ML20203C867
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| ML20203C867 | |
| Person / Time | |
|---|---|
| Site: | 05000054, 07000687 |
| Issue date: | 03/27/1986 |
| From: | Della Ratta A, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20203C794 | List: |
| References | |
| 50-054-86-01, 50-54-86-1, 70-0687-86-02, 70-687-86-2, NUDOCS 8604210254 | |
| Download: ML20203C867 (6) | |
See also: IR 05000054/1986001
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-54/86-01
70-687/86-02
Docket Nos. 50-54
70-687
License Nos. R-81
SNM-639
Safeguards Group: I
Licensee: Cintichem, Inc.
P. O. Box 324
Tuxedo, New York 10987
Facility Name: Sterling Forest Research Center
Inspection At: Tuxedo, New York
Inspection Conducted: February 10-14, 1986
Type of Inspection: Material Control and Accounting, and Physical Security
Date of Last Material Control and Accounting Inspection: August 19-23, 1985
Date of Last Physical Security Inspection: April 24-26, 1985
Inspector: $4
A. Della Ratt'a, Saf
Ltl~
ards Auditor
3-M-f6
date
Approved by: .M 1 g7-JIC
. R. Keimi
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Ch , Safeguards Section date
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[ Nuclear eri . Safety and Safeguards
Branch, SS
! Inspection Summary: Inspection on February 10-14, 1986 (Combined Report
Nos. 50-54/86-01 and 70-687/86-02).
Areas Inspected: Nuclear material control and accounting, and physical security,
including: facility organization and management controls; facility operations
and internal controls; reactor material control and accounting; and physical
protection measures for special nuclear material of moderate strategic signi-
, ficance.
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DO [[
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Results: Five violations were identified: failure to complete internal
transaction reports and the MBA. logbook, (paragraph 6); failure to tamper-safe
10 waste barrels in accordance with written procedures (paragraph 6); failure
to use standard waste barrels that were representative of the full range of the
normal process waste barrels being radiometrically analyzed (paragraph 6);
failure to notify the Commission, within two months, of changes made to the
l NRC-approved physical security plan (paragraph 8); and failure to maintain l records to show compliance with certain requirements as specified in Sec- l tions 3.6 and Section 4.4 of the Physical Security Plan (paragraph 8). {
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! DETAILS
1. Key Persons Contacted
*J. McGovern, Plant Manager
*C. Konnerth, Manager, . Site Operations
*W. Ruzicka, Manager, Nuclear Operations
. *L. Thelin, Radiation Safety Officer
J. Ditton, Health Physics Supervisor
R. Strack, Reactor Supervisor
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S. Lupinski, Chief Reactor Operator
J. Kratochwil, Supervisor, Site Utilities
]
The inspector also interviewed other licensee employees associated with
plant operations, nuclear material control, and physical security.
*present at exit interview
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2. 30703 - Exit Interview
The inspector met with the licensee representatives indicated in para-
graph 1 at the conclusion of the inspection on February 14, 1986, and
summarized the scope and findings of the inspection.
At no time during this inspection was written material provided to the
licensee by the inspector.
3. 92702-Licensee Action en Previously Identified Enforcement Item
-(Closed) Violation (70-687/84-05-02): Failure to conduct the annual
management audit in accordance with the requirement of Section 8.2 of the
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fundamental nuclear material control plan (FNMCP). The inspector's review
of the last management audit, dated October 24, 1985, determined that the ,
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audit was in accordance with the requirements of the FNMCP in that all -
functions were audited and the audit was conducted by an individual who
.' was independent of nuclear material control management, measurement or i utilization. ,
4. 92704-Fo110wup on Headquarters Requests
The inspector reviewed, and discussed with the licensee, the actions
i taken with regard to the NRC Commission Order of September 27, 1985, that
required non-power reactor licensees to show cause why they should not be
L required to reduce the amount of high enriched uranium (HEU) onsite to
- that amount necessary to maintain a normal schedule of operations. Speci-
fically, this Order permits the licensees to keep no more than enough fuel
,
to (1) replace one failed element for each different type of element in
- the core, and (2) replace the amount of fuel depleted during a 90-day
- period of normal operations.
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The licensee's MTR research reactor operates on a 95% duty cycle at a
power level of five megawatts which corresponds to a fuel usage of 28
standard elements per year and is maintaining an inventory of not more
than seven unirradiated standard fuel element assemblies. The licensee's
unirradiated fuel inventory, as of February 14, 1986, was 2 standard
elements and 5 control elements, which is equal to 4.5 standard elements.
(A control element has one half the amount of HEU of a standard element
and, therefore, is counted as one half of a standard element, for inven-
tory purposes.)
5. 85203 - Facility Organization and Manaaement Controls
The inspector discussed with management and reviewed the licensee's annual
audit of the Fundamental Nuclear Material Control Plan (FNMCP) which was
conducted during October, 1985. The results of this audit were documented
on October 24, 1985.
Several minor deficiencies were noted, and some recommendations were made
to management for improvements. Management took corrective actions on the
deficiencies, and responded to the recommendations in a timely manner.
6. 85205 - Facility Operation and Internal Controls
This portion of the inspection included observations, discussions with
licensee personnel, a review of the licensee's records and NRC-approved
FhMCP.
The inspector identified that 319 grams of U-235 had been transferred from
MBA 1 to M3A 2 and then returned to MBA 1 without the completion of an
internal transaction report and recording the transfers in the MBA 1 and
MBA E logbooks. The licensee stated that they did not believe the use of
transaction reports was necessary, since it had been a standard practice
to use a portion of the solution laboratory (MBA 2) as a part of MBA 1
when processing current receipts of feed material from a solid state to
a solution. Also, the licensee stated that the MBA 1 custodian / alternate
never releases possession of the material while it is being processed in
MBA 2. However, the above technique for handling this material is not as
described in the NRC-approved FNMCP. This technique was discussed with
R. Jackson, NRC NMSS, on February 13, 1985 and February 19, 1985, who con- )
curred with the inspector that this handling technique is not in accord-
ance with the NRC-approved FNMCP. This was identified as a violation of
Section 7.2 of the NRC-approved FNMCP (70-687/86-02-01) which requires the
transaction reports and MBA logbooks to be completed promptly, at the time
of transfer.
The inspector's review of the licensee's records identified that the
ten barrels of waste material had been radiometrically analyzed on
January 15, 1986, but had not been tamper-safed immediately after the
completion of the analyses. The ten barrels of waste were tamper-safed
on January 17, 1986. This was identified as a violation of 10 CFR 70.51
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(e)(1)(i) and paragrpah 2.b., of the licensee's tamper safing procedure
titled, " Security Seals for the Protection and Control of Special Nuclear
Material"(70-687/86-02-02) which requires the tamper-safe seal to be
applied immediately after the samples and data to identify and measure
the contents are taken.
In conjunction with the radiometric analyses of the ten waste barrels,
the inspector identified that the licensee failed to use Standard Waste -
Barrels that had been calibrated and that were representative of the full
range of the waste barrels being analyzed. The high concentration of the
Standard Waste Barrel used for the radiometric analysis was 13.99 grams
U-235. However, three waste barrels that were analyzed contained 15.01
grams U-235, 19,58 grams U-235, and 19.25 grams U-235. This was identi-
fied as a violation of Section 4.2.1.4.f. of the FNMCP (70-687/86-02-03).
7. 85102 - Material Control and Accounting
a. Inventory r
The inspector performed an inventory verification, on February 12, 1986,
which consisted of a piece count of the fuel elements and fission ,
counters in the spent fuel pool and storage area vaults, and a com-
parison of the fuel location history sheets to the reactor core and
storage area schematics. No discrepancies were noted. The licensee
had conducted physical inventories as required by 10 CFR 70.51 (d).
The licensee's last physical inventory was performed October 2,1985.
.b. Records and Reports
The inspector reviewed the licensee's rocords, source data, and
Material Balance Reports (00E/NRC Form-742) submitted during the
period Octcber 1,1982-September 30, 1985. Total uranium and U-235
fission and transmutation records were also reviewed. No discrepan- ,
cies were noted.
8. 81480 - General Physical Security Requirements for SNM of Moderate
Strategic Significance
The inspector reviewed the licensee's protecticn of special nuclear
material of moderate strategic significance, for conformance to the
NRC-approved physical security plan, by examining barriers and access
controls, procedures, and by observations of a licensee test of alarm
system features. Implementation of the physical security plan was found
to meet the general performance requirements and objectives of the govern-
ing regulations except as follows:
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a. Security Plan Changes
.The inspector's review of the licensee's NRC-approved physical
security plan identified that the licensee had made changes on
January 31, 1985, and November 1, 1985, but had not submitted these
changes to the NRC within two months after the changes were made, as
required, by License Condition 9.1 of Safeguards Anwndment SG-1,
dated April 12, 1985, and 10 CFR 70.32 (3). Examples of the changes
made are as follows:
1. Tills PAEG'APH CONTAINS SAFEGUARDS
INF0ElliT'0" IUD IS NOT FOR PUBLIC
DISCLCSUilE,II13 INTENIl0NALLY
LEFT DLANK.
2.
Tills PARAGRAPH CONTAINS SAFEGUARDS
INF0'ifMIM C']15 NOT FOR PUBLIC
DISCLOSuiT.111.iINTENTIONALLY
LEFT DLANK.
3. Job titles of certain positions as described on page 3.4 and
page 4.1 of the Physicial Security Plan had been changed on
November 1, 1985 as indicated below:
From H
Plant Manager, Radiochemicals Plant Manager
Nuclear Facility Services Engineer Hot Lab Operations Supervisor
Manager, Engineering and Maintenance Manager, Engineering and
Technology Sales
Failure to submit these changes to the NRC within two months was iden-
tified as a violation (70-1100/86-02-04, and 50-54/86-01-01).
b. Procedure Policy
THIS PARA 99APil CONTAINS SAFEGUARDS
INF01fMT!CH AMD !S !!]T FOR PUBLIC
DISCLOSURE. li i2 HlTENTIONALLY
LEFT DLANK.
Failure to maintain records in order to show compliance with Sections
3.6 and 4.4 of the physical NRC-approved physical security plan was
identified as a violation (70-687/86-02-05, and 50-54/86-01-02).
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