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

Text

{{#Wiki_filter:- . . . -.. . . - , ~ 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 ~ 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 ' Appro.ved by: _ S , -?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. h$ [ DO -C - ; , h ,.

. . 4 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 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: L

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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 of a package, or the number obtained by dividing 50 by the , allowable number of packages which may be transported together e

. . 4 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 e

. . 5 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. . .m.

. . 6 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 0 content of the rings removed from_the 2 tanks ranged from 12.23% to 13.26% which was within the range of 11.8 to 13.8% of 8 0 required by license conditions, 2 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. L

h , - .. . 7 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, u

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' . 8 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 ' 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 .- 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 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. r

1 , ^? . _ . , . 9 . 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. ' 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. , _ }}