ML19259C340

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IE Insp Rept 70-0820/79-04 on 790212-15.Noncompliance Noted:Licensee Failed to Have Alarm Setpoints for Three Criticality Monitors Set Between 5 & 20 Milliroentigens/H
ML19259C340
Person / Time
Site: Wood River Junction
Issue date: 03/15/1979
From: Crocker H, Kinney W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19259C315 List:
References
70-0820-79-04, 70-820-79-4, NUDOCS 7906140608
Download: ML19259C340 (12)


Text

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFOP. CEMENT Region I Report No.

70-820/79-04 Docket No.70-820 License No. SNM-777 Priority 1

Category UR Licensee:

United Nuclear Corporation Wood River Junction, Rhode Island 02894 Facility Name:

Fuel Recovery Operation Inspection at:

Wood River Junction, Rhode Island Inspection conducted: February 12-15, 1979 Inspectors:

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V.1. Kinney/ Project / Inspector

'date signed

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H. W. Crocker, Chief, Fuel Facility Project Section date signed date signed Approved by:

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H. W. Crocker,' Chief, Fuel Facility

/ dafe sicfned Project Section, FF&MS Branch Inspection Summary:

Inspection on February 12-15,1979 (Report No. 70-820/79-04)

Areas Inspected:

Routine, unannounced inspection by region based inspectors of licensee action on previous inspection findings; nuclear safety; operations; organization; facility changes and modifications; procedure control; safety committee activities; and nonroutine events.

The inspection involved 41 inspec-tor-hours onsite by two NRC region based inspectors.

Results:

Of the eight areas inspected, no~ items of noncompliance or deviations were identif od in seven areas.

One apparent item of noncompliance was identified in nuclear safety (infraction - the licensee failed to have the alarm set points for three criticality monitors set between 5 mR/hr. and 20 mR/hr. - Paragraph 3.a).

2282 215 Region I Form 12 (Rev. April 77) 7906140 /c,094.

DETAILS 1.

Persons Contacted

  • C. E. Bowers, General Manager
  • J. H. Wakefield, Operations Manager
  • K. A. Helgeson, Health Physics Specialist
  • D. M. Schultz, Compliance Manager D. F. Cronin, Nuclear and Industrial Safety Manager P. Dessaules, Production Assistant D. A. Daigler, Quality Assurance Engineer T. Ashley, Quality Assurance Engineer J. F. Aiello, Production Supervisor In addition to the persons listed above, the inspector interviewed four operators during the course of the inspection.
  • denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings (Closed) Infraction (70-820/78-06-01):

This item of noncompliance involved three instances of licensee failure to follow standard operating procedures.

The corrective actions for one of the instances and portions of the remaining two instances were verified during Inspections 70-820/78-13 a-J 70-820/78-21.

The corrective actions verified during this current inspection were noted yet to be completed in Inspection 70-820/78-21.

Operating reports were not accurately completed.

The licensee has placed the new dissolver operating report into use.

According to the licensee, approximately 70 percent of Production Department forms have been reviewed and changed.

The licensee plans on having the revision of these forms completed by mid-March.

The licensee plans on reviewing and revising the Quality Assurance and Nuclear and Industrial Safety forms.

They plan on having these completed by July 1979.

Improper storage of 5 shipping containers Standard Operating Pro-cedure (SOP) III-A, Revision VI, was issued effective October 26, 1979.

This completed the corrective action for this item.

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3 (Closed) Infraction (70-820/78-13-01):

This item of nonc'ompliance involved four instances of licensee failure to follow Standard Operating Procedures.

The corrective actions for three of the instances were verified during Inspection 70-820/78-21.

The cor-rective action verified during this current inspection was that noted yet to be completed in Inspection 70-820/78-21.

The inspector reviewed the memorandum of September 29, 1978, which had an attached list of SOP's which needed revision, review, or change in format.

According w a memorandum of December 11, 1978, the licensee planned to have the SOP's requiring revision and re-issuance completed by January 31, 1979; and the licensee plans to have the SOP's requiring rewriting and reissuance. completed by March 30,1979.

(Closed) Infraction (70-820/78-20-01):

Improper storage of special nuclear material (SNM).

The inspector verified that the desks in the process areas have criticality limits posted on them.

According to the Operations Manager, operations personnel were instructed to only place SNM containing material in accordance with posted limits.

(Closed) Infraction (70-820/78-21-01):

Two instances of licensee failure to follow contamination control procedures.

(1) The li-censee was cited for not having established procedures to prevent spread of contamination in the process area as contaminated gloves were put into and removed from contaminated equipment.

The inspector verified that the licensee revised S0P I-H, Contamination Control, effective January 9, 1979, to include a special restriction concerning the special care required to avoid the spread of contamination from liquid or solids containing uranium dropping from gloves or equip-ment onto surfaces outside the hood or glovebox enclosure.

The inspector verified from safety meeting minutes that the licensee had instructed personnel on the necessity for compliance with contamination control requirements.

(2) The licensee failed to survey vehicles transporting SNM to and from the facility.

The inspector verified that survey document has been changed and now specifically requires vehicle surveys.

According to the Health Physics Specialist, the Health Physic Technicians were instructed to make the surveys of the transporting vehicles.

2h2

4 (Closed) Infraction (78-21-02):

The licensee failed to adopt, approve, and implement procedures required by 10 CFR 21.21(a)

" Notification of failure to comply or existence of a defect".

The inspector verified that the licensee has issued procedure "Evaluat-ing Possible Safety Hazards to the General o blic" dated September u

19, 1978.

The procedure was issued to the General Manager, the Quality Assurance Manager, the Operations Manager, the Finance and Administration Manager, and the Compliance Manager.

Since the procedures had sections calling for action from either licensee employees or contract guards, the inspector asked how these people were aware of their responsibilities.

The licensee assured the inspector that all personnel would be made aware of their responsi-bilities given in this procedure.

(Closed) Deficiency (78-21-03):

The licensee failed to post three locations with nuclear safety signs and to identify two process containers as being empty.

The inspector verified that the licensee has increased the frequency of checks for missing or damaged signs. According to the licensee, the operating personnel have been reinstructed as to the requirement for identification of empty SNM containers.

3.

Nuclear Safety a.

Criticality Alarms The inspectors observed the settings of the criticality moni-tors in the facility on February 12.

The inspectors noted that the alarm set points on the criticality monitors in the extraction area, the precipitation area, and the analytical laboratory were all set at 30 mr/hr.

This is in noncompliance with 10 CFR 70.24(a)(2) which requires that the monitoring devices shall have a preset alarm point of not less than 5 millirems per hour nor more than 20 millirems per hour.

The license application also states in section 405.1 that the detectors of the nuclear alarm system shall have a preset alarm level of not less than 5 mR/hr or greater than 20 mR/hr.

The licensee reset the criticality alarm points on the in-struments to 20 mR,'hr.

The inspector verified that the criti-cality monitor ai-1 set points had been reset to 20 mR/hr.

The licensee also :ook steps to assure that the person setting the alarms would set them within the required limits in the 2282 218

5 b.

Evaluations The inspector reviewed Nuclear and Industrial Safety Authori-zations as shown below:

Authorization No.

Subject R0 266 Kenics Extraction Pilot Operation R0 272 Kenics Extraction Pilot Operation R0 275 Kenics Extraction Semi-Works R0 284 Kenics Extraction Organic Wash System R0 289 Drum Counting at Gamma Scan Location R0 291 U-235 in NIS Lab & NIS Offices All of the above authorizations had final NIS approval except Authorization No. 289 for drum counting at the ganma scan lo-cation. The nuclear safety evaluations included in these documents appeared to be in accord with license requirements.

c.

Raschig Ring Filled Vessels The inspector examined the records of the raschig ring level checks for January and February 1979.

The licensee checked the ring levels in 13 vessels which contained raschig rings.

The inspector noted that the ring levels in the coolant tanks of the wet cut-off saw and the milling machine discussed in sections 922.16 and 922.17 of the license application were not included in the raschig ring level checks.

The licensee in-dicated they would include these vessels in their monthly raschig ring level checks.

d.

Posted Nuclear Criticality Safety Limits The inspectors noted that the different zones were posted with nuclear criticality safety limits, and the special nuclear material in the zones were in accord with the posted limits.

The inspectors noted that a canner for sealing cans of product did not appear to have a posted nuclear safety limit associated with it, and the licensee representative could not immediately show the appropriate posting to the inspectors.

The licensee indicated they would assess the situation and put up or modify a nuclear criticality safety limit posting to address the canner if warranted.

2282 219

6 4.

Operations Review a.

Facility Examination The inspectors initiated the inspection after the entrance interview by performing a physical inspection of the main processing facility.

During the course of the inspection, the ncw storage tank for process liquid wastes and the storage warehouse were also physically inspected.

The areas inspected were in a good state of housekeeping.

b.

Standard Operating Procedures The inspector reviewed the Standard Operating Drocedures (S0P's) for four different work stations.

Then each of the operations was discussed with an Operator to assess the Operator's knowledge of the operation and the safety require-ments for the operation, especially those pointed out in the S0P for the operation.

The SOP's reviewed and discussed with different operators are listed below.

S0P No.

Revision Effective Date Subject IV-H III 8/17/76 Operation of the Wet Cut-off Saw V-D VIII 4/14/76 1-J-5 Dissolvers V-E New 4/2/73 4-J-L Series Tray Dissolvers VII-B III 12/29/73 Safety (Extraction)

Each of the first three listed SOP's had a section specifi-cally addressing safety.

As shown in the listing, S0P No.

VII-B specifically addressed safety for the extraction opera-tion.

Each of the SOP's was approved by the Nuclear and Industrial Safety Manager along with the Fuel Recovery Opera-tion General Manager, the Operations Manager, and the Quality Assurance Manager.

2282 220

7 The operators interviewed all demonstrated good knowledge of the operations and the safety aspects involved in the opera-tions.

During the discussion of the operation of the wet cut-off saw, it was determined that operating personnel do not use a vented container to store the metal chips resulting from the cutting operation as called for in NIS Requirement 8.

The licensee indicated they would assess the situation and take appropriate corrective action.

The inspector also questioned the lack of a requirement to have coolant flow prior to starting to cut fuel bearing components.

The licensee said there was an interlock which prevented the saw from operating without the coolant flow.

5.

Organization The organization for United Nuclear Corporation Fuel Recovery Operation is given below.

President - K. Cunningham General Manager - C. Bowers Operat'ons Manager - J. Wakefield Process Analyst - J. Wakefield Production Assistant - P. Desaulles Production Supervisors - J. Aiello, J. Murphy Maintenance and Plant Services - R. Weber Quality Assurance Manager - R. Gregg Nuclear and Industrial Safety Manager - D. F. Cronin Health Physics Specialist - K. Helgeson Health Physics Technicians - T. Itteilag N. Vuono Quality Assurance Engineers - D. Daigler T. Ashley Plant Chemist - T. Deluty Nuclear Material Assistant - J. O'Donnell Material Control Assistant - L. LaFond Security Manager - R. Gigliotti Compliance Manager - D. Schultz Finance and Administration Manager - J. McCusker Purchasing - R. Smith Resource Systems - fl. Clark Speciality Chemicals Manager - J. Dunning Marketing Manager - S. Pennacchini 2282 221

8 The Nuclear and Industrial Safety (NIS) Department is of special interest to the NRC, since the NIS activities include:

1) establish-ment of nuclear and industrial safety policy; 2) preparation of regulatory agency license applications; 3) direction of on-site nuclear criticality safety and health physics control functions independent of, but parallel to, the functions of operation per-sonnel; 4) provision of technical support services, as related to nuclear criticality safety and health physics, for review of proposed additions to or modifications of process equipment; and 5) systematic auditing of plant operations.

As shown above, the NIS Manager reports to the Quality Assurance Manager.

According to Figure 201-I, dated September 1,1975, of Subsection 201, " Division Organization", and Figure 204-I, dated September 1, 1975, of subsection 204, Production Organization, of the approved license application, the Nuclear and Industrial Safety Manager reports to the Fuel Recovery Opertions General Manager rather than to the Quality Assurance Manager.

The separation of reporting responsibility for Nuclear and Industrial Safety from the normal production function is maintained with the present organization.

The present license conditions on organization do not address the position of Health Physics Specialist.

The approved licen:e appli-cation presently assigns the health physics responsibilities to the Nuclear and Industrial Safety Manager in subsection 202, Nuclear and Industrial Safety Department.

According to the licensee, the Health Physics Specialist reports to the Nuclear and Industrial Safety Manager for technical matters; otherwise, the Health Physics Specialist reports to the Quality Assurance Manager.

The licensee now has two health physics technicians.

The technicians report to either the Nuclear and Industrial Safety Manager or the Health Physics Technician depending upon the nature of their duties.

If their duties are primarily routine health physics activities, they report to the Health Physics Specialist.

If their duties are primarily concerned with nuclear safety, they report to the Nuclear and Industrial Safety Manager.

As discussed above, the licensee's current organization for meeting the Nuclear and Industrial Safety function is meeting the intent of the license conditions.

However, the organization is not functioning 2282 222

9 exactly as described in subsection 202, Nuclear and Industrial Safety Departmentpf the approved licensee application.

Also, the Nuclear and Indus' trial Safety Department doesn't report to the General Manager as described in Figures 201-I and 204-I of the approved license application.

The licensee should take steps to have the approved license application correctly reflect the func-tioning organization of the Fuel Recovery Operations.

6.

QA/NIS and HP Coverage on Third (12-8) Shift At the time of the inspection, the licensee is providing QA/NIS coverage on the third (12-8) shift.

The two quality assurance engineers, the health physics specialist, and the NIS manager are providing the coverage on a weekly rotational basis.

No operations requiring a hazard analysis are allowed on the third shift except when the health physics specialist or NIS manager are on the third shift and have approved the operation.

At the present time, both health physics technicians are working on day (8-4) shift.

When the newly assigned health physics technician is adequately trained, the technician will work on the third shift.

The QA/NIS coverage may continue after this time, according to the licensee.

7.

Facility Changes and Modifications Amendment No. 4 to License No. SNM-777, dated November 22, 1978, authorized uranium recovery operatons on lagoon residues in the extension of the north bay area.

The licensee showed the latest building and process equipment layouts to the inspectors.

The licensee is now going to build a one story building 50 feet by 50 feet by 12 feet high instead of a two story building.

The licensee plans on construction of the facility starting during March 1979.

The licensee plans on having the building completed and process equipment and service equipment installed for initial processing in September 1979.

Amendment No. 6 to License No. SNM-777, dated January 15, 1979, imposed condition 26, which requires that the licensee start processing the residues in the existing lagoons by September 1, 1979.

2282 223

10 Amendment No. 6 to License No. SNM-777 mentioned above, authorized the use of a new storage tank for process liquid wastes.

The inspectors noted that the licensee had started collecting waste in this new tank during a physical inspection of the tank.

8.

Procedure Control The licensee has 50P No. O, Revision I, entitled " Standard Opera-ting Procedures", effective July 22, 1977, which establishes:

the format of SOP's; the group that issues SOP's; the managers who review and approve the 50P's; the control of the SOP's; the dis-tribution of the SOP's; and other responsibilities regarding SOP's.

The procedure format given in the 50P incit..es a section entitled "NIS Requirements." This section of the S0P is to address nuclear criticality safety controls, health physics requirements, and other safety and licensing requirements.

Quality Assurance issues the 50P's.

The SOP's are reviewed and approved by the Quality Assurance Manager, the Operations Manager, the Nuclear and Industrial Safety Manager, and the Fuel Recovery Operations General Manager.

Quality Assurance controls the distribution of the 50P's and obtains the obsolete, superceded, or withdrawn procedures.

Quality Assurance also is responsible for periodically reviewing all S0P books to insure their completeness.

Quality Assurance is responsible for the annual review of 50P's for currency and need for revision.

9.

Safety Committees In December 1978, the licensee established a Systems Evaluation Council which has the charter to assist tha General Manager by pro-viding a management overview of the effectiveness, in terms of adequacy and confonnance, of the various systems and procedures utilized in the daily conduct of business by the Fuel Recovery Operation.

The Systems Evaluation Council includes the Resource Systems Manager, the Specialty Chemicals Manager, the Compliance Manager, the Quality Assurance Manager, and the Finance and Administration Manager.

2282 224

11 The Council has established a schedule of systems reviews which include, but are not limited tof the safety system; the housekeeping system; the employee training systemt the accountability system; and the security system.

The Council schedules meetings two times a month, and the meetings have been having a duration of about one and one-half hours.

The staff reporting to the Fuel Recovery Operatons General Manager also acts as a safety committee.

According to the licensee, this activity has been dormant in recent months.

The licensee plans on re,juvenating this safety committee activity of the General Manager's Staff.

Quarterly inspections of the operations are planned as one of the activities.

During this inspection, the UNC Corporate Nuclear Safety Committee was present at the Fuel Recovery Operations facilities.

This committee is examining the nuclear safety programs at all the various UNC sites.

According to the licensee, the committee went over the nuclear safety program at Fuel Recovery Operations.

No recommendation concerning their program was given to the licensee at the time of the inspection.

10.

Nonroutine Eveng According to the licensee, no nonroutine events had occurred at the facility sinca September 15, 1978, the last date of inspection 70-820/78-21.

11.

Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on Feburary 15, 1979. The inspectors presented the scope and fiidings of the inspection.

During the discussion of the item of noncompliance which concerned the improper setting of three criticality monitor set points, the inspector pointed out that proper corrective action had already been taken by the licensee and the corrective action had been verified by the inspector (paragraph 3.a).

2282 225

12 The inspector pointed out that S0P IV-H, Operation of the !;at Cut-Off Saw, called for storing of metal chips in vented container, and the metal chips are stored in unvented containers which are tamper-safed for nuclear material accountability purposes.

The licensee indicated they would assess the situation and take the appropriate corrective action (paragraph 4.b).

The inspector mentioned that there didn't appear to be a nuclear safety limit posting addressing a canner for sealing cans of pro-duct.

The licensee indicated they would take appropriate action (paragraph 3.d).

2282 226 e