ML20137X586

Insp Rept 70-0371/85-06 on 850429-0503.Violations Noted: Failure to Post & Follow Requirements of Nuclear Safety Authorizations in Two Areas of Plant & Failure to Maintain Facility Organization

ML20137X586
Person / Time
Site:	07000371
Issue date:	07/15/1985
From:	Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20137X562	List: ML20137X556 ML20137X574 ML20137X586
References
70-0371-85-06, 70-371-85-6, NUDOCS 8512100565
Download: ML20137X586 (10)

See also: IR 05000429/2005003

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                                         U. S. NUCLEAR REGULATORY COMMISSION
                                                        REGION I
                 Report'No.   70-371/85-06
                 Docket No. 70-371
                 License No. SNM-368                   Priority    1            Category- UHFF
                 Licensee:   UNC Naval Products / Division of UNC Resources, Inc.
                             67 Sandy Desert Road
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                             Uncasville, Connecticut 06382
               . Facility Name:   UNC Naval-Products
                 Inspection At: Montville, Connecticut
                 Inspecth - Conducte'd: April 29 - May 3, 1985
                 Inspector:           i}         h                                       J/f[
                                 Jpoth, Proje       Engineer                           / '/date
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                Appro.ved by:                  _
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                                                                                       -?L g-[[
                                 R./R. Keimig] Chiefg/ Safeguards Section                  date
                                 Nuclear Matdrials 3"afety and Safeguards
                                 Branch, DRSS.
                Inspection Summary: Inspection on April 29 - May 3, 1985
                (Report No.- 70-371/85-06)
               ' Areas inspected:      Routine, unannounced inspection by a region-based
                inspector (48 hours) of f - operations, nuclear criticality safety, organization,
                radiation protection, nonroutine events, and licensee action on previously
                identified enforcement items.
                Results: =Three violations were identified: failure to post nuclear safety
                authorizations-in two areas of the' plant; failure to follow the requirements
              :of nuclear safety authorizations in two areas of the plant; and, failure to
                maintain-the facility organization as described in the approved ifcense
                application.
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                                            DETAILS
       1. Persons Contacted
          *G. O. Amy, President and General Manager
          *R. J. Gregg, Director, Technical Services
          *G. H. Waugh, Executive Vice President, Operations
          *W.  Kirk, Manager, Nuclear and Industrial Safety
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          *present at the exit interview
       2. Licensee Action on Previously Identified Enforcement Items
          (0 pen) Inspector Follow Item (371/82-08-01): Obtain information on the
          quantity of SNM released from the septic tank system into the leach
          field. The inspector verified through a review of licensee records and
          discussions with licensee representatives that the licensee is developing

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          a leach field sampling plan which is expected to be submitted to the
          NRC's Office of Nuclear Material Safety and Safeguards (NMSS) for review
          prior to implementation. Leach field sampling and sample analysis is
          expected to be completed by the fall of 1985.
          (Closed) Violation (371/32-14-03): The pressure drop across the filter
          bank on Hood 14 was not measured. The inspector verified through a
          sample examination of licensee records for the period January I through
          March 30, 1985 that the pressure drop across the filter bank on Hood 14
          was measured and recorded weekly as required.
          (Closed) Inspector Follow Item (371/84-02-02): Improper airflow direction
          between the sample preparation area and the metallography laboratory.
          The inspector observed that the licensee has constructed an " ante" room
          between the sample preparation area and the metallography laboratory in
          order to more effectively control the airflow direction and the possible
          spread of contamination. Ventilation systems in the area have been
          modified to assure proper airflow direction.
       3. Review of Operations
          The inspector examined all areas of the plant to observe operations and
          activities in progress, to inspect the nuclear safety aspects of opera-
          tions and to check the general status of cleanliness, housekeeping, and
          adherence to fire protection rules.
          a.    Nuclear Criticality Safety Postings
                The licensee is required by Section 2.6.1.2 of the approved license
                application to post Nuclear and Industrial Safety (NIS)
                Authorizations throughout the facility where SNM is handled. The
                inspector observed that all areas of the plant were properly posted
                except for the following:

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         (1) X-ray Photometry Room (XRP)
               The inspector observed on April 30, 1985 that only one of three
               XRP units (Unit number 7440) was posted with an NIS Author-
               ization. The other two units (7441 and'7442) were not posted.
               The NIS Authorizations for these units were found by the
               inspector on the floor along-side or underneath XRP units 7441
       .       and 7442, respectively. Failure to post each of the XRP units
               with an NIS Authorization was identified as a violation
               (85-06-01). The inspector also noted on review of the nuclear
               safety evaluation (No. 890) conducted by the licensee for the
               use of SNM on.the XRP units that each unit was to be posted
               with an NIS Authorization. The licensee is evaluating why the
               units were not posted.
         (2)   Isotopic Storage Assay Fissometer (ISAF) Area Wall Array
               The inspector observed on May 1, 1985 that temporary NIS
               Authorization No. 82-11 for the array in the Spectroscopy.
               Laboratory, further discussed in paragraph 3 b (2), was issued
               on October 2, 1984 and expired on January 1, 1985. Failure to
               post the ISAF Area Wall Array with a current sign for the storage
               of metallurgical samples was identified as another illustration
               of the posting violation discussed in paragraph 3 a (1),
               (85-06-C1). The licensee prepared and issued NIS Authorization
                 VII-A-3A, Revision 0, dated May 1,1985,. to cover " Storage of
               Sectioned Elements in ISAF Wall Pots--Bottom Row" prior to the
               end of this inspection.
         (3) Door 28 Shipping Container Storage                                 .
               NIS Authorization No. VII-C-8, Revision 2, dated
               February 2,1985, " Loading / Storing / Unloading of Shipping
               Containers" specifies under " Storage Limits", Class II con-
               tainers to 75 TI (Transport Index) Units and Class III
               containers to approved number of containers. However, the
               approved number of Class III containers was not specified nor-
               was the method of calculating the TI for Class III containers
               specified. The inspector noted that since the storage limit for
               Class II and Class III containers was different, the posting
               should specify the limit for the storage of either Class II or
               Class III shipping containers. The inspector stated that the
               licensee could establish a storage limit on the posting on the
               basis of Transport Index only if the definition in 49CFR 173.403
               (bb)(2) was specified. This definition states that the Trans-
               port Index is determined for Fissile Class II or packages in a
               Fissile Class III shipment, as the number expressing the maximum
               radiation level at one meter (3.3 feet) from the external surface
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               of a package, or the number obtained by dividing 50 by the
               allowable number of packages which may be transported together

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               in a vehicle, whichever is larger. The licensee will re-
              evaluate the posting and modify the wording as necessary. This
               is an Inspector Followup Item and will be reexamined during a
               subsequent inspection (IFI/85-06-02).                            I
     b.  Nuclear and Industrial Safety (NIS) Authorizations
         The licensee posts NIS Authorizations throughout all areas of the
         plant where SNM is handled in order to provide personnel with
         authorized nuclear criticality safety limits and controls as
         required by Section 2.6 of the approved license application. The
         inspector observed that all posted authorizations were being
        -followed in a proper manner except for the following:
         (1) Drum Storage Mezzanine (Building B-North)
              The licensee recently installed a mezzanine in the southwest
              corner of building B-North.    The mezzanine was posted with NIS
              Authorization VII-C-12, Revision 0, dated March 20, 1985, which
              specified a storage zone limit of 100 Transport Index (TI)
              units. The posted controls required that personnel (1)
              Maintain a TI running tally and (2) Maintain a 12 foot
              separation among fuel zones. The licensee had established
              three fuel storage zones containing fuel in the northwest,
              southwest and southeast corners of the mezzanine. TI running
              tallies were being maintained for each zone and the separation
              between the southeast and southwest zones was being maintained
              as required.     However, the inspector determined by independent
              measurement that the separation between fuel in the southwest
              and northwest zones was only 10 feet 10 inches (less than the
              required 12 feet). This was identified as a violation of
              Section 2.6 of the license application (85-06-03). The
              inspector also observed that no SNM.containing components were
              being stored or used in the area under the mezzanine. However,
              the area under the mezzanine was not posted to assure-that no
              SNM will be used or stored in this area. Use or storage of SNM
              in this area would constitute a violation of nuclear safety
              criteria specified in the facility license since multilevel
              storage of SNM is not authorized in the facility. This was
              discussed at the exit interview. Licensee representatives
              indicated that posting of the area under the mezzanine would
              be considered to assure that no SNM is used or stored in this
              area. .This is an Inspector Followup Item and will be reviewed
              during~a subsequent inspection (IFI 85-06-04).
         (2) Spectroscopy Laboratory
              During examination of the Spectroscopy Laboratory, the inspector
              observed that metallurgical specimen sample boxes containing

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                          SNM were-stored outside the storage pots in the ISAF area wall
                          storage array. Temporary NIS Authorization No. 82-11, Revision
                          1, dated October 2,1984, " Temporary Storage of Sectioned
                          (Components) in ISAF Wall Pots" required, under " Controls",
                          that (1) contents of pots were not to extend above the brim,
                          (2) one. pot be kept empty for intermediate storage of contents
                          while retrieving particular (component) sections from the full
                  .       pot, and (3) not more than 315 grams U-235 worth of (component)
                          sections be handled during transport. Storage of SNM outside
                          the pots was not authorized. The inspector observed that
                          approximately 78 grams of SNM were being stored in metallurgical
                          sample boxes outside the pots, but within the array, and there
                          was no empty pot in the approved row of storage pots to facil-
                          itate storage of SNM while retrieving particular (component)
                          sections fr'om a full pot. This was identified as another
                          illustration of the violation described in paragraph 3 b(1)
                          (85-06-03).
             (c) Outside Drum Storage
                    The inspector observed that there were still about 106 drums of
                    contaminated waste stored in Dog Pen #1 located against the east
                    wall of Building M. It was noted that the drums were rusted and
                    that the labels which indicate the centents were difficult to read.
                    Licensee representatives stated that there was an ongoing project
                    to examine these drums, repackage, if necessary, and ship to an
                    approved burial site. Progress on the removal of drums from this
                    area will be reexamined during future inspections (85-04-03).
       4. .  Nuclear Criticality Safety
            .a.     The inspector determined through observation, review of licensee
                    records and discussions with licensee representatives that only one
                    significant facility change and/or modification had been made since
                    the last inspection. This change involved installation of the Drum
                    Storage Mezzanine in Building B - North previously discussed in para-
                    graph 3 b(1).
             b.     Residual Analysis
                    The inspector reviewed shop procedure SP-121 Revision 1, dated
                    October 10, 1983, " Residual Testing and Storage". The procedure
                    provides the-instructions required to analyze and properly store
                    residuals generated in the fabrication process. Between
                    September 5, 1984 and April 29, 1985, residual samples were analyzed
                    and two rejects were identified. A reject is defined as any sample
                    with a gamma radiation level in excess of a predetermined value.
                    The rejects were removed from the residual storage array and placed
                    in another nuclear safe storage array.
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     c.  Raschig Ring Inspection and Analysis
         Licensee records, examined by the inspector, indicated that the
         raschig ring level in all applicable tanks had been inspected by the
         licensee at least quarterly between September 28, 1983 and
         March 1, 1985.
        .The licensee's records also indicated that raschig rings were
         removed from vessels RT-1, RT-2, Sectioning Left and Sectioning
         Right, on May 3, 1984 for chemical analysis. Chemical analysis
         results indicated that the B 02 content of the rings removed from_the
         tanks ranged from 12.23% to 13.26% which was within the range of
         11.8 to 13.8% of 82 0 required by license conditions,
     d.  Criticality Alarm Monitor Calibration
         The inspector verified through a review of licensee records that the
         criticality alarm monitors had been calibrated at least once each
         quarter between May 15, 1983 and February 10, 1985. The monitors
         were also recalibrated as required, prior to installation, whenever
         repairs were made.
     e.  Annual Nuclear Criticality Safety Prc. gram Audits
         Annual' audits of the nuclear criticality safety program at this
         facility were conducted by a consultant from outside the Naval
         Products Division on June 29-30, 1983 and August 14-15, 1984 in
         accordance with_a written audit plan. The inspector reviewed the
         reports and found that no 'significant programmatic deficiencies had
         been identified. The licensee has completed actions on several
         recommendations made during these audits to improve the facility
         nuclear safety program.
     f.  Internal Reviews and Audits
         The inspector questioned licensee representatives regarding the
         conduct of internal reviews and audits from January 24, 1984 through
         March 29, 1985. The inspector reviewed the reports of 96 internal
         Nuclear Industrial Safety inspections which were conducted during
         that time period. These inspections covered the nuclear safety
         aspects of operations during regular and off-shift hours and exami-
         nation of required equipment inspection reports. The inspector
         verified that corrective actions had been taken or initiated in each
         instance identified by the licensee in which required corrective
         action was required.
     g.  Nuclear Safety Evaluations
         The inspector examined 92 nuclear safety evaluations (854-946)
         conducted by-the licensee between January 25, 1984 and March 25, 1985.
         Licensee evaluations were found to be conservative and a second,
         independent review was conducted when required.

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                 During examination of the Raw Fuel Storage Vault, the inspector
                 demonstrated that he could place additional raw fuel storage cans on
                 one of the storage shelves. The inspector placed the cans horizon-
                 tally on a piece of angle iron located on the shelf door prior to
                 closing the door. The shelves are designed to hold the cans in a
                 vertical position and the angle iron was placed on the door to
                 preclude double stacking of the cans. Discussions with licensee
                . representatives indicated that horizontal placement of cans on the
                  shelves would be a violation of applicable administrative nuclear
                  safety procedures. (No stacking of this type was observed by the
                  inspector). However, the' inspector stated that since it was
                 possible to stack cans horizontally, a nuclear safety evaluation
                  should be conducted to determine safety, even if this possible
                  stacking arrangement should occur.     Licensee representatives
                  indicated that reevaluation of the storage shelves will be conducted
                 and will be included in documentation submitted to the NRC as part
                 of the pending license renewal. This is an Inspector Follow Item
                 and will be reexamined by the inspector during subsequent inspections
                 (IFI85-06-05).
        5.  Organization
            During a previous inspection (70-371/84-02), the inspector determined
            through discussions with licensee representatives that the organizationai
            structure had been modified. Mr. R. J. Gregg had been appointed
            Director, Technical Services, responsible for Nuclear Industrial Safety
            (NIS), Nuclear Safeguards and Data Processing. As a result of this
            organizational change, the NIS group no longer reported to the Executive
            Vice President as described in the approved license application (Section
           -2,1). As of this current inspection (70-371/85-06), the licensee had not
            submitted an amendment application to NRC to update the description of
            the organizational structure. Therefore, failure to maintain the
            organizational structure as described in Section 2.1 of the approved
            license application was identified as a violation (85-06-06).
        6.  Radiation Protection
            a.   Air Sampling
                 (1) General Area Samples
                       Section 4.1.3 of the approved license application requires that
                       in plant air concentrations in excess of 50% of maximum permis-
                       sible concentration (MPC), (1 x 10 " uCi U-235/m1, or 220
                       dpm/m') shall require prompt evaluation, i.e., investigation
                       and determination of corrective action,

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                   The inspector examined licensee records of general area air
                   sample results from January 5,1985.through April 16, 1985.
                   The licensee did not identify any instances where air concen-
                   trations 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 (4 x 10 22 uCi U-235/ml or 8.8 dpm/m')
                   shall be immediately resampled and an investigation conducted
                   to determine the source of the release. The inspector examined
                   licensee records of stack air sample results from January 5,
                   1985 through April 16, 1985. The licensee did not identify any
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                   releases which exceeded the action level specified in the
                   facility license.
         b. Smear Samples
            The inspector examined random licensee records of smear sample tests
            performed in Sectioning, the Metallurgical Laboratory and Buildings
            A, B and M (cold side) on floors and equipment from January 10, 1935
            through April 29, 1985. The records indicated that all contam-
            ination in excess of specified action levels was immediately cleaned
            up as required.
         c. Hood Air Flow

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            The inspector examined licensee records of hood air flow measure-
            ments conducted monthly between June 20, 1984 and April 23, 1985.
            The records indicated that corrective actions were taken as required

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            to assure that air flow at the face of the hoods was maintained at a
            minimum of 100 linear feet per minute.
         d. Air Flow Direction
            The inspector examined licensee records of air flow direction
            measurements between various areas of the Building B - South
            facility. The measurements were made at least quarterly between
            April 30, 1984 and April 23, 1985. Corrective actions are still in
            progress to assure proper air flow direction between the metallur-
            gical sample preparation room and the metallurgical sample reading
            room,
         e. Ventilation System Filter Pressure Drop Measurements
            The inspector reviewed licensee records of filter pressure drop
            measurements made between March 3, 1985 and April 28, 1985. All
            pressure drops were found to be less than 4.0 inches of water, as
            required by license conditions.

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              f.       Instrument Calibration
                       The inspector examined several alpha monitoring instruments located
                       throughout the facility to assure that these instruments were
                       properly calibrated in a timely manner. No inadequacies were
                       identified.
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              g.       Health Physics Audits
                       Audits of the facility health physics program were conducted on
                       May 31 - June 1,1983, February 7-8, 1984 and November 7-8, 1984 by
                       personnel from outside the Naval Products Division. . Areas covered
                       included: shop safety committee reports, NRC inspections, envi-
                       ronmental releases, the Radiological Contingency Plan, NRC license
                       amendments, exposure records, in vivo measurements, bioassay
                       sampling, and in plant air and stack sampling data. Results of the
                       audits included racommendations for improving the facility health
                       physics program. The inspector reviewed licensee followup on
                       several of these recommendations and found that the licensee had
                       implemented the suggested changes. The inspector.noted that these
                       audits were being conducted by the licensee's insurer, American
                       Nuclear Insurers.
          7.  Non-routine Events
              The inspector determined through review of licensee records and discus-
              sions with licensee represontatives that no non-routine events within the
              scope of this inspection occurred at this facility since the last inspec-
              tion.
          8.  Exit Interview
              The inspector met with theLlicensee representatives (denoted in paragraph
              1) at the conclusion of the inspection on May 3, 1985. 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 10 address their planned actions, as a result
              of-inspection findings, at the exit interview.         The most'significant items
              addressed by the inspector concerned the apparent failure to maintain
              (1) nuclear criticality safety spacing requirements in the new mezzanine
              drum storage area (paragraph 3 b(1)) and, {2) nuclear criticality safety
              controls in the ISAF area wall storage array (paragraph 3 b(2)). The
             . inspector.was informed, but did not verify, that drums had been moved and
              spacing requirements were being met in the drum storage array and that
              all SNM outside the pots in the ISAF storage erray had been moved and
              placed into the array as required. The ia?)ector did not provide the
              licensee with any written material during the inspection.
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