ML20133P811
| ML20133P811 | |
| Person / Time | |
|---|---|
| Site: | Lynchburg Research Center, 07000824 |
| Issue date: | 07/18/1985 |
| From: | Albright R, Hosey C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20133P738 | List: |
| References | |
| 50-013-85-01, 50-13-85-1, 70-0824-85-05, 70-824-85-5, NUDOCS 8508140494 | |
| Download: ML20133P811 (5) | |
See also: IR 05000013/1985001
Text
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'o WUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET.N.W.
ATLANTA, GEORGI A 30323
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Report Nos.: 70-824/85-05, 50-013/85-01
Licensee: Babcock and Wilcox Company
Lynchburg Research Center
Lynchburg, VA 24505
Docket Nos.: 70-824 and 50-013 License No.: SNM-778 and
CX-10
Facility Name: Lynchburg Research Center
Inspection Conducted: June 10-14, 1985
Inspector: e/N1
y R. H. AlbrigTt
7//s/35
Date signed
Approved by: M 7 / /t' h5
C. M. Hc'sey, Sect ion Chief Date Signed
DivisionofRadia(tionSafetyandSafeguards
SUMMARY
Scope: This routine, unannounced inspection entailed 17 inspector-hours on site
in the area of transportation of radioactive material.
Results: Three violations - Failure to package low specific activity (LSA)
radioactive material in a strong tight package; failure to ensure that the
closure device on a package of Fissile Class II material was free of defects
prior to shipment and failure to ship Fissile Class II material in a tested,
approved package; failure to label packages of radioactive material as required
by the burial facility license.
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8508140494 850729
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REPORT DETAILS
1. Persons Contacted
Licensee Employees
- A. E. Wehrmeister, Manager, System Development Laboratory
- J. P. Doran, Manager, Accounting and Administrative Services
- G. Hoovier, Manager, Building A Decommissioning Project
- J. W. Cure, Supervisor, Health and Safety
- A. Olsen, Senior License Administrator
D. Harris, Health Physics Technician
- Attended Exit Interview.
2. Exit Meeting
The inspection scope and findings were summarized on June 14, 1985, with
those persons indicated in paragraph 1 above. The apparent violation of
10 CFR 71.87 for shipment of a package with a crack under a closure bracket,
violation of 10 CFR 70.42 for transferring special nuclear material to a
land disposal facility without the labels required by receiver's license and
violation of 10 CFR 71.5 for the shipment of a package of LSA radioactive
material which failed to meet the strong tight container requirement were
discussed in detail. Licensee management acknowledged the violations.
The licensee was notified during a telephone conversation on June 19, 1985,
between J. B. Kahle of this office and A. Olsen of the licensee's staff that
failure to choose a package that was proper for the contents was another
example of a violation of 10 CFR 71.87.
The licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3. Licensee Action of Previous Enforcement Matters
This subject was not addressed in the inspection.
4. Transportation of Radioactive Material (86740)
On May 29, 1985, NRC Region II received a copy of a letter dated May 20,
1985, from the State of Washington to the B&W Lynchburg Research Center.
The letter described two violations in shipment No. LRC-23. The first
violation concerned a hole in a drum of LSA radioactive material in
violation of the strong tight package requirement of 49 CFR 173.425. The
second violation concerned the failure to meet requirements of the U.S.
Ecology land disposal facility license by affixing the correct number of
labels to each package.
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On May 1,1985, the licensee made shipment No. LRC-23 to the U.S. Ecology
land disposal facility at Richland Washington. While unloading the shipment
of drums on May 6, 1985, disposal site personnel observed a hole in the side
of drum number 4740. The waste manifest described the contents of the drum
as uranium oxides on lab trash and equipment. The radionuclide content
measured was Uranium-234 at 0.03 mil 11 curies, Uranium-235 at 0.002
millicuries, Uranium-236 at 0.0004 millicuries, and Uranium-238 at 0.01
millicuries. The drum was listed as Fissile Exempt and labeled Radioactive
LSA. The licensee's investigation determined that shifting of a 32 pound
metal object inside the container caused the hole. The inspector discussed,
with the U.S. Ecology health physics (HP) technician who identified the hole
in the drum, the details of the U.S. Ecology receipt of shipment No. LRC-23.
The HP technician stated that the drum with the hole had not been moved from
its shipment position in the trailer before the hole was observed. The hole
was observed after drums in front of this drum were removed while unloading
the shipment. The metal object inside the drum which apparently shifted
during transportation and caused the hole was protruding from the hole when
observed by the HP technician. It was determined that the hole had been
punched through the wall of the Department of Transportation (DOT)
Specification 17 H drum during transport. Surveys outside the hole did not
indicate leakage of radioactive material from the can. The amount of
radioactive material inside the can would not have caused a significant
public health and safety problem if it had been released.
10 CFR 71.5(a) requires that licensees who transport licensed material
outside the confines of its place of use or delivers such material to a
carrier for transport comply with the requirements of DOT regulations
contained in 49 CFR Parts 170 through 189. 49 CFR 173.425 requires that LSA
materials be shipped in a DOT specification 7A Type A package or a strong
tight package such that there will be no leakage of the package contents
during normal conditions of transport. In discussions with licensee
representatives and reviews of shipping papers it was determined that three
licensee personnel observed the drum to be in good condition prior to
transport. No other drums were damaged. Failure to ship LSA radioactive
material in a DOT Specification 7A Type A package or a strong tight package ;
apparent violation of 10 CFR 71.5(a).
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was identified as an
(70-824/85-05-01).
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10 CFR 20.301 prohibits the disposal of radioactive material except under
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specified conditions including _ transfer to an authorized recipient as
provided in the regulations in Parts 30, 40, 60, 61, 70 or 72 of this
chapter, whichever is applicable. 10 CFR 70.42 states requirements that
must be met prior to transferring special nuclear material (SNM). One
requirement is that SNM may be transferred to any person authorized to
receive such SNM under terms of a specific license or a general license or
their equivalents issued by the Commission or an Agreement State. U.S.
Ecology license, from the State of Washington, WN-1019-2, license condition
27(k), requires that when waste is labeled with a DOT White I, Yellow II or
Yellow III label a waste classification label should appear next to or in
close proximity to each DOT label . The license condition further requires ,
that when White I, Yellow II or Yellow III labels are required two of the
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specific labels must be displayed on each drum. Land disposal site
personnel observed that six drums in the LRC-23 shipment displayed two
Yellow II labels. However, only one waste classification label was affixed
to each of the six drums. Failure to comply with requirements of the
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receiver's license by not affixing the appropriate number of waste
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classification labels was identified as an apparent violation of 10 CFR
i 70.42. (70-824/85-05-03).
10 CFR 71.87 requires that prior to each shipment of licensed material that
certain requirements be met. These include ensuring that the package is
prope for the contents to be shipped, that the package is in unimpaired
physical condition except for superficial defects such as marks or dents and
that each closure device of the packaging is properly installed and secured
and free of defects.
Six drums marked Fissile Class II in shipment LRC-23 were listed on the
shipping papers as DOT specification 7A Type A packages. The quantity of
SNM in the six drums ranged from '.7,02 grams (3E-2 milli-curies U-235) to
25.92 grams (SE-2 milli-curies). The inspector reviewed the tests performed
for the 55 gallon drum that was used to meet the DOT specification 7A Type A
requirements. 49 CFR 173.465 specifies the tests that Type A packages must
pass prior to use. Fissile Class II packaging, in addition to other Type A
package tests, requires a free drop from a height of 0.3 meter (1 foot) on
each corner. For cylindrical packagings, the 0.3 meter drop shall be onto
each quarter of each rim. The test data review indicated that the corner
drop test had not been performed. These drums were part of an exclusive use
shipment in a closed transport vehicle. These packages were not damaged
during the shipment and no leakage of radioactive material occurred.
Failure to perform the required drop test resulted in use of an improper
package to ship Fissile Class II material. Failure to ship the Fissile
Class II material in a proper package was identified as an apparent
violation of 10 CFR 71.87. (70-824/85-05-02).
As a part of the decommissioning of the CX-10 reactor at the Lynchburg
Research Center (LRC) the licensee disposed of the reactor's fuel rods by
transfering them to Department of Energy (00E) facilities at Oak Ridge. The
reactor had not been operated above one kilowatt. The fuel was
approximately 2.5 percent enriched in U-235 and was considered unirradiated
per the 00T definition in 49 CFR 173.403. LRC transferred the fuel in
containers covered by NRC Certificate of Compliance No. 9069.
LRC refurbished the containers prior to use. The first shipment of CX-10
fuel arrived at the Oak Ridge National Laboratory (ORNL) on August 21, 1984.
On arrival ORNL personnel discovered a crack in the outer skin of the
outside container just beneath the horizontal weld on one of the lower
ratchet binders. The crack did not affect package integrity. The ratchet
binder is one of twelve primary closure devices. There are also twelve high
strength latch pins which serve as secondary closure devices. After
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receiving notification of this crack from ORNL, the licensee reviewed
photographs of the loaded packages taken prior to shipment and observed that
the crack was evident prior to shipment. The licensee, as corrective
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action, fixed the crack and began performing an extensive receipt inspection
each time the containers arrived back on site and prior to each loading of
fuel for shipment. Failure to ensure that the closure device on a package
of special nuclear material was free of defects prior to shipment was
identified as another example of an apparent violation of 10 CFR 71.87.
(50-013/85-01-01).
5. Enforcement Conference
An enforcement conference was held on June 27, 1985, to discuss recent
violations concerning the transportation of radioactive material. The
following persons were in attendance:
(1) Babcock and Wilcox Lynchburg Research Center
T. C. Engelder, Laboratory Director
C. E. Bell, Facility Manager
A. F. Olsen, License Administrator
J. W. Cure, III, Health and Safety Supervisor
(2) Nuclear Regulatory Commission
J. P. Stohr, Director, Division of Radiation Safety and Safeguards
G. Jenkins, Director, Enforcement and Investigation Coordination
D. Collins, Chief, Emergency Preparedness and Radiological
Protection Branch
C. Hosey, Chief, Facilities Radiation Protection Section
E. McAlpine, Chief, Material Control and Accountability Section
J. Kahle, Fuel Facilities Project Manager
R. Albright, Radiation Specialist
During the meeting, licensee personnel presented discussions of their
radioactive material transportation organization, discussions of each
inspection finding and corrective actions.