ML20215N432

Forwards Unc,Inc 860929-1003 Feeder Rept.Technical Aspects of Nuclear Criticality Safety Training,Analyses & Monthly Insp Extremely Weak.Unc Diluting Process Liquids from Sectioning Area Rather than Treating Liquid

ML20215N432
Person / Time
Site:	07000371
Issue date:	10/23/1986
From:	Bidinger G NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8611050397
Download: ML20215N432 (7)

Text

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.g 007 2 31986 MEMORANDUM FOR: Jerry Roth, Project Engineer Nuclear Materials Safety and Safeguards Branch, RI THRU: W. T. Crow, Acting Chief

. Uranium Fuel Licensing Branch Division of. Fuel Cycle and Material Safety, NMSS FROM: George Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS

SUBJECT:

FEEDER REPORT, ASSESSMENT OF UNC, INC.,

MONTVILLE, CONNECTICUT, SEPTEMBER 29 - OCTOBER 3, 1986, DOCKET 70-371 .

1 Enclosed is the subject feeder report.

4 UNC appears to place total reliance on employees following procedures. There is no evidence of any other real management involvement in the Nuclear Criticality Safety Program. The technical aspects of nuclear criticality safety training, a.nalyses, and monthly inspections are extremely weak. UNC goes through the motions to satisfy the regulatory requirements, but there is little evidence, if any, that UNC management is involved in assuring a quality 4

nuclear criticality safety yogram.

The saving aspect of this program is that most of the UNC process does not involve liquid processing. The customer.'s (DOE) requirements for quality do more to assure nuclear criticality safety than UNC management. These requirements help to reduce the probability of a nuclear criticality accident.

Dur.ing this nuclear safety assessment, I noted that UNC is diluting process liquids from the sectioning area rather than treating the liquid.

This is not an acceptable ALARA process. This results in more uranium going I into the septic system, an activity that is already a regulatory concern.

j Original Signed By:

George Bidinger Uranium Process Licensin'g Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Material Safety, NMSS 8611090397 861023

Enclosure:

As stated PDR ADOCK 07000371 C PDR DISTRIBUTION: w/ encl A Docket 70-371V GHBidinger(2) VLTharpe GSjoblom,IE NMSS r/f FCUP r/f PDR FCUF r/f WTCrow nA >

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NAME:GHBidinger:ht :VLTharpe :WTCrow  :  :-  :

DATE:10/th/86 -

10/f186 :10/h/86:  :  :

0FFICIAL RECORD COPY 4

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OCT 2 3 79y

SUBJECT:

FEEDER REPORT, ASSESSMENT OF UNC, INC., MONTVILLE, CONNECTICUT, SEPTEMBER 29 - OCTOBER 3, 1986, DOCKET N0.70-371

Reference:

Temporary Instruction, TI2600/1, Inspection of Plant Operations of Uranium Fuel Fabrication and Conversion Facilities Introduction The writer was the NMSS representative on the Region I team performing the I inspection required by the IE temporary instruction. referenced above. The administrative controls for nuclear criticality were reviewed assessed and are reported herein.

I. Policy and procedures i A. Observation Initially, the inspector was provided a copy of the corporate policy on Corporate Safety, Environment, and Health dated May 1981.

This document was withdrawn by the UNC _ Technical Services Director because it was under revision by the new corporate officers.

4 Finding A review of the policy document was not permitted by UNC.

B. Observation

A division policy document (15.01-1) states that employee safety and prevention of accidents is one of the most important functions of any person. Another policy document (26.34-2) provides policy that all persons are to erhibit strict compliance with operating procedures.

Another policy statement (13.02-3) requires that all operations be approved by Nuclear and Industrial Safety. The policy (15.01-1) also requires Group Managers.to participate in safety inspections.

Findings

1. UNC policy establishes' nuclear criticality safety. requirements for_all employees.

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2. Group Managers do not. participate in nuclear criticality safety inspections.

2 OCT 2 3199g C. Observation The Division Organization and Policy Manual provides job descriptions for the Division President and his principal staff.

The President is responsible to interpret and ' apply corporation objectives, policies,and-programs. The Vice Presidents of Operations and Quality Control have responsibilities to assure proper working conditions in accordance with requirements for 4 criticality safety ... and "to perform auditing functions as related to ... criticality ...." The Engineering Vice President (VPE) had no criticality safety responsibilities in his job description. However, a policy statement requires that Engineering shall define all needed shop documents. Shop documents include nuclear criticality control documents.

Findings

1. The job description of the President and the Vice Presidents 13f Operations (VP0) and Quality Control (VPQC) establish responsibilities for nuclear safety.

2. The job description of the VPE does not establish any requirements for nuclear criticality safety. The VPE is responsible for designing safe geometry fixtures and for providing Route Cards which included nuclear criticality controls.

3. No evidence was provided to show that the VP0 and the VPQC perform auditing functions related to criticality safety. This is an open issue because the writer failed to pursue this item during the inspection.

D. Observation Human Resources Policy #10198 requires NIS to approve Route Cards.

Engineering Department Procedures (EDP) #102 and 102-1 permit exceptions to the Route Card approval by NIS. The Route Card is the mechanism to provide nuclear criticality safety controls to Operations and Quality Control. personnel.

Finding EDP' procedures permit violations of Division Policy.

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3 OCT 2 31986 E. Observation EDP 102 and EDP 102-1 have a common purpose to establish a standard format and content for Route Cards. By Observation of Route Cards in' manufacturing areas, the inspector acted that some Route Cards provide criticality controls, some reference an NIS posting, ar.d some reference other manufacturing procedures. In.one case where the reader was referenced to the NIS posting for the appropriate criticality control, the posting informed the reader to use an NIS approved fixture. The inspector noted that in the situations where the referenced material was identified, the referenced material could have fit into the space on the Route Card which was used to reference the locations of the criticality limit.

Finding The criticality control content of Route Cards is not standardized.

Finding the criticality control limit is unnecessarily complex.

II. Nuclear Criticality Safety Approvals Observation Records for about 6 months of internal criticality safety analyses and reviews were reviewed. The inspector made the following observations:

1. A request and apprcval form is used to document the request, the NIS analysis, and the NIS approval.

2. Some requests are too cryptic to permit review and audit.

3. One record indicated that the review was done by an unqualified individual (a license violation). Peter Smith, UNC, said that the record was in error because he had performed the analysis; Thomas Gutman, UNC, performed the review. However, Mr. Gutman approved the document before Mr. Smith signed the document.

4. The criticality control posting is made by NIS as part of the approval process.

5. One approval to use a new building addition violated the license requirements. The Technical Services Director-refused to discuss the generic issue of NIS responsibility to see that all license conditions are satisfied, not just criticality safety requirements.

Supposedly, the Director had discussed this issue with Mr. Roth.

N 23q Findings

1. The. request, the analysis, and the review should be well documented i

so that other UNC personnel (managers included) can understand the process and can audit the NIS practice and UNC compliance with the NIS criticality controls.

2. NIS approval should include consideration of all license requirements, not just nuclear criticality controls.

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3. Preparation of the NIS criticality control posting as part of the NIS approval process is a program strength.

4. Each approval should contain unit size and unit spacing limits.

5. Approvals for moderation (hydrogen) control stations or units failed to control hydrogen in non liquid form and hydrogen between small quantities of fuel.

III. Nuclear-Criticality Safety Inspections and Audits A. Observation NIS has established a procedure for conducting criticality safety inspections. The NIS procedure places requirements on Operations and Quality Control personnel to take corrective actions when violations are found. The procedure was not approved by Operations and Quality Control, but corrective actions were being taken according to comments on violation record forms.

The inspection program is controlled by a computer program called

" Audit." Each month.a printout will provide a listing of open items which may include violations, recommendations, and action  !

items. The open items are to be addressed in the inspection. l The inspection program is designed to cover each authorized station in a calendar year with about 10 percent of the stations'being inspected during any one month, but the procedure has not been

, changed to list all inventory control stations for each inspection.

An inventory control station is a work place where a number of

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1 components of sections of components may be handled at any one time. Some, but not all, operating areas must be inspected every 2 months on the second and third operating shifts.

Violations will be reported to the area supervisor or group manager and the NIS Manager. The area supervisor will report his corrective action. These two reports are on an NIS violation form which is maintained in the NIS files.

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During the tour of the facilities, discussions were held by the writer and the team leader with the two NIS personnel who conduct monthly inspections. The NIS personnel could not explain the limits on two postings or how UNC operations could satisfy the posted criticality limits.

Findings

1. Plant management is not involved in the criticality safety inspection program.

2. Findings and corrective actions are not examined by plant management for plant-wide generic implications.

3. The " Audit" record is so cryptic that only the Nuclear Criticality Specialist, relying on his memory, can interpret the inspection findings.

4. The procedure does not require that all operating areas be ~

inspected during second and third shifts.

5. Violations within the NIS department are not documented. (The Technical Services Director said this would be changed.)

6. UNC-NIS inspectors should be trained in interpretation of posted criticality limits so that meaningful inspections are perforned.

7. The narrow approach to station auditing, rather than area auditing, contributed to the NIS failure to have Raschig ring filled drums inspected for solids buildup.

B. Observation The audit program consists of an annual audit by a consultant who submits a written report to the Division President. The consultant develops his audit plan from a UNC procedure which identifies the potential audit areas. For both the 1985 and 1986 audits, the Division President sent the consultant (auditor) a letter stating the UNC corrective actions.

The " Audit" computer program described above is also used to track the action items from the audit report. The tracking is so cryptic that the record does not even identify the source of the item, i.e.,

the audit report.

In reviewing the 1985 audit report, the writer observed that one item recommended a periodic action by UNC. The item was closed when the initial action was taken. No periodic action was taken. UNC has no tracking system for " periodic" items.

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Findings ,

1. The consultant is a qualified auditor.

2. UNC did not perform the " periodic" actions recommended by the auditor.

3. UNC does not have a tracking system to assure " periodic" follow-on actions.

4. The " Action" tracking system is so cryptic that only the Nuclear Safety Specialist can' interpret the line entires.

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IV. Nuclear Criticality Sa'fety Training

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A. Observation l

New employees rec 6ive nuclear safety training as part of orientation. The training consists of a lecture, viewing i

of an Oak Ridge Video, and an examination. ,

The handout (NIS184-2-35) which is distributed during the lecture was reviewed during the assessment. The handout gave a definition of a neutron-chain reiction and described some of the controls which UNC employs for criticality control.

Findings -

1. The new Divisiin~fresident'has not been trained. (This training would have exposed the President to the. poor training.

program as well as' prevent an item of noncompliance.)

2. The training ~pVogram does not cover all control methods used by.

UNC.

3. There is no technical training program for engineers and supervisors.

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