ML20137X586
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| 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: |
| 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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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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