ML20247Q991

Insp Rept 70-0371/89-03 on 890814-18.No Violations & Deviations Noted.Major Areas Inspected:Radiation Protection Program Including Status of Previously Identified Items & Implementation of Radiation Protection Program

ML20247Q991
Person / Time
Site:	07000371
Issue date:	09/21/1989
From:	Loesch R, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20247Q933	List: ML20247Q929 ML20247Q991
References
70-0371-89-03, 70-371-89-3, NUDOCS 8909290141
Download: ML20247Q991 (5)

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U.S. NUCLEAR REGULATORY COMMISSION-

' REGION I 4

Report No. 70-371/89-03 Docket No.70-371 License No. SNM-368 Priority- 1 Category UHFF

' Licensee: UNC Naval Products Division 67 Sandy Desert Road uncasville, connecticut 06382 Facility Name:- UNC Naval Products Inspection At: Montville, ~ Connecticut Inspection Conducted: August 14-18, 1989 Inspectors: ) ~

NscI R.Loesch, Radiation specialist f/#d/'

cate Approved by: @ P/a/ [8f W. Pasciak, E fef, Facilities Radiation date rotection S ction Inspection Summary: Inspection conducted on August 14-18, 1989 (Report Nc.

70-371/89-03

. Areas Inspected: Routine, unannounced inspection of the licensee's Radiat' ion Protection Program. The following areas were reviewed: status of previously identified items, and implementation of the Radiation Protection Program.

Results: No violations were identified.

8909290141 890921 PDR ADOCK 07000371 C PNU ,

DETAILS

-1.0 Persons Contacted

• B. Andrews, President, UNC Naval Products

• G. Waugh, Executive Vice President

• R. Gregg, Director,-Technical Services

• D. Luster, Health Physics Specialist

• G. Surratt, Health Physics Supervisor T. Gutman, Criticality and Licensing Specialist D. Birks, Criticality Engineer )

• Denotes attendance at the exit meeting on August 18, 1989.

Other licensee personnel were contacted or interviewed.

2.0 Purpose

~ The purpose of this routine, unannounced inspection was to review the licensee's Radiation Protection Program with respect to the following elements:

- Status of Previously Identified Items

- Implementation of the Radiation Protection Program, including:

- Management and Organization

- Internal Exposure Controls 3.0 ' Status of Previously Identified Items 3.1 and 88-02-06 h(Closed) ave approved87-08-01 and/or -(Violation)iate appropr health phys (Violation). Failure to ics procedures.

The inspector verified the licensee's corrective actions, as stated in their letters to the NRC dated January 15, 1988, and Jul 13, 1988.

Weaknesses )reviously identified were corrected and new/yrevised procedures lave been issued and approved in conjunction with the ongoing Performance Improvement Program.

l 3.2 (Closed) 88-02-01 (Violation). Failure to perform adequate evaluations

, of intakes greater than 40 MPC-hours in seven consecutive days.

1 The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1988. The licensee has formally implemented the use of " Unusual Occurrence Reports" for the evaluation and documentation of such exposures.

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3 3.3 -(Closed) 88-02-02 (Violation). Failure to use suitable measurements of concentrations of radioactive materials in air.

The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1988. The licensee has implemented the use of additional lapel air samplers and reevaluated both the representativeness of current and the need for additional fixed sample locations.

3.4 (Closed) 88-02-03A (Violation). Failure to evaluate the alpha counting losses due to filter self-absorption.

The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1988. The licensee is applying a conservative 15% alpha correction factor. The licensee stated that this value will be modified as future data warrants.

l 3.5 (Closed) 88-02-04 (Violation). Failure to maintain air balances.

The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1983. The licensee has performed an air balance review and established guidelines to maintain correct air balance in "B" South. The license has been amended with j reference to the Pack Assembly / Change Room flow direction. Inspector i review of current air balance records indicated the licensee is maintaining air balance as required.

l 3.6 (Closed) 88-02-05 movement face veloc(Violation).

ities. Failure to maintain hood minimum l

The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1988. The licensee has modified Task Instruction 5-3, " Hood Velocity Measurements" to provide more detailed guidance to technicians. In addition, the hood referenced in the violation is being modified to increase it's linear face velocity I

I and will not be used until modifications are complete.

3.7 (Closed) 88-02-07 (Violation). Failure to provide comprehensive audits of the Health Physics Program.

The inspector verified the licensee's corrective actions, as stated in their letter to the NRC dated July 13, 1988. Audits are currently performed by UNC Geotech. Initial audit findings were incorporated into the Performance Improvement Program.

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4.0 Implementation of the Radiation Protection,Prcgram The implementation of the licensee's Radiation Protection Program was reviewed with respect to the following criteria:

- 10 CFR 20, " Standards for Protection Against Radiation", and

- SNM License No. 368, cart I, " Conditions and Specifications", Chapters 2.0 and 4.0 Within the scope of this review, no violations were identified.

4.1 Management and Organization The licensee has reorganized the Nuclear & Industrial Safety (NIS)

Department of the Technical Services (TS) Division. The NIS Manager was assigned to a new position as Assistant to the TS Director, the vacated position having been left unfilled. The Health Physics Specialist, who previously reported to the NIS Manager, now reports directly to the TS Director. In addition, the Health Physics Specialist's scope of re: possibilities has been redefined to primarily the technical and managerial aspects of the program. To improve the supervisory oversight of the routine day-to-day activities, the licensee has established a new Health Physics Supervisor position, also reporting to the TS Director.

Through interviews with the Health Physics Supervisor, the inspector noted that the individual had no 3revious experience at fuel fabrication facilities. However,1aving spent over 20 years as an officer in the Navy nuclear program, his background will enhance the the radiation protection staff and provide the necessary supervisory oversight. In addition, the ins)ector noted that although the Health Physics Supervisor had been in iis position for a) proximately three months, he had yet to be provided with a copy of .11s job description.

k' hen brought to the licensee's attention, a copy was immediately provided.

To strengthen the program, licensee management has su) ported an effort to increase industry participation. A " Uranium Users Group" has been formed which includes most of the major fuel facilities in the nation.

This group has been enthusiastically accepted within the industry and has provided a needed forura for discussions and the exchange of technical information.

4.2 Internal Exposure Controls The licensee has established a Task Group for the review of the air sampling program. For each major work area examined, the composition of the team was changed to provide the necessary work related experience. During 1988, the licensee reassessed the Metallography

5 Lab, the Chemistry Lab, and both Ur.it I and Unit 2 processing areas.

The Task Group recommended 18 new fixed air sampling locations, the relocation of 29 sampling heads, the modification of 3 sampling heads, the addition of 3 hoods, and identified 11 additional work evolutions which should be monitored with lapel air samplers. Preliminary .

evaluations of the "L~ Building", still under construction, has begun.

The shearing _ operations had been previously identified by the licensee as a source of airborne radioactive contamination. Engineering controls taken in the past had not significantly reduced the generation of airborne radioactivity. However, recent studies by the licensee have identified that the handlir.g of the cut fuel pieces (coupons) is a major airborne' contributor. In response, licensee has completely enclosed the shearing equipment and has directed that layout work involving coupons be performed in a glovebox. These measures should result -in additional reductions in the exposures of workers to airborne concentrations of radioactive materiuls.

The Health Physics Su)ervisor has been tasked with the development of a formal Respiratory )rotection Program. The program will include both the needs of the Health Physics and the Industrial Safety groups, although it is not clear at this time which group will have ultimate responsibility for program implementation. The licensee does, however, anticipate that the program will be in place by the end of 1989.

5.0 Exit Interview The inspector met with the licensee representatives (denoted in Section 1.0) at the conclusion of the inspection on August 18, 1989. The inspector summarized the purpose and scope o 'f the inspection and findings as described in this report.

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