Information Notice 1999-30, Failure of Double Contingency Based on Administrative Controls Involving Laboratory Sampling and Spectroscopic Analysis of Wet Uranium Waste: Difference between revisions

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{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES


NUCLEAR
NUCLEAR REGULATORY
 
REGULATORY


COMMISSION
COMMISSION


OFFICE
OFFICE OF NUCLEAR MATERIAL


OF NUCLEAR MATERIAL
SAFETY AND SAFEGUARDS
 
SAFETY
 
AND SAFEGUARDS


WASHINGTON,  
WASHINGTON,  
D.C. 20555 November
D.C. 20555 November 8, 1999 NRC INFORMATION
 
8, 1999 NRC INFORMATION
 
NOTICE
 
NO. 99-30:
FAILURE


Of DOUBLE CONTINGENCY BASED
NOTICE NO. 99-30: FAILURE Of DOUBLE CONTINGENCY BASED


ON ADMlNlSTRATlVE
ON ADMlNlSTRATlVE


CONTROLS
CONTROLS INVOLVING
 
INVOLVING


LABORATORY
LABORATORY


SAMPLING
SAMPLING AND SPECTROSCOPIC ANALYSIS OF WET URANIUM
 
AND SPECTROSCOPIC ANALYSIS OF WET URANIUM


WASTE
WASTE
Line 66: Line 49:
to determine uranium
to determine uranium


content, in support
content, in support of administrative criticality safety
 
of administrative criticality safety


controls.
controls.


==Purpose==
==Purpose==
:  
: The U.S. Nuclear Regulatory
The U.S. Nuclear
 
Regulatory


Commission (NRC) is issuing this information
Commission (NRC) is issuing this information


notice
notice to alert addressees
 
to alert addressees


to problems recently noted
to problems recently noted
Line 88: Line 64:
with the laboratory and spectroscopic
with the laboratory and spectroscopic


analysis
analysis of uranium contaminated
 
of uranium
 
contaminated


material.
material.
Line 98: Line 70:
Under certain conditions, incomplete dissolution
Under certain conditions, incomplete dissolution


of samples
of samples may produce a nonconsewative laboratory result and
 
may produce
 
a nonconsewative laboratory result and


lead to violation
lead to violation
Line 108: Line 76:
of criticality safety
of criticality safety


limits.
limits. When the laboratory
 
When the laboratory


sampling
sampling is backed up by spectroscopic analysis, care must be taken to ensure a sufficiently


is backed
precise result through proper
 
up by spectroscopic analysis, care must be taken to ensure
 
a sufficiently
 
precise
 
result through proper


qualification
qualification
Line 130: Line 88:
Recipients
Recipients


are expected
are expected to review this information for applicability
 
to review this information for applicability


to their facilities and consider
to their facilities and consider


actions, as appropriate, to avoid similar problems. Suggestions contained in this
actions, as appropriate, to avoid similar problems. Suggestions contained in this information


information
notice are not NRC requirements. Therefore, no specific action nor written


notice
response is required.
 
are not NRC requirements. Therefore, no specific
 
action nor written
 
response
 
is required.


Descri~tion
Descri~tion


of Circumstances:  
of Circumstances:  
On August
On August 12, 1999, a fuel cycle licensee determined
 
12, 1999, a fuel cycle licensee determined


that a laboratory dissolution process
that a laboratory dissolution process
Line 161: Line 107:
was not completely dissolving the
was not completely dissolving the


uranium
uranium in certain samples, which resulted in underestimating
 
in certain


samples, which resulted
the amount of uranium in wet process waste. Subsequent
 
in underestimating
 
the amount
 
of uranium
 
in wet process waste. Subsequent


licensee gamma spectroscopic
licensee gamma spectroscopic


analysis
analysis of the wet waste also failed to detect the problem, because of inadequate
 
of the wet waste also failed to detect the problem, because of inadequate


spectroscopic
spectroscopic


analysis
analysis conditions.
 
conditions.


Because of these simultaneous failures, excessive uranium was transferred
Because of these simultaneous failures, excessive uranium was transferred


into the wet process
into the wet process waste storage arrays. These deficiencies


waste storage
in sampling and spectroscopic


arrays.
analysis of process waste


These deficiencies
degraded the margin of safety to the
 
in sampling
 
and spectroscopic
 
analysis
 
of process waste
 
degraded
 
the margin
 
of safety to the


extent that a criticality
extent that a criticality


safety
safety limit was violated.
 
limit was violated.
 
IN 99-30 November


8, 1999 Discussion:  
IN 99-30 November 8, 1999 Discussion:  
On July 30, 1999, a fuel
On July 30, 1999, a fuel cycle licensee discovered that a combustible
 
cycle licensee
 
discovered that a
 
combustible


waste bag containing
waste bag containing
Line 232: Line 140:
laboratory
laboratory


filter
filter paper had higher than expected radiation
 
paper had higher
 
than expected
 
radiation


readings.
readings.
Line 246: Line 148:
investigation
investigation


revealed
revealed that the acid leach dissolution process used
 
that the acid leach dissolution process used
 
to prepare
 
samples


for analysis
to prepare samples for analysis of uranium content had not completely dissolved


of uranium
the uranium. When the samples were later filtered during the


content
sample preparation
 
had not completely dissolved
 
the uranium.
 
When the samples
 
were later filtered during the
 
sample
 
preparation


process, some uranium was deposited on the
process, some uranium was deposited on the


filter
filter paper with other solids. The samples in
 
paper with other solids.
 
The samples in


question came from
question came from


a uranium
a uranium recovery process that produced wet solid
 
recovery
 
process that produced wet solid


waste that was collected into
waste that was collected into


5-gallon
5-gallon buckets and stored in
 
buckets and stored in


a safe, single-layer
a safe, single-layer


array.
array. The samples were used to determine
 
The samples
 
were used to determine
 
uranium
 
content
 
before
 
the material
 
was further


collected
uranium content before the material was further collected


into 55-galon
into 55-galon drums. Once the waste was
 
drums.
 
Once the waste was


collected into the 55-gallon drums, the drums
collected into the 55-gallon drums, the drums


were examined
were examined by spectroscopic
 
by spectroscopic
 
analysis
 
before


being stored
analysis before being stored in a safe, triple-layer array.


in a safe, triple-layer array.
The licensee investigation revealed that
 
The licensee
 
investigation revealed that


the 55-gallon drum spectroscopic
the 55-gallon drum spectroscopic
Line 342: Line 188:
analysis was also assigning a
analysis was also assigning a


low value to the uranium
low value to the uranium content of the drums. This was because the drum catibration


content
standard did not adequately


of the drums. This was
resemble the material being


because
counted and the spectroscopic


the drum catibration
analysis did not account
 
standard
 
did not adequately
 
resemble
 
the material being
 
counted and the
 
spectroscopic
 
analysis
 
did not account


for self-shielding
for self-shielding
Line 372: Line 202:
in the drum material.
in the drum material.


The licensee
The licensee had completed
 
had completed


a criticality
a criticality


safety
safety anatysis (CSA) of the tripte-layer


anatysis (CSA) of the tripte-layer
drum storage array to establish safety parameters.


drum storage
The analysis made use of the surface density method to establish
 
array to establish safety parameters.
 
The analysis made use
 
of the surface
 
density
 
method
 
to establish


the maximum uranium content limit for
the maximum uranium content limit for
Line 402: Line 218:
contingency
contingency


for the storage
for the storage array was maintained through sampling of the 5-gallon buckets and
 
array was maintained through sampling of the 5-gallon buckets and


spectroscopic
spectroscopic


analysis of the
analysis of the 55-gallon
 
55-gallon
 
drums.


As a result of
drums. As a result of


these independent and simultaneous failures, drums stored
these independent and simultaneous failures, drums stored in the array exceeded the
 
in the array exceeded the


maximum allowed uranium content
maximum allowed uranium content


for single
for single drums by up to 32%, thereby causing the failure of the double-contingency arrangement.
 
drums by up to 32%, thereby
 
causing
 
the failure
 
of the double-contingency arrangement.


This situation was safety significant in
This situation was safety significant in
Line 440: Line 240:
the total mass
the total mass


involved
involved was far less than
 
was far less than


what would be required for a criticality.
what would be required for a criticality.
Line 450: Line 248:
contributing
contributing


factor
factor in this event was the limited
 
in this event was the limited


scope of the wet waste material
scope of the wet waste material


process
process CSA, which stopped with the material being placed into 5-gallon buckets and did


CSA, which stopped
not overlap the CSA covering the 55-gallon
 
with the material
 
being placed into 5-gallon buckets and did
 
not overlap
 
the CSA covering the 55-gallon


drum storage. Including the
drum storage. Including the


transfer
transfer from 5-gallon buckets to 55-gallon
 
from 5-gallon
 
buckets
 
to 55-gallon
 
drums in the
 
wet waste material
 
CSA should have
 
resulted


in more robust
drums in the wet waste material CSA should have


controls
resulted in more robust controls such as a requirement


such as a requirement
for dual sampling before permitting the
 
for dual sampling
 
before permitting the


transfer.
transfer.
Line 504: Line 274:
contributing
contributing


factor
factor in this event was that the sample processing
 
in this event was that
 
the sample
 
processing


procedures allowed a
procedures allowed a
Line 518: Line 282:
dissolution
dissolution


method
method would produce a substantially
 
would produce
 
a substantially
 
similar


result. The procedure writers mistakenly assumed that the
similar result. The procedure writers mistakenly assumed that the


acid leach dissoiution
acid leach dissoiution


method
method of sample preparation would
 
of sample preparation would


put all uranium into
put all uranium into


solution
solution even if the entire sample
 
even if the entire sample


was not dissolved.
was not dissolved.
Line 552: Line 306:
spectroscopic
spectroscopic


analysis, or require
analysis, or require corrective
 
corrective


action, when spectroscopic
action, when spectroscopic
Line 560: Line 312:
analysis results did
analysis results did


not support
not support laboratory analysis. Spectroscopic
 
laboratory analysis. Spectroscopic


analysis
analysis


IN 99-30 November
IN 99-30 November 8, 1999 of the 55-gallon
 
8, 1999 of the 55-gallon


drums failed to
drums failed to


detect
detect the drums containing


the drums containing
excess uranium due to these
 
excess
 
uranium due to these


failures.
failures.
Line 590: Line 334:
of spectroscopic
of spectroscopic


analysis
analysis sensitivities.
 
sensitivities.


This event highlights
This event highlights
Line 600: Line 342:
for careful review of administrative controls, to ensure that
for careful review of administrative controls, to ensure that


the failure
the failure of such controls is actualty unlikely.
 
of such controls


is actualty
tn addition, CSAs need to be broad enough that the analyst will clearly understand the safety significance
 
unlikely.
 
tn addition, CSAs need to be broad enough
 
that the analyst
 
will clearly understand the safety significance


of proposed controls. All
of proposed controls. All
Line 618: Line 350:
procedures
procedures


having
having an impact on the control need
 
an impact
 
on the control need


to be reviewed carefully
to be reviewed carefully


to ensure
to ensure that the control is


that the control is
actually implemented.
 
actually
 
implemented.


It is expected that addressees
It is expected that addressees
Line 642: Line 366:
applicability
applicability


to licensed
to licensed activities.
 
activities.


This information
This information


notice
notice requires no specific actions nor written
 
requires
 
no specific actions nor written


response.
response.
Line 662: Line 380:
this notice, please contact the technical
this notice, please contact the technical


contact
contact listed below or the appropriate
 
listed
 
below or the appropriate


regionai
regionai office. ck, Ap Dire ~ivi$on of ~uel Cycle Safety and Safeguards


office.
Office of Nuclear Material Safety and Safeguards
 
ck, Ap Dire ~ivi$on
 
of ~uel Cycle Safety and Safeguards
 
Office
 
of Nuclear
 
Material
 
Safety
 
and Safeguards


===Technical Contact:===
===Technical Contact:===
Dennis
Dennis


C. Morey, NMSS 301 -41 5-61 07 E-mail:  
C. Morey, NMSS 301 -41 5-61 07 E-mail: dcm~nrc.gov
dcm~nrc.gov


Attachments:  
Attachments:  
1. List of Recently
1. List of Recently Issued MMSS Information


Issued
Notices 2. List of Recently issued NRG Information
 
MMSS Information
 
Notices
 
2. List of Recently
 
issued
 
NRG Information


Notices
Notices
Line 711: Line 400:
Attachment
Attachment


I IN 99-30 November
I IN 99-30 November 1 1, 1999 LIST OF RECENTLY ISSUED NMSS INFORMATION


1 1, 1999 Page 1 of 1 LIST OF RECENTLY
NOTICES Information


ISSUED
Date of Notice No. Subject Issuance Issued to
 
NMSS INFORMATION
 
NOTICES
 
Information
 
Date of Notice
 
No. Subject
 
Issuance Issued to


99-29 Authorized
99-29 Authorized


Contents
Contents of Spent 10128199 All power reactor licensees
 
of Spent 10128199 All power reactor
 
licensees


and Fuel Casks spent fuel
and Fuel Casks spent fuel


storage
storage licensees
 
licensees


and applicants
and applicants


99-28 Recall
99-28 Recall of Star Brand Fire 913Oig9 Alt holders of licenses for nuclear Protection Sprinkler


of Star Brand Fire 913Oig9 Alt holders
Heads power, research and test reactors, and fuel cycle facilities
 
of licenses for nuclear Protection Sprinkler
 
Heads power, research and test
 
reactors, and fuel cycle facilities


99-27 Malfunction
99-27 Malfunction
Line 764: Line 429:
Teletherapy
Teletherapy


to conduct
to conduct teletherapy
 
teletherapy


treatments Treatment Units
treatments Treatment Units
Line 772: Line 435:
99-26 Safety and
99-26 Safety and


Economic
Economic 8/24/99 All Distributors
 
8/24/99 All Distributors


andlor
andlor Consequences
 
Consequences


of Misleading
of Misleading
Line 790: Line 449:
Information
Information


Licensed
Licensed Products 99-24 Broad-Scope
 
Products
 
99-24 Broad-Scope


Licensees'  
Licensees'  
Line 810: Line 465:
ticensees
ticensees


Sources
Sources and Devices Safety Concerns Related To Repeated Control
 
and Devices
 
Safety
 
Concerns
 
Related
 
To Repeated Control
 
Unit Failures
 
of the Nucletron
 
Ciassic


Model High-Dose-Rate
Unit Failures of the Nucletron


Remote
Ciassic Model High-Dose-Rate


Afterloading
Remote Afterloading


Brachytherapy
Brachytherapy


Devices
Devices ?O CFR 34.43(a)(I):  
 
?O CFR 34.43(a)(I):  
Effective
Effective


Line 849: Line 486:
Contingency
Contingency


Planning
Planning for the 612 519 9 Year 2000 Computer Problem


for the 612 519 9 Year 2000 Computer Problem
Update on NRC's Year 2000 611 4199 Activities for Materials Licensees
 
Update
 
on NRC's Year 2000 611 4199 Activities for Materials Licensees


and Fuel Cycle Licensees
and Fuel Cycle Licensees
Line 867: Line 500:
authorized to use brackytherapy
authorized to use brackytherapy


sources
sources in Nucletron Classic


in Nucletron Classic
Model high-dose-rate ((HDR) remote afterloaders
 
Model high-dose-rate ((HDR)  
remote
 
afterloaders


Industrial Radiography Licensees All material
Industrial Radiography Licensees All material
Line 888: Line 516:
and certificate
and certificate


holders
holders A11 US. Nuclear Regulatory Commission fuel cycle, power
 
A11 US. Nuclear Regulatory Commission fuel cycle, power


reactor, and non-power
reactor, and non-power


reactor
reactor licensees
 
licensees


Attachment
Attachment


2 IN 99-30 November
2 IN 99-30 November 2 I, 1999 Page 1 of l LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES
 
2 I, 1999 Page 1 of l LIST OF RECENTLY
 
ISSUED
 
NRC INFORMATION NOTICES


Information
Information
Line 912: Line 530:
Date of Notice No.
Date of Notice No.


Subject
Subject Issuance Issued to
 
Issuance Issued to


99-29 Authorized
99-29 Authorized


Contents
Contents of Spent 10/28/99 All power reactor licensees
 
of Spent 10/28/99 All power reactor licensees


and Fuel Casks spent fuel storage licensees
and Fuel Casks spent fuel storage licensees
Line 926: Line 540:
and applicants
and applicants


Recall of Star
Recall of Star Brand Fire Protection
 
Brand Fire Protection


Sprinkler
Sprinkler


Heads All holders
Heads All holders of licenses for
 
of licenses for
 
nuclear power, research, and test


reactors, and fuel cyde facilities
nuclear power, research, and test reactors, and fuel cyde facilities


Malfunction of Source
Malfunction of Source
Line 953: Line 561:
Treatment
Treatment


Units Safety
Units Safety and Economic 8/24/99 Consequences of
 
and Economic
 
8/24/99 Consequences of


Misleading
Misleading
Line 976: Line 580:
Unregistered
Unregistered


Sealed
Sealed Sources and Devices Safety Concerns Related
 
Sources
 
and Devices
 
Safety
 
Concerns Related


To 7/6/99 Repeated Control Unit
To 7/6/99 Repeated Control Unit


Failures
Failures of the Nucletron


of the Nucletron
Classic Model High-Dose-Rate


Classic
Remote Aferloading
 
Model High-Dose-Rate
 
Remote
 
Aferloading


Brachytherapy
Brachytherapy


Devices
Devices 10 CFR 34.43{a)(l);  
 
10 CFR 34.43{a)(l);  
Effective
Effective


7/6/99 Date for
7/6/99 Date for Radiographer
 
Radiographer


Certification
Certification
Line 1,019: Line 605:
Discretion All Distributors
Discretion All Distributors


and/or
and/or Manufacturers of Generally


Manufacturers of Generally
Licensed Products All holders of operating


Licensed
licenses for nuclear power plants and fuel cycle facilities


Products
All medical licensees


All holders
of broad- scope and master materials
 
of operating
 
licenses
 
for nuclear
 
power plants and fuel cycle facilities
 
All medical


licensees
licensees


of broad- scope and master
All U.S. NRC medical licensees
 
materials
 
licensees
 
All U.S. NRC medical
 
licensees
 
authorized to use
 
brachytherapy
 
sources
 
in Nudetron
 
Classic


Model high-dose-rate (HDR) remote
authorized to use brachytherapy


afterloaders Industrial Radiography
sources in Nudetron Classic Model high-dose-rate (HDR) remote afterloaders Industrial Radiography


Licensees
Licensees
Line 1,069: Line 627:
OL = Operating
OL = Operating


License
License CP = Construction
 
CP = Construction


Permit
Permit


IN 99-30 November
IN 99-30 November 8, 1999 of the 55-gallon drums failed
 
8, 1999 of the 55-gallon drums failed


to detect the
to detect the
Line 1,083: Line 637:
drums containing
drums containing


excess
excess uranium due to these failures.


uranium
ANSI N15.20-1975 "Guide to Calibrating
 
due to these failures.
 
ANSI N15.20-1975 "Guide
 
to Calibrating


Nondestructive
Nondestructive


Assay Systems"  
Assay Systems" provides a more complete discussion
provides
 
a more complete
 
discussion


of spectroscopic analysis sensitivities.
of spectroscopic analysis sensitivities.
Line 1,112: Line 655:
controls, to ensure
controls, to ensure


that the failure
that the failure of such controls is actually unlikely.
 
of such controls
 
is actually
 
unlikely.


In addition, CSAs need to be broad enough
In addition, CSAs need to be broad enough
Line 1,126: Line 663:
understand
understand


the safety
the safety significance of proposed controls.
 
significance of proposed controls.


All procedures
All procedures
Line 1,140: Line 675:
to ensure that
to ensure that


the control
the control is actually implemented.


is actually
It is expected that addressees will
 
implemented.
 
It is expected
 
that addressees will


evaluate the above information for applicability
evaluate the above information for applicability


to licensed
to licensed activities.
 
activities.


This information notice requires no specific actions nor written
This information notice requires no specific actions nor written
Line 1,160: Line 687:
response.
response.


If you have
If you have any questions about the information in this notice, please contact the
 
any questions about the information in this notice, please contact the


technical contact listed
technical contact listed


below or the
below or the appropriate regional office.
 
appropriate regional office.


Elizabeth
Elizabeth


Q. Ten Eyck, Director
Q. Ten Eyck, Director Division of Fuel Cycle Safety and Safeguards
 
Division
 
of Fuel Cycle Safety


and Safeguards
Office of Nuclear Material


Office
Safety and Safeguards
 
of Nuclear Material
 
Safety
 
and Safeguards


Technical
Technical


Contact:  
Contact: Dennis C. Morey, NMSS 301-415-6107 E-mail: dcm@nrc.gov
Dennis
 
C. Morey, NMSS 301-415-6107 E-mail: dcm@nrc.gov


Attachments:  
Attachments:  
Line 1,200: Line 710:
NMSS Information
NMSS Information


Notices
Notices 2. List of Recently Issued NRC lnformation
 
2. List of Recently
 
Issued
 
NRC lnformation


Notices
Notices FtLE NAME: a:\99-30.in


FtLE NAME: a:\99-30.in
*See ~revious concurrences
 
*See ~revious
 
concurrences


C = COVER E = COVER & ENCLOSURE
C = COVER E = COVER & ENCLOSURE


OFFICIAL
OFFICIAL RECORD COPY N = NO COPY
 
RECORD
 
COPY N = NO COPY


P .: s IN 99-xxx , 1999 It is expected that
P .: s IN 99-xxx , 1999 It is expected that
Line 1,232: Line 728:
for applicability
for applicability


to licensed
to licensed activities.
 
activities.
 
This information notice requires no specific actions nor written response. If you have


any questions
This information notice requires no specific actions nor written response. If you have any questions


about the information
about the information
Line 1,244: Line 736:
in this notice, please
in this notice, please


contact
contact the tdchnical
 
the tdchnical
 
contact


listed below or the
contact listed below or the


appropriate
appropriate


regional
regional office. 1 i i i i r' Elizabeth
 
office.
 
1 i i i i r' Elizabeth


Q. Ten ~~~k, Director Division of Fuel
Q. Ten ~~~k, Director Division of Fuel
Line 1,264: Line 748:
Cyqle Safety and Safeguards
Cyqle Safety and Safeguards


/ Office
/ Office of Nuclear ,Material


of Nuclear ,Material
Safety and safeguards
 
Safety
 
and safeguards


i Technical
i Technical


Contact:  
Contact: Dennis C. Morey, NMSS 301-475-6107 i it E-mail: dcm@nrc.gov
Dennis
 
C. Morey, NMSS 301-475-6107 i it E-mail:  
dcm@nrc.gov


/ i' ,/' Attachments:  
/ i' ,/' Attachments:  
i 1. List of
i 1. List of Recently Issued NMSS
 
Recently Issued NMSS


lnformation
lnformation


~oticed
~oticed 2. List of Recently lssued NRC information
 
2. List of
 
Recently
 
lssued
 
NRC information
 
Notice,$
./ i /' C = COVER ' E = COVER & ENCLOSURE
 
1' OFFICIAL
 
RECORD
 
COPY FILE NAME: a:\fNsiernenl.wpd ,l / C N = NO COPY o FC TECH ED FCOB NAME EKrauss
 
I DMorqh
 
>\'8/pbSM'~ink


DATE 1 199 /!kg9 .A is9 I oi,jigg
Notice,$ ./ i /' C = COVER ' E = COVER & ENCLOSURE


0 FC$B / KK&z?zf
1' OFFICIAL RECORD COPY FILE NAME: a:\fNsiernenl.wpd ,l / C N = NO COPY o FC TECH ED FCOB NAME EKrauss I DMorqh >\'8/pbSM'~ink


KnE! ~$99 1 1~99 I / /' FCOS 6 IMNS}}
DATE 1 199 /!kg9 .A is9 I oi,jigg 0 FC$B / KK&z?zf KnE! ~$99 1 1~99 I / /' FCOS 6 IMNS}}


{{Information notice-Nav}}
{{Information notice-Nav}}

Revision as of 22:20, 5 July 2018

Failure of Double Contingency Based on Administrative Controls Involving Laboratory Sampling and Spectroscopic Analysis of Wet Uranium Waste
ML993060157
Person / Time
Issue date: 11/08/1999
From: TenEyck E Q
NRC/NMSS/FCSS
To:
Ten-Eyck E Q
References
IN-99-030
Download: ML993060157 (7)
v • d • e


UNITED STATES

NUCLEAR REGULATORY

COMMISSION

OFFICE OF NUCLEAR MATERIAL

SAFETY AND SAFEGUARDS

WASHINGTON,

D.C. 20555 November 8, 1999 NRC INFORMATION

NOTICE NO. 99-30: FAILURE Of DOUBLE CONTINGENCY BASED

ON ADMlNlSTRATlVE

CONTROLS INVOLVING

LABORATORY

SAMPLING AND SPECTROSCOPIC ANALYSIS OF WET URANIUM

WASTE

Addressees

All fuel cycle licensees

and certificants

performing laboratory analysis

to determine uranium

content, in support of administrative criticality safety

controls.

Purpose

The U.S. Nuclear Regulatory

Commission (NRC) is issuing this information

notice to alert addressees

to problems recently noted

with the laboratory and spectroscopic

analysis of uranium contaminated

material.

Under certain conditions, incomplete dissolution

of samples may produce a nonconsewative laboratory result and

lead to violation

of criticality safety

limits. When the laboratory

sampling is backed up by spectroscopic analysis, care must be taken to ensure a sufficiently

precise result through proper

qualification

of the spectroscopic method.

Recipients

are expected to review this information for applicability

to their facilities and consider

actions, as appropriate, to avoid similar problems. Suggestions contained in this information

notice are not NRC requirements. Therefore, no specific action nor written

response is required.

Descri~tion

of Circumstances:

On August 12, 1999, a fuel cycle licensee determined

that a laboratory dissolution process

was not completely dissolving the

uranium in certain samples, which resulted in underestimating

the amount of uranium in wet process waste. Subsequent

licensee gamma spectroscopic

analysis of the wet waste also failed to detect the problem, because of inadequate

spectroscopic

analysis conditions.

Because of these simultaneous failures, excessive uranium was transferred

into the wet process waste storage arrays. These deficiencies

in sampling and spectroscopic

analysis of process waste

degraded the margin of safety to the

extent that a criticality

safety limit was violated.

IN 99-30 November 8, 1999 Discussion:

On July 30, 1999, a fuel cycle licensee discovered that a combustible

waste bag containing

laboratory

filter paper had higher than expected radiation

readings.

A subsequent licensee

investigation

revealed that the acid leach dissolution process used

to prepare samples for analysis of uranium content had not completely dissolved

the uranium. When the samples were later filtered during the

sample preparation

process, some uranium was deposited on the

filter paper with other solids. The samples in

question came from

a uranium recovery process that produced wet solid

waste that was collected into

5-gallon buckets and stored in

a safe, single-layer

array. The samples were used to determine

uranium content before the material was further collected

into 55-galon drums. Once the waste was

collected into the 55-gallon drums, the drums

were examined by spectroscopic

analysis before being stored in a safe, triple-layer array.

The licensee investigation revealed that

the 55-gallon drum spectroscopic

analysis was also assigning a

low value to the uranium content of the drums. This was because the drum catibration

standard did not adequately

resemble the material being

counted and the spectroscopic

analysis did not account

for self-shielding

in the drum material.

The licensee had completed

a criticality

safety anatysis (CSA) of the tripte-layer

drum storage array to establish safety parameters.

The analysis made use of the surface density method to establish

the maximum uranium content limit for

individual drums. Double

contingency

for the storage array was maintained through sampling of the 5-gallon buckets and

spectroscopic

analysis of the 55-gallon

drums. As a result of

these independent and simultaneous failures, drums stored in the array exceeded the

maximum allowed uranium content

for single drums by up to 32%, thereby causing the failure of the double-contingency arrangement.

This situation was safety significant in

that no controls remained to

limit the mass in the array, although

the total mass

involved was far less than

what would be required for a criticality.

An important

contributing

factor in this event was the limited

scope of the wet waste material

process CSA, which stopped with the material being placed into 5-gallon buckets and did

not overlap the CSA covering the 55-gallon

drum storage. Including the

transfer from 5-gallon buckets to 55-gallon

drums in the wet waste material CSA should have

resulted in more robust controls such as a requirement

for dual sampling before permitting the

transfer.

An additional

important

contributing

factor in this event was that the sample processing

procedures allowed a

choice of dissolution methods under the assumption that either

dissolution

method would produce a substantially

similar result. The procedure writers mistakenly assumed that the

acid leach dissoiution

method of sample preparation would

put all uranium into

solution even if the entire sample

was not dissolved.

Finally, the spectroscopic analysis

procedures

did not qualify waste streams

for spectroscopic analysis, ensure optimal packaging for

spectroscopic

analysis, or require corrective

action, when spectroscopic

analysis results did

not support laboratory analysis. Spectroscopic

analysis

IN 99-30 November 8, 1999 of the 55-gallon

drums failed to

detect the drums containing

excess uranium due to these

failures.

ANSI N15.20-1975 "Guide to

Calibrating Nondestructive Assay Systems" provides

a more complete discussion

of spectroscopic

analysis sensitivities.

This event highlights

the necessity

for careful review of administrative controls, to ensure that

the failure of such controls is actualty unlikely.

tn addition, CSAs need to be broad enough that the analyst will clearly understand the safety significance

of proposed controls. All

procedures

having an impact on the control need

to be reviewed carefully

to ensure that the control is

actually implemented.

It is expected that addressees

will evaluate the

above information for

applicability

to licensed activities.

This information

notice requires no specific actions nor written

response.

If you have any questions

about the information in

this notice, please contact the technical

contact listed below or the appropriate

regionai office. ck, Ap Dire ~ivi$on of ~uel Cycle Safety and Safeguards

Office of Nuclear Material Safety and Safeguards

Technical Contact:

Dennis

C. Morey, NMSS 301 -41 5-61 07 E-mail: dcm~nrc.gov

Attachments:

1. List of Recently Issued MMSS Information

Notices 2. List of Recently issued NRG Information

Notices

Attachment

I IN 99-30 November 1 1, 1999 LIST OF RECENTLY ISSUED NMSS INFORMATION

NOTICES Information

Date of Notice No. Subject Issuance Issued to

99-29 Authorized

Contents of Spent 10128199 All power reactor licensees

and Fuel Casks spent fuel

storage licensees

and applicants

99-28 Recall of Star Brand Fire 913Oig9 Alt holders of licenses for nuclear Protection Sprinkler

Heads power, research and test reactors, and fuel cycle facilities

99-27 Malfunction

of Source Retraction

9/2/99 All medical licensees authorized

Mechanism in Cobalt-60

Teletherapy

to conduct teletherapy

treatments Treatment Units

99-26 Safety and

Economic 8/24/99 All Distributors

andlor Consequences

of Misleading

Manufacturers

of Generally

Marketing

Information

Licensed Products 99-24 Broad-Scope

Licensees'

711 2/99 All medical

licensees'

of broad- Responsibilities

for Reviewing

and scope and master materials

Approving Unregistered Sealed

ticensees

Sources and Devices Safety Concerns Related To Repeated Control

Unit Failures of the Nucletron

Ciassic Model High-Dose-Rate

Remote Afterloading

Brachytherapy

Devices ?O CFR 34.43(a)(I):

Effective

6/25/99 Date for Radiographer Certification

and Plans for Enforcement

Discretion

Contingency

Planning for the 612 519 9 Year 2000 Computer Problem

Update on NRC's Year 2000 611 4199 Activities for Materials Licensees

and Fuel Cycle Licensees

and Certificate Holders Federal Bureau of Investigation's

5/28/99 Nuclear Site Security Program

All U.S. NRC medical licensees

authorized to use brackytherapy

sources in Nucletron Classic

Model high-dose-rate ((HDR) remote afterloaders

Industrial Radiography Licensees All material

and fuel cycle licensees

and certificate holders

All material and fuel cycle

licensees

and certificate

holders A11 US. Nuclear Regulatory Commission fuel cycle, power

reactor, and non-power

reactor licensees

Attachment

2 IN 99-30 November 2 I, 1999 Page 1 of l LIST OF RECENTLY ISSUED NRC INFORMATION NOTICES

Information

Date of Notice No.

Subject Issuance Issued to

99-29 Authorized

Contents of Spent 10/28/99 All power reactor licensees

and Fuel Casks spent fuel storage licensees

and applicants

Recall of Star Brand Fire Protection

Sprinkler

Heads All holders of licenses for

nuclear power, research, and test reactors, and fuel cyde facilities

Malfunction of Source

Retraction

9/2/99 All medical licensees authorized Mechanism in

Cobalt-60

Teletherapy

to conduct teletherapy treatments

Treatment

Units Safety and Economic 8/24/99 Consequences of

Misleading

Marketing

Information Year 2000 Contingency Planning

8/10/99 Activities

Broad-Scope

Licensees'

7/2 2/99 Responsibilities for Reviewing

and Approving

Unregistered

Sealed Sources and Devices Safety Concerns Related

To 7/6/99 Repeated Control Unit

Failures of the Nucletron

Classic Model High-Dose-Rate

Remote Aferloading

Brachytherapy

Devices 10 CFR 34.43{a)(l);

Effective

7/6/99 Date for Radiographer

Certification

and Plans for

Enforcement

Discretion All Distributors

and/or Manufacturers of Generally

Licensed Products All holders of operating

licenses for nuclear power plants and fuel cycle facilities

All medical licensees

of broad- scope and master materials

licensees

All U.S. NRC medical licensees

authorized to use brachytherapy

sources in Nudetron Classic Model high-dose-rate (HDR) remote afterloaders Industrial Radiography

Licensees

OL = Operating

License CP = Construction

Permit

IN 99-30 November 8, 1999 of the 55-gallon drums failed

to detect the

drums containing

excess uranium due to these failures.

ANSI N15.20-1975 "Guide to Calibrating

Nondestructive

Assay Systems" provides a more complete discussion

of spectroscopic analysis sensitivities.

This event highlights the

necessity for careful review of

administrative

controls, to ensure

that the failure of such controls is actually unlikely.

In addition, CSAs need to be broad enough

that the analyst will clearly

understand

the safety significance of proposed controls.

All procedures

having an impact

on the control need

to be reviewed carefully

to ensure that

the control is actually implemented.

It is expected that addressees will

evaluate the above information for applicability

to licensed activities.

This information notice requires no specific actions nor written

response.

If you have any questions about the information in this notice, please contact the

technical contact listed

below or the appropriate regional office.

Elizabeth

Q. Ten Eyck, Director Division of Fuel Cycle Safety and Safeguards

Office of Nuclear Material

Safety and Safeguards

Technical

Contact: Dennis C. Morey, NMSS 301-415-6107 E-mail: dcm@nrc.gov

Attachments:

1. List of Recently Issued

NMSS Information

Notices 2. List of Recently Issued NRC lnformation

Notices FtLE NAME: a:\99-30.in

  • See ~revious concurrences

C = COVER E = COVER & ENCLOSURE

OFFICIAL RECORD COPY N = NO COPY

P .: s IN 99-xxx , 1999 It is expected that

addressees will evaluate the

above information

for applicability

to licensed activities.

This information notice requires no specific actions nor written response. If you have any questions

about the information

in this notice, please

contact the tdchnical

contact listed below or the

appropriate

regional office. 1 i i i i r' Elizabeth

Q. Ten ~~~k, Director Division of Fuel

Cyqle Safety and Safeguards

/ Office of Nuclear ,Material

Safety and safeguards

i Technical

Contact: Dennis C. Morey, NMSS 301-475-6107 i it E-mail: dcm@nrc.gov

/ i' ,/' Attachments:

i 1. List of Recently Issued NMSS

lnformation

~oticed 2. List of Recently lssued NRC information

Notice,$ ./ i /' C = COVER ' E = COVER & ENCLOSURE

1' OFFICIAL RECORD COPY FILE NAME: a:\fNsiernenl.wpd ,l / C N = NO COPY o FC TECH ED FCOB NAME EKrauss I DMorqh >\'8/pbSM'~ink

DATE 1 199 /!kg9 .A is9 I oi,jigg 0 FC$B / KK&z?zf KnE! ~$99 1 1~99 I / /' FCOS 6 IMNS


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