ML20212K957

Insp Rept 70-0371/86-07 on 860721-25.Violation Noted:Failure to Maintain Record of Nuclear Criticality Safety Insp Conducted During Months of Jan,Mar & May 1986

ML20212K957
Person / Time
Site:	07000371
Issue date:	12/31/1986
From:	Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20212K921	List: ML20212K918 ML20212K944 ML20212K957
References
70-0371-86-07, 70-371-86-7, NUDOCS 8701290251
Download: ML20212K957 (7)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-371/86-07 Docket No.70-371 License No. SNM-361 Priority 1 Category UHFF Licensee: UNC, Inc./UNC Naval Products Division 67 Sandy Desert Road Uncasv111e, Connecticut 06382 Facility Name: UNC Naval Products Division Inspection At: Montville, Connecticut Inspection Conducted: July 21-25, 1986 Inspector: of J. Rot , P1ojEct Engineer N-! b

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Approved by: /2- 3/- /T-

/.R Keimig,[hief afeguards Section, date Inspection Summary: Inspection on July 21-25, 1986, (Report No. 70-371/86-07)

Areas Inspected: Routine unannounced inspection by a region-based inspector of: operations; nuclear criticality safety; organization; radiation protect-ion; radioactive waste management; transportation; nonroutine events; and emer-gency preparedness.

Results: One violation was identified: failure to maintain a record of nuclear criticality safety inspections conducted during the months of January, March, and May, 1986 (paragraph 4.d).

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4 DETAILS

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' 1. Persons Contacted

• N. C. Kaufman, President and General Manager a

• R.'J.'Gregg,. Director, Technical Services

• W. Kirk, Manager, Nuclear and Industrial Safety -

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T. Gu_tman, Criticality Safety Specialist D. Luster, Health Physics Specialist P. Smith, Criticality Safety Engineer- I

• Present at the exit interview.

2. Review of Operations j The-inspectoriexamined all areas of the p' ant to , observei operations and

-activities in progress, to inspect the nuclear safety aspects of operat-ions and to check the general status of cleanliness, housekeeping, and '

adherence to fire protection rules.

a. Housekeeping During examination of the plant, the inspector observed that house-keeping had been improved under the Building M room air supply fan, 4

in the building A basement, and on the upper level of the East Build-

ing low bay area. Housekeeping in those areas had previously-been-

! identified as inadequate during NRC Inspection No. 70-371/86-01.

However, the inspector observed that housekeeping in the Annex III l storage building was not adequate'in that all emergency egress paths -

I from the east end of the building had been blocked with non fuel bear-l ing material and equipment. When the inspector inquired about this-condition, licensee representatives stated that the non fuel bearing material and equipment had been temporarily moved into this area of the Annex III storage building in preparation for maintenance work in other areas of the plant during the annual plant shutdown because this area is infrequently occupied. The shutdown was to start on July 28, 1986, two days after the end of this inspection. This was identified as an Inspector Follov.p ltem (IFI) 371/86-07-01.

No fire protection /preventian i adi :acies were observed during the inspector's plant tour.

b. Storage Box Transfer Cart During NRC Inspection No. 70-371/86-02, the inspector could not ver-ify ae piece count of poisoned or fuel bearing components stored in covered boxes on a transfer cart. As a result, the inspector quest-ioned the validity of the criticality safety limits specified on the posted authorization. Subsequent to that inspection, the licensee

. 3 re-evaluated the . limits and found that the boxes were safe, even if filled te capacity. The limits on the posted authorization were changed to reflect this conservatism. The inspector had no further questions on this item.

3. Nuclear Criticality Safety

a. Facility Modifications Through discussions with licensee representatives, the inspector de-termined that the licensee was planning an expansion of the unclad fuel component fabrication area in Building B-South. As a result,

, the inspector requested the licensee to submit this information along with available preliminary planning drawings and information to the NRC's Office of Nuclear Material Safety and Safeguards. This was identified as an Inspector Followup Item (IFI) 371/86-07-02.

b. Residual Storage Cabinet During examination of the Residual Storage Cabinet located in the Unit 1 Quality Assurance area, the inspector observed that the run-ning log posted on the cabinet indicated a total of about 2700 grams of residuals. The quantity of residuals authorized by the posted criticality safety sign was 10,000 grams. A cabinet inventory check conducted by the inspector indicated the presence of about 5600 grams. Control No.3 on the posted sign stated, in part, that, the quantity, in grams, in the cabinet shall be posted and shall be main-tained to reflect current cabinet contents. Through discussions with an operator present in the area, the inspector determined that about 2900 grams of residuals had been prepared for transfer on July 18, 1986 (three working days earlier), and he had been trying to get

! material control and accounting personnel to effect the transfer l since that time. (The transfer finally took place prior to the end l of this inspection.) The inspector advised licensee representatives that, while the authorized limit of 10,000 grams had not been ex-ceeded, care must be taken to assure that the log reflects the cur-rent cabinet contents, so as not to exceed the posted criticality safety limit. The licensee stated that operators would be rein-structed to assure that the log is not changed until the transfer of material actually takes place. This was identified as an Inspector l Followup Item (IFI) 371/86-07-03.

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c. Raschig Ring Inspection and Analysis

, Licensee records, examined by the inspector, indicated that the ras-( chig ring level in all applicable tanks had been inspected by the licensee at least quarterly between January 2,1986 and July 24, 1986. No inadequacies were identified.

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2 I The licensed s records also indicated that raschig rings were removed l from vessels RT-1, RT-2, Sectioning Left and Sectioning Right, on

! April 26, 1986 for chemical analysis. The results indicated that the

'B20 content of the rings ranged from 11.9% to 12.1% which is within

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the range of 11.8 to 13.8% of B2 0 required by the license condition.

d. Internal Reviews and Audits

. The inspector questioned licensee representatives regarding the con-i duct of internal reviews and audits from January 2, 1986 through June 30,.1986. The licensee has placed the data resulting from these reviews and audits into a. computerized record system, which the Itc-1 ensee considers as the official record. Available for display on the computer terminal is each of the NIS Authorizations posted throughout the facility (each authorization designates a storage location, work j station or transfer cart), the date that each authorization.was exam-j ined, the work shift during that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period, and whether any vio-4 1ations were identified. A hard copy of each violation identified the corrective action taken, and the completion date is maintained separately by the-licensee. The inspector reviewed the computer re-cords of all Nuclear and Industrial Safety (NIS) inspections which were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular and off-shift hours. The inspector verified by examining hard copies of the re-i cords that corrective actions had been taken or initiated in each instance identified. However, the computerized records examined by i the inspector did not indicate any reviews and audits of plant activi-ties by NIS criticality safety personnel during the months of L January, March, and May,1986. Monthly internal reviews and audits are required by Section 2.7.3 of the NRC-approved license applica-l tion. Subsequently, the licensee was able to demonstrate from other l unofficial documentation that the reviews and audits.were conducted,

, but that they were not documented as required. Failure to document i NIS criticality safety reviews and audits for the months of January,

! March and May, 1986 was identified as a violation of NRC require-ments(371/86-07-04).

L e. Nuclear Safety Evaluations t The inspector examined 13 nuclear safety evaluations (962-974) con-

, ducted by the licensee between January 8, 1986 and May 19, 1986.

Licensee evaluations were found to be conservative and that a second, l independent review was conducted when required.

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4. Radiation Protection f a. Air Sampling (1) General Area Samples Section 4.1.3 of the approved license application requires that n

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4 in plant air concentrations in excess of 50% of maximum per-missible concentration (MPC), (1 E-10 uti U-235/ml or 220 dpm/

m3 ), require prompt evaluation, i.e., investigation and deter-mination of corrective action.

The inspector examined licensee records of general area air sam-ple results from February 1,1986 through Jure 30, 1985. The inspector did not identify any instances where air concentrat-ions exceeded the action levels.

(2) Stack Air Samples Section 4.1.2 of the approved license application states that any gaseous effluent discharge samples which exceed 25% of the 10 CFR Part 20 limits (4E-12 uCi U-235/ml or 8.8 dpm/m 3 ) shall be immediately resampled and an investigation conducted to deter-mine the source of the release. The inspector examined licensee records of stack air sample results from February 1,1986 through June 30, 1986. The inspector did not identify any re-leases which exceeded the action levels specified in the facil-ity license.

b. Smear Samples The inspector examined random licensee records of smear sample tests performed in the Sectioning Area, the Metallurgical Laboratory and Buildings A, B and M (cold side) on floors and equipment from January 9, 1986 through July 22, 1986. The records indicated that all contamination in excess of specified action levels was immediate-ly cleaned up, as required.

l c. Hood Air Flow The inspector examined licensee records of hood air flow measurements conducted monthly between June 27, 1985 and June 30, 1986. The re-cords indicated that corrective actions were taken, as required, to assure that air flow at the face of the hoods was maintained at a minimum of 100 linear feet per minute.

5. Non-routine Events The inspector determined through review of licensee records and discuss-ions with licensee representatives that no non routine events, within the l scope of this inspection, occurred at the facility since the last inspect-l ion.

l l 6. Emergency Preparedness During examination of the facility's secondary alarm station (SAS), the l inspector noted that the normal entrance and egress for the SAS is by

( means of a steep set of steps. The inspector questioned the safety in l

. 6 using these steps during an evacuation condition. An alternate route is available, but it could be equally hazardous in the event that an evacuat-ion was necessary. According to licensee representatives, evacuation of the SAS was never tested under simulated emergency conditions and the egress routes have never been used during an actual emergency. The in-spector suggested that this matter be re-evaluated, considering both safe-ty and security. This was identified as an Inspector Followup Item (IFI) 371/86-07-05.

7. Waste Handling

a. Waste Handling Building The inspector observed that the licensee had almost completed con-struction of a new waste handling building that was connected to the unclad fuel handling area at the south outside wall of Building B.

According to licensee representatives, that facility was expected to be completed and in operation by September 1, 1986. The licensee expects to compact, package, store and prepare uranium contaminated waste for shipment from this facility,

b. Radioactive Waste Packaging The inspector observed that the licensee had completed removal of drums of radioactive waste from the " dog pen" located adjacent to the East wall of Building M.

In addition, the licensee had completed the removal of contaminated material stored in trailer No.1 and the locked storage area located in the Building B-South basement. The inspector confirmed that all waste removed from these areas had been repackaged, as necessary, prepared for shipment, and transported to an approved burial site.

B. Shipping of Radioactive Material The inspector examined licensee records of six radioactive waste shipments and five radioactive scrap fuel shipments made between August 28, 1985 and l July 18, 1986. The inspector determined that radiation surveys were made and recorded, and that all shipments were labeled, marked, placarded, in-spected, and recorded as required by federal regulations.

9. Exit Interview The inspector met with the licensee representatives (denoted in paragraph

1) at the conclusion of the inspection on July 25, 1986. The inspector presented the scope and findings of the inspection. The inspector also held a pre-exit discussion with the Director, Technical Services prior to the exit interview. These discussions were found to be helpful in that licensee management was able to address their planned actions, as a result of inspection findings, at the exit interview.

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• 7 The inspector did not provide the licensee with any written material during the inspection.

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