ML20006F222
| ML20006F222 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 02/14/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kaufman N UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 9002270263 | |
| Download: ML20006F222 (2) | |
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1 FEB 141990 j
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b cket No. 70-371-
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UNC, Incorporated
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- UNC Naval. Products
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' ATTN: Mr. N. C. Kaufman
.. President-
'67LSandy Desert Road
.Uncasv111e, Connecticut 06382
' Gentlemen:
Subject:
4 Inspection No. 70-371/89-04 This refers to your letter dated October 26, 1989,. in response to our letter t
dated September. 27, 1989.
Regarding your: response't'o Violation A, it is important to understand that i
.when (a) differe,qt methods of nuclear. safety evaluation are used to e.stablish different configurations of fissile material (e.g., storage boxes and Ltransport' carts) in the same work area, and (b) these different configurations-t
.arefnot--in: fixed locations (e.g., transport carts are movable), then a
NRC-approved license-application) could be implemented by the licensee without' formal review and approval byLthe'NRC-NMSS' l4 Headquarters.. The basis for.the significance of our concern is that-the' formal-
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~ licensing. function directly affects and supports the safety programs s
c administered by the licensee. Thorefore, the Severity. Level of this violation remains unchanged.-
f Regarding the' soil that was collected in the outside alcove area beneath a:
potentially-contaminated discharge point, we recommend that you proceed with your1 independent analysis of.this sample, which was split between you and the yNRC' so'th'at'we may fully characterize the nature of this discharge.
(
k IThank you for_' informing us of the corrective and 4 :eventive~ actions documented
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in"your letter'and the supplemental information provided therein.
These.
't actions will be. examined during a future inspection of your licensed program.
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.t Your cooperation with us'is' appreciated.
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- t Ronald R. Bellamy,-Chief Facilities Radiological Safety and Safe 0uards Branch Division of Radiation Safety and Safeguards cc w/ enc 1:
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State of Connecticut bec'w/ enc 1:
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Management Assistant, DRMA' (w/o enc 1)
J, Roth, DRSS-G. Bidinger,-NMSS M. Austin, DRSS.
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~In Reply Please Refer To:
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NIS-89-10-12 r
m October-26,--1989 i.
Mr._ Ronald R.- Bellamy, Chief
. t Facilities Radiological Safety and SafeguardsiBranch-Division of Radiation Safety and L,
Safeguards U.'S.: Nuclear Regulatory Commission Region 1-475 Allendale Road' King:'of' Prussia, Pennsylvania 19406 r
Subject:
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 29,11989 l
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Dear Mr.iBellamy,
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'This letter'is.in response to the referenced letter'which p
-presented the results of;NRC Inspection 170-371/89-04...As can c
.be seen-from the details;in,the attachment to this letter,1we s
have~taken immediate' corrective actions to. address the-items-identified in your letter.
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-andrews lPresidentL 1
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1 Attachment.
cc:
R. Gregg T. Gutman
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IUNCNavalProducts Attachner.t To Letter, R.B. Andrews to R.R. Bellamy, dated 10-26-89, UNC Response to NRC Inspection 70-371/89-04 j
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Appendit Notice of violation
-A.
NRC Comment Condition No. 10 of License No. SNN-368 requires that the licensee i
i operate in accordance with the statements, representations and conditions in Part I of the application. Section 2.5.1 of Chapter a,-
"organisation Personnel and-Administration", of Part I requires that' licensee manag,ement assure suitable control measures are prescribed for nuclear criticality safety. Section 3.2.1 of Chapter 3,
" Nuclear i
criticality Safety-standardsH, of Part I requires'that nuclear L
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 NC8 a
evaluatione I
contrary to the above, the licensee failed to perform a complete nuclear criticality safety evaluation of a raw. fuel container storage boxnin the Unit 1 Quality control area which resulted in the failure
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to properly apply and use floor markings around the storage box for i
nuclear criticality safety control.
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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 this box have since been. changed.
4 The failure to-apply red dots resulted from the application of' license-amendments to several components in the area.
The box in question was l
not considered'at that time.
Although red dots were applied at.the-time: of the inspection, re-evaluation of the box shows that those dots -
are-not necessary.
Accordingly:
Corrective Actions Taken 1)
Red dots were applied immediately.
They are presently in place although re-evaluation shows that they are not necessary.
Corrective stens To Avoid Future Violations:
2)
All authorisations have been reviewed.
Several are being upgraded to reflect evaluations which r.re 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.
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p_ ate When Full CtemDliance Will Be Achieved 3)
-We will be in full compliance by Oct. 31, 1989.
'B.
10 CFR 70.41(b) states that the licensee shall be subject to the i
provisions of the license. Condition No. 10 of License No.
SNM-368 requires that the licensee operate in accordance with the statements, representations and. conditions-in Part I of the application. Section 2.2.2.3 of Chapter 2, " Organization, Personnel, and Administration", of Part I states that the' Health Physics 8pecialist is responsible for the administration of the licensee's radiation protection program.
Contrary to.the above,.the licensee implemented a change to the j
safety organization 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 RESPONSE UNC concurs that the license had not been modified as of the time of this inspection.
An amendment 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 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 personnel present), of UNC's intent to make this organizational change.
2)
NRC was verbally informed at the time the HP Supervisor was hired.
3)
NRC Inspection 70-371/89-03 states ".....his background will enhance the radiation protection staff and provide the necessary supervisory oversight."
In all of the' dialog with the NRC, the addition of this. position was greeted as being a positive step-towards improving UNC's radiation protection program.
Thus, the change was made 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; ll.a. 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 tho 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.
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Attachment To Letter, R.B. Andrews to R.R. Bellamy,-dated'10-26-09.
~l (Continued)_
i Corrective Actions Takent 1)
A license amendment request was submitted on sept 8, 1989 and approved by the NRC on October 17,: 1989.
lyture Corrective Actions To Avoid Future Violations:
2)
All staffing changes will be reviewed by MIS to determine i
the need for licensing action.
Date When Full Compliance Will Be Achieved 3)
We are currently in full compliance.
ADDITIONAL COMMENTS / CLARIFICATIONS ON SPECIFIC ITEMS
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4.1 Gaseous Discharcet
.The Pack Assembly Evacuation process examined by the inr.pector is a vacuum exhaust serviced by both mechanical and diffusion vacuum pumps.
t These pumps function in_such a manner that any air exhausted from the packs is carried with an oil mist through
-t the pumping chambar and into an oil casing.
The pack components are-prepared,. covered, and sealed in such 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 i,
should any be present, and therefore this' exhaust would not emit radioparticulates into the downstream piping system.
UNC's Health Physics staff had praviously 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
-reguired.
we are current 3y repeating and updating those surveys'and evaluations for future NRC' review.
24'.2 Limuid Discharces n.4.
line 6
\\y The reference to a " settling" pond is not correct.
The E
ponds were. originally designed as and are used for cooling,
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percolation ponds for non-contaminated process rinse water.
No material is being " settled".
Ibid. line 10 UNC's permit to discharge contact and non-contact process water has expired and we are in a review / renewal period for-t this~ discharge.
While we have been working.with the state 3:
on this renewal, we did not intend to give the inspector the1 impression that there is an informal " agreement" regarding this activity, as no such " agreement" exists.
UNC
-is following the standard permitting requirements for-
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