ML20211C146

Insp Rept 70-0371/86-02 on 860303-07.Violations Noted: Failure to Post Table in Electron Beam Welding Room W/ Nuclear Safety Limits,Use of Unauthorized Locations for Storage or Processing of SNM & Inadequate Sampling

ML20211C146
Person / Time
Site:	07000371
Issue date:	05/21/1986
From:	Keimig R, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211C045	List: ML20211C042 ML20211C106 ML20211C146
References
70-0371-86-02, 70-371-86-2, NUDOCS 8606120247
Download: ML20211C146 (11)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.: 70-371/86-02 Docket No.: 7J-371 License No.: SNM-368 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 Inspection Conducted: March 3-7, 1986 Inspector: 4 [ 7/

J. "th ,' P r " e c Engineer / date' Approved by: ,m if.R.~Keimij,C f,4

, Safeguards Section, 2/h

/ dat'e Nuclear Mater s Safety and Safeguards Branch, DRSS Inspection Summary: Inspection on March 3-7, 1986, (Report No. 70-371/86-02 Areas Inspected: Routine unannounced inspection by a region-based inspector of: operations, nuclear criticality safety, organization, radiation protection, radioactive waste management, transportation, nonroutine events and licensee actions on previously identified snforcement items.

Results: Four violations were identified: failure to post a table in the Building B-North electron beam welding room with nuclear safety limits (paragraph 3.a); use of unauthorized locations within the facility for storage and/or processing of special nuclear material (paragraph 4.a); inadequate sampling of three stacks in the plant to assure that the limits specified in 10 CFR 20.106a have not been exceeded (paragraph 5.a.(3)); and, failure to have a procedure that covered sorting, laundering, and contamination surveys of shoe covers (paragraph 5.g).

8606120247 860602 PDR C ADOCK 07000371 pg

DETAILS

1. Persons Contacted G.O. Amy, President and General Manager R.J. Gregg, Director, Technical Services T. Gutman, Criticality Safety Specialist D. Luster, Health Physics Specialist P. Smith, Criticality Safety Engineer '

present at the exit interview

2. Licensee Action on Previously Identified Enforcement and Inspector Followup Items (Closed) Inspector Followup Item (371/83-04-03): Removal of drums from

, Dog Pen 1 located on the east end of Building M. The inspector verified that the licensee had removed, repackaged and shipped, to an approved i burial site, all 55 gallon drums of contaminated waste which had been 1 stored in Dog Pen 1. This work was completed after the last inspection, conducted during August, 1985.

j (Closed) Violation (371/84-08-01): Licensee review of corrective action l program, for personnel contamination surveys to assure that personnel are surveying as required. During Inspection No. 70-371/85-09, the inspector

, verified that all necessary retraining of licensee personnel had been completed. During this inspection, the inspector verified that installation of alarming contamination survey stations was completed and that the stations were operational. Each station is equipped with a visual and an audible indication which alarms if an individual attempts to leave the area without 6ctivating a timer and conducting a contamination survey.

(Closed) Violation (371/85-06-01): Failure to post Nuclear and Industrial Safety (NIS). Authorizations in the XRP room and for a metallurgical sample storage array in the spectroscopy laboratory. The inspector verified by observation that each fuel bearing component inspection device in the XRP room and the metallurgical sample storage array in the spectroscopy laboratory were properly posted with NIS Authorizations.

(Closed) Inspector Followup Item (371/85-06-02): Assure that the licensee rewords the controls specified on the Door 28 shipping container storage area NIS Authorization to account for Fissile Class I, II and III containers. The inspector verified that the NIS Authorization was modified to assure that the storage limit included the sum of the Transport Index units for each container in the area, regardless of the fissile citss.

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. 3 (Closed) Violation (371/85-06-03): Failure to follow specified controls for storage in the new Building B-North mezzanine drum storage area and for storage of metallurgical samples in the spectroscopy laboratory. The inspector verified that the licensee had identified specific, properly spaced zones in the mezzanine for the storage of drums. The inspector also verified through discussions with personnel in the metallurgical laboratory that they were retrained in criticality control in the spectroscopy laboratory. No inadequacies were observed by the inspector in either storage area.

(Closed) Inspector Followup Item (371/85-06-04): Posting of the area under the Building B-North drum storage mezzanine to assure that SNM was not used or stored. The inspector observed that the work area under the drum storage mezzanine had been posted with a sign that stated, "No fuel permitted in white dot zone". The inspector verified that the work area outlined with white dots covered the entire area under the mezzanine.

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 operations 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 NRC 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 in the Building B-North, electron beam (EB) welding room.

During examination of the EB welding room, the inspector observed a fuel bearing component located on a table on the east side of the room. An examination of all the NIS Authorizations posted in the area indicated that this table was not an authorized fuel bearing component work or storage location. Failure to post this table with an NIS Authorization was identified as a violation of Section 2.6.1.2 of the NRC-approved license application (371/86-02-01). Subsequent to the identification of this violation, the licensee prepared and posted an appropriate NIS Authorization for the table. This was verified by the inspector.

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b. Nuclear and Industrial Safety (NIS) Authorizations NIS Authorizations are required to be posted throughout all areas of the plant where SNM is handled in order to provide personnel with authorized nuclear criticality safety limits and controls. This is required by Section 2.6 of the approved license application. The inspector examined selected posted authorizations to assure that the authorized operations, limits, and controls were adequately described. Several questionable practices were noted as follows:

(1) Component Stacking Carts The criticality controls on the authorization (IV-A-2) posted for the parking of component stacking carts did not require that these carts be located only in approved parking locations unless attended or marked empty. This was discussed with licensee representatives and the posted authorization was immediately corrected. This was verified by the inspector.

(2) Storage Box Transfer Cart NIS Authorization i-D-21 specified a limit of 60 fuel bearing or 35 poisoned components in each of two covered boxes on the cart. The inspector examined one of the boxes on a cart and, because of the orientation of the components, could not verify the piece count in the box. This was discussed with licensee representatives who indicated that the criticality safety evaluation was conducted to assure the safety of the boxes if filled to capacity. The inspector stated that the limits as specified on the authorization were not verifiable and that the limits should be changed to "the capacity of the box". Licensee representatives stated that this type of limit would be reevaluated and, if appropriate, the limits on the authorization would be changed. This was identified as an Inspector Followup Item (IFI 371/86-02-02).

(3) Glovebox Enclosure Fire Safety During examination of the glovebox enclosure associated with Unit 2, the inspector observed one glovebox section that contained used paper wipes and a container of flammable solvent. l The glovebox system was open to the air at the time of this j inspection. The authorization (II-E-10) posted for this '

glovebox did not specify controls on the amount of solvents and/or wipes allowed. Since this could constitute a fire hazard, the lack of controls over flammable material was

. 5 discussed with licensee representatives who stated that during normal operation, the glovebox in question contained an argon atmosphere which would eliminate the problem of flammability.

However, since the glovebox was open to the atmosphere during cleanouts etc., fire safety controls would be reexamined and specified, if necessary. This was identified as an Inspector Followup Item (IFI 371/86-02-03).

c. Housekeeping During examination of the plant, the inspector observed inadequate storage and/or excessive accumulation of combustible materials in three areas: (1) under the Building M room air supply fan located in the northwest corner of the building; (2) in the Building A basemerit; and, (3) on the upper level of the East Building low bay area. Thfs was discussed by the inspector with the site Industrial Safety specialist who indicated that, although each of these areas was equipped with fire sprinkler systems, excessive accumulations of combustible materials in the plant were unacceptable and each would be cleaned up. This was identified as an Inspector Followup Item (IFI 371/86-02-04).

d. Component Lifting Fixtures The inspector verified, through a review of licensee records, that each component lifting fixture used in wet operations was visually inspected at least once each quarter from April 1982 through February 20, 1986. The licensee's records also indicated that each of these lifting fixtures had been load tested annually between January,1984 and February,1986. No inadequacies were identified.

4. Nuclear Criticality Safety

a. Facility Modifications During Inspection No. 70-371/85-12, the inspector observed that the licensee'had initiated construction of two building extensions. One construction project was to extend the Building M component inspection room and the other project involved the construction of a component storage building in an area east of Building M and south of the East Building. During this inspection, the inspector observed that the licensee had initiated use of these facilities for the storage and/or inspection of fuel-bearing (SNM) components. In addition, the inspector observed that the licensee had initiated construction of an addition to the Building C office building l (between Building C and Building M) and a new waste handling and storage building to the south of Building B. The licensee had also constructed a new enclosure for an air compressor to the south of Building A and a carpenter's shop to the east of Building M and south of East Building. The licensee's intent to construct the new facilities for the handling and use of SNM was identified to the NRC I

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. 6, in an informational letter to NRC-NMSS Safeguards, dated June 28, 1985. Condition 9 of License No. SNM-368, dated February 27, 1985, states'that the authorized place of use (of SNM) is the licensee's existing facilities at Montville, Connecticut as d.escribed in the NRC approved li. cense application. The new facilities indicated above are not described in the NRC-approved license application, Section 1.2.2. Use of the new facilities, which were not described in the NRC approved licensee application, was identified as a violation (371/86-02-05).

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 January 1, 1985 and February 28, 1986, ~ residual samples were analyzed and three 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.

c. Raschig Ring Inspection and Analysis Licensee resords, examined by the inspector, indicated that the raschig ring b el in all applicabie tanks had been inspected by the licensee at least quarterly between January 2, 1985 sand February 25, 1986. No inadequacies were identified.

The licensee's records also indicated that raschig rings were removed from vessels RT-1, RT-2, Sectioning Left and Sectioning Right, on May 4, 1985 for chemical analypis. The results indicated that the B 20

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content of the rings ranged from 12.58% to 13.6% which was within the range of 11.8 to.13.8% of B2 0 required by license conditions.

d. Criticality Alarm Monitor Calibration The inspector verified, through a r'eview of licensee records, that the criticality alarm monitors had been calibrated at least once each quarter between February 10, 1985 and Febr.;ary 9,1986. The monitors

, were'also recalibrated, as required , v4 c ver repairs were made.

e. Annual Nuclear Criti,cality Safety M war udits An annual audit of the nuclear cricicality safety program at this facility was conducted, by a consultant from outside the Naval Products Division, on August 14-15, 1985, in accordance with a ,

written audit plan. The inspector reviewed th'e report and found that i no significant programmatic-deficiencies had been identified. The licensee had completed actions on several recommendations made during this audit to improve the facility nuclear safety program.

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f. Internal Reviews and Audits The inspector questioned licensee representatives regarding the conduct of internal reviews and audits from January 2,1985 through December 31, 1985. The licensee has placed records of these reviews and audits into a computer program. Displayed on the computer terminal is each of the NIS Authorizations posted throughout the facility (each authorization designates a storage location, work station or transfer cart), the date that each authorization was examined, the work shift during that 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period and whether any violations were identified. A hard copy of each violation identified, the corrective action taken, and the completion date is maintained separately by the licensee. The inspector reviewed the computer records of all Nuclear and Industrial Safety inspections which were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular and off-shift hours. The inspector verified through the examination of licensee written records that corrective actions had been taken or initiated in each instance identified.

5. 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 permissible concentration (MPC), (1 E-10 uCi U-235/ml or 220 dpm/m 3

) require prompt evaluation, i.e., investigatien and determination of corrective action.

The inspector examined licensee records of general area air sample results from December 20, 1985 through February 10, 1986.

The inspector did not identify any instances where air ccncentrations exceeded the action level.

(2) Stack Air Samples i

Section 4.1.2 of the approved license application states that )

any gaseous effluent discharge samples which exceed 25% of the l 10 CFR Part 20 limits (4E-12 uCi U-235/ml or 8.8 dpm/m 3 ) shall l

be immediately resampled and an investigation conducted to j determine the source of the release. The inspector examined '

licensee records of stack air sample results from December 18, i 1985 through February 20, 1986. The inspector did not identify any releases which exceeded the action level specified in the facility license.

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. 8 (3) Stack Air Samplers During review of the stack air sample records, the inspector questioned licensee representatives concerning the stack samplers and whether the stack samplers accurately measured stack releases. The inspector examined the installation of stack samplers on several ventilation system stacks in the plant including: the decontamination area stack, S-26; the sectioning area stack, S-17; the Health Physics Hood stack, S-18; and the Rad Waste Area stacks, S-19 and 20. The inspector observed that stack measurement points S-17, S-18 and S-26 were not properly located in that (a) they were about 10-15 feet away from the sampling point, (b) the sampling lines contained 3 to 5 bends which could restrict the' quantity of activity being measured, and a portion of the sampling lines consisted of tygon tubing which could also reduce the quantity of activity measured. In addition, the inspector observed that three of the sampling points (S-17 and S-19, 20) were located upstream of the absolute filters, but downstream of the fans. On a fume hood stack which had not been used for radioactive materials, the sampling point was located downstream of both the absolute filters and the fan.

It did not appear that isokinetic sampling was being employed by the licensee.

The installation of samplers on stacks S-17, S-IS and S-26 was not adequate to conduct a survey, as defined in 10 CFR 20.201 (a), to assure that releases from the facility met the requirements of 10 CFR 20.106 (a). This was identified as a violation of NRC requirements (371/86-02-06).

b. Smear Samples The inspector examined random licensee records of smear sample tests performed in the Sectioning Area, the Metallurgical Laboratory and Buildings A, B and M (cold side) cn floors and equipment from May 1, 1985 through February 13, 1986. The records indicated that all -

contamination 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 measurements conducted monthly between May 1, 1985 and February 27, 1986. 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.

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d. Air Flow Direction The inspector examined licensee records of air flow direction measurements between various areas of the Building C - South facility. The measurements were made at least quarterly between April 30, 1985 and February 26, 1986. Corrective actions have been completed to assure proper air flow direction between the metallurgical 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 May 1,1985 and February 28, 1986. All pressure drops were found to be less than 4.0 inches of water, as required by license conditions.

Filters were changed whene"er the pressure drop exceeded 4.0 inches of water or when the air flow velocity (in hoods) was less than 100 ifpm.

f. Instrument Calibration The inspector examined licensee records for the calibration of portable survey monitoring instruments. The records indicated that these instruments were calibrated at least every three months between December 1983 and February 1986.

No inadequacies were identified.

g. Contaminated Shoe Covers During examination of the potentially contaminated areas of the plant, the inspector observed that the licensee had initiated the use of rubber coated canvas shoe covers since the last inspection. Prior to this time, the licensee used disposable shoe covers. At each contaminated area entry point, the inspector surveyed at least one shoe cover for contamination. Alpha contamination on these shoe covers ranged from about 1500 to 4000 dpm/100 cm 2 . The inspector was informed by licensee representatives that the shoe covers were laundered in-house. In-house laundering was initiated during September-October 1985 and has been on going since that time. Through discussions with licensee representatives, the inspector determined that the licensee had not written, reviewed and approved a laundering procedure which would provide the workers with radiation safety limits and/or controls for the handling of the potentially contaminated shoe covers (for example, use 3 of a respirator, if necessary, wearing of gloves, j requirements for the conduct of a contamination survey of the laundered shoe covers, release limits for clean shoe covers,etc.). Failure of management to prescribe all

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. 10 pertinent controls or procedures relative to radiological safety for use by operating personnel was identified as a violation of the NRC-approved license application, Section 2.5.1 (371-86-02-07).

6. Non-routine Events The inspector determined through review of licensee records and discussions with licensee representatives that only one non-routine event within the scope of this inspection occurred at this facility since the last inspection.

On September 27, 1985, at 8:15 a.m., facility emergency personnel were placed on standby in order to address, if necessary, potential consequences of Hurricane Gloria that was approaching the area. These emergency personnel were released at about 6:00 p.m. No significant problems, with the exception of periodic power outages, were encountered at the site as a result of the hurricane.

7. Radioactive Waste Disposal

a. Uranium Content of the Facility Septic Field NRC-NMSS requested the licensee to conduct a survey of the septic system field to determine the quantity of uranium accumulated.

During the summer of 1985, the licensee set up a 10 meter grid in the leach fields. Each grid was surveyed with a gamma scintillation survey instrument to select locations for soil sampling. Soil sampling was completed during August 1985 and the samples were submitted for laboratory analysis. On October 29, 1985, the licensee submitted the findings of the soil sampling (See Figure 1) by letter to NRC-NMSS.

During this inspection the inspector reviewed the licensee's reported findings and examined the sampling locations. As a result of this review, the inspector questioned the licensee's presentation of the data in the report, in that, in Figures 3,4 and 6, the data for the Background No. 5 sample appeared to start at a point 8 feet below the other samples when, in fact, the surface of the ground level was 7 feet above the other sample location. In addition, the U-234 to U-235 ratio was determined to be about 12, instead of the expected ratio of between 22 and 26. Additionally, there appeared to be no correlation between the measured values for total uranium and the U-234, 235 and 238 isotopic values. The inspector requested the licensee to reexamine the information presented in the report to NRC-NMSS in the areas questioned and, if necessary, resubmit the report to NRC-NMSS. This was identified as an Inspector Followup Item (IFI#371/82-08-01).

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b. Liquid Radwaste Analyses During review of licensee liquid radwaste release measurement data for the year 1985, the inspector observed that about 68% (about 5 grams U-235 per month) of the SNM released from the final retention tanks ("T" tanks) went through the final filters into the facility septic tank system and only 32% (about 2 grams U-235 per month) was retained by the final 5 micron filter in the radwaste release system.

Upon questioning by the inspector, the licensee could not explain why only 32% of the SNM released from the "T" tanks was retained by the final filter. The inspector opined that the SNM released could be either soluble or less than 5 microns in particle size. The licensee stated that a study would be conducted in an attempt to resolve the matter. This was identified as an Inspector Followup Item (IFI 371/86-02-08).

l 8. Quality Assurance Audit on Shipping Containers The inspector examined records of the annual audit of the " Quality Assurance (QA) Program for Shipping Container Under 10 CFR 71, Appendix E." The audit was conducted on February 26, 1985 by the Manager, Nuclear and Industrial Safety. Several recommendations were made concerning improvements to the program. The inspector verified that the licensee initiated, or completed, actions to incorporate the recommendations in the QA Program.

9. Exit Interview The inspector met with the licensee representatives (denoted in paragraph

1) at the conclusion of the inspection on March 7, 1986. 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 to address their planned actions, as a result of inspection findings, at the exit interview.

The inspector did not provide the licensee with t.ny written material during the inspection.