ML20154C342
| ML20154C342 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 09/11/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154C341 | List: |
| References | |
| 70-1113-98-03, 70-1113-98-3, NUDOCS 9810060243 | |
| Download: ML20154C342 (23) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.:
70-1113 License No.:
SNM-1097 Report No.:
70-1113/98-03 1
Licensee:
General Electric Company j
t Wilmington, NC 28402 Facility Name:
Nuclear Energy Production Dates:
August 17-21, 1998 Inspector:
W. Gloersen Senior Fuel Facility Inspector Accompanying Personnel:
H. Astwood, Environmental Scientist Approved by:
E. J. McAlpine Chief Fuel Facilities Branch Division of Nuclear Materials Safety O
i Enclosure i
9810060243 990911 PDR ADOCK 07001113 C
EXECUTIVE
SUMMARY
General Electric Nuclear Energy NRC Inspection Report 70-1113/98-03 The primary focus of this routine unannounced irlspection was the evaluation of the licensee's conduct of the transportation program for radioactive materials and the radioactive waste management program, including liquid and airborne effluent controls: and the management of solid radioactive waste. The report covered a one week period and included the results of inspection efforts of one regional fuel facility inspector and the Office of Nuclear Materials Safety and Safeguards (NMSS) Project Manager for the facility.
Waltr Manaaement The As Low As Reasonably Achievable (ALARA) program was thorough and complete.
U the )rogram.pper level managers were aware and actively participated in The ALARA program was proactive in finding solutions to furt1er reduce the airborne effluent discharges from operations 4
(Section 2.a(2)).
The review, safety analysis, and follow up to support the temporary cperation of the V-115 nitrate waste tank operation was thorough and well documented.
The temporary V-115 tank alignment was not expected to generate a significant increase in the liquid effluent released (Section 2.b(2)).
The effluent air sampling equipment was in excellent material condition due mainly to the use of stainless steel sample equipment enclosures and sample delivery lines (Section 2.c(2)).
Procedural guidance for technicians to account for alpha particle self-absorption losses on stack particulate filters due to dust loading needed improvement by making appropriate references to the technical document (Section 2.c(2)).
Total quantities of uranium released in the liquid effluent from the facility have been decreasing since 1994. Although the air effluents were slightly higher than the licensee expected, the releases were well below license application and regulatory limits (Section 2.d(2)).
The licensee had committed significant resources to com)lete the restructuring program which included the reduction of t1e volume of recoverable waste, the burial of non-recoverable residue waste, the relocation of CaF, and the recovery of incinerator ash (Section 2
2.f(2)).
The waste shipping manifests were complete and provided an acceptable level of information in the shipping papers to determine the quantities of individual radionuclides shipped (Section 2.h(2)).
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l Transcortation The licensec's rformance in transportation activities was acceptable.
(Section 3.a(2)
The licensee's process to identify and correct incidents that violated regulatory requirements was acceptable and timely. The licensee's responses to the transportation unusual incidents were focussed on
, preventing. recurrence (Section 2.b(2)).
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REPORT DETAILS 1.
Summary of Plant Status This report covered the efforts of one regional inspector and the NMSS Project Manager for the facility for a one week period. The Ammonium Diurante (ADU) and Dry Conversion Process (DCP) powder production facilities had been cleaned for the annual Special Nuclear Material (SNM) inventory on July 31. 1998.
The west nitrate waste lagoon had been cleaned out and relined.
In addition, the licensee was repairing i
and relining the V-104 final nitrate waste holding and treatment vessel, l
A temporary, smaller capacity tank was aligned to receive nitrate wastes until the repairs to the V-104 vessel were com)leted.
There were no unusual plant operational occurrences during tie onsite inspection.
2.
Waste Manaaement (84850. 84900. and 88035) (R3) a.
As low As Reasonably Achievable Proaram for Effluents (1) 1psoection Scooe The inspector reviewed the licensee's program for j
maintaining effluent discharges as low as reasonably achievable (ALARA) in accordance with Regulatory Guide 8.37.
(2)
Observations and Findinas The inspector reviewed the licensee's Practices and
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Procedures for the Operational Radiation Safety Committee.
The Radiation Safety Committee (RSC) was responsible for radiation safety during plant operations. the ALARA program for operations and the development of the annual Radiation Safety Committee Strawman document.
The inspector noted that the records were well maintained.
i The RSC reported to the Wilmington Safety Review Committee (WSRC) which was a panel of upper level managers.
The inspector reviewed the current 1998 " straw man" document which contained a descriation of the review of past o)erational trends and t1e selection of ALARA projects for tie upcoming year. The inspector also reviewed the 1997 Annual Wilmington Safety Review Committee ALARA Review which was a summary of the ALARA projects, actions taken and results from last year's projects.
The RSC met with the WSRC annually to discuss the ALARA program and projects. At this meeting, the past projects were reviewed and projects for the coming year were determined, including projects for effluent controls. The potential projects were first ranked based on factors such as the potential risk, past trends, and possible future impacts. Once the WSRC and the RSC determined projects for the upcoming year. the managers responsible for the areas of concern develo)ed an action plan and assigned responsible persons for t1e project.
As
2 noted in Section 2.d of this report, Effluent Discharges, the licensee was reviewing solutions to further reduce air emissions from the DCP facility due to higher than expected releases from the facility.
(3)
Conclusions The licensee's ALARA program was thorough and complete.
U)per level managers were aware and actively participated in tie program.
The ALARA program was proactive in finding solutions to furthar reduce the airborne effluent discharges from operations.
b.
Liouid Effluent Proaram Controls and Procedures (1)
Insoection Scooe l
The inspector reviewed the licensee's program for liquid effluent controls and monitoring.
(2)
Observations and Findincs The inspector observed technicians collect liquid effluent samples from the north and south lagoons, aeration basin, and site dam.
In addition, the inspector observed liquid samples collected from radwaste and laundry waste.
Licensee procedure PROD. 80.69. NF and CM Process Effluent Control.
i Site Process Lagoons, and Storm Water Management. Revision l
- 16. March 10. 1997 was referred to by the technicians in the
~ field. At the time of this inspection, this procedure was i
under revision. The inspector noted that the technician was knowledgeable of his duties and that the sample collection technicue and sampling equipment used by the technician 1
ensurec that a representative sample was collected.
The inspector also reviewed liquid waste operations in the
' ranium Recovery area. At the time of this inspecti0n. the J
V-104 nitrate waste tank was temporarily out of servi'e due to the replacement / restoration of the rubber liner in the vessel.
Tank V-104 was the final nitrate waste holding and treatment vessel before discharge to the nitrate waste lagoon.
This vessel had a 20.000 gallon capacity.
The licensee was temporarily using a smaller tank (V-115: 9000 gallon capacity) to receive nitrate waste until repairs on the V-104 tank liner were completed. The normal V-104 tank o)eration involved uranium precipitation and flocculation in tie vessel and the removal of solids by filtration and/or centrifugation. After this operation, approximately 2 ppm j
uranium in the supernate flowed to the nitrate waste lagoon.
The V-115 tank was not designed for precipitation and flocculation operations and, in addition, the V-115 tank did
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not have a filtering system.
Thus, a higher concentration e
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l of uranium (approximately 300 ppm U) in the nitrate waste 1
solution was expected to be sent to the central waste lagoon. Flock addition and arecipitation was to occur in the central waste lagoon. T1e licensee had alanned to transfer waste from the V-115 tank on a per )atch basis with an 1 'pection after each batch to monitor for any solids accumulation to prevent the formation of a heel in the domed l
bottom of the tank.
The licensee had 31 aced a 25 kilogram limit on the total mass of uranium to 3e processed and sent to the central waste lagoon via this system alignment.
Even though a higher concentration of uranium was being sent to the central waste lagoon via this temporary tank alignment.
it was expected to have a negligible effect on the liquid effluent released due to the chemical process to settle the uranium solids in the central waste lagoon.
However, the licensee would have to contend with the increased uranium concentration in the sludge of the central waste lagoon.
1 The liquid portion of the waste from the central waste lagoon was being sent to Federated Paper via a tanker truck.
The licensee was authorized via Section 1.3.3.3 of the license application to transfer nitrate-bearing liquids to an off-site liquid treatment system located at a commercial paper operation provided that the uranium concentration does not exceed a 30-day average of five parts per million by weight of the liquids and the enrichment is less than or equal to five weight percent U-235.
With regard to operating the temporary V-115 tank alignment, the inspector Erified that the licensee had addressed the following issues:
De-coupled tank V-115 from other inputs Enhance operator awareness of diligence during nitrate waste solution transfers from tank V-103 to V-115.
Address material control and accounting concerns for accountability cf transfer solutions Review criticality safety assessment assumptions Secure a b3ck-up air compressor to assure that the solids m tank V-115 were kept in suspension via continuous air sparging Maintain configuration control of both V-103 and V-115 e
tanks A) prove a temporary operating instruction to discharge e
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t1e tank l^
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(3)
Conclusions l
The licensee's review safety analysis, and follow up to supnrt the temporary operatiQn of the V-115 nitrate waste tant operation was thorough and well documented. The l.
12mporary V-115 tank alignment was not expected to generate a significant increase in the liquid effluent released.
I c.
Airborne Effluent Proaram Controls and Procedures (1)
Insoection Scoce i
The inspector reviewed the licensee's program for airborne effluent controls and monitoring.
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Observations and Findinas The inspector observed a technician collect a*.r particulate filter samples from five stacks that were designated to be collected on a daily basis due to their operational performance and/or quantity of material released.
The technician used procedure EPI No. 0-6.0. Stack Sampling Program, Revision 39, August 21. 1997.
The technician was observed to properly collect. document, and prepare the samples for gross alpha analysis.
The sampling equipment was in good working order.
The licensee used stainless steel enclosures to protect the sampling equipment from environmental conditions.
The inspector noted the use of stainless steel sample delivery lines which was in good conditico and showed no signs of corrosion.
No obvious problems were noted with the sampling equipment.
The inspector did note that the incinerator stack sample (INXB 2135) collected on August 19. 1998 had a significant accumulation of dust and rust on the particulate filter paper. The inspector discussed with the licensee the concern for gross alpha self-absorption and thus the potential for underestimating the quantity of material released from the stack. The licensee indicated that NSI No. 0.26.0. Laboratory Analysis for Air Sampling Filters.
Revision 20. July 13,1998 provided the necessary guidance to account for self-absorption losses. However EPI 0-6.0 did not make a reference to NSI No. 0.26.0. The licensee indicated that EPI 0-6.0 would be revised to refer the technician to NSI No. 0.26.0 in the event that a stack particulate filter has dust / rust loading and that the technicians would be retrained on NSI 0-26.0.
In addition.
the licensee Indicated that the incinerator stack sample in question would be analyzed using NSI 0-26.0 after it was counted " rough the normal process.
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5 In addition. the inspector discussed high efficiency particulate air (HEPA) filtration system maintenance with ventilation engineers.
The licensee currently does not and was not required by the license to perform periodic in-place leak (or by-pass) tests using dioctyl phthalate (00P) on these systems. The licensee indicated that new HEPA filtered ventilation systems were tested by an outside contractor for in-] lace leaks using 00P.
The HEPA filters were required by Clapter 5. Section 5.3.3 to be investigated when the differential pressure across the filter was greater than four inches of water.
The licensee indicated that the filters were changed when the differential pressure exceeded four inches of water.
The inspector did not identify situations in which the HEPA filters were left in place after the differential pressure exceeded four inches of water.
The HEPA filters were not necessarily changed due to aging (embrittlement concerns). heat damage or water intrusion.
The inspector discussed with the licensee De3artment of Energy (DOE) facility experience with age erarittlement and water intrusion problems associated with HEPA filters that are not routinely changed. The licensee acknowledged the inspector's comments.
(3)
Conclusions The licensee's effluent air sampling equipment was in excellent material condition due mainly to the use of stainless steel sample equipment enclosures and sample delivery lines. Guidance for technicians to account for alpha particle self-absorption losses on stack particulate filters due to dust loading needed improvement. Although the licensee met the requirements of Section 5.3.3 of the license application for monitoring the differential pressure across the HEFA filters in the ventilation systems, the licensee did not have a program to assess HEPA filter integrity due to age embrittlement, water intrusion, or heat damage.
d.
f ffluent Discharaes (1)
Insoection Scooe The inspector reviewed the licensee's air and liquid effluent discharge records and reports to determine if they were in compliance with G i the limits in 10 CFR Part 20 and the license application anc '?) the reporting requirements specified in 10 CFR 70.59.
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6 (2)
Observations and Findinas The inspector reviewed the air discharge records for 1996, 1997 and the first half of 1998.
The inspector also reviewed the dose methodology the licensee used to demonstrate compliance with the 10 mrem / year constraint limit specified in'20.1301(d). The licensee used the USEPA's comply code and a variety of conservative assumptions to demonstrate that the dose due to air emissions to an individual off-site was less than 10 mrem /yr from air discharges. The licensee's use of high efficiency particulate air filtration systems and the operational shift to the dry conversion process helped to maintain these:
off-site releases as low as reasonably achievable.
The doses due to air emissions that were calculated for 1997 were approximately 0.4 mrem /yr.
The inspector reviewed the Semiannual Effluent Release Reports for the period January 1.1997 through December 31.
1997, and verified that they were submitted within the required time frame.
The inspector compared the total quantities of liquid and airborne effluent discharges released in 1997 with 3revious years. The data are summarized in Table 1 Jelow.
Table 1:
Effluent Summary for General Electric Company Nuclear Energy Production (1994-1997)
Quantity Released (microcuries. gC1)
Effluent Nuclide 1914 1995 1995 192Z Airborne U-234 1.04E+02 9.56E+01 9.42E+01 1.64E+02 U-235 4.06E+00 3.84E+00 3.71E+00 6.50E+00 U-236 3.69E-02 1.84E-02 1.21E-01 3.20E-01 U-238 1.65E+01 1.60E+01 1.44E+01 2.50E+01 Total 1.25E+02 1.15E+02 1.13E+02 1.96E+02 Liquid U-234 7.19E+04 6.51E+04 4.97E+04 3.71E+04 U-235 2.81E+03 2.61E+03 1.96E+03 1.50E+03 U-236 2.54E+01 1.21E+01 6.42E+01 8.00E+01 U-238 1.14E+04 1.11E+04 7.60E+03 5.60E+03 Total 8.61E+04 7.88E+04 5.93E+04 4.43E+04 The total quantity of uranium discharged in liquid effluents in 1997 was 4.43E+04 pC1. Since 1994, there has been a decrease in the total quantity of uranium discharged in liquid effluents. The licensee did not calculate a dose based on the total quantity of liquid effluents released r
from the facility in 1997.
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7 Currently the licensee had a quarterly air discharge limit of 1250 gCi of uranium.
In 1995, the licensee discharged a total of 113 gC1 for the entire year.
In addition. the licensee expected that these a.irborne levels will continue l
to decrease because of the new Dry Conversion Procers which was started in mid 1997.
This process was replacing the old ADU process.
The airborne effluent data for 1997 indicated that although there has been some drop in the discharges from the chemical areas due to less operation, the overall airborne effluents released from the site was approximately 196 pCi which was slightly higher than for 1996 (see Table 1).
Part of the increase was due to an unexpected release of low-enriched uranium (~32 uCi) from the HF recovery process exhaust stack on September 4, 1997. This event had been reviewed previously in IR 70-1113/97-08.
The 1997 airborne releases were still significantly less than the license application quarterly limit.
This slight increase appeared to be a concern to the licensee based on l
ALARA considerations and, thus the licensee was working to i
refine the process and the ventilation and filtration systems to reduce this level even farther.
(3)
Conclusions Total quantities of uranium released in the liquid effluent from the facility have been decreasing since 1994.
Although the air effluents were slightly higher than the licensee expected, the releases were well below license application l
l and regulatory limits.
The licensee was proactive in i
seeking solutions to maintain air emissions ALARA.
I e.
Decommissionina i
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Insoection Scoog The inspector reviewed the status of the licensee's current decommissioning actions and reviewed the decommissioning records pursuant to the record keeping requirements in 10 CFR 70.25.
(2)
Observations and Findinas The inspector reviewed the status of the current l
decommissioning actions at the site.
These actions include the final decommissioning survey of the North West Storage Area, the removal and relocation of CaF material from the r
fluoride lagoons to warehouses, and the off-site reprocessing of incinerator ash.
The licerisee had requested permission from the NRC to delay i
performing the final decommissioning survey in the North West Storage Area until October of 1998 because unseasonably 4
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8 wet weather had placed most of the survey area underwater.
which would hinder the licensee from performing radiation survey surface scans. At the time of the inspection, the area continued to be under app,roximately one to two feet of water and the licensee indicated that by mid September 1998 a decision would be made whether to ask for another extension or develop a method for performing the survey with the water in place.
The inspector observed that the licensee was currently building two additional warehouses to hold the approximately one million cubic feet of dewatered CaF materia' from the 2
fluoride lagoons. The licensee had previously constructed a warehouse to store relocated CaF from the North West 2
Storage Area. The schedule was to complete construction of the warehouses by January 1999 and to complete the movement of the CaF material during the following year.
2 The inspector also reviewed the decommissioning file to determine if the file was maintained in accordance with the requirements in 10 CFR 70.25(g).
The file contained information concerning past decommissioning activities and restricted areas and unrestricted areas which will need to be decommissioned in the future.
The file appeared to be maintained on a routine basis.
However. 70.25(g)(3) requires that a single document contain a list of information specified in 70.25(g)(3)(1) through (iv) and that this document be updated every two years.
At the time of the ins 3ection the most recent update to this document was dated Jecember 21. 1995. Although this document was not updated on the two year basis. this failure constitutes a violation of minor significance and will not be not subject to formal enforcement action.
The licensee updated this document during the inspection on August 20, 1998.
In addition, the licensee indicated that this update requirement will be placed on a reminder (or " tickler") list to prevent recurrence.
(3)
Conclusions The licensee had delayed the final status survey of the North West CaF Storage Area due to wet weather conditions 2
that placed the survey area under water.
The licensee was making good process towards removing CaF material from the 2
fluoride lagoons by constructing two warehouses for its storage.
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f.
On Site Waste Storaae (1)
Insoection Scooe The licensee's storage of low ~1evel radioactive waste (LLRW) was reviewed. including management controls and surveys.
adequacy of the storage area, and waste container integrity.
In addition, the inspector reviewed the on-site processing and repackaging of residue material prior to shipment to i
Envirocare for burial.
(2)
Observations and Findinas At present, the licensee was storing large quantities of residue material on site in approximately 26.000 three or l
five gallon cans in their outside waste storage areas or
" pads".
The pads consisted of several graveled surfaces each surrounded by a fence. Although the fences were not locked, all of the waste was located within the controlled area of the facility.
The waste containers were placed directly on the graveled surface.
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Since the last inspection, the licensee had implemented a l
restructuring program to deal with the onsite waste. The program consisted of the following four phases: (1) Reduce l
the volume of recoverable waste (10.200 cans) by continuing operation of the uranium recovery facility: (2) Burial of non-recoverable :esidue waste (10.400 cans): (3) Incinerator l
ash recovery project (5.300 cans): and (4) Calcium fluoride l
relocaticn from lagoons to warehouses. The inspector l
observed that the licensee had acted to reduce the onsite storage of waste and committed significant resources to complete the restructuring program.
The licensee had scheduled the burial of 10.400 cans which I
were to be shipped to Envirocare for disposal. At the time l
of the inspection, over 1100 cans had been shipped to i
Envirocare. Of the remaining 26.000 cans approximately 10.200 of them contained material which the licensee can reprocess to recover the uranium. This recovery operation L
can reprocess several hundred cans per week. The remaining i
5.000 cans contained ash from the incinerator and also l
contained recoverable quantities of uranium. The licensee l-was investigating options for outside contracts to reprocess l-this material.
The inspector also walked through the waste storage pad to review labeling and housekeeping of the area. The area was e
well maintained. All cans were clearly labeled and all cans and bags were in good condition. The inspector randomly selected cans and asked the licensee to trace the inventory number to determine if the licensee could locate the J
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i individual cans.
The licensee was able to locate all cans l
quickly and correctly.
L The inspector also observed and reviewed procedures for l
residue waste assay, processing, and packaging activities.
l These activities were performed in the CaF warehouse and an 2
adjacent building.
The licensee was packaging the residue waste in 55 gallon drums and using the CaF and soil mixture 2
from the CaF, relocation project as filler material for the container.
The licensee was using an administrative limit of 85 grams U-235 per residue can to ensure that a waste shipment would not exceed either the burial site limit or the fissile excepted limit of 400 grams U-235 per shipment specified in 10 CFR 71.53.
To determine the grams of U-235 in the post-processed 55 gallon drum, the licensee used previous MC&A records for the residue waste and the average soil concentration of U-235 in the CaF soil.
The average 2
soil concentration of U.235 was based on a collection of 16 soil samples which were combined and mixed as four composite samples and analyzed by the licensee's Chemet Lab.
The average concentration of U-235 and U-238 in the soil was 37.6 pCi/ gram and 262 pCi/ gram, respectively.
For confirmatory measurement surposes, the inspector requested that three CaF soil _ samp'es be collected and split with the 2
licensee. The licensee was requested to analyze the split samples using their routine analytical methods.
In t.ddition, the licensee agreed to ship the NRC split portion of the samples to the Region II office in a timely manner.
The comaarison of the CaF split soil sample results will 2
be trac (ed as an inspector follow up item (IFI: 70-1113/
98-03-01).
(3)
Conclusions The licensee had committed significant resources to complete the restructuring program which included the reduction of the volume of recoverable waste, the burial of non-recoverable residue waste, the relocation of CaF. and the 2
recovery of incinerator ash. The waste storage pad areas were well maintained and all waste cans were clearly labeled and protective plastic bags were in good condition.
g.
Waste Classification (1)
Insoection Scooe The inspector reviewed the licensee's program to ensu,e that the licensee prepared all wastes so that the waste was classified according to 10 CFR 61.55 and meets the wasto characteristics requirements in 10 CFR 61.56.
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(2)
Observations and Findinas 1
Classification of waste materials intended for burial to meet the SS61.55 requirements.was discussed with licensee representatives. All waste streams were classified utilizing material accountability methods for identification and quantification of radionuclides in each container.
Each waste container was scanned using a sodium iodide (Nal) gamma spectroscopy system. The c %.ciners were rotated in front of the detector and assayed to determine the quantity of U-235 and U-238 within the waste. The licensee j
re-documented its determination of the waste class of the material shipped for burial in a memo to file dated November 25. 1997. To assure proper waste classification, the licensee relied on the source method, which was based on the knowledge and control of the source of the waste.
The source of the waste at the licensee's facility was limited to the radionuclides of the uranium mid actinium series and trace quantities of Tc-99.
In accordance with 10 CFR 61.55, these species would be classified as Class A waste.
The stability of the waste was achieved with the waste container. The licensee controlled the types of materials that could be ) laced in the waste containers and the types of materials tlat were prohibited from being placed in the waste containers by detailed work instructions.
(3)
Conclusions The inspector concluded that the licensee's waste classification program was acceptable and well documented.
h.
WAsfe Shiocina Manifests (1)
Insoection Scoce The ins)ector reviewed the licensee's program for preparing waste slipping manifests as it aertained to the requirements of 10 CFR 20.2006 and Appendix G to 10 CFR Part 20.
(2)
Observations and Findinas From a review of selected records for solid waste disposals made during 1998. it was noted that the licensee had shipped selected noncombustible residue waste items to a licensed waste burial facility (Envirocare of Utah). The inspector verified that the licensee provided an acceptable level of information in the shipping papers to determine the quantities of individual radionuclides shipped.
The inspector reviewed manifest records of selected shipments of radioactive waste made since March 1998.
The manifests were complete and met the applicable require.mnts of Appendix G to 10 CFR Part 20.
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(3)
Conclusions The waste shipping manifests were complete and provided an acceptable level of information in the shipping papers to determine the quan*ities of individual radionuclides shipped.
1.
Follow un on Previously Identified Issues (92701) i (1)
Insoection Scoce Actions to issues identified in previous inspection reports were reviewed for completion and adequacy.
(2)
Observations and Findinas The inspector reviewed the licensee's actions associated with Inspector Follow up Item (IFI) 70-1113/97-03-01: Review the licensee's internal dose assessment of the CaF 2 excavation equipment operators.
The licensee monitored two individuals each performing front j
end loader operations at the CaF basin and warehouse i
2 operations at the CaF storage warehouse.
The equipment 2
operators were provided lapel air samplers and monitored from April 7-10 and 14-17. 1998. The individuals wore the air samplers for the entire period for a total of eight days at an average of ten hours per day. Actual air sample collection times typically ranged from five to seven hours per day.
The licensee calculate' +9 derived air concentration (DAC) hour (hr) res a frca the air sample data. The DAC-hr ranged from 0.09 to 0.3 (solubility class W) which calculates to be less than one millirem.
The warehouse operator received the higher DAC-hr. The licensee required the monitoring of an. individual if the individual was likely to be exposed to greater than 4 DAC-hrs in a week. This sampling demonstrated that typical cperations did not result in exposures requiring personal air.
monitoring.
(3)
Conclusion The licensee's actions associated with IFI 97-03-01 has been adequately completed and is closed.
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13 3.
Transoortation (86740) (R4)
The inspector reviewed the licensee's program for routine radioactive materials shipments to determine whether the licensee had established and was maintaining an effective program, to ensure radiological and nuclear safety in the packaging and delivery to a carrier of licensed radioactive materials, and to determine whether transportation activities were in compliance with the applicable NRC and DOT transport regulations noted below.
During the inspection, trans)ortation activities associated with LLRW and fissile material s11pments.
including procedural guidance, quality control (OC) activities, and record completeness conducted in accordance with 10 CFR Part 71, and 49 CFR Parts 171-178 were reviewed.
10 CFR 71.5(a) requires that licensees who transport licensed material outside the confines of its plant or cther place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of tran7, port of the DOT in 49 CFR Parts 170 through 189.
a.
Preoaration and Delivery of Comoleted Packaaes for Shiomeat.
(R4.01. R4.02)
(1)
Insoection ScooA The inspector examined the licensee's written procedures and shipment records related to the preparation and delivery of completed packages for shipment of LLRW and fissile material.
(2)
Observations and Findinal The inspector verified that the licensee had acceptable procedures for the ) reparation of shipping packages and l
delivery of the paccages to the carrier for shipment.
The l
inspector reviewed selected portions of the shipping procedures and noted that there were no significant changes i
to the procedures since the last inspection of this program l
area. The inspector noted that the licensee's use of flow charts in the Pocedures as an enhancerient that incorporated and implemented the applicable provisions of both NRC and DOT regulations.
The inspector also verified that the appropriate personnel in the traffic department had current copies of the applicable DOT regulations.
During the onsite inspection, licensee transportation activities regarding shipments of unirradiated fuel, unnium F
dioxide powder. UF, heels, and low-level radioactive waste shipments were reviewed.
Selected records covering the period May 1998 to August 1998 for those consignments were reviewed in detail. The inspector reviewed and discussed in j
detail the documentation used, and subsequently maintained
14 in the licensee's records for each radioactive material shipment. including, the Bill of Lading. Radioactive Material Shipment Record. Vehicle Inspection Report. Receipt and Loading Verification Checklist. Packing List (Fuel Assemblies / Component Assemblies). Fuel Shipment Information Form. Container Log Sheet. and Health Physics Survey Forms.
The inspector noted that the ship)ing records were complete and the information supplied on tie shipping papers was appropriate.
The inspector observed the licensee's maintenance activities for the inner and outer fuel shi) ping containers Models OA-2 and RA-3. including the refurbisament and inspection.
oa ins)ector verified on selected RA inner containers that the gascet had been replaced as required and was in good physical condition.
(3)
Conclusion Based on the observation of packaging operations during the inspection, it was concluded that the licensee's performance in transportation activities was acceptable.
The use of flow charts in the shipping 3rocedures that incorporated the applicable provisions of bot 1 NRC and 00T regulations was a
. program enhancement.
b.
Review of Transportation Unusual Incidents (1)
Insoection Scooe The inspector reviewed unusual incident reports (UIRs) and 30 day reports pursuant to 10 CFR 71.95 as they pertained to transportation of radioactive materials events.
The inspector reviewed the events with licensee representatives E
and discussed the applicable corrective actions that were taken.
L (2)
Observations and Findinas l
The inspector reviewed three incidents involving shipping activities that occurred between February and August 1998.
The three incidents pertained to the following:
(1) mislabeled shipment of UF cylinders containing heels:
6 (2) shipment of three BU-J powder shipping containers with reported package deviations: and (3) improper shipment of i
waste drums to Envirocare.
On February 4.1998, five UX-30 overpacks containing five UF cylinders with heels were shipped with incorrect s
labeling to Lockheed Martin Utilities Services in Piketon.
Ohio. The licensee notified the NRC and documented this event in a 30 day report pursuant to 10 CFR 71.95(c) dated 4
k i
15 March 4. 1993.
One of the overpacks was mislabeled as
" Empty" while the other four had the correct " Radioactive Yellow III" labels, but had the wrong activity level written on each label.
The cause of t,he event was the failure to follow procedures in that a check sheet and instruction process, which was identified in the procedures, was not followed. As a result, the overpacks were shipped with the same labeling as when they were received.
The licensee identified the problem during a review of shipping paper work the day following the shipment and notified the receiver.
To prevent recurrence the licensee implemented an independent over check of shipaing paperwork prior to each shipment.
The failure to laael properly the UX-30 overpacks was a violation of the labeling requirements specified in 49 CFR 172.403.
Since this violation was identified by the licensee, and the criteria specified in Section VII.B.(1) of the NRC Enforcement Policy were satisfied, this non-repetitive, licensee-identified and corrected violation is being treated as a Non-Cited Violation (NCV) consistent with Section VII.B.(1) of the NRC Enforcement Policy (NCV: 70-1113/98-03-02: Failure to label properly five UX-30 overpacks on February 4.1998 in accordance with the labeling requirements specified in 49 CFR 172.403.).
On February 18 and 19. 1998. the Empresa Nacional del Uranio (ENUSA) reported to the licensee that three BU-J packages containing uranium dioxide powder were received in a condition that indicated possible deficiencies in the preparation of the package for transport, and could have resulted in reduced effectiveness of the package.
The alleged package deficiencies were as follows:
(1) BU-J M-3638 had water under the lid of the outer part of the package: (2) BU-J M-3537 had a missing gasket on the outer drum lid; and (3) BU-J M-3124 had 12 bolts in the inner container that were not tight.
The licensee immediately initiated an investigation, an
" unusual incident report" (PPL-98-13). and a " corrective action report." The licensee's investigation included interviews with package preparation technicians shipping personnel, and rearesentatives from ENUSA.
Based on several conversations wit 1 various ENUSA representatives, the licensee was unable to develop any meaningful conclusions with regard to the :.abable cause or whether the packages were received in a deficient condition.
The alleged loosened bolt conditions of BU-J M-3124 was of major concern from a safety perspective. The licensee's investigation found no evidence that the package left the Wilmington facility with loose inner container bolts.
Based on the limited information received from ENUSA. the licensee's investigation concluded that the 12 loose bolts could hav9
16 resulted from the receiver's unloading activities.
Based on information in the licensee's incident file (No. 98-07) and 1
discussions with licensee representatives.-the inspector was unable to make any further conclusions with regard to the l
condition of the package; prior to shipment to ENUSA.
The I
inspector indicated to the licensee that an inspector follow u) item would be tracked to further review this incident for tie likely root causes (IFI: 70-1113/98-03-03: Review the root cause of the incident involving the receipt of three BU-J packages in a possible deficient condition).
On August 11, 1998, the licensee shipped 44 drums containing residue material to Envirocare with improper shipping paperwork. This shipment was sent as " exclusive use" and designated as fissile exce)ted per 10 CFR 71.53 requirements.
One drum (Drum io. 42) containing 81 grams of U-235 was incorrectly included in the shipment and as a result, the fissile excepted limit of. 400 grams was exceeded by approximately 19 grams U-235. The licensee discovered this errcr during a subsequent waste shipment preparation to Envirocare on August 18. 1998 when the licensee could not locate drum No 42 (containing the 81 grams U-235) to prepare it for disposal.
The licensee discovered that drum No. 21.containing 6 grams U-235 was still on site when it should have been included in the shipment to Envirocare on August 11, 1998.
Consequently. adding the contents of drum No. 42 to the August 11 shipment resulted in a total of 418.7 grams U-235. However, the shipping manifest and accountability records showed 344 grams U-235.
U)on the discovery, the licensee notified Envirocare and tie NRC inspector onsite. The licensee's corrective actions included (1) performing a complete drum inventory review:
(2) notification of the licensee's shipping contractor of the event: (3) implemantation of a verification cross check of drum checklists to shipment records before making additional shipments to Envirocare: and (4) revision of the material control and accounting records to reflect the current amounts of U-235 in the Augw t 11. 1998 snipment.
The failure to assign an appropriate fissile material classification and include the appropriate description on the shipping paper was a violation of 10 CFR 71.53 and 49 CFR 173.203 requirements.
Since this violation was identified by tha licensee, and the criteria specified in Section VII.B.(1) of the NRC Enforcement Policy were satisfied, this non-repetitive licensee-identified and corrected violation is being treated as a Non-Cited Violation (NCV) consistent with Section VII.B.(1) of the NRC Enforcement Policy (NCV: 70-1113/98-03-04: Failure to assign an appropriate fissile material classification and include the appropriate description on the shipping paper).
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(3)
Conclusion The licensee's identification and correction of incidents that violated regulatory requirements was acceptable and timely.
The licensee's responses to the transportation unusual incidents were focussed on preventing recurrence.
i.
4.
Exit Interview The routine inspection scope and results were summarized on August 21.
l 1998 with those persons indicated in the Attachment.
The inspector discussed in detail the routine program areas inspected, and the findings, including the non-cited violations for a mislabeled shiament of UF, heels and the improper shipment of residue waste drums. A'though proprietary documents and processes were occasionally reviewed during this inspection, the proprietary nature of these documents or processes has been deleted from this report.
No dissenting comments were l
expressed by the licensee.
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ATTACHMENT 1.
PARTIAL LIST OF PERSONS CONTACTED
' Licensee Personne
- E. Anderson. Technical Coordinator. Restructuring
)
D. Barbour.. Team Leader. Radiation Protection D. Brown. Team Leader. Environmental Programs B. Crate. Manager. Industrial Safety
- T. Crawford. Sr. Environmental Engineer
- D.' Doder. Manager. Chenical Product Line R. Foleck. Senior Licensir.g Specialist R. Keenan. Manager. Site Security and Emergency Preparedness
- J. Kline. Fuel Manufacturing
- G. Luciano. Area Manager. Fuel Support
- A. Mabry. Program Manager. Radiation Safety Engineering
- R.:Martyn, Manager. Material Control and Accounting
- C. Monetta. Manager: Environment. Health & Safety
- S. Murray. Manager. Facility Licensing
- E. Palmer. Project Engineer
- L. Paulson. Manager. Nuclear Safety
- R. Reda.- Manager. Fuel Fabrication
- H. Strickler Manager. Site Environment. Health & Safety
- D. Turner. Environmental Engineer: Environment. Health & Safety
- C. Vaughan. Manager.-Strategic Regulatory Planning
- R. Yopp. Specialist. Shipping and Transportation Other licensee employees contacted included engineers, technicians, production staff, security, and office personnel.
- Denotes those present at the exit meeting on August 21, 1998.
2.
INSPECTION PROCEDURES USED IP 84850 Radioactive Waste Management (10 CFR Parts 20 and 61)
IP 84900-Low-level Radioactive Waste Storage
(
IP 86740 Inspection of Transportation Activities l
IP 88035 Radioactive Waste Management j~
IP 92701 Follow up 3.
LIST OF ITEMS OPENED. CLOSED. AND DISCUSSED i
-Item Number.
Status Dgscriotion and Reference 70-1113/97-03-01 Closed IFI: Review the licensee's internal dose assessment of the CaF excavationequipmentoperakors (Section 2.I(2)).
2 Item Number Status.
Descriotion and Reference 70-1113/98-03-01 Optn IFI: Qomparison of three CaF split a
soil sample results for confirmatory measurement purposes (Section
- 2. f(2)).
70-1113/98-03-02 Closed NCV: Failure to label properly five UX-30 overpacks on February 4, 1998-in accordance with the labeling requirements specified in 49 CFR 172.403 (Section 2.b(2)).
70-1113/98-03-03 Open IFI: Review the root cause of the incident involving the receipt of three BU-J packages in a possible deficient condition (Section 2.b(2)).
70-1113/98-03-04 Closed NCV: Failure to assign an appropriate fissile material classification and include the a)propriate description on the slipping paper (Section 2.b(2)).
4.
ACRONYMS ADU Ammonium Diuranate AL Action Level i
ALARA As low As Reasonably Achievable CaF Calcium Fluoride 2
DAC Derived Air Concentration DCP Dry Conversion Process DOE Department of Energy
~'
DOP Dioctyl Phthalate i
EAL Environmental Action Level ECDMS Environmental Compliance Data Management System EPI Environmental Protection Instruction GE General Electric HEPA High Efficiency Particulate Air IFI Inspector Follow-up Item IP Inspection Procedure LA' License Ap)lication LLRW Low Level ladioactive Waste pCi Microcuries MDL Minimum Detection Level NCS Nuclear Criticality Safety NCV Non-Cited Violation NHSS Office of Nuclear Materials Safety and Safeguards NRC-Nuclear Regulatory Commission NSI Nuclear Safet: Instruction
3 P/ P_.
Practices and Procedures pCi-Picocuries apm -
Part Per Million RSC -
Radiation Safety Committee SNM lSpecial Nuclear Material UIR-Unusual Incident Report
^
UN' Uranyl Nitrate 00 Uranium Dioxide 2
' UFs -
Uranium Hexafluoride URU Uranium Recovery Unit VIO-
. Violation
.-.."?
WSRC Wilmington Safety Review Committee S
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