ML20058P706
| ML20058P706 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 12/06/1993 |
| From: | Gloersen W, Kuzo G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058P694 | List: |
| References | |
| 70-1151-93-09, 70-1151-93-9, NUDOCS 9312270243 | |
| Download: ML20058P706 (30) | |
Text
_-
i UNITED STATES
- s meo%
NUCLEAR REGULATORY COMMISSION
, 4
k REGION 11 101 MARIETTA STREET. N.W., SUITE 2900 i
j ATLANTA, GEORGIA 303234199 DEC 8 1993 Report No.:
70-1151/93-09 Licensee:
Westinghouse Electric Corporation Commercial Nuclear Fuel Division Columbia, SC 29250 Docket No.: 70-1151 License No.: SNM-1107 Facility Name: Commercial Nuclear Fuel Division i
Inspection Conducted: Octobe 25-29 and November 9, 1993 Inspector:
wf% /
/#/J/ O W.~ B. Gloersdn Date/ Signed 3f ra fb
[v-n 3 D u e ffD G.B.()Kuzo
[
Date Signed Approved by:
vuve /h d44L
/,2!6!93
[
T. R. Decker, Chief Dats Signed Radiological Effluents and Chemistry Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of radiological liquid and gaseous effluents, solid radiological-waste disposal and transportation, radioactive material transportation activities, onsite j
contamination documentation, and review of inspector followup-issues.
Results:
e The licensee had implemented an effective program to monitor and control liquid and gaseous radioactive effluents. The radioactive material released i
during'the first half of 1993 in the liquid and gaseous effluents were well within the limits specified in the License Application and 10 CFR 20.
Records-a of onsite contamination were reviewed-and it was noted that the files were -
readily accessible,.well organized, and maintained.
Program weaknesses were identified for the preparation, packaging, and shipping of solid radioactive waste and radioactive materials. Several' examples of shipping paper violations and documentation of routine 9312270243 931200 PDR ADOCK 07001151 C
determinations were identified (Paragraph 9).
Procedures and training for shipping paper preparation lacked sufficient detail to ensure compliance with applicable transportation regulations.
The following violation (VIO), non-cited violation (NCV), unresblved ites (URI) and issues to be tracked by the NRC as Inspector Followup Items (IFIs) were identified:
One NRC-identified VIO of 10 CFR 71.5 requirements for failure to meet Department of Transportation (DOT) shipping paper documentation criterta in accordance with 49 CFR 172.200 (Paragraph 9.a)
One NRC-identified NCV for failure to meet 10 CFR 71.91 requirements for-documenting specific determinations required by 10 CFR 71.87 for packaging associated with fissile material shipments (Paragraph 9.d).
NCV of 10 CFR 71.91 with licensee to complete corrective actions by November 30, 1993.
One IFI to review the results of the licensee's vendor laboratory split sample intercomparison (Paragraph 3.a).
One IFI to review licensee evaluation and actions regarding verification of internal contamination levels prior to designating licensed containers previously used for fissile material as " empty" for shipment (Paragraph 9.a).
One URI to review adequacy of current controls regarding the issuance and accuracy of USA /9239/AF packaging QC documentation was identified (Paragraph 9.e).
m 4
l REPORT DETAILS 1
Persons Contacted Licensee Employees M. Adams, Technician, Regulatory Operations
- K. Bartsch, Engineer, Regulatory Engineering J. Bond, Senior Engineer, Product Assurance S. Carver, Technician, Regulatory Operations R. Dortch, Traffic & Storeroom Services R. Erwin, Senior Engineer, Nuclear Materials Management and. Product Records
- J. Fici, Plant Manager
- R. Fischer, Senior Engineer, Regulatory Engineering G. Gantt, Senior Engineer, Regulatory Engineering
- D. Goldbach, Manager, Chemical Process Engineering
- W. Goodwin, Manager, Regulatory Affairs
+*J. Heath, Manager, Regulatory Operations
- J. Hooper, Engineer, Regulatory Engineering
- R. Jacobs, Conversion Supervisor
- E. Keelen, Manager, Manufacturing
- G. LaBruyere, Manager, Conversion Services R. McCormac III, Principal Engineer
- S. Mcdonald, Manager, Technical Services R. Montgomery, Regulatory Engineer F. Moorer, Coordinator, Traffic & Storeroom Services
- D. Precht, Manager, Materials Planning and Services
- J. Purcell, Manager, Traffic and Storeroom Services
- G. Rice, Quality Assurance
- E. Reitler, Manager, Regulatory Engineering T. Ross, Planning Specialist, Uranium Planning and Services _
- G. Rice, Senior Engineer, Nuclear Manufacturing Division, Quality Assurance
- C Sanders, Manager, Nuclear Materials Management and Product Records
- D. Trevett, Manager, Component Services
- W. Ward, Manager, Uranium Recycle and Recovery R. Williams, Technical Coordinator, Regulatory Affairs c
Other licensee employees contacted included engineers, technicians, and office personnel.
- Attended exit interview on October 29, 1993
+ Participated in telephone interview on November 9, 1993 2.
Followup Items (92701)
The following previously identified issues tracked as inspector followup items (IFIs) were reviewed and discussed with cognizant licensee representatives:
i; 2
a.
(0 pen) IFI 70-1151/93-04-01:
Evaluate the self-absorption correction factor for alpha particles and review procedure R0 004-A, Alpha Activity of a Water Sample.
The inspector reviewed the licensee's actions to address this issue which included revising procedure HP-05-004-1, Gross Alpha Activity of a Water Sample. At the time of this inspection, HP-05-004-1 had not been approved. The inspector reviewed the procedure and noted that the self-absorption correction factor was based on empirical methods using similar counting equipment at another laboratory facility. The inspector discussed with licensee representatives that the self-absorption correction factor should be empirically determined on the licensee's counting equipment and not on the results of another laboratory. This item will remain open.
b.
(Closed) IFI 70-1151/93-04-02:
Evaluate effluent sample delivery line configurations with respect to the guidance in ANSI N13.1.
During the last inspection (70-1151/93-04-02), it was noted that several sample delivery lines were not installed in accordance with the guidance in ANSI N13.1-1969, American National Standard Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities.
In particular, the inspector noted that the following sample delivery lines had two or more 90 degree bends between the sample collector probe and particle collector:
Furnace Exhaust Line 5 MAP Vent MAP Combined Exhaust ANSI N13.1-1969 recommends that 90 degree bends (or " elbows") in sampling lines should be avoided if at all possible, but when they_
are required, the bend radius of the elbow should be as long as practical, and design flow rates through any line containing an-elbow should be kept low.
It is recognized that flow patterns in elbows are complex, both in laminar and turbulent flow, and give rise to particle deposition greater than in the same length of_
straight tubing. No adequate theoretical treatment and very-little experimental data are available to define deposition loses quantitatively as a function of tube diameter, bend radius, flow rate, and particle size. However, ANSI N13.1, indicated that particle deposition appears to increase markedly with particle size and flow rate.
It was noted during this inspection, that the licensee took prompt action to evaluate the three sample delivery systems identified above and initiate corrective action to achieve ideal sampling l
3 conditions. The inspector noted that work order FBC-930-560 was initiated to reconfigure and/or relocate the three sample delivery systems in question.
The work was completed on October-19,1993.
The inspector examined the Furnace Exhaust Line 5, Map Combined Exhaust, and Map Vent-39 A and B and verified that the modifications had been performed. This item is considered closed.
3.
Liquid Effluents (88035) a.
Radioactive Liquid Waste Sampling and Analysis Safaty Condition S-1 of Materials License No. SNM-1107 authorized the use of licensed materials in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the License Application and approved supplements thereto.
Section 1.3.6 of the License Application described the sampling, monitoring and recording of radioactivity concentrations in liquid process wastes prior to discharge to the Waste Water Treatment Facility (WWTF).
In addition, Section 2.2.7 of the License Application specified the sampling and analytical controls for liquid waste disposal.
The liquid effluent released to the Congaree River from the WWTF was required to be sampled continuously by a flow rate proportional sample collector.
The licensee discharged approximately 130,000 gallons of liquid effluent per day. The licensee collected daily samples from the proportional sampler to monitor for National Pollution and Discharge Elimination System (NPDES) chemical parameters and gross alpha activity. As part of the NRC's confirmatory measurements program, on October 29, 1993, licensee representatives and the inspector collected two one liter liquid samples from the Waste Treatment Facility downstream from-the composite sampler so that a comparison could be made between.
the NRC and licensee results.
Samples were not collected from the composite sampler since there was insufficient sample volume to perform a sample split. The purpose of these comparative measurements was to verify the licensee's capability to measure quantities of radionuclides accurately in the liquid waste stream.
The licensee was required by Section 2.2.7.1 of the License Application to analyze 30-day composite liquid waste samples for gross alpha, gross beta, and isotopic uranium. The licensee utilized the services of a contract laboratory to perform these analyses. The inspector requested that one of the split samples be delivered to the licensee's contract laboratory without any indication that the sample is being used in a confirmatory measurements study with the NRC. The inspector also requested that the second split sample be delivered to the NRC Region II (RII) office. The licensee agreed with the inspector's request.
The inspector informed licensee management that the comparison of the sample analyses would be considered as an IFI (IFI 70-1151/93-09-01).
4
)
The inspector also reviewed a tabulation of the uranium isotopic analytical results for the monthly composite samples of the liquid i
effluents collected during January through June 1993 and determined that the concentrations of uranium (U)-234, U-235, and U-238 were well below their limits as specified in 10 CFR 20, Appendix B.
Based on observations, interviews with licensee representatives, and a review of applicable records, it was apparent that the WWTF was operating within its normal design parameters.such that the release ~of radioactive materials in the liquid effluent would be minimized.
b.
Sanitary Sewerage Waste System 10 CFR 20.303 specified the conditions for disposal of licensed material by release into sanitary sewerage systems. The licensee operated an onsite sewage treatment facility. Sanitary waste was treated in a 75,000 gallon extended aeration package plant-followed by a 1,500,000 gallon sanitary lagoon which was used as a polishing pond.
Gaseous chlorination was installed to assure compliance with the fecal coliform parameter. Prior to discharge the waste water was dechlorinated with sulphur dioxide. All' domestic wastes, shower water, cafeteria water, and miscellaneous waste streams were routed to the sanitary waste system. The treated water discharged from the Sanitary Waste Facility flowed into the liquid effluent discharge line which incorporated a continuous proportional effluent sampler as described above. The I
waste water was included as part of the total plant liquid effluent.
Solid waste was incinerated at the facility and the fly i
ash was disposed of as radioactive waste.
c.
NPDES Permit Section 2.2.7.2 of the License Application specified that any violation of the NPDES Permit shall be submitted within ten days of confirmation of the event to the NRC RII Office.
The inspector reviewed applicable records since the last inspection and discussed with the licensee situations involving violations of the licensee's NPDES Permit (#SC0001848).
It was noted that for the period June 1, 1993 through June 30, 1993,.the total solids parameter averaged 41.3 pounds per day which exceeded' the NPDES Permit limit of 32 pounds per day monthly average.
During that time period, the maximum daily average was not exceeded. The situation occurred due to excessive heat and resultant algae growth in the sanitary and industrial batch process lagoons. The licensee's corrective action to prevent
P 5
recurrence included increasing the chlorination in the lagoons to reduce the algae growth. A review of the licensee's processing, sampling, and laboratory methods indicated that 'all suspended solids limitations were being met. The licensee confirmed the event in late July 1993 after sample results were received from the contract laboratory and notified the State of South Carolina and the NRC RII Office by letter dated August 4, 1993.
Within the areas inspected, no violations were identified and the program was considered acceptable.
4.
Radioactive Gaseous Effluents (88035) a.
Radioactive Gaseous Effluent Sampling and Controls Safety Condition S-1 of Materials License No. SNM-1107 authorized the use of licensed materials in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the License Application and approved supplements thereto.
i Section 3.2.3.6 of the License Application specified the sampling and analytical controls for gaseous effluents.
Continuous sampling was required during production operations for those operations which could result in exhausting radioactive materials to unrestricted areas. Collection and analysis of those samples 4
was required to be performed on a schedule determined by the Radiation Protection Component of the licensee's organization to assure the required sensitivity of the measurement. The adequacy of the gaseous effluent controls was required to be determined by representative stack sampling to demonstrate compliance with 40 CFR 190.
In addition, the licensee was required to submit a report to the NRC whenever the radioactivity in the plant gaseous effluents exceeded 1500 microcuries per calendar quarter. The report was required to include the corrective actions to be taken to reduce the release rates.
The inspector discussed with licensee representatives and reviewed
[
monthly effluent and environmental monitoring reports for the period January to August 1993, and noted that the licensee had not exceeded the 1500 microcuries per calendar quarter limit during the aforementioned time period. The inspector did note that in May 1993 and August 1993, the maximum monthly average airborne radionuclide concentrations associated with the U 0, stripping 3
exhaust stack and the incinerator exhaust stack at the point of discharge were 147 percent and 158 percent, respectively, of the maximum airborne permissible concentration (MPC.) for insoluble U-234 as specified in 10 CFR 20, Appendix B for release to unrestricted areas.
It should be noted that these concentrations would be further diluted at the site boundary due to atmospheric i
e l
r-
~
6 mixing processes.
Procedure RA-401, Environmental Control Requirements Mandated by 10 CFR 20, Revision (Rev.) 3, May 5, 1992, specifies that if a daily stack air particulate sample exceeded the maximum permissible concentration of 4.0E-12 uCi/ml for.more than four consecutive samples, then the respective operation shall be terminated until the problem can be identified and evaluated. The inspector noted from the data reviewed above that the incinerator exhaust stack sample exceeded the MPC, for more than four consecutive times from August 10-16,-1993. At the time of the onsite inspection, appropriate records and work requests showing the corrective actions were not available. The inspector indicated at the exit meeting that the appropriate records would be needed to evaluate this issue. On November 9, 1993, during a telephone call, the inspector discussed with a licensee representative the information provided in the records which was received by faximile on the same day.. Based on a review of the records noted above, appropriate measures were taken to correct the problem, including replacement of the High Efficiency Particulate Air (HEPA) filter and in-place leakage and by-pass testing of the HEPA filter and housing using dioctyl phthalate (D0P).
The inspector reviewed procedure R0-06-002, " Roof Effluent Air Sampling and Counting," Rev. 8, September 20, 1993, and determined that it included provisions for the daily collection of air particulate samples from 44 sampling locations and analysis after a 24-hour decay period.
The inspector noted that Revision.7 of-the procedure utilized a one minute counting time on a proportional counter for the air particulate samples. A one minute counting interval on the licensee's proportional counter would typically result in a minimum analytical sensitivity of approximately 3E-13.uti/ml. The MPC, for insoluble U-235 in an unrestricted area is 4E-12 uti/ml. Revision'8 increased the:
counting time to ten minutes which effectively improved the minimal detectable activity (MDA) of the licensee's analytical equipment. A ten minute count with a' background count rate of three counts per minute (cpm) would result in an MDA of approximately 8E-14 uti/ml. Similarly, a ten minute count with a background count rate of one cpm would result in an MDA of approximately 5E-14 uCi/ml.
b.
Analytical Equipment
]
1 The inspector examined the licensee's counting and.anhlytical laboratory which was used primarily for analyzing both roof stack air particulate samples and in-plant stationary and mobile air particulate samples. The examination included both a review of records and interviews with laboratory personnel. Analytical j
l
7 equipment used for gross alpha and/or-beta counting included six Tennelec Model LB 5100 alpha / beta proportional counters and three Eberline Scintillation Alpha Counters (SAC-4).
In order to achieve the lower MDA's for analyzing roof stack samples, the licensee dedicated one Tennelec Model LB 5100 alpha / beta proportional counter for analyzing approximately 44 roof stack samples each collected once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Eberline SAC-4's were dedicated to count environmental air sampling station samples. The inspector reviewed the calibration records and the.
quality control source and background check records for the period December 13, 1992 - September 8,1993 for the Tennelec Model LB 5100 alpha / beta proportional counter (counter #4) dedicated for the analysis of the roof stack samples. The equipment was calibrated within the established procedural frequency (quarterly).
and included voltage plateau determinations, efficiency calculations, and Chi-Squared tests.
In addition, the inspector verified that the SAC-4s had been calibrated semiannually by a vendor (Eberline) and that the source checks were performed in s
accordance with procedural requirements. The inspector also verified that selected Regulatory Operations Technicians were knowledgeable of the limitations and operation of the instruments being used.
Within the areas ' inspected, no violations were identified and the l
program was considered acceptable.
5.
Records and Reports of Radioactive Effluents (88035) 10 CFR 70.59 requires the licensee to submit a report to the NRC RII i
office, within 60 days after January I and July 1 of each year, specifying the quantity of each the of the principal radionuclides released to unrestricted areas in liquid and gaseous effluents during the previous six months of operation.
If the quantities of radioactive-materials released during the reporting periods are significantly above -
the licensee's design objectives previously reviewed as part of the licensing process, the report shall cover this specifically.
t The inspector reviewed the Semiannual Effluent Release Report for the six-month period January 1, 1993 through June 30, 1993, and verified that it was submitted within the required time frame. -Although the.
minimum reporting requ;eements of 10 CFR 70.59 were met, the inspector observed that the report format guidance specified in Regulatory Guide 4.16, Monitoring and Reporting Radioactivity in Releases of Radioactive Materials in Liquid and Gaseous Effluents From Nuclear Fuel Processing and Fabrication Plants and Uranium Hexafluoride Production Plants, Rev.
1, December 1985, was not utilized. The inspector noted that the reporting format of the licensee's semiannual report.would be reviewed i
during a subsequent inspection. The quantities'of radionuclides released to unrestricted areas presented in' Table I were derived from previous licensee effluent release reports.
3
f 8
Table 1 Effluent Summary for Westinghouse Commercial Nuclear Fuel Division Activity Released (millicuries)
Year Gaseous Effluents Liouid Effluents 1985 1.54 246.20 1986 1.51 111.17 1987 1.40 57.16 1988
-1.44 34.54 1989 1.23 53.93 1990 1.23 24.34 1991 1.16 38.00 1992 0.99 18.56 1993 (Jan-June) 0.53 14.12 The total gaseous radioactivity discharged during 1992, was 0.99 millicuries of uranium, compared with 1.16 millicuries during 1991.
The licensee has experienced statistically significant downward trends during the last five years. Similarly,18.56 millicuries of uranium was discharged to the Congaree River in 1992, compared with approximately 38 mil 11 curies during 1991. Although there was a significant decrease in total liquid radioactivity discharged in 1992, during the last five years there were no apparent statistically significant trends identified. As indicated in Table 1 above, the annual totals for.
gaseous effluents since 1987 were less than 1500 microcuries, therefore no reports to the NRC were necessary for exceeding the License Application limit of 1500 microcuries per calendar quarter.
The inspector reviewed the report for 1993, and discussed the quantities of radionuclides released to unrestricted areas with the Senior Regulatory Engineer.
The licensee representative attributed the decrease in the quantities released to the following:
improved administrative controls for segregation of small unfiltered liquid waste streams into the waste treatment systems; improved operating practices for secondary filtration and removal of uranium from liquid waste generated by the ammonium diuranate (ADU) conversion process;.and a shift in the manufacturing operations to more use'of the direct'UF, to a
U0, powder conversion process and less use of the ADU conversion process.
Within the areas inspected, no violations were identified.
It was concluded that the licensee had implemented an effective program to monitor and control liquid and gaseous radioactive effluents and an 9
adequate program for the reporting of those effluents. The activity released during.the first' half of 1993 in the liquid and gaseous 3
effluents were well within the limits specified in the License Application and 10 CFR 20.106.
I 9
6.
New 10 CFR 20 Preparation and Implementation (88035,.88045)
The inspector discussed with the licensee the preparation.and planning i
for implementation of the new 10 CFR Part 20 by January 1, 1994..The discussions included changes in effluent controls, analytical procedures, license conditions, equipment, and dose calculation methodology. Many of the changes discussed below were in the planning stage and have not been implemented. At the time of this inspection, the licensee was not planning to submit a license amendment incorporating the changes required by the new 10 CFR 20.
l
'The licensee identified several air filtration systems where double HEPA filtration units could be added in order for roof effluents to be as low as reasonably achievable (ALARA). The following exhaust systems were identified based on a history of past discharges:
MAP Combined Exhaust U308-HF Stripping Exhaust Conversion I-A, 1-B, 3-A, and 3-B Incinerator Exhaust
'I Furnace Exhaust (Pellet) Line 5 In addition, the licensee was reviewing the following liquid effluent control upgrades:
Eliminate unknown source inputs of soluble uranium.
Flange off the discharge sump to the East lagoon from the cylinder recertification building.
Write a procedure to insure the contaminated sump and the final.
discharge sump are inspected on a semi-annual basis and the solids removed (inadvertent pH changes could cause the uranium in the-solids to solubilize).
Assure that liquid in Tank 1187 is continuously recirculated through the "Cuno" filter prior to discharge.
-l Reroute the sump discharge from the UNH pad to the solvent extraction or scrap recovery building rather than the current l
practice of pumping untreated waste to the contaminated sump.
Reroute the UF, trench effluent so that it is pumped to the Q tanks if this waste stream volume is small.
I l
9 10 4
As discussed in Paragraph 4.a, the licensee increased the counting time for roof stack air particulate filter samples from one minute to ten minutes. The increased count time effectively improved the minimal detectable activity of the licensee's analytical equipment, thus insuring the licensee would meet the new 10 CFR 20 limits. With the increased counting time, the licensee had dedicated one alpha / beta proportional counter for analyzing roof stack samples.
With regard to dose calculation methodology changes, the licensee was evaluating the US Environmental Protection Agency's (USEPA) COMPLY dose model code for site specific applicability. Presently,.the licensee used an in-house dose model code (STAR). The licensee also listed approximately eight Regulatory Affairs and Regulatory Operations procedures that required revision.
The inspector discussed the amount of implementation work that was r
required to be completed before January 1,1994 at the exit meeting.
The licensee acknowledged the inspector's concerns.
Within the areas inspected, no violations were identified.
t 7.
Onsite Contamination (88035, 88045, 84850) 10 CFR 70.25(g) and 70.30(d) specifically require licensees to maintain certain records important to the safe and effective decommissioning of the facility in an identified location until the license is terminated by the Commission. These records shall include drawings of structures and equipment in restricted areas where radioactive materials were used or stored, documentation identifying the location of inaccessible residual contamination, and detailed descriptions of unusual occurrences or spills of radioactive materials that can affect decommissioning.
The inspector reviewed with the licensee the onsite burial or-abandonment of radioactive materials in locations around the Westinghouse-Columbia facility. The inspector noted.that the licensee had maintained a " Decommissioning File" which included the following subfiles: (1) decommissioning plan preparation for the Columbia Fuel Fabrication Facility; (2) decommissioning reference manuals; (3) plant decommissioning meeting minutes and records; (4) pi nt decommissioning t
financial assurance mechanisms; (5) decommissioning records (residual contamination events, unusual occurrences, drawings, and spills of radioactive material); and (6) Site Decommissioning Management Plan (SDMP) records and documents. The inspector noted that the files were
)
readily accessible, well organized, and maintained.
]
Based on interviews with the licensee and a review of the records noted above, it appeared that the licensee had not buried.any contaminated equipment'or radioactive materials onsite, other than three decontaminated slab tanks (1971-1972). The licensee had identified the' following events, spills, or unusual occurrences involving radioactive material releases:
j I
11 P'ipe trench between the southwest. expansion and the WWTF..-In this area, various pipes had been rerouted so that they would be:above ground. The licensee had elected to leave the old,.slightly contaminated pipes underground. This area became part. of a new building and was subsequently covered with concrete..
j West lagoon rupture (northeast corner) in 1971. Approximately 1.5E+06 gallons of treated process water was released to Sunset -
Lake with gross alpha concentrations'less than ten percent MPC (this incident was addressed in the 1975 Environmental Report).-
-i Spillage of UNH between 1975-1978'on asphalt roadway (near Waste.-
Treatment). The roadway was subsequently sealed.
Approximately 100 pounds.of UF, was released for one hour in March 1
1977 from the ADV conversion aret The contamination was mostly q
confined in the building.
i Approximately ten gallons urainyl nitrate (UNH) was spilled at-the Dock Area 4 Door in 1991, and released to the. storm drain, but contained and cleaned up.
j Butler Building (storage of contaminated equipment)
.f
^
Old Chemical Nuclear Concrete Pad (storage of contaminated parts and equipment)
Old Decontamination Pad-Waste Treatment (cleaning of contaminated-parts and equipment)
The inspector also discussed with the licensee and reviewed records,-
drawings, and sampling results pertaining to the-uraniusa contamination j
in the soil below the solvent extraction (SOLX) subfloor. The SOLX-floor had areas where.the floor material-had " bubbled up"_ and/or was chipped. Some of the floor area had disintegrated exposing the sandy soil under the subfloor. On October 30, 1991', the licensee had designed-i a plan to determine (1) the extent-of-the contamination of the soil-under the 50LX floor; (2) repair.the floor;.and (3) prevent further-contamination of the; soil from spilled solutions. On November 18, 1991, the licensee initiated soil sampling activities at 13 locations' atl varying depths. The-licensee noted that the soil-below the bore holes was dry and. free of liquid. The location of significant contamination -
was under the dissolver with'a maximum concentration of 2711'pCi/ gram-gross alpha. The contamination was confined to a volume of-1 approximately 30 feet by 13 feet. and to a depth of 12 feet.- 'On January 3, 1992, the licensee-notified the RII. office regarding the
~
discovery of the uranium contamination below the SOLX floor.
The 1
~
licensee also performed soil and groundwater monitoring outside the-l solvent extraction area.
Based on ' groundwater sampling results from.
Well 37 (W-37), it was' concluded that it was unlikely that a'significant impact to the ground water in the vicinity of the solvent extraction l
=
i
?
-4 w
l area had occurred. However, soil concentrations at location HC-7 and HA-14 were 30.5 pCi/ gram and 44.3 pCi/ gram, respectively.
Corrective i
actions included removing approx!mately six feet of soil around sample locations HC-7, HA-14 and HA-15 for decontamination purposes.
In addition, a ground water monitoring well (W-38) was added in the r
vicinity of sample location HC-5.
The licensee also repaired the i
affected areas of the SOLX concrete floor that had been damaged from nitric acid spills with an epoxy coating.
On April 8,1992, the NRC RII Radiological Effluents and' Chemistry Section Chief made a site visit to review the current status the ground
[
contamination characterization. During the onsite visit,-two soil and five well water samples were prepared for an analytical comparison between NRC and the licensee. Oak Ridge Associated Universities performed the analyses for the NRC. Tables 2 and 3 summarizes the comparison of the sample matrices. The criteria for comparing analytical measurements is provided in Attachment 1.
Table 2 l
Confirmatory Measurement Comparisons Of Gross Alpha and Gross Beta Analyses For Hydrocone And Well Samples At The Westinghouse Commercial Nuclear Fuel Plant On April 8, 1992 Gross Alpha Well Licensee NRC 4
Sample #
1pCi/1)
(pCi/1)
Resolution Ratio Comparison-HC-2 6.0 (18)'
< 3.4 N.A.2 N.A.
N.A.
HC-5 5.0 (18)
< 4.3 N.A.
N.A.
N.A.
HC-6 0.0 (18) 6.7+/-2.5 3
0 Disagreement HC-9 6.0 (18)
< 4.0 N.A.
N.A.
N.A.
W-37 4.0 (20.5) < 3.3 N.A.
N.A.
N.A.
[
Gross Beta l
Well Licensee NRC Sample #
(pCi/1)
(DCi/1)
Resolution Ratio Comparison HC-2 12.0 (18)'
< 4.2 N.A.'
N.A.
N.A.
HC-5 11.0 (18) 4.4+/-2.6 2
2.5 Agreement HC-6 12.0 (18) 4.7+/-2.6 2
2.6 Disagreement.
HC-9 11.0 (18) 12.9+/-2.9 4
0.9 Agreement-W-37 12.0 (20.5) < 4.1 N.A.
N.A.
N.A.
'Well depth (feet) 2 Not Applicable 1
i
13 4
Table 3 Gross Alpha and Uranium Isotopic Analyses For Hydrocone And Auger Soil Samples At The Westinghouse Commercial Nuclear Fuel Plant On April 8,'1992 Gross Alpha NRC Soil Licensee U-234 U-235 U-238 Sample #
(DC1/a)
(DCi/a)
(DCi/a)
(DCi/a)
Ratio' HC-7 30.5 1.0+/-0.2
< 0.1-2.0+/-0.2 10.2 HA-14 44.3 75.2+/-l.3-4.1+/-0.4 16.6+/-0.7 0.5
'For determining the ratio, the concentrations of the uranium isotopes were added and compared.to the licensee's gross alpha measurement.
i From a review of the data in the tables above, the uncertainty associated with the well water samples is high and therefore a comparison of the measurements becomes less meaningful. A comparison of the soil sample data could not be made using the criteria. In Enclosure I since the licensee provided gross alpha measurements and the NRC's values were isotopic measurements.
Within the areas inspected, no violations were identified and the program was considered acceptable.
8.
Radioactive Waste Management (84850)
During the inspection, licensee initiatives, programs and associated documentation to meet requirements of the license application (Application), and/or 10 CFR Sections (55) 20.311, 61.55 and 61.56, as applicable to Low Level Radioactive Waste (LLRW) reduction, onsite-storage, and subsequent classification and characterization activities required for final disposal at a licensed burial site were reviewed and discussed in detail.
a.
LLRW Reduction Initiatives During the onsite inspection, licensee representatives outlined-the current status of their LLRW reduction program.
The inspector toured the outside storage locations established.to receive-and temporarily store LLRW generated from.onsite ~
activities.
Other than difficult to read label information for t
several 55 gallon drums ' queued for subsequent. shipping activities,.
no significant concerns regarding housekeeping. and. radiological-controls, that is posting and labeling, associated with the LLRW i
storage areas were identified.
Licensee representatives were aware.of the label concerns and noted that the barrels were.
awaiting shipping activities.
14 k
Licensee representatives outlined the status of the actions regarding LLRW reduction initiatives.. As of October 25 1993, licensee representatives projected that for calendar year (CY) 1993, approximately 2600 cubic feet (ft*) would be disposed of at a licensed burial facility and noted that the.value was similar to data presented for CY 1992.
Previous licensee initiatives which were successfully implemented included shredding, ultra-compaction, waste minimization, and the decommissioning of parts and equipment. The identified initiatives have resulted in a noted reduction in LLRW shipped for burial from approximately 5500 ft* in 1988 to the 2600 ft* projected for 1993.
For CY 1993, licensee initiatives included continued minimization efforts and a LLRW metals sorting program in preparation for potential smelting of contaminated materials by a vendor facility. The inspector informed licensee representatives that their LLRW reduction efforts were considered program strengths.
No violations or deviations were identified b.
Part 61 Analyses and Waste Classification 10 CFR 20.311(d) requires, in part, that each licensee prepare all wastes so that the waste is classified according to 10 CFR 61.55 and meets the waste characteristics requirements in 961.56 of the chapter.
Further, the NRC Branch Technical Position (BTP) on Radioactive Waste Classification, dated April 11, 1983, provides acceptable guidance for determining the presence and concentrations of radionuclides for classifying waste for near surface disposal.
During the on;ite inspection, current guidance and results for classification of LLRW generated from selected operations were reviewed and discussed with licensee representatives. The following procedures were reviewed and discussed in detail:
Chemical Operating Procedure (COP) - 831001, Handling, Processing and Disposing LLRW, Rev. 21, September 9, 1993 C0P - 831010, Inspection of Non-solidified LLRW Shipment, Rev. 10, September 24, 1992 CDP - 831011, Shipping documents's Preparation of LLRW Shipment, Rev. 9, September 2, 1993 From review of the documented guidance and discussions with selected licensee personnel, the inspector determined that the procedures provided details for processing and preparing _for disposal all routine LLRW types generated including combustible and non-combustible dry active waste (DAW), dried press cake (DPC), HEPA and intermediate filters, and scrap metals.
Appropriately trained individuals used scaling factors based on b
15 the total quantity of U-235 to determine the radioisotopes of U-234, U-236, and U-238 within each container of LLRW. The inspector verified that the scaling factors for the radioisotopes-of uranium, including U-234, U-236 and U-238 relative to the U-235 quantity were determined annually..For each container prior. to shipment, the content of U-235 was to be determined either through measurement of samples of waste material, for example, DPC, or direct gamma-scans of the selected LLRW material within containers.
Further, the inspector verified that the procedure required all wastes to be shipped as " low specific activity" and as " Class A," unstable wastes.
From review of the procedural limits regarding radionuclide content and current processes..
allowed for waste stabilization, the inspector verified that the current descriptors specified for LLRW shipped to a licensed burial facility were appropriate.
The inspector verified that appropriate 10 CFR Part 61 analyses were made and applied to seven waste consignments shipped to a licensed burial site from May 13, 1993 through September 14,-1993.
The shipments included DAW and DPC concentrates.
For the waste analyses, licensee actions met licensee procedural guidance and exceeded the requirements specified in 10 CFR 20.311 and 61.55, and the guidance presented in the applicable BTP. However, from discussions with individuals responsible and review of applicable procedures for packaging LLRW for disposal at a burial facility, the inspector noted a weakness regarding the responsible individuals' understanding of, and/or lack of documentation detailing the bases for limits specified within the current procedures.
In particular, the bases for the limitations regarding waste stability classification and for radionuclide quantity limitations were not understood nor were the bases detailed within the current procedures.
In several instances, questions by the inspector regarding the waste stability classification or radionuclide quantity limitations were not' answered, or. answered erroneously by personnel overseeing the radioactive waste packaging.
Following discussions regarding this issue, licensee representatives informed the inspector that technical details regarding waste shipping and burial were the responsibility of the Regulatory Affairs Department but stated that the noted issue would be reviewed to determine if additional procedural details and/or training would be appropriate.
No violations or deviations were identified.
c.
Waste Manifests 10 CFR 20.311(b) requires that a manifest system be used for shipments of waste to a licensed burial facility or licensed waste processor.
- ~.
~
+
)
~.:
/i
.i 4
16 r
U The inspector reviewed licensee manifests for.seven'LLRW shipments:
l made to licensed waste processing and/or burial facilities between q
May 13, and September 14, 1993. All manifests were completed in'-
accordance with the requirements'specified in 10 CFR 20.311'66b-d.
1 For selected shipments, the inspector. verified that' the waste was classified apprcpriately as Class A.
In addition, the inspectorc l
discussed licensee waste processing and verified the licensee l
characterization for the waste shipments. The classification 'and -
characterization of the wastes as "A Unstable '(AU)" for the i
shipments reviewed was determined to be appropriate. '
i i
R No violations or deviations were identified.
e y
9.
Transportation Act1 W 4s (86740) i L
10 CFR 71.5(a) requ.... _h licensee who transports licensed material-l outside the confines of its plant or other place of use, or who' delivers 1
licensed material.to a carrier for transport, to comply with the i
applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation-(DOT) in 49 CFR Parts 170-189.
.j t
During the onsite' inspection, transportation activities. including j
procedural guidance, record completeness and accuracy, and emergency a
response information to meet 10 CFR Part 71, 49 CFR Parts 171 -178,. and -
1 License Application requirements were reviewed, ay a.
Review of Shipping Activities During the onsite inspection, licensee transporta%m activities j
regarding shipments of fissile material, of empty packaging previously containing fissile material, and of LLRW made.to a j
licensed burial site.or processor were. reviewed. Selected records-for the following consignments were reviewed in detail.
j i
Radioactive Material LSA, NOS UN 2912, for seven separate j
shipments containing various-quantities of drums ~ of LLRW -
l shipped to a licensed burial site _or LLRW processor from 7
May 13, 1993 through September-14, 1993 i
RQ Radioactive Material Fissile,~ NOS UN 2918,' for seven separate ~ shipments of fissile: material ~containing fuel
~
elements shipped to selected power reactor facilities from.
July.28, 1993 through Octobar 8, 1993.
Empty Packaging,-NOS UN 2910, for a September 29,x1993 shipment of empty-packages previously used to transport:
j fissile material.
d a
'f j
17 The inspector. reviewed and discussed in detail the fol1'0 wing l
documentation used, and subsequently maintained in the licensee's' jl records for each fissile, LLRW, or empty package shipment, as' applicable.
Bill of Lading I
Radioactive Material Shipment Record
.i a
Customer Pre-shipment Checklist Vehicle Inspection Report.
Receipt and Loading Verification Checklist South Carolina Department of Health and Environmental l
Control (SC DHEC) RadWaste Shipment Notification SC DHEC Waste Manifest Form
)
Drivers Checklist for LLRW Shipments Packing List (Fuel Assemblies / Component Assemblies) l Fuel Shipment Information Form Container Log Sheet-1
=
Health Phys,1cs Request Form YLM Source Data, Radioactive Material Shipment' Record Subsequent to detailed reviews of specific shipment documentation, j
the following regulatory compliance issues were reviewed and discussed with cognizant licensee representatives.
49 CFR 172.201(c) requires shipping papers consisting of.
i more than one page to be consecutively numbered.and the.
i first page to bear a notation specifying the total number of
~l pages included in the shipping paper.
-- r The inspector noted that the required shipping paper i
descriptions required by 49 CFR.172.201-205 for seven LLRW consignments shipped between May 13 and September 14, 1993,--
were not listed on consecutively numbered pages nor were the correct total number of pages containing all the required information notated.
From discussions with' responsible individuals and review of applicable procedures,. the 1
inspector noted that responsible individuals were unaware of the applicable requirement nor was appropriate. guidance in l
place.
49 CFR 172.201(d) requires,'in part, that shipping' papers L
must'contain an. emergency response telephone number. as.
prescribed in Subpart G of Part 172Jof this subchapter.
During review of-shipping papers, the inspector noted that for an Auguct 3, 1993 LLRW consignment an emergency response telephonc number was not included on the' shipping papers.
Further inspection indicated the subject. documentation lwas completed by a shipping department representative'.
i substituting for the primary individual.
l i
t
~
18 4
49 CFR 172.203(c)(2) requires, in part, that the letters "RQ" be entered on the shipping paper either before or after the basic description required by sl72.202 for reportable quantities of hazardous substance as defined in 49 CFR 171.8 and listed in Column 3 of the Appendix to 9172.101.
Shipping paper descriptions for seven LLRW consignments shipped between May 13 and September 14, 1993, were listed improperly as having RQ of radioactive materials before the basic description required by 5172.202. The error was attributed to assessing the need for the RQ description based on the total quantity of radioactive materials in the shipment rather than the quantity of radioactivity within each individual container as required.
49 CFR 172.203(d)(vi) requires, in part, that shipping l
papers for a consignment of fissile radioactive materials include the words " Fissile Exempt," if the package is exempt from the requirements of 49 CFR 173.451-459 pursuant to 6173.453 of the subchapter.
Shipping paper descriptions for seven shipments of LLRW shipped between May 13, 1993 and September 14, 1993, which included packages containing fissile material exempted from the requirements of 49 CFR 173.451-459 in accordance with 5173.453, did not include the additional description of the hazardous material as " Fissile Exempt."
Excluding the need to number shipping paper continuation pages in accordance with 49 CFR 172.201(c), licensee representatives were knowledgeable of the requirements for reportable-quantities and fissile exempt descriptions on shipping papers. However, review of the licensee's applicable procedures used for preparing documentation associated with shipment of LLRW materials indicated that detailed guidance for RQ and continuation page descriptions were not provided.
Licensee representatives stated that corrective actions to the noted examples of noncompliance would include a review of the current procedures.
The inspector informed licensee representatives that failure to meet DOT shipping paper documentation requirements for hazardous materials as noted-in the examples above were considered collectively as a violation of 10 CFR 71.5 requirements (VIO 70-1151/93_-09-02).
In addition, the following weaknesses in transportation program activities were identified and discussed with licensee representatives.
i
w 19 Empty Package Contamination Surveys 49 CFR 173.427 requires, in part, that'a package which previously contained radioactive materials and has been emptied of contents as far as practical, is excepted from the shipping paper and certification, marking and labeling requirements of this subchapter, and for the requirements of this subpart, provided that (b) the package is unimpaired and securely closed, and (c) internal contamination does not exceed 100 times the limits specified in 9173.443.
During discussions and review of records associated with a September 29, 1993 shipment of empty packages which previously contained fissile material, the inspector noted that data regarding internal contamination levels were not available. Licensee representatives stated internal contamination surveys were not conducted for each package in I
an empty container shipment, but that' a large proportion of all incoming packages were surveyed during refurbishment activities on an informal basis.
Further, all refurbishment activities were conducted outside of the licensee's radiologically controlled areas prior to any shipment of the empty packaging. The inspector selectivaly reviewed results -
of internal package contamination surveys conducted between r
July 1, and October 1,1993, following receipt of empty i
shipping containers. All contamination survey results were less than the limits specified in 49 CFR 173.443.
Following discussion regarding the weaknesses in the currentipractice for verifying empty package internal ~ contamination levels, licensee representatives stated that the current practice would be either formalized or. a procedural change implemented to conduct internal surveys of'each empty package shipped from the site. The inspector informed licensee representatives that their evaluation and subsequent actions regarding program enhanecments to verify internal contamination surveys for shipping empty containers would ba tracked by the NRC as an IFI (IFI 70-1151/93-09.
03).
Supplemental Record Completeness and Accuracy During review of Radioactive Material Shipping Records, the inspector noted numerous errors in completing this supplemental documentation associated with proper listing of container types, completion of applicable checkoffs and accurate listing of total activity for fissile materials
~
contained in selected packages. Review of required shipping paper documentation indicated that the proper container types and activity levels were entered on the required
.i shipping records. However, the inspector noted that the errors indicated a lack of attention to detail regarding preparation of the supplemental documentation and a lack of a
3
20 4
management oversight regarding shipping activities.
Licensee representatives stated that increased overview of these areas would be initiated.
No additional issues regarding shipping paper documentation activities were identified.
One VIO of 10 CFR Part 71.5 requirements for failure to follow DOT shipping paper criteria and one IFI to review licensee evaluation and subsequent actions regarding monitoring of internal contamination levels prior to shipping."as empty" packages previously containing fissile material were. identified.
b.
Procedural Guidance During the onsite inspection the procedural guidance specified for the shipment of radioactive materials was reviewed against the selected criteria specified in 49 CFR Parts 171-178.
In addition to the shipping paper requirements specified in 49 CFR' Subpart C, procedural details were reviewed against requirements established for packaging (49 CFR Part 173), marking and. labeling (49 CFR Part 172, subpart D, 56172.400-407.and 90172.436-440),
monitoring (49 CFR Part 171, subpart I), and emergency response information (49 CFR, subpart G).
CDP - 831011, Shipping Documents' Preparation of LLRW Shipment, Rev. 9, September'2, 1993' Nuclear Materials Management & Product Records Critical Procedure-650, Nuclear Material Shipments, Rev. 5, May 5, 1993 The inspector reviewed and evaluated the above' procedures regarding the above referenced DOT requirements. Additionally, the procedure was reviewed for appropriate guidance in response to concerns involving.the inability to. complete required shipping
'l paper documentation as identified during review of applicable records. The inspector noted the following program weaknesses 4
from review and discussion of current shipping practices. Two different departments were responsible for preparation of LLRW shipping paper documentation. Neither department was aware of, or; participated in reviews of each other's procedures.
- Further, Nuclear Materials Management & Product Records Critical Procedure-
.i 650, Nuclear Material Shipments, Rev. 5, May 5,1993, provided minimal guidance regarding shipping requirements.
Licensee representatives stated that completion of shipping activities was dependent upon the extensive knowledge of the applicable regulations in 49 CFR for personnel, i.'e., both the primary and backup individuals. The inspector noted that the issues of noncompliance associated with 00T documentation as identified during the onsite inspection may have been avoided with improved procedural guidance.
Licensee representatives stated that
21 corrective actions associated with their response to the noted example of noncompliance identified in Paragraph 9.a would include review of the current procedures.
No violations or deviations were identified.
c.
Authorized Packages 10 CFR 71.12 (Subpart. C) requires, in part, that (a) a general license is issued to any licensee of the Commission to deliver to a carrier for transport, licensed material in a package for which a license, certificate of compliance (CoC), or other approval has been issued by the NRC and; and applies only to a licensee who (c)(1) has a copy of the specific Coc, and other approval of the package and has the drawings and other documents referenced in the approval relating to the use and maintenance of the packaging and to the actions to be taken prior to shipment and (c)(2) complies with the terms and conditions of the license, CoC, or other approval as applicable, and the applicable requirements of Subparts A, G, and H of this Part.
F 49 CFR 173.471 details additional requirements for the shipment of NRC-approved packager.
During the onsite inspection, licensee activities associated with packaging and shipping of fissile materials were reviewed in detail.
i The inspector reviewed and discussed with cognizant licensee representatives selected aspects of current quality control (QC) program activities associated with packaging and transportation operations for fissile material shipments made between July 28, and October 8, 1993. The inspector noted that the fissile material was shipped using CoC No. 9239, USA /9239/AF packaging.
The inspector verified that the licensee maintained the most recent revision of CoC No. 9239, i.e., Rev.1, July 6,1992, and referenced documents in accordance with 10 CFR 71.12(c)(1) requirements and, in addition, was a registered user of the package in accordance with 71.12(c)(3).
No violations or deviations were identified.
d.
Operating Controls and Procedures 10 CFR 71.91(a)(10) (Subpart G) requires, in part, each licensee l
to maintain for a period of three years after shipment a recordlof each shipment of licensed material not exempt under 971.10 showing results of the determinations required by 971.87 and by the conditions of the package approval.
I r
n 22 10 CFR 71.87 requires, in part, that prior to each shipment the licensee shall ensure that the package is (a) proper for the shipment type, (b) in unimpaired physical condition; (c) Closure devices are properly installed, secured, and free of defects; (f) the package has been loaded and closed in accordance with written procedures; (h) any structural package lifting or tie-down devices are rendered inoperable; and (i&j) the levels of contamination and external radiation levels on each package are within specified limits.
The following guidance including procedures and checkoff sheets associated with quality control activities for fissile material shipments using the USA /9239/AF packaging (MCC) was reviewed in detail.
Regulatory Operations Operating (R00) Procedure, R00 02-002, Surveys of Outgoing Shipments of Radioactive Materials, Rev. 3, December 21, 1993 Quality Control Instruction (QCI) Number (No.) 938603, Fuel Assembly & Skeleton Shipping Container Checklist, Container Inspection Prior to Assembly Loading, Rev.107, October 20, 1993 QCI No. 93604, Fuel Assembly Shipping Container, After Container Closing, Rev. 24, 1992 QCI No. 938605, Fuel Assembly Shipping Container Checklist, Rev. 21, July 13, 1993 CF-75B-004, Truck Loading Routing and Verification Checklist, Rev. O, November 12,'1992 Mechanical Operating Procedure (M0P) 755703, Truck Loading of Shipping Containers, Rev. 14, November 19, 1992 From detailed review of the referenced guidance and selected review of shipment records associated with fissile material shipments made using the MCC packaging, the inspector noted that documentation for all of the applicable determinations required by 10 CFR 71.87 were not available for review.
In particular, the inspector noted that no documentation was available indicating that structural package lifting devices were rendered inoperable-in accordance with 10 CFR 71.87(h); and in addition, that although the levels of external radiation were determined and subsequently documented for the packages, results verifying thet the contamination levels were within the specified limits were not documented for each container.
From discussion with cognizant licensee representatives, the inspector noted that contamination surveys were conducted for each container but only the maximum
i i
4 23 value associated with each shipment was documented. The. inspector informed licensee representatives that the failure to maintain selected records of the determinations required by 10 CFR 71.87 was a violation of 10 CFR 71.91(a)(10) requirements.
Following identification of the current. issue, licensee representatives stated that procedural / program changes needed to meet the documentation requirements specified by 10 CFR 71.91 for the specific CoC packages used for shipments of fissile material would be initiated.
Further,. licensee representatives stated that; these changes would be completed by December 1, 1993. The inspector informed licensee representatives that as a result-of the low safety significance of the issue and proposed corrective actions,'the violation for failure to meet 10 CFR 71.91 documentation requirements met the criteria specified in Section VII.B of the Enforcement Policy and would not be cited (NCV 70-1151/93-09-04).
One NCV for failure to document in accordance with 10 CFR 71.91 t
specific determinations required by 10 CFR 71.87 for packaging i
used to ship fissile material was identified.
e.
Packaging Quality Assurance (QA) Program (86740) 10 CFR 71.101 (Subpart H) requires each licensee to establish, maintain, and execute a QA program satisfying each of the applicable criteria of s9101 through 137.
The inspector reviewed and discussed with cognizant licensee representatives selected aspects of current QA program and QC activities associated with packaging and transportation operations.
Program areas reviewed included.
packaging / transportation and QC program organizational structures and responsibilities, QC activities and documentation, and licensee audits. The following QA program areas associated with licensee implementation of selected 10 CFR 71, Subpart H requirements were reviewed.
s 71.103 requires, in part, that the persons and organizations performing QA functions must have sufficient authority and organizational freedom to identify quality problems. The persons / organization'must report to a management level which assures that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
The current transportation and associated QA organizational structures and assigned responsibilities were reviewed and discussed with cognizant licensee representatives. The m
24 inspector noted that personnel independent of the shipping department provided QC review of activities associated with packaging / transport of fissile material shipments.
5 971.113 requires, in part, that the licensee establish measures to control the issuance of documents such as-instructions, procedures, and drawings, including changes, which prescribe all activities affecting quality. These measures must assure that documents, including changes are reviewed for adequacy, approved for release by authorized personnel, and distributed and used at the location where the prescribed activity is performed.
The inspector reviewed and discussed selected QC records-associated with MCC contriners, i.e., package Model USA /9239/AF, Certificate of Compliance (CoC) No. 9239, Rev.1, dated July 6,1992.
At the time of the onsite inspection, Fuel Assembly Shipping Container Inspection Checklist, Form No. CF-75B-002, Rev. 4, dated June 10, 1993, was being used in association with packaging refurbishment activities.. The inspector noted that one QC checklist required operators to verify that the license plates on. the packages bore an USA /5450/AF designation rather than the correct USA /9238/AF identification.
Further. review of August 1, through October 1993 refurbishment records for MCC packages indicated that all checkoff sheets regarding this issue were checked improperly as being acceptable by operators.
From review of ongoing refurbishment activities and discussion with operators, the inspector noted that QC-record discrepancy had not be noticed nor identified for corrective actions. Because this issue was identified during the final day of the onsite. inspection, the inspector requested licensee representatives to review the adequacy of the current container inspection checklist. The inspector informed licensee representatives that the adequacy of their l
review and control of the QC documents for the MCC packaging would be considered an unresolved item (URI) pending results of their evaluation (URI 70-1151/93-09-05).
s71.137 requires, in part, the licensee to carry out a-comprehensive system of planned and periodic audits to verify compliance with all aspects of the QA program and to determine the effectiveness of the program.
The inspector reviewed and discussed the current program for conducting audits of transportation / packaging activities with cognizant licensee representatives. Requirements for conducting the routine and_special audits are'provided in Nuclear Manufacturing Division QA procedure No. QA2.18.1,.
Internal Quality Assurance Audits, Rev.14, October 15, 1993. Audits of each department performing activities related to quality are conducted annually and each QA
25 program criterion is covered in at least one audit at each site. The audits are to be conducted by trained and qualified staff provided by the Nuclear Manufacturing Division corporate office.
The. procedure requires that the audits are performed in accordance with written checklists and that the results are documented and reviewed by appropriate management.
Further, the procedure provides appropriate guidance for receiving responses to finding and conducting followup of each response. Status of items is maintain-d in an Audit Commitment Tracking System. The inspector noted the audit system guidance as a program strength.
Audits of transportation / packaging activities conducted between January 1, 1992 and October 22, 1993, were' reviewed
+
and discussed with cognizant licensee representatives. 'The inspector verified that the audits were performed in accordance with written procedures or checklists by appropriately trained personnel who did not have direct responsibilities within the areas being audited.
- Further, the audit results were documented and reviewed by management having responsibility in the area audited and that followup actions, including reaudits of deficient areas, were completed, as applicable. The following audits were reviewed and discussed.
Internal Audit 192-01-Shipping containers, Transportation (10 CFR 71), conducted February 24-28, 1993.
QA Mini Audit of Shipping Container Log Books, October 11, 1993 For the audits reviewed, the inspector verified that responses and subsequent corrective actions regarding identified quality issues were completed and corrective actions appeared appropriate.
Further, the inspector noted that the majority of identified issues within the packaging and transportation program were associated with proper control of container parts. The inspector verified that corrective actions were completed and/or in progress and none of the identified items involved issues similar to those identified during the current NRC inspection.
One URI to review current license measures to control the issuance of MCC container refurbishment QC document accuracy was identified.
_.1 F-26 10.
Information Notices (92701)
L The inspector determined that the following Information Notices (ins) had been received by the licensee, reviewed for applicability, distributed to appropriate personnel, and that action, as appropriate, was taken or scheduled.
92-11: Soil and Water Contamination at Fuel Facilities
.i 92-14: Uranium 0xide Fires at Fuel Facilities 92-58: Uranium Hexafluoride Cylinders - Deviations in Coupling Welds 92-62:
Emergency Response Information Requirements for Radioactive Materials Shipments The inspector noted that the licensee did not have copies of the following ins and, therefore, copies were provided to the licensee during the onsite inspection:
92-34: New Exposure Limits for Airborne Uranium and Thorium 92-72: Employee Training and Shipper Registration Requirements
=
?
for Transporting Radioactive Materials Within the areas inspected, no violations were identified.
11.
Exit Interview The inspector met with licensee representatives indicated in Paragraph 1 at the conclusion of the inspection on October 29, 1993, and via telephone on November 9, 1993. The inspector summarized the scope and findings of the inspection, including the violations, URI, and IFIs.-
The inspector also discussed the likely informational content of.the inspection report with regard to documents or processes reviewed by the inspector during the inspection. Although proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes have been deleted in this report. Dissenting comments were not received from the licensee.
During the November 9, 1993 telephone _ conversation with the licensee,
[
the inspector discussed records and work requests pertaining to the corrective actions taken due to the incinerator exhaust stack air-particulate sample exceeding the MPC for more than four consecutive samples. The appropriate records were received by faximile on the same day.
f n
j
'I 27 y
Type Item Number
' Status' Description and Reference l
t
- IFI.
70-1151/93-04-01 Open Evaluate the self-absorption-l correction. factor-for alpha--
particles'and review procedure.RO.
05-004-A, Alpha Activity of.a Water
'i Sample (Paragraph 2.a).
IFI 70-1151/93-04-02 Closed-Evaluate effluent sample delivery--
line configurations with-respect to'
,i the guidance in ANSI N13.1-(Paragraph 2.b).
t IFI 70-1151/93-09 Open Compare. analytical results for gross?
j alpha, gross beta, and isotopic l
uranium of a liquid waste sample i
collected on October 29, 1993 (Paragraph 3.a).-
j VIO 70-1151/93-09-02 Open Failure to meet DOT shipping paper.
documentation criteria in.accordance1.
-i with 49.CFR 172.200 (Paragraph 9.a)..
IFI 70-1151/93-09-03 Open Review licensee evaluation'and '
actions regarding. verification of internal contamination -levels prior to. designating licensed containers'.
previously used for fissile material as " empty" for. shipment-l (Faragraph 9.a).'
NCV 70-1151/93-09-04 Open Failure to meet'10 CFR 71.91-requirements for documenting' _
specific determinations' required by' i
10 CFR 71.87 for. packaging.
j associated with fissile material:
1 shipments-(Paragraph 9.d).
1 URI 70-1151/93-09-05 Open-Review adequacy of current controls' regarding the. issuance'and accuracy of USA /9239/AF packaging QCL.
documentation (Paragraph 9.e).
j t
h I
i
?
. m
.w ATTACHMENT 1
{
1 CRITERIA FOR COMPARING ANALYTICAL MEASUREMENTS This enclosure provides criteria for comparing results of capability tests and.
verification measurements. The criteria are based on an. empirical relationship which combines prior experience and the accuracy needs of this program.
~!
In this criteria, the judgement limits denoting agreement or disagreement-between licensee and NRC results are variable. This variability is a function i
of the NRC's value to its associated uncertainty. As the ratio of the NRC value to its uncertainty, referred to in this program as the resolution' increases, the range of acceptable differences between the NRC and licensee values should be more restrictive.
Conversely, poorer agreement between NRC and licensee values must be considered acceptable as the resolution decreases.
2 For comparison purposes, a comparison ratio of the licensee value to the NRC value for each individual nuclide is computed. This ratio is then evaluated for agreement based on the calculated resolution. The corresponding resolution and calculated ratios which denote agreement are listed in Table 1 below. Values outside of the agreement ratio for a particular nuclide are considered in disagreement.
3 TABLE 1 1
Confirmatory Measurements Acceptance Criteria Resolutions versus Comparison Ratio Resolution Comparison Ratio for Agreement
<4 0.40 - 2.5 I
-7 0.50 - 2.0 J - 15 0.60 - 1.66 16 - 50 0.75 - 1.33 51 - 200 0.80 - 1.25
> 200 0.85 - 1.18 4
i i
' Resolution - NRC Reference Value for a Particular Nuclide Associated Uncertainty for the Value 2 Comparison Ratio - Licensee Value NRC Reference Value l
I