IR 05000047/1974001
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U.S. ATOMIC ENERGY CC: !ISSION DIRECTC? ATE OF RECULATORY OPEFATIONS
REGION I
30-47
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Docket No:
- RO Inspectien Report No t R-65 Army Materials and Mechanics Research Center License No.
Licensee:
(AMMRC)
Priority:
C Category:
Watertown, Massachusetts Locat' ion:
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Research Reactor (Dea'ctivated 3MW Pool Type)
Typ'e o.,,icensee.
Routine (Announced)
ype of Inspection:
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Dates of Inspection:
I April 20, 1972
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Dates of Previcus Inspection:
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Reporting Inspector
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'Karl E. Plumlee, Reactor Inspector Accompanying Inspectors:
NONE Date Date Date
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NONE Other Acccmpanyin Perscnnel:
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Revicwed By:
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Date D. Caphton, Se'nior Reactor Inspector
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8204210695 811005 PDR FOIA KABAT-ZB1-311 PDR
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SUMMARY OF FINDINGS Enforcement Action A.
Violations 1.
Cathodic Protection for Containment Shell Technical Specification 4.b. requires quarterly and semiaanual checks on the cathodic protection system, and records and
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evaluation thereof.
Contrary to the above the most recent recorded check was dated May, 1973, when the cathodic protection system was found to have failed.
The system had not been repaired by the comple-tion of this inspection on July 12, 1974. This apparent violation is repetitive in that a citation was made on the preceding inspection * for failure to carry out T.S. No. 4.b.
(Details, Paragraph 7)
2.
Radiation Monitoring Technical Specification No. 3.a. requires monthly radiation surveys.
Contrary to the above only 7 surveys were made during 1972, 5 during 1973, and 3 during the first six months of 1974** for an average of half the required number of surveys.
(Details, Paragraph 5)
3.
Posted Information The Code of Federal Regulations in part 10 CFR 19.11 requires the posting of licenses.
Contrary to the above, no copy of License No. R-65 was posted when inspected on July 10, 1974.
This matter was corrected by the ccepletion of the inspection.
(Details, Paragraph 2.c)
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B.
Safety None Inspection Report No. 50-47/72-01
Smears made during July had not been counted by July 10, because
high seasonal temperature aciected the counting equipment.
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Licensee Action on Previously Identified Enforcement Items 1.
Cathodic Protection System The preceding inspection identified a failure to perform quarterly checks of the cathodic protection system (required by TS 4.b.).
The licensee's reply dated June 5,1972, following a notice of violation, stated that TS 4.b. would be carried out " effective 4th Qtr FY 72".
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A further violation of TS 4.b. was identified on this inspection.
(Violations, Item 1)
2.
Operability of Fire Alarm Systems The preceding inspection identified a failure to perform semiannual operability checks of the fire alarm system (required by TS 1.d.).
The licensee's reply dated June 5, 1972 stated that semiannual tests would be done ccomencing June, 1972.
On this inspection these records appeared to be in order but cross checking of fire inspection records against logged entries into the plant area resulted in an unexplained possible discrepancy that re-mains unresolved.
(Details, Paragraph 9)
3.
Annual Preventive Maintenance on crane The preceding inspection identified an apparent f ailure to perform annual preventive =aintenance on the polar crane *.
The licensee's reply dated June 5,1972, explained that this maintenance was done when due but the records failed to show this until they were sub-sequently reviewed and corrected.
On this inspection these matters appeared to be in order. This item is considered closed.
(Details, Paragraph 8)
Design Changes None Unusual Occurrences
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None A commitment stated by the licensee's Deactivation Report for Reactor
Facility, dated February 3, 1970.
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Other Significant Findings A.
Current (Unresolved)
1.
Differences between dates on inspection records and logged entries into the plant area.
(Details, Paragraph 9)
2.
Identific'ation of a complete file of preventive maintenance records.
(Details, Paragraph 11)
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3.
Semiannual audits by Reactor Safeguards Committee.
(Details, Paragraph 2.b.)
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3.
Status of Previously Reoorted Unresc1ved Items None
Management Interview The management interview was conducted on July 12, 1974, with the following representatives of the licensee:
Dr. A. E. Gorum,* Director, AMMRC Mr. S. J. Lavery,* Chief, Administrative and Logistics Services Offices Mr. J. J. O'Connor,** Chief, Technology Planning and Exploitation Division Mr. S. Levin, Chief, Radiation and Occupational Saf ety Branch The following items were reviewed:
A.
Scope of Inspection The inspector stated that this inspection involved the following general categories:
1.
Technical Specification requirements.
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Followup on items from the preceding inspection.
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Upkeep of the facility.
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New Regulatory requirements (since April,1972).
B.
Violations f
The inspector stated the three apparent violations.
(See Violations)
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Present during part of the meeting.
- Reactor Facility Supervisor.
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The licensee's representatives stated an intent to restore the cathodic protection system to operation before the end of July, 1974 and to meet the Technical Specification requirements for frequency of radiation surveys and maintenance.
The possibility of obtaining changes to the Technical Specifica-ticas and eventually a license termination were discussed.
C.
Paint Problems
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The inspector stated that paint had deteriorated on the exterior of the containment shell and the stack flanges, and rust was
evident.
The inspector stated that rust was visible on the inside of the containment shell where insulation had peeled off.
(Details, Paragraph 4)
The licensee's representatives stated that a contract was being negotiated to paint the exterior of the containment shell this summer and that indoor humidity was being reduced by operating the air conditioning.
D.
Management's Resconsibilities The inspector stated that the Reactor Safeguards Committee was re-quired by the Technical Specifications to audit and verifv that emmissions did not occur. The inspector stated that two violations, l
identified on this inspection, had existed for more than a year in for semiannual audits spite of a Technical Specification requirement l
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to verify that eff ective practices are maintained.
(Details, Para-graph 2.b)
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This item will be followed up on a subsequent inspection.
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E.
Develooments Since The Preceding Inspection The following developments were discussed:
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Relocation of Regional Office I to King of Prussia, Pa.
2.
Requirements under 10 CFR 19.
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3.
Categories of Violations.
Public document room copies of inspection reports and correspondence.
5.
Proprietary information, and withholding of proprietary in-formation from public disclosure.
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DETAILS 1.
Persons Contacted The inspector interviewed the following persons:
Mr. P. J. Burke, Health Physics Technician Lt. A. R. D'Arpino, Intelligence and Security. Branch Mr. J. Druwing, Electrical Engineer Dr. A. E. Gorum, Director, AMXRC Mr. S. J. Lavery, Chief, Administrative and Logistics Ser* rices Offices Mr. S. Levin, Chief, Radiation and Occupational Safety 3 ranch Mr. J. J. O'Connor, Chief, Technology Planning and Exploitation Division Mr. W. E. Walsh, Chief of Maintenance 2.
Administration and Organization a.
Responsibility for Reactor Facility The AMMRC Director is Dr. A. E. Gorum.
The AMMRC Commander / Deputy Director is LTC R. 3. Henry.-
The Reactor Facility Supervisor is Mr. J. J. O'Connor whose title is Chief, Technology Planning and Exploitation Division.
b.
Reactor Safeguards Committee (RS C)
The Technical Specifications in parts 2.b.(2) and (3) respec-tively require RSC review of reactor procedures and a semi-annual audit of activities performed in the plant area to verify that effective safety and radiological control practices are maintained.
Review of RSC minutes for the most recent meeting (May 21, 1974)
did not confirm that semiannual auditing (if any) was ef fective.
Although awareness of a problem with the cathodic protection was apparen t, it appeared that violations Nos.1 and 2 both existed
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for more than a year without correction.
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RSC activities will again be reviewed on a subsequent inspection.
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Membership of the RSC was indicated to be the following:
H. Priest, Chairman J. Antal D. Chipman S. Levin J. O' Connor K. Tauer c.
Posted Information
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Inspection of inf ormation posted in accordance with the Code of Federal Regulations in part 10 CFR 19.11 found that License No. R-65 was not posted.
(See Violations). The licensee's representative corrected this item before the completion of the inspection.
3.
Condition of the Reactor The licensee's representative described the reactor as defueled and drained.
Visual inspection confirmed that' the reactor vessel was open, defueled and dry inside.
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No discrepancy was found in comparison to the status described by the licensee's Deactivation Raport for Reactor Facility, dated February 3,1970 (on a sample basis).
The licensee's radiation survey records indicated that the maximum radiation inside the reactor vessel is about 6 R/hr.
No problem was identified involving the condition of the reactor.
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4.
Containment
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a.
Paint and Rust
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Visual inspection of the exterior found noticable paint peeling
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f and rust at the flanges of the stack and on top of the cor 1 l
ment shell.
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Rust was found on visible exterior surf aces that were below l
grade, such as pipe pits.
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Inspection of the interior showed that a few patches of insula-tion had dropped from the underside of the containment shell,
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and some rust was visible, typically in the larger areas.
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When questiened, the licensee's representative stated that the exterior was to be painted this summer, and that the cathodic protection system would be restored to service before the end of July.
The licensee's representative stated that one possible cause of the insulation problem was high humidity which might have caused moisture to condense in the insulation. Humidity was being controlled, when inspected, by operation of the air conditioning in the containment.
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b.
General Condition of Containment Structure for problems with paint, sprayed on insulation, and Except no deterioration of the containment structure or associ-rust, ated aquipment was noticed.
5.
Radiation Monitoring TS 3 requires a monthly radiation survey, including smears, and control of radioactive and conexninated =aterials removed frem the plant area.
Inspection of records of surveys, air samples, and smears indicated that on the average half as many surveys were made as stated by IS 3.
All of the survey results inspected were well below one cr/hr except those taken inside the reactor vessel which were as high as %6 R/hr.
Most of the air sample results were recorded as below the detection level and none appeared to be significantly above that level or in excess of 10 CFR 20 limits.
2 e activity.
2 3 and 2 uuci/cm Smears were no higher than 39 vuci/cm The recorded dates en the survey record sheets were noninally as follows:
l 1972 1973 1974 l
January 21 January 19 January 15
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February 23 June 11 May 24 March 24 August 1 June 19
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April 21 November 14 July 9*
June 20 December 11 July 27 December 5
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- Smears taken July 9 were not counted by the date of the inspection because of high seasonal temperature, said to affect the performance
of the counting equipment.
6.
Liquid Radwaste Release Records Review of the licensee's release record sheets indicated that a total of about 2 uCi of activity in 5,400 gallons of wa~ter was released to the sewer during 1973, and 48 uCi of activiry in 23,000 gallons of water was released during 1974 to date.
No problem was identified with the releases or the records.
7.
Cathodic Protection System Inspection of records indicated that the most recent quarterly check of the cathodic protection system was in May,1973 at which time it
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was found to have failed.
(See violations)
A representative of the licensee stated there was difficulty in re-placing a rectifier, and that an adaptation was being made. He stated that the cathodic protection system should be back in opera-tion before the end of July.
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S.
Preventive Maintenance on the Crane Inspection of preventive maintenance on the crane indicated that the licensee's records on this ites are in order. No Technical Specifi-cation is involved.
This item is considered closed until the crane is placed in service.
9.
Fire Prevention Reports Records of monthly fire prevention inspection for January through June, 1974 and semiannual operability tests (required by TS 4.c and d., respectively) appeared to be in order.
A cross-check against the logged entries into the containment area (a record required by TS 1.c) confirmed that the fire inspector entered on four of the six dates shown by the reports.
(See next item)
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10.
Physical Security (TS 1.c.)_
Observation of physical security did not indicate any violation of Technical Specification requirements on key centrol or access control for the plant area.
A cross-check between logged entries by personnel and reports of surveys and maintenance confirmed that the number of logged entries (and dates, on a spot check basis) were consistent except
for the fire Laspections.
Fire prevention reports for 1974 were as follows:
Date Fire Insoector Access January 2,1974 (Logged entry)
January 30, 1974 (Logged entry)
February 28, 1974 (Logged entry)
March 22, 1974 (Logged entry)
April 30,1974 (No logged entry *)
May 31, 1974 (Others logged entries)
June 25, 1974 (Logged entry)
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- The fire inspector was not logged into the plant area during April, and no one was logged in on April 30.
The lack of a logged entry was not explained unanimously. The~
fire inspector was on leave at the time of this inspection.
Cross checks of records will again be made on a subsequent in-spection.
11.
Preventive Maintenance IS 4.a. requires a weekly visual inspection and a monthly check of all equipment in the plant area. TS 5.b. requires records of inspections.
Inspection of a file of checksheets bearing a weekly notation in-dicated that 9 were completed during 1971, 13 during 1972, 22 during 1973, and 8 during 1974 to date.
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The licensee's representative objected to a possible citation on the above, and this item remains unresolved pending resolution of ques-tions of completeness and proper identification of the file folders for weekly and monthly =aintenance surveillance records.
This item will be inspected on a subsequent inspection.
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