ML19294B199

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Forwards Questions & Comments Re 790302 Application for Amend of License Section 200, Organization,Personnel & Administration. Proposed Changes Are More Substantive than Reassignments of Qualified Personnel
ML19294B199
Person / Time
Site: Wood River Junction
Issue date: 07/30/1979
From: Stevenson R
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Bowers C
UNC RECOVERY SYSTEMS, UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
References
NUDOCS 8002270548
Download: ML19294B199 (3)


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JUL 3 01979 FCUF:RLS Docket No.70-820 United Nuclear Corporation Recovery Systems ATTN: Mr. C. E. Bowers, General Manager One Narragansett Trail Wood River Junction, Rhode Island 02894 Gentlemen:

We have reviewed your March 2,1979 application for amendment of Section 200, " Organization, Personnel and Administration," of License No. SNM-777. We find that the proposed changes are more substantive than mere reassignments of qualified personnel and in need of further clarification and justification. Our specific comments are given in the attachment.

We would appreciate receipt of the requested additional information, including revised pages for Section 200, within sixty (60) days, to permit timely continued effort on your application.

Sincerely, f.Ad-

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hew Robert L. Stevenson Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and s.lMaterial Safety

Enclosure:

Questions and Comments on Amendment Application, Pages dated March 1, 1979, Docket 70-820 80022%

QUESTIONS AND COMMENTS ON AMENDMENT APPLICATION, PAGES DATED MARCH 1, 1979, UNITED NUCLEAR CORPORATION, DOCKET N0.70-820 1.

Subsection 201, Division Organization - The text on this page refers to the Manager, Fuel Recovery Operations, but should describe the division organization.

2.

Figures 201-1 and 201-II - The text on para. 201 and these figures do not describe a clearly consistent entity.

(a)

If the General Manager shown on Figure 201-II is not the Division General Manager, (and it is not clear that he is) the figures are not consistent and need to be redone.

(b) The right half of Figure 201-II shows " future blocks of uncertain purpose, including the position of NIS in the chain of command, that require clarification. There appears to be a hazard that NIS could be placed under the control of the operations group and subject to undue pressure.

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3.

Subsection 202, Nuclear and Industrial Safety Department -

(a) The term Department appears to be a misnomer for a unit no larger than a subsection and should be made consistent with the text of para.1, Organization.

(b)

Para. 2, Responsibilities -

I - Words appear to have been omitted from the first sentence, which should explain the objective of the safety evaluations.

II - The revised text deletes reference to NIS responsibility for a "one-over-one" review by technically competent personnel, which should be retained to help clarify the intent of 206.2.2.

(c)

Para. 3, Personnel Qualifications - The qualifications should be revised to be consistent with the current standards in the Division.

4.

Subsection 205, pace i of 2 pages - The issue date for this page should be March 1, 1979 instead of March 1,~1975.

5.

Subsection 206, Para. 2.2 -

(a)

Please explain what is meant by, " Safety calculations other than those approved by sections of this license...."

(b) The reference to technical qualifications should be to 202.3 instead of 206.2.2.

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- The proposed revision deletes reference 6.

Subsection 206, Para. 2.3 to qualifled technical safety personnel making safety evaluations prior to approval of the Manager, NIS.

In view of personnel reassignments, the originc1 text should be retained.

7.

Subsection _206 - Paras. 3. Records and 4. Suspension of Operations were omitted from the revised text and should be reinstated.

8.

Subsection 207, Para 1. Inspection - This paragraph should include the maximum allowed interval duriiig which all of the identified items will be inspected.

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