ML20011A066
| ML20011A066 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 08/26/1981 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011A065 | List: |
| References | |
| 70-0371-81-13, 70-371-81-13, NUDOCS 8110060479 | |
| Download: ML20011A066 (10) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 70-371/81-13 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:
l'NC Naval Products Inspec. tion at: Montville, Connecticut
/// ply 13-7,1981 Insp.ction Conduct
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Inspectors:
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W.~ W. Kinneygro ect Jdispector clite st'gned
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Approved b a
H. W. Crocker, Ch'ief, Fuel Facility d'a te' ~s fg n ed Projects Section, PB #2, DRPI Inspection Summary:
l Inspection on July 13-17,1981 (Report No. 70-371/81-13)
Areas Inspected:
Routine unannounced inspection by a region-based inspector of:
licensee action on previously ic'entified enforcement items; organization; nuclear criticality safety; operations; facility changes and modifications; safety committee activities; internal reviews and audits; procedure control; and liquid holding ponds.
The inspecton involved 32 inspector-hours onsite by one NRC region-based inspector.
Results: No items of noncompliance were identified.
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g DETAILS 1.
Persons Contacted
- G. O. Amy, Executive Vice President
- W. Kirk, Manager, Nuclear and Industrial Safety
- J. Neumann, Criticality Specialist D. Luster, Health Physics Specialist E. Barton, Safety Specialist J. Czapski, Engineer The inspector also interviewed a health physics technician, a production supervisor, and four operators during the inspection.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Identified Enforcement Items (Closed) Unresolved Item (70-371/78-02-01): The nuclear safety analysis for the vertical suspension storage area in the license issued prior to May 3, 1977, used concrete as an isolation media between the vertical suspension storage area and the Colson rack storage area.
The use of concrete as a nuclear isolation media was not incorporated in the present license dated May 3, 1977. The inspector found that the licensee had analyzed each of the storage arrays involved as an infinite array.
In the case of the vertical suspension storage array, water at 0.05 gram per cubic centimeter was used as a moderator.
In the case of the Colson rack array water at 0.01 gram per cubic centimeter was used.
In both analyses the infinite arrays were safe. Therefore, the arrays could be placed immediately next to each other without the need for concrete as an isolation media.
(Closed) Infraction (70-371/78-16-02): The licensee failed to take remedial actions in response to air samples containing concentrations in excess of control limits. The inspector verified that the form used to report the daily concentration values for the stack samples was revised to show the action limits.
The health physics technician was aware of the limits and the action to be taken if limits were exceeded.
(Closed) Infraction (70-371/79-20-01): The licensee was using UNC-2600 shipping containers which were either not constructed in accordance with the drawings or were not using the materials called for in the drawings specified in Certificate of Compliance No. 5086. During Inspection No.
70-371/80-12 the inspector verified the licensee's corrective action except for the revision of the Container Specification and Inspection Report (CSIR) form.
During this inspection, the inspector verified that the CSIR form for the UNC-2600 shipping container was revised in April 1981.
3 (Closed) Infraction (70-371/80-12-01): The liquid level in tank RT-1 was as much as 3 inches above the raschig rings, and the requirement allowed the liquid level to be only 1 1/2 inches above the raschig rir.gs. The inspector verified that the tanks in service now have liquid level alarms with signals in either the health physics area of the basement or to an always attended location.
(Closed) Deviation (70-371/80-12-02): This deviation concerned the licensee's failure to revise the CSIR form for the UNC-260 shipping container. As discussed above, the licensee revised this form in April 1981.
3.
Organization UNC Naval Products is becoming a division of UNC Resources Corporation rather than being a division of the United Nuclear Corporation.
Mr. D. E. Ganley is the president of UNC Naval Products. The President's staff as of June 8,1981 is given below.
G. O. Amy, Executive Vice President 4
R. W. Barret, Vice President, Business Planning and Marketing G. H. Waugh, Vice President, Quality Control R. B. Andrews, Manager, Engineering A. A. Bombassei, Senior Project Manager M. E. Cassidy, Project Manager J. P. Corrigan, Senior Project Manager R. B. Guest, Cc9 troller, Finance J. C. Parker, Renager, Human Resources T. A. Shea, Operations Manager, Galli'i-Lane Facility J. J. Vickary, Senior Project Mar e Presently, the manager of Nuclear and Industrial Safety (NIS) reports to Executive Vice President Amy.
The NIS organization is given below.
W. Kirk, Manager, Nuclear and Industrial Safety J. C7apski, Engineer "A" D. Luster, Health Physics Specialist J. Neumann, Criticality Specialist E. Barton, Sattty Specialist R. Berzins, Industrial Nurse (1st)
S. Monahan, Industrial Nurse (2nd)
R. Brubaker, M.D. - Plant Physician
4 Mr. T. Gutman, an engineering specialist in Nondestructive Testing, and R. J. Schwensfeir, Jr., a former employee currently employed as a consultant, are working for NIS to resolve the questions from Uranium Fuel Licensing Branch of NRC:NMSS concerning their March 1978 amendment application to use a surface density method to provide more general nuclear criticality safety criteria.
4.
Nuclear Criticality Safety l
a.
Inspection of Facility The inspector physically inspected the facility as the initial effort in the inspection. The inspector found that, in general, nuclear criticality safety postings were well located and visible, and personnel appeared to be following the posted limits. There l
were some exceptions which are discussed below.
In the QC area next to the room in the "D&V" area, NIS Authorization No. II-B-4, Revision 3 (06-25-81), allowed a 1 ounce can of residual material in the area along with other material.
There was a 2 ounce can for residual material rather than a 1 ounce can.
The licensee placed the residual material into a 1 ounce can.
The posted NIS authorization for a fuel storage area in the vicinity of the stores cage was inaccessible and could not be read because drums of non-special nuclear material were stored in front of the posting. The licensee moved the posting to an accessible location.
In the pack welding area, there appeared te be three fuel packs in a welding zone and the NIS authorization allowed only one fuel pack in the welding zone.
Further examination of the situation revealed that two of the " fuel packs" actually were developmental units which contained no fuel. The route card for the two developmental units was a dummy element route card.
The route card called for the dummy elements to be handled as if they were real elements'containing fuel from a criticality safety standpoint. The engineer in charge of the developmental work stated that the two developmental units really weren't dummy elements, but that they contained no fuel.
He had simply used the dummy element route card as a mechanism to get the units on tFe floor so that'the developmental work could be performed. The licensee started handling the material in accordance with the route card, and stated that in the future route cards would be modified appropriately and operators would follow the route card to assure consistent handling of material from a nuclear criticality safety point of view.
In the XRP room the NIS authorization did rot address a table in the area which had fuel on it.
Instead, the authorization only referred to the storage racks and other work stations. Also, the posting was outside the XRP room rather than inside the room readily
5 visible to the sorking personnel. The licensee indicated the NIS authorization would be changed to include all the zones in the room and the posting would be moved inside the room.
In the sectioning area, it was noted that the operators did not clean out a machine as required by the NIS authorization for the machine. lne oper&tions personnel showed the special authorization given to allow them to accumulate more fines than normal.
Ordinarily, the machine had to be cleaned after 300 grams of fuel, as fines, were accumulated in the machine.
In this instance, they were allowed to accumulate 350 grams of fuel as fines.
b.
Criticality Alarm Instruments The inspector inspected the 35 NMC Model GA-2T and GA-2TO instruments n.easuring gamma radiation at various locations in the facility. The white light of each instrument was on indicating that power was on.
The inspector also inspected the alarm console. All of the lights on the alarm console were on white indicating no problems.
According to the security officer at the console, the yellow light on one of the instruments had gone on earlier in the day. The health physics technician said that the instr ument background setting had drifted so that the lower level failsafe value was indicated by the instrument.
The health physics technician reset the background setting of the instrument to approximately 0.4 mR/hr.
The inspector reviewed the health physics records of the adjustment and calibration of the criticality monitors. The records show the licensee performed the adjustments and calibrations on a quarterly basis with the last calibration being made on May 10, 1981.
According to the procedure, the instrument is set so that the amber
" failsafe" light comes on when the instrument registers 0.1 mR/hr.
The instrument is set so that the background radiation reading is from 0.4 to 0.5 mR/hr.
Using a radiation source at the proper distance from the instrument to give 7 mR/hr of radiation to the instrument, the blue alert light is set to illuminate.
Using the source at a distance so that the radiation is 18 mR/hr, the alarm setting is established on the instrument.
The inspector also reviewed the records o.1the monthly horn checks for the period of August 1980 through June 1981. During the April 15, 1981 horn audibility test, areas were found where the horn audibility was judged to be inadequate by the licensee.
The licensee has obtained additional horns and is installing them as needed to obtain adequate horn audibility.
6 c.
Licensee Nuclear Criticality Safety Inspection Reports and Violation Reports The inspector reviewed nuclear criticality inspection reports 80-37 through 81-64. These reports listed 61 items requiring correction.
The items were corrected according to the reports.
The inspector reviewed the licensee's Log of Nuclear Criticality Safety Reports. During 1980 the licensee issued 22 violation reports.
Thus far during 1981 the licensee has issued 13 violation reports.
Corrective action was documented on all but the last three items.
d.
Criticality Control Reviews The inspector examined the criticality control review log and selected four of the criticality control reviews (CCR's) for further examination. The CCR's showed that the licensee made' adequate evaluations of the requests for criticality control review and took appropriate action from a nuclear safety standpoint. As of the date of the inspection the last CCR logged was CCR-765.
e.
IE Circular No. 80-20: Cha'gec_in Safe-Slab Tank Dimensions The licensee does not use solutions containing fissile material in its processes; therefore, they do not have any tanks using geometry for nuclear criticality safety. The problem of changes to dimensions of safe-slab tanks holding fissile material solution does not pertain to the licensee.
5.
Operations Review The inspector examined most areas of the plant to observe operations and activities in progress.
The operational areas of the facility appeared to be in a good state of housekeeping.
The inspector reviewed 6 procedures located at the work stations and reviewed them with operators to assess the operator's knowledge of the operation and safety implications of the work.
Procedures involved were:
M0p-W-046, Revision 6 M0P-W-047, Revision 5 M0P-W-048. Revision 11 MSP-W-001, Revision 3, General Weld Procedure WP-W-009, Revision 4, Sub-assembly Bracket Welding No I.D. Number, Waste Compactor Operation
7 The operators were knowledgeable of the safety implications and nuclear safety limits of the operations.
They were also aware of the potential for personal radioactive material contamination. While the welder performed his work and before starting to weld, the welder asked the inspector and the licensee representative to leave the_ room.
Upon inquiry after return, the welder told the inspector that he had asked the inspector and licenses representative to ve because of their lack of proper eye protection to observe welding.
The inspector also discussed the hradling of material into and out of the Colson racks with two material
-ndlers.
These individuals demonstrated good knowledge of the safety impilcations of their work. They pointed out "do not-operate" tags on some Colson racks which prohibited their use until they met load handling tests.
During the inspection, the inspector noted that protective clothing lab coats were hung one on top of the other.
The potential of contaminating the inside of the protective clothing was pointed out to the licensee.
6.
Facility Changes and Modifications The licensee has modified facilities for installation of equipment-for the Modified Fuel process (MFP).
c The licensee is also installing an Advanced Poison Facility in their storage building; a new furnace in Building A; and a new main entrance to the facility 'o provide enhanced physical security.
The inspector inquired as to the work control procedures the licensee has to assure that hazards to personnel and property are recognized and dealt with during the f.;ility modification and equipment installation work.
The licensee provided the inspector with. copies of Maintenance and Plant Services Procedure, MPSP-104-G, Revision 0, dated May 1, 1978, entitled
" Work Permit", and Manufacturing Department Procedure MDP 107, Revision 1, dated May 23, 1978, entitled, " Work Permit Procedurs".
The purpose of each of these procedures was given as follows.
"The purpose of this procedure is to establish a Work Permit system to control the maintenance, repair, remodeling, and construction activities within the Naval Products Division when such activities require special precautions to protect people, product, equipment, and/or plant facilities."
According to the procedure, the following activities require work permits:
Welding (non product)
Oxy - Acetylene Burning and Cutting Painting Construction
8 Remodeling Overhead (over product flow areas)
Soldering / Brazing (excluding such work done within control cabinets or in Maintenance areas)
Sheet Metal Work Grinding Equipment Installation, relocation Asbestos, fibrous glass or other mineral fiber l
Any other activity requiring special precautions for the protection of people, product, equipment or plant facilities.
The Work Permit is defined as a document issuad prior to the start of maintenance type activities (as outliced above) for the purpose of providing specific instructions to the personnel involved in such activities.
The procedure outlines the responsibilities of the interacting groups concerned with the activities. These groups include: the Performing Department; the Requesting Department; the Maintenance Department; Quality Control Department; Engineering Department; NIS Department; Plant Facilities Department; and Manufacturing Department. The procedure j
appears to be well conceived with an app *opriate Work Permit form and attachments to the form giving specific instructions for electrical work; painting, construction, major equipment repair; equipment relocation; welding; overhead rigging; sheet metal work; piping and plumbing, and work with asbestos, fibrous glass or other mineral fiber.
The inspector then inspected the work sites. The work sites appeared to be typical for equipment installation sites. When he asked to see the Work Permits for the installation of the Modified Fuel Process and Advanced Poison Facility, the licensee representatives stated that Work Permits were not needed for these activities because the activities were in areas separated from the operating fuel manufac' iring areas. This situation does not appear to be ln accord with the defined Work Permit Procedure. Although the use of this Work Permit Procedure is not required by the NRC license, use of the procedure by the licensee in all areas would be prudent.
7.
Safety Committee Activities The inspector reviewed the available monthly Shop Safety Committee inspection reports for the period of August 1980 through June 1981.
The safety committees use a checklist for noting conditions.
The chacklist includes fire protection, housekeeping, tools, personal protective equipment, machinery, pressure equipment, unsafe practices, first-aid, and miscellaneous items.
The safety committees continued to find numerous items requiring corrective action in Shops I and II. The reports for inspections of Shops III & IV showed improvement both in fewer number of items requiring correction and fewer repeat items.
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8.
Internal Review and Audit The inspections of the facilities by the nuclear safety engineer was discussed in section 4.C. of this report.
The 1980 annual audit of criticality safety was performed on August 20, 21, and 22, 1980, by a criticality specialist from outside UNC Naval Products. The written report to the licensee for this audit was dated July 2, 1981. According to this report, the audit disclosed no serious problems with the licensee's nuclear safety program.
The auditor did give suggestions for improvements in the program.
9.
Procedure Control The licensee has several procedural systems.
The license application addresses the NPD Organizational and Policy Manual, Standard Operating Procedures, Manufacturing Operating Procedures and Quality Instructions, Radiation Protection Instructions, and Route Cards. As indicated previously in Section 6 of this report, the licensee also has Maintenance and Plant Services Procedures and Manufacturing Department Procedures.
The licensee also has Division Operating Procedures and Engineering Department Procedures.
The foregoing show that UNC Naval Products is oriented toward having their activities defined by procedures.
The licensee's procedures define the system to assure that items are manufactured according to the appropriate procedures and to assure that the performance of the work is well documented.
Division Operating Procedure, D0P-006, Revision 3, dated July 17, 1980, entitled " Procedure Control" defines the system for controlling the issue, revision and r
withdrawal of documents authorized fc use on specific contracts and define the system to provide a recoru of the manner in which all permanent document revisions were imp'emented.
This system uses a Process Information Control Center for implementation.
I The route card system is a basic document in the licensee's procedure control system.
Nuclear Industrial Safety reviews and approves manufacturing route cards for compliance with NIS requirements.
Policy Statement 13.02-2 dated November 11, 1980, defines this requirement as does Engineering Department Procedures, EDP #102, " Preparation of Manufacturing Route Cards" and EDP #104, " Document Review".
The inspector examined manufacturing route cards in use in the operating areas and noted that there was a signature block for the NIS Manager which was signed and dated.
In the area of radiation protection instructions, the Health Physics Specialist has written and approved the " Supervisor's Health Physics Guide".
These procedures are controlled by the Health Physics Specialist.
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- 10. Ponds for Aqueous Wastes The licensee has two ponds to receive the pickling, cleaning, and rinse
)
solutions used with the clad components. These solutions c!o not contact the uranium in the components which are cleaned.
According to the licensee, these ponds are intended to release the water to the ground. The water going to the ponds is analyzed. A monthly composite of weekly samples is analyzed for uranium, nitrates, phosphates, fluorides, oil and grease.
The licensee indicated they 1
i recently found trace uranium in two samples of the water.
Investigation i
showed that the vessel in which the samples were placed was contaminated.
The health physicist involved in using the contaminated vessel was retrained in proper sampling techniques.
The licensee stated that the liquid ponds are not a potential source for contamination of the ground water with radionuclides.
11.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph
- 1) at the conclusion of the inspection on July 17, 1981.
The scope of the inspection was presented, and the following items were discussed.
i The minor problems discovered in the following of nuclear safety postings were discussed. The failure of personnel to properly implement UNC Naval Products policy to handle non-fuel-bearing components as if they were fuel-bearing in the pack weld area was discussed. The licensee indicated they would take appropriate action to assure that their policy is followed properly.
(paragraph 4.a).
The fact that the criticality alarm horns were found to not be audible in all plant locations was discussed.
The licensee indicated they are correcting this situation.
(paragraph 4.b)
The poor practice of hanging protective labcoats on top of the outside of other labcoats was discussed. The licensee indicated they would take appropriate action (paragraph 5).
The fact that the Work Permit Procedure defined by a Maintenance and Plant Services Departmer.t Procedure and a Manufacturing Department i
Procedure are not being followed in the installation of the Modified Fuel Process was pointed out by the inspector. The licensee noted the observation.
(paragraph 6).
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