ML19261D756
| ML19261D756 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 03/09/1979 |
| From: | Ganley D UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19261D755 | List: |
| References | |
| NUDOCS 7906260331 | |
| Download: ML19261D756 (5) | |
Text
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UflC UNITED NUCLEAR C 0 R P O R A T I O N In Reply, Please e7 saNov omstaT acao Refer To: NIS:
UNCASVILLE, CONNECTICUT C63e2 79-3-25 Ta' ede-isu March 9, 1979 Mr. George H.
Smith, Chief Fuel Facility and Materials Safety Branch U.S.
Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
Inspection 70-371/79-01
Reference:
- Letter, G.H.
Smith, NRC, to D.E.
Ganley, UNC, dated February 14, 1979
Dear Sir:
In reply to referenced letter:
Appendix A,
Item A.1 and 2 and Para. 4.a and 5.b (1), (2 ) of Details - Cart Parking 1.
Corrective steps which have been taken and the results achieved Unattended and incorrectly parked storage carts were re-parked in authorized locations.
2.
Corrective steps which will be taken to avoid further items of non-compliance a.
Supervisors / foremen o f Shops II, III and IV shall be re-instructed in required fuel handling procedures in documented meetings by April 15, 1979.
Future occurrences of this nature shall be the subject of disciplinary action.
2311 080 790326033)
D
Mr. George H.
Smith Page 2 March 9, 1979 y
b.
We are currently reviewing modifications to our rigid criticality control system that would allow greater flexibrlity and reduced personnel control for our operating group so that such occasional infraction conditions as noted shall be eliminated as requirements.
~
Implementation is expected to begin shortly and carry over a psriod of one year.
3.
The date when full compliance will be achieved Our facility is currently in full compliance.
Appcadix A, Item B and Para. 4.c of Details B-South Use of Lab Coats 1.
Corrective steps which have been taken and the results achieved The lighted signs have been modified to include " lab coats".
No contamination hazard existed at the time of the inspection entry without lab coats since no work was being conducted in the area on the second shift.
2.
Corrective steps which will be taken to avoid further items of non-compliance See above.
3.
The date when full compliance will be achieved our facility is currently in full ec 711ance.
Appendix A,
Item C.1 and Para. 5.c (1) of Details Contamination Control - Wash and Survey 1.
Corrective steps which have been taken and the results achieved Cupervisory personnel associated with laboratory operations have been again re-instructed in required health physics rules.
2.
Corrective steps which will be taken to avoid further items of non-compliance Additional signs and postings will be in place by April 1,
1979.
Documented awareness meetings shall be conducted with all lab personnel to re-emphasize all health physics controls and their.
enforcement.
Future violators shall be subject to disciplinary actions'by their department.
3.
The date when full compliance will be achieved Our facility is currently in full compliance.
2311 081 4..
Mr. George H.
Smith Page 3 March 9, 1979 Appendix A, Item C.2 and Para.
- 5. c 'l) of Details Location of Survey Meter 1.
Corrective steps which have been taken and the results achieved Supervisory laboratory personnel have been again re-instructed in required health physics rules.
2.
Corrective steps which will be taken to avoid further items of non-compliance The location of the survey meter shall be changed to be at the exit doorway from the Spectrographic Laboratory by April 1,
1979.
The present location next to the sink had been considered to be more functional by the responsible chemist.
3.
The date when full compliance will be achieved Our facility shall be in full compliance by April 1, 1979.
Appendix A, Items C.3 and C.4 and Para. 5.c(2) of Details Contamination Centrol - Wash and Survey 1.
Corrective steps which have been taken and the results achieved Health Physics technicians have been instructed as to proper procedures to be followed within their own work areas even when known contamination levels are low.
The personal survey meter has been repaired and returned to location.
A sink has always been available in the area; showers are available in adjacent s ?mp areas.
When special contamination control zones are established for limited times, all normal procedures (e.g.,
handling of 5 gallon containers) shall be reviewed for compliance with the new imposed conditions.
2.
Corrective steps which will be taken to avoid further items of non-compliance A documented re-instruction of H.P.
technicians shall be done by April 1,
1979.
3.
The date when full compliance will be achieved our facility is currently in full compliance.
Appendix A, Item D and Para. 5.c(3) of Details Posting of Controlled Area 1.
Corrective steps which have been taken and the results achieved The door between the Sectioning Area and the Spectrographic Laboratory is intended for transfer of material such as drums; containers, and trash bags between the area-Limited personnel use of this door is acceptable provided th se has been evaluated and posted by Health Physics.
A definitive posting shall be added concerning personnel usage.
In addition, the door shall be correctly labeled with the radicactive symbol denoting entry into a " Controlled Area".
2311 082 8
' Mr. George H.
Smith Page 4 March 9, 1979 NRC Inspection 78-02 had brought to our attention the potential fire hazard of plastic bags of trash next to this door.
We corrected this situation by having the waste handling personnel take the bagged material from the laboratories directly to the compactor.
2.
Corrective steps which will be taken to avoid further items of non-compliance The area door shall be posted with the required radioactive symbol and the conditions of limited personnel use of the door by March 23, 1979.
3.
The date when full compliance will be achieved Our facility shall be in full compliance by March 23, 1979.
Appendix A, Item E and Para. 5.f of Details NIL Approval of Documents Our system of nuclear safety control has always been based on control of operations within the plant facilities through (a) specification and posting of criticality requirements throughout the plant, (b) selective zoning, (c) operations route card approval, (d) fixture / tooling approval where more than one normal safe quantity (S.Q.) of SNM con-tained components is employed, (a) training and auditing.
All personnel are thoroughly trained to work in compliance with nuclear criticality limits as che prime work area requirement.
Precess specifi-cations (PS) and manufacturing operating procedures (MOP) are documents that give employees details of how to perform work operations and no:
affect posted required criticality limits.
No beneficial increase in nuclear criticality safety would be obtained by NIS approval of such documents.
Since there are several thousand documents of different categories that are associated with SNM materials, the effort required to continued NIS review and approval of such documents would contribute more of a dilution effect to important control systems than an improve-ment in safety.
We have always considered that the review and approval of operations in any area was denoted by the route card epnraval and criticality posting; the route card carries a list of applicable MOP's at each operation, and in any area in which more operational details.are needed, the MOP is also reviewed as part of the route card review and approval.
1.
Corrective steps which have been taken and the results achieved We.have reviewed the subject and commented as noted above.
2.
Corrective steps which will be taken to avoid further items of non-compliance A review shall be made of the Divisional Master list of Approved Documents for items that fall within the ce i
- t of the NRC license.
Such items that are acceptable to NIS will :a signed off on the MLAD listings.
The NIS Department will then maintain a listing of their approvals without the necessity o f signature directly on each document.
This listing will be available for NRC review.
2311 083
Mr. George H.
Smith Page 5 March 9, 1979 3.
The date when full compliance will be achieved This system shall be in effect by May 1,
1979.
Para. 5.a of Details Permanent Shipping Container Markinc
-Permanent tags shall be affixed to all UNC-2500 shipping containers by March 14, 1979.
The tag shall show model number and cer-tificata of compliance number.
Para. 5.d of Details Storage of Co-60 Source External radiation from the storage location, though currently quite low and acceptable to 10 CFR 20, shall be reduced to ALA RA by March 23, 1979.
Para. 5.e of Details Safety During Cleanine with Acetone A safety bulletin on the occurrence noted has been distributed to all supervision 2nd posted.
Para. 7.c of Details - Organization An organizational update shall be submitted to the NRC by May 1, 1979, or earlier if appropriate documents are being processed to NRC - Washington.
Should further information be required, please contact us.
Very truly yours, UNITED NUCLEAR CORPORATION I
David E. Ganleyl ~'
Acting General Manager Naval Products Division
/cjm 231l 084
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