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U.S. NUCLEAR REGULATORY COMMISSIONOFFICE OF INSPECTION AND ENFORCEMENT

Region I

Report No. 70-820/79-13__

Docket No. 70-820

License No. SNM-777 Priority 1 Category UR

Licensee: United Nuclear Corporation

UNC Recovery systems.

Wood River Junction, Rhede Island G2894

Facility Name: UNC Recovery Systems

Investigation at: Wood River Junction, Rhode Island

Investigation conducted: June 25-26, 1979

Investigators: [ b o. n# 4 /d//#/'19L. U. Gallina, Ph.U. ,. investigation Specialist date signed

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|0 /C '79E. F. Woltner, Safeguards Auditor date signed

date signed

date signedj/. / /

} / / ' i f t L .' 1

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// ! ' O 'iApproved by: ../

J. W. Devlin, Chief, Security and Investigation date signed'

Section, Safeguards Branch,

Investigation Summary:Investigation on June 25-26,1979 (Investigation Report No. 70-820/79-13)Areas Investigated: The investigation covered the area of Nuclear MaterialTransaction Reports at the UNC-RS site. The investigation involved 14 man-hourson site by one NRC investigator and one NRC inspector.Results: The investigation resulted in one (1) item of noncompliance: (Infrac-tion - failure to complete Nuclear Material Transaction Report on day of SNMshipment).

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Region I Fom 143(Rev. October 1977)

TABLE OF CONTENTS

I. Backgrgund

A. Reason for Investigation

B. Identification of Involved Organizations

II. Summary of Findings

A. Investigation Findings

B. Management Meeting

III. Details

A. Introduction

B. Scope of Investigation

C. Persons Interviewed During the NRC Investigation,

D. NRC Findings and Conclusions

IV. Exhibits

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I. Background

A. Reason for Investigation

On June 19, 1979, the Nuclear Regulatory Commission (NRC), Office ofInspection and Enforcement - Region I, was notified by Union CarbideCorporation (UCC) of Tuxedo, New York (Docket No. 70-587) that ashipment of special nuclear material had been received from UnitedNuclear Corporation - UNC Recovery System (UNC-RS) (Docket No. 70-820)on June 12, 1979, which was not accompanied by the required NuclearMaterial Transaction Report (DOE /NRC-741). After confirming the accept-ability of the shipper / receiver differences between the above referencedlicensees, an investigation was initiated on June 25, 1979.

B. Identification of Involved Organizations

1. United Nuclear Corporation (UNC-RS)UNC Recovery SystemsWood River Junction, Rhode Island 02894

A corporation licensed by the NRC to conduct activities associatedwith fuel recovery operations.

2. Union Carbide Corporation (UCC)P. O. Box 324Tuxedo, New York 10987

A corporation licensed by the NRC to operate an industrialreactor facility associated with the production of radiopharma-ceuticals.

II. Sumary of Findings

A. Investigation Fi:. dings

This investigation identified an infraction level item of noncompliancewith respect to 10 CFR 70.54 insofar as a shipment of SNM was made byUNC-RS to UCC on June 12, 1979, and the required Nuclear MaterialTransaction Report (D0E/NRC-741) was intentionally not completed untilJune 19,1979, seven days after the shipment had been made (Details,Section D).

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B. Management Meeting

A management meeting was held with the licensee on June 26, 1979, inorder to review the seriousness of the infraction identified and toreview proposed corrective action. The following individuals were inatt'endance:

Dr. C. O. Gallina, Investigation Specialist, NRCMr. E. F. Woltner, Auditor, NRCMr. C. E. Bowers, General Manager, UNC-RSMr. D. M. Schultz, Manager, Compliance, UNC-RSMr. R. J. Gregg, Manager, Quality Assurance, UNC-RS

III. Details

A. Introduction

This investigation was initiated as a result of NRC-Region I beingcontacted by Union Carbide Corporation on June 19, 1979, stating thata shipment of SNM was received from UNC-se.:overy Systems on June 12,1979, without the completed Nuclear Mate",21 Transaction Report (DOE /NRC-741).

B. Scope of Investigation

This investigation included an examination of pertinent doceaents andrecords at the UNC-RS site, interviews and contacts with involved

individuals, and observations by the NRC investigators.

C. Persons Directly Interviewed During the NRC Investigation

C. E. Bowers, General Manager, UNCD. M. Schultz, Manager, Conpliance, UNCR. J. Gregg, Manager, Quality Assurance, UNCD. A. Daigler, Quality Assurance Engineer, UNCT. Itteileg, Nuclear and Industrial Safety Technician, UNCL. Heinz, Material Accountability Clerk, UNC

D. NRC Findings and Conclusions

NRC-Region I was notified by a representative nf Union Carbide Corpor-ation (UCC) on June 19, 1979, that a reportable shipment of SNM hadbeen received from UNC-RS at Wood River Juncti]n, Rhode Island, onJune 12,1979, which was not accompanied by a Nuclear Material Trans-action Report (Form DOE /NRC-741). The UCC representative stated that

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he had contacted UNC and received confirmation that a DOE /NRC-741 hadnot yet been completed because of a plant shutdown. The transactioninvolved was ZWT-ZWN-166.

Subsequent to this notification, NRC-Region I contacted UNC and confirmedthat the shipment was made on June 12, 1979, but that the DOE /NRC-741 wasnot prepared until June 18, 1979 because no one was available toprepare the form and it was not signed until June 19, 1979, 7 daysfollowing the shipment. UNC's measured values for the material trans-ferred were recorded and compared to UCC's values. This comparisonindicated that the shipper / receiver (S/R) difference was not significantaccording to the criteria of 10 CFR 70.58(g)(3) since the S/R did notexceed 50 grams. Due to the unusual circumstances surrounding thetransfer, including potential noncompliance with 10 CFR 70.54, aninvestigation was initiated on June 25, 1979.

The investigators examined all relative packaging, surveys, and transferdata with respect to the shipment which left the UNC-RS site on June12, 1979, and found that with the exception of the DOE /NRC-741 beingdelayed, no irregularities had occurred. The investigators noted thattwo cans containing SNM had been prepared for shipment on June 7,1979, and sealed in larger containers on this date. One of the shipmentshad been made on June 12, 1979, as stated above, and the second shipmentwas scheduled to leave the UNC-RS site on June 26, 1979. The investi-gators examined all pertinent packaging, survey, and transfer recordsfor this second shipment and found them to be in order.

The investigators inte: viewed the individual amployees involved in theinitial transfer in order to determine if the apparent noncompliancewas inadvertent or willful. The Manager of Quality Assurance statedthat the material accountability clerk just couldn't get to fillingout the appropriate forms before the shutdown. The clerk, however,stated that she realized that the forms were required, that they mightnot be filled out in time. She stated that she contacted DOE toinform them of the potential delay and then asked the Manager ofQuality Assurance if she should stay to get the form finished as faras she could with the remaining information to be filled in just priorto shipment. According to the clerk, the Manager of Quality Assurancetold her not to bother filling out the forms due to his belief that afour day delay was not a long time.

The investigators informed management representatives that the failureto complete the required material transfer form (DOE /NRC-741) was aninfraction level of noncompliance with respect to 10 CFR 70.54, whichrequires that each licensee who transfers special nuclear material

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complete a Nuclear Material Transaction Report on Fonn DOE /NRC-741 onthe same day the material is shipped. The investigators stated that theseriousness of this item was due not to any compromise with respect tothe security or accountability of the material, but rather the apparentwillful nature of the noncompliance. This later aspect of the noncom-

p(UNC) to W. G. Martin (y the licensee in a letter from C. E. Boesliance was confirmed b

NRC) dated June 22, 1979 (Exhibit I), whichstated that "the delay was intentionally taken by an accounting repre-sentative to facilitate UCC's schedule."

The investigators also tock exception to the licensee's statement inthe same referenced letter which stated that the DOE /NRC-741 form was" mailed in adequate time to allow receiver reconciliation and compliancewithin the historically - acceptable ten-day period." The investigatorsstated that the form was required to be completed and signed on theday _ the material was shipped and that the 10 day accounting peiiodstated in 10 CFR TC54 applied only to the receiver in order to allowconfirmatory measurements to be made. The investigation emphasizedagain that no 10 day accounting period had ever been accepted withrespect to the shippers Nuclear Material Transaction Report and thatprior contact with DOE did not mitigate the licensee's responsibilityto comply with NRC requirements.

The investigators also reviewed the corrective action prepared by thelicensee in his letter dated June 22, 1979, in order to prevent futurenoncompliance and had had no further questions in this area.

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