ML20043A383

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Matl Control & Accounting & Physical Security Insp Repts 50-223/90-02 & 70-0738/90-01 on 900410-13.Violations Noted. Major Areas Inspected:Shipping & Receiving,Storage & Internal Controls,Inventory & Physical Protection Measures
ML20043A383
Person / Time
Site: University of Lowell, 07000738
Issue date: 05/03/1990
From: Della Ratta A, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20043A377 List:
References
50-223-90-02, 50-223-90-2, 70-0738-90-01, 70-738-90-1, NUDOCS 9005210280
Download: ML20043A383 (7)


See also: IR 05000223/1990002

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

50-223/90-02

Report Nos.

70-738/90-01

50-223

Decket Nos.70-738

R-125

$

License Nos.

SNM-734

Licensee:

University of Lowell

1 University Avenue

LoweO , Massachusetts 01854

]

Facility Name:

University of Lowell Nuclear Center

Inspection /st:

Lowell, Massachusetts

Inspection Conducted: April 10-13, 1990

Type of Inspection:

Unannounced Material Control and Accounting, and

, Physical Security

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Inspector:

d

di

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  1. #-fv

A. Della Ratta, Shfeguards Inspector

date

Approved by: _/

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  1. -3 - 16,

R. R. Keinl,9 rChipfJf3afeguards Section,

date

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/FacilitiesRadicAtical Safety and Safeguards

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Branch, Division of Radiation Safety and

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Safeguards

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Inspection Summary:

Routine, unannounced safeguards inspection on

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April 10-13, 1990 (Combined Report Nos. 50-223/90-02 and 70-738/90-01)

Areas Inspected:

Nuclear material control and accounting, and physical

security, including:

organization and operation; shipping and receiving;

storage and internal controls; inventory; records and reports; and physical

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protection measures for special nuclear material of moderate strategic

significance.

Results:

Four violations were identified:

failure to conduct a physical

inventory of all SNM possessed under license every twelve months, (paragraph

2.d.); f ailure to perform leak tests of sealed plutonium-beryllium sources at

intervals not to exceed six months (paragraph 2.e.); failure to notify the

Commission within two months of changes made to the NRC-approved physical

security plan (paragraph 3.a.); and f ailure to maintain records to show

compliance with certain requirements as specified in the NRC-approved physical

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security plan (paragraph 3.b.).

9005210280 900508

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DETAILS

1.

Key Persons Contacted

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  • Dr. L. Beghian, Associate Vice President for Research
  • T. Wallace, Reactor Supervisor
  • W. Church, Radiation Safety Officer

L. Bobek, Chief Reactor Operator

R. Hobbs, Senior Reactor Operator

J. Rowe, Chief, Campus Police

D. Dowling Dispatcher Campus Police

  • present at exit interview

2.

Material Control and Accounting Program

a.

Program Management

The inspector verified through a review of records that the licensee

maintained an organizational structure with responsibility for

special nuclear material (SNM) control and accounting. Written

statements of responsibility and authority had been established for

those positions with responsibility.for the SNM.

Custody of all SNM

and the management of the nuclear material control and accountability

program is the responsibility of the Radiation Safety Officer.

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The Radiation Safety Officer is in the process of revising the SNM

control and accounting procedures to reflect current practices.

The

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revision will be completed and submitted to the Radiation Safety

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Committee for approval by May 31, 1990.

No discrepancies were

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identified,

b.

Shipping and Receiving

The inspector determined through a review of records that with the

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exception noted in paragraph 2.d., the licensee maintained procedures

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to assure that all SNM received or shipped was accurately accounted

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for.

A review was performed of all DOE /NRC Form-741's generated during

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October 1, 1983 through September 30, 1989 to assure that each was

properly signed, dispatched in a timely manner, and that the data

were accurate. No discrepancies were identified.

c.

Storage and Internal Control

The inspector determined thrcugh observations and review of records

that, with the exception noted in paragraph 2.d., the licensee was

maintaining a system of storage and internal controls that indicated

the quantity, identity, and current location of all SNM within the

facility.

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The licensee maintains a computer printcut that provides the serial

number and location of the fuel elements in the reactor core and

storage areas, and the uranium fission and transmutation calculations

for each fuel element. No discrepancies were identified.

d.

Inventory

The inspector performed an SNM inventnry verification on

April 11, 1990.

The inventory consisted of a piece count of the

thirty-two fuel elements located in storage areas and a comparison of

the fuel location to the fuel location schematic.

The inspector also

audited other selected items on the facility physical inventory.

During the inventory verification, the inspector determined that

seven SNM bearing metal foils (received on January 14,1985) and one

SNW bearing fission chamber (received on February 19, 1985) in the

licensee's possession, were not listed on the licensee's master

inventory listing. -The absence of these items from the. master

listing resulted in these SNM bearing items not being physically

accounted for during inventories, conducted every twelve months,

between January 1985 and December 1989 as required by 10 CFR 70.51(d).

Failure to comply with 10 CFR 70.51(d) is an apparent

violation of NRC requirements (70-738/90-01-01).

The licensee agreed to conduct another inventory of the SNM located

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et the facility to determine if all the SNM has been accounted for

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and will provide Region I with the inventory results by May 31, 1990,

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Records and Reports

e.

The inspector reviewed the licensee's records, reports, and source

data. All Material Balance Reports (DOE /NRC Form-742) submitted by

the licensee for the period October 1,1983 to September 30, 1989

were reviewed for compliance with 10 CFR 70.53. Total uranium and

uranium depletion records were also reviewed. No discrepancies were

identified.

The inspector reviewed the records of semi-annual leak tests of the

eleven plutonium-beryllium (PuBe) sources.

The inspector found that

in two instances, leak tests for six PuBe sources were not performed

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at six month intervals as required by License Condition 13. A(1) of

License No. SNM-714, Amendment No. 08, dated August 12, 1988.

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leak tests performed on April 14, 1987 were not performed within six

months of the previous leak tests that were performed on

July 30, 1986, and the leak tests performed on March 25, 1988 were,

not performed within six months of the previous leak tests that were

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performed on July 14, 1987.

In all cases, the tests performed did

not identify any leaking sources.

Failure to perform leak tests on

the six PuBe sources within the required intervals was identified as

an apparent violation of NRC requirements (70-738/90--01-02).

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Exhibits I through III, sur.marize the licensee's nuclear material

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activity for the period October 1, 1983 - September 30, 1989.

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3.

General Physical Security Requirements for SNM of Moderate

Strategic Significance

The licensee's program for the physical protection of SNM of moderate

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strategic significance was reviewed by the inspector for conformance with

the NRC-approved physical security plan.

The inspector examined physical

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barriers, access controls, procedures, and key control, and observed a

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licensee test of alarm system features.

The inspector found that the

licensee's program and its implementation met the general performance

requirements and objectives of the governing regulations, except as

follows:

a.

The inspector's review of the NRC-approved physical security plan

identified that the licensee had made numerous changes to the plan in

Revision I, dated January 4, 1988, but had not submitted these

changes to the NRC within two months after the changes were made, as

required by 10 CFR 50.54(p).

These changes as implemented were

designed to enhance the overall security program and did not

decrease the safeguards effectiveness of the plan.

Failure to submit

these changes to the NRC within two months was identified as an

apparent violation (50-223/90-02-01).

The licensee is in the process of reviewing the current plan to

determine the need for additional changes and committed to submit a

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report to the NRC containing a description of al' changes by

May 31, 1990.

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b.

The inspector identified to the licensee that the section titled

" Security Records" of the NRC-approved physical security plan,

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states, in part that the results of the physical inventory of locks,

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cores, keys and key cards shall be maintained at the facility for at

least 24 months.

The inspector's review found that, with the

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exception of the key cards, the licensee could not provide the

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results of the physical inventory of locks, cores and keys for the

previous 24 months, However, the inspector's physical inventory

results of these items determined that all of the locks, cores and

keys were accounted for.

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Failure to maintain records in order to show compliance with the

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NRC-approved physical security plan was identified as an apparent

violation (50-223/90-02-02).

4.

Exit Interview

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The inspector met with the licensee representatives indicated in

paragraph 1 at the conclusion of the inspection on April 13, 1990. At

that time, the purpose and scope for the inspection were reviewed and the

findings were presented.

The licensee's commitments, as documented in

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this report, were reviewed and confirmed with the licensee.

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EXHIBIT I

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University of Lowell

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Docket Nos. 50-223 and-70-738

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License Nos. R-125 and $NM-7111

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Material Balance for Period: October 1, 1983 - September 30, 1989

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Reporting Identification Symbol: ZLV

Reporting Unit:

Grams-

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' Enriched Uranium

Plutonium

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Element

Isotope

Element-

Isotope

Beginning Inventory:-

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(October 1,1983)

4,376'

4,066-

272~

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Additions:

Receipts:

-0-

-0-

-0-

-0-

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Materia' to Account For:

~ 4,376

4,066-

272;

251

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Removais-

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Shipments:

-0-

-0-

-0-

-0-

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Fission and Transmutation:

36.-

-36-

-0 .

-0--

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Decay:

-0-

-0-

-0 -

-0-

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Total Removals:

36

36'

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Ending Inventory:

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(September 30,1989)

4,340

4,030

272.

_251.

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251

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Material Accounted For:

4,376

4,066

272:

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EXHIBIT II

University of Lowell

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Docket No.=70-738' License No. SNM-714

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Material Balance for Period: October 1. 1983 - September 30,!!989

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. Reporting Identification Symbol: ZLV

Reporting Unit: Grams'

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Enriched Uranium

Plutonium.

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Element.

_ Isotope

Element

-Isotope.

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Beginning Inventory:'

-0-

-0

-0-

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(October 1,1983)

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Additions:

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Receipts:

108-

101

29

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Material to Account For:

108-

101-

29

28-

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Removals:

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Shipments:

-0-

-0-

-0-

-0-

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Ending Inventory:

(September. 30,'1989)

108

101

29

28

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Material Accounted For:

108

101-

-29:

28'

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EkHIBIT III:

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University of Lowell

Docket No.70-738

License No. SNM-714

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Material' Balance for Period: October 1, 1983 - September 30,~1989!

. Reporting Identification Symbol:

ZLV

Reportino Unit:

Grams

Uranium -233

Element-

LIsotope-

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Beginning. Inventory:-

(October 1,'1983)

~0-

-0-

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Additions:

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Receipts:

3'

3

Material:to Account-For:

3

.-- 3

=

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Removals:

Shipments:

-0 -

-0-

Ending Inventory:

9

(September 30,1989)

3

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Material Accounted For:

3

3

4

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