ML20245D168

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Insp Rept 70-0371/89-02 on 890313-16.No Violations or Deviations Noted.Major Areas Inspected:Operations,Nuclear Criticality Safety,Organization & Licensing Activities
ML20245D168
Person / Time
Site: 07000371
Issue date: 04/07/1989
From: Austin M, Pasciak W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20245D161 List:
References
70-0371-89-02, 70-371-89-2, NUDOCS 8904280138
Download: ML20245D168 (6)


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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-371/89-02 Docket No.70-371 License No. SNM-368 Priority _1_ Category UHFF Licensee: UNC Naval Products 67 Sandy Desert Road Uncasville, Connecticut 06382-0981  ;

Facility Name: UNC Naval Products Inspection At: Montville, Connecticut Inspection Conducted: March 13-16, 1989 Inspectors:

M. A. A'stin, b

Radiation Specialist 3/ 89 u / daty /

s Approved by Nl '

M @ 2 ~~OI J. Pasciak, Ohlef, Effluents date'

@RadiationProtectionSection,DRSS Inspection Summary: Inspection on March 13-16, 1989 (Inspection Report No. 70-371/89-02).

Areas Inspected: Routine, unannounced inspection by a region-based inspector of: operations, nuc' ear criticality safety, organization and licensing activities.

Results: No violations were identified. Construction within L Building is continuing while some raw fuel operations are scheduled to begin pending NRC approval of license amendment requests. Improvements in the performance of internal inspections, procedures review, and safety analyses by the Nuclear Criticality Safety function are described in written procedures. Recently implemented changes to the safety organization are being documented via >

license amer.dment and renewal submittals for NRC approval.

890428013e epo43o

{DR ADOCK 07ooo373 PDC

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DETAILS

1. Persons Contacted
  • B. Andrews, Executive Vice President
  • R. Gigliotti, Director, Security
  • T. Gutman, Criticality and Licensing Specialist
  • D. Birks, Criticality Engineer D. Luster, Health Physics Specialist
  • Present at the exit interview.

Other employees were also interviewed during the inspection.

2. Review of Operations The inspector examined the plant to observe activities in progress, to inspect the nuclear criticality safety aspects of existing operations, and to check the general status of the construction and installation of planned operations.
a. Existing Process Operations The inspector examined all of the major fissile material handling systems, from the receipt of the raw fuel to the manufacture of the final components. The inspector examined the nuclear criticality safety postings and observed the various methods implemented by the licensee for the safe processing, transfer and storage of fissile mate rial . The inspector noted that the new computer generateo postings developed by the Criticality Engineer were a significant improvement over the old version observed in a previous inspectian.

No violations were identified,

b. Planned Process Operations The inspector toured the continuing construction of the L-Building that will be used for a new process operation. The inspector held discussions with licensee project engineers in the L-Building who stated the licensee's plans to: complete construction of the vault and receive raw fuel for storage in April 1989; begin pre-fabrication preparation of the raw fuel in the vault area in June 1989; complete construction of the adjacent component fabrication area and begin trial startup of the new process equipment in December 1989; and begin actual component fabrication in June 1990. At th? time of the inspection, no fissile material was authorized for storage in L-Building, and no radiological or criticality safety controls were implemented in the construction area. Licensee representatives confirmed that all required criticality monitoring equipment would be installed and fully i

2 operational before the receipt and storage of any raw fuel in the vault. No violations were identified.

3. Nuclear Criticality Safety The inspector examined the nuclear criticality safety (NCS) controls implemented throughout all of'the major material process systems from the receipt of raw fuel to the fabrication of the final components.
a. Administrative Controls The inspector observed the licensee's use of NCS postings within.

visibly-marked NCS' zones as an administrative control in all phases of the fissile material process. In certain NCS zones where raw fuel is handled, the inspector observed operators maintaining material balance log sheets to ensure the posted NCS mass limits were not exceeded. In NCS zones where the raw fuel has already been processed into a fixed configuration within components, the inspector observed that the licensee controls the allowable mass'of fissile material by evaluating and defining the " Standard Safe Quantity" of a particular component that would be safe under worst-case circumstances (e.g., maximum moderation). The inspector observed that these defined " Safe Quantities" were then specified on NCS postings to aid the operators to comply with the fissile material mass limits in a given NCS zone. No violations were identified. {

b. Geometry Controls The inrpector examined several different examples of geometry controls designed into equipment by the licensee to help ensure safe processing, transfer and storage of fissile material. Engineered geometry controls, such as rigid fixture spacing, are used throughout the process to limit the amount of fissile material within an array and to ensure proper separation between different arrays. In the design of all phases of the process, the inspector observed the licensee's implementation of the " double contingency principle (i.e., at least two unrelated criticality safeguards must fail before an accident can occur). No violations were identified.
c. Criticality Monitor System The inspector reviewed the design and operation of the licensee's criticality monitoring system. In discussions with the Health Physics Specialist, the inspector determined that, because the existing facility was licensed to possess special nuclear material pH or to December 6, 1974, the licensee's criticality monitoring ,

system is subject to the requirements specified in 10 CFR i 70.24(a)(2). The licensee's system is comprised of 31 scintillation detectors located throughout the facility and an alarm monitoring i

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3 panel located in the Central Alarm Station (CAS) that is continuously manned by members of the site security force. The inspector examired the CAS monitoring panel and observed that each detector is repre-sented by four lights: (a) a white light that is always lit under normal conditions to indicate the detector is functioning; (b) a yellow light that is lit when a "downscale" level of less than 0.5 millirem per hour is indicated; (c) a blue light that is lit when an

" alert" level of 8.0 millirem per hour is indicated; and (d) a red light that is lit when a " trip" level of 18 millirem per hour is indicated. Whenever a "downscale" or " alert" condition is indicated, the CAS notifies the Emergency Director and all movement of fuel between nuclear criticality safety zones is stopped until the alarm is investigated and resolved (e.g., the detector is repaired). If a

" trip" level is indicated, an audible airhorn alarm is activated that signals all personnel to evacuate the facility. In discussions with the inspector inside the CAS, the licensee's Security Shift Supervisor demonstrated his knowledge of the operation of the criticality alarm monitoring panel and of the responsibilities of the site security force in the event of an alarm. No violations were identified.

d. Internal Reviews and Audits The inspector questioned licensee representatives regarding the conduct of internal reviews and audits from January 3,1989 through March 10, 1989. The licensee has placed records of these reviews and audits into a computer file. The inspector observed that the Criticality Engineer had changed the computer program in February 1989 to generate an improved printout that presents detailed audit findings in an easier-to read format. A hard copy of each finding identified, the corrective action taken, and the completion date is maintained separately by the licensee. The inspector reviewed the computer records of all inspections which were conducted during this time period. The inspector verified through the exami-nation of licensee written records that corrective actions had been taken or initiated for each finding identified. No violations were identified.
4. Organization
a. Deletion of Nuclear and Industrial Safety Department The inspector identified that the licensee has implemented a change in the management of its safety functions that is described in an amendment application dated May 6, 1988. Prior to this change, the Criticality and Licensing Specialist, Health Physics Specialist, and Industrial Safety Specialist all reported to a Nuclear and Industrial Safety (NIS) Department Manager who reported to the Director of Tecwncal Services. The new organization had deleted the NIS Department Manager position, and the three above-mentioned

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l safety specialist positions now report directly to the Director of 1 Technical Services. The inspector stated the necessit.i of maintaining an open communications interface among these three ]

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safety functions, which is achieve ( . in part, by close supervision.

Licensee management explained to the inspector that one of the objectives of this change was to provide a higher level of management attention to these safety functions. The effectiveness of this new organization will be further evaluated in a future inspection.

b. Addition of Health Physics Supervisor The inspector identified that the licensee has added a new position of Health Physics Supervisor to its organization, which is not described in any submittals to NRC. The licensee had recently recruited an individual for this new position, but this person was not being fully utilized at the time of the inspection because the required security clearance approval had not yet been obtained.

The inspector believes this increase in health physics staff manpower can be considered as an improvement, but the specific duties and responsibilities of this new position and the effectiveness of this change will be further reviewed in a future inspection.

5. Licensing
a. L-Building Amendments The inspector reviewed an amendment application dated October 14, 1988 and a major revision of the same application dated February 10, 1989, which request authorization to receive, store and begin pre-fabrication preparation of raw fuel in the vault area of the new L-Building under construction. The licensee has requested NRC approval by April 1989 to support its projected production schedule. Licensee representatives stated that additional amendment applications will be submitted in a timely manner during 1989 to support the construction and startup plans for the new process operation.
b. Renewal Application The inspector reviewed the status of the License No. SNM-368 renewal application. A licensee representative stated that the application had been submitted to NRC in letters dated January 22, 1986 and November 30, 1987. However, the licensee representative stated that a complete revision of the application was being prepared with tentative plans for completion in May 1989, which would reflect a number of changes including: deletion of certain license sections no longer applicable to present-day operations; changes in the safety organization; technical changes in criticality safety

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analytical methods; and incorporation of recent amendments. The status of this renewal activity will continue to be monitored in future inspections.

6. Exit Interview The inspector met with the licensee representatives (denoted in Paragraph
1) at the conclusior, of the inspection on March 16, 1989. The inspector presented the scope of findings of the inspection. The inspector did not provide the licensee with any written material during the inspection.

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