ML20043C456

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Insp Rept 70-0687/89-200 on 890328-30.No Violations or Deviations Noted.Major Areas Inspected:Matl Control & Accounting Sys Mgt & Assessment,Internal Controls & Measurement Sys & Controls
ML20043C456
Person / Time
Site: 07000687
Issue date: 04/28/1989
From: Gundersen G, Rolonda Jackson, Kasun D
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20043C415 List:
References
FOIA-90-97 70-0687-89-200, 70-687-89-200, NUDOCS 9006050208
Download: ML20043C456 (6)


Text

{{#Wiki_filter:r The information on this page is considered to be appropriate for public disclosure pursuant to 10 CTR 2.790 U.S NUCLEAR REGULATORY COMMISSION Washington, D.C. 20555 Report Nunber 70 687/89 200 License Number SNil-639 Safeguards Group !! Licensee: Cintichem, Inc. P.O. Box 816 l Tuxedo, N.Y. 10987 Facility Name: Cintichem, Inc. Inspection conducted: March 28 through 30, 1989 Inspectors:

== ( %Cl R. L. Jackso Q, PhysicalScientist(MC&A) Date Signed Physical Secur1Ty and liC&A Licensing and Inspection 5 etios SGDB, SSTR, NMSS 1 4212+1) OY 'l G. E. Gun'aersen, SG Physical Scientist (MC&A)Da'te 51gned Physical Security and MC&A Licensing and Inspection Section, SGOB, SGTR, NUS$ Oh h Mk Approved by: .D. J. Wun~, Section Leaoer, Physical Date Signed Security and MC&A Licencing and Inspection Section, SGDB, SGTR, NMS$ Summary: Inspection on liarch 28-30. 1989 (70-687/89 200) Areas Inspected: A routine announced material control and accounting safeguards inspection was conducted by two MC&A inspectors from the Office of Nuclear Material Safety and Safeguards. The areas inspected were MC&A system manage-ment and assessment, internal controls, measurement systems, measurement controls, entrance and exit interviews. Inspection Procedures 85203, 85205, 85207, 85209, 85211, 85215 and 30703 were addressed. 900605020s 900330 L90 PDR'

l i l' l Results: Within the scope of the inspection, no violations, deviations or cec 11ning performances were identified by the NRC inspectors. A management system has been established, maintained and is being followed which provides for the development, revision, implementation and enforcement of internal MC&A procedures, the Fundamental Nuclear Material Control (FNMC) Plan, applicable portions of 10 CFR Part 70 and License Conditions contained in Safeguards Amendment SG-1. The measurement and measurement control programs are providing special nuclear material values that are acceptable for this facility.

Report, Details 3.- Key Persont M.a e.t d 'J. McGovera, F Wt Manager i

  • L. Thelin, 5tM h sith Physicist F. J. Morse, unager - Engineering and Measurement Control Coordinator
  • C. Anderson, Manager - Quality Control and Analytical Service
  • J. L. Ditton, Assistant Radiation Safety Officer M. A. Gordon, Training and Retraining Coordinator G. Wright Custodian - MBA-1 L. Pitt, Custodian - MBA-2 S. Lupinski, Custodian - MBA-3 G. Richards, Custodian - MBA-4 S. Decker, Senior Technician A. Stewart - Quality Control and Analytical Service Radiochemical Supervisor
  • Present at exit interview 2.

Functional Areas Inspected a. Facility Oreanization and Management Controls (85203) The overall MCEA management-structure was assessed by the inspector to be adequate with all major HC&A functions being properly covered. The MC&A staff was deemed to be experienced and competent in that the inspector determined that the MC&A program is being conducted in an effective manner. The organizational structure, as evidenced by the organization chart revised as of M6rch 28, 1989, provides a sufficient level of independence and separation of functions so that the activities of one individual or organizational unit serve as a check and balance on other individuals or org6nizational units. The inspector determined that a management system is in place which provides for the development, revision, implementation, and enforce-ment of MC&A procedures. This system provides for written approval of MC&A procedures and any revisions to those procedures by the individual with overall MC&A responsibility and by plant management. The inspector conducted a spot-check review of MC&A procedures which included: " Procedure for SNM Physical Inventory" dated 3/2/89. " Tamper-Safing of SNM" no. UR-01-01 dated 3/24/88 and "ProcedureForReceiptandDissolutionofSNM(EnrichedU-235)- Feed Material" dated 11/4/88. i

~ In addition, the " Quality Control Manual" which is referenced later in this report, was reviewed.- Cintichem lab and appropriate management personnel are in the process of revising those procedures which they feel require a greater level of detail. Additional revisions to the procedure forms will provide author and approval documentation as well as appropriate dates. The last annual audit relating to the licensee's uranium measurement quality assurance program, as required by 10 CFR 70.57(b)(2), was conducted on December 12 thru 19,1988 with the report finalized on December 30, 1988. The previous annual audit was finalized on December 29, 1987. The review and audit was conducted by an individual independent of nuclear material control management, and personnel who have direct responsibility for receipt, custody, utilization, measurement, measure-ment quality, and shipment of special nuclear material. Tht results of the annual review and audit, along with recomenddtions, was docu-mented and reported to the licensee's plant management. The inspector noted that the recommendations contained in the audit and review report were, as appropriate, incorporated into Cintichem's Fundenental Nuclear Material Control (FNHC) Plan dated December 19, 1988, b. Facility Operations and Internal Controls (85205) Tne inspector cetermined that procedures are established, maintained and followed for tamper-safing containers or vaults containing SNM. These procedures describe control of tamper-safing devices, records of the date, time and individual who applies a tamper-safing device, and the program for verifying the integrity of. tamper-safing devices and responding to devices which are found to have been compromised. It was recommended by the inspector that a current list of authorized tamper-safing cevice users be established and maintained. The licensee agreed to establish and maintain such a list. The inspector also determined that procedures are established, main-tained and followed to assure accurate identification of SNM received and shipped by the licensee and to review and evaluate shipper-receiver differences on an individual container or lot easis, on a shipment basis, and on a cumulative basis for like material. These procedures describe appropriate investigative and corrective actions which will be taken to reconcile significant shipper-receiver differences. i

'I-The inspectors also determined that the licensee properly prepared and maintained control of SNM transfer documents. The inspectors reviewed certain selected transfer documents issued during the period November 1, 1988 - March 22, 1988 for number of items, destination quantity of SNMtransferred,signaturesofauthorizedpersonsinvolvedinthe transfer, and accuracy of the central record system. With the exception ofminordeficiencies,!nodiscrepancieswereidentified.'Thedefi-5 receiver dates missing as well as 2 MBA's not identified as recipient ciencies were corrected while the inspectors were on site. Authorized MBA custodians and their approved alternates were reviewed against such a list provided by the licensee dated January 4, 1989. One alternate's training records, R. Pindilli, was spot checked as to the documentation of the extent of her training and the date she was qualified to be an alternate. The training appeared adequate and was properly certified -prior to January 4, 1989. c. Measurement Systems (85207) The licensee has established measurement systems which substantiate the quantities of special nuclear material in its possession. The " Quality Control Manual," which contains all on-site measurements procedures was reviewed by the inspector, it is currently being upgraded by adding more detail and better docunentation as to who wrote the procedure, who approved it and the associated dates. Receipts of uranium oxide from the Martin Marietta, DOE facility have shown a consistent bias with licensee measuring less than the shipper. This bias, if real, rewits in the inventory difference being understated by about thirty gw.s per inventory period. The bias is within the shipper-receiver difference action limit of fifty grams U-235 per shipment specified in 10CFR70.58(g)(3). Standards for the calibration and control measure-ments are maintained and systems are recalibrated when control data indicates the need. Measurement systems are being requalified as required. The inspector cetermined that the measurement program used for account-ability purposes is producing acceptable results, d. Measurement Control and Statistics (85209) License conditions 4.1, 4.2 and 4.3 of Amendment SG-1 to License No. SHM-639 gives exemptions to: 10 CFR 70.57(b)(4) which requires sampling systematic errors and engineering tests on all material types; 10 CFR 70.51(e)(4)(i) which requires limit of error of inventory (difference (LEID) to be calculated around each inventory difference ID). This regulation is effective only)if the ID exceeds 300 grams uranium or U-235;10CFR70.57(b)(8)(ii requires a replicate program for random errors, this regulation is only effective if the 10 exceeds 300 grams uranium or U-235. The last two ids were about 140 grams of U-235 and previous ones were about 40 grams U-235 to the above regulations do not apply. The measurement systems are controlled using X and R charts for control standard measurements at the 0.05 and 0.001 levels of significance. Shipper-receiver differences on receipts have been discussed above. Shipments made by the licensee are accepted by the receivers at shippers values. The inspector determined that the measurement control program is acceptable for the current level of operations.

1 e. Physica1' Inventory (85211) l,' The inspector verified that the SNM Accounting Master Ledger and appro-priate MBA accounts were reconciled within 30 days to the November 4, 1988 physical inventory. The inventory difference was well within regulatory limits, f. Records and Reports (85215) The inspector determined that Material Status Reports (DOE /NRC Form 742 and Form 7420) are prepared and distributed as required. The inspector determineo that the forms, for the past 2 years, were filed within 30 days of March 31 and September 30 as required. The inspector also r determinedthatnuclearmaterialtransferreports(DOE /NRCForm-741) for the period of 10/27/88 - 3/20/89 were prepared and distributed as required. The inspector determined that measurement control program data, information, repurts and documents are organized for efficient retrieval. Program results are readily relatable to the original measurement data.and to all other relevant progran information. 3. Management Meetings, Entrance and Exit Interviews (30703) An entrance meeting was conducted on Tuesday morning, tiarch 28, 1989 with Messrs. J. J. McGovern, J. Ditton and L. Thelin to outline the scope and duration of the inspection. The exit interview was conducted Thursday afternoon March 30, 1989 with those management and-technical staff denoted in paragraph 1 of this report. The inspection findings of the inspectors were presented.

( g \\/ ) g [ Jt)L g 91985 ,i Docket Nos: 50-54 A l 70-687 h e =' ~ ~ Jhb. Carbide CorporatTK ctpTtcEATW ]E***"~ ATTN: Mr. James J,.McGovern Business Manager, Radiochem P. O. Box 324 als Tuxedo, New York 10987 fcLA-90-4I r Gentlemen:

4. m s

Subject:

Combined Inspection os. 50-54/85-02 and 70-687/85-03 This refers t'o t un ne sa this office o R-81 and SKM-pril 24 - 26, 198. inspection conducted by Mr. W. Madden of activities authorized by NRC License No. nd in + with you'and members of your staff at the conclusion of the inspect Areas exasined during this inspection are described in the NRC R on. Inspectior. Report which is enclosed with this letter. egion I records, f r.te views with personnel, and observatio n representative Within the supe of this inspection, no violations were obs pector. erved. Sections cf tne enclosed inspection report contain details program that T. ave been determined to be exempt from public disclof your security .cordance w'th either 10 CFR 73.21 (Safeguards Information (Commercial c-Financial Information). osure in ac-will receive Timited distribution.in the ins;:+::: ion report will-not be Document Rcom, remaining pc ions of the inspection report will be placed in thThe inspection in accordance with 10 CFR 2.790(a). e Public No reply to s.ws letter is required. is apprecia ec.. Your cooperation with us in this matter Sincerely, original SiSDdT8 'mdica ir !;Js n:nf :: m:!cd JanosB..T07ner idr.00 with the faer-d Inbma!!on Thomas T. Martin, Director cxem licas u Y Division of Radiation Safety fg and Safeguards q \\ 0FFICIAL RECORD COPY IR UNION CARBIDE 85-02/03 - 0001 0 0 -{L pyg t ,%.. - si.. y m ~ _ >. '.y "g. -f, p }l. g i V,; '.'-- ';** w~ 1 ^1 : e it 5 T ^ ' '

.R lt ED BY: 7 z e.)r ~ 'date ignaiue~ USNRC ' organization U.S. NUCLEAR REGULATORY COMMIS$10N REGION I Report Nos. 70-687/85-0_3 and 50-54/85-02: Docket Hos. 70-687 License Nos. SNM-639 R-81 50-54_ Union Carbide Corporation Licensee: P.O. Box 324 ,Tyxedo, New York 10987i Sterling Forest Research. Center Facility Name: Inspection At: Tuxedo, New York 10987 Inspection Conducted: April 24 - 26, 1985 March 30 - 31. 1982 Date of Last Physical Security Inspection: Routine, Dnannounced Physical Protection-Type of Inspe: tion: I_ 7 /9 -gJ' Inspector: date >#n i am J. adde hysical tect I ector 7 / f-#[ M,- ~ date Approved by: Rf. '. Kehig/ Chief f/ Eafeguards %ction,(Auclear Materials Safety and Safeguards Branch Routine Physical Protection Inspection Inspection Summary: 70-687/85-03 and 50-54/85-02). (Combinec Report Nos. General Requirements for Special Nuclear Material of Moderate Security Plan; Protection of Areas inspe:ted: Strategic Significance at fixed sites including: Special-Nuciear Material (SNM); Security Organization; Records and -Alarm Systers; and Communications. a region based inspector. The Mcensee was in compliance with NRC requirements in Results: the areas examined. SGS-RI-85-29 Copy ~~Gof 6 Col 4 Pages REPORT DETAILS CONTAINS_ '2.790(d) INFORMATION M /hN""* ) n : m. n. n._ .m

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.( m ,s + 4 DETAILS 1. Key Persons Contacted i

  • J. McGovern, Business Manager, Radiochemicals
  • W. Ruzicka, Reactor Supervisor

'R. Hubbard, Manager, Maintenance and Engineering C. Konnerth, Manager, Health, Safety and Environmental Af f airs

  • J. Baird, Senior Reactor Operator G. Wright, Production Control Supervisor' S. Lupinski, Chief, Reactor Operator J. Kratochwil, Utilities Supervisor
  • denotes those present at exit interview.

2. 30703 - Exit Interview The inspector met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on April 26, 1985, and summarized the scope and findings of the inspection. At no time during the inspection was written material provided to the licensee by the inspection. 3. 81480 - General Requirements for Special Nuclear Material of Moderate Strategic Significance at Fixed Sites a. Security Plan: The current site security, plan was approved by NRC's Of fice of Nuclear Reactor Regulation letter dated October 28, 1984 and by the Of fice of Nuclear Materials Safety and Safeguards letter dated May 26, 1983. The plan provides for the protection of SNM in storage and/or in use in contiguous facilities under NRC Reactor License No. R-81 and Hot Laboratory SNH License No. SNM-639, and for SNM in-transit. The plan addresses SNM of both of Low and Moderate Strategic Significance and implements the performance objectives of 10 CFR 73.67 and takes credit for " exempt material" categories of SNM provided for by 10 CFR 73.67(b)(1). The plan limits the total quantity of non-exempt SNM possessed under both licenses to less than a formula quantity. The inspector confirmed, by review and walk-through, that the plan and implementing procedures meet the requirements of 10 CFR 73.67. b. Prote ion of SNM: ~ Jt$khh $$[%%hM.,h 3

  • .l,

) f, / Sl J Q f f W., C0FI - Commercial or Financial Information that is exempt from public disclosure in accordance with 10 CFR 9.5(a)(4).

l $$hMf...hhb)WI f [ The inspector toured the facilities and concluded that the licensee was maintaining the non-exempt $NM inventory level below the "less than 5 kg." limit as defined in paragraphs 3A and B of the approved Security Plan. Non-exempt $NM on hand, in the form of encapsulated fuel and feed material, was less than 2 kg, on April 25, 1985. (C0FI) Jeactor Operators and Bo11erpersons;p@y._organiza' tion includ.= Security Organization: (C0FI) The s c. f v i r - U DFI) The inspector confirmea snat all personnel involved were umiliar with their-specific duties and responsibilities as required by the security plan. d. Records and Reports: The inspector reviewed the licensee's SNM inventory results of March 19, 1985 and April 12, 1985; Access Con-trol Authorization t.isting dated April 12, 1985; Alarm Test Records for January - April,1985 and a Security Program Audit accomplished on January 18, 1984 by the Manager, Health, Safety and Environmental Affairs and dated January 24, 1984. (COFI) The audit resulted in the replacement or ~~ 7 SNM storage cabinets L j and on plating Tao uovr. Fasi;;;; by : W...; rwi.ords wera reviewed pr for the period January - April 25, 1985. locks V -for the Controlled Access Area Doors / Cab %u nre inst ^ changed on April 12, 1985, coincidental with the favorable termination of an employee. Personnel access records for the reactor fuel vault were reviewed for the periods February and April,1985. (C0FI) All records and reports were in conformance with the Security Plan. t e. Alarm Systems: (COFQI' ,5 (i ,~Although~nh ~ a requirement,'this improvement 'would enhance ~ ~alaVii'm~onitoring and response. (C0FI)

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f. _ Communications:

(COFI)J c Ch / tthe inspector confirmed the vallany or 1,nese ! numbers by telephone contact with the dispatchers at both locations on April 25, 1985. (C0FI The inspector found communications capa-bilities in conformance w)th the approved security plan.' i 9 O 4 e e S S . I i-}}