ML20148U244
| ML20148U244 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 11/18/1978 |
| From: | Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20148U211 | List: |
| References | |
| 70-0371-78-15, 70-371-78-15, NUDOCS 7812060328 | |
| Download: ML20148U244 (2) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
'({ Region I l l Report No. 70-371/78-15 I l Docket No. 70-371 l l License No. SNM-368 Priority 1 Category UR Licensee: United Nuclear Corporation 67 Sandy Desert Road Uncasville, Connecticut 06382 Facility Name: Naval Products Division Inspection at: Montville, Connecticut Inspection conducted: September 25-28, 1978 Inspectors: h , bM ~
/ci ///T />g J.Rp,ProjectInspector date signed date signed date signed Approved by A f,L - /D// y/7f H. W. Crocker, Chtef, Fuel Facility 'date' signed Projects Section, FF&MS Branch Inspection Summary:
Inspection on September 25-28, 1978 (Report No. 70-371/78-15) Areas Inspected: Routine unannounced inspection by a region based inspector of criticality ancf engineered systems including: scope of operations; 10 CFR Part 21; facility changes and modifications; internal review and audit; safety conmittees; training; maintenance; review of operations; nuclear criticality safety; packaging and shi pp.ing of radioactive material; nonroutine events; licensee action on previously identified enforcement items; and, followup on regional office Bulletins. This inspec-tion was initiated during the evening shift (off-shift) on September 25, 1978. The inspection involved 32 inspector-hours onsite by one NRC region based inspector. Results: Of the 13 areas inspected; no items of noncompliance were identified in 12 areas; one apparent item of noncompliance was identified in one area (Infraction - instances of failure to follow procedures; attaching safety instructions to a work . permit; improper parking of fuel storage carts; and, health physics fai. led to sign a route card. (78-15-01)- Paragraph 4c, 4d and 5b. Region I Form 12 (Rev. April 77) 781206032E
DETAILS
- 1. Persons Contacted: i
*D. E. Ganley, General Manager, Naval Products Division
*W. Kirk, Manager, Nuclear and Industrial Safety Services
*J. Newman, Nuclear Criticality Safety Specialist
*T. Collopy, Manager, Nuclear Material Control D. Luster, Radiological and Environmental Control Specialist D. McFadden, Second Shift Superintendent R. Schwensfier, Nuclear Criticality Safety Specialist l
Others Contacted Chappell-Librarian, Raymond Hill Library, Oakdale, ' Mrs. Connecticut Dorothy (LPDR) The inspector also interviewed 25 other licensee employees during the course of this inspection.
- denotes those present at the exit interview. -
- 2. Scope of Operation
' The licensee continues to engage primarily in the manufacture of highly enriched uranium cores for The Naval Reactors Program.
- 3. Licensee Action on Previously Identified Enforcement Items (Closed) Infraction (371/78-06-02): Improper storage of two 5 gallon pails containing SNM in the Spectroscopy Laboratory. The inspector verified that the nuclear criticality safety posting for the ISAF area of the Spectroscopy Laboratory had been modified to allow storage of up to four 5 gallon pails outside of the storage rack in designated, evaluated, locations. In addition, the in-spector verified that laboratory personnel were reinstructed in the authorized storage criteria. Corrective actions have been completed on this item of noncompliance.
(Closed) Infraction (371/78-06-03): Two instances of failure to comply with protective clothing requirement. (1)l$andlingwet,- leaking containers which contained SNM without wearing gloves in' the Spectroscopy Laboratory. . The inspector verified that operators were reinstructed in the proper protective clothing to be used in the area. Individuals were also instructed to "think things through" prior to responding to incidents with hasty actions. (2) Handling
3 l potentially contaminated fuel storage cans in the storage vault I without wearing gloves. The inspector verified that the licensee has implemented requirements for operators in the Fuel Storage Vault to wear gloves when handling fuel storage cans. This require- I ment was implemented as required by June 8,1978. Corrective actions have been completed on this item of noncompliance. (Closed) Infraction (371/78-06-04): Failure to maintain air flow from areas of lower to areas of higher contamination. (Sectioning Area to Spectroscopy Laboratory) The inspector verified that the hinged pass-through window in the door between the Sectioning Area and the Spectroscopy Laboratory had been replaced by a window which tracks up and down. This window must be physically held open to use, otherwise, it remains in a normally closed position. Discussions held with facility maintenance personnel indicated that adjustments have been made to the system air flow balance and that measurements made by the licensee indicate an improvement in the air flow direction so that air flow is normally from the Sectioning Area to the
, Spectroscopy Laboratory to the Chemistry Laboratory. In addition it was noted that signs have been posted on the affected doors to remind personnel that these doors are not to be held open any longer than necessary. Corrective actions have been completed on this item of noncompliance.
(Closed) Deficiency (371/78-06-05): Failure to maintain the required 10 CFR 21.6 postings. The inspector verified that the licensee had uncovered and/or reposted the notices required by 10 CFR Part 21. Each of the postings have been marked "to Remain Permanently Posted - Do Not Remove." The licensee has completed corrective actions on this item of noncompliance. (Closed) Infraction (371-09-01): Failure to label containers of radioactive materials in compliance with 10 CFR 20.203(f). The inspector verified that the licensee has issued a policy statement in a Memo NIS:78-8-49 " Standards or other small quantities of uranium" dated August 30, 1978. This policy statement covers the identification, categorization, and disoosition of SNM according to 10 CFR labeling, marking - control requirements and it also covers the criteria established for the selection of an appropriate category. The inspector also verified that the containers identified during inspection 70-371/78-09 had been removed from the identified ,l storage areas. Corrective actions have been completed on this item l of ncncompliance. l (Closed) Infraction (371/78-09-02): Failure to carry out criticality controls in storing three containters. The inspector verified that the licensee had removed the two containers of SNM which had been
4 i 1 stored in unathorized locations in the filler fabrication areas. l The third container of SNM located in a safe in the Industrial l Hygiene and Safety Office had been properly labeled to identify the presence of SNM. In addition, instructions were posted in the filler fabrication areas which modified the techniaue for the storage of " empty" containers in such a way as to assure that these containers were, in fact, empty, and control of SNM in the disassembly area was modified by means of instructions posted by Memo NIS:78 54 dated June 26, 1978. Corrective actions have been completed on this item of noncompliance.
- 4. Off-Shift Review of Operations The inspector started this inspection with an unannounced off-shift examination of the facility at about 6:45 p.m. on September 25, 1978. During this off-shift inspection, the inspector observed operations and activities in progress and examined the nuclear safety aspects of operations being conducted in the facilities.
- a. It was noted that a new speaker for the plant PA system had been placed in the southeast room of the Structural Machine Shop. Announcemnets heard over this new speaker were heard clearly and any announcements made over the Plant PA system affecting safety should now be clearly heard and understood by personnel working in this area.
- b. It was observed that several fuel component shipping containers stored throughout the East Plant were not conspicuously marked as being empty and were stored in areas which were not authorized for storage of SNM. It was determined by the inspector that shipping containers which held SNM were being properly stored and that each of the empty containers was inconspicuous 1y marked as being empty. This was discussed at the exit interview and the inspector stated that empty shipping containers should be marked more conspicuously as being empty to reduce confusion on the part of employees as to the status of these containers.
- c. The inspector examined a work permit (SWP-3649) for the installation of a new 22 inch autoclave in the Building M Metals Processing Area. It was noted that this SWP identified 6 special instruction sheet.s which were to be attached to the SWP cover sheet to describe the safety requirements for this construction job. At the time of this inspection none of the special instruction sheets were attached to the SWP and could not be found in the immediate area by the inspector or the licensee representative accompanying the inspector. The special instructions which were to be attached inciuded the following:
1. Work Permit Attachment #1 - Electrical Instructions
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- 2. Work Permit Attachment #3 - Construction Instructions
'3. Work Permit Attachment #6 - Welding Instructions
- 4. Work Permit Attachment #8 - Sheet Metal Instructions
- 5. Work Permit Attachment #9 - Plumbing / Piping Instructions
- 6. Work Permit Attachment #10 - General Instructions Failure to attach the special instructions (safety requirements for the job)- to the work permit was identified as part of an item of noncompliance. These instructions were required to inform nonemployee construction workers of the safety require-ments for work to be done in this area. (78-15-01) p
- d. The inspector observed that two fuel storage carts which contained fuel bearing components.were unattended and were not parked in authorized cart park locations. One unattended fuel storage cart was located in an unauthorized location just north of the work zone designated for the fuel component cleaning line located in the Metals Processing Area of Build-ing M. The other unattended fuel storage cart was located in an unauthorized location between the welding boxes located on the north side of Building A. in each case, when area super-vision was informed of the situation, corrective action was immediately taken to park these carts in authroized locations.
Failure to park unattended fuel bearing storage carts in authorized locations was identified as part of an item of noncompliance. (78-15-01)
- e. The inspector noted that a nuclear criticality safety posting for a cart park area was partially covered by tarpaulins which were hung temporarily to separate the construction area for the new 22 inch autoclave from the rest of the facility in the Metals Processing Area of Suilding M. The tarpaulin was immediately repositioned by licensee representatives. -
- f. The inspector observed that components were being stored on a storage rack located in the northeast corner of Building B. By observation, neither the inspector nor the licensee representa-tive could identify if these components were fuel bearing or nonfuel'. If fuel bearing, the configuration, (double or single) could not be determined. There also was no paperwork in the area which could identify these components. A nuclear safety posting for the storage rack (NIS Authorization III-A-22 Revision 1 dated February 6,1978) under " controls" stated that "the above limit and controls may be voided out when and for such time as all fuel is removed from the area and nonfuel only is processed ud stored." The accompanying licensee
4 6 representative contacted the area foreman by telephone and I determined that all components in the. area were nonfuel bearing. Thus, there was no question of safety in the area during this iitspection. However, the inspector stated to licensee representatives that the nuclear safety posting appeared to be permissive if a means of identifying the presence or nonpresence of fuel bearing components was not specified and/or required. This item was discussed at the l exit meeting. (78-15-02) '
- 5. Review of Operations 1
The inspector examined all 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 in the facility.
- a. As the inspector entered Filler Febrication Area No. 2 it was observed that two emergency doors (?? and 33) located on the east side of Building B south were postea with signs " Warn-ing - Hazard Beyond Do Not Use!" Previous examination of the ,
area outside these doors indicated that at the time of this inspection there were no hazardous areas on the other side of these doors which would preclude their use in case of emergency. Discussion with licensee representatives indicated that there was construction work being done outside the building in this area which had been completed and warning signs had not been removed. However, the licensee representatives indicated that the signs would be removed immediately. This was not rechecked by the inspector. (See Paragraph 10c for additional details.) The inspector stated that the warning signs should have been removed as soon as construction was completed to afford person-nel full egress from the building in case of emergency. In addition, it was observed that the emergency door exit from the Chemistry Laboratory to the west side of Building :' was partially Slocked on the outside by laboratory supplies being delivered to the laboratory. This was dis 7ussed at the exit interview.
- b. During examination of Filler Fabrication Area No.1, it was noted thac the facility was undergoing a cleanup operation.
The inspector examined the posted route card " Color Code Change Cleanup -- type 1/3." Step two of the route card stated "HP to take reference smears of box / boxes as considered l necessary prior to producticn entering box / boxes. HP sianature l l 1 l l l
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7 required prior to production ent -ing box / boxes." At the time of this inspection, 3 product' arsonnel were observed within the boxes and Step 2 < oute card had not been signed by health physics pers n fact, as established, the posted route card indicate 'th physics sign-off for Step 2 was not applicable u1scussion with licensee representatives indicated that xes had been surveyed by health physics on September 18, ,and the route card had not be signed as of the date of this inspection September 26, 1978. The discussion also indicated that the smears obtained on September 18, 1978 by health personnel were clean and no hazard existed to production personnel entering the boxes. Failure to follow the requirements of the route card was identified as part of an item of noncompliance. (78-15-01)
- 6. Nuclear Criticality Safety
- a. The inspector examined criticality monitors located throughout the facility and observed that each monitor appeared to be operating as required. The inspector also examined the new nuclear alarm console panel which was installed in the primary guard station during plant shutdown during July-August,1978.
The alarm panel has a four color display; white-power on; amber-malfunction, bright amber-unit keyed out; blue-alert radiation level; red-alarm radiation level. The location of the alarm panel assures that there will be continuous observation of the status of these nuclear alarm monitors. Licensee records examined by the inspector indicated that the criticality monitors have been calibrated quarterly during the time period December 11, 1977 and September 24, 1978. Records also indicated t..at the monitors had been recalibrated whenever repair work was done prior to placing the affected unit back into operation.
- b. The inspector examined licensee records which indicated that vessels RT-1 and RT-2 waste receivers had been inspected at least once each month, from March 31, 1978 through Septem-ber 22,1978, to verify raschig ring content levels. Licensee records also indicated that raschig rings were removed from tanks RT-1 and RT-2 on April 14, 1978 and from tanks 3 and 4 on May 3,1978 for chemical analysis of the raschig rings for B02 3 content. Chemical analysis results indicated that the B203 content of the rings removed from the tanks ranged from 12.48% to 13.68% which was within the range of 11.8 to 13.8%
of B 02 3 required by license conditions.
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- c. The inspector examined the Criticality Control Review Log for the time period April 6,1978 through June 27, 1978 (CCR-625 throught642). The inspector noted that none of the CCR's examined required dual review and that most of the CCR's involved realignment of criticality zones based on NRC approved criteria.
- d. The inspector examined the licensee's reply to the annual audit of the nuclear criticality safety program at this facility.
The audit was conducted by a person from outside the division during the month of March 1978. The audit report, dated March 29,1978, was previously examined during inspection 70- ' 371/78-06. The reply letter dated May 30, 1978, covered two points raised in the audit report. The floor marking system and the use of plastic overlay plant layouts. In each case, the licensee reiterated to the consultant, the rationale for using the systems concerned and indicated that corrective action had been initiated on all points raised in the audit report. This was verified by the inspector.
- e. The inspector questioned licensee representatives regarding the conduct of internal reviews and audits during the time period April 4,1978 through September 21, 1978. The inspector reviewed the reports of 68 internal NIS inspections which were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular and off-shift hours and examination of required equipment inspection reports. The inspector verified that corrective actions had been taken in each instance which was identified by the licensee as requiring corrective action.
- 7. Safety Committees The l';ensee has delegated responsibility to facility safety reviews to the Nuclear and Industrial Department. This department overviews Health Physics, Nuclear Criticality and Industrial Safety throughout the facility through random inspections and audits of the facility. Results of the random inspection relative to Nuclear Criticality Safety was previously discussed in Paragraph 6e of this report. In addition the facility manufacturing department has established a Plant Housekeeping Committee which performs monthly inspections. The inspector examined a report of a recent inspection conducted September 14, 1978. This report listed housekeeping action items observed during the inspection. The report also indicated the groundrules for completion of the action items including responsibility for completion, responsibility for review to assure completion, date for the review and the date for the next inspection.
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- 8. Nonroutine Events The inspector reviewed licensee actions with respect to the following nonroutine events to verify that the events were reviewed and evaluated by the licensee as required by licensee conditions and federal regulations; that corrective actions were taken by the licensee and that safety limits were not exceeded. The inspector examined license investigation reports and records, and interviewed selected personnel.
- a. (Component Cleaning) Misoperation on July 21, 1978.
- b. ISAF Sludge Bottle Spill on August 23, 1978.
- c. Power failure on September 22, 1978.
In addition, the inspector examined the completed evaluation of the metal fire in a wet cutamatic hood located in the sectioning area which occurred on August 8,1978. In each case, the inspector determined that the licensee used conservative evaluation techniques and that corrective actions had been taken or initiated to preclude recurrance of the incident.
- 9. Maintenance
- a. Work Permits The inspector reviewed the content and applicability of a Manufacturing Department Procedure (MDP-107 Revision 0 dated December 20,1976, " Work Permit Procedure") which establishes a work permit system to control the maintenance, repair, remodeling, and construction activities on the site when such activities require special precautions to protect people, product, equipment, and/or facilities. Those activities requiring work permits include but are not limited to:
welding, burning and cutting non-product; painting; construction; remodeling; soldering and brazing sheet metal; grinding; and equipment installation or relocation. The work permit is a document issued prior to the start of activities given above for the purpose of providing specific instructions regarding safety to the personnel involved in such activities. Work permit attachment are issued along with work permits when the activities are such as to require additional safety instructions to those noted on the work permit. These attachments provide additional safety instructions covering the construction activities listed above. Whenever a work permit is issued covering work to be done in the Building B south contamination control areas, a Health Physics Special Work Permit may also be issued. Personnel issuing the work permit are responsible
10 for also obtaining the Health Physics Special Work Permit prior to the start of work in contamination controlled areas. No instances of failure to obtain a health physics special work permit were identified by the inspector. However, an instance of failure to attach the required attachments to a work permit issued in the Metals Processing Area of Building M was previously discussed in Paragnph 4c of this report. These attachments were required to inform non-employee con-struction workers of the safety requirements for work done in l . this area.
- b. Preventative Maintenance The licensee has established a preventative maintenance program which covers equipment items including those which are necessary for safe operation of the facility (i.e. alarm systems, nuclear alarms, ventilation system components, smoke detectors, heat sensors, mixing valves). The inspection cycle varies from weekly to annually depending on the equipment involved. A preventative maintenance schedule is established and issued to each shop area approximately one to two weeks prior to the start of maintenance so that the shop supervisors can schedule operations within the shop around the maintenance being performed.
- 10. Facility Changes and Modifications
- a. The inspector noted that site work had been started for the construction of Annex 3 to the Ea3 Plant facility. This new building will be located at the north east corner of the East Plant. A soll Butler type building (the Carpenter Shop) had been moved from a location just north east of the East Plant to a location at the south east corner of Building M. Portions of the slope running east of Building C has been regraded and leveled to the elevation of the East Plant. The north east, east and south east site fence lines have been relocated in order to facilitate relocation and construction of an access road on the site around the new building. As of the time of this inspection, actual pouring of the building footings and construction of the building had not been started. The inspector determined through discussions with licensee repre-sentatives that this new building will be used for the storage of fuel and nonfuel bearing components.
- b. It was observed that the licensee is installing a concrete pipe chase around the pipes leading from Buildings A and M to the spent acid storage tanks. This pipe chase will facilitate examination and repair of these pipes, if necessary, without excavating the road bed.
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- c. It was noted that the area, between Building B and Building A, had been excavated to repipe the cooling water from various units from the site septic system to the storm drain system.
It was this excavation which necessitated placing the warning signs on the emergency doors 22 and 33 leading from Building B south to the outside which was previously discussed in Para-graph Sa.
- d. It was observed that a'new fresh acid storage room has been added at the west end of Building B.
- e. The inspector observed that a new emergency exit had been cut in the concrete wall located between the Building M Metals Processing Area and the Building A Metals Processing Area.
- 11. Licensee Action on Regional Office Bulletins and Circulars The inspector examined licensee reports, made direct observations and interviewed selected licensee personnel to determine the status of licensee review and/or implementation of the following NRC Inspection and Enforcement Circulars and Bulletins.
- a. IE Bulletin 77-08 " Assurance of Safety and Safeguards During an Emergency-Locking Systems"
- b. IE Circular No. 77-14 " Separation of Contaminated Water Systems from Noncontaminated Plant Systems"
- c. IE Circular No. 77-15 " Degradation of Fuel Oil Flow to the Emergency Diesel Generator" The inspector determined that the licensee had examined each of these documents for applicability and in each case no problem areas were identified.
- 12. 10 CFR Part 21 The inspector reviewed the policy statement " Reporting Substantial Safety Hazards to the General Public" which had been issued as Policy Statemert No.18.01 Revision 0 on June 27, 1977. This document establishes and defines the criteria used for the evalu-ation of substantial safety hazards and specifies the evaluation and reporting procedures required for the prompt notification of UNC-NPD management specifies the required reporting sequence and establishes an internal facility evaluation committee.
- 13. Training
- a. The inspector discussed the current status of reorientation L _ _ _ _ _ _ - - -_ _ - .
12 training with licensee representatives. It was determined that the lic"1see had discontinued relying on a personnel screening test program to determine employee knowledge in the areas of health physics, security, safety (including emergency procedures and nuclear criticality safety). Instead, the licensee established an intensive campaign to give classroom training required by licensee conditions to each employee by means of video tape films which had been prepared to cover each of the required areas. This intensive training schedule was started on July 17, 1978 and was essentially completed by September 22, 1978. During this time period all but 23 facility employees received the required reorientation training. These 23 have been scheduled for reorientation training which will be completed by October 15, 1978.
- b. The inspector reviewed the continuing training records for the time period January,1978 through September,1978. The following topics were covered during this time period: Health Physics Aspects of Building B South: Security; Criticality; Compliance on Procedures; Safety; Contamination Incidents; What is Radi-ation?;. Types of Radiation; and. The Material Handling Manual.
- c. Initial indoctrination of employees is given usually within the first three weeks of employment at the site. Topics discussed included: Health Physics; Criticality; Emergency Procedures; Security Indoctrination; Materials Control; Records; and, Oreintation on Processes. Retention of material presented during initial indoctrination is determined by means of tests given in each subject covered. The number of employees receiving initial indoctrination since January 1,1978 was not determined by the inspector during this inspection but will Le determined during a subsequent inspection.
- 14. Packaging and Shipment of Radioactive Material _
During inspection 70-371/78-06 the inspector observed that the licensee was refurbishing shipping containers which were previously identified with a DOT 5782 designation and were being marked with a USA /6406/BF (ERDA-NR) identification number. During the current inspection, the inspector examined the documentation relating to these packages which was being maintained as required by the licensee. Other aspects of shipping and receiving of SNM will be examined during subsequent inspection.
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- 15. Emergency Medical Incident Test l
The inspector observed an emergency drill which included a scenerio that involved an accidental criticality incident in the chemistry laboratory with an injury combined with personnel contamination. During the test, an individual was transferred to the emergency control center, slightly decontaminated, medical injury a' tended to, and then the man was transferred to but not into the local hospital by means of the local ambulance service. This test was run to test the response capability of the local ambulance service and as an adjunct it was used to prepare a training film which will be used by the licensee during future training sessions concerning emergency preparedness.
- 16. Visit to the Local Public Document Room The inspector visited the facility local public document room which was located at the Raymond Hill Library, Oakdale, Connecticut on the evening of September 27, 1978. It was determined that this library was receiving the reports issued by NRC and that these reports were available for inspection by the public.
- 17. Exit Interview The inspector met with licensee representatives (denoted in Para-graph 1) at the conclusion of the inspection on September 28, 1978, at 4:00 p.m. The inspector summarized the scope and findings of the inspection. Licensee representatives made the following remarks in response to items discussed by the inspector.
Stated that it was their understanding that the attach-ments to the work permit were found on a table located in the construction area and that they had been attached to the work permit prior to the end of the inspection. (Paragraph 4c) Stated that the posting concerning nonfuel bearing compo-nents would be modified to indicate that nonfuel bearing components must be identified as such prior to disregarding the posted limits. (Paragraph 4f) Stated that the signs on the two emergency doors were to be removed to allow use of these emergency exits if required. (Paragraph Sa) The inspector also informed the licensee that the office commerical telephone number had been changed to 215-337-5000 effective Octo-ber 2, 1978.
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14 On September 29, 1978, the inspector held a telephone discussion with Mr. T. Collopy concerning the information discussed during the exit meeting with regard to attachment of instructions to the posted work permit. Mr. Collopy restated the information indicated above and that the instructions had been retyped and attached to i the work permit on the morning of September 26, 1978. The inspector I indicated that an unsuccessful effort had been made to locate the i instructions in the area at the time of the inspection as stated in Paracraph 4c of this inspection report and that this item would remain as part of an item of noncompliance. l O L}}