rece of i washington. d.c. · 2000 navy pentagon washington. d.c. 20350-2000 5104 in reply refer to...

EPARTMENT OF THE NAVY ICE OF THE CHIEF OF NAVAL OPERATIONS

2000 NAVY PENTAGON RECE t V& REGION I WASHINGTON. D.C. 20350-2000

IN REPLY REFER TO

5104 Ser N455C/3U574838 19 November 2003

From : To :

Subj :

Encl :

Chairman, Naval Radiation Safety Committee Distribution

MINUTES OF NAVAL RADIATION SAFETY COMMITTEE MEETING THIRD QUARTER, CY-2003

(1) NRSC Meeting Agenda ( 2 ) Report to NRC on SIMA San Diego Radiography Event (3) Lost IBIS Brief and Report to NRC (4) DU CIWS Allegation Brief and Report to NRC ( 5 ) Master Material License Annual Program Review Brief ( 6 ) NRMP Action and Inspection Summaries (7) Current NRMP Summary

1. The Naval Radiation Safety Committee (NRSC) convened at 1000 on Wednesday, 10 September 2003, to discuss agenda items provided in enclosure (1). The following individuals were in attendance:

Mr. W. Mattheis CAPT D. Farrand CDR R. Fong CDR W. Adams CDR L. Fragoso CDR S. Gaiter LCDR P. Fetherston Mr. D. Collins Mr. G. Pangburn Mr. J. Diaz Mr. U. Bhachu Dr. J. Jones

Chairman, NRSC Executive Secretary, NRSC BUMED (M3F71) NAVSEA (SEA 04N)

HQMC ( SD) NEHC NRC Region I1 NRC Region I NRC Region I1 NRC Headquarters NAVSEA (SEA 08R)

OIC, RASO

* Note - LCDR J. Sanders (N455C) was not in attendance.

2. Mr. Mattheis opened the meeting by welcoming the committee members and representatives from the Nuclear Regulatory Commission (NRC) to the NRSC Meeting, Third Quarter, 2003.

3. There were two Action Items carried over from the last NRSC meeting :

a. The Inadvertent Expenditure of Depleted Uranium Munitions at Vieques. This action item remains open pending ATSDR’s publication of the Air Pathway Report. CAPT Farrand stated that he had recently called ATSDR and the project manager

Subj: MINUTES OF NAVAL RADIATION SAFETY COMMITTEE MEETING THIRD QUARTER, CY-2003

said the final report should be issued soon and that the document was currently undergoing translation into Spanish. It was reemphasized that even though the Navy had turned over land custody of the former training range to the Department of the Interior, the Navy was still responsible to meet any environmental cleanup requirements.

b. SIMA San Diego Camera Malfunction. CAPT Farrand stated that one of SIMA San Diego's radiography exposure devices malfunctioned on 3 June 2003. This item was only briefly discussed at the last NRSC meeting, since it occurred shortly before the last NRSC meeting and the investigation results were only preliminary. CAPT Farrand provided a summary of the event and a copy to each attendee of the NRC Event Report, enclosure (2)

4. There were two New Action Items:

a. Lost In-Flight Blade Inspection System (IBIS) Device. CAPT Farrand reported that on 8 August 2003, a CH-53 helicopter lost an IBIS device approximately 5 miles northwest of Richlands, NC. The IBIS broke off the rotor assembly when the cowling came off the #3 engine and struck the IBIS. An aerial search was conducted but the device was not found and is estimated to be located somewhere in an unpopulated 3 square mile area that contains mostly open fields and some wooded areas. NRC and State of North Carolina were notified. North Carolina stated that they were not going to attempt to recover the device. Further details of the event are contained in the Lost IBIS presentation and the Report of Loss of Licensed Material, enclosure ( 3 ) .

b. Allegations Concerning Depleted Uranium (DU) Ammunition. CAPT Farrand stated that the NRC had forwarded to the Navy on 9 July 2003, three allegations pertaining to Depleted Uranium ammunition operations in the Navy. The three allegations were:

(1) The Navy does not designated individuals responsible for DU ammunition radiation safety at each location per the NMRP issued to the Naval Surface Warfare Center, Crane, IN.

( 2 ) The Navy does not keep record of its DU inventory. The Navy does not know where or how many of their DU rounds were fired, lost or stolen.

2

Subj: MINUTES OF NAVAL RADIATION SAFETY COMMITTEE MEETING SECOND QUARTER, CY-2003

(3) The Navy conducted an unauthorized transfer of 1700 DU Close-In Weapon System (CIWS) rounds to the Coast Guard in August 2001.

CAPT Farrand reported that an investigation was conducted to determine whether the concerns expressed in the allegations had merit. The investigative team consisted of CAPT Farrand, CDR Fragoso, and Mr. Lowman (RASO). The team found that allegations (1) and (2) above did not have any merit but that allegation (3) did occur. CAPT Farrand provided a detailed brief of the team's findings and the Navy's corrective actions to allegation (3). A copy of the brief and a copy of the NRSC's response to the allegations are provided as enclosure (4).

5. There was one Discussion Item presented: Captain Farrand provided a brief on the annual Master Material License (MML) program review that was conducted in August 2003 by Captain Farrand, Commander Fong, and Commander Adams. The program review included technical support center operations, an analysis of inspection violation trends, and an examination of personnel radiation exposures over the last 5 years. Overall, the program was found to be healthy with an effective inspection program. The MML program review presentation is included as enclosure (5).

6. LCDR Fetherston (NEHC) and CDR Fragoso (RASO) discussed the status of Naval Radioactive Materials Permit (NRMP) actions and inspections conducted during the quarter. NRMP actions for NEHC and RASO are listed as enclosure (6). The current number of NRMPs is 136. Of the 136 NRMPs, 24 are managed by NEHC, with the balance, 112, managed by RASO. A summary of the current NRMPs is included as enclosure ( 7 ) . LCDR Fetherston noted that several NRMP renewals were beyond the NRSC guidance (1 year) for processing. She stated that all medical Permittee's had submitted renewal applications per NEHCs direction and guidance to formally incorporate the new 10 CFR 35 requirements. NEHC is continuing their review of the applications for completeness. LCDR Fetherston stated that she anticipated many of the renewals would be completed by the next NRSC meeting.

7 . Mr. Mattheis afforded the NRC an opportunity to discuss any issues of programmatic interest.

a. Mr. Collins stated that the NRC will consolidate portions of the nuclear materials program. As of 1 October 2003, NRC's Region I would take over the regulatory responsibilities of the nuclear materials program at NRC Region 11. He introduced Mr. George Pangburn who is the NRC Region I, Division Director of

3

Sub]: MINUTES OF NAVAL RADIATION SAFETY COMMITTEE MEETING SECOND QUARTER, CY-2003

Nuclear Materials Safety. Mr. Pangburn stated that Mr. Diaz would remain the NRC’s project manager for the Naval Master Material License and would remain located in Atlanta but that correspondence should now be addressed to both the NRC Region I in King of Prussia, PA and the NRC Region I Atlanta, GA Office.

8. Mr. Mattheis thanked the NRC for attending the meeting and extended his appreciation for their continued support of the Navy’s radiation safety program. The NRSC meeting was adjourned at 1105. The next meeting of the NRSC is tentatively scheduled for Wednesday, 17 December 2003.

I

Distribution: COMNAVSEASYSCOM (SEA 04N - CDR Adams) COMNAVSEASYSCOM (SEA 08R - J. Jones) CHBUMED (M3F71 - CDR Fong) USMC HQ (SD - CDR Gaiter) NAVSEADET RASO (OIC) NAVENVHELCEN (Rad Safety - LCDR Fetherston) NRC Region I (King of Prussia, PA) NRC Region I Atlanta Office (ATTN: J. Diaz) NRC Headquarters (ATTN: Mr. U. Bachu, Mail Stop T-8F5)

4

Naval Radiation Safety Committee Meeting Agenda 3rd Quarter - September IO, 2003

1. Opening Remarks-

Rep resentat ives: Mr. Mattheis welcomes NRC Region 11, NRC Region I, and NRC Headquarters

Mr. Doug Collins NRC Region II Mr. George Pangburn NRC Region I Mr. J. Diaz Velez MML Project Coordinator, NRC Region II Mr. U. Bhachu Headquarters, NRC

2. Chairman, NRSC welcomes visitors and Executive Secretary, NRSC introduces NRSC members.

Mr. Mattheis

CAPT Farrand

CDR Adams

CDR Fong

CDR Gaiter

CDR Fragoso

LCDR Fetherston

LCDR Sanders (Absent-TDY)

Dr. J. Jones (Ad hoc Member)

Acting Director, Environmental Readiness Division Chairman, Naval Radiation Safety Committee (N45)

Executive Secretary, Naval Radiation Safety Committee Head, Radiological Controls and Health Branch (N455)

Director, Radiological Controls Program Off ice Commander, Naval Sea Systems Command (SEA-O4N)

Off ice of Undersea Medicine and Radiation Health, Bureau of Medicine and Surgery (MED-M3F71)

Health Physics Program Manager, Safety Division, Headquarters, United States Marine Corps

Officer in Charge, Radiological Affairs Support Off ice

Head, Radiation Health Team, Navy Environmental Health Center, Notfolk, VA

Recording Secretary, Naval Radiation Safety Committee Radiological Control and Health Branch (N455C)

Radiation Health Program Manager Naval Nuclear Power Program Naval Sea Systems Command (NAVSEA-08R)

3. Executive Secretary begins the NRSC actions summary at the discretion of the Chairman, NRSC.

4. There are 2 Outstanding Action Item carried forward from the previous NRSC Meeting, 2nd Quarter 2003 (June 11,2003).

a. Inadvertent Expenditure of DU Rounds on Vieques on 19 Feb 1999 (1) Waiting for ATSDR publication of the Vieques Air Pathway Report to finalize

our assessment. ATSDR states that the report is in the final stages of being translated into Spanish before official release.

(2) N455 reviewing a Draft Radiological Assessment of the event and subsequent recovery of the DU rounds prepared by RASO.

b. SlMA San Diego Camera Malfunction - See Report to NRC

5. New Action Items:

a. Lost IBIS Near Richlands, North Carolina - See Slide Presentation and Report to NRC

b. Allegations Concerning Depleted Uranium Ammunition - See Slide Presentation and Report to NRC

6. Updates on permitting and inspection actions: NEHC - LCDR Fetherston, MSC, USN RASO - CDR Fragoso, MSC, USN

7. Discussion:

a. Master Material License Program Review

8. NRC Remarks: NRC Representatives

9. Closing: Mr. Mattheis

10. Next Meeting: Tentatively scheduled for Wednesday, December 17,2003.

2

DEPARTMENT O F THE NAVY OFFICE OF THE C H I E F O F NAVAL OPERATIONS

2000 NAVY PENTAGON WASHINGTON. D.C. 20350-2000

IN REPLY REFER TO

5104 Ser N455C/3U574730 2 Jul 2003

U.S. Nuclear Regulatory Cornmission Division of Industrial and Medical Nuclear Safety Washington, DC 20555-0001

Ladies and Gentlemen:

A n event reportable under Title 10, Code of Federal Regulations, Part 34.101(a) (2) and (3) (10 CFR 34.101(a) (2) and (3)) occurred with a gamma radiography exposure device possessed under the authority of Nuclear Regulatory Commission (NRC) Master Materials License No. 45-23645-01NA. information required by 10 CFR 34.101(b) for reporting the event.

'

Enclosure (1) provides a l l

Naval Radiation Safety Committee

copy to: . Director, Office for Analysis and Evaluation of Operational Data,

' USNRC Region I1 NAVSEADET RASO

U . S . Nuclear Regulatory Commission

REPORT OF RADIOGRAPHIC EXPOSURE DEVICE FAILURE AT SHORE INTERMEDIATE MAINTENANCE ACTIVITY, SAN DIEGO, CALIFORNIA

1. Description of the equipment problem. On June 3, 2003, gamma radiography operations using an AEA Technology/QSA Model 660A exposure device in a permanent radiography facility at Shore Intermediate Maintenance Activity were being performed under the authority of Naval Radioactive Materials Permit (NRMP) No. 04- 65918-AlNP. On the tenth exposure of the day the radiographer attempted to retract the radiographic source into the radiographic exposure device. The radiographer placed the drive cable brake in the "off" position and rapidly cranked the source in the retract direction. The number of turns coming in matched the number of turns going out. The permanent facility gamma alarm shut off, however the radiographer did not hear the locking slide mechanism engage which is normally heard clearly when retracting the source. as required by the operating procedure, the source did expose again. The Radiation Safety Officer was present and directed the radiographer to retract the source again. attempt to retract the source, the slide bar did not click in the safe position again and the gamma alarm shut off. Safety Officer entered the permanent facility with an operating survey meter. The locking slide bar indicated green (safe) but it was not locked in that position. The Radiation Safety Officer approached the device and observed a reading of approximately 8mrem/hr on the front of the device and 1 0 mrem/hr on the back of the device. She exited the permanent facility and discussed the situation with the radiographer. then directed the radiographer to maintain control of the crank assembly handle and she entered the permanent facility with a survey meter and pushed the slide bar to the red (expose) position. facility and instructed the radiographer to retract the source to the fully locked position. The retraction was successful and the slide bar was heard to click to the fully green (safe) position. The Radiation Safety Officer checked her self-indicating pocket dosimeters which both indicated zero exposure.

When attempting to re-expose the source

As with the first

The Radiation

The Radiation Safety Officer

The Radiation Safety Officer exited the permanent

The source was transferred to an AEA 650L source changer on June 4, 2003. A "dummy" source was installed in the exposure device and the locking slide bar was placed in various positions to experiment and recreate the scenario. tests, the radiographers were not able to lock the slide into place without unlocking the drive cable crank assembly and applying minimal pressure towards the expose position. This is considered a neutral position and not an exposed position. minimal pressure the slide bar mechanism easily locked into the exposed position.

Frequently during these

With

Enclosure (1)

2. Cause of each incident. be twofold. Primarily the compression springs for the posi-lock may have been excessively worn. Secondarily, the Shore Intermediate Maintenance Activity, San Diego operating procedure did not call for them to unlock the crank assembly cable lock prior to rotating the selector ring to the operate position and pushing the posi-lock slide bar from the green (retracted) position to the red (operate) position as stated in the most recent AEA exposure device manual. We believe that the faulty springs were the main factor as the posi-lock slide bar can be pushed to the red position with the crank assembly cable lock in the 'on" position but that procedure may have contributed to the excessive wear on the compression springs.

The cause of the incident appears to

3. involved in the incident. was manufactured by AEA Technology/QSA and consisted of a Model 660A exposure device, serial number A4450 with a 13.6 curie Ir- 192 source.

Name of the manufacturer and model number of equipment The equipment involved in the incident

4. Place, date and time of the incident. The incident occurred at Shore Intermediate Maintenance Activity, San Diego, California in a permanent facility on June 3 , 2003.

5. Actions taken to establish normal operations. The Radiation Safety Officer entered the permanent facility and manually pushed the locking slide bar to the unlocked (red) position. The Radiation Safety Officer exited the permanent facility and instructed the radiographer to attempt to retract the source. The source was successfully retracted to the fully locked position and the locking slide bar was heard to lock.

6. Corrective actions taken or planned to prevent recurrence. Shore Intermediate Maintenance Facility, San Diego replaced the compression springs f o r the posi-lock assembly on the exposure device. Additionally, they have changed their operating procedure to unlock the crank assembly cable lock prior to rotating the selector ring to the operate position and pushing the posi-lock slide bar from the green (retracted) position to the red (operate) position.

7. Qualifications of personnel involved in the incident. The radiographer and Radiation Safety Officer involved in the incident were both ASNT certified gamma radiographers.

2 Enclosure (1)

Lost IBIS Near Richlands, NC

Event Description - - 8 Aug 2003 an engine cowling came off a CH-53

- Helicopter immediately returned to New River MCAS to

- Damage - Missing engine cowling and part of an In-Flight

Helicopter - 5 miles N W of Richlands, NC

check for damage

Blade Inspection System (IBIS) that contains the 500 microcurie Sr-90 source

- Source determined to be anywhere in a 3 square mile area consisting of open fields and wooded area and unpopulated

- An aerial search for the cowling debris was conducted with no success

Lost IBIS Near Richlands, NC Corrective Actions - Helicopter was surveyed - No contamination - Notified NC Radiation Safety Personnel

Assisted NC in developing a Public Notice describing the BIS and warning persons not to handle the material Several NC newspapers carried the story NC has no plans to search for the source at this time due to the small size of the source and the large unpopulated area where it fell

- Requested NAVAIR evaluate developing new cowlings or latch assemblies

1

Lost IBIS Near Richlands, NC

Reports- - NRC Operations Center notified on 15 Aug 2003, event

- 30 Day Follow-up Report forwarded 8 September 2003 assigned Item No. 30647

to NRC Region II

2

DEPARTMENT O F THE NAVY OFFICE OF THE CHIEF OF NAVAL OPERATIONS

2000 NAVY PENTAGON WASHINGTON. D.C. 20350-2000

IN REPLY REFER TO 5104 Ser N455C/3U574793 8 September 2003

U.S. Nuclear Regulatory Commission Region I1 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303-8931

Gentlemen:

SUBJECT: REPORT OF LOSS OF LICENSED MATERIAL

This written report is submitted under Title 10, Code of . Federal Regulations, Part 20.2201 "Reports of theft or loss of

licensed material,, , subparagraphs (b) (i) through (vi) and satisfies the requirements of the 30 day notification of the loss of radioactive material. Initial voice notification was telephonically reported to the NRC Operations Center, Rockville, on August 15, 2003 and designated NRC Event No. 30647. The lost radioactive material was an In-flight Blade Inspection System (IBIS) device possessed under the authority of Nuclear Regulatory Commission (NRC) Master Materials License No. 4 5 - 23645-01NA. Enclosure (1) provides all information required by 10 CFR 20.2201 for reporting the event.

_ _

Questions pertaining to this report can be directed to CAPT David Farrand at (703) 602-5365.

Executive Secretary Naval Radiation Safety Committee

Enclosure:

(IBIS) DEVICE NEAR RICHLANDS, NC REPORT ON THE LOSS OF AN IN-FLIGHT BLADE INSPECTION SYSTEM

copy to: COMNAVAIRSYSCOM (AIR-8.4.4) CMC (SD) HMM 266 22nd MEU NAVSEADET RASO

REPORT ON THE LOSS OF AN IN-FLIGHT BLADE INSPECTION SYSTEM (IBIS) DEVICE NEAR RICHLANDS, NC

(1) Description of the licensed material:

The device involved was a helicopter In-Flight Blade Inspection System (IBIS) gauge manufactured by General Nucleonics, Inc.; model number GNI 12210-1 or 12220-1. The Sealed Source and Device Registration Number for the device is CA321D103G. The device contains either an Isotopes Products Laboratory or Amersham Model GND 12205 sealed source with a maximum activity of 500 microcuries of Strontium 90. The IBIS is permitted under Naval Radioactive Material Permit, NRMP 19-00019-TSNP.

(2) or theft occurred:

Description of the circumstances under which the loss

On August 8, 2003 a helicopter CH-53 Sea Stallion was flying from New River, NC to Quantico, VA. The aircraft was leveled at 3000 feet flying at 120 knots and

- approximately 5 miles northwest of Richlands, North Carolina when the cowling from the #3 aft outboard engine disengaged, hit the rotor and damaged one of the In-flight Blade Inspection System (IBIS) devices. The debris was observed falling in an area containing open fields with some wooded areas and was unpopulated. The aircraft returned to base without further problems.

Upon arrival at the base the helicopter was examined and found that the only damage to the aircraft was the missing #3 aft outboard engine cowling and a damaged IBIS with the section containing the radioactive source missing. It was determined that the source may have fallen anywhere in area approximately 3 square miles. This area was later searched from the air but no debris was found. The aircraft was surveyed and no radioactive. contamination was found.

(3) Disposition, or probable disposition, of the licensed material :

- - . _. .

The radioactive material is located somewhere in a field and wooded area located approximately 5 miles northwest of Richlands, North Carolina. Since the helicopter rotor blades showed no indication of contamination, the radioactive source may have fallen to the ground intact.

2


( 4 ) Exposures to individuals, circumstances under which the exposures occurred, and the possible total effective dose equivalent to persons in unrestricted areas:

It was determined that the source may have fallen anywhere in area approximately 3 square miles which contained open fields and wooded areas. There were no indications of persons residing in the area, therefore it is highly unlikely that someone will find the device and receive an exposure.

The state of North Carolina was notified of the l o s s of radioactive material and as a precautionary measure they have distributed notices describing the IBIS and warning persons not to handle the material. The fliers include how to contact North Carolina Radiation Safety personnel in case somebody finds the source.

(5) Actions taken or planned to recover the licensed material : -_ . _._

The portion of the IBIS that broke off with the source is approximately 2.5 inches long by 2.75 inches in diameter. The assembly that contains the radioactive source is about the size of a golf tee. Because of the device's small size and the location and size of the area the source was lost, it is highly unlikely the source would be found. The State of North Carolina has no plans to search for the source at this time. The Navy will assist the state if those plans change.

(6) Procedures that have been, or will be, adopted to ensure against a recurrence of the loss of licensed material :

The IBIS was damaged and the radioactive source lost when it was hit by the engine cowling that disengaged from the engine of the helicopter. The cause of the cowling accident remains undetermined because it has not been recovered and most likely broke into small pieces when it hit the main rotor. An analysis of the past 13 years data for all aircraft shows that cowlings departing the aircraft while in-flight were due to three factors:

3


- Cracks developing in the cowling. - Delamination of the cowling. - Cowling latch assemblies not seated correctly,

opening or failing in flight.

After the accident the squadron inspected the other helicopter cowlings for cracks and delamination with no remarkable result. Command to investigate the feasibility of developing new engine cowlings or new latch assemblies and to study methods to eliminate delamination.

A request was sent to Naval Air Systems

. . . . . . .. . . . _ _ .. , . . . . . . . . . . ..... .. . . .. . . . . . .. . . . ... . . - - .

4

Allegations Three concerns pertaining to operations of the Depleted Uranium (DU) NRMP issued to Crane Division. - Individuals for DU radiation safety not designated at

- Records of DU ammunition inventory not being kept - Unauthorized transfer of DU ammunition to the Coast Guard

Investigation conducted by CAP" Farrand, CDR Fragoso, and Dick Lowman

activities storing DU munitions

in 2001

Individuals Responsible for DU Radiation Safety

Requirement - Applies to ship and shore commands that store DU

munitions - Commanders shall designate in writing an individual

responsible for the radiological safety aspects of DU munitions

Finding - Commanders do designate individuals in writing - Document filed locally - Compliance monitored through ammunition supply

inspections and Permittee site audits. Deficiencies corrected.

1

DU Ammunition Inventory Requirement

Findings - Conduct a physical inventory every 12 months

- Annual physical inventory conducted per NAVSUP P-724 - Accountability accomplished using same ammunition supply

databases for other conventional ammunition - data is safeguarded for national security reasons

- Database systems track current inventory, receipts, transfers, and expenditures (PAC fires included) at the local level with global visibility

- Allowance lists and other controls embedded in the database - Database information is periodically reviewed by ammunition

management personnel for accuracy - Discrepancies noted in the inventory are investigated and

reconciled - Ammunition supply inspections and Permittee audits evaluate

compliance

Unauthorized Transfer of CIWS Ammunition to Coast Guard

Requirement - A Licensee can only transfer licensed radioactive material to an activity authorized by a license to receive it. Findings - CG Cutter MELLON requested 1500 tungsten CIWS rounds - No local inventory of tungsten rounds were available so

AMMOPAC substituted DU CIWS rounds and assigned Indian Island to fill the order

- CG is not licensed to receive CIWS DU ammunition. Authorized only tungsten CIWS ammunition.

- Database was lacking a CG restriction prohibiting the substitution of tungsten CIWS rounds with DU rounds

- Ammunition requisition personnel did not check the CIWS DU ammunition authorization list. No CG activity is on this list.

- USCGC MELLON returned the DU ammunition 3 weeks later

2

Unauthorized Transfer of CIWS Ammunition to Coast Guard

Corrective Actions - Database Restriction codes were implemented

Prohibit the substitution of tungsten CIWS rounds with DU and vice versa without the Inventory Manager’s approval

- Change to NAVSUP 802 will be made to include a footnote concerning the prohibition of substituting CIWS ammunition

- Ammunition Information Notice will be published addressing the restrictions placed on DU CIWS rounds

3

DEPARTMENT OF THE NAVY OFFICE OF THE CHIEF OF NAVAL OPERATIONS

2000 NAVY PENTAGON WASH I NGTO N. D.C. 20350 - 2000

5 104 IN REPLY REFER TO

Ser N455/3U574791 5 Sep 2003

Ms. Carolyn Evans Regional Counsel/Enforcement Officer United States Nuclear Regulatory Commission Region I1 Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 . Atlanta, GA 30303-8931

SUBJECT: NUCLEAR REGULATORY COMMISSION (NRC) ALLEGATION

Dear Ms. Evans:

The Nuclear Regulatory Commission (NRC) forwarded Allegation Numbers RII-2003-A-0070 and RII-2003-A-0080 to the Naval Radiation Safety Committee (NRSC) fo r action on July 9, 2003. Radioactive Material Permit NO. 10-00164-L1NP, issued to the Crane Division, Naval Surface Warfare Center, Crane, Indiana.

These allegations concerned the operations of the Navy's

An investigation was conducted to determine whether the concerns expressed in the allegations had merit. The investigative team consisted of Captain David Farrand, Executive Secretary of the NRSC; Commander Lino Fragoso, Officer in Charge, Radiological Affairs Support Office; and M r . Richard Lowman, Director, Radiation Programs, Radiological Affairs Support Office. The results of the investigation are addressed in the attachment.

In summation, the investigation concluded that the Navy does assign personnel responsible for the radiological safety of depleted uranium ammunition at its storage activities, it does maintain an inventory of depleted uranium ammunition, and the Navy did inappropriately transfer depleted uranium ammunition to the Coast Guard in 2001.

SUBJECT: NUCLEAR REGULATORY COMMISSION (NRC) ALLEGATION

Questions may be addressed to the Executive Secretary, Naval Radiation Safety Committee, CAPT David E. Farrand, at (703) 602-5365.

& 6 . n , MSC, U.S. Navy m x e c u t i v e Secretary, Naval

Radiation Safety Committee

2

ALLEGATION NO. RII-2003-A-0070

CONCERN 1: WHY DOESN'T THE NAVY HAVE DESIGNATED PEOPLE AT EACH LOCATION AS SPECIFIED BY THE NRC?

NRC Comment:

This concern is in regard to Permit Condition No. 17, to the Navy's Radioactive Material Permit No. 10-00164-L1NP, Amendment 2,which requires, that Commanders of Navy and Marine Corps facilities that store DU munitions under the permit, designate in writing, individuals to be responsible for the radiological safety aspects of DU munitions.

Please review the above referenced concern and determine if individuals responsible for the radiological safety aspects of DU munitions have been designated in writing for all Navy and Marine Corps facilities that store DU munitions under this permit. Determine if such designation was performed by the Commanders of the Navy and Marine Corps facilities involved. A l s o , please describe how this requirement relates to the storage of DU munitions on board ships. Please extend the scope of your review to 2 years or the last inspections (whichever is longer).

Investigation Findings for RII-2003-A-0070, Concern 1:

Navy and Marine Corps facilities and ships that store DU munitions under the permit do designate in writing individuals that are responsible for the radiological safety aspects of DU munitions. assigns this responsibility usually in a letter directly to the individual. The letter is filed locally and is reviewed during periodic audits conducted by ammunition inspection teams and the Radiation Safety Officer for the Permit. deficiencies are either corrected on the spot or are tracked. until completed.

The Commanding Officer of the facility or ship

Inspection

3


CONCERN 2 : THE NAVY DOES NOT KNOW WHERE OR HOW MANY.OF THEIR DU ROUNDS WERE FIRED, LOST OR STOLEN.

THE NAVY DOES NOT KEEP RECORD OF ITS DU INVENTORY.

NRC Comment:

This concern is related to Permit Condition No. 18, to the Navy's Radioactive Material Permit No. 10-00164-L1NP, Amendment 2, which requires that the command conduct and reconcile a physical inventory every twelve months to account for all sources received, transferred, and possessed under the permit. This condition also requires that records of such inventories be maintained for five years. This concern is also associated with the Security and Control of Licensed Materials as required by 10 CFR Part 20. NRC Region 11 was provided with information that appears to indicate that the Navy does not keep track of the number of DU rounds fired at sea or where they are fired. While we understand that NRC regulations and the Navy's license do not require the Navy to record the number of DU rounds fired nor the location where they were fired, control of licensed material is still a requirement of the above referenced permit and under 10 CFR Part 20.

Please review the above referenced concern and in your response describe how you keep control of licensed material received, possessed or transferred under this permit. Please describe how your materials accounting system (including your annual inventory) helps you identify any lost or stolen sources, and how it ensures you can identify how much material is in storage at a warehouse, is at sea (aboard vessels), and how and when the inventory is adjusted when it is used for the Pre-Action Calibration and Alignment (functionality and serviceability) procedure of CIWS Systems.

Investigation Findings for RII-2003-A-0070, Concern 2 :

The Navy has an effective material accounting system for controlling the receipt, storage, segregation and inspection of all ammunition including those containing depleted uranium (DU) . The integrity of the Navy's ammunition stockpile and the accuracy of the ammunition inventory form the basis upon which important strategic decisions are made such as ordnance positioning, fleet support, readiness assessment, requirements

4


CONCERN 2: THE NAVY DOES NOT KEEP RECORD OF ITS DU INVENTORY. THE NAVY DOES NOT KNOW WHERE OR HOW MANY OF THEIR DU ROUNDS WERE F I R E D , LOST OR STOLEN. (continued)

determination, and ordnance acquisition programs. Because of its strategic importance, ammunition inventory information is safeguarded for national security reasons. However, those individuals who perform ammunition acquisition, inventory management, and requisition processing functions have ready access to this information to properly perform their job responsibilities.

There are several Naval publications and instructions that prescribe policies and procedures for Navy and Marine Corps conventional ordnance distribution, requisition, stockpile management, accountability, and inventory processes. Naval Supply Publication P-724, 'Conventional Ordnance Stockpile Management" prescribes most of these policies and procedures. It is applicable to all NavylMarine Corps activities and personnel involved in the management of explosive ordnance material. This publication specifically addresses DU ammunition and requires an annual 100% physical inventory of the DU ammunition at the local level and the reporting of any discrepancies.

Accountability of CIWS depleted uranium ammunition is accomplished through the same supply/management databases used for all Navy conventional ammunition. These databases track the current inventory, receipts, transfers, and expenditures (including the Pre-Calibration and Alignment test of t h e CIWS system) at the local level (ship and shore activities) and are globally visible. of conventional ammunition, these databases are also embedded with allowance lists (activities authorized to possess a specific ammunition) , Non-Combat Expenditure Allocation data for each ammunition type, and other information such as use priorities and restrictions on specific ammunition. databases are periodically reviewed by ammunition management personnel for inventory and transaction accuracy. Discrepancies are investigated and reconciled.

To aid the requisition process and management

The

5


CONCERN: UNAUTHORIZED TRANSFER OF 1700 ROUNDS OF MK 149 MOD 2 AMMUNITION (DU) TO THE COAST GUARD (PACIFIC ARMORY DETACHMENT SEATTLE) ON AUGUST 2001.

NRC Comment:

The shipment consisted of 1700 rounds of MK 149 Mod 2 ammunition that was delivered to the Pacific Area Armory Detachment Seattle on August 7, 2001. This ammunition was then transferred to Coast Guard Cutter MELLON (WHEC-717) on August 15, 2001. The ammunition was transferred to the Naval Weapon Station Indian Island on August 23, 2001. .The coast Guard was not licensed to

. possess DU.

Please perform a thorough review of the circumstances of the transfer. Include in your review any apparent violations and their root cause. Describe why existing processes for the security and control of licensed materials failed to prevent this apparent unauthorized transfer of licensed materials to the Coast Guard.

Investigation Findings for Allegation Rll-2003-A-0080:

The Navy did transfer 1700 depleted uranium (DU) rounds of MK 149 Mod 2 Close-In-Weapon-System (CIWS) ammunition to the United States Coast Guard (USCG) Pacific Armory Detachment Seattle in August 2001. The Coast Guard is not authorized to receive these DU rounds.

Series of events:

USCGC MELLON submitted a requisition through the ammunition supply system in August 2001 for 1500 rounds of MK 149 tungsten Close-In-Weapon System (CIWS) rounds to be delivered to the USCG Pacific Armory Detachment, Seattle, Washington.

This requisition was processed through the Naval Ammunition Logistic Center, Pacific (AMMOPAC) who determined that Naval Magazine, Indian Island, Washington was the closest source for the CIWS ammunition. However, at the time Indian Island did not have a sufficient inventory of tungsten CIWS ammunition to fill USCGC MELLON’s request. AMMOPAC substituted the tungsten rounds with DU rounds and requested Indian Island to fill the request.

6


CONCERN: UNAUTHORIZED TRANSFER OF 1700 ROUNDS OF MK 149 MOD 2 AMMUNITION (DU) TO THE COAST GUARD (PACIFIC ARMORY DETACHMENT SEATTLE) ON AUGUST 2001. (continued)

At the time of the request, AMMOPAC personnel noted that there was not a restriction in the database or other documents prohibiting the substitution of CIWS tungsten rounds with DU rounds. However, they apparently did not check the allowance list for the DU CIWS rounds. This allowance list is embedded in the ammunition supply database and shows no Coast Guard ship as authorized to receive DU CIWS ammunition. Indian Island issued 1700 DU CIWS rounds to Pacific Armory Detachment Seattle (the quantity was changed from 1500 to 1700 rounds to prevent cutting the package'banding and having a partial box/lots left over). Pacific Armory Detachment Seattle received the 1700 DU rounds on Aug 7, 2001 and then issued the DU rounds to the USCGC MELLON on Aug 15, 2001. On September 5, 2001 the USCGC MELLON returned the 1700 DU rounds to Indian Island after determining they were not authorized to receive this ammunition.

Root Cause :

1) NAVSUP P-802, Navy Ammunition Logistic Codes, Part Four provides guidance for the issue priority of this type of ammunition and the allowances for substitute ammunition. NAVSUP-802 does not have a note prohibiting the substitution of tungsten CIWS rounds with DU rounds when a Coast Guard vessel requests CIWS ammunition. In addition, the ammunition databases used in'the requisition process do not contain information that restricts the substitution of tungsten CIWS rounds with DU rounds.

2) A contributory cause to the event was that the ammunition requisition personnel did not check the allowance list for the CIWS DU rounds before substituting the tungsten ammunition with DU ammunition. Coast Guard ships are not authorized to receive DU CIWS ammunition per this list.

Short Term Corrective Action:

1) Database controls were implemented so that only the ammunition inventory manager at the Headquarters Naval

7


CONCERN: UNAUTHORIZED TRANSFER OF 1700 ROUNDS OF MK 149 MOD 2 AMMUNITION (DU) TO THE COAST GUaRD (PACIFIC ARMORY DETACHMENT SEATTLE) ON AUGUST 2001. (continued)

Ammunition Logistics Center can make a substitution of DU CIWS ammunition for tungsten and vice versa. The ammunition item manager is fully aware of the NRMP requirements and that the Coast Guard is not authorized to receive DU ammunition.

Long Term Corrective Action:

1) A change to NAVSUP-802 will be made to include a footnote that USCG vessels are not authorized to receive DU ammunition as a substitute for tungsten ammunition.

2 ) Re-emphasize to ammunition supply personnel through an ammunition information notice that Coast Guard vessels are not authorized to receive DU ammunitions and that DU ammunition shall not be used as a substitute when Coast Guard ships request tungsten CIWS ammunition.

8

PERSONNEL CONTACTED DURING INVESTIGATION RESPONDING TO NRC ALLEGATION NOS. RII-2003-A-0070 AND RII-2003-A-0080

1. 10-00164-L1NP, Crane Division, Naval Surface Warfare Center

Mr. Mark Qualkenbush - Radiation Safety Officer f o r "RMP No.

2 . Mr. Thomas McAtee - Minor Caliber Ammo Program Manager (CIWS Ammunition Program Manager), Naval Sea Systems Command Conventional Ammunition Program O f f i c e

3 . Chief of Naval Operations (N411)

CDR Michael Kelly - Conventional Ordnance Program Manager,

4. Mr. Michael Koblish, CIWS Ammunition Inventory Manager, HQ Naval Ammunition Logistics Center

9


Naval Master Material License Annual Program Review

UNCLASSIFIED

~ ~ _____ ~~~~~~~ ~


MML Program Review 2003 Conducted August 2003 +Technical Support Center review

conducted 18-22 August 2003

Scope +Operations +Permit and

Review

at Technical Support Centers Inspection Documentation

+Personnel Radiation Exposure Analysis

UNCLASSIFIED

1


Technical Support Centers 1 Manning-

+ NEHC - 1 Military, 2 Civilian Inspector hired August 2003

1 military, 1 civilian vacancy 2 environmental positions created

+ RASO - 3 Military, 12 Civilian

Inspections + Excellent documentation + Conducted within the NRSC guidelines - Except Deployed

and Overseas Activities + Reports submitted to NRSC on time - One exception + Command responses to Inspection Reports were generally

on time - Tracking systems effective

UNCLASSIFIED


Technical Support Centers (continued) rn Permits

+ Excellent Documentation by both

+ NEHC - All Medical NRMPs undergoing Technical Support Centers

renewal to formalize new Part 35 requirements

+NEHC - Drug Screening Labs terminating

UNCLASSIFIED

2


0

Violation Trend Analysis

occ Total Dose Average Code Occupation Code Title (mrem) Dose (mrem)

32 Nuclear Medicine 11005 75.4 a 3 3 Theram (Medical) 630 16.6

70 Number of Inspections Average per Inspection

0

Number of Inspections 10 4- with No Violations

O I I I I I

.. .. _ _ I , I - -

40 Gamma Radiography 3428 13.1 0 4 3 FiADlAC Calibration 647 3.9 0 4 4 General Industrial 1161 3.3

3.0

2.0

1 .o

0.0

cY-98 CY-99 CY-00 cy-oi CY-02

UNCLASSIFIED


CY-2002 Exposure Summary

0 50 I Research I 5201 2.3 Research Isotopes I 4221 2.9

UNCLASSIFIED

3

. Naval Radiation Safety Committee

CY-2002 Exposure Summary occ Exposure Ranges (mrem)

33 18 19 1

Codes o 1-100 101-zoo zoi-300 301400 401-500 501-1000 1001-2000 32 46 49 36 11 3 1

# of Persons

146 38

44 50 51

Total

Occupation Description Code

32 Nuclear Medicine > 100 mrem

281 75 356 194 28 1 223 105 39 144 911 360 46 13 4 0 1 0 1335

33 Therapy (Medical) 40 Gamma Radiography 43 RADIAC Calibration 44 General Industrial 50 Research

Total Number of Gamma Neutron Total Dose

1-10

Average

51 Research Isotopes 0 mrem

1999 1684 2000 1424 2001 1419 2002 1335

UNCIASSIFIED

171 57 445 17602 10.45 20452 839 21291 14.95 17025 71 3 17738 12.5 16588 1225 17813 13.3

~ ~~ ~~

Naval Radiation Sa fetv Committee

ALL OCCUPATIONAL NRMP CODES 2500 T

1500 People Monitored

low/ 500

25000

20000

15000 Total Dose

10000

5000

0

(mrem)

Year I Persons Monitored I Dose (mrem)] Dose (mrem)l (mrem) I Dose (mrem) 1998 I 2335 I 18452 I 964 I 19416 I 8.3

IINCI AS!!IFIED

4

TECHNICAL SUPPORT CENTER = RADIOLOGICAL AFFAIRS SUPPORT OFFICE (RASO)

Permit Actions Permit Actions Carried Over from Previous Quarter Permit Actions Received During Quarter Total Permit Actions "In House" During Quarter

Actions Signed Out by NRSC Actions Pendina at End of Quarter

New Issues Terminations Amendments Renewals Totals 1 0 0 6 7 2 1 19 1 23 3 1 19 7 30 2 1 16 2 21 1 0 3 5 9

]Actions Exceeding NRSC Guidelines *I I 0 I 0 I 0 I 0 I 0 I

Quarterly Average Inspection Report Processing Time (Days) ,Longest Inspection Report Processing Time This Quarter (Days) Inspection Reports Exceeding NRSC Guidelines *2

Conducted 6 machine inspections

15 27 0

Remarks:

*I (New Issues, Terminations, Amendments < 6 Months) (Renewals e 12 Months) *2 ( Satisfactory Inspection < 60 days, Unsatisfactory or Containing Level 111 Violation < 14 days)

TECHNICAL SUPPORT CENTER = NAVY ENVIRONMENTAL HEALTH CENTER (NEHC)

Permit Actions Permit Actions Carried Over from Previous Quarter Permit Actions Received During Quarter Total Permit Actions "In House" During Quarter Actions Signed Out by NRSC

~

New Issues Terminations Amendments Renewals Totals 0 2 0 7 9

0 1 6 11 18 0 3 6 18 27

0 3 6 0 9

IActions Pendina at End of Quarter I 0 i 0 I 0 I 18 I

Permit Inspections

Inspection Reports Carried over from Previous Quarter Inspections Conducted During Quarter Total Inspection Reports "In House" During Quarter Inspection Reports Signed out by NRSC

Total

2 2

4 3

,Quarter% Average Inspection Report Processing Time (Days) Longest Inspection Report Processing Time This Quarter (Days)

51 98

1 Inspection Reports Exceeding NRSC Guidelines '2

Remarks: *I (New Issues, Terminations, Amendments < 6 Months) (Renewals 12 Months)

)*2 ( Satisfactory Inspection < 60 days, Unsatisfactory or Containing Level 111 Violation c 14 days)

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NRMP SUMMARY 3rd QUARTER CY-2003

Type Code Description Number 1 Nuclear Medicine (Limited Scope) 13 2 Nuclear Medicine (Broad Scope) 1 3 Teletherapy 0 4 Research (Non-Human Use) 5 5 Irradiators (< 10,000 Curies) 0 6 Navy Drug Screening Laboratories 3 7 Gas Chromatographs 0 a Special Nuclear Material SNM (<200 grams) 0 9 Other (Dosimeter Calibration) 2

Total NEHC NRMPS 24

Type Code Description Number A Radiography (Fixed and Field Ops) 13 B General Industrial 11 C Instrument Calibration Services 17 D Decomissioning of Byproduct Material 0 E R & D Type A Broad Scope 3 F R & D Type B Broad Scope 1 G R & D Type C Broad Scope 0 H Special Nuclear Material SNM (Unsealed, < Critical Mass) 0

I Portable Gauges 11

K Gas Chromatographs 0 L DU Munitions Distribution and Storage 2

J Analytical Measuring Instruments 28

M Subcritical Assemblies 1 N RTG Power Sources 2 0 Not Used 0 P Fixed Gauges 1 Q Irradiators 1 R Buried Waste (Substrata for hardpan) 1 S Source Material 2 T Radioactive Commodities Distribution and Use 9 U Leak Test Services 0 v Special Nuclear Material SNM (c 200 grams) 1 W Research and Development 6 X Byproduct Material Standby (No ops) 0 Y Source Material Standby (No ops) 1 Z VACIS System Usage 1

otal RASO NRMPs 112

GRAND TOTAL NRMPs 136

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