ML21105A055

Alliant Techsystems Operations, LLC - NRC Inspection No. 04008850/2021001 and Notice of Violation

ML21105A055
Person / Time
Site:	04008850
Issue date:	04/12/2021
From:	Christopher Cahill NRC Region 1
To:	Fritz C Alliant Techsystems Operations
References
IR 2021001
Download: ML21105A055 (9)

See also: IR 05000202/2010001

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BLVD.

KING OF PRUSSIA, PA 19406-2713

April 12, 2021

Chris Fritz, Senior Director,

Operations Support

Alliant Techsystems Operations, LLC

210 State Route 956

Rocket Center, WV 26726

SUBJECT: ALLIANT TECHSYSTEMS OPERATIONS, LLC - NRC INSPECTION NO.

04008850/2021001 AND NOTICE OF VIOLATION

Dear Mr. Fritz:

This letter refers to the inspection conducted on March 1, 2021, at your Rocket Center, WV

facility. This inspection examined activities conducted under your license as they relate to

public health and safety, and to confirm compliance with the Commission's rules and regulations

and with the conditions of your license. Within these areas, the inspection consisted of selected

examination of procedures and representative records, observations of activities, and interviews

with personnel. Additional information was requested on March 1, 2021, and received on March

9, 2021. A final exit meeting was held with you and your staff on March 30, 2021.

Based on the results of this inspection, the NRC has determined that one Severity Level IV

violation(s) of NRC requirements occurred. The violation was evaluated in accordance with the

NRC Enforcement Policy. The current Enforcement Policy is included on the NRC's Web site at

https://www.nrc.gov/about-nrc/regulatory/enforcement/enforce-pol.html. The violation is cited in

the enclosed Notice of Violation (Notice) because the violation was identified by the NRC.

You are required to respond to this letter and should follow the instructions specified in the

enclosed Notice when preparing your response. If you have additional information that you

believe the NRC should consider, you may provide it in your response to the Notice. The NRC

review of your response to the Notice will also determine whether further enforcement action is

necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and your

response will be made available electronically for public inspection in the NRC Public Document

Room or from the NRC document system (ADAMS), accessible from the NRC Web site at

http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not

include any personal privacy, proprietary, or safeguards information so that it can be made

available to the Public without redaction.

If you have any questions regarding this matter, please contact Randolph Ragland of my staff at

610-337-5083 or via electronic mail at Randolph.Ragland@nrc.gov.

C. Fritz 2

Thank you for your cooperation.

Sincerely,

Christopher Digitally signed by Christopher G. Cahill

Date: 2021.04.12 13:46:19 -04'00'

G. Cahill

Christopher G. Cahill, Chief

Commercial, Industrial, R&D

and Academic Branch

Division of Radiological Safety and Security

Region I

Docket No. 04008850

License No. SUB-1440

Enclosure:

Notice of Violation

cc w/ enclosure

George Sherman, Radiation Safety Officer

State of West Virginia

C. Fritz 3

ALLIANT TECHSYSTEMS OPERATIONS, LLC - NRC INSPECTION NO. 04008850/2021001

AND NOTICE OF VIOLATION DATED APRIL 12, 2021

DOCUMENT NAME: https://usnrc.sharepoint.com/teams/Region-I-CIRDA/Inspection Documentation/Inspection

Documentation - Draft/LSUB-1440.2021001.docx

x Non-Sensitive x Publicly Available

x SUNSI Review

Sensitive Non-Publicly Available

OFFICE RI: DNMS RI: DNMS RI: DNMS

ETindle-

NAME RRagland (RCR) CCahill (CGC)

Engelmann/EDTE

DATE 03/30/2021 04/05/2021 04/08/2021

OFFICIAL RECORD COPY

NOTICE OF VIOLATION

Alliant Techsystems Operations, LLC Docket No. 04008850

Rocket Center, WV License No. SUB-1440

During an NRC inspection conducted on March 1, 2021, one violation of NRC requirements was

identified. In accordance with the NRC Enforcement Policy, the violation is listed below:

10 CFR 20.1802 requires that the licensee control and maintain constant surveillance of

licensed material that is in a controlled or unrestricted area and that is not in storage.

Contrary to the above, on March 1, 2021, Alliant Techsystems Operations, LLC did not

control and maintain constant surveillance of licensed materials that was in a controlled

or unrestricted area and that was not in storage. Specifically, the licensee left at least

188 kg of depleted uranium in the D.U. Operations Building unattended with an exterior

door open for an undetermined amount of time.

This is a Severity Level IV violation (Enforcement Policy Section 6.7).

Pursuant to the provisions of 10 CFR 2.201, Alliant Techsystems Operations, LLC, is hereby

required to submit a written statement or explanation to the U.S. Nuclear Regulatory

Commission, ATTN: Document Control Desk, Washington, D.C. 20555, with a copy to the

Regional Administrator, Region I, within 30 days of the date of the letter transmitting this Notice

of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation"

and should include for each violation: (1) the reason for the violation, or, if contested, the basis

for disputing the violation, (2) the corrective steps that have been taken and the results

achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date

when full compliance will be achieved. Your response may reference or include previous

docketed correspondence, if the correspondence adequately addresses the required response.

If an adequate reply is not received within the time specified in this Notice, an order or a

Demand for Information may be issued as to why the license should not be modified,

suspended, or revoked, or why such other action as may be proper should not be taken. Where

good cause is shown, consideration will be given to extending the response time.

If you contest this enforcement action, you should also provide a copy of your response to the

Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington,

DC 20555-0001. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, any response

which contests an enforcement action shall be submitted under oath or affirmation.

Your response will be placed in the NRC Public Document Room (PDR) and on the NRC Web

site. To the extent possible, it should, therefore, not include any personal privacy, proprietary,

or safeguards information so that it can be made publicly available without redaction. However,

if you find it necessary to include such information, you should clearly indicate the specific

information that you desire not to be placed in the PDR, and provide the legal basis to support

your request for withholding the information from the public.

In accordance with 10 CFR 19.11, you may be required to post this Notice within two working

days of receipt.

Dated This 12 day of _April_ 2021

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

INSPECTION REPORT

Inspection No. 04008850/2021001

Docket No. 04008850

License No. SUB-1440

Licensee: Alliant Techsystems Operations, LLC

Address: Alliant Techsystems Operations, LLC

210 State Route 956

Rocket Center, WV 26726

Inspection Dates: March 1, 2021

Exit Meeting: March 30, 2021

Digitally signed by Elizabeth

Elizabeth D. D. Tindle-Engelmann

Tindle-Engelmann Date: 2021.04.08 16:26:59

Inspector(s): ______________________________

-04'00'

_______________

Elizabeth D. Tindle-Engelmann date

Health Physicist

Medical and Licensing Assistance Branch

Division of Nuclear Materials Safety

Randolph C. Digitally signed by

Randolph C. Ragland

Date: 2021.04.12 13:37:29

Ragland

______________________________

-04'00' _______________

Randolph C. Ragland, Jr. date

Senior Health Physicist

Commercial, Industrial, R&D and Academic Branch

Division of Nuclear Materials Safety

Christopher G. Digitally signed by

Christopher G. Cahill

Date: 2021.04.12 13:46:56

Cahill

Approved By: ______________________________

-04'00'

_______________

Christopher G. Cahill, Chief date

Commercial, Industrial, R&D and Academic Branch

Division of Nuclear Materials Safety

1 Inspection Report No. 04008850/2021001

EXECUTIVE SUMMARY

Alliant Techsystems Operations, LLC

NRC Inspection Report No. 04008850/2021001

The NRC conducted a routine, announced inspection to review the organization and scope of

activities performed under Alliant Techsystems Operations, LLCs NRC License No. SUB-1440.

The licensee is a defense contractor that assembles depleted uranium munitions in Rocket

Center, WV.

During the inspection, one apparent violation of NRC requirements was identified. The

apparent violations involved the failure to control and maintain constant surveillance of licensed

material that is in a controlled or unrestricted area and that is not in storage in accordance with

10 CFR 20.1802.

2 Inspection Report No. 04008850/2021001

REPORT DETAILS

1. Organization and Scope of the Program

a. Inspection Scope

The inspectors reviewed the organization and scope of activities performed under Alliant

Techsystems Operations, LLC NRC License No. SUB-1440. Information was gathered

through direct observation of licensed activities, interviews with licensee staff, a review

of selected records, and a tour of the facilities.

b. Observations and Findings

The licensee assembles munitions which contain depleted uranium (DU). The licensee

receives machined DU and then trained personnel assemble the munitions manually

while wearing gloves. The licensee only handles DU in one building which is called the

D.U. Operations building. There is a storage bunker where the DU is kept until use. The

workload fluctuates based on contracts with the Department of Defense.

The Radiation Safety Officer (RSO) is onsite daily. The RSO is supported by the safety

manager and technicians from another department. The RSO is responsible for

oversight of the program while the technicians perform surveys and area audits. The

licensee maintains a Radiation Safety Committee (RSC) that meets regularly to discuss

ALARA matters, incidents, and radiation safety.

2. Review of Licensed Activities

a. Inspection Scope

The inspectors performed an announced routine inspection utilizing NRC Inspection

Procedure 87126, Industrial/Academic/Research Programs to conduct the inspection.

Information was gathered through interviews with cognizant personnel, direct

observation of licensed activities, review of records, tours of the facilities, and through

the performance of independent radiation surveys.

b. Direct Observations, Interviews, and Records Review

The inspectors reviewed select records including the ambient radiation level surveys,

contamination surveys, dosimetry, DOT/HAZMAT training, instrument calibrations, and

the radiation safety manual.

Inspection Report No. 2016-001 described a violation pertaining to 49 CFR 172 training

requirements. In accordance with the corrective actions described in the previous

inspection, the RSO received DOT training and the licensee implemented a training

program for all HAZMAT employees. The training was conducted annually in the

licensees learning management system and was supplemented by a job instruction.

This closes the previous violation.

3 Inspection Report No. 04008850/2021001

The licensee was operational, but at a reduced capacity. The inspectors toured the

licensees facility and observed one individual handling licensed material. During the

facility tour it was determined that the licensee failed to control and maintain constant

surveillance of licensed material that was in a controlled that was not in storage in

accordance with 10 CFR 20.1802. Specifically, during the tour the inspectors observed

an exterior door that was open and unattended. Upon questioning, the licensee

immediately closed and secured the door. The licensee determined that the latch on the

door was broken. As a preventative action the licensee ordered a new door with a

functional closure.

Independent Radiation Measurements

The inspectors performed independent ambient radiation level and contamination

surveys at the facility. The surveys were conducted in the D.U. Operations building; the

survey results were consistent with the licensees postings, the licensees results, and

applicable regulatory limits.

c. Conclusions

During this inspection, one apparent violations of NRC requirements was identified. The

following is the apparent violations:

10 CFR 20.1802 requires that the licensee control and maintain constant

surveillance of licensed material that is in a controlled or unrestricted area and

that is not in storage.

Contrary to the above, on March 1, 2021, the licensee did not control or maintain

constant surveillance of 188 kg of depleted uranium located in D.U. Operations

Building, which is a controlled area. Specifically, on March 1, 2021, the licensee

left the licensed material in the D.U. Operations Building unattended with an

exterior door open for an undetermined amount of time.

This is a Severity Level IV violation (Enforcement Policy Section 6.7).

3. Exit Meeting

On March 1, 2021, the inspectors conducted an onsite exit debrief with the licensee.

The inspection findings and apparent violation were discussed. The licensee

acknowledged the inspection findings and committed to developing corrective and

preventative actions. The licensee created a corrective action plan and submitted it to

the NRC on March 9, 2021. On March 30, 2021 the inspectors conducted a virtual exit

meeting with the licensee; the inspection apparent violation and need for a more in-

depth root cause analysis was discussed.

4 Inspection Report No. 04008850/2021001

ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

1. Individual(s) present at entrance meeting

+ Individual(s) present for onsite inspection debrief on March 1, 2021

^ Individual(s) present for virtual exit meeting on March 30, 2021

1. +^ George Sherman, RSO

1. +^ Zack LeMasters, Safety Manager

+ Mary Ellen Patt, NPT Manager

^ Bill Hixon, Director, Operations

^ Chris Fritz, Senior Director, Operations Support

INSPECTION PROCEDURES USED

IP 87126, Industrial/Academic/Research Programs

LIST OF NRC SURVEY INSTRUMENT USED

Ludlum Model 2401-P, serial number 285217 (calibration exp. date: September 30, 2021)

Ludlum Model 30, NRC serial number 25016145, combined with a Ludlum 44-1 probe, NRC

serial number 23205G (calibration exp. Date: January 20, 2022)

LIST OF ACRONYMS USED

DU: Depleted Uranium

NRC: Nuclear Regulatory Commission

RSC: Radiation Safety Committee

RSO: Radiation Safety Officer

5 Inspection Report No. 04008850/2021001