ML20039E441
| ML20039E441 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 12/23/1981 |
| From: | Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20039E434 | List: |
| References | |
| 70-0371-81-18, 70-371-81-18, NUDOCS 8201070296 | |
| Download: ML20039E441 (10) | |
Text
f U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT-
' Region I Report No.
70-371/81-18 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:
November 16-19, 1981 Inspectors:
M
/7-/2 3 /P/-
y R'oth! Project Inspector date signed '
Accompanied by:
G. Bidinoer
. Project Manager, NRC-NMSS date signed
. Approved by:
b kO Se _ M l'2f27[f/
R. R. Keimig, Chief date signed Projects Branch No. 2,
.DRPI Inspection Summary:
Inspection on November 16-19, 1981 (Report No. 70-371/81-18)
Areas Inspected:
Routine, unannounced inspection by a region-based inspector of: organization; 10 CFR Part 21; facility changes and modifications; internal review and audit; review of operations; nuclear criticality safety; transportation activities; and, nonroutine events. The inspection was initiated on the day shift and involved 31 inspector-hours onsite by one NRC region-based inspector.
Results: Of the 9 areas inspected,'no items of noncompliance were identified in 8 areas; three items of noncompliance were identified in one area (Violations-Failure to establish adequate nuclear criticality safety controls in six areas of the plant, paragraph 3a. and 3b.;' Exceeded posted nuclear safety limits in two areas of the_ plant, paragraph 3b.; Failure to follow procedures, paragraph 3c.)
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DETAILS
'l.
Persons Contacted G. H. Waugh, Vice President, Quality Control W. Kirk, Manager, Nuclear and Industrial Safety
~J. Neumann, Nuclear Criticality Safety Specialist J. Czapski, Engineer "A" The inspector also interviewed 15 other licensee employees during the inspection.
denotes those present at the exit interview.
2.
Organization The inspector determined through discussions with licensee representatives that there were no changes in.the facility organization since the last inspection (70-371/81-13). However, it was-determined that UNC Naval Products will remain as a division of the United Nuclear Corporation rather than a division of UNC Resources Corporation.
No items of noncompliance were identified.
3.
Review of Operations-The inspector examined areas of the plant to observe operations'and activities in progress; to inspect the nuclear safety aspects of operations; and, to check the general state of cleanliness, housekeeping and adherence to fire protection rules.
a.
Nuclear Safety Postings The inspector examined nuclear criticality safety postings throughout the facility. Most of the areas of the plant were adequately posted with signs which specified required controls except for the'following:
L 1)
Filler Fabrication Area No. 2 Authorization No IIB-7, Revision 0, dated November 8, 1979,-
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" Residual Storage in the...QC Area", specified a limit of-10-kg residuals to be stored in'the cabinet. No additional controls were specified, i.e., there~ were no controls on: the array size, there were no U-235 analytical contents specified,
.and there were no controls on the quantity of hydrogenous material present. The residuals-are placed in 1 ounce 7
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stainless steel cans which in turn are placed into compartments of covered plastic trays.
The trays are then stored to the capacity of each shelf in the cabinet. Approximately 4.8 kg of residuals were located on the top two shelves of the cabinet at the time of thic inspection. The nuclear safety evaluation for the storage of residuals in the storage cabinet was examined by the inspector. The evaluation was based on the average historical analytical value for the content of U-235 in residuals and was approved "provided that there was no confusion with' aborted charges" which contain in excess of 15 times this average value, 2)
Chemistry Laboratory c
The inspector observed that there were several unsafe geometry containers located in various zones within the chemistry laboratory. These consisted of three 55 gallon-drums in the chemistry laboratory, three 55 gallon drums in the spectroscopy laboratory and approximately 6 unsafe geometry carboys of waste solutions. No controls were specified on nuclear safety postings, i.e., maintaining a running balance of the U-235 content of the drums was not specified and no spacing of the carboys of waste solutions was required.
It was noted that the carboys were labeled with running balances of U-235 contents; however, according to licensee representatives, the U-235 content was an estimated value rather than an analytical value.
3)
Outside Drum Storage i
During examination of outside areas of the plant within the protected area, the inspector observed that two, drum.
storage " dog pens" had been installed.
a.) Dog Pen No. 1 Authorization No. VII C-4A, Revision 0, dated August 10, 198", was posted.
This sign authorized the storage of 55 gallon drums, each to contain up to 50 grams U-235. The dog pen was limited "to capacity of the fenced area".
No additional storage criteria were identified. Dog Pen No. 1 was located adjacent to the east end of Building M.
b.) Dog Pen No. 2 Authorization No. VII C-48, Revision 0, dated November 9, 1981, was posted. This sign authorized the storage of 55 gallon drums in the fenced area. North Portion not-to exceed 15 grams U-235 in each drum, South Portion -
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4 not to exceed 50 grams J 235 in each drum.
No additional storage criteria were indicated.
There was about a 15 foot isolation zone roped off adjacent to the South wall of Building A which contained drums which were not, in all cases, identified as empty. There was an additional 10 foot zone extending from the rope identified above and bounded by a second ropa which, according to licensee repre.entatives, was to contain the drums holding up to 15 c ams of U-235. The 50 gram U-235 per drum zone extencMd from this rope to the fence line.
None of these zones were identified on the posted sign.
The inspector examined the nuclear safety evaluatians for the storage of drums in the dog pens.
The evaluations required a 20 foot spacing from the building and a 20 foot separation from SNM in other storage arrays, in transport ation, or at work stations.
Use of these storage areas was identified "for short term storage of waste drums". None of these criteria were identified on the posted signs.
In addition, the size (length, width, or height) of the storage arrays and the term "short term storage" were not defined or specified.
The inspector asked license representatives if radiological safety controls had been established to monitor the drums while in outside storage.
Licensee representatives stated that contamination and radiation surveys were conducted on these drums prior to release from the building, but that no ongoing surveillance activities were established to assure that the drums did not rust through and that contamination had not been inadvertently released during storage under adverse weather conditions.
4)
Health Physics Basement Drum Storage Area The inspector noted that the basement drum storage area was posted with an area limit of 100 TI units. At the time of this inspection, there were no licensee records available which indicated the current running balance of TI units in the area. A tota _1 of about 40-50 individual entries would have to be added together to-determine the current contents of the area prior to placing additional drums into storage.
5)
Trailer Drum Storage The SNM content of drums stored in trailer number 2 wts not recorded on any running inventory list or record madeavailable to the inspector by licensee representatives. These drums contained empty, contaminated, raw fuel cans.
The above instances of failure to specify and maintai1 nuclear and radiological safety controls in work stations and storage
5 locations at the facility were identified as an item of noncompliance (81-18-01).
b.
Posted Limits 1.) Metallography Laboratory-Authorization No. VII A-1, Revision 6, dated November 30, 1977, for the Sample Inspection Room, specifies a zone limit of 350 grams of U-235. Upon questioning licensee representatives, the inspector was informed that the zone contained a total of 328 grams of U-235.
Sincc no running balance of SNM was maintained for the zone by the licensee, the inspector conducted a rapid inventory
'of the zone which indicated that the zone was in excessive of the 350 gram limit. The licensee conducted an indepth. inventory of the zone' and verified that the zone limit had been exceeded (369.5 grams U-235 present).
l 2.). Outside Drum Storage:
Authorization No. VII C-4B, Revision 0, dated November 9, 1981, posted on Dog Pen No. 2, specifies a drum limit of 50 gram U-235. During examination of drum storage records the inspector determined that two drums (10-80_and 1-81) contained in excess of the 50 gram U-235 limit (50.7 grams and 50.6. grams, respectively).
j l
Failure-to maintain the SNM content of the Metallo-graphy Laboratory and the two drums, within the posted limits, was identified as an item of noncompliance (81-
+
18-02).
1 c.
Fuel Cart Parking l-The UNC-NP " Material. Handling Rules Manual", dated August 3, 1973, under " Criticality Control Rules", states, in part, that fuel carts in an aisle must be attended at all times.
It further states that designated fuel cart parks will be defined.
The inspector observed that a fuel cart containing 3 fuel bearing components was located in an aisle in the Dye Penetrant test area of Building M but was not attended. The licensee took immediate steps to move this cart to a designated parking area.
Failure to attend a fuel cart containing fuel-L bearing components while parked in an aisle was. identified as an item of noncompliance (81-18-03).
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6 d.
-Empty Shipping Containers The inspector observed that at least two closed Model 2600
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shipping containers were being stored outside of, but adjacent to, the east fence of Dog Pen No. 2.
According to licensee representatives, these shipping containers were empty but not marked as such.
The inspector-stated that closed containers are assumed to contain SNM unless marked empty. The licensee'immediately placed empty labels on these containers.
No items of noncompliance were identified.
e.
_ Zone Marking The licensee utilizes a technique for defining fuel zones by placing red or white dotted lines on the floor. In'the Filler Fabrication Area No. l' QC Desiccator Storage' Roon., it was noted that zone marking dots on the floor on the'left side of-the room were adjacent to the desiccator array while the dots on the right side of the room were obout 3 feet away from the desiccator array.
The inspector stated that the use of zone marking should be applied in a. consistent manner, otherwise, personnel will be subjected to: confusion with respect to the application of'the zone markings.
Licensee representatives stated that nuclear safety evaluations of these zones indicated that no fuel exclusion area was required extending beyond the physical boundary of the array and that the. dotted lines were placed for.the sake of' convenience.
However, inconsistent use of zone marking will be reviewed and corrected as necessary. This was discussed at the exit interview.
No items of noncompliance were identified.
f.
Emergency Exits-During examination of-outside areas of the facility, the inspector observed that an emergency exit doorway from the Modified Fuel Process area, located between Buildings A and B, was partailly blocked by a cement block and a trash dumpster. This blockage was removed by the licensee prior to the end of this inspection. This was discussed at the exit interview.
No items of noncompliance were identified.
7 4.
Nuclear Criticality Safety a.
Criticality Monitors The inspector examined licensee records which-indicated that the i
criticality monitors located throughout the facility,-were calibrated quarterly during the time per'?d February 8,1981 through November 15, 1981.
Records also indicated that the monitors were recalibrated whenever repair work was done prior to placing the unit back.into operation.
No items of noncompliance were identified.
b.
Raschig Ring Inspection and Analysis 4
Licensee records indicated that vessels RT-1 and RT-2 wasto receivers were inspected at least once each month, from January 28,:1981 through November 12, 1981, to verify the_raschig ring content level. Tank RT-2 was out of service from July'19, 1980 to February 25, 1981. New raschig rings were placed.into.this s
tank on February 25, 1981, and the tank'was calibrated to show a glass volume of 26% which is in-excess of the required 22%.
This tank was placed into service on February 25, 1981. The raschig rings in tank RT-l~were replaced on August 18, 1981, and the tank was placed back into service. Calibration of this tank on August..
18, 1981 indicated a glass volume of 39%. The1 glass volume differential between the two tanks was explained by the use of-two different types of acceptable raschig rings.
l Licensee records also indicated that raschig rings were removed from tanks RT-1, RT-2, Sectioning Left and Sectioning Right, on May 7, 1981 for chemical analysis.
Chemical analysis results i
indicated that the B 0 content of the rings ' removed from -the tanks ranged from 12.52% to 13.10% which was within the range of
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11.8 to 13.8% of B 0 required by.= licensee conditions.-
No items of noncompliance were identified.
c.
Pickling Fixture Checks u
The inspector examined reco'rds of pickling ; fixture checks for fixtures located in Building M for the time period March 23, 1981 through October 29,.1981.
These records. indicated that the listed fixtures had been checked 'at least.okch each two months'asl required.. It was noted that effective-June 15,.1981( the licensee-initiated a two month recorded fixture check cycle,rather than a one month cycle which was previously the practice.
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. 0 No items of noncompliance.were identified.
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d.
Annual Nuclear Criticality Safety Program Audit An annual audit of the nuclear criticality safety program at this facility was conducted by a consultant from.outside-the division from August 31, 1981 to September 1, 1981. The audit report, dated November.4, 1981, was examined by the_ inspector. The auditor stated that the: program was satisfactory, and that its insiementation was effective. Areas covered included: management, a'ssignment-of responsibility, procedures, working conditions, training, meaical, incident report system, and the technical bases for safety limits and staffing of the NIS Department.
'S.uggestions~and recommendations were made for improving computer analytical ~ methods, transmitting'information relative to recorded violations _and other appropriate criticality safety topics to supervisors?and managers and increasing the support level of the NIS Department.
No items of noncompliance were ideintified.
e.
Nuclear Safety EvaluatinrLs The inspector examined nuclear safety evaluations for three operations 11ncluding: drum storage in the dog pens (previously discussed ~in paragraph 3a. 3); residual. storage in the Filler.
Fabrication Area No. 2 QC area (previously discussed in paragraph 3a.1); and, the RFA Vertical Storage Rack located in Annex ~3.
This evaluation indicated that the licensee properly evaluated Keff including concrete reflection, full plus interspersed moderation, and the effect of fire sprinklers on.Keff.
Minimum separation requirements were built into the rack and procedures included rack loading and unloading requirements.
No items of noncompliance were identified.
l f.
Inte'rnaj Reviews and Aiidits F
The' fnspector c;uestioned licensee representatives regarding the-conduct of internal reviews and audits during 'the time period
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July 13, 1981 through October 30, 1981 (81-65 to'81-93). The inspector reviewed the reports of.29 internal NIS inspections which~were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular
-ar.d off-shift hours and examination of required equipment inspection j;
reports.
The inspector verified that corrective actions had been taken or initiated in each instance identified by the licensee-which requir61 corrective action.
No items of noncompliance were identified.
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9 5.
Nonroutine Events The inspector determined through review of licensee records and discussions with licensee representatives that no nonroutine events within the scope of this inspection occurred at this facility since the last inspection.
No items of noncompliance were identified.
6.
Facility Changes and Modifications The licensee has modified facilities for the installation of equipment
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- for the Modified Fuel Process (MFP).
The licensee is also installing a hexane distillation system outside the protected area fence south of Building B.
Equipment for the Modified Fuel Process is being installed in the Filler Fabrication No. 2 area and in the new facility added on between Buildings A and B.
The inspector initiated a review of this installation to assure that it corresponds with descriptions contained in classified license amendment applications submitted to NRC-NMSS.
No items of noncompliance were identified.
7.
Part 21 Inspection The inspector verified that the postings required by 10 CFR 21.6 contained the information required and were accessible for examination by licensee employees as required.
j N,o items of noncompliance were identified.
3.
Transportation Activities The inspector determined through a review of licensee records and discussions with licensee representatives that the licensee uses the following contain'ers routinely for the transport and/or storage of special nuclear material.
These containers include:
specification containers 6J,17H, 6L, and 6M; certificate of compliance containers 5908, 6357, 5641, 5086, 9123, 6294, 4949, 6406, and 6386; and, the IAEA0002 container. The inspector verified that the licensee had established procedures for container inspection, container opening and container closing.
No items of noncompliance were identified.
g, 9.
NRC-NMSS Personnel'Accorpaniment The inspector was accompanied curing this inspection by a member of the staff of NRC-NMSS. One purpose of this inspection was to acquaint this individual with the operational status of this facility.
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10 10.
Exit Interview
.The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection at about 4:00 p.m. on November 19, 1981. The inspector presented the scope and findings of the inspection. Comments made by the licensee representatives during the exit interview have been incorporated into the applicable paragraphs of the report details.
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