ML19261D769
| ML19261D769 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 02/12/1979 |
| From: | Crocker H, Kinney W, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19261D755 | List: |
| References | |
| 70-0371-79-01, 70-371-79-1, NUDOCS 7906260347 | |
| Download: ML19261D769 (15) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No.
70-371/79-01 Docket No.70-371 License No. SNM-368 Priority 1
Category UR Licensee:
United Nuclear Corcoration 67 Sandy Desert Road Uncasville. Connecticut 06382 Facility Name:
Naval Droducts Division Inspection at:
Montville, Connecticut Inspection conducted:
January 8-12, 1979 79 Inspectors:
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'1 //2.b 9 H. VT.7Crocker, Chief, Fuel Facility c' ate signed PMjects Section, FF&MS Branch Inspection Summary:
Inspection on January 8-12, 1979 (Report No. 70-371/79-01)
Areas Insoected: Routine, unannounced inspection by region based inspectors of the facility licensed programs including:
scope of operation; organization; facility changes and modifications; internal review and audit; safety committees; review of operations; nuclear criticality safety; followup on nonroutine events; and, licensee action on previously identified enforcement items. This inspection was initiated during the evening shift (off-shift) on January 8,1979, and involved 66 inspector-hours onsite by two NRC region based inspectors.
Resul ts:
Of the 9 areas inspected, no items of noncompliance were identified in 7 areas; five apparent items of noncompliance were identified in two areas (Infraction - three instances of improper parking of fuel bearing storage carts (79-01-02), paragraph 4.a. 5.b(1), 5.b(2); Infraction - failure to identify and enforce proper protective clothing for entry into a potentially contaminated Region I Form 12 7 9 0 6 2,6 02f 7 (Rev. April 77)
Inspection Summary 2
area (79-01-03), paragraph 4.c; Infraction - four instances of failure to follow radiation protection procedures (79-01-04), paragraph 5.c(1), 5.c(2); Infraction -
failure to post a used entrance to a controlled area and provide shower and change facilities at this entrance (79-01-05), paragraph 5.c(3); Infraction -
failure of the NIS Department to provide written approval of the operating procedures for operations involving SNM (79-01-06), paragraph 5.f).
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DETAILS 1.
Persons Contacted
- D. E. Ganley, General Manager, Naval Products Division
- J. Neuman, Nuclear Criticality Safety Specialist
- D. Luster, Radiological and Environmental Control Specialist
- R. Gustafson, Division Security Director D. McFadden, Second Shift Superintendent R. Schwensfier, Nuclear Criticality Safety Specialist The inspectors also interviewed twenty five other licensee employees during the course of this inspection.
- denotes those present at the exit interview.
2.
Scope of Ooeration The licensee continues to engage primarily in the manufacture of highly enriched uranium bearing components for the Naval Reactors Program.
3.
Licensee Action on Previously Identified Enforcement Items (0 pen) l'nresolved (371/78-02-01):
Construction of the vertical suspension storage area to previously approved criteria which were not incorporated into the currently approved license dated May 3, 1977. The use of concrete as a nuclear isolation medium was not incorporated into the current license. The licensee has been developing the in-house capability to use the " keno" nuclear safety evaluation code. The code has been developed and is currently undergoing validation testing.
Upon completion, the licensee expects to use this code to evaluate the effect of concrete on the interaction between adjacent storage arrays which are separated by concrete walls.
(Closad) Infraction (371/78-15-01):
Failure to follow procedures:
(1) Attaching safety instructions to a work permit; (2) Improper parking of fuel carts; (3) Failure of health physics personnel to sign a cleanup route card. The inspector verified that:
(1)
Documented awareness meetings were held prior to December 1, 1978 for the Maintenance Department, Facilities Engineering, Equipment 2311 095
4 Engineering, and Tool Engineering groups to reestablish and reiterate their responsibilities in the proper completion of work permits; (2) Documented awareness meetings were held prior to December 1, 1978 by area foreman to refresh material handlers and other employees moving fuel of their responsibilities under "The Material Handling Rules Manual"; (3) The health physics personnel were reinstructed in the proper methods of filling out " color code change cleaning" route cards during documented awareness meetings held prior to December 1,1978.
Examination of a " color code change cleaning" route card in use in Filler Fabrication #2 during this inspection verified that the route card was being completed correctly. Corrective actions on this item of noncompliance have been completed.
4.
Off-Shift Review of Operations The inspectors started this inspection with an unannounced off-shift examination of the facility at about 7:00 p.m., on January 8, 1979.
During this off-shift inspection, the inspectors observed operations and activities in progress and examined the nuclear safety aspects of operations being conducted in the facility.
a.
Storaae of Fuel Bearing Comoonents It was noted that a cart loaded with a fuel bearing component was not properly parked within the designated floor marked zone in the transfer room located between Annex 1 and the east structural machine shop.
The cart could not be properly located because of the inadvertent storage of nonfuel bearing components along the west wall of the transfer room.
This item was identified as an example of noncompliance (79-01-02).
b.
NIS Authorizations The inspector observed that the nuclear safety posting for a storage rack (NIS Authorization III-A-22) located in the northeast corner of Building B had been modified to eliminate the following statement under " Controls" "the above limit and controls may be voided out when and for such time as all fuel is removed from the area and nonfuel only is processed and stored".
Since fuel bearing and nonfuel bearing components appear to be identical in form and shape, the current posting would require both fuel and nonfuel components to be handled as being fuel bearing.
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5 c.
QntaminationControl(EntrancetoFillerFabricationAreas)
As the inspectors entered Filler Fabrication Area No. 2 it was noted that a sign was lighted and flashing on and off. The flashing sign read " shoe covers required". A posting at the entrance to the area described the " - Facility Protective Clothing Requirement".
Item 4 on this sign stated:
" Lab coats and shoe covers required when:
(1) Boxes are or have been opened; (2) During cleanups; (3) Suspected contamination; (4) Visitors present more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> total per day".
Item 5 on the sign stated the following:
"When the above conditions (4.1, 2, 3, 4) exist, signs will be posted making protective clothing and step-off pads mandatory". A white letter on blue background sign was posted at the entrance which read " shoe covers". The inspectors noted that the step-off pad was in place and that shoe covers but not lab coats were available for use. The licensee representative indicated that he read item 5 of the sign posted outside the area to mean that all requirements of item 4 must be satisfied to require the donning of both lab coats and shoe covers and that since he and the inspectors would not be spending more than two hours in the area then lab coats were not required; however, since the area was specifically posted to require shoe covers we were instructed to put on shoe covers prior to entry to the facility. The inspectors and the licensee representative put on shoe covers and entered Filler Fabrication Area #2.
During examination of the facility which was not in operation, it was noted that the Filler Fabrication glove box was open and that a sign was posted above the opening. This sign read "When the box is open - labcoats and shoe covers required".
Upon observing this sign the inspectors and the licensee representative imediately left the area, and each person used an alpha survey instrument to check clothes, body, and shoes for contam-ination. No contamination was found.
Failure to identify and enforce proper protective clothing for entry into a potentially contaminated area was identified as an item of noncompliance (79-01-03).
5.
Operations Review The inspectors examined all areas of the plant to observe operations and activities in progress; to inspect the nuclear safety aspects 2311 097
6 of operations; to check the general state of cleanliness, house-keeping, and adherence to fire protection rules in the facility; and, to review the safety aspects of manufacturing instructions with operators.
a.
Shipping Containers The inspectort noted that a stainless steel UNC-2500 shipping container stored in the empty drum storage area located outside the building between Building A and Building B was marked with a flow type pen to indicate the model number and certificate of compliance number.
The inspector commented that the model number and the certificate of compliance number should be marked on this container by a more durable technique than by means of marking with a flow type pen. This item was discussed at the exit interview.
b.
Storage of Fuel Bearing Comoonents (1) The inspector observed that a fuel storage cart containing fuel bearing components was unattended and not parked in a authorized cart park location between the welding boxes located on the north side of Building A.
This was iden-tified as an example of noncompliance (79-01-02).
(2) The inspector observed that NIS Authorization V B-3, Revision 4, dated February 1978, for the south metal processing line in the Building M vertical " processing" room, states that the zone limit was one fixture.
At the time of this examination, in addition to the one fixture, which was in a processing tank, a fuel cart containing 3 fuel bearing components was also located in the zone.
This was identified as an example of noncompliance (79-01-02).
c.
Contamination Control (B-South)
(1)
During examination of the spectroscopy laboratory on the afternoon of January 10, 1979, the inspectors observed two individuals exiting the laboratory several times without washing hands and surveying for contamination as required. One additional individual was observed walking 2311 098
7 through the spectroscopy laboratory from the sectioning area to the chemistry laboratory, also, without washing hands and surveying for contamination.
The sectioning area is a controlled contamination zone and the spectroscopy laboratory is - limited control (contamination) zone.
In each case observed, protective clothing was put en and/or removed as required. The above instances of failure to follow radiation protection procedures were identified as examples of noncompliance (79-01-04).
(2)
During examination of the B South basement area, two individuals were observed leaving a posted contaminated zone without surveying for contamination as required and four 5 gallon containers were observed removed from this area in the B South basement and hand carried to the spectroscopy laboratory without being surveyed for con-tamination as required by license conditions. The above instances of failure to follow radiation protection procedures were identified as examples of noncompliance (79-01-04).
(3) The facility license requires that all entrances to controlled areas shall be posted with yellow " Caution -
Controlled Area" signs bearing the radiation symbol.
In addition, protective clothing, shower, and change facilities shall be provided for use. The inspectors observed that the door from the spectroscopy laboratory to the sectioning area (a controlled contamination area) was not posted with the required sign and shower and change facilities were not provided for use at this entrance to the sectioning area. This item was identified as an item of noncompliance (79-01-05).
d.
Storace of Cobalt-60 Source The inspector observed that a cobalt-60 source was being stored in a cabinet located in a storage room in the Building B South basement. At the request of the inspector radiation level readings were taken by a licensee representative with an end window gieger counter. On contact with the closed cabinet readings of 12 to 15 mr/hr were obtained in the vicinity of the source. At one foot from the cabinet the radiation levels fell off to about 2 mr/hr.
10 CFR 20.204(a) provides that the 2311 099
8 cabinet need not be posted with a caution sign because of the presence of a sealed source when the radiation level twelve inches from the source container or housing does not exceed 5 mr/hr. However, the inspector commented that the licensee should consider adding additional shielding to the source container in an attempt to reduce the radiation levels.
This was discussed at the exit interview.
e.
Observation of Operations and Discussions with Goerators The inspector observed some of the cleaning operations. The operator used the fixtures specified in the procedures for the components cleaned. The operator appeared to perform the operation safely from a nuclear safety point of view. However, the operator did not follow good safety practice while using acetone to clean a component.
The operator was smoking and he placed a lighted cigarette on the cart next to the workbench where the operator was working. A caution label on the acetone container stated that acetone is highly flammable.
The caution label also called for protective gloves to be worn while handling acetone, and the operator did not wear gloves while cleaning a component with an acetone soaked rag.
The inspector discussed the above with the operator. The inspector also asked the operator about the posted safety precautions which he was required to follow while performing the operations. The operator did not point out the nuclear safety posting as one of the posted safety precautions.
The inspector inquired as to the nuclear safety limits the operator was to follow. The operator correctly described the safety limits for nuclear safety which he was required to follow.
The inspector also discussed the sectioning of pieces and the processing of the sectioned coupons with an operator. The operator was well aware of the nuclear safety limits to be followed during the operations.
The operator showed the inspector the protective equipment he wore while working with acid. These were rubber gauntlets, plastic apron, and a plastic face shield. The operator stated that a procedure for preparing the acid baths was being prepared.
The inspector discussed the blending operation with another operator. The operator demonstrated good knowledge of the nuclear safety aspects of the blending operation.
He was aware of the protective clothing requirements and the atmos-phere requirements for the blending operation.
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9 f.
Approval of Operatina Procedures The inspector reviewed operating proce6res which were supplied to him as the specific operational procedures which described the cleaning of components, the sectioning and processing of sample coupons, and the blending of charges. The procedures reviewed are listed below.
M0P-U-014 Grade A Cleaning M0P-U-015 Grade B Cleaning M0P-W-196 Fixture and Criticality Control List PS-W-245 Sectioning and Coupon Processing PS-S-245 Sectioning and Coupon Processing M0P-U-046 Blending of Charges In all instances, the procedures were prepared by Engineering and approved by Engineering and Manufacturing.
In the case of the Manufacturing Operating Procedures (M0P's), Engineering prepared and reviewed the procedures, and Engineering and Manufacturing management approved the procedures. The Nuclear and Industrial Safety (NIS) Department approved only one procedure, M0P-W-196.
Revisions to procedures were prepared by Engineering and approved by Engineering and Manufacturing management. The NIS Department did not show written approval of any of the revisions to procedures including M0P-W-196.
In Section 2.5, Operation Control, of the Conditions and Specifications of License No. SNM-368, it is clearly stated that operations and procedures involving the handling, storing, processing, or shipping of SNM require NIS approval.
In Section 2.5.2, Operational Procedures, the following is stated:
" 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, in Section 2.5.2.1, NPD Oraanizational and Policy Manual, policy statements con-cerning an integrated system of operating and administrative procedures are given. The following is stated in these statements:
"Any procedure involving the handling, storing, processing, or shipping of SNM shall require NIS approval of the procedure".
Failure of the NIS Department to provide written approval of the operating procedures for operations involving special nuclear material (SNM) is an item of non-compliance (79-01-06).
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10 g.
Safety Content of Ooeratina Procedures The procedures for cleaning of components and parts, M0P-U-014 and M0P-U-15, had a statement related to nuclear safety which required that a fixture per the route card or applicable fixture list be used. These procedures also required that operators follow posted safety precautions in the area as applicable.
The procedures for sectioning of pieces and processing of the sectioned coupons, PS-W-245 and PS-S-245, had statements related to nuclear safety which required the operator:
(1) to check a sectioning log and clean the equipment if required; and (2) to observe posted criticality limits. These procedures also had special precautions for use of acids.
These pre-cautions stated that the acids could cause painful and dis-abling burns and blindness if allowed to come in contact with skin and eyes. Also, any accident involving inhalation of acid fumes was required to be reported to supervision. The procedures did not call for any special protective equipment to be used in working with the acids, which could well contain radioactive material.
The procedure for blending charges called for the operator to wear a protective suit with clean rubber gloves.
The procedure also called for a glovebox atmosphere of low oxygen content for fire safety.
6.
Nuclear Criticality Safety a.
Criticality Monitors The inspectors examined criticality monitors located through-out the facility and observed that each monitor appeared to be operating properly.
Licensee records examined by the inspector indicated that the criticality monitors had been calibrated quarterly during the time period June 24, 1978, through December 10, 1978.
Records also indicated that the monitors had been recalibrated whenever repair work was done prior to placing the affected unit back into operation.
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11 b.
Raschig Ring Tanks The inspector examined licensee records which indicated that vessels RT-1 and RT-2 waste receivers had been inspected at least once each month from June 30, 1978, through December 12, 1978, to verify raschig ring content levels.
c.
Pickling Fixture Records The inspector examined records of monthly pickling fixture checks, for fixtures located in the Building M metals pro-cessing area, for the time period August 28, 1978, through January 7, 1979. These records indicated that the fixtures had been checked at least once each two months as required and that where necessary, corrective actions had been taken to repair defective fixtures. The corrective actions taken were recorded in the check record log book.
d.
Criticality Control Review Loa The inspector examined the criticality control review log for the time period June 9,1978, through January 10, 1979 (CCR 642 through 688). The inspector noted that few of the CCR's examined required dual review and that most of the CCR's involved realignment of criticality zones based on NRC approved criteria. An indepth review was conducted on the following CCR's selected at random.
(1) CCR-646, "Radwaste Tank Cleanout," dated July 21, 1978.
An attempt was made to establish an indefinite time interval between tank cleanouts on the basis of nuclear safety considerations. The conclusion was reached that an indefinite time interval could not be established.
(2) CCR-651, " Component," " Storage in High Bay Bunkers,"
dated August 28, 1978. Additional storage controls were established and the storage of these components was approved on September 18, 1978.
(3) CCR-661, " Metal Processing (Fuel Component) Fixtures 303455 and 303462," dated September 11, 1978.
Criticality limits and conditions of use were established. The fixtures were approved on November 1,1978.
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12 (4) CCR-679, " Interim In-Transit Storage of (Fuel Components),"
dated November 17, 1978.
Review of the request and the stipulated handling procedure indicated that specific approval for this type of storage was not required.
In each case reviewed by the inspector, the licensee appeared to use a conservative approach in the evaluation and each evaluation which established a new limit of U-235 containing fuel was given a dual review as required.
e.
Internal Review and Audit The inspector questioned licensee representatives regardinc the conduct of internal reviews and audits during the time period October 11, 1978, through December 29, 1978. The inspector reviewed the reports of 25 internal NIS inspections which were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular and off-shift hours and examination of required equipment inspection reports. The inspector verified that corrective actions had been taken in each instance which was identified by the licensee as requiring corrective action.
7.
Organization a.
The inspector examined the current organization of the Nuclear Products Division.
Following is a listing of management per-sonnel reporting to the General Manager effective October 16, 1978.
D. E. Ganley, (Acting) General Manager, Naval Products Division R. McVerry, Administrative Assistant R. C. Johnson, Vice President, Finance B. J. Lowe, Vice President, Quality Control J. C. Andress, Senior Projects Manager, D-W Projects W. Stanton, Project Leader, D-W Projects T. J. Collopy, (Acting) Manager, Nuclear Safeguards J. P. Corrigan, Project Manager, D-G Projects M. J. Hannon, Director, Personnel / Training / Administrative Services F. R. Luszcz, Manager, Manufacturing J. V. Olson, Manager, Materials T. A. Shea, Senior Projects Manager, S-G Projects J. J. Vickary, Special Projects Manager G. H. Waugh, Manager, Engineering 2311 104
13 b.
The current organizational structure of Nuclear and Industrial Safety and Nuclear Material Control groups is as follows effective October 16, 1978.
Nuclear and Industrial Safety T.J.Collopy,(Acting) Manager,NIS/ Medical W. Kirk, Manager NIS R. Berzins, Industrial Nurse (1st)
S. Monahan, Industrial Nurse (part-time)
S. McAneeny, Industrial Nurse (2nd)
E. Barton, Safety Specialist T. Gutman, Consulting Engineer D. Luster, Health Physics Specialist J. Neuman, Criticality Specialist R. Schwensfeir, Criticality Specialist R. Brubaker, M. D., Plant Physician Nuclear Material Control T.J.Collopy,(Acting) Manager,NuclearSafeguards T. J. Collopy, Manager, Nuclear Material Control J. L'Heureux, Foreman, N. M. C.
A. Wolvendyk, Nuclear Material Controller R. Gustafson, Security Director J. Mcdonald, Security Administrator B. Johnson, Security Shift Supervisor W. Ormeno, Security Shift Supervisor D. Vernon, Security Shift Supervisor c.
The inspector discussed the organizational structure with a licensee representative and pointed out that the current organization of the Naval Products Division does not correspond with the descriptions presented in sections 2.1, 2.2, and 2.3 of the approved license application.
For instance, the Manager, Nuclear and Industrial Safety (Section 2.2) and the Manager, Nuclear Materials (Section 2.3) are to report to the Manager, Administrative Services who in turn is to report to the Vice President and General Manager (Section 2.1). Currently the Acting General Manager has delegated the responsibilities 2311 105
14 of the nuclear materials management, nuclear criticality, and radiological safety programs to the Acting Manager fluclear Safeguards (a new position). Although there are no safety problems associated with the current organization, the inspector requested that the organizational aspects of the approved license application be updated by means of an amendment application to NRC-NMSS. This was discussed at the exit interview.
8.
Safety Committees The licensee has delegated responsibility for facility safety reviews to the Nuclear and Industrial Safety Department. This department overviews Health Physics, Nuclear Criticality, and Industrial Safety throughout the facility through random inspections and audits of the facility.
Results of the random inspections re-lative to nuclear criticality safety were previously discussed in paragraph 6.e of this report.
In addition, the facility manufactur-ing department has established a Plant Housekeeping Conmittee which performs monthly inspections. The inspector examined reports of these inspections conducted between July 19, 1978, and December 7, 1978.
The reports listed action items observed during the in-spection.
The reports also indicated the ground rules for com-pletion of the action items including responsibility for completion, 4te for the review, and the date for the next inspection.
9.
Nonroutine Events It was determined by the inspector through discussions with licensee representatives that no nonroutine reportable or non-reportable events, within the scope of this inspection, had occurred at this facility since the last inspection (70-371/78-15).
10.
Facility Chances and Modifications The inspector determined through discussions with licensee rep-resentatives and through examination of the facility that no sig-nificant facility changes and/or modifications had been installed or initiated since the last inspection (70-371/78-15).
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15 11.
Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on January 12, 1978, at 10:30 a.m.
The inspector suninarized the scope and findings of the inspection.
Licensee representatives made the following remarks in response to items discussed by the inspector.
stated that the protective clothes requirement postings and flashing signs at the entrances to the Filler Fabrication Areas had been modified to clarify the entrance requirements when the gloveboxes are open and/or the area is in a cleanup operation (paragraph 4.d).
stated that the containers removed from the B South basement area (a posted contaminated area) had not been individually surveyed for contamination. These containers will be surveyed for contamination as necessary (paragraph 5.c(1)).
stated that the door between the spectroscopy laboratory (a limited control area) and the sectioning area (a controlled area) was there not as a personnel passageway but was to be used to transfer drums and materials back and forth for non-destructive analysis. The door will be posted (paragraph 5.c(3)).
stated that the source stored in the cabinet in the B south basement contributed only to a potential extremity dose to personnel.
However, a means of reducing the radiation dose would be investigated and instituted (paragraph 5.d).
stated that there was no intent to have the NIS Department approve all operating procedures associated with the handling of SNM as apparently required by the license and that the intent in the license would be clarified by a submittal to NRC-NMSS (paragraph 5.f).
stated that the description of the Division organization in the license would be clarified in an application to be submitted to NRC-NMSS (paragraph 7.c).
The inspector also informed the licensee that the new project inspector for this facility would be Mr. W. Kinney as of the end of this inspection.
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