ML19325E663
| ML19325E663 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 10/26/1989 |
| From: | Andrews R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NIS-89-10-12, NUDOCS 8911080212 | |
| Download: ML19325E663 (4) | |
Text
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R. Bruce Ardows p+
Presdent -
e e,
'UNCNavalProducts LK=
Urcaswile. Connectcut 06382 0981 In Reply Please Refer To:
NIS-89-10-12 October 26, 1989 Mr. Ronald R.
Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region 1 475'Allendale Road King of Prussia, Pennsylvania 19406 Subjects UNC Response to NRC Inspection No. 70-371/89-04 of August 21-25, 1989
Reference:
Letter, R. R. Bellamy to B. Andrews, same subject Dated September 29, 1989
Dear Mr. Bullamy,
This letter is in response to the referenced letter which presented the results of NRC Inspection 70-371/89-04.
As can be seen from the details in the attachment'to this letter, we have taken immediate corrective actions to address the items identified in your letter.
Ve f uly y urs, l
/WIW M 3 i
s R
r1Me Andrews l
President i
/jmp l
Attachment cc:
R. Gregg T.
Gutman D.
Luster 1090 h
C A UNC Company
. ~...
UNCNavalProducts Attachment To Letter, R.B. Andrews to R.R. Bellamy, dated 10-26-89.
UNC Response to NRC Inspection 70-371/89-04 I.
Appendix Notice of Violation A.
NRC Comment condition No. 10 of License No. SNM-368 requires that the licensee operate in accordtnce with the statements, representations and conditions in Part I of the application. Section 2.5.1 of Chapter 2, "Organisation, Personnel and Administration", of Part I requires that licensee management assure suitable control measures are prescribed for nuclear criticality safety. Section 3.2.1 of Chapter 3, " Nuclear criticality safety Standards", of Part I requires that nuclear criticality safety (NCS) evaluations consider all factors which may i
affect the criticality of a system, including the interaction parameter.- Section 3.6 of Chapter 3 of Part I requires that the application and use of markings for the overall NCS program be established by the licensee on the basis of a documented NCS evaluation.
Contrary to the above, the licensee failed to perform a complete i
nuclear criticality safety evaluation of a raw fuel container storage-box in the Unit 1 Quality control area which resulted in the failure to properly apply and use floor markings around the storage box for nuclear criticality safety control.
UNC Response A complete Nuclear Criticality Safety evaluation of the storage box was performed'on 11-28-77.
No red dots were required by the method of analysis used at that time.
Neither the location or the limits for I
this box have since been changed.
i The failure to apply red dots resulted from the application of license amendments to several. components in the area.
The box in question was not considered at that time.
Although red dots were applied at the i
time of the inspection, re-evaluation of the box shows that those dots l
are not necessary.
Accordingly Corrective Actions Takent 1)
Red dots were applied immediately.
They are presently in place although re-evaluation shows that they are not necessary.
Corrective Steps To Avoid Future Violationst 2)
All authorizations have been reviewed.
Several are being upgraded to reflect evaluations which are being written in more complete form.
Because no changes to limits, controls, or spacings result from this review, upgraded evaluations will be completed by oct. 31, 1989.
OSSPO550 A UNC Company
l
'f, UNCNavalProducts Data When Full Conoliance Will Be Achievedt 3)
We will be in full compliance by oct. 31, 1989.
I l
B.
10 CFR 70.41(b) states that the licensee shall be subject to the provisions of the license. Condition No. 10 of License No.
i SNM-368 requires that the licensee operate in accordance with the statements, representations and conditions in Part I of the l
application. Section 2.2.2.3 of Chapter 2, "organisation, Personnel, and Administration, of Part I states that the Health n
l Physics Specialist is responsible for the administration of the l
licensee's radiation protection program.
Contrary to the above, the licensee implemented a change to the j
safety organisation described in Part I of the license without NRC approval, which reassigned the administration of the daily health physics surveillance program to a newly-developed position of Health Physics Supervisor.
UNC RESPON8E UNC concurs that the license had not been modified as of the time of this inspection.
An maandment was submitted on September 8, 1989 and approved by the NRC on october 17, 1989.
We disagree, however, with the NRC's categorisation of this as a Severity I
Level IV violation, for the following reasons:
1)
The NRC was notified, as early as September 1988 (PIP meeting at Region 1, with both Region 1 and Licensing e
personnel present), of UNC's intent to make this organisational change.
2)
NRC was verbally informed at the time the HP Supervisor was hired.
3)
NRC Inspection 70-371/89-03 statesgH,,,,,hig bggggggggd will enhance the radiation protection staff and provide the necessary supervisory oversight."
In all of the dialog with the NRC, the addition
't on2s position was greeted as being a positive step towards improvl
~ UNC's radiation protection program.
Thus, the change was anae both with NRC's cognizance, and recognition as being a program enhancement.
NRC's guidelines (10CFR2, Appendix C) state that " Severity Level IV violations are less serious but are of more than minor concern; i.e. if left uncorrected, they could lead to a more serious concern.
Severity Level V violations are of minor safety or environmental concern."
Based on the above and the fact that the failure to submit a timely license change in this case constitutes neither a safety or an environmental concern, UNC requests that NRC change this item to a Severity Level V violation.
osseosso A UNC Company
1 UNCNavalProducts 1
Attachment To Letter, R.B. Andrews to R.R. Bellamy, dated 10-26-89.
(Continued)
Corrective Actions Taken:
1)
A license amendment request was submitted on.8ept 8, 1989 and approved by the NRC on October 17, 1989.
Future Corrective Actions'To Avoid Future Violationst 2)
All staffing changes will be reviewed by NIS to determine the.need for licensing action.
Date When Full conoliance Will Be Achieved:
3)
We are currently in full compliance.
ADDITIONAL COMMENTS / CLARIFICATIONS ON SPECIFIC ITEM 8 4.1 Gaseous Discharaos The Pack Assembly Evacuation process examined by the
+
inspector is a vacuum exhaust serviced by both mechanical and diffusion vacuum pumps.
These pumps function in such a manner that any air exhausted from the packs is carried with an oil mist through I
the pumping chamber and into an oil casing.
The pack components are prepared, coveret, and sealed in r.uch a manner that the potential for presence of radioactive particulates is improbable.
The small quantity of air (less than is cubic inches) which is evacuated through the vacuum pumping chamber will not pass radioactive particulates should any be present, and therefore this exhaust would not emit radioparticulates into the downstream piping system.
UNC's Health Physics staff had previously performed evaluation and surveys of the pump manifold internals and the collected oil during routine maintenance of the system over a three year period.
The results of these evaluations demonstrated that radioparticulates were not being exhausted and thus, special handling, controls, or monitoring were not required.
We are current 3y repeating and updating those surveys and evaluations for future NRC review.
4.2 Licuid Discharaes D.4, line 6 The reference to a " settling" pond is not correct.
The ponds were originally designed as and are used for cooling, i
percolation ponds for non-contaminated process rinse water.
No material is being " settled".
Ikid, line 10 UNC's permit to discharge contact and non-contact process water has expired and we are in a review / renewal period for this discharge.
While we have been working with the State on this renewal, we did not intend to give the inspector the impression that there is an informal " agreement" regarding this activity, as no such " agreement" exists.
UNC is following the standard permitting requirements for renewal application.
.-