ML21105A055
| 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
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
- 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
- +^ George Sherman, RSO
- +^ 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