ML19037A271

NRC-2018-000571 - Resp 2 - Final, Agency Records Subject to the Request Are Enclosed - Released Version

ML19037A271
Person / Time
Issue date:	02/01/2019
From:	NRC/OCIO
To:
Shared Package
ML19037A273	List: ML19037A271 ML19037A272
References
FOIA, NRC-2018-000571
Download: ML19037A271 (102)

Text

Received !(b )(7)(C) I Entered 07/16/2013 Closed 10/21/4 0 13 CLOSED CASE CHRONOLOGY I Total Da r, f O pe 11 Rll-2013-A-0100 I CONCERN I ACTION I PERSON I NO. NO. ASSIGNED N on Respons i ve Record DATE I ASSIGNED DATE I DUE DATE I COMPLETE 104 DAYS TO COMPLETE Wednesd(ly, November 06 , 2 013 Page 1 of 3 Received!(b )(7)(C) I En te red 07/16/2013 Clos e d 1 0/21/20 1 3 CONCERN I ACTION NO. _ NO. 2 5 4 3 2 l 1 I CLOS E D CASE CHRO N OLOGY I T o tal D av s O pe 11 Rll-2013-A-0100 I PERSON ASSIGNED HICKE Y Sta t us L ett er HICKEY Revi e w S ubmitt a l DA TE A SSIGNED 10/03/2013 09/30/2013 DATE D U E 10/30/2013 10/30/2013 DATE COMPLETE 10/21/2013 10/03/2013 1 0 4 DAYS TO COMPLETE 18 3 Review the Ucensee response, complete an RF/ checklist and prepare closure documentation as appropriate. HICKEY 08/01/2013 09/30/2013 09/27/20 1 3 57 R e sponse to Referral On 8/23 Uc called to request a 30 day extension to respond to allegation R/1-201 3-A-0100. The licensee reported that many of the records requiring review are 30 years old so the process for locating, obtaining and reviewing will be very time consuming.

The licensee infonned that they have a letter in route to the NRG making the request and including the circumstances involved.

The licensee r e quest for 30 day extension was granted. HI C KE Y 08/01/2013 08/15/2013 08/02/20 1 3 1 Lic e n s e e RFI Ca llba c lc HICKE Y Ref er ral Letter RF/ 07/23/2013 08/06/2013 08/01/20 1 3 9 N o n Respo n sive Re c o rd W e dn e s d a y, Nove mb e r 06 , 2 013 Page 2 of 3 Received !(b )(7)(C I Entered 07/16/2013 Closed 10/21/2013 CLOSED CASE CHRONOLOGY I Total Dal's O pe n Rll-2013-A-0100 I CONCERN I ACTION I PERSON I NO. NO. ASSIGNED DATE I ASSIGNED Non Respons i ve Record DATE I DUE DATE I COMPLETE 1()4 DAYS TO I COMPLETE Wednesd ay , November 06, 2013 Page 3 of 3 N o n Respo n s i v e Reco r d INDEX OF CONCERNS I Wednesday, November 06, 2013 Rll-2013-A-0100 I Page 1 of 3 INDEX OF CONCERNS I Rll-2013-A-0100 I We dnesday, Nov e mber 06 , 2013 CONCERN: 2 Training/Qual ifi ca ti ons Fuel F a c ility Forme r licens e e Employ e e NMSS )"toR KFP , DID N OT RECEIVE PROP E R TRAINING OR PROTECTION WHI L E HANDUN d"'" (,.;.;b.1.)( ... 4~)----i I (b )( 4) _ FROM RUSSIA TO BE CONVERTED INTO UF6. SUBSTANTIATED

L N I ENF: N o EA NO~ OT CLSD: 10/21/2013 Response to Concern: (b)l4) . The ore concentrates a r e sti ll , howe v er, c l assified a \b)(4) ~iµu.,~u.1:.¥JS:.Ja1,'ed records and interviewed personnel and determined that the ore co n cen t rates fro m t h e ffl""i'~ ...... --.,_ _ __, do not require additional worker training or safety measures to ensure proper handl i ng. As ..._ ___ __, , the activity concen t rations of ore concentrates from the former Soviet repu b lics remain be l ow l e v e l s t hat would warrant additional t raining or safety measures beyond those already in place at MTW. Conc l usion: The NRC has not observed an roblems wi t h Hone ell?s wor k ers r eceivin ro e r training or protection wh il e ha n dling i.;.{b..:.l(;...4J~-------------------------

The NRC inspec t o r was unable to substa n tia t e the concern. No n R espons i ve R eco r d Page 2 of 3 Non Responsive Record INDEX OF CONCERNS I Wednesday, November 06 , 2013 Rll-2013-A-0100 I Page 3 of 3 REGION II ALLEGATION RECEIPT FORM Allegation Number: Rll-2013-A-0100

• <b J(?J(CJ I Date Rece i ved: I r Received By; Nicholas P eterka Allegation Received V i a: D T elephone l:8l In person 0Email D Letter D 01 Trans c ript# Prepa r ed B y: N icholas Peterka Is there a otential overrldin Note: (b)(?)(C Non Responsi v e Re c ord l Concern #: 2 Facility: Honeywell 0 Fax Docket No: 40-3392 0 DOL Complaint Date Prepared:

7/11/2013 N Concern Descr ip t i on: l (b)(4 l I Workers did not receive proper tra i ning or protection while handling from Russia to be converted into UF6. .._ _______ _. Concern Back g round Information

The Cls stated that workers were exposed to!(b J(4 J !when they began process i ng drums of materia l from Russia. The Cls stated they did not r ece i ved additiona l training or per.sonal p r otect io n equipment to handle the (b J(4 J (T he followin g i nformat i on is supp l ementa l t o the concern) I n addition , the Cls stated due to the (b J(4 J war ers were told to only dump one drum per shift. Did the alleger raise t he concern to managem e nt? Unknown If so, what actions have been taken , and when? I f no why not?* Commen t s: T h i s s p ecific alleg at ion was taken j'b)(7)(G) ! an d the i ndividual stated that he had to l e a ve. Th i s quest io n was not asked. _________

.... Non Responsi v e Re c ord No n Responsive Reco r d Alie er's lnforma

• Allegation Source: fb)(7 J(C) Alleger's Name: [8J..,.M.,..r-. _..,.....s _____ ..., Alleger's Employer: NA A Alleger's Home Address: (b)(7)(C)

,,;;,,.-.~.,..,,.,.-

....... .....--,....,.

..... --------'

Home Phone Number b 7 C Work Phone Numbe r. Email Address: NA Preferences for method and time of contact: Method: D Letter OEmall [81 Telephone

-Which number?!(b)(7)(C)

I Alleger's Information

-Cl#2 Allegation Source: Former Lic~nsee Empiov;e Alleger's Name: [81 Mr. D Ms.((b)(7)(C)

_ Cell Phone Numb er: NA T i me: DAM 0PM Allege r's Employer: NA ..,.,..,~~w' !U!rui.l.lll9DLJJW W:s.B. ______ _ Alleger's Home Address: (b)(7)(C)

Home Phone Number*r.(~b)~(7~)~(C~)----n=l".""Fl

=~==~n"ll"---,"'"="'""":"".!one Number: NA Email Address: NA Preferences for method and time of contact: Method: D Letter D Email ~(b)(?)(C)

[81 Telephone

-Which numbe, , .... ____ _. j Identity Protection Policy/Confidentiality Was the alle er Informed of ID Protection Policy?: No Comments:

(b)(7)(C J (b)(4) Was Confidentiality Comments:

NA I RFI Considerations Alleger Ob'ects to RFI?: No * (b)(4) Is the alleger concerne a out eing I entified to the licensee?:

N o If so , why? Does the alleger object to having his/her ident i ty re l eased?: No If so , why? T i me: DAM 0PM I Discrimination/

Harassment

& Intimidation (H&I) -to be discussed onl y if the alle g er brin g s it up Is the alleger asserting discrimination (i.e. alleged retaliation for raising a safety concern)?: No Was alleger informed of DOL rights?: No J No further contact requests -to be discussed onl y If the alle g er brin g s It up Did the alleger request no further contact with the NRC?: N o We r e th e benefit s of con t inu ed process i n volvement discu s se d?: S e lec t *If more than 3 concerns were received, please fill out a separate form. Only the concern section needs to be completed.

ALLEGATION REVIEW BOARD

SUMMARY

Tuesday , July 23 , 20 1 3 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Allega ti on Numbe r: Rll-201 3-A-0100 ARB Type: I niti a l Facility: H oneywell ARB Date: 7/16/2013 Responsible Branch: D F F I/FF B 2 ARB Purpose: T n ... ,ine co u rse of action *(b)(7)(CJ I (b)l7)(C) Rec e ived p a~e~ I Allegat i on Source: I I 3 0-D ays = (b J{ l< T otal# Co n cerns: 4 1 5 0-D a ys 180-Da ys Non Respons i ve Record ALLEGATION REVIEW BOARD

SUMMARY

Tuesday , July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Estimated Completion T i me: 14 DA YS Concern#: 2 Concern Type: Allegat i on Discipline:

Select Training/Qualifications

{Se lect Only One) Concern Description

l (b J(4 J WORKERS DID NOT RECEIVE PROPER TRAINING OR PROTECTION WHILE HANDLING..__ __ (b)(4) Follow-Up ARB Input: (if applicab le) Safety Impact and Applicable Regulation

Safety Significance

Low Describe potential safety Impact , assuming concern is true: Potential exposure to workers not accounted for and exposure records no t documented. Applica.ble Reg~lat~on

. J C b J(?J(C) When did potentia l v1olat1on occur (date)?!,_ __ _, Concern Disposition Method/Branch Input and Comments: 0 Transfer to: (NRC Internal Exchange to another region/NRR/NMSS , etc.) 181 Request for Additional Information (RFI): Le tter to licensee for additional information. Branch to rev i ew the l icensee re spo n se to the RFI: 0 Provide to Licensee for Information Only: 0 Referral to Select : 0 Inspection Follow-Up: (P rovide i nformation on what is to be I nspe ct ed , inspect i on schedule , etc.) 0 ADR: (For discrimination c ases. after prima facie has been established) 0 Office of Investigations (01): (P rovi d e draft NOV to Allegations Office) D Too General/Need More Details: (Pro vide recommendation, e.g. Inspector contact alleger for details , etc.) D Closure in acknowledgment letter: D Closure Lett er or Memo to File: D Other: Specify recommendation (e.g. Con tact licensee , chilling effect letter etc.) D EICS Close FIie Administratively:

Prompt notification of SRI/RI o r region-based inspector requ i red: A l ready No tified Re lated previous allegation number: N IA [81 Related 01 Case Numb er: N I A [81 Is this a response after closure?:

Select To be filled out at the ARB ARB Assigned Actions: RFI Assigned Bra nch/Individua l: DFF I/FFB 2 Estimated Complet ion Time: 14 DAYS ALLEGATION REVIEW BOARD

SUMMARY

Tuesday, July 23, 2013 ARB MINUTES ARE REVJEWEO AND APPROVED BY THE ARB CHAJR AT THE ARB I\Jon Responsive Record ALLEGAT I ON REVIEW BOARD

SUMMARY

Tuesday , July 23, 2013 ARB MINUTES ARE REVIEWED AND APPROVED BY THE ARB CHAIR AT THE ARB Non Respons i ve Re c o r d RF1 Considerations Applicable Concern(s): 4 Does the concern(s) present an Overriding Safety Issue? Y O N (gi If yes, an RFI. will nonnally be issued to the licensee (verb ally fi r st, then in writing) Notes/Comments

Conditions I n hib i ting RFI: D Will compromise alleger identity protection D Will compromise investigation or i nspection D Against management that would r ev i ew RFI 0 Fed or State agency disapproves of RFI Other RFI Considerat i ons ff Inhibiting Condit i ons Do Not A pp ly D Release co uld bring harm to alleger. Describe: D Alleger Objects to RFI. Describe: D Alleger ob j ects to re l easing th e ir ide ntity in RFI , when necessary for adequate follow-up. Describe: D Alleger i s concerned about be i ng i dentified to the licensee.

Descr ib e: D Alleger has ra i sed concern to licensee w/ unsat i sfactory results. Describe: D Recent NRG concerns w/ licensee RFI responses. Describe: Other Items Potentiall y Affecting RFI Response Qualit y: 0 Recent Inspect i on findings?

Las t P l&R? Describe: I AL L EGATION REVIEW BOARD SUMMA R Y Tuesday , July 23 , 2013 ARB M I NUTES ARE REVIEWED AND APPROVED BY T HE ARB CHAIR AT THE ARB D Substan t ive Cross-Cutting I ssue? Describe: D Allegation h i sto r y issues? Describe: D Licensee policy/process issues? D escribe: D Resource issues? Describe: D Other? Describe: ts RFI an Acc e ptab le Opt i o n? Y 15<1 N O Summarize mason; Both Cls do not object , o an RFI nor t o b eing identified t o t h e lic e nsee. 1 ... (b-l(7-l(_c i ________________

__.J I ARB Attend e e s Chairs: C. CHRISTENSE N , W J ONES , T. GODY EICS: 0. D EMI RANDA, M. C H ECKLE, A ALLEN 01: H b )(7)(C) I OGC/Co u nsel: C. EVA N S Br anch Chiefs: J. HICKEY O t her Attendees:

J. DODSON, R. PATTE R SON , L HA L L , J. BROWN CHECKLIST FOR NRC STAFF REVIEW OF LICENSEE RESPONSE TO AN ALLEGATION REQUEST FOR INFORMATION The purpose of this checklist is to assis t the staff i n eval u ating the adequacy of a lice nsee's response to an allegation Request for Information (RFI), independently verifying aspects of the information provided by the licensee , and t o support the development of the p ro posed basis f or a dditiona l staff actions if i t is determined that the licensee's resp onse i s inadequate, inaccura t e, or otherwise una cce ptable. Note: Th e term " licensee" in the work sh eet r efe r s to any NRC licensee , certificate holder , license o r certificate appl i ca n t, o r vendor that may be the subject of an allegation concern. ALLEGATION NUMBER: Rll-2013-A-0 100 AFFECTED CONCERN($):

Concerns 1 -4 FACILITY: H oneywell A: Determining the Adequacy of the L i censee=s Response to an Allegation RFI N ote: Yes" answers normally i ndi cate that the licensee's res ponse to an RFI is adequate, while "No" answers indicate addi tional action may be necessary.

Eva l uator Independence Yes [8J No O Does the r elationship between the i nd ividua l (s) chosen by the licensee to evaluate the concem(s) and the concern(s) being evaluated allow for appropriate objectivity (e.g., thir.d party or interna l evaluator, but not i n the same management chain as those in volve d in concern(s))?

No te: Use best judgmen t for sm aller organizations when c lea r manageme n t c h ain i ndependence may not be possible. Comments: T he Independent Investigator is an outside counsel. Evaluator Competence Yes~ No D Based on the inform ation provided, is the evalua t o r competent in related functional area? C , t)J , ,, c , omments: He has (0 1 711( De pt h and Scope of E valuation Yes [8J N o D Yes~ NoD Yes 1:8:J No D Are all R Fl-related concerns addressed?

I s the evaluation rigor co mmensurate wi th the level o f concern detail prov ided? F or example, if appropriate, d i d evaluation include extent of condition review, root/apparent cause assessment, or generic considerations?

Are the conclusions pr ovided b y the licensee supported by the evaluation?

Yes t8J No D Are all affected personnel/groups/departments considered in the evaluation?

For examp l e, if interviews were conducted, did the licensee describe the basis for the number and cross section of individuals interviewed and is bas i s adequate?

Were the i nterv i ew questions appropriate?

Yes t8J No D N/A D If the NRC asked add i tional specific questions, are they answered satisfactorily?

Yes t8J No D N/A D If the names of specific individuals were referenced in the RFI, did the l icensee contact those individuals and/or appropr i ately consider their i nvolvement i n the allegation concern? Yes~ No D NIA D If specific documentation was refe renced in the RF I, did the licensee evaluate that documentation and/or appropriately consider it in the evaluation of the allegation concern? Yes~ No D N/A D If the l ic ensee reviewed a samp l e of related documentation and/or potent ially affected structures, systems , and components, d i d the licensee describe the samp l e and provide the bas i s for determining that the sample size was appropriately representative?

Comments:

__ Effectiveness of Corrective Actions YesO NoO N/A181 Yes D NoO N/A181 Yes D No D N/A 181 Yes D No D N/A t8J Comments:

__ If applicable, were appropriate immediate corrective actions taken by the licensee?

If applicable , were operability and reportability determinations appropriate?

If applicable, were appropriate corrective act i ons proposed?

I f applicable, were i ssues entered into the correct i ve act i on program? NRC Violations (substantiated concerns on l y) Yes D No D N/A 181 If the substantiated concern represents a violation, did the licensee appropriately acknowledge and articulate the violation in response to the RF I? Comments:

__ B: NRC Independent Review Effort NRC staff evaluating lice nsee RFI response should attempt to independently validate aspects of the information provided by the licensee.

Indicate any of the following that apply: D Additional questions posed to the licensee.

D Performed or coordinated an independent inspection or technical review activity to ver i fy a condit i on i ndicated in the response.

D Reviewed the results of recently conducted NRC inspections in the funct i onal area related to the allegation concerns.

181 Verified the existence and applicability of technical references noted in the response.

D Verified the existence and applicabil i ty of procedures referenced in the response. Ensured revision number referenced is appropriate.

D Verified the existence and content of corrective action program documentation referenced in the response. D Checked calculations noted in the response.

D Other. Describe:

--Comments: --C: CONCLUSION

[81 Adequate RFI Response D Inadequate RFI Response Basis: The li censee has an adequate r esponse to the requested information in the RFI. Note: Notify the responsible Branch Ch i e f and the OAC of the results of this review. PREPARED BY: R-~r; <J;j BRANCH CHIEF: r DATE PREPARED:

10/2/2013 DATE REVIEWED:

1PJk~/ 3 Performance Materials a nd Technologies Honeywe ll P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 September 27 , 2013 CERTIFIED 7010 0290 0001 5998 0229 Mr. Oscar DeMiranda Senior Allegation Coordinator , EICS Office of the Regional Adminis tr ator , Region II U.S. Nuclear Regulatory Comm i ssion P.O. Box 56274 Atlanta , GA 30343 Docket No. 40-3392 License No. SUB-526 RE: HONEYWELL METROPOLIS WORKS' RESPONSE TO ALLEGATION NO. Rll-2013-A-0100 Honeywell This l etter forwards the report of the i nvestiga ti on performe d by an Independent Investigator to eva l uate the concerns i dentified in the NRC's August 1 , 2013 letter transmitting Allegation Rll-2013-A--0100. The Independent Invest i gator is outside counsel from Winston & St r awn L L P. with more th an t en years of experience in nuclear regulatory matters. Upon evaluating the concerns set forth i n the NRC's letter , Honeywell determined that it needed additional time to fina liz e the i nvestigation , and requested that the reply date be extended to 60 days from the da t e of t he NRC's letter. Th i s extension was granted by you via telephone on August 23 , 2013 , and docume n ted in Honeywell's letter to Mr. James A Hickey on that same date. The Independent Invest i gator found that the four concerns in the Alleo::1tionwere unsubstantiated.

Spec i fically: (1 I Non Responsi v e Record I Non Responsi v e Record 1 (2) While m aterial from l<bl 14 l I (b)(4) aaamonal training and protections are no t warranted; (3 J Non Responsive Record Non Responsive Record Non Responsive Record I and ( 4 )j Noo Responsive Record I Non Re s ponsive Recorct Supporting documenta ti on is attached t o the Independent Investigator

's report. MTW intends t o ensure that a ll concerns expressed by MTW employees and contractors are received and resolved i n an effort to continue to improve our safety and performance.

Enclosures 2

Honeywell M etropolis W orks (MTW) Review of Nuclear Regulatory Commission (NRC) Allegation N o. Rll-2013-A-0100 Dated August 1, 2013 Inde p endent Investi g ator 1-Outside Counsel (Winston & Strawn LLP) Washington , DC September 27, 2013 1 BACKGROUND By letter dated August 1 , 2013 , 1 the U.S. Nuclear Regulatory Commission (NRG) forwarded to Honeywell International Inc. (Honeywell) four concerns r egarding activ i ties at the Honeywell Metropolis Works (MTW) facility in Metropolis , Illinois.

The NRG requested that Honeywell evaluate the information described i n the letter's enclosure and provide the results to the NRG RII Allegations Coordinator.

Th i s report presents the results of an independent investigat i on of the concerns forwarded by t he NRG. ISSUES INVESTIGATED Non Responsive Record Concern 2: (b)(4) Did the material from Russia hflve ._!'b...,, 1 (4 ... ) ----'~ And if so , did it require additional training to ensure proper hand li ng? Non Respons i ve Reco r d INVESTIGATION APPROACH (t,)(7/(CJ These allegations we r e evaluated by an i ndependent inve.,;s:;..t.,.i ,;;a ... to_r..._ ____ __......__......J

{b)(7)(C. is outs i de counsel from Winston & Strawn LLP. (b)(7){Cl (b)(7J(Cj Letter , J. Hickey to f bl(?l(C) l. " Allegation No. Rll-2013-A-0100

," Aug. 1 , 2013. The enclosure is marked as .. ~, et fe'er P1,1eliG Oi~c l o&* 4i " 2 l (b)f7l(C) matters .. (b)(7}(C !(b)(7)(C)

He h as a l The i nvestigation began w i th a review of current and historical documents relevant to the concerns identified by the NRG. The invest l gator also obtained MTW procedures relating to the issues addressed in th i s report. The relevant documents rev i ewed by the investigator are listed for each concern. In addition J bJ(T)(s, !questioned subject matter experts at MTW , also identified below , who had knowledge of events or respons i bilities in functional areas relevant to the concerns. From the review o f the or i ginal concerns , the documents identified during the i nvestigation, and the interviews with subject matte r experts. the investigator assembled a list of inc i dents or examples that are encompassed by the concerns. The investigator evaluated each i nc i dent or example to the extent prac ti cable given the nature of the matter , and also evaluated the overall timeline in assessing the overarching issues r aised i n the allegations. FINDINGS OF FACT Non Responsi v e Rec or d 3 Non Respons i ve Re c o r t1 4 Non Responsive Record No n Respo n sive Record Concern 2 -Unsubstantiated The investigator reviewed the requirements of NRC l i cense SUB-526 issued to Hone well for the MTW facilit and obtained information and documentation re ardin (b)(4 J The investigator also interv i ewed l(bl(T!(C1 I the MTW (blC 7 HCl , to obtain back round information on MTW processes for receipt and sampling of incomin ,:i (~)~~~ial. (b)/7)( J has worked r MTW fo 8 ears_ arlc:i isre$ponsiblefor the (b)(7)(C) Honeywell's license authorizes it to possess up to 68 million kg (150 million l bs) of natural uranium in the form of '1 yellow cake," U30s, U02 , U03, UF4, UFa, and chemical intermediates of these compounds.

The l icense does no t i mpose any specific restrict i ons on the "activity ," "specific activity," or activ i ty concentration" of natural uranium ore concentrates received by Honeywell.

Honeywell receives uran i um ore concentrates in 55-gallon drums via common carrier from uranium mills throughout the world.3 Each sh i pment is unloaded at the Sampling Plant. Each lot of concentrates is we i ghed and sto r ed on storage pads unt i l acco u ntability procedures and uranium and impurity analyses are completed.

The uranium ore concentrates. are sampled in the Sampling Plant (except for hard or wet ore) to obtain stat i stically-significant analytical samples i n accordance with ASTM standards.

Th~ sampling resu l ts confirm that the ma t erial i s natu r al uranium ore concentrates , as defined i n ASTM standards.

In add i tion , MTW sampling procedu r es ensure that any material that deviates from the range of acceptable o r e concent r ates is identif i ed and appropriate steps taken to address any safety concerns. According to l (bl{7J(C i ( MTW does not currently r eceive ore fro ft ~1,:;s j a r TW does , however , receive ore from former Soviet republics, i nclud i ng!n<cJ and l<bi<7 1(c, l Shipments from these co u nt r ies are often referred to colloquially as " Russian" ore. For the pu r pose of this report, the i nvest i gator assumes that the concern relates to ore concentrates from the former Soviet republics, rather than ore concentrates from Russia itself. A d. l (b){7)(C)

I . h' . II d . d . . h c cor rng to , uranium ore s 1pments are typ1ca y es i gne to max 1 m1 z e t e amount of o r e i n a sinale sh i pment in order to min i mize t ransportation costs. Because {b)(4J (b)(4) I. Ac c ord i ng to l (b>C7HC.: J I mater i al from the former .._ ___________

_. ._ ___ _ 3 According to 10 CFR 71.4 , the natural uranium ore concentrates at MTW are low speci fi c activity materials.

The International Atom i c Energy Agency (IAEA) also de fi nes natu r al uranium as a low specific act i v i ty materia l. 6 (b)(7)(C)

(b)(4) A review of s hipment manifests addressing uran i um from multiole locations ind i cates (b)(4) 4 5 6 Country of Origin I Total Activity I # Drums I Activity/drum 6 (b):4 I-USA I -344 GBq I 43 I 8.0 GBq/drum (b)(4\ According to !(b)l7)(Cl I. the samples listed are broadly representative of the range of material received by MTW. For natural ore concentrates , activity is proportional to the quantity of uranium. The term "activ i ty co ncent ratio n is used to indicate the activity per unit mass (or volume) of material and i s similar to specific activity." Spec i fic activity, however, is typically reserved for use i n reference to a pure sample of a radionuclide , while activity concentration is used when referring to a material t hat contains rad i onuclides. This represents the average activity conce ntrat io n for drums of ore concentrates.

7 Country of Origin u (%) U-234 $04(%)'8 1 Na (%)<al {b)(4) I USA 76.21 46.12 ppm 0.99 0.44 -USA 78.92 5 1.47 ppm 0.44 0.5.2 USA 81.02 54.28 ppm 3.04 0.48 USA 81.29 53.81 ppm 1.89 0.54 (b )(4) ,., Su lf ur and sod i um a r e just two of many elements that m a y be f ound in uranium ore concentrates. Th ey a r e listed h ere to help ill um l nate t he reas ons fo r differences i n uran i um c oncen t ra tio ns amon g mate rial from different regions. Althou h the ore concentrates from former Soviet re ublics !{b}(4) I (b)(4) the mater i al still meets the e in 10n o natural uranium ore concentrates per AS T M standards e .. ASTM C967 Standard S ecification for Uranium Ore Concentrate).

The ._(b_,1_71_1c_, _____ _. (b}(4) etween a drum of material from a former Soviet republic an . .._ _ _, ano er ocat,on 1s not si nificant from f *

• to (b)(7)(CJ j<bl(7J{C) J the (b l(7)(C 1 at MTW, no s ec,al r ecessary o accoun or ( , l L:----,,---~~~---=-~---:-'

(b)(4) between ore concent ra tes from former Soviet republics and ore concentrates rom ot er locations. No additional training or safety measures beyond those already in place at MTW are necessary because MTW's Radiation Protection and ALARA programs are des ig ned to provide protection for a wide range of rad i ol o gical materials , including natural uranium ore concentrates j (b}(4) I !(b)(4) I Response to NRC questions regarding Concern No. 2: 1. Did the material from Russia have h i gher activity?

(b )(4) {b)(4) I The ore concentrates are still, however , classified as natural uran i um ore concentrates. 2. And i f so , did it require additional training to ensure proper handl i ng? Ore concentrates from fo r mer Soviet repub l ics do not require additional training or safety measures to ensure proper handling.

As natural uranium , the activity concentrations of ore conce ntrates from former Sov i e t republ i cs remai n below levels t hat would warrant additional training or s afety measures beyond those already in place at MTW. In addition , MTW sampling procedures ensure that material that could pose additional safety concerns i s identified and addressed. 8 Actions Planned No additional act i ons are considered necessary at th is time. Actions Taken This invest igat ion was conducted and a response was prepared as directed i n the NRC's letter dated August. 1 , 2013. l~on Responsi v e Reco r d 9

Non Respons iv e Reco r d Actions Planned No additional actions are considered necessary at this t i me. Actions Taken This investigation was conducted and a response was prepared as directed in the NRC's letter dated August 1 , 2013. CONCLUSION After rev iewing th e evidence, the independent investigator conc lude s that:

• Concern 2: " W orkers did not receive proper training or protection while handling !(b l(4 l I from Russia to be converted into uranium hexafluoride (UF 6)" is unsubstantiated. While material from former Soviet republics!(b)(4) I l{b)(4) I addit i onal tra i ning an d protections are no t warrante d. N o n R es pons i v e Record *

• 12 A TT ACHME N T S List of Attachments N o n Respo n s i ve Record List of Persons Interviewed

• * * (b)(7)(C) 13 ATTACHMENT 1 Letter from !(b)(?)(C) ! Allied Signal , to NRG , " Retraction of Request for License Amendment ," dated July 17 , 1998.

• 411iedSignal CHEMICALS July 17 , 1998 Director Office of Nuclear Material and Safeguards, U.S. Nuclear Regulatory Commission A TIN: Document Control Desk, Washington, D.C. 20555 AllkdS i gnal I nc. Nm:h::ir/Fluorim: Spn:ia ltics Routt' .; 5 North P.O. llox 4W Metropolis, II. 62')6() l 'SA ()185242111 61 H 524 6239 Fax Certified Mail: P-218-965-303 Re: Retraction of Request for License Amendment Source Material License SUB-526 Docket 40-3392 TAC No. L31076

Dear Sir:

AlliedSignal has previously requested a license amendment dated May 8, 1998 to include re ceiving, possessing, processing and converting unirradiated material potentially contaminated with plutonium-239 to uranium hexafluoride. This request was initiated due to extremely low but allegedly detectable levels of Pu-238 and Pu-239 reported in this material.

In conjunction with the request for license amendment, AlliedSignal has requested further analysis of the material in question from two different laboratories.

Nine duplicate samples were prepared and forwarded to F luo rDan ie l Fernald and to Thermo NuT ech laboratories for independent analyses.

The samples were selected from lots that indicated relatively moderate to high concentrations of p lu tonium. based on the original analyses by FluorDanie

l. Lots showing low values were not retes ted. Included with these samples were four samples of natural uran i um tetrafluoride produced at Metropolis Works for comparison.

We have received the resul t s from both la boratories and th e results are consistent wi t h natural mate rial. Nine lots were analyzed for Pu-238 and Pu-239. Seven of the nine lots tested showed less than minimum detectable concentration (MDC) of plutonium by both laboratories.

One lot , #2641 , tested slightly above the minimum detectable concentration by Thermo Nu Tech for Pu-238 at 0.100 pCi/g. The MDC for this analysis VoiaS 0.060 with an error of 0.054. One lot, #2562 , tested slightly above the minir.ium detectable concentrat ion (MOC) by Fluo r Daniel for Pu-239 at 0.032 pCi/g. The lv10C for this analysis was 0.031 with an error of 0.028. I n both of these cases, the other l aboratory showed less than MDC quantities for the respective isotopes.

Director, Office of Nuclear Material and Safeguards U.S. Nuclear Regulatory Commiss ion A TIN: Document Control Desk Page 2 Four samples of natural uranium tetrafluoride produced at Metropolis works were included for comparison.

Thermo NuTech showed Pu-238 slightly greater than detectable in three of the four samples. FluorDaniel showed slightly greater than MDC in the other sample. Once again, no sample tested positive for any plutonium isotope by both laboratories. Analysis of the data indicates that in every case where a laboratory yielded a positive result for either Pu-238 or Pu-239, the laboratory counting error was sufficient to cause the value to be above the MDC. It is our feeling that we are dealing with an analytical method that is so sensitive and minimum detectable quantities that are so low that any noise, counting error, or background interference may calculate to a value near or above the MDC. Although we do not propose dilution as an acceptable method to reduce the analytical results, we do realize that commingling with the material in our existing process would certainly reduce the concentrations well below the detection limit making any further analysis a moot point. It is likely that we would get similar analytical results hovering around and mostly below the minimum detectable concentration. Once again, interference, counting error and background may calculate to some positive but meaningless result. When comparing plutonium levels in the Metropolis natural material to the "contaminated' material, it was found that the levels were very similar. This would confirm the original contention that the uranium tetrafluoride purchased from Fermco is indeed not contaminated with plutonium. Any indication of plutonium con tamination could be due to a variety of factors including:

a) reporting of results that are below the MDC; b) laboratory error that would make an analytical value that should be below the MDC slightly higher than the MDC; c) performing analyses at such low levels that background or other interference may yield false positive results. We also believe that the positive plutonium results reported in the Metropolis Works UF 4 are a result of a similar phenomenon and that there has been no contamination of our facil i ty. Work room air sampling has been performed and there is no evidence of plutonium contamination in the samples. It is our intention to perform additional sampling during and upon completion of the processing of the UF 4 to v e rify these results. Further more, the analytical results for this material were compared to th e I AEA definition of unirradiated uranium as defined in paragraph 245 of IAEA ST-1 , R eg ulations for the Safe Transport of Radioactive Material , 1996 Edition. This paragraph defi ne s unirradiated material using 3 parameters

tota l plutonium.

fissi on product activity, and U 236 concen t ration. Th8 follow i ng tcible compa.res the Nnne s_! val1..:e of tile analyses for eithe r l aboratory to tne IAEA standard:

• Director, Office of Nuclear Material and Safeg u ards U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Page 3 --Analytical Units Lot Laboratory Parameter Number Plutonium Bq/g LJ 235 2565 Thermo NuTech Fission Bq/g u 235 2639 Fluor Daniel Products u 23a -9 u236 / g u 23s I Alt Fluor Daniel Highest IAEA Laboratory Standard Result 2.266 2,000 629 9,000 , 000 <0.000140 0.005 For each parameter , the analyzed value is several orders of magnitude below the IA EA definition. Based upon these concurr i ng results by independen t laboratories and the fact that no parameter approaches the IAEA definition of unirradiated uranium , it is our contention that the uranium tetrafluoride i n question mee ts the requi rements of our existing operating license and that no amendment is required to possess or process this material.

These laboratory results also indicate that the p l u tonium in the UF 4 is at or below the labora tory counting error a nd therefore , this facility is not contaminated with plutonium.

We respectfully req uest that the re quest for license amendment be retracted.

We apologize for any inconvenience that you ma y have incurred as a result of our initial request. We will appreciate your prompt rev iew of this submittal.

If our have an uestions or need more information , please call (b)(7)(C) or l (b)(7)(C) I* Sincerely, (b )(7)(C) PGG/sm cc. (b )(7)(C) Mr. Mi k e Lamastra Div. of Fuel Cycle Safety & Safeguards US NRC Wa s l1in gto n. D C 2 0 555 Mr. Pat H Ha nd NRC -Region Ill 801 Warrenville Rd. Li s l e , IL 60532-4351 ATIACHMENT2 l (b)(7}(C) I . , Letter from M. Lamastra , NRC , to Allied Signal , ,;Amendment Request to Process Pu~239 Contaminated Material," dated August 5 , 1998.

..

• Mr.P.G.Gaperinl l rurim Pla l'lt Manager AlliedSignll , Inc. P.O. Box 430 Metropolit , lllinoil 82960 August 5, 1998

SUBJECT:

AME NDMENT REQUEST TO PROCESS Pu-239 CONT AM1NA Ti.;O MATERIAL (TAC No. L31078) DNr Mr. Gape,i ni: Thie~ to your applic:ation dlltad May 8, 1998, requnting a n amendment to Matenall Uc:enM SUB-528 for approval lo prooeaa material d\at ii contaminlt9d With Pu-239 , and your ,My 17. 1988, reqiN to withdraw the amendmwrt.

Baed on the new information llJbmtttad t,r Y04/I Jut, 17 , 1981 , laaar that the Pu-238 and Pu-238 11 at minimum~ concerlb'ltionl and ia wllh nanl maeen.. we agree thal the material may be pn,caeNd under yow CUfflN1t aulhoriZlltion wtlh no amendment reqund. ~. no fur1hlr ICtiOl'l 11 ~. and TAC No. L31078 i9 oonaider doMd. If you qu111k)M rega,dinO tit mdlt. plow oantact me It (301) 4 15-1138. ~. D:erbfon (Controt 'No. 3006) Ortg1~1 signed by: Mk:haal A. Lamattra Ucwine Section 2 Uceneing Branch OMliorl r:I Fuel Cyae 8*y and U.guarda.

NU SS Doclllt 40-3382 PU8UC NRC File c.r.-N MSS R/F FCLB R/F FC88 M Region Ill O:\allwlt O, C .,.. FCLB £:, '" ** ... **, py "(J"' '#! . ---... -------------------------

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UNtTED STATES HL'CL EA P. RECULA T ORY C OMMI SSION WAIH t HGTON. D.C. : OIH ODD1 Avgu st S, l 998 (b)(7)(C)

SUBJECT:

AMENDMENT AeQUEST TO PROCESS Pu-239 CONTAMINATED MATERIAL (TAC No. l31078) Dear!(b )(7)(C) Thia rwfefl to your appticltion dated May 8. 1998; an amendment to M ateriat t Uoenee SUB-526 for epproval to proofft m eterial that* cont aminated With Pu-230. and your 17. 1991, request t o wrthdrN Che 8mendment. Baled on the new lnform.ttior, subm ttted by your ,My 17. 1 998, ,-., that Che f'u.238 P u-238 ta .t minimum dlltectable c: on c eutnttion.

and II conliatant with nltunll material , we agree lhlt the material may be procetNd under ,out* current tutt.oriz at ion '1With no amendment required. Accordi ngty , no further action Ill rwquired, atw.t TAC No. L31078 it consider doled. If you h8Y9 rwprd.ng thlt m attrr. pleaN con tact me ac (30 1) 4 15-8139. Slnelt'efy. --... ----,A41* '. -------M ichaet A. Llk:il nting Section 2 Licensi ng Bnndl 2 C Dtv'8ton of Fuel C ycle Snty lnd~.NMSS ----------

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A TT ACHMENT 3 Representative Rai/car Stenciling DOT 112SSOOW FUJORl)E, ANHYDROUS INHALATION HAZARD DOT P111.51 ~~Oi!!j5 ATTACHMENT 4 Representative Railcar ID Plate

6 a ss2 46 38!> Safety Tr a il er 02: 02: 2 0 p.m. 09-2 7-2013 2 /28 Honeywell Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis , IL 62960 September

27. 2013 CERTIFIED 7010 0290 000159980229 Mr. Oscar DeMiranda Senior Allegation Coordinator, EICS Office of the Regional Adm i nistrator, Region II U.S. Nuclear Regulatory Commission P.O. Box 56274 Atlanta, GA 30343 Docket No. 40-3392 L i cense No. SUB-526 RE: HONEYWELL METROPOLIS WORKS' RESPONSE TO ALLEGATION NO. Rll-2013-A-0100 This letter forwards the report of the investigation performed by an Independent Investigator to evaluate the concerns identified in the NRC's August 1, 2013 letter transmitting Allega t ion R ll-2013-A-0100. The Independent Investigator is outside counsel from Winston & Strawn LLP , with more than ten years of experience in nuclear regulatory matters. Upon evaluating the concerns set forth in the NRC's letter, HoneyweU detennined that it needed additional time to finalize the Investigation, and requested that the reply date be extended to 60 days from the date of the NRC's l etter. This extension was granted by you via telephone on August 23 , 2013, and documented in Honeywell's letter to Mr. James A. Hickey on that same date. The Independent Invest i gator found that the four concerns in the Allegation were unsubstantiated.

Specifically

(1) Green salt from Fernald did not contain plutonium or neptunium in analyt i ca l ly significant quantities; (2) While material from former Soviet republics sometimes has a higher activity concentration than material from other l ocations, add i tional training and protections are not warranted; (3) Railcars used to store anhydrous hydrofluoric acid (AHF) contain pressure relief valves with appropriate set points. and no scrubber system is necessary given the substantial margin between the vapor pressure of AHF and the relief valve set point; and (4) While Metropolis Works (MlW) at one time requ i red e x it monitoring only for personnel working in process areas , by the mid-1990s all persons leaving the restricted area were required to perform exit monitoring , and no records were found of off site contamination during the per i od of interest.

Supporting documentation Is attached to the Independent Investigator

's report. MTW intends to ensure that all concerns expressed by MlW employees and contractors are received and resolved in an effort to continue to improve our safety and performance.

, 6 1 8 52 4 6~85 safety Tra il er 02: 03:23 p.m. 09-27-2013 If there are any questions regard i ng the enclosed i nformation , please call Mark Wol f , Nuclear Compliance Direc t or , et (618) 309-5013. Sincerely, :::::~~~f Plant Manager J.g H. $'.,....r, Enclosures 2 3 /28 6J8524638!i SafetyTraller 02: 03: 47 p.m. 09-27-2013 Honeywell Metropolis Works (MTW) Review of Nuclear Regulatory Commission (NRC) Allegation No. Rll-2013-A-0100 Dated August 1, 2013 IDd@PIQdent Investigator Tyson Smith -Outside Counsel (Winston & Strawn LLP) Washington , DC September27

, 2013 1 4/28

, 618524ti385 SafetyTra ll e r 02:0 4: 15 p.m. 09-27-2013 BACKGROUND By letter dated August 1, 2013 , 1 the U.S. Nuclear Regulatory Commission (NRC) forwarded to Honeywell International I nc. (Honeywell) four concerns regarding activities at the Honeywell Metropolis Works (MlW} facility In Metropofis, Illinois. The NRC requested that Honeywell evaluate the Information described in the letter's enclosure and provide the results to the NRC RII AUegations Coordinator.

This report presents the results of an Independent Investigation of the concems forwarded by the NRC. ISSUES INVESTIGA TEO Concern 1: In the mid 90s, workers were unknowingly exposed to Plutonium and Neptunium while processing green salt from the Fernald Department of Energy (DOE) facility. Determine If a Plutonium and Neptunium hazard resulted from processing green salt from the Fernald DOE facility. If so , wem worlcers properly trained for those hazards'?

Were there any exposum events Involving Plutonium and Neptunium?

If so , what were the levels and resufts? Concem 2: Workers d;d not receive proper training or protection while handling higher actiVlty material from Russia to be converted Into uranium hexafluoride (UFe), Did the material from Russia h~ve higher actrlity?

And if so, did It require additional training to ensure proper handling?

Conoem 3: The railcars stored on-site for transfer of anhydrous hydrofluoric acid (AHF} to the Feed Materials Building are not properly configured with a relief system in the event of an over-pressurization and are not connected to a scrubber system. What features are n,quired and/or available for rail cars stored onsite which may be subject to an over-pressurization event? Conoem 4: In the mid 90s, individuals wera not required to monitor out of the facJ/lty and could have bsen spreading c;ontaminatlon offslte. One lnrf,vidual was noted to hava gone home contaminated. Provide information regarding offsite contamination 9Vent(s) and correct actions resulting from any event(s) which occu"ed In the mid 90s. INYESJJGA TION APPROACH These allegations were evaluated by an independent lnves11gator, Tyson R. Smith. Mr. Smith is outside counsel from Winston & Strawn LLP. Mr. Smith has more than ten years of experience In NRC regulatory matters, including investigations and enforcement Letter , J. Hickey to L. Smith, "Allegation No. Rll-201~A-0100

," Aug. 1, 2013. The enclosure is marked as "Not For Public Disclosure

." 2 5/2 8 638 52 46385 Safety Tra il e r 02:05:1 7 p.m. 09-2 7-2013 matters. Mr. Smith was employed by the NRC from 2003*2005. He has a B.S. in Civil and Environmental Engineering from Vanderbilt University, an M.S. In Civil and Environmental Engineering from Stanford University, and a J.D. from Lewis & Clark Law School. The investigation began with a review of current and historical documents relevant to the concerns identified by the NRC. The Investigator also obtained MlW procedures relating to the Issues addressed In this report. The relevant documents reviewed by the investigator are listed for each concern. In addition, Mr. Smith questioned subjed matter experts at MTW, also Identified below , who had knowledge of events or reaponslbllltles In functional areas relevant to the concerns. From the review of the original concerns, the documents identified during the investigation , and the interviews with subject matter experts, the Investigator assembled a list of incidents or examples that are encompassed by the concerns. The Investigator evaluated each Incident or example to the extent practicable given the nature of the matter, and also evaluated the overall timeline In assessing the overarching Issues raised in the allegations. FINDING§ OF FACT Concern 1 -U nsu b§tanU.te d Through a review of historical documents, Including correspondence with the NRC, the investigator compiled a regulatory history relating to shipments of green salt from the Fernald DOE facility.2 The available documentat i on supports the conclus i on that MTW workers were not exposed to plutonium or neptunium while processing green salt from Fernald. Additionally, the documents confirm that no plutonium or neptunium hazard resulted from processing this green salt, and that workers therefore needed no special training. The following chronology of events provides detailed background regarding green sa l t received at MTW, wh i ch at the time was operated by AlliedSlgnal, from the Fernald DOE facility. 2

• November 1995: Allie<fSignal receives shipment of uranium tetrafluoride (UF") green salt from FERMCO (Fernald , Ohio).

• November 1996: Five lots of potentially contaminated UF" from FERMCO are Identified for the first time during a review of materia l for sale.

• February 1997: FERMCO green salt Is tested for contaminants by two separate laboratories. All lots except one show nor,..ctetectable levels of plutonium.

Neptunium contamination was not detected in any samples. Uranium tetrafluoride (UF .. ) is a green crystalline solid .known as green salt. Green salt Is an Intermediate compound In the conversion of uranium oxides to uranium hexafluoride.

3 6 /2 8

• 618524638 5 Safety Tr a iler 02: 0 6: 2 3 p.m. 09-2 7-2 013

• March 17, 1997: AllledS l gnal requests a license amendment from the NRC that would authorize possession of UF,. contaminated with plutonium (for the one lot showing detectable level of plutonium}.

• April 2 and 16, 1997: A li edSlgnal responds to NRC Staff requests for information regarding the license amendment request.

• May 6 , 1997: NRC grants license amendment authorizing AJliedSlgnel to possess the contaminated FERMCO UF4.

• May 8 , 1998: AltiedSignal requests Hoense amendment to authorize proce86ing and conversion of contaminated FERMCO UF,..

• June 17, 1998: NRC issues request for additional Informat i on regarding ficense amendment request.

• July 17, 1998: AllledSignal withdraws request for license amendment. Based on subsequent analys i s, MlW determined that the FERMCO green salt I n fact met the requirements of the MTW operati'll llcellN at that time. As a result , no amendment was necessary to possess or process that green salt. Accord i ng to the July 17, 1998 letter , analyses of n i ne lots of the gree n salt by two separate laboratories showed results consistent with natu r al (unirrad l ated} green salt. Seven lots had les s than the m i nimum detectable concentrations

{MDC) of plutonium based on result s from both laboratories. One lot ahowed sHghtty above MOC by one laboratory , and a different lo t showed slightly above MO C by the other laboratory. In both of these cases , the other laboratory showed Jess than MDC quantities.

AJso , in both of these cases the laboratory co unting e rror alone was sufficient to cause the va l ue to be above MD C. AllledSlgnal therefore concluded tha t UF 4 from FERM CO was not in fact contaminated with plutonium , and that any Indication of contamination was likely the result of l aboratory error or other an al ytical issue. AlliedSignal als o affirmat i ve l y stated that there was no contam i nation of the facility.

• August 5 , 1998: NRC agreed that, based on the In f ormation In AJliedSlgna l's July 17, 1998 letter, the plutonium was at m i nlmLrn detectable concentrations i n the FERMCO green salt. The NRC concluded that the green salt material analyse s were con s istent with natural material and that t he FERMCO green salt c o uld be processed under the MTW l ic ense without amendment

• Present day: Seven drums of t he FE RMC O green sa l t rema i n ons lt e. T he drums are Individually identified and marked. No special procedures or supplemental protections relating to the storage or handling of the green salt are i n place or necessary. 4 7 /2 8 6 l 8 52 46 3 85 Safe ty T ra il er 0 2: 07: 27 p.m. 0 9-2 7-2 013 Response to NRC questions regarding Concern No. 1: 1. Determine If a plutonium and neptunium hazard resulted from processing green salt from the Fernald DOE facility. Based on a review of MTW correspondence with the NRC, there were (and are) no plutonium or neptunium hazards resulting from green salt received from the Fernald facility.

Extensive laboratory testing indicated that green salt from Fernald dld not contain plutonium o r neptunium In anatytlcally

~gniflcant quantities. As a result, the green salt could be processed under the then-existing MTW license. The FERMCO green salt has been and wlll be processed In accordance with the MTW license and applicable procechxes. I n adcition and as documented in the letter from the NRC to AllledSlgnal on August 5, 1998 , the NRC speclflca(ly agreed with AlliedSlgnal that there was no special hazard associated with the FERMCO green salt. Honeywell has attached the followlng documents to support this conc\ua l on:

• Latter from P.G. Gasperini , Allied Signal , to NRC, " Retraction of Request for License Amendment,*

dated July 17 , 1998.

• Letter from M. Lamastra, NRC , to P.G. Gasperini , AIUed Slgnal , "Amendment Request to Prooess Pu-239 Contaminated Material ," dated August 5, 1998. 2. If so, were workers property trained for those hazards? A5 noted above , there was (and Is) no special hazard associated with the Fernald green salt. Since there were no pkrtonium or neptunium hazards resulting from green salt from the Fema l d fa<::ility, workers needed no special training for processing end handling the green salt (i.e., no additional training Is necessary beyond that normally required for site workers handling radiological materials). 3. Were there any exposure events involving Pluton i um and Neptunium?

No. The investigation identified no exposure events I nvolving plutonium or neptunium.

4. If so , what were the levels and resuls? Not applicable.

The investigation Identified no exposure events involving plutonium or neptunium. Actions Planned No additional actions are considered necessary at this time. 5 8 /2 8

, 618 5 246 385 Safety Tr a il e r 02: 08: 2 3 p.m. 09-27-2 0 1 3 Actions Taken This Investigation was conducted end a response was prepared as directed in the NRC's letter daed August 1 , 2013. No further action is necessary. Concern 2 -Unsubstantiated The Investigator reviewed the requirements of NRC license SUB-526 Issued to Honeywell ror the MTW facility and obtained Information and documentation regard i ng the activity of shipments of uranium, including those from Kazakhstan and Uzbekistan. The investigator also interviewed Jason Cybulski, the MlW Site Services Manager, to obtain background information on MTW processes for receipt and sampling of incoming material.

Mr. Cybulski has worked at MTW for 17 years and Is responslble for the supply chain and uranium Inventory control. Honeywell's license authorizes It to possess up to 68 mHlion kg (150 mlHlon lbs} of natural uranium In the form of "yeHow cake,* u,o,. U0 2 , UO,, UF4, UF, , and chemical intermediates of these compounds. The license does not Impose any specific restrictions on the " activity:

" specific activity," or "activity concentration*

of natural uranium ore concentrates received by Honeywell.

Honeywell receives uranium ore concentrates in 55--gallon drums via common carrie r from uranium mills throughout the world.' Each shipment I s unloaded at the Sampling Plant. Each lot of concentrates Is weighed and stored on storage pads untll accountability procedures and uranium and impurity analyses are completed. The uranium ore concentrates are sampled in the Sampling Pll!lnt (except for hard or wet ore) to obtain statlstically-slgn l flcant analytical samples In accordance with ASTM standards. T~ sampling resu l ts confirm that the material is natural uran i um ore conoentrates, as defined In ASTM standards.

In addition, MTW sampting procedures ensure that any material that deviates from the range of acoeptable ore concentrates is I dentified and appropriate steps taken to address any safety concerns. According to Mr. Cybulski, MTW does not currently receive ore from Russia. MTW does. however, receive ore from former Soviet republics , Including Kazakhstan and Uzbekistan. Shipments from these countries are often referred lo colloqulally as *Russian" ore. For the purpose of this report, the investigator assumes that the concern relates to ore concentrates from the forme r Soviet republics , rather than ore concentrates from Russia itself. According to Mr. Cybulskl, uranium ore shipments are typically designed to maximize the amount of ore in a single shipment in order to minimize transportation costs. Because uranium concentrates sent from former Soviet republics may have a higher percentage of uranium relative to other elements or Impurities , shipments of ores from these locations often consist of fewer drums (with more weight per drum) In order to remain within acceptable transport limits. According to Mr. Cybulski, material from the former 3 According to 10 CFR 71.4, the natural uranium ore concentrates at MlW are low specific activity materials. The International Atomic Energy Agency (IAEA) also defines natural uranium as a low specific activity material. 6 9/28 6]85 246 38~ S a fety Trail e r 02:09: 37 p.m. 09-2 7-2 013 Soviet republics is sometimes referred to internally as "the good stutr In reference to the fact that the concentrates typically have e higher peroentage of uranium on a per drum basis. The relatively higher percentage of uranium in the ore concentrates is also taken into account when blending various drums of material at the start of the UFa production proces s. A review of shipment manifests addressing uranium from multiple locations Indicates that the total activity of a ahipmert of ore concentrates from former Sovie t republic is comparable to that of ore concentrates sent from other locations. 4 Howeve r , ore concentrates from former Sovie t republics may have a higher "activity concentration" than materia l from oth er locations If there ls more ur:an l um per drum.6 4 5 6 Country of Origin Total Activity # Drums Activity/drum*

Namib i a 299 GBq 54 5.5 GBq/drum Austra li a 356 GBq 48 7 .4 GBq/drum USA -344G8q 43 8.0 GBq/drum Nam i bia 388 GBq 46 8.4 GBq/drum Australia 440 GBq 48 9.2 GBq/drum Uzbekistan 322GBq 35 9.2 GBq/drum Kazakhstan 360 GBq 36 10.0 GBq/drum Accord i ng to Mr. Cybulski , the samples listed are broadly representative of the range of material received by MTW. Fo r natural ore concentrate s, activity is proportional to the quantity of uranium. The term " activity concentration" is used to Indicate the activity per unit mass {or volume) of materia l and i s simtlar to " specifi c activity." Specffic act i vity , however , Is typically reserved for use in reference to a pure sample of a rad i onuclide , while activity concentrat i on Is used when refer r ing to a material that contains radionuclides. T his represent s t he average activty concentra ti on for drums of ore concen t rates. 7 10 /28

, 61 85 24.638 5 S a fety Tra il er 02: 1 0: 29 p.m. 0 9-2 7-20 13 Country of Origin U(%) U-234 so .. (%}(I) Na(%)'., Namib l a 73.22 54.10 ppm 2.27 1.83 USA 76.21 46.12 ppm 0.99 0.44 USA 78.92 51.47 ppm 0.44 0.52 USA 81.02 54.28 ppm 3.04 0.48 USA 81.29 53.81 ppm 1.89 0.54 Kazakhstan 83.30 54.08ppm 0.79 0.24 Australia 84.05 53.96 ppm 0.59 0.06 Uzbekistan 86.89 60.36 ppm 0.01 <0.01 (a) SUifur and ICd.m n just &>No of many elements that may be b.M In 1nn11.1m ant ooncenlrates. Thay are latld hll't lo help lllumlnlte the re .. one for dlfferencM In ul'91ium coneenlrl1lon*

among Mllllrial from dlffllrenl raglona. Although the ore concentrates from forme r Soviet republics typlcaly have a higher activity concentration than material from other locations , the material stlll meets the definltfon of natural uranium ore concentrates per ASTM standards (e.g., ASiM C967, Standard Specification

'for Uranium Ore Concentrate). The difference In activity concentration levels between a drum of material from a former Soviet republ i c and from another location is not significant from a safety perspective. According to Sean Patterson , the Regulatory Affairs Manager (former1y Health Physics Supervisor) at MlW , no spacial precautions are necessary to account for the relatively small differences Jn activity concentration levels between ore concentrates from former Soviet republics and 01'8 concentrates from other locations. No addlt l onal training or safety measures beyond those already In place at MlW are necessary because M1Ws Radiation Protection and ALARA programs are designed to provide protection for a wide range of radiological materials , including natural uranium ore concentrates with relatively higher activity concentrations. Response to NRC questlona regardf ng Con cam No. 2: 1. Did the material from Russia have higher activity?

As discussed above , shipments of ore concentrates from the former Soviet republics typlcaffy have activity levels that are comparable to sh i pments from othe r locations. However , ore concentrates from the former Soviet republics often have a higher activity concentrations due to the relatively h i gher percentage of uranium In the concen t rates. The ore concentrates are stil, however , c l assified as natura l uranium ore concentrates. 2. And I f so, d i d it require additiona l tra i ning to ensure proper handling?

Ore concentrates from former Soviet republics do not require additional training or safety measures to ensure proper handling. As natural uranium, the activity concentrations of ore concentrates from former Soviet republics remain below levels that would warrant additional training or safety measures beyond those already in place at MTW. In addition, MlW sampling procedures ensure that material that could pose additional safety concerns is identified a n d addressed. 8 1 1 /28 6185246385 Safety Trailer 02: 11 :40 p.m. 09-27-2013 Actions Planned No addit i onal actlons are considered necessary at this time. Actions Taken This investigation was conducted and a response was prepared as directed in the NRC's letter dated August 1, 2013. concern 3 -unsubstantiated At MTW, anhydrous hydrofluoric acid (AHF) is brought onto the site via railcar. After the railcar containing the AHF Is brought into the Restricted Area of the site, the rallcar is stored on site until it is connected to the process line at the Feed Materials Buffding.

The aUegation reiates specifically to the safety of the AHF rallcars stored at the site prior to being connected to the process line.7 To investigate the allegation, the Investigator reviewed the specifications and safety features of rallcars that contain AHF when stored onslte and conducted interviews with personnel regarding AHF storage. AHF is shipped in railcars that meet or exceed DOT specifications, Including specffications requiring relief valves.1 RaHcars approved for the transport of AHF have relief valves set at a pressure that ensures a substantial margin between the pressure relief valve and the vapor pressure of the AHF in the railcar. 9 While being stored at MTW, the railcar is not connected to a scrubber system. However, a scrubber system is not necessary because the railcar is designed to withstand pressures significantly If'! excess of the vapor pressure of the AHF in the railcar. 1 8 The Investigation did not specifically address the safety of rallcars once they are connected to the process lines et MTW because this Issue is outside the seope of the concern. According to 49 CFR 173.244, AHF must be transported In tank cars having a test pressure of 300 psig or greater and conform to DOT C l asses 105, 112, 114, or 120. The railcar ID data plate for one AHF railcar at MTW identifies the railcar as type DOT 112A500W.

This railcar type satisfies DOT requirements for shipment of AHF (see 49 CFR 173.244).

The stenciling on the railcar identifies It as type DOT 112SSOOW.

According to the GATX manual , rallcar type DOT 112SSOOW is the same railcar as DOT 112A500W, but equipped with head shields. According to the rallcar stencil in g, the railcar is fitted with a safety valve set at 375 psig. Railcars of this type have a bursting pressure of at least 1250 psig. See49 CFR 179.101-1. According to Jon Price, Technical Manager at MTW , the vapor pressure of AHF at the maximum reasonable ambient temperature at M1W, which is 100 degrees F , is approximately 13 pslg. 9 12 /28 6185246385 Safety Trai l er 02: 12: 43 p.m. 09-27-2013 RNponse to NRC questions regarding Concern No. 3: 1. What features are required and/or available for rail cars stored onslte which may be subjected to an over pressurization event? Railcars coraining AHF are required to meet DOT specifications.

including specifications regarding relief valve presaure set polnw. The vapor pressure of AHF at the maximum reasonable ambient temperature at MlW Is approximately 13 psg. Raicars designed to DOT specifications have rellef valves set at pressures significantly beyond those expected to occur at MTW. A scrubber system is not necessary In light of the significant differential between the vapor pressure of AHF end the relief valve set point. Action* Planned No additional actions are consrdered necessary at this time. Actions Taken This investigation was conducted and a response was prepared as directed In the NRC's letter dated August 1, 2013. Concern 4 -unsubstantiated According to the concern, in the mld-1990s Individuals were not required to monitor out of the facility and could have been spreading contamination offsite. The concern states that one individual went home contaminated. To respond lo this concern, the investigator reviewed records related to hletorfcal plant practices and any Incidents of offslte contamination during the period discussed In the concern. The investigator also conducted an interview with Sean Patterson, Regulatory Affairs Manager (fonnerly Health Phyaics Supervisor) at MTW. Mr. Patterson was In the Health Physics department at MTW for 20 years. During the Interview with Mr. Patterson, he explalned that, at least as far back as 1986, the license requirements for MTW required that persons workJng in *controlled" (I.e., U Fe process) areas perform exit monitoring. Persons who did not work in process areas were not required to perform exit monitoring. This is reflected In health physics prooodures In use at the time, as well as the NRC license for MTW, Issued on November 10, 1993, which states (at License Condition

17) that exit* monitoring Is required for persons exiting contaminat i on controlled areas. In the mld-1990s, MTW changed practices to require that all persons exiting the Restricted Area (I.e., the area within the inner security fence) perform exit monitoring. The MTW license renewal application, dated July 11, 1994, state8 In Section 3.2.1 that visitors and employees who have worked in , or visited, the Restricted Area at the site must perform personal exit monitoring upon leaving the Restricted Area. That requirement, which was Incorporated by reference into the renewed M1W license, was also reflected in the Health Physics Procedure for Contamination Control no later than 1996. 10 13 /28 61852463,8 5 Safety Tr a iler 0 2:13: SOp.m. 0 9-2 7-20 1 3 The Investigation did not reveal any specfflc incident that led to the c h ange in procedu r e. And, the precise date of the change in practice at MTW could not be ascertained because of the manner in which MlW license documentation was maintained. At the time, changes to the license were incorporated by remov i ng a page and replacing it with a new page. Based on the interview with Mr. Patterson, the change i n practice was likely made sometime in the mid-1990s, which would be consistent with the license renewal application filed in 1994. The current MlW license renewal application (Section 3.2.1), which is also incorporated Into the current MlW llcense, continues to require exit monitoring for all persons leaving the Restricted Area.10 The license applicat i on also states that Honeywell shall not permit an individual to exit the Restricted Area with skin or clothing contam i nation at levels exceeding the guidanoe p r ovided in Section 2.6 of Regulatory Guide 8.30 without specffic Health Physics approval.

With respect to offsite contamination events, MTW reported that records reviewed to respond to the request for information did not reveal any I nstances of offslte contamination during the period of time discussed in the concern. Based on a review of personnel exit survey reports from January 1991 through April 1992, all personnel were documented as performing exit monitoring correctly. T hese reports , however, appear to be a random sampling of employee exit monitoring practices, not forma l dally documentation of emp l oyee exit records. Health Physie& technician log books for the peri o d between February 1995 and October 1999 identified 45 contamination events at the exit monito r. Howeve r , In all cases the employee was decontaminated pr i o r to leaving the facility. Based on a review of Incident & Spill Reports from 1996 th r ough 1999 , there was one report regarding an instance of PPE being worn outs i de th e Restricted Area. Upon Investigation, It was determined that the employee's street clothes , which were be i ng worn under h i s plant overalls, had been contaminated while at the plant. Before leaving the site , the emp l oyee dressed In a new pa i r of coveralls , was monitored and found clean, and then left the plant wearing the coveralls. There was no offsite contaminat i on. Mr. Patterson also recalled one Instance in 2000 In which an emp l oyee's home and personal veh i cle were surveyed following a urine sample result that showed relatively high amounts o f uranium. According to contemporaneous documentation,* follow-up urine samples did not show the same high levels . of uranium. Nevertheless, MTW personnel perfonned surveys of the employee's home, i ncluding steps and sidewalk, as well as the employee's personal vehicle. No survey readings were above background levels. Response to NRC questions regarding Concern No. 4: 10 1. Provide i nformation regarding offsite contamination event(s) and corrective actions resulting from any event(s) which occurred I n the mid 90s. The investigation did not reveal any records or reports of offsite contamination In the 1990s. There was a change in MTW practices related to exit monitoring that occurred in the mid~ 1990s. Speclflcally, M1W transitioned from requiring exit monitoring only for persons working In process areas to requiring exit mon i tor i ng MTW-SOP-HP

-0112, "Re l ease of Personnel , Materials , Equ i pment, and Transport Vehicles from the Restricted Area." 1 1 1 4 /28 6.18 5 246 385 Safe t y Tr a li e r 02:15:11 p.m. 09-27-2013 for all persons exiting the Restricted Area of the site. A review of available documentation did not Indicate whether the change was made as a corrective action foUowing a particular incident, In conjunction with license renewal, or as part of site continuous improvement or ALARA efforts. Actions Planned No additional actions are considered necessary at this time. Actions Taken Th i s Investigat i on was conducted and a response was prepared as directed In the NRC's letter dated August 1, 2013. CONCLUSION After reviewing the evidence.

the Independent Investigator concludes that:

• Concern 1: *in the mid 90s, worl<ers were unknowingly exposed to Plutonium and Neptunium while processing green salt from the Fernald Department of Energy (DOE) facility is unsub&tantJated. Green salt from Fernald did net contain plutonium or neptunium in analytically slgnlflcant quantities.

• Concern 2: " Wor1<'ers did not receive proper training or protection while handlfng higher sctivlty material from Russia to be oonverted Into uranium hexsfluortde (UFJ" Is unsubstantiated. While material from former Soviet republics typically has a higher activity concentration than material from other locat i ons, additional training and protections are not warranted.

• Concam 3: "The rsilcsrs stored on-site for transfer of anhydrous hydroffuorlc acid (AHF) to Iha Feed Materials Bui/ding sre not properly configured with a relief system In the event of an over-pressurization and are not connected to a scrubber system" ls unsubstantiated.

Rallcars used to store AHF are required to have pressure relier valves with appropriate set points. Although the rallcars are not connected to a scrubber system while being stored at the site, no scrubber system is necessary given the substantial margin between the vapor pressure of AHF and the relief valve set point.

• Concern 4: *in the mid 90s, individuals were not required to monitor out of the facility and could have been spreading contamination offs l te. One individual was noted to have gone home contaminated" l s unsubstantiated. Whlle MlW at one time required exit monito ri ng only for personnel working In process areas, by the mld-1990s all persons leaving the Restricted Area of the site were required to perform exit monitoring.

In addition, no records or reports we r e found of offs i te contamination during the period of interest. 12 15 /28 61852463.85 S a fety Trailer AUACl1MENTS List of Attachments 02:16:11 p.m. 09-27-2013 1. Letter from P.G. Gasperini, Allied S i gnal. to NRC , "Retraction of Request for License Amendment ," dated July 17, 1998. 2. Lette r from M. Lamastra, NRC, to P.G. Gasperini , Allied Signal , *Amendment Request to Process Pu-239 Contaminated Material," dated August 5, 1998. 3. Representative rancar stenciling

4. Representative railcar ID plate Ust of Persons lntervieW&d

• J. Cybulski

• J. Pr i ce

• S. Patterson 13 16 /28 Performance Materials and Technologies Honeywell P.O. Box 430 2768 North US 45 Road Metropolis, IL 62960 August23,2013 CERTIFIED

... r_)(-?)-(C_) _____ __. James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection U.S. Nuclear Regulatory Commission, Region II 245 Pe achtree Center Avenue NE , Suite 1200 Atlanta, GA 30303-1257 DocketNo.40-3392 License No. SUB-526 RE: HONEYWELL METROPOLIS WORKS' REQUEST TO EXTEND RESPONSE PERIOD TO ALLEGATION Rll-2013-A-0100 Honeywell Th i s communicatio n Is with regard to Honeywell Metropolis Works' response to the Allegation Rll-20 13-A-0100 requested in th e NRC l etter dated August 1 1 2013. The NRC asked that Honeyw e ll evaluate the informa tion described in t he enclosure to t h e l ette r and submit the results of that evaluation to Region II within 30 days of the date of the l e tter. Evalu a ting the concerns identified in the subject NRC letter , Honeywe ll determined that it needs additional time to finalize the fi ndings related to the validity of the Allegation Rll-2013-A-0100.

Consequently, Honeywell requests to extend the response per iod to sixty (60) days of the date of the NRC letter transmitting the Allegation Rll-2013-A-0100.

If y ou have q uestions , or wish to discuss this matter, please contact _!(b_)(7_)_c c_) ___ _ !(b )(7)(C) Mr. Oscar de Miranda , Senior Allegation Coordinator Enforcement and Investigations Coordination Staff Office of the Regional Administrator, Region II U.S. Nuclear Regulatory Commission 245 Peachtree Center Avenue NE, Su i te 1200 Atlanta. GA 30303-1257 l El : COMPLETE TJ-115 SECTION COMPLETE T/1/S SECTION ON DELIVERY

• Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired.

• Print your name and address on the reverse so that we can return the card to you.

• Attach this card to the back of the mail piece or on the front If space permits. 1. Article Addressed to: (b)(?)(C) Honeywell Metropolis works P.O. Box 430 Metropolis, IL 62960 2. t N~mber (11 .. ,,:;re, from service label) t PS Form 3811, February 2004 (b)(?)(C)

(b)(?)(C) 0 Agent 0 Addressee C. Date of Delivery D. Is dellve,y address different from Item 1? D Yes If YES, enter dellve,y address below: D No 3. SSrvlceType

~/ -~101',-*r olcertilled Mau D Express Mail D Registered D Return Receipt for Merchandise 0 Insured Man O C.0.0. 4. Res1rlcted Deliveiy?

{8(tra Fee) 0 Yes 102695-02-M-1540 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION It 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA. GEORGIA 30303-1257 r b)(7)(C) Honeywell International Inc. P.O. BOX 430 Metropolis , IL 62960 August 1 , 2013

SUBJECT:

ALLEGATION NO. Rll-2013-A

-0100 Dea r!(b )(?)(C) l The U.S. Nuclear Regulatory Commission (NRC) recently received information concerning activities at the Honeywell Metropolis Works facility in Metropolis , Illinois. We requ est that Honeywell evaluate the information described in the Enclosure to th is l etter and submit the results of that eva lu ation to Region II. Within 30 days of the date of this letter , we ask that you inform Mr. Oscar DeMiranda, in writing , the details of your eva luat ion and your find i ngs related to the validity of the information provided. If Honeywell determines a concern to be substan tiated , please discuss Honeywell's consideratio n of appropriate root or apparent causes and generic impl ications of the substantiated concern. and the appropriateness of corrective actions taken or planned commensurate w i th the significance of the issue. Additionally , if your evaluation identifies any compliance issue with regard to NRC regulatory requirements or NRC commitments, please info rm us regarding the requ irement or comm i tm ent that was violated , the corrective actions taken or planned, and the correc t ive action documenta tion that addressed the issue. We ask that you reference our tracking number (R ll-2013-A-0 100) in your written response and , also, make any records of your eva luation available for possible NRC inspec t io n. The NR C w i ll review your response t o determine whether: (a) the individual conducting the invest igation was independent of the orga nization with responsibility for the re lated functional area; (b) the evaluator has suffic i ent knowledge and experience to conduct a review in the related functional area; and (c) the evaluation was of sufficient depth and scope. Your response should describe how each of these attributes was satis fi e d. If indiv i duals were interviewed as part of your review, your response should i nclude the basis for determining that the number and cross section of individua ls interview ed was appropriate to obtain the informat ion necessary to fully evaluate the concern(s), and the int erv iew questions used. I f your evaluation included a sample review of relate d documentation and/or potentially affected structures, systems. and components, your response should include the basis for determining that the selected sample size was appropriately representat i ve and adequate to obtain the information necessary to fully evaluate the concern(s)" The NRC will consider these factors in rev ie wing the adequacy of your evaluation of th is/t hese issue(s) and in developing our conclusions w i th regard to the concerns provided in the Enclosure. CERTIFIED MAIL NUMBER ._!tb_H_7}_tc_1 _____ ___. RETURN RECEIPT REQUIRED 2 Rll-2013-A-0100 We request that your response only be sent to Mr. Oscar DeMiranda, Senior Allegat i on Coordinator.

EICS , Office of the Regional Administrator, Region II , at the following address: P. 0. Box 56274. Atlanta , GA 30343, and fax him a copy at 404-997-4 903. No other copies should be sent to the NRC , i.e., your response should not be docketed or otherwise subm i tted to the NRC Document Contro l Desk. We also request that your response contain no personal privacy, proprietary , or safeguards information.

If personal privacy or proprietary information is necessary to prov i de an acceptable response. please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld , and prov i de in detail the .bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted i nvas i on of personal pr i vacy or provide the i nformation requ ir ed by 10 CFR 2.390(b) to support a request for withholding confidential commercial or financial i nformat i on). If safeguards information is necessary to provide an acceptable response, please prov i de the level of protection described in 10 CFR 73.2 1. This letter and its Enclosure should be controlled and d i stribution limited to personnel w i th a "need to know." The response requested by this letter and the accompanying Enclosure are not subject to the clea r ance procedures of the Off ic e of Management and Budget, as required by the Paperwork Reduction Act of 1980, Pub. L.96-511. Lastly , we ask that you contact the NRC as your review effort begins , to assure a common understanding of the issues discussed in the Enclosure , and the NRC's expectations for up and response , and to discuss your plan to evaluate the issues. P l ease contact James Hickey at 404-997-4628 with this information. Any r equests for additional information or change in response date shou l d be directed to Mr. Oscar DeMiranda at 404-997-4424.

Enclosure:

As stated James . Hickey , Ch i ef Fuel Facility Inspection Branch 2 Div i sion of Fuel Facility Inspection

~,OT FOR PUBLIC DISCLOSURE HONEYWELL METROPOLIS WORKS WORKERS UNKNOWINGLY EXPOSED TO LICENSED MATER I ALS ALLEGATION NUMBER Rll-20 1 3-A-0100 T he NRC has received info r matio n t hat: Non R esponsive Record Conce rn N o. 2: Wo r ke r s d id not receive proper tra i n i ng or protection while handling h i gher activity mate r ial from Russia t o b e conv e rted into uranium hexaf l uoride (U F 5). l (b)(4) L Di d t h e mat e rial from Russ i a have

• v And if so , did it requ i re a d di t i o nal t r a i nin g t o e n s ur e p r oper h a ndling? N on Respons i ve Record f'40T FOR PUBLIC D I SCLOSURE Enclosure (b)(?)(C) 2 Rll-2013-A-0100 We request that your response only be sen t to M r. Osca r DeM i randa , Senior Allegation Coordinator , EICS , Office of the Regional Adm i nistrator , Reg i on II , at the following address: P. 0. Box 56274 , Atlanta , GA 30343 , and fa x hi m a copy at 404-997-4903. No o the r copies should be sent to the NRG , i.e., your respo n se shou l d not be docketed or otherw i se subm i tted to the NRC Document Control Desk. We a l so request th at your response conta i n no personal privacy , proprietary , or safeguards information.

If personal privacy or propr i etary informat i on is necessary to provide an accepta b le response , please provide a bracketed copy of your response that identifies the informat i on t h at shou l d be protec t ed and a redacted copy of your response that deletes such information. If you request w i t h hold i ng of such material , you must specifically identify the port i ons of yo u r response that you seek to have w i thheld , and provide in detail the bases for your cla i m of withho l d i ng (e.g., expla i n why the d i sclosure of information will c r eate an unwarranted invas i on of pe r sona J p ri vacy o r prov i de the i nformation required by 10 CFR 2.390(b) to support a req u est for w i thhold in g confidential commercial or financial information). If safeguards i nfo r mat i o n is necessary to pro vi de an acceptable response , p l ease provide the le v el of pro t ection described in 1 0 CFR 73.21. This letter and its Enclosure sho ul d be contro ll ed and d i s t r i b u tion lim i ted to personne l w i th a "need to know.~ The response requested b y th i s letter and the accompanying Enclosure are not subject to the* clearance procedures of the Office of Management and B u dget , as required by the Paperwork Reduction Act of 1980 , Pub. L.96-511. Lastly , we ask that you contact the NRC as y ou r r eview effort begins , to assure a common understanding of the issues discussed in t h e Enclosure , and the NRC's* expectations for up and response , and to d i scuss your pla n to eva l ua t e the i ssues. Please contact James Hickey at 404-997-4628 w i th th i s i nformat i o n. Any requests for additional information or change in response date sho u ld be directed to M r. Oscar DeMiranda at 404-99 7-4424. O FF ICE ~Rll: D FFI SIGNAT U RE NAME R G i b son DAT E 7/3 I /2 gJ..:l E-MAI L COPY Y E S l!W' Rll: E I CS vf ,L_ ODeMiran da fi t J /2013 YE S NO S i nce r ely , James A H i ckey , Ch i ef Fuel Fa ci lity Inspection Branch 2 Divis i on of Fuel Fac ili ty Inspect i on e,..-._OffJ. Ai ,[_A *,--,,,,. -:s'~ , t..,µ;;:.{

~J , j u,~ ,,Jo OFFICIA L RE CO RD CO P Y D OCUMEN T N A M E. G.\P RO T E C TED\ALLEGAT IO NS\DF F I\BRANCH 2\HONE YWEL L RFI L ETIER Rll-20 1 3-A-0100.DOCX RFI LICENSEE CALLBACK RECORD OF CONVERSATION Allegation Number: Rll-2013-A-

-0100 Responsible Branch: DFFI/FFB2

Background

AGM 2008*001 requires tha t the l icensee contac t t h e responsible branch chief , or other appropriate staff , to ensure common understanding of the scope of the allegation and the staff's e x pectat i ons for follow-up and response. During this d i scussion , the staff shou l d be mi n dful not to dictate specific requirements that may restrict or limit the l icensee's response. Rather , th i s dis c ussi o n is i ntended to ensure that the act i ons proposed by the licensee to evaluate the allegat i on concern (s) appear likely to result i n a product that meets the NRC's stated e x pectations and thoroughly addresses the concern(s) raised. If upon completion of th i s or subsequent discussions , it is determined that the licensee's plan of a ct i o n is unlike l y t o be successfu l, the responsible Branch Ch i ef will reconvene the ARB to cons i de r a fo ll ow-up teleph o ne call with s enior licensee managemen t, or NRC inspection activity.

A record of the conv e rsat i on w i th the li c ensee shall be included in the allegation file. Date of Phone Call: 08/02/2013 (b)(7)(C) Name of Licensee Contact: Summary of Conversation

Confirmed unders t and i ng of RFI concerns licensee's plan of action sounded reasonable

Y D N If no , please state Why: Describe any additiona l act i ons needed: N I A Re*ARB required:

D Y [8J N Prepared by: Jim Hickey Title: Branch Chief Date Prepared: 8/2/2013 Please return this to EICS (R2EICSA11eg@nrc

.gov) along with any support i ng documentation available (e.g. mail from licensee, etc.), i f any.

UNITED ST ATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE, SUITE 1200 ATLANTA , GEORGIA 30303-1257 August 1, 2013 Mr. Larry Smith Plant Manager Honeywell In ternational Inc. P.O. BOX430 Metr opolis, IL 62960

SUBJECT:

ALLEGATION NO. Rll-2013-A-0100

Dear Mr. Smith:

The U.S. Nuclear Regulatory Commission (NR C) recently received information concerning activities at the Honeywell Metropolis Works facility in Metropol is , Il lino is. We request that Honeywell evaluate the , information described in the Enclosure to th is letter and submit the results of that evaluation to Region II. Within 30 days of the date of thi s l etter , we ask that you inform Mr. Oscar DeM i randa , in writing , the details of your evaluation and your findings related to the validity of the information provided. If Honeywell determines a concern to be substantiated , please discuss H oneywell's consideration of appropriate root or apparent causes and generic implica t ions of t he su bstant iate d concern , and the appropriateness of corrective actions taken or planned commensurate with the significance of the issue. Additionally, if your evaluation identifies any compliance issue with regard to NRC regulatory requirements or NR C commitments , please inform us regarding the requirement or commitment that was violated, the corrective a ctio ns taken or planned, and the corrective a c tion documentation that addressed the issue. We ask that you reference our t racki ng numbe r (Rll-2013-A-0 100) in your written response and , also , make any records of your evaluation available for possible NRC inspection.

The NRC will review you r response to determine whether: (a) the individual conducting the investigation was independent of the organization with responsibility for the related functional area; (b) the evaluator has sufficient knowledge and experience to conduct a review in the related functional area; and (c) the evaluation was of sufficient depth and scope. Your response should descr ibe how each of these attr ib utes was satisfied.

If individuals were interviewed as part of your review, you r response should include the basis for dete r mining that the number and cross section of individua l s interviewed was appropriate to obtain the information necessary to fully eva luate the concern(s), and the interview questions used. I f your evaluation included a sample review of related documentation and/or potentially affected structures , systems , and components, your response should i nclude the bas i s for determining that the selected sample size was appropriately representative and adequate to obtain the information necessary to fully evaluate the co ncern (s). The NRC will consider these factors i n reviewing the adequacy of your evaluation of this/these iss ue(s) and in developing our conclusions with regard to the concerns provided i n the Enclosure. CERTIFIED MAIL NUMBER 7011 2000 0001 0083 4597 RETURN RECEIPT REQUIRED (b)(7)(C) 2 Rll-2013-A-0100 We request that your response only be sent to Mr. Oscar DeMiranda , Senior Allegation Coordinator, EICS , Office of the Reg i ona l Administrator, Region II , at the following address: P. 0. Box 56274 , At l anta , GA 30343, and fax him a copy at 404-997-49 03. No other copies should be sent to the NRC , i.e .. your response should not be docketed or otherwise submitted to the NRC Document Control Desk. We also request that your response contain no personal privacy, proprietary , or safeguards informat ion. If personal privacy or proprietary i nformation is necessary to provide an acceptable response. please provide a bracketed copy of your response that identifies the in formation that should be protected and a redacted copy of your response that deletes such inform ation. If you request withholding of such material , you must specifically identif y the portions of your response that you seek to have withheld, and provide in detail the bases for your claim of withholding (e.g., explain why the d isclosure of information wlll create an unwarranted invasion of personal privacy or prov i de the information requlred by 1 O CFR 2.39 0(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to p rovide an acceptable response , please provide the level of protection described in 10 CFR 73.21 This letter and its Enclosure should be controlled and distribution limited to personnel with a " need to know. The response requested by this letter and the accompanying Enclosu re are not subject to the clearance procedures of the Office of Management and Budget , as required by the Paperwork Red uctio n Act of 1980 , Pub. L.96-511 Lastly , we ask that you contact the NRC as your review effort begins, to assure a common understanding of the issues discussed i n the Enclo sure. and the NRC's expectations for followup and response, and to discuss your p lan to evaluate the i ssues. Please contact James Hickey at 404-997-4628 with this information. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424.

Enclosure:

As stated Sincerely, /RAJ James A H ick ey , Chief Fuel Facility Inspection Branch 2 Division of Fue l Facility Inspection

, I (b)(7)(C) 2 Rll-2013-A-0100 We request that your response only be sent to Mr_ Oscar DeMiranda , Senior Allegation Coordinator , EICS , Office of the Regional Adm i nistrator , Region 11 , at the following address: P. 0. Box 56274 , Atlanta, GA 30343 , and fax him a copy at 404-997-4903. No other copies stiould be sent to the NRC , i.e .* your response should not be docketed or otherwise submitted to the NRC Document Contro l Desk. We also request that your response contain no personal privacy, proprietary , or safeguards information. If personal pr i vacy or proprietary information is necessary to provide an acceptable response , please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such i nformation. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld , and provide in detail the bases for your claim of w i thholding (e.g., explain w hy the disclosure of information will create an unwarranted invasion of personal privacy or provide the i nformation required by 10 CFR 2.390(b) to support a request for w i thholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response , please provide the level of protection descr i bed in 10 CFR 73.21. This letter and its Enclosure s ho uld be controlled and distribution limited to personnel with a "need to know." The response requested by this letter and the accompany i ng Enclosure are not subject to the clearance procedures of the Office of Management and Budget , as required by the Paperwork Reduction Act of 1980 , Pub. L.96-511. Lastly, we ask that you contact the NRC as your review effort beg i ns , to assure a common understanding of the issues discussed in the Enclosure , and t he NRC's expectations for up and response , and to discuss your plan to evaluate t he issues. Please contact James Hickey at 404-997-4628 with this informat i on. Any requests for additional information or change in response date should be directed to Mr. Oscar DeMiranda at 404-997-4424 OFFICE R ll: OFFI SIGNATURE I RA/ NAME RG i bs on DATE 7/ 3 1 /2 0 13 E-MAIL COPY YES NO R ll: E I CS C Eva n s fo r O DeM lr a nda 8/1/20 1 3 Y ES N O S i ncerely , IRA/ James A. Hickey , Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection OFFICIAL RECORD COPY DO C UMENT NAME_ G:\P R OTEC T ED\ALLEGATIONS\DFFI\BRANCH 2\HONEYWELL RFI LETTER R ll-2013-A-0 10 0.DOCX

• N O T FOR P U BLIC DISC L OSURE HONEYWELL METROPOLIS WORKS WORKERS UNKNOWINGLY EXPOSED TO LICENSED MATERIALS ALLEGATION NUMBER Rll-2013-A-0100 T he NRC has received information that: Concern No. 1: In the mid 90's workers were unknowingly exposed to Plutonium and Neptunium wh il e processing green salt from the Fernald Department of Energy (DO E) facili t y. Determine if a Plutonium and N eptunium hazard resulted from process i ng green salt from the Ferna l d DOE facility. I f so , were workers properly tra i ned for those hazards? Were there any exposure events involv i ng Pluton i um and Neptunium?

I f so , what were the levels and results? Concern N o. 2: Workers did not rece i ve proper tra i n i ng or protect i on while handling higher activity material from Russia to be converted i nto uranium hexafluor i de (UF a). Did the materia l from Russia have h igher activity?

And i f so , did it require addit i onal train i ng to ensure proper handling?

Concern No. 3: The railcars stored on-s i te for transfer of anhydrous hydrofluor i c acid (AHF) to the Feed Materials Build i ng are not proper l y configured w i th a rel i ef system in the event of an pressurization and are not connected to a scrubber system. What features are required and/or available for ra il cars stored onsite wh i ch may be subjected to an over pressurization event? Concern No. 4: In the mid 90's individuals were not required to monitor out of the facility and cou l d have been spread i ng contam i nation offs i te. One ind i vidua l was noted to have gone home contam i nated. Prov i de information regarding offs i te contam i nat i on event(s) and corrective actions resulting fr om any event(s) which occurred in the mid 90's. NOT FOR PUBLIC D I SCLOSURE Enc l osure

,.. -100 Checkle , Melanie (b)(5) 1 CheckJe, Melanie lb)(5) 13 ,too

{~!Ji ' . James Hickey Chief, Fuel Facility Inspection Branch 2 Reg i on II 404-997-4628 l (b)(7)(C) I James.H icke y@nrc.gov 2

\j -\00 Checkle, Melanie From: Hickey, James Sent: Wednesday , December 04 , 2013 6:52 AM To: R2Allegations Resource; (heckle, Melan ie \OO

Subject:

Update: Vo i cemail from O regarding closure letter. Ril-2013-A~~ ~(b}(7)(C) I received two voicemails from the C l while I was out of the office on 12/4. I will give the Cl my cell phone# to call me when he gets off work. Regards, Jim

• From: Hickey , James Sent: Monday, December 0 2 , 2013 2:59 PM To: R2ALLEGATIONS

@NRC.GOV; Checkle, Melan ie

Subject:

Voicemail from a regard i ng closu re lette r. RII-2013-A

-2013 I received a v oicema il on 11/29/20 13 from the Cl. It appears he has questions regarding our closure letter. attempted a callback th is morn i ng and left a voice message. Regards , Jim James Hickey Ch ief, Fuel Facility Inspection Branch 2 Reg i o n II 404-99 7 -4628 l (b)(7)(C) I J ames.Hickey@nrc.gov l

Checkle, Melanie From: Sent: To:

Subject:

G i bson , Richard Th u rsday, Au g ust 22, 2013 2: 01 PM (heckle , Melanie RE: Ril-2013-A-0100 (Sensi t iv e Allegation Mater i al I've ju s t called h i m , and he was appreciative. Richard From: Checkle, Melanie Sent: Thursday, August 22, 2013 1:57 PM To: Gibson, Richard

Subject:

Re: Ril-2013-A-0100 (Sensitive Allegation Material If you know the status, yo u can give h im a call. All you have to tell him is that the concerns are still under review and that we are awaitin g the re sponse to our re ques t for information from the licensee.

That's pretty much all we can tell him at this poin t. Thank s. Melanie, (b)(7)(C) called me and le ft a message. He wanted to know the status of his concerns.

He can be con ac e at: Do you w i sh to con t act hrm? Or , do you want me to contact h i m? We have an RFI to the licensee that is due by August 30 , 20 1 3. r an Responsive Record Concern 2: Workers did not receive proper tra in ing o r protect ion while handling._!(b-)(4_l ______ _.L. f °" R~po,oi" R~o, d R i chard 1 Checkle, Melanie From: Checkle , Me l anie Sent: Thursday, August 01, 2013 1:26 PM To: Cc: H i ckey , James; Peterka, N ic holas; Gibson, Richard; DeM iranda , Oscar Evans, Carolyn

Subject:

RE: 13-100 Concern 4 -Phone Call from Q #1 *SE NS IDV E INFORMATION*

Thanks Jim. When closing Concern 4 with Cl #1 , please make reference to my conve r sation with him yesterday a nd what I explained to him (t hat we would review the information but would make a determination of whether or not we needed t o followup). I just don't want him to fe e l l ike we just ignored his reques t. Jrt.e[anie

<M.. CliecfiJe Allegation Coordinator Enforcement and Investigation Coordination Staff U.S. Nuclear Regulatory Commission 404.997.4426

• If this emai l contains sens itive allegation information , please delete when no longer needed.* From: Hickey, James Sent: Thursday , August 01, 2013 7:16 AM To: Peterka, Nicholas; Checkle, Melanie; Gibson, Richard; DeMiranda, Oscar Cc: Evans, Carolyn

Subject:

RE: 13-100 Concern 4 -Phone Call from CI #1 *S ENSffiVE I NFORMATION

• We will inc lude co ncern #4 in our RFI. From: Peterka, Nicholas Sent: Wednesday, July 31, 2013 11:07 AM To: Checkle, Melan i e; Hickey , James; Gibson, Richard; DeMiranda, Oscar Cc: Evans, Carolyn

Subject:

RE: 13-100 Concern 4 -Phone Call from Q #1 *SE NSITIVE INFORMATION*

Melanie , r i (7 i(C J Nick From: Checkle, Melanie Sent: Wednesday, J uly 31, 2013 10:48 AM To: Hickey, James; Gibson, Ric h ard; DeMiranda, Oscar Cc: Evans, Carolyn; Peterka, Nicholas

Subject:

13-100 Concern 4 -Phone Call from CT #1 *SENSI11VE INFORMATION

• FFB2 and Oscar , l Non Res po ns i ve Record 2 Checkle, Melanie From: Gibson, Richard Sent: To: Fr iday, July 12, 2013 10:09 AM Checkle, Melanie

Subject:

RE: !!!!!WA RN ING -S~f4.!!Ffh'E ALLE6A"FIOP4 P.V.;;i;:EFY,.O.b!!!!

! Yes. {b J(7)(C) Richard From: Checkle, Melanie Sent: Friday, Ju ly 12, 2013 9:5 4 AM To: Gibson, Richard

Subject:

RE: !!!!!WARNING. SENSR=I'IE ALL[GA.+.[Q~I MA+ilaYAI..

!!!!! H~H. C!Wd.t ~MJ.k-l/~~~

U.S. N<<dl#> R~ 404.1fl.4426 "If this email contains sensitive allegation information , please delete when no longer needed.*' From: G i bson, Richard Sent: Thursday, July 11, 2013 3:30 PM To: R2EICS Cc: Checkle, Melan ie

Subject:

FW: !!!!!WARNING-

~-~l~Wl'E Al I FGAJTQN MAJFRTAU!!

!! Let me know if you need additional info. From: Peterka, Nicholas sent: Thursday, July 11, 2013 3:05 P M To: Gibson, Richard

Subject:

! ! ! ! !WARNING -~NSl I IVE ALLE6,;i;JQ~I MAIER JAL I.LJ.! ! Richard, As discussed, leas e see the attached documents.

The Part 1 and 2 documents capture th e concerns and the last document (b)(7)(C i contact information. Thanks for submitt i ng i t and rev i ewing the concerns.

Nick Pete rka Nicholas Peterka USNRC Region It Divis i on of Fuel Facilit y Inspection Fuel Facility Insp ector, B ran ch 3 1 404-997-4556 2

COMPLETE THIS SECTION

• Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery I s desired.

• Print your name and address on the reverse so that we can return the card to you.

• Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 2. , Number ft,_..,7bf' from service label) COMPLETE rHIS SECTION ON DELIVERY D. Is delivery address different from item 1? If YES, enter deliveiy address below: 3. Serl9C8lype

• c92)l3--:.

-c G,1'6ertlfled Mall O Express Mell D Regist81'8d O Return ReceJpt for Mffl:handlse 0 Insured Mail O C.O.D. 4. Restricted Oe Uveiy? (Extra Fee) 0 Yes : PS Form 3811, February 2004 1 Domestic Return Receipt 102595-02-M-1640

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEAC H T REE CENTER AVENUE NE, SUITE 1200 ATLANTA, GEORGIA 30303-1257 October 21, 2013

SUBJECT:

CO NCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100 Dear!(b)(7)(C)

I: The Nuclear Regulatory Comm i ssion (NRC) has com leted i ts follow u se to Concern brought to o~u~r.!;: a~tt~e!.!.nt~io~n~(~bJ~( :;.J c..:.1 ___________

......_._1 (b)( )( ) re rding: Non R esponsive Record r.;..,=~---~~------------.,..

e enc osure o 1s etter restates your concerns and descr i bes the NRC's review and conclusions with regard to those conce rns. Thank you for informing us of your concerns. We believe that our actions i n this matter have been respons ive. Clos ure of an allegation does not prevent us from revi siti ng a concern , espec i ally if we obtain new informat i on. Allegations are an important source of informat i on i n support of the NRC's safety mission. We take our safety responsibil i ty to the public seriously and will continue to do so within the bounds of our lawful authority. Unless the NRC receives additional informa t io n that suggests that our conclusio ns shou l d be altered, we plan no further action on this matter. Should you have any additional questions or if I can be of further assistance in th i s matter , please call me toll-free at 1-800-577-8510 ext. 4628 or you may prov ideinfo rmation to me in writing at P.O. Box 56274 , Atlanta , GA 30343. .,,, *7

Enclosure:

As stated CERTIFIED MAIL NUMBER 1...l (b_l(_,,_(c_, _____ __. RETURN RECEIPT REQUESTED

( ' Non Responsive Recoro RESPONSE TO CONCERN HONEYWELL METROPOLIS WORKS ALLEGAT I ON NO. RU-2013-A-0100 . Enclosure

'

2 Rll-2013-A-0100 No n R es pon s i v e R eco r d Concern 2: Workers did not receive proper training or protection while handling Ll (b_Jc_4' ______ ___.!from Russia to be converted into UFa. Background Information

You stated that workers were exposed to!(b~(4; !when they began processing drums of material from Russ i a. You also s a ed th at th e workers did not received additional training or personal protection equipment to han dle the!Cb)C 4 l I Response to Concern: The NRC requested that MTW evaluate and respond to the concern , and the NRC inspector reviewed the response. Ho neywell selected an Jndependent lnvesti ator which erform d interviews with the MTW b) 7 (C) i.:.(b.:.:.)(7..:.)(:_C;..J --------r-~------' (bJ(7J(CJ . According to the (b)(7)(C) shipments of ore concentrates from the form er So , ie t republics c;C b~l(~4 l:._ _______________

__. !(b)(4 J J However , ore concen trates from the former S v* can have (b)(4 J (b)(4 J e ore concentrates are still , however, classified as natural uranium. The investigator reviewed records and interviewed personnel and determined that the ore concentrates from the former Soviet republics do not require additional worker training or safety measures to ensure proper handling.

As natural uranium , the activity concentrations of ore concentrates from the forme r Soviet republics remain below leve ls that would warrant additional training or safety measures beyond those a l ready in place at MTW.

Conclusion:

The NRC has not observed a~y problems wjt h 1 oneywell's workers re ceiving proper training or protection while handling !(b Jt 7 J(c J from the former Soviet repub lics to be converted into UFs. The NRC i nspector was unable to substantiate the concern. Non R es pon s i ve R eco r d Enclosure 3 Rll-2013-A-0100 N on Respo n sive Rec,rrd Enclosure I f 4 Rll-2013-A-0100 No n R es p o n s i ve R ecord Enclosure OFFICE October 21 , 2013

SUBJECT:

CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS -ALLEGATION Rll-2013-A-0100 Dear j!b)(7)(C) j: No n Responsive Record N on Respons i ve Record The enclosure to this letter restates your concerns and describes the NRC's review and conclusions w i th regard to those concerns.

Thank you for informing us of your concerns. We believe that our actions in this matter have been responsive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obta i n new information.

Allegations are an important source of information in support of the NRC's safety mission. We take our safety responsib i lity to the public seriously and will contin ue to do so with i n the bounds of our lawful authority. Unless the NRC rece i ves additional informat i on that suggests that our conclusions should be altered , we plan no further action on this matter. Should you have any additional questions or if I can be of further assistance in th is matter , please call me toll-free at 1-800-577-8510 ext. 4628 or you may provide i nformation to me in writing at P.O. Box 56274, Atlanta, GA 30343.

Enclosure:

As stated 5/t}J, Y , James A. Hickey, Chief Fuel Facility Inspection Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER .... !lb_}(_7)_(c_, _____ __ RETURN RECEIPT REQUESTED RII: DFFI Rll;EICS tt,~fr SIGNATURE

//1/-;,d NAME RGibson DATE 10/ /2012 E-MAIL COPY? YES NO OFFICIAL RECORD COPY 2 Rll-2013-A-0100

.DOCX ODeMiranda 13' r-r. ,.., _1.c/ 10/ /2012 101-i, /2013' 10/ /2 013 10/ /2013 10/ /2013 10/ YES NO YES NO YES NO YES N O YES NO YES DOCUMENT NAME: G:\PROTECTED\ALLEGATIONS\DFF I\BRANCH 2\LETIER TO ALLEGER /2013 NO OFF I CE r b)(7)(C)

SUBJECT:

CONCERNS YOU RAISED TO THE NRC REGARD I NG HONEYWELL METROPOLIS WORKS -ALLEGATION Rll-2013-A

-0100

Dear!(b){7)(C) I:

The Nuclear Regulatory Commiss i on (NRC) has completed its follow u review in response to Concerns 1-4 ou initially brought to our attent i on {b l(7 l(Cl {b){ )(C) re ardin '. ""'N-on..,.R.-es-p-011...,.si v-e""'R-ec-or""'d ------------

---

. Non Responsi v e Record 2) worke r s did no t receive proper t r a i ning or p r otect i on while handling (b)(4) ~~---""'--i from Russ i a to be converted into UF e , Non Responsi v e Rec o rd N o n R e sponsi v e Record Non Responsi v e Record e enc OSUre O IS e er res a es your concerns an descr i bes the NRC's rev i ew and conclusions w i th regard to those concerns. Thank you for informing us of your concerns. We bel i eve that our actions in th i s matter have been responsive.

Closure of an allegation does n ot prevent us fro m revisiting a concern, especially if we obta i n new information.

Allegat i ons are an important source of information in support of the NRC's safety mission. We take our sa f ety responsibility to the public seriously and wi ll continue to do so w it h i n the bounds of our lawfu l autho r ity. Unless the NRC receives addit i onal informat i on that suggests that our conclus i ons should be altered , we plan no further action on th is matter. Should you have any add i tional questions or if I can be of further assistance i n this matter, please call rn e toll-free at 1-800-577-8510 ext. 46 2 8 or you mqy provide i nformat i on to me in writing at P.O. Box 56274 , At l anta , GA 30343. E n closu r e: As stated S i ncerely , James A Hickey, Chief Fuel Fac ili ty Inspect i on Branch 2 Division of Fuel Facil i ty Inspect i on CERTIFIED MAIL NUMBER~)(?)(C 1 RETURN RECEIPT REQUE s-=., r""" e--0-------.... R II* DFFI RII: EICS S I GNAT U RE iD t725Y1 NA ME RGlbson DATE 10/2)/2012 E-MAI L CO P Y? YES fN97 OFF J C I AL R ECORD COPY 2 Rll-2013-A--0100.00CX OOeMlranda 10/lf/2012 10/ /20 13 10/ /2013 10/ /2013 10/ /2013 10/ YES NO YES NO YES NO YES N O YES N O YES DOCUMENT NAME: G:\PROTECTEDIALLEGATIONS\DFFI\BRA N CH 2\LE n E R TO AL LE G E R /2013 NO II : COMPLETE THIS SECTION

• Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired.

• Print your name and address on the reverse so that we can return the card to you.

• Attach thls card to the back of the mallpiece, or on the front If space permits. 1. Artlcle Addressed to: 2 i ~, .. _...__ COMPLETE THIS SECnON ON DELIVERY D Agent , D Addre ssee 1

• Date of Delivery ' D. Is delvery address different from Item 1? D Yes If YES, enter dellvery address below: D No 3. sepl(ce lype ef' Oertllled Ma11 a Express Ma11 D Reg181ie,&d a Return Receipt for Merchandise I 0 lnsun,d Mail Cl C.O.D. 4. Restricted Dellvery? (Extra Fee) 0 Yes PS Form 3811. February 2004 Domestic Return Rece ipt )ll.25 9S-02*M*1540 r b)(7)(CI UNITED STA TES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE , SUITE 1200 A T LANTA , GEORGIA 30303-1257 July 25 , 2013

SUBJECT:

Concerns You Raised to the NRC Regard i ng Honeywell

-Allegation Report Rll-2013-A-0100 Dea d (b)(7)(C)

!: This letter ref r to

• sion (NRG staff members (bl(7 l(C Ourin (b l(7 l(Cl (b)(7)(CJ you expressed concerns related to several i ssues at Honeywell. (b)(7)(CJ (b)(7)(C) (b)(7)(C) Enclosure 1 to this letter documents your concerns as we understand them. We have initiated actions to evaluate your concerns and will inform you of our findings.

The NRG normally conducts an evaluation of a concern with i n six months, although complex issues may taKe longer. If the description of any of your concerns. i dentified as Concerns 1. 2, 3 and 4, as noted in Enclosure 1 is not accurate , please contact me so that we can assure that your concerns are appropriately described and adequate\y addressed prior to the completion of our review, As part of our response to Concern 1 , 2, 3, and 4 , we intend to request Honeywell to perform an evaluation and provide a written response to the NRC. Your name and any other identify i ng information w,11 be excluded from the information that is provided to Honeywell in the request for information.

We will request that Honeywell's evaluation be thorough , obiective, and that the evaluator be independent of Honeywell management responsible for oversight of the functional area re la ted to your concerns. We will evaluate Honeywell's response, and consider it in developing our conclusions regarding your concerns.

We will inform yo u of our disposition once we have evaluated Honeywell's response and taken any additional actions , if necessary , to address your concerns. In your conversation with Mr. Nicholas Peterka, NRC staff member, on !(b)(7lCCJ

l. you indicated that you would not object to the NRC requesting information from the licensee with regard to your concerns. Enclosed with this letter is a brochure entitled "Reporting Safety Concerns to the NRG ," which includes an import ant discussion of the identity protection provided by the NRG regarding these matters as well as those circumstances that limit the NRC's ability to protect an alleger's identity, such as this case. Please read that section of the brochure.

If a request is filed under the Freedom of Info rmation Act (FOlA} related to your areas of concern , the inforn:iation provided will, to the extent consistent w i th that act, be purged of names CERTIFIED MAI L:l[b)(?)(C)

RETURN RECEIP"" T"""'R"""'E ... Q ..... U""" E ..... S ... TE.,....D------------------

2 Rll-2013-A

-0100 and other potential identifiers. Further , you should be aware you are not considered a confident i al source un l ess confidentiality has been formally granted i n writ i ng. Thank you for notifying us of your concerns. We w i ll adv i se you when we have completed our rev i ew o f C o ncerns1 , 2 , 3 and 4. Should you have any add i tional questions , or i f the NRC can be of further assistance, please call me at the regional office toll-free number 1-800-577-8510 extens i on 4426 or you may provide information to me in writ i ng at P. 0. Box 56274 , Atlanta, GA 30343. You may also communicate with me by electronic mail , if you so choose. However , when doing so. p l ease call me i n advance or prov i de your phone number in you r e-mail message so that she can conf i rm that you are the source of the information. Also. please be advised that the NRC cannot protect the information during transmission on the Internet and there is a possibility that someone could read your response while it i s i n transit. My e-mail address is Melanie.Checkle@nrc

.gov Enclosures

As stated Sin~1[elr, ?--z.,_ Melan i e M. Checkle Allegations Coordinator Enforcement and Investigations Coordinat i on Staff Enclosure 1 Rll-2013-A

-0100 HONEYWELL STA T EMENT OF CONCERNS No n Responsi v e Record Concern 2: Workers did n ot receive p r oper training or protection while handling!(b)(4) I f rom Russia to be converted i nto UF6. ...._ ______ ___. No n Respo n si v e Record Er : COMPLETE THIS SECTION

• Complete Items 1, 2, and 3. Also comp l ete Item 4 if Restricted Delivery i s des i red.

• Print your name and address on the reverse so that we can return the card to you.

• Attach this card to the back of the ma i l p iece , or on the front if space permits. 1. Article Addressed to: (b)(?)(C) 2. { Number (b)(?)(C) (i.. . .,,'er from service label) COMPLETE THIS SECTION ON DELIVERY B. Received by ( Printed Name) D. Is delivery address different from Item 1? I f YES , enter dellvery address below: 3. ~Cl;? Type -c)Q/ .j-jl--<.. Q.Cei-tifled Mall O Express Mail D Registered O Aetum Receipt for Merchandise D Insured Man D c.o.o. 4. Restricted Delivery? (Extra Fee) D Yes ; PS Form 3811 , February 2004 Domestic Return Receipt 102695-02-M-1540

]

(b)(7)(C)

UN IT ED STATES NUCLEAR R EGULATOR Y COMMISSION REGION II 245 PEA CH TREE C EN T ER AVENUE NE. SUITE 1200 ATL ANTA , GEORG I A 303 03-12 57 October 21 , 2013 SU B J E CT: CONCERNS YOU RAISED TO TH E NRC R E GARDING H ONEYWELL M ET ROPO LI S WORKS -AL L E GA T ION R ll-2013-A-0100 Dear (b)(7)(C) The Nu c le ar Regulatory Commiss i on (NRC) has com lete d its follow u review in res onse to Concerns 1-4 ou initial! b r o ught to o * ..:: u:.:.r.;;;a:.:.: tt:.::: e.:.:.nt.:.:.: io::.: n.:.1,...(b_l (7-l (_c ___________

..,__ _ __, (b)(7)(C regarding: N o n R e sp o n si v e R eco rd N o n Re s p o n s i ve Rec o rd N o n R es p o n s i v e Re c o r d The En cl osure to this l etter restates your concerns an d descri b es the N RC's review and c onclus i on s wit h regard to those concerns. Thank you for informing us of yo u r concerns. We believe that our actio n s in this matter have b ee n respo n sive. Closure of an allegation does not prevent us from revisiting a concern, especially if we obtain new informa t ion. A ll egations are an important source of i nformat i on in support of the NRC's safe t y mis si on. We ta k e our safety responsibility to the pub l ic se r ious l y an d will continue to do so with i n the bounds of o u r l awful au t hority. Un l ess the N R C receives add i tio n a l information that suggests that our conclusions should be a l te r ed , we plan no fu rth er action on this matter. Shou l d you have any additional questions or i f I c a n be o f further assis t ance i n this matter, plea s e call me to ll-free at 1-800-577-8510 ext. 4628 or you may A :evti i~formation to me in w r iting at P.O. Box 56274 , A t l a n ta, GA 30343. E n closur e: As stated CERTIFIED MAIL NU M BE Rl 1-~b_)(_7)_(C_) --------'

RETURN RECEIPT REQUEST ED Concern 1: RESPONSE TO CONCERN ALLEGATION NO. Rll-2013-A-0100 Workers were unknowingly exposed to Pluton ium and Neptunium in the mid-90's wh i le processing green salt from the Fernald Department of Energy (DOE) facility.

Background Information

You stated that during the mid-90s , Honeywell or at the time AlliedSignal.

processed green salt from the Fernald DOE site which was contaminated with plutonium and neptunium. The . workers were not informed they were processing anything other than normal green salt and were told by the analytical lab they were handling green salt co n taminated with traces of plutonium and neptunium. You also stated that you confronted management and demanded to be tested , but was told you would have to go to Oak Ridge National Lab (ORNL) for the testing, and you were never sent for testing. Response to Concern: The NRC requested that the Honeywell Metropolis Works (MlW} evaluate and respond to the concern , and the NRC inspector reviewed the response. Honeywell selected an Independent Investigator who, through reviews of historical documents , including correspondence with the NRC, compiled a regulatory history relating to shipments of green salt from the Fernald DOE facility. The investigator determined that according to AJliedS i gnal's July 17, 1998 letter , analyses of nine lots of green salt by two separate laboratories showed results consistent with natural (un-i rrad ia ted) green salt. Seven lots had less than the minimum detectable concentrations (MDC) of pluton i um based on results from both laboratories.

Therefore, AlliedSignal concluded that UF4 (g reen salt) from FERMCO (Fernald, Ohio), was not contaminated with plutonium and that any in dicat ion of contaminatio n was likely the result of labo ratory error or other ana l ytica l issues. AlliedSignal also affirmatively stated that there was no contamination of the facility.

In an NRC August 5 , 1998 letter , the NRC agreed that based on the information in AlliedSignal

's July 17, 1998 letter , the pluton i um was at m i nimum detectable concentrations in the FERMCO green salt. The NRC concluded that the green salt material analyses were consistent with natural material and that the FERMCO gree n salt could be processed under the MTW l icense without amendment.

Based on a review of the MTW correspondence , the NRC conc ludes that there were no plutonium or neptunium hazards resulting from green salt received from the Fernald facility. Extensive laboratory testing indicated that green sa l t from Fernald did not contain plutonium or neptunium i n analytically significant quantities. The NRC agreed w i th AlliedSignal in the August 5th letter that there were no special hazards assoc i ated with the FERMCO green salt , no additional training was needed, and nor were there any exposure events.

Conclusion:

The NRC has not observed any problems with Honeywell processing green sa,lt from the Fernald DOE faci l ity in the mid-90s. The NRC inspector was unable to substantiate the concern that workers were unknowingly exposed to plutonium and neptunium in the mid-90s while processing green sa l t from the Fernald Department of Energy facility.

Enclosure 2 Rll-2013-A-0100 Concern 2: Workers did not receive proper training or protection whi l e handling h i gher activ i ty mater i a l from Russia to be converted into UF 6. Background Informat i on: You stated that workers were exposed to higher activity material when they began processing drums of material from Russia. You also stated that the workers did not received add i tional training or personal protection equipment to handle the higher activity material.

Response to Concern: The NRC requested that MlW ev~luate and respond to the concern , and the NRC inspector reviewed the response.

Honeywell selected an Independent Investigator which performed interviews with the MlW Site Services Manager responsible for the process for receiving and sampling of incoming material.

According to the S i te Services Manager , shipments of ore concentrates from the former Soviet republics typically have activity levels that are comparable to shipments from other l ocat i ons. However , ore concentrates from the former Soviet republics can have higher activity concentrat i ons due to the relatively higher percentage of uranium in the concentrates. The ore concentrates are st i ll , however , classified as natural uranium. The i nvestigator reviewed records and i nterviewed personnel and determined that the ore concentrates from the former Soviet republics do not require additional worker training or safety measures to ensure proper handling. As na t ural uranium , the activity concentrations of ore concentrates from the former Soviet republ i cs remain below l evels that would warrant additional training or safety measures beyond those already i n place at MlW.

Conclusion:

The NRC has not observed any problems with Honeywell's workers receiving proper training or protection while handling higher activ i ty mater i al from the former Soviet republ i cs to be converted into UFs. The NRC i nspector was unable to substantiate the concern. Concern 3: The railcars stored onsite for transfer of Hydrogen F l uoride to the Feed Materials Building are not proper l y configured with a relief system i n the event of an over-pressurization and are not connected to a scrubber system. Background Information:

You stated that you were concerned that the rai l cars containing Hydrogen Fluoride stored onsite are not properly configured w i th an over-pressurization relief system. You further stated that your concern is that during a fire or other event wh i ch could result in the pressurization of the tank car, the pressure within the car would build to the point of rupturing resulting in an uncontrolled release of mater i al.

3 Rll-2013-A-0100 Respgnse to Concern: The NRC requested that MTW evaluate and respond to the concern , and the NRC inspector reviewed the response. Honeywell selected an I ndependent Investigator which reviewed the specifications and safety features of railcars that contain Anhydrous Hydrogen F l uoride (AHF) when stored onsite and conducted interviews with personnel regard i ng AHF storage. The i nvestigator determined from interviews and rev i ews that AHF i s shipped in railcars that meet or exceed the Department of Transportation specifications , i ncluding specifications requiring relief valves. Railcars approved for the transport of AHF have relief valves set at a pressure that ensures a substantial margin between the pressure relief valve and the vapor pressure of the AHF i n the railcar. While being stored at MTW. the railcar is not connected to a scrubber system. However , a scrubber system i s not necessary because the railcar is des i gned to withstand pressure significantly in excess of the vapor pressure of the AHF in the railcar.

Conclusion:

The NRC has not observed any problems w i th AHF railcars onsite for storage and transfer of AHF to the Feed Materials Building.

The NRC i nspector was unable to substantiate the concern that raifcars stored ons i te for transfer of AHF to the Feed Ma t er i als Building are not properly configured with a relief system in the event of an over-pressurization arid need to be connected to a scrubber system. Concern 4: In the mid~90's , individuals were not required to monitor out-of the facility and could have been spreading contaminat i on offsite. Cl knows of one i ndividual who went home contaminated. Response to Concern: The NRC requested that MTW evaluate and respond to the concern , and the NRC inspector rev i ewed the response. Honeywell selected an lndepender:it Investigator who reviewed records related to historical plant practices and any i nci d ents of offsite contamination dur i ng the mid-90s. The i nvest i gator also conducted an i n t erv i ew w i th the Regulatory Affairs Manager, formerty the Health Physics Superv i sor at MTW. The investigator determined from i nterv i ews and rev i ews that as far back as 1986 , MTW license required that persons working in controlled UF 8 process areas perform exit monitoring.

Persons who did not work i n process areas were not requ i red to perform exit monitoring.

However , in the mid-90s , MTW changed practices to requ i re that all persons exiting the Restricted Area (i.e., the a r ea within the inner secur i ty fence) perform exit mon i tor i ng. This was required in Section 3.2.1 of the ficense applicat i on , dated July 11 , 1994. The i nvestigator also determ i ned from the Health Ph y s i cs techn i cian l og books for the per i od between February 1995 and October 1999 identified 45 contamination events at the ex i t monitor. In all cases , the employee was decontaminated p r ior to leaving the facility. While MTW at one t i me required exit monitoring on l y for personnel working i n process areas , by the mid-90s all persons leaving the Restricted Area o f the site were required to perform exit monitoring. Also, no records or reports were found by the i nvestigator of offsite contaminat i on during the mid-90s.

4 Rll-2013-A-0100

==

Conclusion:==

The NRC has not observed any problems with the personnel monitoring requirements at MTW. The NRC inspector was unable to substantiate the concern that, in the mid-90's , individuals were not required to monitor out of the facility and cou l d have been spreading contamination offsite. t TF OFFICE r b)(7)1C J October 21 , 2013 SUBJECT~ CONCERNS YOU RA I SED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100

Dear j (b)(7)(C) t ~~---...i;;;,

, workers d1 not rece i ve proper training or protection while handlin (b l(4 i from Russia to be converted in to UF5, Non Respons i ve Reco r d Non Respons i v e Rec or d describes the NRC's review an Thank you for informing us of your concerns.

We believe that our actions i n this matter have been responsive. Closure of an a ll egation does no t pre v ent us from revisiting a concern, especially if we obtain new info rmation. Allegations are an important source of informa tion in support of the NRC's safety m i ss i on. We take our safety respons i bility to the public seriously and will cont i nue to do so with in the bounds of our lawful authority.

Un less the NRC receives additional information that suggests that our conclusions shou l d be a lt ered , we plan no further act i on on this matter. Shou l d you have any additional questions or if I can be of further assis t ance in th i s matter , please call me toll-free at 1-800-5 77-85 1 0 e xt. 4628 or you may provide informatio n to me in writ i ng at P.O. Box 56274 , Atla n ta , GA 30343.

Enclosure:

As stated Sincerely, J,mckey , Chief Fue l Facili t y Inspection Branch 2 Divis i on of F uel Fa cility Inspect i on CERTIFIED MAIL NUMBER ~)(/)(C) RETURN RECEIPT REQUES°T~E""'b ,__ ______ _. Rll:DFF I Rll: EICS Rll: DFFI SIGNATURE NAME RGibson DATE 10/ /2013 E-MAIL COPY? YES NO OFFICIAL RECORD COPY Rll-2 0 13-A-0 100.DOCX ODeMiranda JHickey 10/ /2013 10/ /20 13 10/ /2013 1 0/ /2013 10/ /2 01 3 10/ YES NO Y E S NO YES N O YES NO YES NO YES DOCUMENT NAME: G*\PROTECTEOIALL E GATIONS\DFFI\BRA N CH 2\LETIER TO ALLEGER /2 013 NO OFF I CE

SUBJECT:

CONCERNS YOU RAISED TO THE NRC REGARDING HONEYWELL METROPOLIS WORKS-ALLEGATION Rll-2013-A-0100 Oea d (b)(7)(C) l: The Nuclear Regulatory Commission (NRC) has com p leted its follow u p review in res p onse to Concerns 1-4 ou i nit i ally brought to our attention!(b)(7)(CJ I (b)(7)(C) re ard i n : Non Responsi ve Record Non Respo n sive Record ~il,l_l,j,l..

---1,..;2;..{workers did no t receive proper trainin or protect i on wh i le handlin (bJ(4) rom Russia to be converte_d i nto UF s, Non Responsive Re co rd Non Respons i v e Record he Enc OSUre to I S et e r r estates your concerns and describes the NRC's review and conclusions with rega r d to those concerns.

Thank you for inform i ng us of your concerns. We bel i eve that our act i ons i n this matter have been responsive.

Closure of an allegation does not prevent us from revis i ting a concern , especially if we obtain new information. Allegations are an i mportant source of i nformation in support of the NRC's safety mission. We take our safety responsib i lity to the public ser i ous l y and will continue to do so w i thin the bounds of our lawful authority. Unless the NRC receives additional i nformation that suggests that our conclus i ons should be altered , we plan no further action on this matter. Should you have any additiona l questions or if I can be of further assistance in this matter , please ca ll me toll-free at 1-800-577-851 O ext. 4628 or you may provide information to me in writing at P.O. Box 56274 , Atlanta , GA 30343.

Enclosure:

As stated Sincere l y , James A. Hickey , Chief Fuel Fac i li t y Inspect i on Branch 2 Division of Fuel Facility Inspection CERTIFIED MAIL NUMBER!(b)~7J(C1 RETURN RECEIPT REQUES'!::o.TE=o---------'

/' R!l: DFF I Rll: ElCS R ll:¢J 1, SIGNATURE

_If\ /JDl'f J (7/~ NAME RGibso n DATE 1 0 ft.l /2013 E-MAIL COPY? YES (FI O -OFF I CIAL RECORD COP Y Rll-201 3-A-0 1 00.DOCX ODeM i ran d a ,)fllitt<e r 10/<) /2 013 1 0/ /2 0 13 1 0/ /201 3 1 0/ /2013 10/ /20 1 3 1 0/ YES NO YES NO YES NO Y E S NO YES NO YES D OC UMENT NAME: G: IP ROTECTEDIALLEGAT I ONS\OFFI\BRANCH 2\LETTER T O ALLEGER /201 3 NO

• Complete Items 1, 2, and 3. Also complete Item 4 if Restricted Oellvery rs des/Md.

• Print your name and address on th e rev e rse so that we can return th.e card to you.

• Attach this card to the back of the mallplece , or on the front if space pe,mlts. 1. Artlcl e Addressed to: (b)(7)(C) 2 (_ l (b.)(?)(C) COMPLETE THIS SECTION ON DELIVERY 3. a Express Mall 0 Retum Reoelpt for Merchandise

• DYes PS Fomt 3811 , F e bruary 2004 i::>omes1l c Return Receipt 102595-02-M*1S40 1a-100'D J Mr. Howard Cook 4628 Orchard Road Metropolis , IL 62960 UNITED STATES NUCLEAR REGULATORY COMMISSION REGION II 245 PEACHTREE CENTER AVENUE NE , SUITE 1200 ATLANTA, GEORGIA 30303-1257 July 25, 2013

SUBJECT:

Concerns You Raised to the NRC Regarding Honeywell

-Allegat i on Report Rll-2 013-A-0100

Dear Mr. Cook:

This letter refers to your conversation with U.S. Nuclear Regulatory Commission (NRC) staff members while at a public meeting conducted at Honeywell on July 9 , 2013. Dur i ng the meeting , you expressed concerns related to several issues at Honeywell.

In that you provided your concerns during a public meeting, in front of members of the licensee , the NRC will be unable to protect your identity with regard to these concerns. Enclosure 1 to th i s l etter documents your concerns as we understand them. We have initiated actions to evaluate your concerns and will inform you of our findings.

The NRC normally conducts an evaluation of a concern within six months, although complex issues may take longer. If the description of any of your concerns, identified as Concerns 1 , 2, 3 and 4 , as noted 1n Enclosure 1 is not accurate, please contact me so that we can assure that your concerns are appropriately described and adequately addressed prior to the completion of our review. As part of our response to Concerns 1 , 2, 3, and 4 , we Intend to request Honeywell to perform an evaluation and provide a written response to the NRC. Your name and any other identifying i nformation will be excluded from the information that is provided to Honeywell in the request for i nformation.

We will request that Honeywell's evaluation be thorough, objective, and that the evaluator be independent of Honeywell management responsible for oversight of the functional area related to your concerns.

We will evaluate Honeywell's response, and consider it in developing our conclusions regarding your concerns. We will inform you of our disposition once we have evaluated Honeywell's response and taken an additional actions, if necessary , to address your concerns. In your conversation with (bJ (7)(c J NRC staff member , on July 9, 2013, you indicated that you would not object to the NRC requesting information from the licensee with regard to your concerns.

Enclosed with this letter is a brochure entitled " Reporting Safety Concerns to the NRC," which includes an important discussion of the identity protection provided by the NRC regarding these matters as well as those circumstances that limit the NRC's ability to protect an alleger's identity, such as this case. Please read that section of the brochure.

If a request is filed under the Freedom of Information Act (FOIA) related to your areas of concern, the information provided will , to the extent consistent with that act, be purged of names CERTIFIED MAIL: 7012 1010 0002 6821 4438 RETURN RECEIPT REQUESTED 1:-i. Cook 2 RI 1-2013-A-0100 and other potent i al identifiers. Further , you should be aware you are not considered a confidential source un l ess confidentia l ity has been formally granted in wr i ting. Thank you for notify i ng us of your concerns. We will adv i se you when we have completed our review of Concerns1 , 2 , 3 and 4. Should you have any additional questions , or i f the NRC can be of further assistance , please call me at the regional off i ce toll-free number 1-800-577-8510 extension 4426 or you may provide information t o me in wr i ting at P. 0. Box 56274 , Atlanta, GA 30343. You may also communicate with me by e l ectronic ma il , if you so choose. However, when doing so, please call me i n advance or prov i de your phone number in your e-ma i l message so that she can confirm that you are the source of t he information. Also, p l ease be advised that the NRC cannot protect the i nfo rm at i on during transmission on the Internet and there is a possibility that someone could read your response wh il e it is i n transit. My e-mail address is Melanie.Checkle@nrc

.gov.

Enclosures:

As sta t ed Me l an i e M. Check l e Allegat i ons Coordinator Enforcement and Investigat i ons Coordination Staff Enclosure 1 Concern 1: HONEYWELL Rll-2013-A-0100 STATEMENT OF CONCERNS Rll-2013-A-0100 Workers were unknowingly exposed to Plutonium and Neptunium in the mid-90s while processing green salt from the Fernald Department of Energy (DOE) Facility.

Concern 2: Workers did not receive proper training or protection while handling higher activity material from Russia to be converted into UF6. Concern 3: The railcars stored on-site for transfer of Hydrogen Fluoride to the Feed Materials Building are not properly configured with a relief system in the event of an over-p ress urization and are not connec ted to a scrubber system. Concern 4: In the Mid-90s, individuals were not required to monitor out of the facility and could have been spreading contamination offsite. You know of one indivi dua l who went home contaminated.