ML19296D236
| ML19296D236 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 12/11/1979 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D227 | List: |
| References | |
| 70-0371-79-20, 70-371-79-20, NUDOCS 8003030052 | |
| Download: ML19296D236 (9) | |
Text
.
U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION I Report No.
70-371/79-20 Docket No.70-371 License No.
SNM-368 Priority 1
Category UR Licensee:
United Nuclear Corporation 67 Sandy Desert Road Uncasville, Connecticut 06382 Facility Name:
UNC Naval Products Inspection At:
Montville, Connecticut Inspection Conducted:
October 15-19, 1979 Inspectors:
h./ M V
/2. /N f
. Kinney, Prof 6ct Inspector date date date Approved by:
V
/2 /#/7/)
H. 77Crocker, Chief,Juel Facility Projects date Sddtion, FF&MS Branch Inspection Summary:
Inspection on October 15-19, 1979 (Report No. 70-371/79-20)
Areas Inspected:
Routine, unannounced inspection by a region based inspector of licensee action on previously identified enforcement items; transportation pro-gram; initial use of packages for packaging of radioactive material for transport; routine use of packages for transport of radioactive material; compliance with 00T requirements; operations; nuclear safety; and training.
The inspection involved 28 inspector-hours on site by one region based inspector.
Results:
Of the 8 areas inspected, no apparent items of noncompliance or devia-tions were identified in 6 areas.
Three apparent items of noncompliance were identified in 2 areas: (Infraction - UNC-2600 shipping containers were not in accord with appropriate drawings, paragraph 3.C (79-20-01); Infraction - failure to use lute on threads of 2R containers of DOT 6M shipping container, paragraph 3.C (79-20-02); and Deficiency - failure to follow nuclear safety postings in two instances, paragraph 4 (79-20-03).
Region I Form 167 (August 1979) 8003030o 5 L
DETAILS 1.
Persons Contacted
- D. E. Ganley, President, UNC Naval Products
- T. J. Collopy, Manager, Nuclear Safeguards "W. F. Kirk, Manager, Nuclear and Industrial Safety
- J. E. Neumann, Criticality Specialist R. Schwensfeir, Criticality Specialist D. Luster, Health Physics Specialist G. Marenholz, Plant Superintendent (Second Shift)
The inspector also interviewed nine other licensee employees during the course of the inspection.
- denotes those present at the exit interview 2.
Licensee Action on Previously Identified Enforcement Items (Closed) Infraction (371/79-01-02):
Fuel carts holding fuel bearing com-ponents were not located in defined and designated fuel cart park locations.
The inspector verified that each supervisor / foremen of Shops II, III and IV attended one of the meetings held on March 22, 23, and 27 in which re-in-structions were given on fuel handling procedures.
The licensee considered modifying the criticality control system for storing loaded fuel carts; however, the licensee decided to retain the same unmodified system.
(Closed) Infraction (371/79-01-03):
The licensee failed to identify and enforce proper protective clothing to be worn by personnel entering into a potentially contaminated area.
The inspector verified that the licensee had modified both the " Facility Protective Clothing Requirement" sign and the sign which may be lighted to help avoid confusion over the protective clothing requirements for entry into the potentially contaminated area.
(Closed) Infraction (371/79-01-04):
Four instances of licensee failure to follow radiation protective procedures or failure to provide required equipment were observed.
The inspector verified by review of records that laboratory personnel had meetings on February 2, and April 16, 1979, in which the health physics controls in the laboratory were emphasized.
The inspector verified that the licensee installed a sink at the exit doorway from the Spectrographic
3 Laboratory and that the survey meter is also located at this exit doorway.
The inspector verified that on January 15, 1979, the licensee re-instructed health physics personnel on:
the requirement to use har.d monitors when leaving a posted contamination zone; the handling of 5 gallon pails con-taining contaminated material; and general equipment handling and waste procedures.
(Closed) Infraction (371/79-01-05):
The licensee failed to post a door used as an entrance to a controlled area properly and no shower or change facilities were provided at this entrance.
The inspector verified that the entrance door from the Spectrographic Laboratory into the Sectioning area had a posting showing personnel that they were entering a controlled area.
A sign is also at this door defining which personnel may use this door and the conditions for the use of this door.
(Closed) Infraction (371/7S-01-06):
The Nuclear and Industrial Safety (NIS) Department was not providing written approval of operating procedures involving the handling, storing, processing or shipping of special nuclear material (SNM).
The inspector verified that the licensee reviewed their divisional master list of approved documents and identified those documents requiring NIS approval.
The licensee then reviewed the applicable documents and signed and dated a copy of the master list of approved documents upon approval of each document's contents.
There were a few documents which had to yet be revised to gain NIS approval, and effcrts were being expended to obtain these required revisions.
Currently, the NIS Department receives a copy of each document as it is issued.
If they approve the document, they sign and date an appropriate record.
If they do not, they seek the necessary revisions to the documents.
(Closed) Infraction (371/79-08-01):
A work desk and a table used in handling fissile material were not located in any of three demarked criticality zones for the corrosion coupon test operation.
The inspector verified that the zone for the work desk and table was re-located after an appropriate nuclear safety evaluation was performed and the new zone was authorized.
The inspector also noted that the desk and table were in the demarked zone during this inspection.
3.
Packaging of Radioactive Material for Transport a.
Transportation Program The licensee has a document entitled "SNM Shippina Guide" which provided a program for ensuring safety and compliance with NRC and 00T requirements covering the receipt of radioactive material and
4 the packaging and labeling of radioactive material for transport.
This guide was approved by the Nuclear Materials Manager and the Nuclear and Industrial Safety Manager.
b.
Initial Use of Packages The shipping containers in use by the licensee in packaging SNM for shipment (other than final product) have been in service for some time.
c.
Routine Use of Packages Currently the licensee is using the following shipping containers for packaging Type B quantities of special nuclear material other than final product for transport.
Model No.
Identification Certificate No.
Revision No.
UNC-2500 USA /5641/AF 5641 0
UNC-2600 USA /5086/8( )F 5086 0
00T-6M Type B USA /5908/B( )F 5908 5
The licensee also uses 6J packages for shipment of Type A quantities of uranium.
The inspector reviewed the Certificates of Compliance and the refer-enced drawings and letters for Certificate of Compliance No. 5641 for the UNC-2500 shipping container and for Certificate of Compliance No. 5086 for the UNC-2600 shipping container.
The licensee had all the drawings and references.
However, there is confusion concerning the drawings for the UNC-2600 shipping containers, which is discussed below.
Certificate of Compliance No. 5086 calls for the UNC-2600 shipping container to be constructed in accordance with United Nuclear Corpor-ation Drawing E-20354, Sheets 1 through 5.
The drawings supplied with the United Nuclear Corporation application of January 3, 1967, were:
E-20354, Sheet 1 of 5, Revision 1; E-20354-1, Sheet 2 of 5, Revision 1; E-20354-2, Sheet 3 of 5, Revision 1; E-20354-3, Sheet 4 of 5, Revision 1; and, E-20354-4, Sheet 5 of 5, Revision 1.
The Certificate of Compliance did not state the revision number of the drawings.
The licensee revised the drawings to Revision 2 in January, 1967, mainly to allow the use of a different inner container; however, none of the referenced supplements to the January 3, 1967 application
5 included a reference to these revisions of the drawings.
As far as the licensee is concerned, the shipping containers tested under the hypothetical accident conditions and currently in service were fabricated in accordance with the Revision 2 drawings rather than the Revision 1 drawings.
Also, the written description of the container given in the supplement dated June 14, 1968 confirms the contention that the shipping containers were fabricated according to the Revision 2 of the drawings rather than Revision 1 as follows.
Drawing E-20354-3, Sheet 4 of 5, Revision 1, calls for the bolts and nuts holding the inner container stop bars in place to be %" 1 " long standard bolts and \\" - 20 standard nuts.
Drawing E-20354-4, Sheet 4 of 6, Revision 2, calls for the bolts and nuts to be h" 1" long bolts and " - 13 standard nuts.
The written description of the inner container supports given in the June 14, 1968 supplement states, "Two 1 inch X 3/8 inch X various length steel stop bars each bolted with two standard inch bolts and nuts are placed across the cage openings."
It should be noted that the written description referred to the inch bolts and it referred to stop bars of various lengths to accommodate the use of the different containers provided for by Revision 2 of the druings.
Since the drawings currently on file by the NRC do not completely represent the UNC-2600 shipping container, the licensee should send a supplement to their application for Certificate of Compliance No.
5086 which supplies the correct drawings for the UNC-2600 shipping containers.
The inspector reviewed the licensee's drawings for the UNC-2600 shipping container and then inspected partially disassembled shipping containers, the " Container Specification and Inspection Report," and the route card entitled " Outgoing SNM Shipment (Other Than Final Product) for compliance of the package to the drawings.
The inspector noted the following discrepancies which constitute an item of noncompli-ance. (79-20-01)
Drawing E-20354-3, Revision 2, calls for the inch bolts fastening the inner container stop bars in place to be secured with nuts which are welded to the 3/8 inch thick end plate of the insertable cage.
Instead, the 3/8 inch thick end plates of the shipping containers were drilled and tapped to accept the
" bolts.
Drawing E-20354-1, Revision 2, calls for blocks of oak to be placed in the ends of the inner container.
The licensee does not always use the blocks of oak in the ends of the container, even though they do cushion and block items in the inner con-tainer to prevent shifting during shipment.
6 Drawing E-20354-1, Revision 2, calls for 3 strap assemblies made according to UNC Drawing No. 837AZ be used to hold the inner container closed.
The licensee is using tape instead of the strap assemblies to hold the inner containers closed.
Drawing E-20354-4, Revision 2, calls for the rubber bumper rings placed between the ends of the insertable cage and ends of the outer container to be either solid or laminated rubber with no holes in the rubber other than the center 10 inch diameter hole. One of the rings which had been in service had holes in the ring.
The inspector reviewed the packaging of radioactive material for transport in the D0T-6M Type B container, Certificate of Compliance 5908.
The inspector discussed the procedure given in the route card and the " Container Specification and Inspection Report (CSIR) for the packaging of the radioactive material in the D0T-6M Type B container with the Nuclear Material Control (NMC) personnel, since they prepare the packages for shipment.
The route card has a step which required that NMC clean and inspect shipping containers per the specific applicable CSIR Form." The route card also has a step
" Material placed in inner container is identified and authorized on CSIR." The CSIR identifies the steps to be taken for the preuse inspection of the shipping container.
Also, the CSIR calls for the inner 2R specification container to have the contents properly packaged and the inner cap luted and properly torqued.
The inspector inquired as to the lute being used in the sealing of the 2R specifi-cation container.
The licensee indicated that for approximately the last year lute had not been used as called for in the CSIR because they had been directed to discontinue the use of the lute.
The licensee was unable to find the authority that had given them the direction to discontinue the use of the lute in the closure of the 2R specification container of the DOT-6M Type B container.
Failure to lute the threads of this inner 2R specification container is an item of noncompliance. (79-20-02)
The inspector reviewea the records for preparation of packages for shipment.
The records included the following.
Form 741 - Nuclear Material Transaction Report Factory Shipping Order Verification and Packing Report Container Specification and Inspection Report Smear Survey Record Outgoing SNM Shipment Route Card
7 These records were properly filled out except for the following.
The Centainer Specification and Inspection Reports for sc.me 00T-6M Type B packages indicated that Transport Indexes were not needed, when a Transport Index is always needed for this container. The licensee indicated that the labels placed on the containers were properly filled out with the proper Transport Index indicated.
An Outgoing SNM Shipment Route Card was prepared for a shipment which included a loaded UNC-2600 shipping container and loaded D0T 5pecifi-cation 6J containers.
The data needed for these two containers is different, and the data entered was incoinple+.e.
The licensee should fill out different route cards for each type shipping container used.
d.
00T Requirements The icensee records showed that the licensee applied the proper labels to the containers and these labels showed the package contents, the number of curies of radioactive material, and the transport index.
The licensee's smear records showed that smear surveys for removable contamination were performed, and the removable contamination was well within the DOT limits.
The records showed that the licensee measured the radiation dose rates from packages at the surface only.
Measurements of the dose rates at 3 feet were not taken.
The records examined showed the surface dose rates to be such that the dose rates at 3 feet would have been at background levels.
4.
Operations Review The inspector initiated the inspection during the 4 - 12 shift on October 15, 1979, with inspection of the portions of Building B in which exposed uranium may be handled.
Inspection of the remainder of Building 8 and other buildings were completed later in the inspection period.
During the initial inspection of the sectioning area, the inspector noted an instance in which a nuclear safety posting was not followed.
A fuel element was stored on a work bench located in the coupon pickling zone, and the nuclear safety posting allowed only coupons to be present in the zone.
During a later inspection of the scrap room, another instance of failure to follow a nuclear safety posting was noted.
The licensee had lab coats, cardboard boxes, and a jacket stored on top of a box container having fissile material stored in it. Control 8 of the nuclear safety posting for the scrap room called for keeping hydrogenous material (plastic, cardboard) and combustibles to a minimum in the room.
These instances of failure to follow the nuclear safety postings constitutes an item of noncompliance. (79-20-03)
8 During the inspection of the facility, the inspector noted that the radiation survey meters located at the exits from controlled areas appeared to be working properly.
During the inspection of the cleaning area, a component with a large piece missing was noted.
The foreman responsible for the area was contacted, and he indicated that it had been established that no uranium was at the surface where the piece was missing so that it could be dissolved by the cleaning agents.
5.
Nuclear Safety As was indicated in the prtnious section, the inspector examined the manufacturing areas for th
- sence of nuclear criticality safety postings and compliance with the ~
ags.
Besides the two instances of failure to follow the postings inspector noted a few cf the latches on storage racks for secu.ing fuel elements in the racks were not properly fastened.
Discussion with the licensee indicated this is an ongoing problem which they must continually check and attempt to solve.
The number of improperly fastened latches was small compared to the number of properly fastened latches at the time of this inspection.
However, it was evident that this could become a problem if operating personnel were to become careless.
The licensee has many 55 gallon drums containing various quantities of uranium stored in an area with a posted nuclear criticality safety limit on the cumulative transport indexes of the drums.
The drums in the area may have a cumulative transport index of 75.
The inspector and the licensee determined the cumulative transport index for the drums.
The total of the transport indexes was the same as that given in the log kept by the licensee.
The total of the transport indexes w,s within the posted limit.
The inspector reviewed the Criticality Control Review Log maintained by the Criticality Specialists for the reviews performed during 1979.
Thus far, during 1979 the specialists have had requests for 41 criticality reviews (CCR687-727).
The inspector reviewed four of these reviews. In one case, one criticality specialist performed the review and the other criticality specialist checked the review.
The criticality safety evalu-ations performed in the reviews appeared to have been thorough and conser-vative.
6.
Training The licensee has a professional training staff which has as part of its duties, the indoctrination and training of new emplo,aes and the annual re-orientation of all employees in the safety aspects of work performed
~
9 in the shops and offices of UNC Naval Products.
This staff uses the NIS safety specialist staff to help prepare training video tapes and other materials to prepare tests on material presented, and to grade the tests.
The training staff coordinates the preparation of training materials, schedules the training, and keeps records of the training of each employee.
According to the licensee's records, the licensee has had 58 new hires thus far during 1979. The licensee has completed the indoctrination and training of 25 new people. The others either have not received their security clearances or the training has not been completed.
The licensee conducts the annual re-training from April through September.
The exempt people are scheduled during April through June, and the non-exempt people are scheduled during July through September.
At this time of the inspection, the licensee had four employees who had not attended the re-orientation training.
The licensee had scheduled the completion of this training for these four employeen.
The inspector reviewed the video tapes for the re-orientation on nuclear criticality safety and radiation safety.
The information presented appeared to be suitable.
The inspector noted that the instructions for nuclear criticality evacuations did not stress the need for rapid evacuation.
This fact was pointed out to the licensee.
7.
Exit Interview The inspector met with licensee :_presentatives (deaoted in paragraph 1) at the conclusion of the inspection on October 19, 1979.
The inspector presented the scope and findings of the inspection.