ML19341A314
| ML19341A314 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 11/05/1980 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Gamley D UNITED NUCLEAR CORP., UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| Shared Package | |
| ML19341A310 | List: |
| References | |
| NUDOCS 8101220581 | |
| Download: ML19341A314 (2) | |
Text
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~I UNITED STATES 4,
M1 NUCLEAR REGULATORY COMMISslON
<i 63f PARK AVENUE REGION I e
'g ef KING OF PRUS$1 A, PENNSYLVANI A 19406 Docket No.70-371 United Nuclear Corporation thval Products ATTN: Mr. D. E. Ganley President 67 Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:
Subject:
Inspection 70-371/80-07 This refers to your letter dated September 29, 1980, in response to our letter dated September 2, 1980.
In your communication dated September 29,1980 (NIS-80-9-62) you make the following statement:
"We had expected that the information supplied in Reference (2) would be sufficient to demonstrate that the Corporate Nuclear Safety Team Review was a proper review to be recognized as an annual review of various items of nuclear safety, including health physics. An evaluation by NRC management of the acceptability of this audit is still requested."
For the reasons presented below, neither the review by the Corporate Nuclear Safety Team nor the review by the American Nuclear Insurers Staff Nuclear Engineer constitute an adequate audit.
An audit is a documented activity performed in accordance with written procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the radiation protection program have been developed, documented, and effectively implemented in accordance with specified requirements.
Your Corporate Nuclear Safety Team did not make this verification.
The inspector was told that the Corporate Nuclear Safety Team had been " presented" the radiation protection program in a seminar.
This is not acceptable as satisfying the audit requirement.
l l
With reference to, "the detailed review and evaluation of our Radiation Protection l
Program by our nuclear risk specialists," this review did not constitute an adequate audit.
The nuclear risk specialists report did not cover the following I
areas which, among others, we expect to be addressed in an adequate audit:
l 8101220b
!T 0 5 D80 United Nuclear Corporation 2
1.
Health Physics Organization 2.
Health Physics Training a.
General training for all licensee personnel b.
Health Physics Personnel 3.
Instrument Maintenance and Calibration a.
Counting Room Equipment b.
Portable Instruments c.
Criticality Monitors 4.
ALARA 5.
Health Physics Records a.
Air Samples b.
External Radiation Surveys c.
Exposure Information d.
Smear Surveys e.
Waste Disposal With reference to Item A of Appendix A of the Notice of Violation included in our letter dated May 15, 1980, please submit to this office within ten (10) days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further items of noncompliance; and (3) the date when full compliance will be achieved.
Based on the information in your letter and the telephone conversation on September 26, 1980 between Mr. Kirk of your staff and Mr. Crocker and Mr. Clemons of this office, we understand that it is now not possible to enter "B" South without passing the posting as required by 10 CFR 20.203(e). If this under-standing is not correct please clarify this matter in your reply.
Sincerely, n
ykfh/ f r
George H. Smith, Chie i
Fuel Facility and Materials Safety Branch I