ML19261D767
| ML19261D767 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 02/12/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19261D755 | List: |
| References | |
| 70-0371-79-01, 70-371-79-1, NUDOCS 7906260342 | |
| Download: ML19261D767 (4) | |
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APPENDIX A NOTICE OF VIOLATION United Nuclear Corporation Docket No.70-371 Naval Products Division Based on the results of an NRC inspection conducted on January 8-12, 1979, it appears that certain of your activities were not conducted in full compliance with NRC regulations and the conditions of your facility license as indicated below.
Items A through E are infractions.
A.
Condition 10 of your facility licenta which incorporates Section 2.5, " Operation Control," of your approved license application dated March 28, 1977, requires, in part, in Section 2.5.1, " General,"
that NPD Management shall require supervision at all levels to assure themselves that all pertinent regulations, controls, or procedures relative to nuclear criticality safety shall be followed by supervision and all operating personnel.
The United Nuclear Corporation Naval Products Division " Material Handling Rules Manual," dated August 3, 1973, under " Criticality Control Rules," in item 3, states, in part, that designated fuel cart parks will be defined.
Item 5 states, in part, that fuel carts in an aisle must be attended at all times.
HIS Authorization V B-3, Revision 4, dated February 1978, states that the nuclear safety limit for the south metal processing line in the Building M vertical " processing" room is - one fixture.
Contrary to the above, on January 8 and 9, 1979, supervision did not assure themselves that all pertinent procedures and controls relative to nuclear criticality safety had been followed by supervision and all operating personnel in that:
1.
One fuel cart containing a fuel bearing component, which was located in the transfer room between the East Building Annex 1 and the East Structural Machine Shop, was not parked in a defined, designated fuel cart park location and another fuel cart containing fuel bearing components, which was located in the aisle between the welding boxes in Building A, was not parked in a defined designated fuel cart park location and was not attended.
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Appendix A 2
2.
The authorized limit of one fixture in the south metal processing line in the Building M vertical " processing" room was exceeded in that one fixture containing a fuel bearing component was in a processing tank and a fuel cart containing three fuel bearing components was also located in the zone.
B.
Condition 10 of your facility license which incorporates Section 2.5, " Operation Control," of your approved license application dated March 28, 1977, requires, in part, in Section 2.5.1, " General,"
that NPD Management shall require supervision at all levels to assure themselves that suitable control measures shall be prescribed and that all pertinent regulations, controls, or procedures relative to radiological safety shall be followed by supervision and all operating personnel.
Contrary to the above, on January 8, 1979, supervision did not assure themselves that suitable contamination control measures were prescribed in that signs posted at the entrance to Filler Fabri-cation Area No. 2 and a sign posted in the area were not consis-tent. One sign at the entrance entitled " Facility Protective Clothing Requirements" prescribed in item 4 that lab coats and shoe covers were required under four conditions, including:
(1)"When boxes are or have been opened."
Item 5 on this sign stated, "When the above conditions (4.1, 2, 3, 4) exist, signs will be posted making protective clothing and step off pads mandatory." The signs posted at the entrance called only for " shoe covers," not for lab coats and shoe covers. The sign posted at the Filler Fabrication glove box stated, "When the box is open - labcoat and shoe covers required." Based on the inconsistent signs at the entrance, the licensee representative and the inspectors, as instructed, put on only shoe covers prior to entry into Filler Fabrication Area No. 2, when lab coats and shoe covers were actually required.
C.
Condition 10 of License No. SNM-368 authorizes use of special nuclear material in accordance with your application revision dated March 4, 1977. Section 4.4.1 of this application, " Zoning,"
which defines controlled areas and limited control areas and the control measures associated with the areas, requires the following:
1.
"All personnel shall be cognizant of entering such an area and shall observe the special protection measures applicable to that area".
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Appendix A 3
2.
A hand washing facility and alpha survey meter or hand monitor shall be provided at the ex1t from the controlled area and limited control area".
3.
" Permissible contamination levels shall be established by Health Physics and/or Quality Control and shall be evaluated by Health Physics as necessary".
4.
"Special contamination control zones established temporarily or for quality control purposes, which have sink and shower facilities accessible, but not necessarily in the control zone, may be approved by Health Physics".
Contrary to the above, on January 10, 1979, licensee personnel did not comply with the above requirements in the foll ming instances.
1.
Two individuals exited from the spectroscopy laboratory, a limited control area, several times, and another individual, exited from the sectioning area, a controlled area, via the spectroscopy laboratory in each case without washing their hands and performing a personal contamination survey as required by items 1 and 2 above.
2.
There was no personnel survey meter available for use at the exit of the spectroscopy laboratory, a limited control area, as required by item 2 above. There was a survty meter available inside this area.
3.
A special contamination control zone was established temporarily in the B-south basement. There was no personnel radiation monitor available for use by personnel leaving the zone, and there were no sink and shower facilities accessible as req'uired by items 2 and 4 above. Also, two individuals were observed leaving the special contamination zone without performing a personal survey at the nearest personnel survey monitor as required by items 1 and 2 above.
4.
Licensee personnel removed four 5 gallon containers from the posted contamination zone in the B-south basement without permissible contamination levels on these containers being evaluated by Health Physics as required by item 3 above.
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Appendix A 4
D.
Condition 10 of your facility license which incorporates Section 4.4.1, " Zoning," of your approved license applicated dated March 4, 1977, defines controlled areas.
It also states, in part, that "such areas shall be clearly indicated at all entrances with magenta and yellow CAUTION - CONTROLLED AREA signs bearing the radiation symbol. Thus, all personnel shall be cognizant of entering such an area and shall observe the special protective measures applicable to that area".
In addition, it states that " shower and change facilities shall be provided for use in the controlled area".
Contrary to the above, on January 10, 1979, the door from the spectroscopy laboratory to the sectioning area (a controlled area) was used as an entrance / exit point into the sectioning area and was not posted with a magenta and yellow Caution - Controlled Area sign bearing the radiation symbol.
In addition, shower and change facilities were not provided for use at this entrance / exit point.
E.
Condition 10 of your facility license which incorporates Section 2.5, " Operation Control," of your approved license application dated March 28, 1977, requires, in part, in Section 2.5.2, " Operational Precedures," that " specific operational procedures shall be set up to control the handling of special nuclear material. These procedures shall be followed from the receipt of incoming material through all manufacturing phases of the product, up to and including shipment.
Operations involving SNM shall require prior written approval by the NIS Department".
Further, Section 2.5.2.1, "NPD Organizational and Policy Manual," states that "Any procedure involving the handling, storing, processing, or shipping of SNM shall require NIS approval of the procedure".
Contrary (NIS) Department did not provide written approval of operating to the above, on January 11, 1979, the Nuclear and Industrial Safety procedures involving the handling, storing, processing, or shipping of special nuclear material (SNM) including the following procedures:
M0P-U-014, M0P-U-015, PS-W-245, PS-S-245, M0P-U-046, and the revisions of M0P-W-196.
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