (86740)

On May 29, 1985, NRC Region II received a copy of a letter dated May 20,

1985, from the State of Washington to the B&W Lynchburg Research Center.

The letter described two violations in shipment No. LRC-23.

The first

violation concerned a hole in a drum of LSA radioactive material in

violation of the strong tight package requirement of 49 CFR 173.425.

The

second violation concerned the failure to meet requirements of the U.S.

Ecology land disposal facility license by affixing the correct number of

labels to each package.

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On May 1,1985, the licensee made shipment No. LRC-23 to the U.S. Ecology

land disposal facility at Richland Washington. While unloading the shipment

of drums on May 6, 1985, disposal site personnel observed a hole in the side

of drum number 4740. The waste manifest described the contents of the drum

as uranium oxides on lab trash and equipment.

The radionuclide content

measured was Uranium-234 at 0.03 mil 11 curies, Uranium-235 at 0.002

millicuries, Uranium-236 at 0.0004 millicuries, and Uranium-238 at 0.01

millicuries. The drum was listed as Fissile Exempt and labeled Radioactive

LSA. The licensee's investigation determined that shifting of a 32 pound

metal object inside the container caused the hole. The inspector discussed,

with the U.S. Ecology health physics (HP) technician who identified the hole

in the drum, the details of the U.S. Ecology receipt of shipment No. LRC-23.

The HP technician stated that the drum with the hole had not been moved from

its shipment position in the trailer before the hole was observed. The hole

was observed after drums in front of this drum were removed while unloading

the shipment. The metal object inside the drum which apparently shifted

during transportation and caused the hole was protruding from the hole when

observed by the HP technician.

It was determined that the hole had been

punched through the wall of the Department of Transportation (DOT)

Specification 17 H drum during transport. Surveys outside the hole did not

indicate leakage of radioactive material from the can.

The amount of

radioactive material inside the can would not have caused a significant

public health and safety problem if it had been released.

10 CFR 71.5(a) requires that licensees who transport licensed material

outside the confines of its place of use or delivers such material to a

carrier for transport comply with the requirements of DOT regulations

contained in 49 CFR Parts 170 through 189. 49 CFR 173.425 requires that LSA

materials be shipped in a DOT specification 7A Type A package or a strong

tight package such that there will be no leakage of the package contents

during normal conditions of transport.

In discussions with licensee

representatives and reviews of shipping papers it was determined that three

licensee personnel observed the drum to be in good condition prior to

transport.

No other drums were damaged.

Failure to ship LSA radioactive

material in a DOT Specification 7A Type A package or a strong tight package

was

identified

as

an

apparent

violation

of

10 CFR 71.5(a).

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(70-824/85-05-01).

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10 CFR 20.301 prohibits the disposal of radioactive material except under

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specified conditions including _ transfer to an authorized recipient as

provided in the regulations in Parts 30, 40, 60, 61, 70 or 72 of this

chapter, whichever is applicable.

10 CFR 70.42 states requirements that

must be met prior to transferring special nuclear material (SNM).

One

requirement is that SNM may be transferred to any person authorized to

receive such SNM under terms of a specific license or a general license or

their equivalents issued by the Commission or an Agreement State.

U.S.

Ecology license, from the State of Washington, WN-1019-2, license condition

27(k), requires that when waste is labeled with a DOT White I, Yellow II or

Yellow III label a waste classification label should appear next to or in

close proximity to each DOT label . The license condition further requires

,

that when White I, Yellow II or Yellow III labels are required two of the

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specific labels must be displayed on each drum.

Land disposal site

personnel observed that six drums in the LRC-23 shipment displayed two

Yellow II labels.

However, only one waste classification label was affixed

to each of the six drums.

Failure to comply with requirements of the

receiver's license by not affixing the appropriate number of waste

,

classification labels was identified as an apparent violation of 10 CFR

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70.42.

(70-824/85-05-03).

10 CFR 71.87 requires that prior to each shipment of licensed material that

certain requirements be met. These include ensuring that the package is

prope for the contents to be shipped, that the package is in unimpaired

physical condition except for superficial defects such as marks or dents and

that each closure device of the packaging is properly installed and secured

and free of defects.

Six drums marked Fissile Class II in shipment LRC-23 were listed on the

shipping papers as DOT specification 7A Type A packages.

The quantity of

SNM in the six drums ranged from '.7,02 grams (3E-2 milli-curies U-235) to

25.92 grams (SE-2 milli-curies). The inspector reviewed the tests performed

for the 55 gallon drum that was used to meet the DOT specification 7A Type A

requirements. 49 CFR 173.465 specifies the tests that Type A packages must

pass prior to use. Fissile Class II packaging, in addition to other Type A

package tests, requires a free drop from a height of 0.3 meter (1 foot) on

each corner. For cylindrical packagings, the 0.3 meter drop shall be onto

each quarter of each rim.

The test data review indicated that the corner

drop test had not been performed. These drums were part of an exclusive use

shipment in a closed transport vehicle.

These packages were not damaged

during the shipment and no leakage of radioactive material occurred.

Failure to perform the required drop test resulted in use of an improper

package to ship Fissile Class II material. Failure to ship the Fissile

Class II material in a proper package was identified as an apparent

violation of 10 CFR 71.87.

(70-824/85-05-02).

As a part of the decommissioning of the CX-10 reactor at the Lynchburg

Research Center (LRC) the licensee disposed of the reactor's fuel rods by

transfering them to Department of Energy (00E) facilities at Oak Ridge. The

reactor had not been operated above one kilowatt.

The fuel was

approximately 2.5 percent enriched in U-235 and was considered unirradiated

per the 00T definition in 49 CFR 173.403.

LRC transferred the fuel in

containers covered by NRC Certificate of Compliance No. 9069.

LRC refurbished the containers prior to use.

The first shipment of CX-10

fuel arrived at the Oak Ridge National Laboratory (ORNL) on August 21, 1984.

On arrival ORNL personnel discovered a crack in the outer skin of the

outside container just beneath the horizontal weld on one of the lower

ratchet binders. The crack did not affect package integrity.

The ratchet

binder is one of twelve primary closure devices. There are also twelve high

strength latch pins which serve as secondary closure devices.

After

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receiving notification of this crack from ORNL, the licensee reviewed

photographs of the loaded packages taken prior to shipment and observed that

the crack was evident prior to shipment.

The licensee, as corrective

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action, fixed the crack and began performing an extensive receipt inspection

each time the containers arrived back on site and prior to each loading of

fuel for shipment. Failure to ensure that the closure device on a package

of special nuclear material was free of defects prior to shipment was

identified as another example of an apparent violation of 10 CFR 71.87.

(50-013/85-01-01).

5.

Enforcement Conference

An enforcement conference was held on June 27, 1985, to discuss recent

violations concerning the transportation of radioactive material.

The

following persons were in attendance:

(1) Babcock and Wilcox Lynchburg Research Center

T. C. Engelder, Laboratory Director

C. E. Bell, Facility Manager

A. F. Olsen, License Administrator

J. W. Cure, III, Health and Safety Supervisor

(2) Nuclear Regulatory Commission

J. P. Stohr, Director, Division of Radiation Safety and Safeguards

G. Jenkins, Director, Enforcement and Investigation Coordination

D. Collins, Chief, Emergency Preparedness and Radiological

Protection Branch

C. Hosey, Chief, Facilities Radiation Protection Section

E. McAlpine, Chief, Material Control and Accountability Section

J. Kahle, Fuel Facilities Project Manager

R. Albright, Radiation Specialist

During the meeting, licensee personnel presented discussions of their

radioactive material transportation organization, discussions of each

inspection finding and corrective actions.