IR 05000054/1982001
| ML20042C683 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 04/29/1982 |
| From: | Dunlap J, Gody A, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20042C684 | List: |
| References | |
| 50-054-82-01, 50-54-82-1, 70-0687-82-02, 70-687-82-2, NUDOCS 8205170454 | |
| Download: ML20042C683 (1) | |
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U. S. NUCLEAR REGULATORY COMMIS$10N
REGION I
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70-687/82-02 SNM-639 Report No.
50-54/82-01 License No.
R-81 Safeguards Group I
Licensee:
Lnion Carbi Corporation
gg Tuxedo,_New York 109S7 W
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Facility Name:
Sterlino Forest Research Center Inspection At: _ Juxedo, New York 10937
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Inspection Conducted:
March D -31,_1932
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Date of last Physical Security Inspection:
Fay 26-29, 1981 _
Type of Inspection:
Rou*ir Urannounc Physical P-otection Inspectors:
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A. T. Gody, ChieJ/$afeguards Section, da cfe Technical ProVams Branch Inspection Summary,;,
Routine Unannounced Physical Protection _ Insp~ection March 30-31, 1982 Rombi_ned Report Nos. 70-6STE2-02 and 5044/T2-01)
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Areas Inspected: GeneralRRiirementsforSpecialNuclearMaterialofModerate
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Ftrategic Significance at fixed sites including:
Security Plan; Protection of
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SNM; Security Organization; Access Control; Alarm Systems; Keys and locks, Communications; Surveillance; Procedures; and Security Program Review.
The inspection also included follow-up on a previous inspection finding.
The inspection was begun during regular duty-hours and involved twenty-six inspector
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hours onsite by two region based inspectors.
Results:
The licensee was found to be in compliance with NRC requirements in l
the areas examined.
THE INFORMATION ON THIS PAGE IS DEEMEn S-F1-92-46 Region I Form 12 TOBEAPPROPRIATEFORPilRLICDISCLOSilRECopy_4,of51 CkTIN r
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o DETAILS
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Key Persons Contacte,d i
'J. McGovern, Business Manager,'Radiochemicals
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- M. Voth, Manager, Nuclear Operations l
W. Ru;icka. Reactor Supervisor j
P. Orake, Maintenance Supervisor i.
R. Hubbard, Manager, Maintenance Engineering
- denotes those present at exit interview.
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2.
30703-Exit Interview The inspector met with licensee representatives (denote in Faragraph 1)
I at the conclusion of the ir.spection on March 31, ic!2.
The inspector Summarized the secpe and findirgs of the inspection.
3, 92702 - Follow-vo on Previous _!nspection Findines (Closed) Viciation-657/79-04-01' Failure of the licensee tc eit5er M mmnEL-The licensee
alarm the
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has not. armed th ggg,yd -
jhTJver on 11-20-81 a procedsre wasimplementedwhichreoutres*hk
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. E '.e2. v M,yThe above action is considerec acequate to provide protection
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of the SKM in the &
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81490-3eneral Requirements for _$NM of Mode-ate Strategic Significance at fixed $ites No violations were identified.
The inspection results were attained through review of the following areas, a.
Security Plan l
The " Physical Security Plan for the Union Carbide Corporation Medical l
Products Division, Tuxedo, New York," was dated January 15, 1982.
l This plan was written in response to the requirements contained in L
10 CFR 73.67 and covered activities and materials licensed as follows.
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1.
NRC License Number R-81, Docket Number 50-54.
2.
NRC License Number SNM-639, Docket Number 70-687.
b.
Protection of SNM Review of the protection of SNM included:
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An examination of the licensee's
Verificatier,thatthelwpervision of ore r * rnore 6t-]The individuals s is only opened ander the 2.
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Union Carbide Corperation (UCC) security procedures.
3.
A tour of the f
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c.
Security Organi:ation Review of the security organi:ation included:
Verificat on that the UCC employees [,,,,f ] ;..ho perform 1.
i watch.ien duties are deployed and used as prescribed in the security plan.
2.
Discs.,sions, with tha { ll,~i g lin order to verify their under-
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stanc,ing of their conaterai secu ity related cuties.
d.
Access Controls Review of access cartrols included:
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A tour of
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Observaticn of packages being searched prict to acmittance to the protec',ed area.
3.
Verification that all individuals entering the protected area were issued an appropritate identificaticn M dge.
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Alarm Systems Review of the alarm systems included performance testing 6 1ocated at the following entrances.
Entrance No.
Location
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Keys and locks l
The review of the security keys and locks' included:
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A review of lock chan rotords to verify that
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e nere were ten lock changes one y tne icensee s nce ay 951.
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An invento of securit reia.ed Leys maintained ir, th g -..
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Communications Review of the communications consisted of performance testing the assigneo for security use.
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h, Surveillance
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The surveillance review consisted of the following:
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A review of randomly selected l
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Discussions with watchmen ar.d licensee personr.el regarding surveillance of SNM during regular and non-regular working hours.
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procedures The procedures review included:
1.
A review of security procedure RS-40-1 dated November 20, 1981 that was used to perform entrance alarm tests.
2.
A review of security procedure RM-12-3, dated September 1,1980 that was used to implement the security plan.
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Discussions with operations personnel and watchmen regarding response procedures and responsibilities during various hours
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Security Program Review
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l The security plan requires that the site's security program be reviewed once every two years.
The licensee stated that the last
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review was concucted in January 1982.
The current plan, dated Janua ry 15, 1932 is based on the results of the Security Program Review.
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~ EEDOM OF INFORMATION REROEST
FREEDOM OF INf DMA110N t%3LOf
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),S A$e county PUaLICATIONS, A DIVis10N OF OTT AWAY NCWs
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40 Multierry Strwt, Middletown, New York Ig Iggg
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ACT REQUEST
Feb. 22, 1990 Office of the Administrator US Nuclear Regulatory Commission FREEDOM 0F INFORMATION REQUEST Washington, D.C.
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Dear Sir This is a Freedom of Inf ormation request f or copies of the followinds 1. Yearly reports or comoitations of reports done yearly on the operations at Cinticheme which runs a 5-megawatt reactor on Lont Headow Roadi Sterling Foreste Tuxedo. (We have the Jan. 23, 1990 report on' inspections done in October of 1988 - Docket Nos. 50-54 70-687.) We request these reports for the pat.t 10 years.
2. Responses by Cintichem to those reperts, detailing actions, the i
company contemplated taking in response. (We do not have a copy of l
Cintichemis Jan. 23, 1990 report response. We understand it has not been sent to you. But we would request it when filed.)
3. Any pri.liminery notification by Cintichem to the NRC about unusual events at the plant. Also, for the last 10 years.
4. Any settlements, agreementsi or other legal statements in which Cint1 Chem agrees to undertake corrective actions as a result of having been found in violation of NRC regulations.
5. A blueprinte maps or other geographic or architectural material filed with you by Cintichem showing its layout.
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6. Specifically we request a copy of the agreement or settlement of violations dated April 23:1987 in which the company was fined or agreed to pay a fine of $12 500.
We realize that some of this information.may be more readily found than other parts. We request the most readily accessed as L
soon as possible.
Thank you for your cooperation.
If this request should be denied please tell us who your appeals officer is so our lawyers may act quickly.
Special Projects Writer
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UNION CAR 8IDE CORPORATION i
MEDICAL PRODUCTS DIVISION P C. 00 * 324, TUxf 00 Ntw VORM 1096?
TELtpHONti 916351213)
t November 10, 1981 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attn: Mr. Richard W. Stalostecki, Director
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Division of Resident & Project Inspection
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Subj:
Inspection Nos. 50-54/81-02 and 70-687/81-04 Notice of Violation Gentlemen:
This letter is in response to the subject Notice of Violation for falling to conduct an audit of the management of the UCC Fundamental Nuclear 14aterial Control Plan within the prescribed time schedule.
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Audit assignments had been made by the Nuclear Safeguards Committee in a timely fashion however, some were assigned to persons outside of the Radiochemicals line organization.
Nomal follow-up procedures on the part of the Secretary of the Committee were not effective in accomplishing some audits on schedule.
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S-F1-81-77 Copy of Copies 2 Pages
- 90MGb/W2gg
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Inspection Nos. $0-54/81-02
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& 70-687/81-04 Notice of Violation-2-November 10, 1981 Future audits will be assigned only to employees within the Radiochemical line organization.
The assigments will be made. *a part of the departmental project assigment schedule which is. rev.iewed monthly for status reports to management on all projects.
This follow-up procedure will provide management with the necessary control :for assuring that audits are completed on time.
This new program for audit control was implemented on 10/28/81 and it should prevent a recurrence of this item of non-compliance.
The management audit that was the subject of this Notice of Violation was completed.
Very truly yours, fu 4cA
- gy James J. McGovern Business Manager Radiochemicals JJMcG
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cc C. J. Konnerth W. G. Ruzicka M. H. Voth
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STATE OF NEW YORK)
SS COUNTY OF ORANGE)
On this ##4 day of November 1981, before me personally came James J.
McGovern to me known and known to me to be the individual described in and who executed the foregoing instrument and acknowledged that he executed the same.
tid. ? * m f Notary Public.d
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R REGULATORY COMMIS$10N
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nacioN 1 434 PARK AVENUE j
KING OF P AUlll A. PENN6Yl.V ANI A 19404
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50-54
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Docket Nos:
70-687
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Union Carbide Corporation ATTN: Mr. James J. McGovern Business Manager, Radiochemicals
P. O. Box 324 Tuxedo, New York 10987
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Gentlemen:
Subject:
Combined Inspection 50-54/81-02; 70-687/81-04
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This refers to your _ letter dated November 10, 1981, in response to our letter dated October 16, 1981, f
Thank you fee informing us of the corrective and preventive actions documented l
in your letter.
These act10ns will be examined during a future inspection
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of your licensed prograie.
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In accordance with 10 CFR 73.21 of the NRC's regulations, documentatiort of
findings of your control and accounting procedures for safegijarding special nuclear materials and y0ur facility security measures for physical protection
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l are de2msd to be Safeguards Information.
Each person who produces, receives or acquires Safeguards Information it required to ensure that it is protected against unauthorized disclosure.
Therefore, the referenced letter will not be placed in the Public Document Room and will be distributed pursuant to
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i Your cooperation with us is appreciated.
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Sincerely, l
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Thomas T. Martin, Director (
Division of Engineering and i
Technical Inspection
cc:
Mr. H. Voth, Manager Nuclear Operations W. G. Ruzicka, Reactor Project Engineer C. J Konnerth, Health Physicist Dr. R. E. Bollinger, Vice President, Medical Products / Division Public DocumentRoom(PDR) w/o cy of licensee's response 1.ocal Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
State of New York
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UnionCarbideCorp.
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Region I Docket Room (with concurrences)
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NUCLEAR REGULATORY cOMMisslON
) j APR 1981
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$3% P ARE AvtNWR 19404 MIN 0 0F PRUSSI A. PthhSVLV ANI A
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Docket No.70-687
Union Carbide Corporation Mr. James J. McGovern ATTN:
Business Manager, Radiochemicals P. O. Box 324 Tuxedo, New York 10987 Gentlemen:
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Inspection Report No. 70-687/81-02 Subject:
This refers to the routine inspection conducted by M the discussions of our findings held by Mr. P. Bissett with yours on March 16-20, 1981, Konnerth at the conclusion of the inspection.
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Areas examined during this inspection are described in the Of
'i Within and Enforcement inspection Report which is enclosed with this letter these areas, the inspection consisted of sele
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inspector.
Within the scope of this inspection, no items of ncncomplianc L
In accordance with Section 2.790(d) of the NRC's %ules of Title 10, Code of Federal Regulations, documentation of fi l
and accounting procedures for safeguarding l
or financial infonnation within the meaning
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therefore, the enclosed inspection report will not be placed in
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Document Room and will receive limited distribution.
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No reply to this letter is required; however, should you hav
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concerning this inspection, we will be pleased to discuss them
Sincerely, iniox.atiaa in this record wa: dt!!!cd (~
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James H. Joyner Chief, Technical ct e on
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Inspection Branch, Division of Engineering and Technical Inspection Office of Inspection and Enforcement Inspection
Enclosure:
l Report Number 70-687/81-02 f
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Union Carbide Corporation
21 APR 1001
REGION 1 Report No. 70-687/81-02 Docket No. 70-687_
License No. SNM-_639_
Safeguards Group I,
licensce:
Union Carbide Corporation P.O. Box 374 Tuxedo, New York facility Name: Sterling Forest _Research Center _
Inspection At: Tuxedo, New York
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inspection Conducted:
March 16_20 1981
Date of Last Material Control and Accounting Inspection:
April 27, 1979_
Type of Inspection: Unannounced Materia _1__Co,ntrol and Accounting Inspectio_n
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inspectors:
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eq erial Contr and Accountability Section Inspection Summary:Facility Organization, facility Operation, Shipping and Areas inspected:
Receiving, Storage and Internal Control, 10 and Associated LEID, Physical
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Inventory, and Records and Reports.
The inspection involved 28 inspector hours onsite by one regional based inspector and was begun during the regular hours.
Results: The licensee was found to be in compliance with NRC requirements in the scien areas examined during the inspection.
S-F1-81-4 SPages[3 THE INFORMATION _0N_ THIS PAGE IS DEEMED TO BE APPROPRIATE Copylof Copir FOR PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.790_
THE REPORT DETAILS CONTAIN
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Persons Contacted
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'J. McGovern, Business Manager, Radiochemicals
- C, Kcnnerth, Manager, Health, Safety and Environmental Affairs
L. Thelin, Health Physics Supervisor G. Yright, Plating Lab supervisor J. Stuart, Hot Lab Technician
- denotes. lose present at the exit interview.
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Licensee Action on Previous Inspection Findings
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Previous items of noncompliance were not reviewed by the inspector.
J 3.
Exit Interview
The inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on March 20, 1981.
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The inspector summarized the purpose and scope of the inspection
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and the findings.
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4.
Unreselved items there were no unresolved items resulting from this insp(etion.
5.
Indepe:, dent _ inspection Ef fort There was no independent inspection effort during this inspection <
6.
MCM202B Facility Organization No items of noncompliance were 'noted.
The inspection results were attained through discussions with licensee management and review of the licensee's Fundamental Nuclear Material Control llan (FNMCP)
and operating procedures.
The licensee submitted a consolidated and revised FNMC Plan, dated May 15, 1980 which was approved by the Material Control Licensing Branch on January 19, 1981.
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MC85204B Facility Operation No items noncomoliance.were_noted.
The licensee 1 oJ g ation,s,7 Sonsis Lo
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toured UTU$Tfatibnal areas and obs_erv....
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ed the Trcensee's operations
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and activities.
There were no instances observed by the inspector for which the possession, use.or location of special nuclear material (SNM) were contrary to the license.
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8.
MC85208 Shipping and Receiving No items of noncompliance were noted.
The licensee has established and is maintaining a program to assure that all SNM received and
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shipped is accurately accounted for.
Also, the site accountability of ficer (SAO) coordinates ef forts to insure that license (SNM-639)
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possession limits are not exceeded.
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Until recently, all SNM shipments from the facility have consisted of smal) quantities of either nonirradiated weste or irradiated waste containing essentially all-of the uraniem in the targets (resulting from the separation of the desired raoto%otopes from the irradiated targets).
The licensee is now, however, shipping the majority of irradiated waste to Savannah River for recovery.
Two shipments have occurred thus far but no recovery results have been received.
Material transaction reports (Form NRC-741) for all receipts were acknowledged and returned within 10 days.
Material transaction reports for all shipments were prepared as required by the printed instructions for completing Form NRC-741.
9.
MC85210 Storage and Internal Control No items of noncompliance were noted.
The licensee has established a system of storage and internal control which provides for current knowledge of the quantity, identity and location of all SNM within
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the facility, in accordance with the licensee's FNMCP and appli-cable license conditions.
The controls include the master log, subsidiary logs for each material balance area (MBA), and support-
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ing internal transfer documents for transfers between MBAs.
The licensee has the following MBAs:
MBAs Description
Feed Area
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Plating Operation
Reactor
Radiochemistry Area (Hot Cells)
The inspector selected a representative number of postings in the master log and subsidiary logs and verified that they were supported
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by either material transaction reports (Form NRC-741), or internal transfer documents, o applicable.
10.
MC85212 Physical Inventory No items of noncompliance were noted.
The inspector reviewed the results of the licensee's last eleven inventories dating back to April 26, l'49.
These inventories were conducted in accordance with approved physical inventory procedures.
The inspector also determined that, for each inventory, the master log and the MBA logs were reconciled and adjusted to the inventory results within 30 days. The inspector also verified the presence of the licensee's PuBe neutron source, located in MBA-3 and authorized under this license.
11. MC85214 Inventory _ Difference 110) and Its r
Associated Limit of Error (LEID)
No items of noncompliance were identified. The licensee's inven-tory difference calculation was reviewed by the inspector for each of the eleven inventory periods covering February 26, 1979 to
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December 30, 1980.
The ids were accurately determined.
No addi-tional loss mechanisms that could contribute to 10 were identified.
The licensee had been granted relief from calculating the LEID whenever the 10 is less than 150 grams. However, with their submis-sion of a revised FNMCP,as' stated in paragraph 6,and its' sub-sequent approval, the LEID now is to be calculated if the 10 exceeds 300 grams,in accordance with 10 CFR 70.51(e)(5).
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MC85216 Records and Reports No items of noncompliance were identified.
In addition to the review of the master log, subsidiary logs, internal transfer documerits, and inventory records, the inspector also reviewed all material transaction reports (Form NRC-741) and material status reports (Form NRC-742) for the three six-month reporting periods ending September 30, 1979, March 31, 1980,and September 30, 1980.
These were reviewed for timeliness, accuracy, and proper signatures.
The inspector discovered that the licensee had inadvertent'y omitted two Form-141 corrected copy receipts (ZWT-ZWN 187 cel..id 191 cel)
from their September 30, 1980 Form NRC-742 report.
This resulted in a disagreement of 1 gram 'Jranium and (2) grams U-235 between Form NRC-742 and the master 139 The licensee agreed to correct this ommission when the March 21, 1981 Form NRC-742 report is submitted.
(70-687/81-02)
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SSI PAAM AVENUE KING OF PRUS$1 A.PENNSYLV ANI A 19404 gj lg Docket Nos. 50-54 70-687 Union Carbide Corporation ATTN: Mr. James J. McGovern Business Manager, Radiochemicals P. O. Box 324 Tuxedo, New York 10987 Gentlemen:-
Subject:
Combined Inspection Nos. 50-54/81-01 and 70-687/81-03 This refers to the routine unannounced physical protection inspection co'nducted by Mr. R.H. Ladun of this office on May 26-29, 1981 of activities authorized by NRC License Nos. R-81 and SNM-639 and to the discussions of our findings held by Mr. Ladun with Mr. M. Voth of your staff at the conclusion of the inspection.
'
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector..
!
Our inspector also verified the steps you have taken to correct the items
of noncompliance brought to your attention in the enclosure to our. letters dated Novepber 2, 1979, November 14, 1978, and July 29, 1977. We have no further qJestions regardirsg your action at this time.
Withir. the scope of this inspection, no items of noncompliance were observed.
In accordarce with Section 2.790(d) of the NRC's " Rules of Practice," Part
- -
l 2, Title 10, Code of Federal Regulations, documentation of findings of your control and accounting procedures for safeguarding special nuclear materials and your facility security measures for physical protection are deemed to be commercial or financial information within the meaning of 10 CFR 9.5(a)(4)
and shall be subject to disclosure only in accordance with the provisions
!
l i
information in this record was de:e.'cd in accordan:e with thefreedom of Information
Act, extm tions 2AN FOIA-P_dp_ l f
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Union Carbide Corporation
3 1 M6 188l
of 10 CFR 9.12; therefore, the enclosed inspection report will not be placed in the Public Document Room and will receive limited distribution.
Noreplytothisletterisrequired;however,ssV183o'uhaveanyquestions concerning this inspection, we will be pleased to discuss them with you.
Sincerely . _ J -- - El on J. Brunner, Chief, Projects Brahch #1, Division of Resident and Project Inspection -
Enclosure:
Combined Office of Inspection and Enforcement Inspection Report Numbers 50-54/81-01 and 70-687/81-03 (f4ttt.Mw M<N(CEfM M
REGION I== ,
5- ! 63l PARM AVENUS ' KING OF PRUS$1 A, PENNSYLVANI A 19404 ..... Docket Nos. 70-687 50-54 Union Carbide Corporation ATTN: Mr. James J. McGovern Business Manager, Radiochemicals P. O. Box 324 Tuxedo, New York 10987 Gentlemen: Subject: Combined Inspection Nos. 70-687/81-05 and 50-54/81-03 This refers to the routine safeguards inspection conducted by Mr. H. Zibulsky of this office on October 13-16, 1981 of activities authorized by NRC License Nos. SNM-639 and R-81 and to the discussions of our findings held by Mr. Zibulsky with Mr. J. McGovern at the conclusion of the inspection.
Areas examined during this inspection are described in the Office of Inspection and Enforcement Inspection Report which is enclosed with this letter.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, measurements made by the inspector, and observations by the inspector.
Within the scope of this inspection, no items of noncompliance were observed.
In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2, Title 10, Code of Fe: cal Regulations, documentation of findings of your control and accounting procedures for safeguarding special nuclear materials and your facility security measures for physical protection are deemed to be commercial or financial information within the meaning-of 10 CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12; therefore, except for the' report cover sheet, the enclosed inspection report will no_t be placed in the Public Document Room and will receive limited distribution.
No reply to this letter is required; however, should you have any questions concerning this inspection, we will be pleased to discuss' them with you.-
Sincerely, Wormation in this (c Ord was dieted gg r . c=ordance w;th th reedom of Information , Act. exemgo03 --- h omas T. Mar n, Director FOIA___m._-fy -- Division of Engineering and Technical Inspection _ _ _ _ _
, .
Union Carbide Corporation
3 TCO W -
Enclosure:
Combined Office of Inspection and Enforcement Inspection Report Numbers 70-687/81-05 and 50-54/81-03 (e " '-- a ' ^ ' y infe)-~
REGION I== Report Nos. 70-687/81-05 50-54/81-03 Docket Nos. 70-687 License Nos. SNM-639 50-54 R-81 Safeguards Group
Licensee: Union Carbide Corp.
P. O. Box 324 Tuxedo, New York 10987 Sterlin t orest Research Center F Facility Name: Inspection At: Tuxedo, New York i Inspection Conducted: October 13-16, 1981 Date of Last Material Control and Accounting Inspection: July 13-16, 1981 Type of Inspection: Announced Material Control and Accounting Inspector: hM 2 -/-FL H. ZibulskW @ mist date ' ' Approved by: sl244w 2.-/-f A-J. H.
oyn e r', ng Thief, Material date trol and Ac ntability Section, Technical Inspection Branch l Inspection Summary: Inspection on October 13-16, 1981-(Combined Report Nos. 50-54/81-03 and 70-687/81-05) < l l Areas Inspected: Routine, announced inspection of Special Nuclear Material' Control and Accounting including: Measurement and Statistical Controls and Sampling of Raw Fission Waste.
The inspection involved 26.5 inspector-hours onsite by one NRC Regional l Based Inspector.
THE INFORMATION ON THIS PAGE IS DEEMED TO BE APPROPRIATE S-F1-82-06 $pyf ofgCop-Co FOR PUBLIC DISCLOSURE PURSUANT TO 10 CFR 2.790 Pages THE REPORT DETAILS CONTAIN ,
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- .. -- ,,.. - - - ^ -- .. . .. . .. ..,. .. .... .. ., m p - .. , . , , t i Results: The licensee was found to be in compliance with NRC requirements-in the areas examined.
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. . DETAILS 1.
Persons Contacted
- J. McGovern, Business Manager, Radiochemicals
- F. Morse, Manager, Radiochemical Process Engineer
- D. Grogan, Manager, Radiochemical Production
' W. Leinheiser, Supervisor, Quality Control The inspector also interviewed other licensee employees associated with measurements and plant operations.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings Previous items of noncompliance were not reviewed by the inspector.
3.
Exit Interview . The inspector met with the licensee representatives (denoted in paragraph 1) at the. conclusion of the inspection on October 16, 1981.
The inspector summarized the scope and findings of the inspection.
4.
MC 927138 - Independent Inspection Effort No items of noncompliance were noted.
Ouring a previous material control and accounting inspection (70-687/ ,_ l 81-04), the inspectors determined that an internal measurement control l: audit dated _ January 31, 1981, identified areas in the measurement control program that were in.need of improvement.
During the current inspection, the inspectors reviewed the status of licensee followup of the internal audit.
An internal licensee memo dated September 16, 1981, from M. E. Bordoni to J. J. McGovern, discussed the status of these improvements.
The inspectors will perform a detailed followup of the licensee's action during a. future inspection.
? 5.
MC 852068 - Measurement and Statistical Controls a.
License SNM-639 No items of noncompliance were noted.
The iteensee analyzed the uranium content of standards that were prepared with normal uranium and certified by the New Brunswick Laboratory. One analyst, using the Gravimetric Davies and Gray titration procedure, performed the analyses.
During inspection 70-687/81-04, the standards analyzed by the licensee were not within the normal range of the material routinely analyzed.
The
, . -- -- 7 , ,, w. - ( .- - '
. , concentrations of the new standards were within the licensee's normal operational range.
The three uranyl nitrate standard solutions were as follows:
- M = 0.004983 gu/mi Y
- N = 0.007111 gu/ml
- P = 0.008989 gu/mi The three uranyl nitrate standard solutions had mean relative biases of -0.07%, -0.20%, and -0.92%.
Only the bias of the last-standard was statistically significant at the 2-sigma confidence level.
The results of these standards identified areas in the licensee's procedure where some errors may be reduced.
The licensee will change the type of platinum and calomel electrodes used to provide a more immediate response.
Also, the Itcensee will weigh their samples and perform a specific gravity determination-on the solution in lieu of aliquoting the solutions.
The licensee's procedure, subject to some minor changes, is now " state of the art", and will be used to analyze total uranium of irradiated fuel in a hot cell, b.
License R-81 On December 18, 1979, the licensee submitted a procedure relating to the Uranium Waste Recovery Process to the NRC Advanced Fuel' and Spent Fuel Licensing Branch.
The plan was approved on June 27, 1980 after an April 2, 1980 revision.
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for analysis.
Licensee samples will go to Oak Ridge National Laboratory for analysis.
The analyses requested will be: . (1) Total Uranium (2) Total Plutonium (3) Isotopic distribution of both Uranium and plutonium .' (4) Strontium-90 (5) Cesium-137 (6) Gamma scan L q - i e , - .
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atoloN 1 5* H1 PARK AV NUE j t, xiuo o, enunia.esuumvania i,*a 9 JUL 1982 ..... ' Docket Nos. 70-687 50-54 , ! ' Union Carbide Corporation ATTN: Mr. James J. McGovern Bustness Manager, Radiochemicals P. O. Box 324 _' Tuxedo, New York 10987 Gentlemen: Subject: Inspection Nos. 70-687/82-04; 50-54/82-02 This refers to the routine safeguards inspection conducted by Mr. H. Zibulsky of this office on May 10-14, 1982 of activities authorized by NRC License Nos.
SNM-639 and R-81'and to the discussions of our findings held by Mr. Zibulsky at the con,clusion of the inspection.
Areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
Our inspector also verified the steps you have taken to correct the violation " brought to your attention in the enclosure to our letter dated November 10, 1981.
We have no further questions regarding your action at this time.
Within the scope of this inspection, no violations were observed.
In ac:ordance with Section 2.790(d) of the-NRC's " Rules of Practice," Part 2, i Title 10, Code of Federal Regulations, documentation of findings of your control and accounting procedures for safeguarding special nuclear materials are deemed to be commercial or financial information within the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12; therefore, except for the report cover sheet, the enclosed inspection report will not be placed in the Public Document Room and-will receive limited distribution.
No reply to this' letter is required. Your cooperation with us in this matter is appreciated.
Sincerely, h the Frec o o n omaW M W cc y Y t,ct, excm;4 ions T omas T. Martin, frector - - - ep., &f@. -.. - ivision of Engineering and Technical . , Programs
Enclosure:
Combined NRC Region I Inspection Report Number 70-687/82-04 M 1 &and 50-54/82-02 ff ' Q . . -- - - - -- - .
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_.. _.. _. ,- , ,. V'nton Carbide Corporation
9 JUI.1982
REGION I== o,% * 631 PARK AVENUE KING OF PRUS$1A. PENNSYLVANIA 19400 1 ; C.]I g
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Docket No. 70-687 Union Carbide Corporation ATTN: Mr. James J. McGovern Business Manager, Radiochemicals , P. O. Box 324 Tuxedo, New York 10987 Gentlemen: Subject: Inspectio?. Report No. 70-687/82-06 ' This refers to the routine safeguards inspection conducted by Mr. H. Zibulsky of this office on September 7-10, 1982 of activities authorized by NRC License No. SNM-639 and to the' discussions of our findings held by Mr. Zibulsky with-
you at the conclusion of the inspection.
Areas examined during-this inspection are desc"ibed in the NRC Region I Inspection Report which is enclosed with this letter.
Within these areas, the inspection consisted of selective examinations of procedures and represent-ative records, interviews with personnel, measurements made by the inspector, and observations by the inspector.
Within the scope of this inspection, no violations were observed.
In accordance with.Section 2.790(d) of the NRC's " Rules of Practice," Part 2, Title-10, Code of Federal Regulations, documentation of findings of'your control and accounting procedures for safeguarding special nuclear materials are deemed to be commercial or financial information within the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12; therefore, except for the report' cover sheet, the enclosed inspection report will not be placed in the Public Document Room and will receive limited distribution.
No reply to'this letter is required.
Your cooperation with us in this matter is appreciated.
Sincerely, Information in this record was de'eted l in accordance with the eedom of Information , Act, mm s - M o as T. Martl 01 rect F01A - ision of Engineering and Technical -- Programs
Enclosure:
NRC Region I Inspection Report No. 70-687/82-06 (C5nt:inc % informaf % _ .
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Union' Carbide Corporation
i CCT 1982 - , ,
REGION I== Report Nos.
70-687/85-03 and 50-54/85-02 Docket Nos.
70-687 License Nos.
SNM-639 50-54 R-81 Licensee: Union Carbide Corporation P.O. Box 324 Tuxedo, New York 10987 Facility Name: Sterling Forest Research Center Inspection At: Tuxedo, New York 10987 Inspection Conducted: April 24 - 26, 1985 Date of Last Physical Security Inspection: March 30 - 31, 1982 Type of Inspection: Routi ; ynannounced Physical Protection ' M 7 - / #)-- gJ' Inspector: __'liam J.
.addeyf/ ff date ' , ' Physical otect%n IMpector M e-Jg-#[ Approved by: __ _ _ _. Keimig Chief date R.
afeguards ction, uclear Materials Safety and Safeguards Branch Inspection Summary: Routine Physical Protection Inspection (Combined Report Nos. 70-687/85-03 and 50-54/85-02).
Areas Inspected: General Requirements for Special Nuclear Material of Moderate Strategic Significance at fixed sites including: Security Plan; Protection of Special Nuclear Material (SNM); Security Organization; Records and Reports; Alarm Systems'; and Communications.
The inspection involved 18 hours onsite by a region based inspector.
. Results: The licenset was in compliance with NRC requirements in .the areas examtaed.
SGS-RI-85-29 Copy I_of 6 Copies 4 Pages wFn~ _ .
- . DETAILS . 1.
Key Persons Contacted
- J. McGovern, Business Manager, Radiochemicals
- W. Ruzicka, Reactor Supervisor
- R. Hubbard, Manager, Maintenance and Engineering.
C. Konnerth, Manager, Health, Safety and Environmental Affairs
- J. Baird, Senior Reactor Operator G. Wright, Production Control Supervisor *
S. Lupinski, Chief, Reactor Operator J. Kratochwil, Utilities Supervisor
- denotes tho,se present at exit interview.
2.
30703 - Exit Interview } The inspector me6 with licensee representatives (denoted in Paragraph-1) at the conclusion of the inspection on April 26, 1985,.and summarized the scope and findings of the inspection. At no time during the inspection i was written material provided to the licensee by the inspection.
3.
81480 - General Requirements for Special Nuclear Material of Moderate Strategic Significance at Fixed Sites a.
Security _ Plan: The current site security plan was approved.by 'NRC's Office of Nuclear Reactor Regulation letter dated October 28, '1984 and by the Of fice of Nuclear Materials Safety and Safeguards letter dated May 26, 1983.
The plan'provides for the protection of
SNM in storage and/or in use in contiguous facilities under NRC Reactor License No. R-81 and Hot Laboratory SNM License No. SNM-639, and for SNM in-transit.
The plan addresses SNM of both of Low and.
Moderate Strategic Significance and implements the performance objectives of 10 CFR 73.67 and takes credit for " exempt material" categories of SNM provided for by 10 CFR 73.67(b)(1).
The plan
. limits the total quantity of non-exempt SNM possessed under both licenses to less than.a formula quantity.
The inspector confirmed, t by review and walk-through, that the plan and implementing procedures ! meet the: requirements of-10 CFR 73.67.
b.
Protection of SNM: (C0FI) The inspector confirmed that the licensee protects SNM in authorized F ~~ ~ % ~ ~ ~ ~ r . u w- -~--,.- ~__.
. _.
, C0FI - Commercial or Financial Information that is exempt from public disclosure in accordance with 10 CFR 9.5(a)(4).
i , .
p ,. - -. _ - -. _ - -. - - - _.___ _. - -. _ _ _ - , , The 1nspector toured the facilities and concluded that the licensee was maintaining the non-exempt SNM inventory level below the "less than 5 kg." limit as defined in paragraphs 3A and 8 of the approved Security Plan, Non-exempt SNM on hand, in the form of encapsulated-fuel and' feed material, was less than 2 kg. on April 25, 1985.
(COFI) _gFI)These,c3rityorganizationincludes (
- SecurityOrganization
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- (C0FI) The inspector
' confirmed that all personnel involved were familiar with their , specific duties and responsibilities as required by the security plan, d.
Records and Reports: The inspector reviewed the licensee's SNM inventory results of March 19, 1985 and April 12, 1995; Access Con-trol futhorization Listing dated April 12, 1985; Alarm Test Records for January - April,1985 and a Security Program Audit accomplished on January 18, 1984 by the Manager, Health, Safety and Environmental' ' Affairs and dated,.denva_ry 24, 1984.
QF.D The audit resulted in = the~~ replacementofT _ T ' ~ - ~ ~ ~ { ~i heJ eriod Ja,nu,a,,ry_- A>rilf5 cili'tykey'co I . ~ ~~ - , a Tor t 25. 1995. F l _ .
p ere l _ast changec^on fT,Y., m _ _ - w >'T ' kr3 II, , coincidental'with the favorable termination of an employee, Personnel access records for the M w d lgwere reviewed for the periods February and April,~1985.
(C0FI) Al records i and reports were in conformance with the Security Plan, e,' Alarm Systems: (C0FI) h ' ' ~ ' ~ ~ ~'T _ ~.- m. m .,,.. 7 - <! m.m % uma s,, .._.. m., c m . s s - m m. m. 2 Successful tests of theEweA><dalarm were~ demonstrated on April ~ ~ 25, 1985. The inspector ~folind the alarm system to bo in conformance with the' Security Plan. Management is curr onsider improvement to the alarm stem whic oug not u rement, th mprovement wou ance a arm monitoring and response.
(C0FI)
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Communications: (C0FI) " N ' . - ~ - 7 r,g.the crimary means of communication.
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.u g ~ ... i ,_ cations.b.etweek ' , telepflone numbers were available to bot % ' ~ ' ~'"] The inspector confirmed the validity ot7 net g numbers uy t.eiephone contact with the dispatchers at both locations on April 25, 1985.
(C0FI) The inspector found communications capa-bilities in conformance with the approved-security plan.
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o , - - Doctet Nos: 50-54 70-687 ^ Cintichem, Inc.
ATTN: Mr. James J. McGovern Plant Manager P. O. Box 816 Tuxedo, New York 10987 Gentlemen: Subject: Combined Inspection Nos. $0-54/86-01 and 70-687/86-02 This refers to the routine safeguards inspection conducted by Mr. A. Della Ratta of this of fice on February 10-14, 1986 of activities authorized by NRC License Nos. R-81 and SNM-639, and to the discussions of our findings held by Mr. Della Ratta with yourself and members of your staf f at the, conclusion of the inspection.
Areas examined during this inspection are described in the NRC Region ! Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and repre-sentative records, interviews with personnel, and observations by the inspector.
Our inspector also verified the steps you had taken to correct Violation 8 brought to your attention in a letter dated January 17, 1985. We have no further questions regarding the steps you took to correct that violation. We did not review your correcthe actions for Llation A during this inspection, g Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as a , ! Set forth.in the Notices of Violation, enclosed herewith as Appendices A and B.
X3 These violations have been categorized by severity level in accordance with the jy revised NRC Enforcement Policy (10 CFR 2. Appendix C) published in the Federal Register Notice (49 FR 8583) dated March 8,1984. You are required to respond b I to this letter and in preparing your response, you should follow the instruc-lY tions in Appehdices A and B.
- g Nb Appendix B to this letter and Paragraphs 8 a. and 8.b. in the enclosed inspec-
' ,Nj tion repo.t contain details of your security program that have been detonained -..e . to be exempt from public disclosure in accordance with 10 CFR 73.21, Safeguards g W u.
Information. Therefore, these will not be placed in the NRC Public Document Og ' Room and will receive limited distribution. This letter, Appendix A and the iii l $ g.
emainder of Appendix B and the inspection report will be placed in the Public g . hg g Document Room, in accordance with 10 CFR 2.790(a).
\\4
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.' I ' Cintichen, Inc.
APR 141N6 ' ' . The responses directed by this letter and the' accompanying Notices are not i subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Your cooperation with us in this matter is appreciated.
Sincerely, j Ortainal S1 # 878 Jc :sH.Joruu Thomas T. Martin, Director Division of Radiation Safety S and Safeguards i
Enclosures:
1. Appendix A, Notice of Violation i 2. Appendix B. Notice of Violation +th) ' 3. Combined NRC Region ! Inspection Report Nos. 50-54/86-01 and 70-687/86-02 i (Paragraphs 9a. and 8.b. of the combined inspection report and portions ! Loi Appwnnr1PeerhWM9%i es Wwmats.
(Zi7
REGION I== Report Nos.
50-54/86-01 70!Tf77EFD} Dociet Nos.
50-54 ~ 70-687 License Nos.
R-81 SNM-619 ._ Safeguards Group: _I Licensee: Cintichem Inc.
~i N~'Boi 124 tuxedo,New York 10987 Facility Name: $terling Forest Research Center Inspection At: Tuxedo., New Yort inspection Conducted: Februa;j_10-14 1986
Type of Inspection.
Material Control and Accounting, and Physical Security Date of last Material Control and Accounting Inspection: August 19-23, 1985 Date of last Physical Security inspection: April 24-26; 1985 Inspector:
d 3-g-/$ K. D W a Ratre, Saf 2ards Auditor date ' ' . . . f.g 7-M Approved by: . _ R. Keimi, Ch , Safeguards Section date Nuclear M eri.
Safety and Safeguards Branch, SS Inspection Summary: Inspection on February ~10-14, 1986 (Combined Report Nos. 50-54/86-01 and'70 Ts7786-0}}. Areas Inspected: Nuclear material control and accounting, and physical security, including: facility organization and management controls; facility operations and internal controls; reactor material control and accounting; and physical protection measures for special nuclear material of moderate strategic signi-fiCanCG.
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, Results: Five violations were identified: failure to complete internal transaction reports and the MBA logbook. (paragraph 6); failure to tamper-safe 10 waste barrels in accordance with written procedures (paragraph 6); failure to use standard waste barrels that were representative of the full range of the normal process waste barrels being radiometrically analyzed (paragraph 6); f ailure to notify the Commission, within two months, of changes made to the NRC-approved physical security plan (paragraph 8); and failure to maintain records to show compliance with certain requirements as specified in Sec-tions 3.6 and Section 4.4 of the Physical Security Plan (paragraph 8).
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! . . - > , DETAILS 1.
Key Persons Contacted
- J. McGovern, Plant Manager
,
- C Konnerth, Manager Site Operations
-
- W. Ruzicka, Manager, Nuclear Operations
- L. Thelin, Radiation Safety Officer J. Ditton, Health Physics Supervisor R. Strack, Reactor Supervisor S. Lupinski, Chief Reactor Operator J. Kratochwil, Supervisor. Site Utilities The inspector also interviewed other licensee employees associated with plant operations, nuclear material control, and physical security.
- present at exit interview
' 2.
30703 - Exit Interview The inspector met with the licensee representatives indicated in para-graph 1 at the conclusion of the inspection on February 14, 1986, and sumarized the scope and findings of the inspection.
l At no time during this inspection was written material provided to the licensee by the inspector.
3.
92702-Licensee Action on Previously Identified Enforcement item (Closed) Violation (70-687/84-0502): Failure to conduct the annual . management audit in accordance with the requirement of Section 8.2 of the l fundamental nuclear material control plan (FNMCP). The inspector's review of the last management audit, dated October 24, 1985, detennined that the audit was in accordance with the requirements of the FNMCP in that all functions were audited and the audit was conducted by an individual who , was independent of nuclear material control management, measurement or utilization.
4.
92704-Fo110wup on Headquarters Requests The inspector reviewed, and discussed with the licensee, the actions taken with regard to the NRC Comission Order of September 27, 1985, that required non-power reactor licensees to show cause why they)should not be ' requiredtoreducetheamountofhighenricheduranium(HEU onsite to that amount necessary to maintain a nonnel schedule of operations. Speci-fically, this Order pennits the licensees to keep no more than enough fuel to (1) replace one failed element for each different type of element in the core, and (2) replace the amount of fuel depleted during a 90-day period of nonnal operations.
l - _. .--
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' . . The licensee's MTR research reactor operates on a 95% duty cycle at a p.ower level of five megawatts which corresponds to a fuel usage of 28 standard elements per year and is maintaining an inventory of not more than seven unirradiated standard fuel element assemblies.
The licensee's unirradiated fuel inventory, as of February 14, 1986, was 2 standard elements and 5 control elements, which is equal to 4.5 standard elements.
(A control element has one half the amount of HEU of a standard element and, therefore, is counted as one half of a standard element, for inven-tory purposes.)
5.
85203 - Facility Organization and Management Controls The inspector discussed with management and reviewed the licensee's annual audit of the Fundamental Nuclear Material Control Plan (FNMCP) which was conducted during October, 1985.
The results of this audit were documented on October 24, 1985.
Several minor deficiencies were noted, and some recorsnendations were made to management for improvements. Management took corrective actions on the deficiencies, and responded to the recomendations in a timely manner.
6.
85205 - Facility Operation and Internal Controls - This portion of the inspection included observations, discussions with licensee personnel, a review of the licensee's records and NRC-approved FNMCP.
, ' The inspector identified that 319 grams of U 235 had been transferred from MBA 1 to MBA 2 and then returned to MBA 1 without the completion of an internal transaction report and recording the transfers in the MBA 1 and MBA 2 logbooks. The licensee stated that they did not believe the use of transaction reports was necessary, since it had been a standard practice to use a portion of the solution laboratory (MBA 2) as a part of MBA 1 when processing current receipts of feed material from a solid state to a solution. Also, the licensee stated that the MBA 1 custodian / alternate never releases possession of the material while it is being processed in MBA 2.
However, the above technique for handling this material is not as described in the NRC-approved FWICP. This technique was discussed with R. Jackson, NRC NMSS, on February 13, 1985 and February 19,1985, who con-curred with the inspector that thit, handing technique is not in accord-ance with the NRC-approved FNMCP. This was identified as a violation of Section7.2oftheNRCapprovedFNMCP(70-687/86-02-01) which requires the transaction reports and MBA logbooks to be completed promptly, at the time of transfer.
The inspector's review of the licensee's records identified that the ten barrels of waste material had been radiometrically analyzed on January 15, 1986, but had not been tamper-safed immediately after the completion of the analyses.
The ten barrels of waste were tamper-safed on January 17,1986.
This was identified as a violation of 10 CFR 70.51 l _ _.. _ _ _ _ _.
.
e
- i I (e)(1)(1) and paragrpah 2.b., of the licensee's tamper safing procedure titled, " Security Seals for the Protection and Control of Special Nuclear Material"(70-687/8602-02) which requires the temper-safe seal to be applied immediately af ter the samples and data to identify and measure the contents are taken.
in conjunction with the radiometric analyses of the ten waste barrels, the inspector identified that the licensee failed to use Standard Waste Barrels that had been calibrated and that were representative of the full range of the waste barrels being analyzed.
The high concentration of the., Standard Waste Barrei used for the raciometric analysis was 13.99 grams U-235.
However, three waste barrels that were analyzed contained 15.01 grams U-235, 19.58 grams U-235, al.d 19.25 grams U-235.
This was identi-fied as a violation of Section 4.2.1.4.f. of the FhMCP (70-687/86 02-03).
7.
85103 - Material Control and Accounting a.
Inventory The inspector performed an inventory verification, on February 12, 1986, which consisted of a piece count of the fuel elements and fission counters in the spent fuel pool and storage area vaults, and a com-parison of the fuel location history sheets to the reactor core and storage area schematics.
No discrepancies were noted.
The licensee had conducted physical inventories as required by 10 CFR 70.51 (d).
The licensee's last physical inventory was performed October 2, 1985, b.
Records and Reports The inspector reviewed the licensee's records, source data, and Material Balance Reports.(DOE /NRC Form-742) submitted during the period October 1,194-Septea$er 30, 1985. Total uranium and U-235 fission and transmutation records were also reviewed.
No discrepan-cies were noted.
8.
81480 - General Physical Security Requirements for SNM of Moderate Strategic Significance The inspector reviewed the licensee's protection of special nuclear material of moderate strategic significance, for confonnance to the NRC-approved physical security plan, by examining barriers and access controls, procedures, and by observations of a licensee test of alann system features.
Implementation of the physical security plan was found to meet the general perfonnance requirements and objectives of the govern-ing regulations except as follows: ,
_._. _ _ _ __ _ _ _ _ - ~- _ _ _ _.. _ _ _ __ _ _ _ __.___ ' .. l' ' 4.
Security Plan Changes l The inspector's review of the licensee's NRC approved physical security plan identified that the licensee had made changes on
January 31, 1985, and November 1, 1985, but had not submitted these-changes to the NRC within two months after the changes were made, as required, by License Condition 9.1 of Safe 12,1985,and10CFR70.32(3)guardsAmendmentSG-1,
dated April Examples of the changes . made are as follows: 1.
(SGI) The Receptionist's Office located adjacent to the main entrance door (nonnal ace.ess point) in Building 2, was no longer i being used as a receptionist's office since the retirement of ' the receptionist on January 31, 1985.
(SGI) l i 2.
(SGI) The licensee has no immediate plans to replace the retired receptionist and who had, among other duties, the responsibility of caring for all visitors' packages. carried into ~~ the controlled access area that had not beenF ~ (SGl) 3.
Job titles of certain positions as described on page 3.4 and ' l page 4.1' of the Physicial Security Plan had been changed on l November 1, 1985 as indicated below: l From
Plant Manager, Radiochemicals Plant Manager Nuclear Facility Services Engineer Hot Lab Operations Supervisor l Manager, Engineering and Maintenance Manager Engineering and Technology Sales Failure to submit these changes to the NRC within two months was iden- , tifiedasaviolation(70-1100/86-02-04,and50-54/86-01-01), "- b.
Procedure Policy (SGI) Section 3.6 ' Search Policy," of the licensee's physical security plan, states, in part, that searches of packages and cles leaving ~the controlled access area will occur at a ratel,vehi- ~~' ~' . {~were established Ty.The inspector's review identified that n3 mea 6st I being carried out.
($GI) L L (SGI) Additionally, the inspector identified to the licensee that Section 4.4, " Watchman," of the licensee's NRC-approved physical security plan, states, in part, Qat the watchman tour of the con-trolled access area.is ' complete & - ^ andthat[~ jt ToHtfo'ns throughout"ThT] ~ controlled ~ access area.
Me~tTuY covers the essential reactor > - -- -
'. , ' s egu.1,pmen,t,wh,ich_i,ni udtsf ~ ' ' l ( j in the unlikely eventle warchsih~are unable to complete a scheduled tour of the control access area, an authorized individual, designated by the watchmen, will be The designated individual,,.ggtified in advance to.per,fom the tour.
However, the inspector's review found that watchmen had designat the reactor contral room personnel to perfom a scheduled tour on January 1,1986, Janucry 5,1986, and February 11, 1986, that the watchmen were unable to complete but there were no records indi- .cating that the_ tours.had been CompletedI or tttati - i Failure to maintain records in order to show compliance with Sections 3.6 and 4.4 of the physical NRC-approved physical security plan was identified as a violation (70-687/86-02-05, and 50-54/e6-01-02).
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l T., j,... _._--. -- ------- ^~ - T i ..i Docket Nos: 50-54; 70-687 ~4 . Cintichen, Inc.
' ATTN: Mr. James J. McGovern x o e rk 0987 Gentlemen: i Subject: Inspection Report 50-54/86-02; 70-687/86-03 This refers to the special inspection conducted by Mr. D. Haverkamp of this office on August 6-8, 1986 of activities authorized by NRC License Nos. R-81 and SNM-639 ! f and to the discussions of our findings held by Mr. Haverkamp with yourself and other members of your staff at the conclusion of the/ inspection.
This also refers to subsequent telephone conversations with Mr. W. Ruzicka of your staff and with , t i several of your licensed operators on November 14, 16, and 17, 1986, and to our telephone conversation on November 25, 1986.
Areas examined during this inspection are described in the NRC Region I Inspection ' Report which is enclosed with this letter.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, in-terviews with personnel, and observations by the inspector.
Based on the results of this inspection, it appears that certain of your activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A.
These violations have been ,3 categorized by severity level in accordance with the " General Statement of Policy
and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (Enforcement
- &
Policy).
You are required to respond to this letter and in preparing your response, Fi '5 you should follow the instructions in Appendix A.
.g is 'g !! The first violation described in Appendix A (Item A) concerns inadequate control ,3 of access to the fa.ility when NRC inspectors were afforded unescorted access g h.,7 without proper authorization.
Since similar incidents involving your employees N occurred just prior to this inspection we are concerned that corrective actions-2 , "-s
were not offective in preventing recurr,ence of the violation.
Therefore, in your D 12 I response to Appendix A, you should particularly address those measures taken to prevent recurrence of this violation.
. @EB.
The second violation described in Appendix A (Item B) concerned failure to properly aM 55E*@ establish reactor building confinement prior to a reactor startup on October 8, - 1984.
This appears to be an isolated incident; however, we are concerned that your staff did not understand fully the requirements for establishing confinement prior to reactor operation.
, Two other concerns with potential to impact safety were identified during this in-spection. The first is your past practice of administrating licensed operator re-g q Q g yd g as take-home exams on an honor-system basis. Our in-
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' , -. # -- - a (7;[.W.i, 1.r. M g [.fgg ;(*y; [ ., itial evaluation is that this practice is unacceptable for future administration ) of requalification exams This matter has been referred to Mr. Robert Keller, Chief, Operator Licensin Section, NRC Region I, for formal evaluation.
If you have any questions in th s regard, you may contact Mr. Keller at (215) 337-5211.
The second concern pertains to a reactor startup conducted on March 7, 1986, with reactor pool visibility substantially degraded.
Details of that incident are de-scribed in Paragraph 2.3 of the enclosed inspection report.
As discussed during our telephone conversation on Ne, ember 25, 1986, we request that you submit within 30 days a written report whkn addresses: (1) confirmation of our understanding of the matter as described in the enclosed inspection report, (2) your justifica-tion for permitting reactor operation with a nonvisible core including an evalu-ation of the safety considerations, and (3) the steps you have taken to avoid re-currence.
Sections of the enclosed Appendix A contain details of your security program that have been determined to be exempt from public disclosure in accordance with 10 CFR 73.21, Safeguards Information.
The sections so identified will not be placed in the NRC Public Document Room and will receive limited distribution.
The inspection report and any remaining portions of Appendix A will be placed in the Public Docu-ment Room, in accordance with 10 CFR 2.790(a).
The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Your cooperation with us in this matter is appreciated.
Sincerely, Original Sisaed By Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Reactor Projects
Enclosures:
1.
Appendix A, Notice of Violation * 2.
Combined NRC Region ! Inspection Report 50-54/96-02; 70-687/86-03 <
REGION I== 50-54/86-02 Report Nos.
70-687/86-03 50-54 Docket Nos.
70-687 R-81 License Nos.
SNM-639 Licensee: Cintichem, Inc.
P. O. Box 324 Tuxedo, New York 10987 Facility Name: Sterling Forest Research Reactor / Hot Laboratory Int.pection At: Tuxedo, New York Inspection Conducted: August 6-8, 1986
Inspectors: D. Haverkamp, Project Engineer J. Roth, Frojec Engineer Approved by: !M If /2f/86 T. C. Elsasser, Chief, Reptor Projects Section 3C Date Inspection Summary: Inspection on August 6-8, 1986 (Report Nos. 50-54/86-02: 70-687/86-03) Areas Inspected: Special, unannounced inspection of alleged concerns regarding management followup to violations, and routine inspection of licensee activities including facility operations and Nuclear Safeguards Committee reviews.
Results: Two violations concerning failure to properly establish reactor building , ! confinement prior to startup of.the reactor (Section 2.1) and inadequate control l of access to the facility (Section 2.4) were identified during the course of-this inspection.
The alleged concerns regarding inadequate management followup to ' violations of Technical Specifications and procedures generally were not substan-tiated, with the exception of management followup to previous licensee-identified , l facility access violations.
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. . I DETAll.S l 1.0 Persons Contacted During the course of this inspection, the following personnel were contacted or interviewed: J. Baird Senior Reactor Operator ' O. Cagney, Senior Reactor Operator
- C. Konnerth, Manager, Site Operations I. Kroun, Senior Reactor Operator
- J. McGovern, Plant Manager 1. Nach, Reactor Operator (Trainee)
K. Morales, Senior Reactor Operator
- W. Ruzicka, Nuclear Operations Manager R. Saxtan, Reactor Operator L, TN1an, Radiation Safety Officer
- Pcesent at the exit interview on August 8, 1986, 2.0 Alleged Concerns Regarding Management Followup to Violations In early July 1986, an anonymous individual called the NRC Headquarters Duty Of ficer who then bridged the call to the NRC Region 1 Outy Officer.
The caller identified several alleged concerns regarding various past practices at the Cintichem reactor facility that he considered were indicative that violations of Technical Specifications and procedures were overlooked by man-agement.
A few days later, as agreed during the initial telephone conversa-l tion, the alleger called again to provide amplifying information regarding the initial concerns as well as to discuss some additional concerns.
Follow-ing these initial contacts, the alleger called during July and August 1986 to determine the NRC's plans in reviewing the concerns; however, no additional concerns or amplifying information were identified during the subsequent calls.
A total of nine separate concerns of alleged inadequate management followup or questionable practices were identified by the anonymous caller.
During this inspection, interviews were conducted with a representative number of , I licensed reactor operators and senior reactor operators to obtain additional , or clarifying information regarding the alleged concerns.
The inspectors also interviewed plant operations department supervisory personnel regarding these matters and reviewed applicable Technical Specifications and procedural re-quirements.
Each of the concerns, as initially alleged and subsequently clarified, and the inspectors' findings regarding the concerns are discussed in the sections - that follow.
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' . 2.1 Concern No.1 - Reactor Startup Without Containment i Summary of Allegation About six months ago (late 1985), the reactor was shut down to repair an air supply solenoid valve associated with containment ventilation.
The reactor was started up with the repair unfinished and the air supply valve open, but with no containment.
A senior reactor operator brought the matter to the attention of the nuclear operations manager, who the whole thing.
All licensed people knew about this incident and are surprised that no one did anything about it.
Clarification of Allegation Based on discussions with licensed operators and nuclear operations de-partment supervisors, the inspector determined that on October 8 1984,
while the reactor was operating, a boiler house air compressor ma,lfunc-tion occurred.
The reactor was shut down and the air compressor problem corrected.
However, in the process of restoring normal ventilation, a solenoid f allure was detected in one of the two (hot or cold) air supply , dampers.
The failure caused the damper to close which resulted in a large negative pressure, possibly as high as one inch, in the reactor building.
In order to gain control of the building pressure differential and to reduce the negative pressure to normal values, it was necessary , to increase air flow into the building.
With the unaffected (hot or cold) air supply damper open, the inner sliding door of the double air lock doors between the reactor building and the hot laboratory was partially opened.
The outer door was physically closed but the 0-ring gasket was not inflated.
In that condition the increased' air in-leakage reduced the building pressure to a balanced, smaller negative pressure.
With the partial normal air supply to the reactor building and the abnor-mal augmented air supply via air lock door in-leakage, a reactor startup commenced and power was held at 0.01-0.1% of rated power.
About 15 minutes later the air supply damper repairs were completed.
The damper was reopened, the outer door gasket was inflated, and the reactor startup > was continued i.nto the power range.
The inspector noted that this ab-normal operating condition during the reactor startup was not logged.
In fact, one of the operators believed he would have been in trouble if this was logged, as the chief reactor operator was at the console.
As a result of not logging or otherwise communicating the abnormal startup conditions, the nuclear operations manager did not become aware of the problems that had occurred until cne to two weeks af ter the event.
He assessed the Technical Specifications requirements and nuclear safety considerations, determined that no violations or adverse safety condi-tions occurred, and discussed the event with the chief reactor operator.
, l In their view, although the 0-ring gasket was not inflated, the door was in its closed position, which thus complied with the Technical Specifi-l cations for confinement.
Furthermore, the negative pressure was being ' maintained.
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. , , Findinas The inspector considered that the alleged event and subsequent abnormal reactor startup was substantiated, although the problem reportedly oc-curred in late 1984, not in 1985.
Based on the inspector's review of this event and Technical Specification " Confinement," although a negative press (TS) 3.5.3, requirements for ure in the reactor building was present during the startup, the airlock door clearly was not " closed" when its 0-ring gasket was not inflated.
In the event of exhaust fan or damper malfunction, thera would have been no assurance of maintaining building leakage inward under accident conditions.
Therefore, conducting a reactor startup without at least one door of the double airlock doors fully closed (with its gasket inflated) is considered a violation of TS 3.5.3 (54/86 02-01).
Furthermore, the abnormal conditions were not identified in the operator's log and there was no feedback to operators of the nuclear operations manager's review of the event.
This matter is discussed further in Paragraph 2.10.
2.2 Concern No. 2 - Violation of Startup Procedure Summary of Alleaation During the second or third week in May 1986, the project engineer was on the console performing shift duty to maintain his license.
In pre-paration for changing fission product molybdenum (FPM) irradiation tar-gets, he ran the rods in ton far and inadvertently shut down the reactor.
' Targets were then changed.
Subsequently, he did a startup-to 100% of rated power with ne restart checks, no heat balance at 50% of rated power, l ! and he ignored procedures.
When informed, the manager - nuclear opera-tions said, "We'll call it a long dip." The caller alleged that the above actions violated the procedure, if not the Technical Specifications.
Clarification of Allegation Based on discussions with licensed operators, the inspector determined that the events occurred, essentially as described above, on May 1, 1986 when the nuclear project engineer, under supervision by the assistant chief reactor operator, ran the rods in to the seat.
He reportedly had used the " normal" switch vice the manual run-in method, The nuclear operations manager was informed of the abnormal reactor power i reduction for changing FPM targets about one week or more af ter its oc-He then discussed the matter with the nuclear project engineer currence.
and operations management personnel including the assistant chief reactor operator, the chief reactor operator and the reactor supervisor.
He did not consider the occurrence to be a major incident.
The matter was treated as more of a political rather than a technical concern, due to the percept Ln of some operators that a " double standard" existed for disciplinary actions when operating errors were caused by licensed engi- , neers or operations supervisors as compared with mistakes made by non- -y w g p,,--
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., . supervisory licensed operators.
The plant operations manager had coa-mitted to operators to discuss the recults of the operations management review of this event, but that discussion had not yet been co. ducted.
Findings The inspector reviewed Technical Specifications requirements and applic-able reactor operating procedures for sample (target) changes, reactor startup, and reactor restart checks.
Althcugh the rods were inserted - to the seat, rather than only partially inserted as during other routine ' target changes, the reactor technically was still in operation, albeit subcritical, comparable to the power level of a normal partial insertion.
On the other hand, more negative reactivity resulted from full insertion of the rods, as compared to the normal partial (subcritical) insertion associated with target changes.
In fact, the reactor was shut down, as the Technical Specifications define " Reactor Shutdown." However, this condition lasted only a short time (15-20 minutes), before the rods were withdrawn and the reactor returned to 100% of rated full power.
During the time that the rods were fully inserted, all equipment remained in a normal operating configuration.
Therefore, although the abnormal rod insertion ("long dip") was substantiated, there were no apparent Techni-cal Specifications violations, procedural violations, or adverse safety implications as a result of this event.
Nonetheless, the abnormal rod manipulation for the target change was not logged or otherwise documented as an abnormal operating condition.
Also, this matter had not been dis-cussed with operators, although three months had passed since the event occurred.
The inspector noted that there were no regulatory or proce-dural requirements for such feedback of operating experience, but in light of the sensitivity of the matter as viewed b of a " double standard" and the operations manager'y operator's perception s admission that this was a " political" concern, the operations management review of the event shot.1d have been done more promptly.
This matter is discussed further in Paragraph 2.10.
2. 3 Concern No. 3 - Unsafe Reattor Operation Due to Nonvisible Core Summary of Allegation At the end of April or the beg nning of May 1986, heat exchanger cleaning was conducted using hydrogen peroxitie, and some of the hydrogen peroxide.
. got into the pool of the reactor.
Although this had caused very poor ' visibility in the pool, operations personnel decided to start up the reactor.
At SMW, operators could not even see the glow from the reactor.
Operators wrote a letter to management about the unsafe startup, but nothing was done.
Clarification of Allegation Based on discussions with licensed operators and the nuclear operations manager, the inspector determined that the hydrogen peroxide intrusion to the reactor pool occurred on Thursday, March 6,1986, generally as __ __ _ _
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summarized above.
Heat exchanger cleaning is done normally on an annual frequency, generally each spring.
In past years, there had been some , cloudiness of the pool water, but in this case the walls of the pool were also cleaned more intensely than normal.
Also, there may have been a
valving error when cicaning the heat exchanger such that hydrogen perox-ide entered the pool, but this is somewhat speculative and not proven.
Nonetheless, the pool water had become very cloudy during this year's cleaning.
With water level lowered and operators standing on the pool shelf, they observed no objects present over the core that could restrict or inhibit flow.
The nuclear operations manager was aware of the extent- ' of murkiness of the water.
But having assessed the condition, the reac-tor was started up on the midshift on March 7, 1986.
About 8:00 a.m.
, - that morning, the plant manager, manager-site cperations, and nuclear operations manager all observed the cloudiness of the water.
They as- " sessed that it was safe to continue to operate because the murkiness was due to small particulate that was being filtered.
Also, based on past experience, any flow core problems caused by blockage would be detected early by the log N instrument that would become erratic and oscillate due to voids forming.
However, plant management did not inform the operators on Friday of the basis for their judgement, and operator con-cern apparently escalated over the weekend.
That is when the operators' letter of concern was written, although it was dated March 14, 1986.
(That memo included the operators' statement of their hope that management develop a plan which would eliminate future situations where production schedules come before safety.
During telephone conversations with several operators on November 16 and 17,1986, the inspector verified that the operators' basis for their expressed concern was limited to the startup of March 7,1986, and no similar situations.)
Plant management I,ad considered the known and measurable core parameters that could predict or indicate a degrading flow condition, they had questioned the possible mechanisms for flow blockage, and they had as-sessed the risk of not detecting degraded flow auring operation with reduced core visibility.
However, their considerations were not communi-cated to operators.
Also, the operators' concerns were not conveyed directly to plant management during the weekend.
However, af ter receiv-ing the operators' letter, management immediately met with the operators and met subsequently on several additional occasions to discuss this matter.
Findinos The inspector reviewed Technical Specifications for water quality and reactor operating procedures and determined that there were no violations or direct adverse safety concerns as a result of this occurrence.
The Technical Specifications include no specifit; provisions for pool water clarity, but only for pool water quality.
The pH of the pool water was maintained between 5.0 and 7.5 following the heat exchanger and pool wall , cleaning operations.
The pool water specific resistance fell below the . --.. m- - .. m-- - - - - - _, - - -.. ._ _.,.,,. _ ,.,,,
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, normal operating limit of 200,000 ohn-cm, to as low as 160,000 ohn-ca.
' This was well above the 70,000 obn-ce Technical Specification transient ilmit, and the specific resistance was restored to greater than 200,000 ohn-cm on March 13, 1986, which w e within the 14 days allowed by the Technical Specifications.
Nevertheless, operators were clearly not com-fortable operating in the abnormal condition of not having the core visible, although they did not express their concern directly to manage-ment during the weekend.
It is probable that the operators would have , gained the insight to monitor flow conditions using alternate methods had they expressed their concern.
This matter has been reviewed by the nuclear safety committee, and the heat exchanger cleaning procedure will be reviewed and revised prior to its next use, as discussed in Paragraph 4.
The inspector determined that although the alleged clouding of the pool was substantiated, contrary to the allegation, management acted respons-ibly and promptly in response to the operators' written concerns. However, the decisions and performance of both operators and management before and af ter the startup on March 7,1986 were questionable.
Simply stated, the startup probably should not have been permitted to proceed with the , pool water clarity substantially degraded.
The cloudy water condition t was not normal for plant startup and power operation.
Furthermore, .' operating with the core not visible is not specifically covered by Tech-nical Specifications and only marginally addressed in plant procedures.
The NRC corsiders that operation with the core visible is a prudent mode of operation for the facility; and operation with the core not visible is abnormal and should have been treated as such.
Operations and facil-ity management should have better (and formally) evaluated the abnonnat operating conditions, established appropriate compensatory (or backup) measures for operation, and properly informed the operators concerning - their assessment and decisions.
Further, the operators should have voiced and emphasized their concerns of safe operation prior to the startup on March 7, 1986.
Although this is considered an isolated oc-currence, the NRC is concerned that this event occurred.
Further ex-planation of management's review of this incident has been requested in the cover letter which transmits this report.
This item is unresolved pending review of the licensee's response, in-ciuding verification of actions taken to prevent recurrence, during a subsequent NRC inspection (54/86-02-02).
2. 4 Concern No. 4 - Unauthorized Access to Reactor Building Summary of Allegation In March or April 1986, the quality control supervisor, authorized for unescorted access to the building, informed one of his workers, who was not authorized for unescorted access, how to access the building.
This action gave the person access without using the access procedure.. Opera- . -
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] - , i tors were concerned about unauthorized access and the safety of indivi-duals involved.
Now operators do not challenge individuals suspected ' of not having authorized access, because "no one cares."
, Clarification of Allegation Based on discussions with licensed operators, the inspector determined that on two other occasions, once last winter and most recently a month ago (during July 1986), different individuals, who were not authorized access, were informed how to access Buildings 1 and 2 (the reactor build-ing and hot laboratory).
The reactor supervisor, also assigned as the designated controlled area access security officer, became aware of these or similar incidents, which, as he noted in a memorandum to all facility department heads dated July 21, 1986, "seem to indicate a lack of appre-ciation or understanding of our security plan." The memorandum empha-sized the heavy dependence of the security system's success on the employees, and requested each group to conduct team meetings or other communications to inform employees of the importance of properly imple-menting the required security measures of the controlled access area.
The memorandum also specifically stated certain responsibilities of people who are not authorized access to Buildings 1 and 2, as well as people who are authorized access.
Findings i Although the specific example of unauthorized access, as described in the initial allegation was not confirmed by the operators interviewed, other similar examples were described that, in effect, substantiated the alleged concern.
These incidents were known by responsible licensee security management, and measures were initiated to correct the problems and prevent recurrence of past violations.
t' However, at or about 7:00 a.m. on August 7,1986, another incident oc-curred that indicated a continuing. lack of appreciation or understanding of the security plan.
The inspectors were then at the entrance of Build- ' ings 1 and 2 and desired to contact a control room operator to obtain escorted access to the facility.
Seeing a telephone by the door, the inspectors asked two painters (temporary summer help), in the vicinity , - l of the entrance, the telephone number of the control room.
The painters ! did not know the number.
The inspectors then asked how to get into the , control room.
The workers provided specific directions in response to ! this question and, if the inspectors had implemented the directions as subsequently demonstrated to the licensee, the inspectors could have " accessed the buildings and the control room without authorization.
, t Failure to properly control access is considered a violation of the ! security plan, for which previous corrective actions were not effective l (54/86-02-03).
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, 2. 5 Concern No. 5 - Improper Administration of Requalification Examination Summary of Allegation The licensed operator requalification examinations have been routinely passed out and collected two weeks later.
The lowest grade on the recent examinations was 89.
The caller questioned whether requalification ex-aminations are supposeo to be given in a two-week period.
Clarification of Allegation
Based on discussions with licensed operators and nuclear operations de- , partment supervisors, the inspector determined that requalification ex-aminations have been routinely administered as a take-home exam taken by operators on an honor system basis.
By letter dated May 5, 1986, the licensee provided NRC Re ion I a copy of the Operator Requalification Program (ORP).
The ORP ntroduction states: "The purpose of this requalification program is to take into account the requirements of 10 CFR 50.54(1-1) while recognizing the problems associated with a requalification program for research reactors which have a limited training staff available.
This requalification. program meets these purposes while providing flexibility which en- " ables facilities with minimum staff to' complete the program bienni-sily.
This requalification program also meets the requirements of , the American National Standard 15.4 ' Selection and Training of ^ Personnel for Research Reactors. '" Regarding the comprehensive biennial written exam given to all licensed personnel, the ORP states, in part, "...Because of the problems associ-ated with proper reactor staffing during periods when the examinations will be administered to operating staff members, the examinations may be given in parts and within a 2 week period."
Findings
Based on the inspector's review, the alleged requalification exam admini-stration practices are substantiated.
The ORP does not appear to pro-hibit administration of the requalification exam as a take-home exam to be taken on an honor-system basis.
However, neither does the ORP clearly permit this practice.
Further, the NRC Region I staff had not previously understood that this exam was taken home and returned for grading two weeks later.
Clearly, this raises serious questions as to the integrity and validity of the requalification exam process.
Based on informal.
' discussions following this inspection and preliminary review of this
matter, the NRC Region I staff's initial determination is that adminis-tration of requalification exams as a take-home exam is an unacceptable practice.
However, because the ORP is not specific to addressing this practice, this matter is being referred to the Operator Licensing Section, NRC Region I for their formal assessment and evaluation.
This item is unresolved (54/86-02-04); . - - _ __
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. . 2. 6 Concern No. 6 - Potential Conflict of Interest Regarding Nuclear Safe-guards Committee Staffing Summary of Allegation The nuclear safeguards committee consists of " business" people motivated by profit.
The caller questioned whether this was a conflict (of inter-i est), as he stated that this may be part of the general problem ha per-i ceived and alleged of violations being overlooked by management.
J Clarification of Allegation Based on interviews with licensed operators and nuclear operations de-partment superviscrs, the inspectors determined that none of the indi-viduals shared the alleged concern.
In fact, each person interviewed either had no adverse opinion or generally expressed their respect for and confidence in the motivation of nuclear safeguards committee (NSC) members.
The inspector reviewed the Technical Specifications require-ments for the composition and technical qualifications of NSC members and verified that these requirements were met.
In addition, the inspec-tor reviewed NSC meeting minutes (also see Paragraph 4.0) and verified that the predominant emphasis of NSC concerns was toward nuclear safety.
Findings The alleged implied concern regarding NSC members being unduly motivated by profit was not substantiated.
Although business profit is expected to be a consideration in overall facility operations, the inspector found no evidence that NSC recommendations or actions were improperly balanced toward business profit as opposed to safety of operations.
, 2. 7 Concern No. 7 - Reactor Startup to Avoid Reporting Shutdown Summary of Allegation Management conducted a startup of the reactor within 23 hours of being shut down, since they knew that Technical Specifications require inform-ing the NRC if shut down over 24 hours.
The caller could not find the requirement in Technical Specifications, but he stated that it may be in 10 CFR or in procedures.
He alleged further that the requirement was common knowledge among operators.
Clarification of Allegation Based on discussions with licensed operators and nuclear operation de-partment supervisors, none of the individuals were aware of any startup conducted within a certain time period, as described above, in order to not inform the NRC of the shutdown.
Furthermore, none of the individuals were aware of any requirements in either Techreical Specifications or .
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The inspector reviewed Technical Specifications and verified that there were no such reporting requirements.
Findinus The alleged concern was not substantiated due to the lack of specificity.
regarding the initial allegation, tne inability to confirm the alleged startup for the alleged reasons, and the inability to identify the al-leged requirements.
2.8 Concern No. 8 - Unexplained Processina/ Discharge of Contaminated Water Summary of Allegation Prior to the caller's arrival (employment) onsite, about 30,000 gallons of water got into duct work over a hot cell.
The water then contained fission product iodine and was put in a holding tank from which it dis-appeared in about a week.
The site evaporator has a capacity of only about 500 gallons per day.
Clarification of Findings Based on discussions with the licensee representatives and a review of licensee records, the inspector determined that about 45,000 gallons of ground water leaked into the room containing the T-1 liquid was+e storage tank during March-April 1983.
The inspector verified through direct observation that there was no interconnection between this room, located under the Building 2 Isotope Laboratory, and the Hot Cell ventilation system.
This water contained residual fission product activity as a result of contact with the radiologically contaminated floor and walls of the T-1 tank room.
The water was transferred to a series of mall tanks, analyzed for fission product activity, and released from the facility without going through the site evaporator.
Licensee records-indicated that a total of 77.4 microcuries (strontium-90 equivalent) of fission products were released from the facility during April 1983.
This value corresponds to an average concentration of 2.76 E-8 microcuries per cubic centimeter, which amounts to less than one percent of the 10 CFR Part 20, Appendix B. Table II, Column 2 limit for the release of soluble strontium, in water, to unrestricted areas.
Findings The alleged improper processing or disappearance of water containing fission product iodine was not substantiated.
Although the alleged con-cern was not entirely accurate, in that a substantial quantity of water did not get'into ventilation duct work over the hot cell, the inspectors substantiated that in excess of 30,000 gallons of contaminated water was released from the facility without going through the site evaporator.
However, no federal regulations or ficility license conditions were _ _ _.,.. . . .
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. violated as a result of this release of liquid waste.
Based on the in-spector's review of this incident, the licensee's actions taken to pro-p cess and release the water were found acceptable.
2.9 Concern No. 9 - Operator Counselled to Withhold Information from NRC Summary of Allegation During an NRC inspection, a lead opemtor was asked about the requalifi-cation program.
He responded that there wasn t any but they had the-books'for self-study.
Management later told him not to say anything if it would look bad.
Clarification of Allegation Based on dit ossions with licensed operators, the inspector determined that the ge mtors were generally dissatisfied with the requalification training pr: gram relying primarily on self study vice formal retraining lectures /w.ninars.
However, the inspector verified that such self-study-was in conformance with Operator Requalification Program requirements.
One of the operators confirmed that following an NRC inspection exit meeting, the p'lant manager told him not to tell the NRC about " things that are bad.
The inspector noted that this recollection was a minority - view, as all other operators had not recalled being given such direction.
The inspector reviewed a memorandum issued by the plant manager in March 1979 which provided clear and definitive guidance regarding the method for contacting the NRC Region I office and the freedom to express indi- ' vidual safet,v concerns to the NRC.
The memorandum also requested that- - such concerns also be identified to plant management but did not~ mandate' such in-house notification as a prerequisite to ' contacting the NRC.
This memorandum was included as an attachment to the operators letter of con ' cern regarding teactor operation-with cloudy pool water after cleaning the heat exchanger (see Paragraph 2.3).
Thus, this' memorandum was common knowledge to all operators.
As a related matter, the inspector asked each person-interviewed during this inspection if he had been given any instructions as to what to say during the interview.
Each of the opera-tors said the only directions they were given were to answer the inspec-tors' questions honestly and completely.
Findings The inspector determined that although the operators shared a common preference for formal requalification lectures / seminars in lieu of self- . study, the ORP supported the latter.
With respect to alleged management directives to not say anything to NRC inspectors if it would look bad, the prevailing view was that operators should be candid and forthright intheirdiscussionswithNRCinspectors,particularlyregardingpoten-tial safety concerns.
The inspector considered that management s in-structions to not say anything bad was nothing more than encouragement to put one's best foot forward or to not express differing management / l l l .
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. . employee views of established policies / practices merely in order to qtir, l some kind of job-related benefit or advantage.
Moreover, there wu & -evidence to substantiate that management had acted unfavorably towarJ an employee for expressing dissenting or differing views.
2.10 Summary and Conclusions . Although certain of the alleged concerns were substantiated fully, or in part, the inspector determined that there were no common indicators - or trends that formed the bases to generally conclude either: 1) that management had taken improper corrective actions to problems brought to their. attention or 2) that management would require, approve, or otherwise encourage operators to act in a manner unsafe to reactor oper6-j tions.
However, as a result of the forthright and direct responses to the inspector's questions by both licensed operators and facility man-agement, certain problem areas or operating weaknesses were identified that require corrective measures.
The inspector learned that a recently licensed operator was dismissed for cause based on some specific in-stances'of conduct unacceptable to management.
The reasons for the operator's dismissal were not related directly to improper performance .of his licensed duties, but were associated more with indicators of overall attitude, professionalism,. attention to duties, and general maturity and behavior.
Nonetheless, the individual's dismissal has- . clearly resulted in a heightened degree of polarization and perhaps distrust between management and operators.
This is a condition that must l be promptly rectified to assure continued safe operation of the facility.
L Lastly, some operators were of the view that nuclear operations managers L and supervisors simply were not communicating effectively with each other ' and with operators. ' Although no specific instances were, identified, operators-felt that the personalities of some individuals did.not facili-tate free and candid. communications of operating problems.
Operators-felt that one or another individual would respond to problems and. solve ' them independently and not inform their supervisors of either that prob-lem or the corrective action taken.
e The inspector discussed these concerns with nuclear operations department j and plant management.
They were sensitive to some of the recent com-x munications problems and noted that.they were attempting to communicate i g more frequently and more openly with plant operators.
They acknowledged-p the-inspector's comments regarding the apparent need to develop a system .' for identification of operating problems and feedback of operating ex- .perience.
The inspector stated that this area would be reviewed during ,_ future inspections (54/86-02-05).
The fundamental weakness of facility operations that requires improvement , is operator / management communications.
Operators need to be aware of management's bases for operating decisions and management needs to be informed promptly of operators' concerns regarding safe operation of the l facility.
The inspector noted that operating logs seldom describe plant i i
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, . I problems or abnormal conditions.
Further, there is no system in place to facilitate identification of operator's perceptions of abnormal
6perating conditions or operating problems such that the abnormal condi-tion is required to be evaluated and resolved by plant management, and that there is feedback of the solutions or management decisions to l , operating personnel.
' Some of the operators believed that an operator representative should.
be permitted to attend meetings of the nuclear safeguards committee.
This could strengthen their understanding of the technical bases for NSC ( recommendations and-judgements.
Some operators'also believed that they ! should review NSC minutes.
The inspector considered that both of the ' . actions could strengthen operator / management communications.
3.0 Facility Operations On several occasions during the inspection, the inspectors toured the facility with licensee representatives.
During the tours, the inspectors verified the correct status'of plant conditions and equipment.
The inspectors also veri-fied that the facility was manned in accordance with Technical-Specifications requirements and that plant logs accurately reflected plant conditions. 'The* L inspectors found that, in general, housekeeping, radiological and security controls were adequate, with the exception of a security violation that oc-curred on August 7, 1986 (see Paragraph 2.4).
' The reactor operated at full power during the inspection with the' exception- ,. ! !. of a scheduled shutdown on August 7,1986 to change FPH targets and to install l new test and experiment equipment in the reactor pool.
During that shutdown ,' L period, the inspectors observed the rigging operations, including the lift L and placement, associated with the major structural assembly of the recently manufactured Neutron Transmutation Doping (NTD) Silicon Irradiation Facility.
'The reactor core had been-moved about 15-20 feet from its normal operating position to aL temporary staging position between the fuel pool / storage pool divider wall passageway, and the pool level had been lowered to permit per - sonnel access to the fuel pool ledge to facilitate handling and placement of s the NTD facility.
The inspectors noted that handling operations were properly i supervised and were being conducted in a controlled manner by maintenance ! personnel.
Also, special radiation surveys were being performed by plant operations and health physics personnel to identify increased radiation levels that might result from the lowered pool level.
As a result.of that survey, ' a neutron radiation source was found exposed above the water surface, causing: a localized elevated radiation area (about 100 mrem /hr).
The source was lowered;into the water, which reduced the radiation field to the general area background level.
- I The inspectors expressed concern regarding one aspect of the NTD facility.
handling operation.
The inspectors first observation of the rigging operation occurred while the NTD structure was suspended above and being lowered into the fuel pool.
Af ter the structure was placed on the pool floor, the inspec-tors questioned operations personnel and management regarding lifting of the structure in relatively close proximity to the suspended core.
The inspectors'
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. . L concern in this case was the possibility of damage to the reactor core or its support bridge in the event of postulated drop of the NTO structure.
Although ' the structure was not lifted directly over the' reactor core, it was large enough to possibly impact the core and core supports if it had dropped.
This.
event did not occur, however, the inspectors stated that the licensee hazard summary for the NTD facility r possibility and consequences o(see Paragraph 4.0) should have evaluated the f a postulated heavy load accident as a result ,' of dropping the NTD facility structure, or the core should have been moved' further from its normal operating position, where the NTD structure was being installed.
Licensee management acknowledged the inspectors' concern and later that day, when the NTD structure had to be lifted from the pool as a result ' of misalignment. problems, the nuclear operations manager stated that the reactor core was moved further from its normal location to prevent any pos-sible damage from the postulated drop of the NTD structure.
The inspector had no further questions concerning this matter.
4.0 Nuclear Safeguards Committee Reviews ! The independent review of reactor facility operations is performed by the Nuclear Safeguards Committee (NSC).
The NSC is comprised of a minirnum of five members who collectively are required to provide a broad spectrum of expertise-in the appropriate reactor technology.
During this inspection, the inspector reviewed NSC meeting minutes to verify that NSC review functions were conducted as required by Technical Specifications 6.2.3 and 6.4 The inspector's review' t included the minutes for NSC Meeting Nos. 117, dated August 20, 1985; 118,. . !: . dated November 6, 1985; 119, dated December 21, 1985; and 120, dated May 21, l " 1986.
NSC Meeting No. 117 included reviews of (1) new waste storage plugs, (2) a wiring modification'to the function switch of'the reactor log-N amplifiers, L (3) cutting reactor beam tubes, and (4) fire protection.
With regard to the latter item, the consequences of two recent fires in the waste hot cell were L discussed..The committee requested that a full report of the incidents be submitted to the NSC with recommendations for corrective actions.
Also, the NSC requested that a subcommittee be formed to review fire protection in hot cells and that they submit recommendations to the NSC for review.
g NSC Meeting No.118 included reviews of (1) topaz irradiation, (2) cutting.
l beam tubes, (3) the B-3 cnk unload procedure, (4) wiring modification to L function switch, (5) aud %, (6) the fire in hot cell No. 1, and (7) formation ! of a three person fire protection committee (FPC).
The FPC was charged with reviewing fire protection in hot cells and reporting back to the NSC by the end of the year (1985)..
NSC Meeting No.119 included reviews of (1) audits, (2) topaz irradiation, (3) expected radiation levels from N-16 activity, and (4) the North Face
Silicon Irradiation Facility polystyrene containers, reactivity analysis, and o lp thermal analysis.
The NSC requested Operations to consolidate all engineering analysis reports into a formal Hazard Summary for the new Neutron Transmuta-u l tion Doping (NTD) Silicon Irradiation Facility.
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16 -. . ! , NSC Meeting No. 120 included reviews of (1) the B-3 cask maintenance procedure, (2) pool duct sweep modifications, (3) a radiation safety audit, (4) topaz irradiation, (5) annual audit of the physical security program, (6) the con - , solidated hazard summary for the North Face NTD Silicon Irradiation Facility, (7) a modification to the ion chamber alignment shelf and to uncompensated
-ion chamber containment cans, and (8) heat exchanger cleaning treatment which' caused the re6ctor pool to become' cloudy and which led to operator concerns
' in the areas of safety and production.
With respect to the last item, the NSC concluded that better communications between operators and supervisors / management could have relieved operator concerns.at an earlier time and that-procedures are in existence to handle such questions.
Reactor Operations alsu committed to a review 'and update of the cresent peroxide cleaning procedure
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prior to its next use.
This item is also discussed in Paragraph 2.3.
With respect to the hazard summary for the North Face NTO Silicon Irradiation Facility, the inspector considered that the analyses included appropriate discussions of the expected radiation hazards, reactivity effects, heat-generation, interference with core components, and component installation.
.i Based'on the inspector's review of NSC meeting minutes, the inspector deter - mined the NSC reviews were conducted as required by Technical Specifications and to an appropriate _ depth of technical assessment analysis.
The fire pro-tection committee report of fire protection in the hot cells has not yet been
! completed due to delays caused by other priority work assigned to the commit-- ' tee members, but this report is still expected 'o a near-term NSC meeting.
The inspector had no further questions concerning this matter.
J ' 5.
Exit Interview The inspector met with licensee personnel denoted in Section 1.0 at the con-p clusion of the. inspection on August 8, 1986.
The scope and findings of the ' in.spection were discussed at that time.
At no time during this inspection !, was written material provided to the-licensee by the inspector, i . , , ?. ? }}