ML19296D232
| ML19296D232 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 12/11/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19296D227 | List: |
| References | |
| 70-0371-79-20, 70-371-79-20, NUDOCS 8003030047 | |
| Download: ML19296D232 (3) | |
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APPENDIX A
.N0TICE OF VIOLATION United Nuclear Corporation Docket No.70-371 UNC Naval Products Based on the results of an NRC inspection conducted on October 15-19, 1979, it appears that certain of your activities were not conducted in full compliance with conditions of your NRC License No. SNM-368 as indicated below. The first two items are infractions. The third and last item is a deficiency.
1.
10 CFR 71.12(b)(1)(ii), General License for Shipment in DOT specification containers, states in part, "A general license is hereby issued to persons deliver material to a carrier for transport (pursuant to this chapter to holding a general or specific license issued b) In a package for which a license, certificate of compliance or other approval has been issued by the Commission's Director of Nuclear Material Safety and Safeguards provided (1) The person using(a package pursuant to the general license that:
provided by this package:
ii) Complies with the terms and conditions of the certificate."
Certificate of Compliance No. 5086, Revision 0, Section 4, Conditions, states that the certificate is conditional upon the fulfilling of the conditions specified in item 5 of the certificate.
Item 5(a)(3), Drawings, states "the packaging is constructed in accordance with United Nuclear Corporation Drawings E-20354, Sheets 1 through 5."
Contrary to the above, on October 17, 1979, the licensee was using UNC-2600 shipping containers which were not constructed in accordance with United Nuclear Corporation Drawings E-20354, Sheets 1 through 5 as listed below:
Drawing E-20354-3, Revision 2, call for the h inch bolts fastening the inner container stop bars in place to be secured with nuts which were welded to the 3/8 inch thick end plate of the insertable cage.
- Instead, the 3/8 inch thick end plates of the shipping containers were drilled and tapped to accept the bolts.
Drawing E-20354-1, Revision 2, calls for blocks of oak to be placed in the ends of the inner container. The licensee does not always use blocks of oak in the ends of the container.
Drawing E-20354-1, Revision 2, calls for 3 strap assemblies made according to UNC Drawing No. 837AZ be used to hold the inner container closed. The licensee is using tape instead of the strap assemblies to hold the inner container closed.
t 8003030
APPENDIX A 2
Drawing E-20354-4, Revision 2, calls for the rubber bumper rings placed between the ends of the insertable cage and ends of tb.e outer container to be either solid or laminated rubber with no holes in the rubber other than the center 10 inch diameter hole. The licensee had used a ring which had holes cut in the ring.
2.
10 CFR 71.12(b)(1)(ii), General license for shipment in DOT specification containers, states in part, "A general license is hereby issued to persons holding a general or specific license issued pursuant to this chapter to deliver material to a carrier for transport (b) In a package for which a license, certificate of compliance or othe approval has been issued by the Commission's Director of Nuclear Material Safety and Safeguards provided (1) The person using(a ackage pursuant to the general license that:
11 Complies with the terms and conditions of provided by this package:
the certificate."
Certificate of Compliance No. 5908, Revision 5, Section 4, Conditions, states that the certificate is conditional upon the fulfilling of the conditions specified in item 5 of the certificate.
Item 5(a)(2), Description, states " Metal packaging as described and constructed in accordance with DOT Specification 6M (Title 49 5 178.104).
49 CFR 178.104(b), Specification 6M; metal packaging, states, in part, that
" Inner containment vessel must conform to specification 2R or equivalent."
49 CFR 178.34(a)(1), Specification 2R; inside containment vessel, states, in part, that "Each closure device must be as follows:
(1) " Screw-type cap or plug,... Pipe threads must be luted with an appropriate non-hardening 0
0 compound which must be capable of withstanding up to 149 C (300 F) without loss of efficiency."
Contrary to the above, during 1979, the licensee packaged fissile material in D0T Specification 6M containers using specification 2R inside contain-ment vessels with a screw-type cap without the required lute on the pipe threads.
3.
License Condition 10 of License No. SNM-368 authorizes use of special nuclear materials in accordance with statements, representations and conditions in Part I of the licensee's application.
Section 2.6, Nuclear and Industrial Safety Controls, of Part I requires, in part, that, " Operation Supervision must assure that Nuclear Criticality Safety and Health Physics control measures shall be followed as defined by or approved by NIS."
NIS Authorization No. VII-D-4, Revision 1 (5/24/76), Subject - Coupon Pickling Operations, established a zone limit of 150 S&P coupons.
APPENDIX A 3
NIS Authorization No. VII-C-7, Revision 0 (3/5/76), Subject - Scrap Retainers and Sectioned Element Storage, Condition 8 requires, " Keep hydrogenous materials (plastic, cardboard) and combustibles to a minimum in the room."
Contrary to the above, on October 15, 1979, Operation Supervision did not assure that Nuclear Criticality Safety controls measures as defined by NIS Authorizations VII-D-4, Revision 1, and VII-C-7, Revision 0, were followed.
Operations had a fuel element located in the zone for the coupon pickling operation, and the 1-qit allows only S&P coupons.
Operations had lab coats, cardboard boxes, and a jacket stored on top of a fissile material container located in the scrap retainers and sectioned element storage room.