ML20217F477
| ML20217F477 | |
| Person / Time | |
|---|---|
| Issue date: | 04/21/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217F475 | List: |
| References | |
| REF-QA-99990004-980421 99990004-97-04, 99990004-97-4, NUDOCS 9804280171 | |
| Download: ML20217F477 (29) | |
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ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket No. 99990004 License No. Not Applicable Report No. 99990004/97-04 Licensee: Envirocare of Utah, Inc.
- Facility: South Clive Facility Location: Tooele County, Utah Dates: June 9-10, June 16-18, and October 6-9,1997 Inspector: Robert J. Evans, P.E., Health Physicist Nuclear Materials Safety Branch 1 Division of Nuclear Materials Safety Accompanied By: Linda L. Howell, Deputy Director (on October 9,1997) Division of Nuclear Materials Safety Approved By: Charles L. Cain, Chief Nuclear Materials Safety Branch 1 Division of Nuclear Materials Safety Attachments: 1. Supplementary Information
- 2. Photographs Taken at the Envirocare Facility 9804280171 980421 hhNo00 f EECE U
EXECUTIVE
SUMMARY
Envirocare of Utah, Inc.
NRC inspection Report 99990004/97-04 This special inspection included a review of site oyrations as they relate to Envirocare's possession of special nuclear material at the South Clive facility.
Ooerations Review A review of site activities revealed that Envirocare possessed special nuclear materialin quantities that exceeded the NRC limits established in 10 CFR 150.10 and 150.11 on at least three separate occasions (May, June, and September 1997). Envirocare's failure to maintain quantities of uranium-235 below the 350 gram limit was identified as a potential violation of NRC regulations. Although three particular points in time have been clearly identified Envirocare may have possessed quantities of special nuclear material that exceeded the regulatory limit numerous times since 1995.
One possible cause of the problem was Envirocare's interpretation of the concept of possession. Envirocare's definition of possession differed from the State's and the NRC's concepts of the term. A second possible cause was Envirocare's failure to discuss, in writing, its understanding and definition of possession with either the State of Utah or the NRC between 1994 and 1996. In particular, Envirocare revised the definition of possession at least three times between 1994 and 1996 without clear written approval of either the State or the NRC.
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- A contributing cause of the apparent violation was Envirocare's failure to implement a thorough corrective action review in a timely manner. During September 1997, Envirocare found that it had again exceeded the 350-gram limit for uranium-235. A root cause analysis, if performed during May-June 1997, may have prevented the September 1997 incident from occurring.
- Corrective actions were taken by Envirocare, including reduction of the amount of SNM inside of the restricted area that was not disposed of to less than 350 grams. Also, Envirocare fulfilled all requirements that were stipulated in the NRC's Confirmatory Action Letter and Confirmatory Order issued during June 1997.
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REPORT DETAILS 1 BACKGROUND Envirocare received a State of Utah license for disposal of wastes containing naturally occurring radioactive material (NORM) at the South Clive site during February 1988. The State of Utah revised the license in March 1991 to allow for disposal of low-level radioactive wastes. Envirocare also received a Resource Conservation and Recovery Act (RCRA) permit from the State of Utah's Solid and Hazardous Waste Board in 1990 and a Hazardous and Solid Waste Act Permit from the U.S. Environmental Protection Agency in February 1991. The permits allow Envirocare to operate a hazardous waste storage, treatment, and disposal facility at the site. The NRC issued a license to Envirocare in November 1993 for possession of 11e.(2) byproduct material.11e.(2) material is defined as tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content.
Since 1988, Envirocare has constructed and utilized three disposal cells: the 11e.(2), the low activity radioactive waste (LARW), and the mixed waste disposal cells. Disposal of material in the LARW and mixed waste cells is regulated by the State of Utah, which is an Agreement State. A fourth waste disposat cell, containing uranium mili tai 8ngs from the former Vitro Chemical Company, is located adjacent to the site property. This fourth cellis owned and controlled by the Department of Energy.
Envirocare has a mixed waste treatment facility in operation at the site. A second mixed waste treatment facility was under construction during the NRC inspection. Mixed wastes are essentially radioactive wastes that also contain other hazardous wastes.
Prior to disposal, the mixed wastes have to be processed. Processing may include one or more of the following: waste separation and screening, waste shredding, stabilization and treatment, or solidification. The processing method used depends on the specific wastes involved. All mixed w;aste process methodologies have to be approved by the State of Utah prior to implementation.
Envirocare received its first shipment r,f mixed wastes in April 1993, and the mixed waste treatment facility went into service du,ing the Summer of 1994. Envirocare has been able to treat about 70-75 cubic yards of material per day. Wastes that cannot be properly processed have to be returned to the generator of the wastes.
l 2 OPERATIONS REVIEW (88020) 2.1 Insoection Scoce The objective of this portion of the inspection was to verify that site activities were being conducted in accordance with applicabic NRC regulations and to ensure that operational -
controls were adequate to protect the health and safety of the workers and the members of the general public.
2.2 License and Regulatorv Recuirements l In accordance with 10 CFR 70.3, no person subject to the regulations in 10 CFR Part 70 l shall receive title to, own, acquire, deliver, receive, possess, use, or transfer special l
nuclear material (SNM) except as authorized in a license issued by the Commission I
pursuant to these regulations. SNM typically includes plutonium, uranium-233, and uranium-235, although other radionuclides can be considered SNM by the NRC under special circumstances.
i An exception to this NRC regulation is provided in 10 CFR Part 150.10 which states, in part, that any person in an Agreement State who manufactures, produces, receives, possesses, uses, or transfers byproduct material, source material, or SNM in quantitie's not sufficient to form a critical mass is exempt from the requirements for a NRC license and from regulations of the Commission applicable to licensees. According to 10 CFR 150.11, SNM in quantities not sufficient to form a critical mass means uranium enriched in the isotope uranium-235 in quantities not exceeding 350 grams of contained uranium-235; uranium-233 in quantities not exceeding 200 grams; plutonium in quantities not exceeding 200 grams; or any combination of them in accordance with the following i formula:
(grams contained U-235) + (arams U-233) + (arams Pu) s 1 350 200 200 j In other words, the NRC has delegated the regulatory oversight of SNM in quantities not sufficient to form a critical mass to the Agreement States. The State of Utah became an Agreement State with the NRC on April 1,1984; therefore, the State of Utah has the authority to provide regulatory oversight over small quantities of SNM. The NRC retains the responsibility to regulate SNM in quantities sufficient to form a critical mass. The intent of reserving NRC regulatory authority in this area was to assure that large, discrete quantities of SNM would be subject to NRC regulation. This would assure physical security and criticality safety, two vital considerations inherent to the possession of large, discrete sources of SNM.
In accordance with the conditions of Utah License UT 2300249, Envirocare is authorized to possess limited amounts of SNM. Condition 13 of License UT 2300249 states that the maximum quantity of SNM that the licensee may possess, undisposed of, at any one time, shall not exceed 350 grams of uranium-235,200 grams of uranium-233, and 200 grams of plutonium, or any combination in accordance with the formula mentioned above. Once the SNM has been disposed of in a disposal cell, the SNM material was no longer considered to be in the possession of the licensee.
Condition 6 of the State license lists the specific radionuclides that are allowed to be disposed of at the site and the concentration limits allowed for disposal. Uranium-235 ;
and plutonium are listed in Condition 6 and are allowed to be disposed of at the facility.
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I Uranium-233 is not listed in Condition 6; therefore, Envirocare is not authorized by the State to dispose of this radionuclide in any disposal cell on site property.
As of June 1997. Envirocare had disposed of waste material containing roughly 240,000 grams of uranium-235 and 33 grams of plutonium in the mixed waste and .
LARW disposal cells. (By definition SNM is not the same as 11e.(2) material, and SNM i cannot be disposed of in the NRC-licensed 11e.(2) disposal cell.) In accordance with )
License Condition 6, Envirocare's records indicated that it did not have any uranium-233 '
on site property at the time of the NRC onsite inspections.
On October 21,1992, Envirocare submitted a request to the NRC for an exemption from )
the requirements of 10 CFR'Part 150.10. Envirocare requested the exemption based on l its expectations that future waste shipments may contain increasing quantities of SNM.
Gpecifically, Envirocare expected to be in receipt of a 100-car rail shipment during the winter of 1992-1993 that could contain up to 350 grams of SNM per rail car. On February 22,1993, the NRC published Envirocare's exemption request as a petition for rulemaking in the Federal Reoister for public comment. The comment period ended in April 1993. The NRC subsequently received two comments from the public for consideration.
Envirocare subsequently submitted a letter dated October 1,1993, to the NRC requesting expediency in the NRC's review of its petition for rulemaking. Envirocare again noted that relief was needed to help alleviate a " bottleneck" associated with the receipt and disposal of waste material containing SNM. The licensee apparently had operational difficulties related to the acceptance and disposal of increasing volumes of waste material containing SNM that was arriving by railcar at the site.
In addition to the petition for rulemaking, on February 22,1993, Envirocare requested a temporary exemption from the requirements of 10 CFR Part 70 to permit possession of 1,050 grams of uranium-235. Envirocare requested this temporary exemption for 30 days. As justification, Envirocare noted that the SNM was intermixed with large quantities of waste debris which made the potential of a criticality incident extremely remote. On March 16,1993, Envirocare submitted a second written request to NRC to extend the temporary exemption period from 30 days to one year. By letter dated April 2, 1993, the NRC denied Envirocare's temporary exemption request and suggested that Envirocare submit their request as an application for a license under 10 CFR Part 70 for possession of SNM.
In a letter dated March 28,1994, the NRC advised Envirocare that it may be able to possess uranium-235 in quantities greater than the 350-gram limit if it applied for and received a license under the requirements of 10 CFR Part 61, " Licensing Requirements for Land Disposal of Radioactive Wastes." A representative of Envirocare noted during the inspection that they thought the NRC would implement rulemaking before a license could be issued and that the rulemaking would be in Envirocare's favor. Therefore,
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Envirocare did not pursue a Pa t 61 or Part 70 license during the 1992 to mid-1997 time frame. I 1
Envirocare submitted letters dated July 16,1997, and August 11,1997, to the NRC l requesting an immediate final rule and an exemption from the licensing requirements of ;
10 CFR Part 70 for receipt and storage of diffuse SNM. On August 25,1997, the NRC l responded by noting that a Commission Paper was being prepared on this issue and that
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NRC staff would inform Envirocare of its decision at a later date. As of late-February :
1998, NRC had not formally informed Envirocare of its decision on the rulemaking i petition and exemption requests.
On December 5,1997. Envirocare formally submitted a license application pursuant to '
10 CFR Part 70. Envirocare requested authorization for the receipt, storage, processing, 1 treatment and transfer of radioactive wastes containing SNM. NRC acknowledged receipt of the application by letter dated December 16,1997. The first step of NRC's license review process was to perform an acceptance (administrative) review of the application to identify any omissions and to verify that sufficient information was available to perform a technical review of the application. By letter dated March 4,1998, the NRC informed Envirocare that the application did not contain adequate information. Upon submission of a revised application, the NRC will again conduct an administrative acceptance review of the Part 70 license application.
In summary, Envirocare was not authorized by the State license, an NRC license, or an i exemption to 10 CFR Parts 70 and 150 to possess uranium-235 in quantities greater than 350 grams between February 1988 (when first State license was issued) and October 1997 (end of NRC onsite inspections). As discussed in Sections 2.6,2.7, and 2.9 of this inspection Report, Envirocare was discovered to have possessed uranium-235 in quantities that exceeded the 350-gram limit on at least three occasions during 1997.
2.3 Control of Radioactive Wastes at the Site Radioactive wastes arrive at the site by one of two methods, either by bulk shipment or by container shipment. Bulk waste shipments include rail cars, dump truck loads, and intermodal containers. Container waste shipments include boxes, drums, bags, " super sacks," and "seavans." Following sampling, the low-level radioactive waste material is transported to the LARW/ NORM disposal cell or placed into short-term storage. Mixed wastes are typically transported to the mixed waste storage area for short-term storage prior to processing of the material for land disposal Mixed wastes are disposed in the mixed waste disposal cell immediately upon completion of waste processing and final sampling.
i in accordance with site operating procedures, bulk low-level radioactive wastes have to be placed into storage or into the disposal cell within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the shipment is unloaded. Also, containerized low-level radioactive wastes have to be placed into l
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.o storage or disposed of within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of being unloaded. Containerized wastes can remain in storage up to 180 days if necessary to resolve any discrepancies that are identified during the acceptance process.
Mixed wastes can be held for up to 10 days prior to movement to a storage, treatment, or disposal location. Envirocare has not set an upper limit in their onsite procedures for how long mixed wastes can be stored on site property prior to disposal. However, 40 CFR 268.50 provides a one-year storage interval restriction unless certain conditions are met. As of October 1997, some mixed wastes had remained in storage for greater than one year; however, these wastes did not contain any SNM material.
Envirocare had established a method for effectively controlling radioactive wastes from the time wastes arrived onsite to the time wastes were properly disposed. The controls included time limits on how long wastes could remain in storage. These rules applied regardless of whether the wastes contained SNM material or not. As will be discussed later in this report, Envirocare did not always handle wastes containing SNM in an i effective manner. Although controls were in place to govern the timeliness of handling wastes, effective controls were not in place to govern quantities of SNM possessed at the site.
2.4 Control of SNM in Possession of Envirocare (1992 Throuah June 1997)
Envirocare received its first shipment of waste material containing SNM in 1992. Prior to July 1993, Envirocare kept track of the quantity of SNM in its possession in an informal manner. During July 1993, Envirocare established a log to keep track of the amount of SNM in its possession. The log was used to document the amount of SNM, in grams, in Envirocare's possession on a daily basis. The log was used primarily to ensure compliance with Condition 13 of the State license. A member of the shipping and receiving department logged the SNM shipments into the log book when the wastes were ,
accepted for managemerst and logged them out when the wastes were disposed. I The manual log was discontinued during February 1996 when the documentation of SNM possession was transferred to a computer database. Between February 1996 and October 1996, an interim tog was maintained using a spreadsheet application. During October 1996, Envirocare's computerized Waste Information System (WIS) was fully implemented. The WIS was then used to monitor SNM possession on a daily basis.
During June 1997, Envirocare's computerized SNM log was reviewed. The log consisted of a printout identifyicg material considered to be in Envirocare's possession on that particular day. Printouts were requested specifically for June 9,10, and 17,1997. The daily inventory printouts for those days showed the possession of SNM to be 240,240, and 178 grams, respectively. Envirocare could not easily recreate the SNM possession log for any particular day since the discontinuance of the manuallog because of the design of the computer software and because of a previous incident involving a computer virus that resulted in a loss of electronic data.
On July 17,1997, a revised spreadsheet application was put into service to keep track of SNM that was in Envirocare's possession. During August 1997, Envirocare incorporated the spreadsheet application from a stand-alone program back into the integrated WIS computer system. As of October 1997, the shipping and receiving department still maintained control of the electronic SNM log.
During routine waste disposal operations, waste generators typically would send advance copies of the manifests to Envirocare. These manifests listed the amount of SNM that would be present in a particular shipment of waste. The shipping and receiving clerk then entered the amount of SNM shown on each manifest into the WIS.
When the shipment arrived onsite, shipping and receiving coordinators reviewed the previously entered information, generated a unique tracking n0mber (referred to as a
Bates Number") for each manifested-shipment, and subsequently accepted the shipment for onsite disposal.
l The shipping and receiving coordinators also filled out the electronic SNM log when the respective waste shipments arrived onsite. If the material was going directly to the ,
disposal cell, the possession date and amount of SNM disposed was entered into the SNM Log. This action added the SNM to the log, but the waste was not applied aanst ;
the possession limit. However, if the material was not disposed in a cell in one d ay, then l the SNM for that shiprrent was added to the daily total. When the material was i nally I disposed of, the SNM quantity for that shipment was dropped from the daily SNN log. I Envirocare had to rely on verbal or informally-written instructions between the shipping and receiving and operations personnel to update the SNM log. For example, if a shipment containing SNM that was previously in storage had finally been disposed, operations personnel were expected to notify shipping and receiving personnel either verbally or by marking up a copy of the daily SNM log. The shipping and receiving ,
department then used this information to update the computerized SNM log. This i method of operations relied on timely and effective communications between shipping ;
and receiving and operations personnel to keep the SNM log up-to-date. i Eiivirocare representatives noted that in the near future, they planned to install a bar code system for tracking of waste shipments. When implemented, the bar code system should provide instantaneous, real-time tracking of SNM within the restricted area.
In summary, Envirocare had developed a method of tracking SNM under its control. The control of SNM evolved over time from no control (no log), to a manual log, and finally to a computerized log. However, the information that was used as input to the manual and computerized log depended on verbal and informally written communications.
The review of the SNM log revealed severalimportant findings which will be discussed later in this report. First, the log entries suggested that Envirocare first appeared to have exceeded the unity equation (meaning that quantities of SNM were above the State-authorized possession limit) during the fall of 1995. Next, Envirocare eventually failed to
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use the log in an effective manner by not recording all shipments in storage that contained SNM. Finally, the use of informal communications resulted, in part, in an incident during September 1997 in which Envirocare exceeded the 350-gram limit for uranium-235, 2.5 Definition of Possession Envirocare's definitions of possession and acceptance were reviewed during the 1997.
The concepts of acceptance were clearly discussed in the State license application, waste management plans, and operating procedures. However, the concept of possession was not defined in these documents, but evolved over time through the use of internal memorandums and occasional correspondence with the State of Utah.
According to verbal information provided by Envirocare, in 1992 any SNM that was on j site property and not in a disposal cell was considered to be in possession. Envirocare i subsequently determined that this definition was too restrictive because of its inability to easily control when the material arrived onsite. Instances also occurred when waste material containing SNM arrived onsite by third-party carriers with aggregate totals of ,
more than 350 grams.
For example, on May 11,1994, Envirocare discovered six trucks from one private I industry waste generator located on site property, but outside of the restricted area in the l truck staging area. These trucks collectively contained SNM in quantities that exceeded i the 350-gram limit. Envirocare immediately directed four of the six trucks offsite to bring the site back into the 350-gram limit. Envirocare sent a letter to the State the following day, informing them of this observed instance of noncompliance with the State license requirements.
During 1994, Envirocare revised its definition of possession to include only SNM that was inside of the restricted area. (Restricted area means an area where access is limited by Envirocare for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.) As documented in a letter to the State of Utah dated May 18,1994, Envirocare decided that waste shipments arriving at the site were not considered to be in their possession until the shipments had been administratively processed and were found to be acceptable. Envirocare subsequently used this definition to permit the staging of shipments on site property, but outside of the restricted area, until the shipments had been inspected and administratively processed.
In accordance with Envirocare's procedures in place at the time, the acceptance process included a review of the manifest, radiological survey and smear test (for loose contamination) of the container, visual inspection, and collection of waste material samples for confirmatory analysis. Acceptance formally occurred when an authorized representative signed the " Approved For Disposal / Storage" blank on the Incoming and Acceptance Record Form EC-18. Once accepted, the shipments were then brought into the restricted area and were considered to be in Envirocare's possession.
Possession of SNM in mixed wastes was the subject of an April 26,1994, letter from the {
State of Utah. The State noted that Envirocare might exceed the 350-gram limit because of on-going treatment of mixed wastes. The State informed Envirocare that wastes placed in the mixed waste disposal cell were considered to be disposed of and should not count against the 350-gram limit. Further, mixed wastes containing SNM awaiting analysis or curing could also be placed in the disposal cell and not be counted against the limit. These actions were authorized because the State assumed that Envirocare had no intention of removing the wastes from the disposal cell even if the wastes were still temporarily stored in containers.
In a letter dated June 27,1994, the State informed Envirocare that possession of SNM also depended on whether the waste material was considered to be in the transport' i mode or not. Specifically, if the waste shipments were no longer in transit (for example, if l the hauler was no longer the custodian of the waste shipment), then the quantity of SNM .
contained in the shipment was to be counted against the inventory limit. In practice, Envirocare no longer added wastes that were immediately disposed of to the daily SNM log. i in an internal memorandum dated November 15,1994, Envirocare further refined its concept of possession. In this memo, Envirocare discussed specific instances involving trucks and rail shipments when SNM material was or was not to be considered in its possession. For example, waste received by truck was not considered to be in Envirocare's possession until the shipment had been accepted and unloaded. Also, sealed rail shipments could traverse through the restricted area during certain rail movement evolutions without being considered in Envirocare's possession.
In another memorandum dated January 30,1995, Envirocare clearly defined its definitions of acceptance and possession. These new definitions applied to all shipments regardless of whether they contained SNM or not. These definitions were based on a more rigorous, detailed set of criteria that had to be completed before the incoming waste could be accepted and before the waste material was considered to be in Envirocare's possession.
The five new steps for acceptance included: (1) an initial inspection of the incoming shipment to ensure compliance with Department of Transportation regulations, (2) a visual inspection of the wastes and initial collection of waste samples for laboratory analysis, (3) an immediate chemical analysis to demonstrate that the wastes were the same as described in the generator's contract with Envirocare, (4) a radiological analysis to confirm the accuracy of the manifest information and to ensure compliance with the
' licensed limits, and (5) a delayed chemical analysis to show compliance with the land disposal restrictions.
Once the five steps were completed (or completed to a point where Envirocare felt comfortable with accepting possession of the waste prior to the conclusion of the five steps), the material was considered to be in Envirocare's possession. Envirocare noted f
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l in its January 1995 memo that the completion of these five steps could delay the acceptance process for up to several months in some cases. Envirocare intended that unburied waste material remained the property of the generator, since the material may have to be returned to the generator, until such a time as all qualifying criteria met Envirocare's standards. In other words, as stated in the January 1995 memo, " ..the time at which Envirocare takes possession is when the shipment is formally accepted for disposal."
The manual SNM log (discussed in Section 2.4 above) included a column for the summation of fractions (the formula listed in Section 2.2 above) as one method of monitoring the amount of SNM in possession on a daily basis. Several entries were !
made during the fall of'1995 that included a fraction calculation of greater than~1.0, suggesting that Envirocare had exceeded its possession limit on those days. However, j these entries were later superseded because Envirocare subsequently concluded that the entries were entered in the log in error. In one instance, the log noted that " ..these ,
wastes (the wastes that resulted in the sum of fractions being greater than 1.0) have not l been accepted by Envirocare." In summary, Envirocare was the recipient of wastes that appeared to push Envirocare above the SNM possession limit during the fall of 1995; however, Envirocare concluded that the excess material did not meet its criteria for possession because Envirocare defined " acceptance of wastes" differently from
" possession of wastes" at that time.
The definition of SNM possession was modified by another internal memorandum dated January 9,1996. In this case, possession was redefined as such:
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If the waste material was placed into a disposal cell the same day that it arrived onsite, then the material was not considered to be in Envirocare's possession even though the material had to pass through the restricted area for final disposal.
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Low activity radioactive waste material that was being held for more than one day for confirmation of laboratory test results was not considered to be in Envirocare's possession because the material could be rejected and returned to the generator.
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Mixed waste material that had not undergone successful treatment was not considered to be in Envirocare's possession because the material still could be rejected and retumed to the generator.
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Mixed waste material that had been successfully treated and was ready for t disposal would not be considered in Envirocare's possession unless the material i was stored for more than one day. In practice, this meant that once the mixed waste material had been processed and was ready for disposal, then the waste's SNM content was considered to be in the possession of Envirocare. However, at this point in time, the waste material was typically then disposed of immediately and not added to the SNM log.
During the fall of 1996, Envirocare redefined possession in an additional manner that was not clearly documented in either a letter or an internal memorandum. In this case, wastes that had been accepted by Envirocare and were ready for disposal would not be j considered to be in its possession if there was no space available in the respective l disposal cell for the waste material. In other words, if the wastes could not be disposed l of, then the wastes could not be in Envirocare's possession. This new definition was aimed primarily at " mobile" wastes.
Mobile wastes include radionuclides that have a high potential for groundwater contamination because of their ability to traverse through the ground more readily than other radionuclides. The radionuclides include tritium (hydrogen-3), carbon-14, technetium-99, iodine-129, and ne'ptunium-237. Envirocare must dispose of mobile wastes in disposal cells that are fabricated with specially-designed liners, and these cells have to be approved by the State of Utah prior to use.
in the fall of 1996, Envirocare possessed mobile wastes that were ready for disposal, but no location was available to bury the wastes because state approval had not been granted for expansion of the existing mobile waste disposal cell. Modification of the mobile waste cell had begun in August 1996 but the cell was not available for use until June 1997 when the State granted approval for its use. These mobile wastes were stored on the low-level waste container storage pad on an interim basis, but Envirocare did not consider the mobile waste to be in its possession because a disposal cell was not available from August 1996 to June 1997.
In summary, using its definitions of possession and acceptance, Envirocare " possessed" SNM in quantities less than the 350-gram restriction, but had " accepted" and stored SNM in quantities greater than 350 grams intermittently between the fall of 1995 until July 1997. (As discussed below, Envirocare's policy for possession of wastes changed during mid-1997 following NRC and State review of this subject area.) Envirocare apparently continued to revise their definition of possession during 1994-1996 without written NRC or State authorization or input. This action subsequently resulted in Envirocare possessing SNM in aggregate amounts that were above the State-authorized limit. Finally, Envirocare did not effectively use the SNM log because some shipments in storage, induding mobile wastes, were not added to the active SNM log.
2.6 State of IJtah Site insoections The StMe of Utah performs a comprehensive site audit at Envirocare once per year.
Conditan 13 of the State license, the condition that places limits on Envirocare's possession of SNM, was reviewed by State inspectors during their 1993 and 1994 inspe:4 ions. Neither of these inspections ider.tified any concerns with Envirocare's compiance with Condition 13. The State did not perform a documented review of Licen se Condition 13 during the 1995 and 1996 annual inspections.
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l On May 15,1997, the State performed a partial audit of the materialin storage on the low-level radioactive waste container storage pad. According to information obtained from the State, the materialin storage at that time included a 494-gram shipment of SNM commingled with mobile wastes that had been in storage since November 1996. The audit findings subsequently resulted in the State issuing a Notice of Violation and Civil Penalty and an Order to Dispose to Envirocare on May 27,1997.
A second review of the amount of SNM onsite was performed five days later during the State's annual comprehensive audit of site activities. As of May 20,1997, the State inspector concluded that Envirocare possessed about 2,208 grams of SNM that was intermixed with several shipments of waste material being stored on the low-level waste container storage pad.
Envirocare's possession of 2,208 grams of uranium-235 contained in waste material stored on the low-level waste container storage pad on May 20,1997, was identified as the first example of an apparent violation of 10 CFR 150.10 and 150.11 (99990004/9704 -01).
2.7 NRC Site Insoections durina June 1997 During two NRC inspections conducted in June 1997, independent audits of SNM in storage at the site were performed. Based on Envirocare's definition of possession, Envirocare determined it possessed about 240 grams of SNM onsite as of June 9,1997.
This material was being stored on the low-level waste container storage pad. Envirocare had reduced the amount of SNM that was being stored at this location from roughly 2,200 grams to 240 grams since the two May 1997 State inspections.
The mobile wastes that had been stored on the low-level waste storage pad had been relocated to a temporary slot in the LARW disposal cell folicwing the State's May 1997 inspections. When the state approved the new mobile waste storage cell on June 12, 1997, the mobile wastes were then transferred from the temporary location to the new cell for permanent disposal.
The NRC inspector identified about 2,200 grams of additional SNM in storage at Envirocare's mixed waste storage area. (The storage of wastes in the mixed waste storage area was not reviewed during the State's May 1997 inspections.) Combined with the 240 grams of SNM on the container storage pad, Envirocare had about 2,400 grams of SNM inside of the restricted area and above ground on June 9,1997. From a health and safety standpoint, the material was most likely not in a configuration that would create a concern for a potential criticality incident because the SNM was dispersed within tons of waste material.
Envirocare had a tendency of stockpiling mixed wastes (a concept referred to as " buffer storage" by one Erevirocare representative) to ensure that a sufficient quantity of material was available to keep the mixed waste treatment facility process equipment in l
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l continuous operation. This method of operation made the treatment process more efficient because the mixed waste treatment facility had to be cleaned and prepped prior to processing different waste streams. Other reasons for stockpiling included cell space limitations, receipt of delayed test results, and to consolidate similar wastes for disposal at the same time (such as wastes containing asbestos).
Envirocare informed the NRC inspector that it did not consider the mixed waste material to be in its possession based on Envirocare's definition of possession as described in the memorandum dated January 9,1996. Envirocare's possession of about 2,400 grams of ,
uranium-235 contained in waste materiallocated above ground on both the low-level l waste container storage pad and in the mixed waste storage area on June 9,1997, was identified as the second example of an apparent violation'of 10 CFR 150.10 and 150.11 (99990004/9704-01).
Envirocare has since implemented corrective actions in response to the State's and NRC's concerns which included re-prioritizing the processing of mixed wastes to reduce the amount of SNM being held above ground in the mixed waste storage area.
2.8 NRC Followuo Activities Following the first NRC onsite inspection, NRC issued a Confirmatory Action Letter (CAL) to Envirocare on June 12,1997. The CAL documented actions Envirocare had agreed to take to bring the site into compliance with the State's and NRC's possession limits.
Actions to be taken by Envirocare included discontinuing receipt of wastes containing SNM (with some minor exceptions) until SNM possessed, but not disposed, at the site was below the 350-gram limit.
In accordance with the CAL, Envirocare was also required to swnd: written plan to document how it planned to remain below the 350-gram limit in the future. The CAL set a deadline of June 25,1997, for Envirocare to complete the actions specified in the letter.
In its response letter dated June 16,1997, Envirocare submitted a written disposal plan to NRC and noted that 2,391 grams of SNM was in the site inventory at that time.
Envirocare also stated that it would not be able to dispose of sufficient quantities of SNM inventory to meet the 350-gram limit by the June 25,1997, deadline. By letter dated June 18,1997, Envirocare formally asked for an extension of the compliance deadline from June 25 to August 1,1997. The primary reason for the extension was to provide time to properly treat and dispose mixed wastes that contained SNM.
On June 25,1997, the NRC issued a Confirmatory Order (Order) to Envirocare that superseded the CAL dated June 12,1997. In summary, the Order stated that Envirocare could not receive SNM (with some minor exceptions) until four business days after Envirocare had notified NRC that the actions described in its June 16,1997, disposal l plan had been completed. The Order also stated that a stand-alone compliance plan l had to be submitted to the NRC for review and approval by July 7,1997. This
l compliance plan was expected to clearly define Envirocare's concept of " possession" to the NRC.
Envirocare subsequently submitted a draft compliance plan to NRC on July 2,1997.
Following discussions with NRC, a revised compliance plan was submitted to NRC by letter dated July 7,1,997. By letter dated July 21,1997, NRC rejected portions of Envirocare's compliance plan. Specifically, the NRC did not agree with the Envirocare's definition of possession. The NRC noted that any proposal that did not include all SNM within the restricted area as part of the materialin Envirocare's possession was not acceptable.
NRC noted in the July 21,1997, letter a potential exception to the 350-gram site possession limit that would be acceptable to the staff. Wastes that were being delivered by truck straight to the disposal cell were not considered to be in the possession of Envirocare as long as the truck did not exceed the 350-gram limit and as long as the carrier remained in control of the conveyance until the waste was disposed. In other words, the NRC concluded that if the material was still in transit, then the SNM in the shipment would not be counted against Envirocare's possession limit. This exception is allowed because 10 CFR 70.12 provides an exemption for carriers of SNM.
Envirocare submitted a revised compliance plan (Revision 2) to NRC by letter dated July 23,1997. Envirocare revised its defMition of possession to include all SNM within the restricted area, with the exception of trucks that delivered wastes directly to the disposal cell. In this case, the waste material was to be considered in transit until the time of disposal. In essence, Envirocare accepted the NRC's concept of possession and documented this concept in its compliance plan. NRC approved Revision 2 of the compliance plan on August 1,1997. The plan went into effect that day at the site.
On September 24,1997, Utah revised License UT 2300249 to clearly define the concept of possession. Based on this revision, Condition 65.A reads as follows:
" Radioactive and mixed waste within any restricted area is possessed by the Licensee. WWo conveyed to the disposal facility by truck is in transport as long as the commercial carrier remains in control of the vehicle and may be excluded from any possession limits by the licensee. Any waste containing SNM, not disposed on the day delivered, shall be considered to be in the possession of the Licensee."
In summary, Envirocare took prompt corrective actions in response to the NRC's onsite inspection and subsequent letters. These actions included actively reducing the SNM quantities to below the State-licensed limit and implementing a compliance plan to revise the concept of possession of SNM at the site.
2.9 Envirocare's Self-identified Exceedence of the SNM Possession Limit On September 18,1997. Envirocare received several shipments of waste material from a particular generator. The material contained a total SNM quantity of 595 grams divided between two shipments. The two shipments were brought into the restricted area for sampling. The shipments failed the initial chemical screen test. The following day, Envirocare noted that the shipments were stillinside of the restricted area and had not been disposed. An initial assessment was performed by Envirocare, and it was determined that Envirocare had pcssessed (as defined by the compliance plan) up to 933.586 grams of SNM within the restricted area for roughly 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />.
Immediate corrective actions were taken by Envirocare, including disposal of these and other wastes containing SNM. At the end of the day on September 19,1997, Envirocare had reduced the SNM inventory to 251 grams. Also, the State of Utah was verbally informed of the incident by Envirocare on September 19,1997.
A written notification of the event was submitted to the State of Utah by Envirocare on September 24,1997. Envirocare noted that the causes of the incident included a breakdown in communications between the shipping and receiving department and the operations staff. The facility operator was not aware that the load contained SNM and had to be discarded that day in the disposal cell. Short term corrective actions included staff discussions and modification of a label that was routinely applied to all containers of waste. Longer-term planned cc,rective actions included the installation of a bar code system that would track SNM in an instantaneous, real-time manner.
Envirocare's possession of 934 grams of uranium-235 contained in waste material located above ground inside of the restricted area on September 19,1997, was identified as the third example of an apparent violation of 10 CFR 150.10 and 150.11 (99990004/9704-01).
2.10 NRC Site insoection durina October 1997 Corrective actions taken by Envirocare since the June 1997 inspection were reviewed during the third NRC onsite inspection. These corrective actions included actions implemented in response to the June 12,1997, CAL and the June 25,1997, Order, as well as the actions taken in response to the September 18-19,1997, incident.
In summary, all actions specified in the CAL and the Order had been implemented by Envirocare within the deadlines specified in those documents. For example, Condition 4 of the Order stated that Envirocare would submit to NRC no later than August 4,1997, written confirmation that the actions described in its disposal plan dated June 16,1997, had been completed. Envirocare completed the actions specified in the plan (specifically, the reduction of the onsite SNM quantities to below 350 grams) on July 17, 1997. Written confirmation of the completion of the disposal plan was submitted to the NRC on July 18,1997.
l Condition 1 of the Order stated that Envirocare shall not receive SNM at the site in quantities greater than 1 gram per shipment until four business days after compliance with Condition 4. The first waste shipments not already in transit when the Order was issued containing SNM in quantities greater than 1 gram arrived onsite on July 31,1997, or nine business days after compliance with Condition 4 of the Order.
Envirocare's compliance plan, mentioned in Conditions 1 and 3 of the Order, was submitted to the NRC for review and approval on the deadline (July 7,1997), although copies of a draft compliance plan had been submitted to NRC several days earlier to allow for NRC review and comment. The compliance plan was subsequently approved by NRC on August 1,1997.
Other onsite corrective actions taken since the June 1997 inspection included:
- Reduction of the onsite SNM quantities from about 2,400 grams on June 6,1997, to 296 grams on July 17,1997. Although Envirocare possessed 934 grams of SNM briefly during September 18-19,1997, the SNM in the possession of Envirocare on October 6,1997, was less than 97 grams sccording to site inventory records.
- Reassignment of an individual from the main office to the position of LARW site manager, a staffing position that was open during the first NRC onsite inspection.
- Updating the computerized WIS to include quantities of SNM listed on incoming manifests.
- Implementation of an upgraded SNM Log on July 17,1997, the day the quantity of SNM dropped below the 350-gram limit.
The events surrounding the September 18-19,1997, incident were also reviewed by the NRC during the October 1997 inspection. Corrective actions taken by Envirocare since the incident included employee retraining, revising container labels to specify if the material fell into the category of " direct disposal" (meaning that the wastes had to be disposed of that day), and revising the SNM log to specify if the material met the category of " direct disposal" waste material or not. Also, the facility operators were to be provided v.ith daily delivery schedules which identified the shipments containing SNM and the quantity of SNM in these shipments.
Longer term corrective actions planned included installation of the bar code system and review and approval of an SNM management portion of the procedure that was still in draft form during the October 1997 inspection. (After the onsite inspection, Envirocare decided to incorporate the SNM management requirements into existing procedures rather than implement one single SNM procedure.)
4 The causes of the September 1997 event were reviewed by the NRC inspector.
According to Envirocare's letter to the State dated July 24,1997, the causes of the incident included a breakdown in communications and mismanagement of the shipments. Additional contributing causes to the event identified during the NRC inspection included:
+
Envirocare's failure to have an implementing procedure in place to provide written i contingency instructions to operations personnel.
Misdirection of a high-profile shipment. The material was unloaded into the l restricted area but failed a critical chemical test. The procedure guidance in l place at that time was inadequate to clearly ascertain what should be done next, I
such as whether or not to return the shipment to the generator.
Too much informality in the process of controlling SNM onsite. For example, the SNM log was updated based on verbal communications.
a An ineffective SNM tracking system. (The implementation of the bar code system may resolve this dilemma.)
Site operators not being aware that the shipments had large amounts of SNM in them. In response to this problem, Envirocare revised the label that was affixed to all containers entering the site restricted area to clearly designate if that particular container included SNM.
In summary, although the licensee had identified an apparent root cause for the incident, i
a number of other causes were identified by the NRC inspector that may have had a direct or indirect impact on the incident.
Envirocare had a program available for use in determining a root cause, the quality assurance corrective action program (CAP), but decided against using it. The CAP, as discussed in the quality assurance manual, was used to identify and correct " conditions adverse to quality." These conditions include, but are not limited to, non-conformances, failures, malfunctions, errors, deficiencies, deviations, and defective materials.
The SNM exceedences, identified during May 1997 by the State, during June 1997 by the NRC, and during September 1997 by the licensee, were noted by the NRC inspector to meet the criteria of a " deficiency," based on the definitions provided in the licensee's l quality assurance manual. Specifically, the incidents 'were relevant to meeting regulatory l commitments and the incidents had the potential for recurrence. If implemented, the l CAP could have been used to document the incident, to assign responsibility for l identifying the root causes through causal analysis, to identify proposed corrective actions, and to ensure implementation of the proposed corrective actions.
However, Envirocare chose not to implement the CAP review process based on the i quality assurance manual statement: "In general, CAP items should be those that cannot be corrected immediately (within two days) or which require capital improvements, design changes, or major structural reconfiguration." Since the incident i lasted only 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, certain Envirocare representatives decided that the I September 1997 incident did not meet the CAP criteria. On the other hand, two problem reports were written by Envirocare for the shipments' failure of the chemical screen tests, but not for the exceedence of the SNM possession limits. (The problem reporting program was not a method used by Envirocare to identify and correct major site problems; therefore, Envirocare would not have written a problem report to perform a programmatic review of the SNM issues.)
Envirocare did write a CAP report on October 7,1997, to ensure that the SNM implementing procedure was developed and implemented to supplement the Compliance Plan. This particular report was not written to perform a detailed problem analysis, but to ensure that a specific corrective action was completed in a timely manner, i
The NRC inspector concluded that Envirocare may not have performed an adequate l assessment of the initial SNM exceedence incidents. Envirocare had a program, the CAP process, in place to perfo.m programmatic reviews, but it chose not to perform such l a review. If Envirocare had implemented a CAP review in response to the State's and i NRC's findings of May-June 1997, and if a root cause had been identified and corrected, l then the September 18-19,1997, incident may not have occurred.
l In a different matter, the September 18-19,1997, incident occurred on a Thursday and i Friday. The incident was identified by site operations personnel and reported to the i responsible State agency in a timely manner. The site radiation safety officer was informed of the event the following Monday. The corporate radiation safety officer, located offsite, was notified later the following week. The site operations staff did not i notify the responsible radiation safety staff members in a timely manner, although the incident involved radioactive materials. This occurrence was indicative of a potential need for Envirocare to improve internal notification of incidents to the responsible personnel.
In summary, Envirocare was noted to have fulfilled all requirements that were listed in the CAL and Order. However, an incident occurred which resulted in Envirocare exceeding the SNM possessoa limits for a third time since May 1997. The cause of the September 1997 incident was attributed by Envirocare to be a breakdown in communications and mismanagement of a high-profile shipment. Since Envirocare did not perform a formal corrective action program analysis, the root causes of the incident may not have been clearly identified. The two problem reports and one CAP report that were issued immediately after the incident occurred were only related to the failure of the chemical screen tests and completion of one particular corrective action.
2.11 Conclusions A review of the site activities indicated that Envirocare had SNM in its inventory in quantities that exceeded the NRC limits established in 10 CFR Parts 70.3,150.10, and 150.11 on at least three separate occasions. Envirocare's failure to maintain the uranium-235 quantity below the 350-gram limit on three specific dates was identified as an apparent violation of NRC requirements. Although three examples of the potential violation have been clearly identified, the licensee apparently exceeded the SNM limit on numerous occasions since 1995. l One plausible root cause of the problem was Envirocare's interpretation of what
, constituted possession. Envirocare's definition of possession differed from the State's and the NRC's concepts of the term. In addition, Envirocare failed to clearly discuss, in J
writing, its understanding and definition of possession with either the State of Utah or NRC. Envirocare appeared to deviate from the State's written understanding of possession during the fall of 1994. Envirocare continued to modify or revise its definition of possession without clear, written approval of either the State or the NRC. Finally, Envirocare informally revised the definition of possession in the fall of 1996 without even documenting the new interpretation. The licensee subsequently stored wastes containing mobile radionuclides on the low level radioactive waste storage pad starting in the fall of 1996 without adding the wastes to the SNM log. This action deviated from Envirocare's last written policy, established in January 1996, related to possession of SNM.
A second contributing cause to the potential violation of NRC requirements was Envirocare's failure to implement a corrective action program review of the SNM incident in an effective manner. The completion of a timely and thorough review of the problem following discovery of the SNM exceedences during May-June 1997 may have prevented the September 1997 incident from occurring.
A possible contributing cause to the third event was Envirocare's reliance on informal communications to update the onsite SNM log. Verbal and informal written ;
communications were used, in part, to keep the SNM log up-to-date. If a better method '
of communications between operations and shipping and receiving personnel had been formalized and established, then the third event may not have occurred. ,
Corrective actions were taken by Envirocare, including a reduction of the amount of SNM inside of the restricted area. As of October 1997, the licensee had less than 100 grams of SNM in its possession. Also, Envirocare fulfilled all requirements that stipulated in the NRC's CAL and Order.
3 Exit Meeting Summary The inspector presented the preliminary inspection results to the representatives of Envirocare at the conclusion of the first and third inspections on June 10,1997, and
October 9,1997, respectively. Envirocare's representatives acknowledged the findings as presented. Envirocare did not identify any documents reviewed by the NRC inspector as proprietary information.
On April 21,1998, a post-inspection discussion was held telephonically with Envirocare, and the final inspection results were presented to Envirocare at that time. l
[-
Attachment 1 PARTIAL LIST OF PERSONS CONTACTED Envirocare of Utah. Inc.
V. Andrews, Corporate Radiation Safety Officer G. Copeland, Director of Operations M. Davis, Low Activity Radioactive Waste Assistant Site Manager A. Erichsen, Facility Radiation Safety Officer D. Gilson, Shipping and Receiving Manager R. Hahn, Low Activity Radioactive Waste Site Manager G. Helstrom, Project Manager, Government Affairs K. Kesler, Compliance Officer C. Kirk, Assistant Quality Assurance Officer P. Larsen, Mixed Waste Sits Manager M. Wicks, Site Customer Services Representative State of Utah. Deoartment of Environmental Quality. Division of Radiation Control !
D. Finerfrock, Section Manager J. Hultquist, Environmental Health Scientist W. Sinclair, Director ITEMS OPENED, CLOSED AND DISCUSSED Ooened 99990004/9704-01 APV Envirocare's failure to maintain the quantity of uranium-235 in their )
possession below the 350-gram limit was an apparent violation of 10 CFR Pads 70 and 150.
Closed None Discussed None l
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.- i 2-x LIST OF ACRONYMS
. CAL Confirmatory Action Letter CAP corrective action program CFR Code of Federal Regulations LARW low activity radioactive waste NORM naturally occurring radioactive material NOV Notice of Violation .
PDR Public Document Room !
RCRA- Resource Conservation and Recovery Act SNM special nuclear material -
WIS Waste Information System 4
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. 6ttachmenL2 PHOTOGRAPHS TAKEN AT THE ENVIROCARE FACILITY 4
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