ML20009D140
| ML20009D140 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 04/30/1981 |
| From: | Crow W UNITED NUCLEAR CORP., UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Miller W NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| 19071, NUDOCS 8107230212 | |
| Download: ML20009D140 (14) | |
Text
r UnC ORVAL PRODUCT 5
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3u-ss Desron of Unded Nucler Corporaton 67 Sandy Desert Road Telephone 203/848-1511 g
A unc mesounces Cornpany UncasvtHe. Connecticut 06382 e
m April 30, 1981 D
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4 Mr. R
- 1. Page, Chief ff W
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P' /ision of Fuel Cycle and Material: G 1 S Nuclear Regulatory Commission 7
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7915 Eastern Avenue Silver Springs, Maryland 20910 g ;t W
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'h' Subj ect: Amendment of License cd 4
Reference:
- 1) SNM License 368, Docket 70-371
Dear Mr. Page:
UNC Naval Products requests amendment to license SNM #368 to change the following:
a.
Section 4.7 Environmental sampling for non-radioactive materials.
These requirements were placed in the NRC license prior to the es-tablishment of the U. S. Environmental Protection Agency and the Connecticut Department of Environmental Protection.
Presently, we are subject to the Conn. DEP regulations for facility effluent and discharge control.
Revised Part I, pages 4-24 and 4-25 dated 4/27/81 are attached.
Even radioactive effluents are controlled by 40 CFR 190 (EPA) and recognized by 10 CFR 20, 46 FR 18525-6.
b.
Section 2.7 Inspections and Audits Due to several problems encountered in performing these reviews, we request revision as noted in Part I, pages 2-12 and 2-13 dated 4/27/81 as attached.
c.
Licensed Possession Limits.
Please change our licensed possession limit from 12,000 Kg. U-235 to 20,000 Kg. U-235.
Changing work levels are anticipated requiring higher inventory limits.
d.
Reorientation Training. We request that this retraining be changed f rom " annual" _to "every two years".
In reviewing NRC, Region. II d
inspection reports, we recently noted that SNM #42 li' cense,js only required to do such retraining every two years. Lo_th, SNM ;f 4_2,,and
- 368 were renewed in March 1977.
Revised P rggge 2-14 dated Si, 81 is att.fdhed. l','d I [ X,Ti. L.
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'Mr. ~R. G. Page, Chief, Uranium Fuel Licensing Br nch April 30, 1981
. Page 2.-
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e De' minimus uranium release' concentrations.
Re f. : Letter-V..L.
Miller' to All Industrial Licensees on Reduction of Leval Wastes dated September 12,.1980.
This amendment will permit' the disposal via conventional means of speci-fic batch quantities of liquid waste containing de minimus quantities of
. uranium.* l Information. and controls are' presented to justify this waste
- disposal without impacting the general environment.
- - See Table ' A.
Sampling,- Analysis and Disposition:
'A representative. sample :from each drum or carboy will be taken and analyzed for uranium.
The results shall be evaluated and used to disposition the con-tsiner to either conventional waste. disposal in accordance with Table A or
-licensed. waste disposal.
' Record Keeping:
Results of analyses will be recorded in parts per million uranium and/or
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pCi/gm. uranium. Each drum or carboy released under this amendment will be recorded in a log containing. the following information: Date filled; source of waste; date of representative sampling and signatures of person
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' taking sample; analysis results; OK for Release signature; date of removal
- from company property; name of vendor removing item or emptying tank.
UNC-NP shall maintain a current list of state approved waste disposal ven-dors with which it contracts to do business.
Discussion:
J
-Oils: Was te' oil, non contaminated, are routinely poured into an on-site 1,000 gallon-tank. When the tank is full, the oil is pumped out by a state licensed. hauler and-trucked away. We currently haul away approximately 12,000 gallons per year.
The de minimus contaminated oil would be poured into this same on-site tank,
-(not to exceed two drums per tank) thus receiving additional dilution of at least 10:1 prior to release from licenser *1 property.
Further combination of the 1,000 gallon batch with batches from other industries on the vendors pick-up circuit dilute the original de minimus uranium value to undetectable levels by any means.
The waste oil is burned by the vendor.
Solvents :
Waste solvents, non contaminated, are routinely collected into 55 gallon drums, stored -and picked up by a state licensed waste hauler. We currently
' haul away approximately 30 drums per year.
The de minimus contaminated sol-
- vent drums would be mixed with similar solvents at the vendors waste disposal
-site and incinerated.
Mr. R.
G.' Page, Chief, Uranium Fuel Licensing Branch April 30, 1981 Page 3.
Acid:
Spent nitric acid, non contaminated, is presently trucked away by a licensed waste vendor in 5,000 gallon batches from a 10,000 holding tank located on site. ' We currently haul away approxLnately 180,000 gallons per year. The de minimus contaminated spent acid would be poured into the vendor tank truck 20 gallons per truck load.
Thus on-site dilution of 250:1 will reduce the uranium concentration to undetectable levels prior to leaving licensee pro-pe r ty.
Septic Tank Sludge:
Septic tank sludge is removed from the primary settling chamber on a preventive maintenance schedule of 1-2 times per year. Slurry can be carried over from
' this chamber into a secondary chamber where it has the potential to become slightly contaminated. The slightly contaminated septic slurry would be pumped out via a commercial septic tank service along with the primary sludge.
This material is disposed via state or local approved sanitary landfills.
Dilu-tion will be sufficient to reduce any uranium quantities to non-detectable. As an option, UNC-NP could retain the slightly contaminated septic tank slurry and, with NRC approval, dispose of it within our on-site septic field.
Benefit / Rick-There is a primary benefit to accepting the proposed de minimus release levels for the wastes identified. Approval of de minimus release levels will lessen
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the burden on the licensed burial grounds. Particularly, in this situation, the waste materials identified are difficult to solidify using readily availa-ble methods.
Solidification will result in 3 to 4 times volume increase.
There is no additional risk to the public health or environment for the de RLnimus waste disposals described. C'2rrent federal state and/or local regula-tions are already in effect for the disposal of the oils, solvents and septic tank sludge identified.
This addition of de minimus amounts of uranium to the overall waste disposal methods already approved by these agencies will have no added measurable impact.
Alterna tives :
Alternatives for disposal of these materials are:
1.
Purchase, installation and operation of suitable equipment for removing the uranium.
This will still involve generation of waste for burial.
2.
Continue to drum up materials and store on-site.
3.
Set up on-site NRC licensed incineration facility.
ikr. R. ~ G. Page, Chief, Uranium Fuel Licensing Brancit spril 30, 1981
- Page 4.
Item (1) is unacceptable from the economic standpoint as well as from the reasonable use of remaining space in currently licensed low waste burial grounds.
Item (2) does not solve the problem of disposal. - It does create en cdditional problem of on-site waste management.
Item (3) is not justified for the quantities presently generated.
Attached is our check for $1,400.00 covering the cost of a minor Safety and Environmental Amendment.
_Very.' truly yours,
/
W. F. Kirk,. Manager Nuclear and Industrial Safety
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TABLE A.
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Uranium Release IDENTIFICATION OF WASTES:
Concentrations
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Estimated Quantity (prior to combination I tem Pa_cka_ge;
_ _ P_e r Yea r_ _. _
with ' on-site non-radio-
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_Ana_1 si_s 1
a_c_tiv_e_was_tc)_ _ _ _ _ _
(A) Oils (hydraulic, vacuum) 55 gal. drum 20 drums
$ 2 ppm
- fluorome tric 55 gal drum (B) isopropyl alcohol 55 gal. drum 5 drums.
1-10 ppm radio:netric (C) spent nitric acid 20 gal, carboy 10 carboys d 10 ppm fluorome tric (D) septic tank sludge commercial ' septic 2000 gallons 20 pei/gm radiome tric waste tank truck' cr isotopic (E) Miscellaneous solvents 55 gal. drum 50 drums i
10 ppm radionvitric or isotopic e
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$.,(. S u5. 0 $. N $ 0 0t
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O R A T I o N LICENSE:
SNM-368, DOCKET No.70-371 Revision 3 NAVAL PRODUCTS DIVISION Ap7 roved PART 1:
CONDITIONS AND SPECIFICATIONS I sued' April 27, 1981 ]
CHAPTER:
4 - HEALTH PHYSICS STANDARDS Supersedes Approved SECTION:
4.7 - ENVIRONMENTAL SURVEILLANCE Rev. 2 May 3, 1977 4.7 - ENVIRONMENTAL SURVEILLANCE 4.7.1.
General The UNC fabrication activities at Montville consist of receipt of uranium-bearing materials, fabrication of uranium fuel fillers, fabrication of encapsulated ele-ments, and core assembly operations.
The types of effluent discharges anticipated at the facility are:
Onsite release and control of warm water that is used daily in cleaning operations and to remove heat from chemical reactions and process equipment such as furnaces and vacuum pumps (there is no i: eat generated by nuclear, reaction or decay at our facilitics).
Onsite release and control of small quantities of spent chemicals (containing trace amounts of uranium) to the environs, af ter treatment.
Onsite release and control of detergents and chemicals to the environs, e
Offsite release of small quantities of spent chemicals containing trace amounts of urdnium to state approved conventional waste disposal vendors.
Onsite release and control of sanitary sewage to the environs af ter treatment. Off-L site. release of trace uranium bearing septic tank sludge to a commercial tank hauler.
Release of trace quantities of uranium and chemicals to the atmosphere.
Prior to the onsite relea'se of trace quantities of uranium, the waste shall be sampled and administrative controls shall be applied before discharge.
Solid waste shall be packaged and shipped off site for disposal.
Chemicals (Spent Acids) are sold to a vendor, and removed from the site by truck.
These chemicals are normally contamination free, but they shall be analyzed for uranium prior to removal from site to assure that uranium concentr.itions shall not exceed 0.1 ppm.
Based on the Environmental Impact Appraisal pre' pared by the Commission, a negative declaration has been issued.
This is further discussed in Part II.
4-23
I y
UflC U!NilTED DdUCL.tEJ2 C o R P O R A T I o N 3
LICENSE:
. SNM-368, DOCKET NO.70-371 Revision 3
NAVAL PRODUCTS DIVISION Approved PART I:
CONDITIONS. AND SPECIFICATIONS Issued April 27, 1981 CHAPTER:
4-HEALTH PHYSICS STANDARDS Supersedes Approved SECTION:
4.7-ENVIRONMENTAL SURVEILLANCE Rev. 2 May 3, 1977 Site surveillance shall be designated to establish the quantities and concentrations of effluents regulated by 10 CFR 20 af ter they have been released but prior to leaving the site boundaries. The environmental acceptance of 10 CFR 20 effluents shall be evaluated on an annual basis against applicable State and Federal regulations.
4.7.2.2 Site Surveillance
.1 Air Locations surrounding the plant, coordinated with _ meteorological data, shall be sampled approximately 24 continuous hours using high volume air samples. Sampling frequency for each site shall be every other month.
Filters shall be analyzed for gross alpha and beta / gamma activity.
.2 Water
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Surface water shall be analyzed at least quarterly at the four locations :
(1) ' Thames River-Upstream and downstream from the plant (2)
Traders Cove (3) Outfall of drainage trench (4)
Incoming city water Samples from all four locations shall be analyred for uranium.
Ground water samples shall be obtained at leut quarterly from wells surrounding the plant. and shall be analyzed for uranium radioactivity and trends evaluated, to assure that the plant discharge water is not adversely affecting residential wellc.
At least four residential wells surrounding, and in close proximity to the site boundary, shall be sampled, analyzed and evaluated at least annually for uranium, to detect any changes in the basic quality of the residential wells.
s.
G 4-24
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UGC UD507ED MUCLEAR C o R P O R A T I O N LICENSE:
SNM-368, DOCKET NO.70-371 Revision 3
NAVAL PRODUCTS DIVISION Approved PART I:
CONDITIONS AND SPECIFICATIONS Issued April 27, 1981 CHAPTER:
4 - HEALTH PHYSICS STANDARDS Supersedes Approved SECTION:
4.7 - ENVIRONMENTAL SURVEILLANCE Rev. 2 May 3. 1977 4.7.2.3 Release Surveillance
.1 Air Ef fluents.
All stacks emitting radioactive.
particulates shall be con-tinuously monitored for alpha activity at the point of release. Emissions shall be kept within and below 10 CFR 20 limits as stated in Par. 4.1.2.
Beta / Gamma activity shall be monitored and analyzed when necessary.
.2 Liquid Effluents pj Eas te A proportional sample shall be taken of the liquid effluent from each 2500 gallon retentiion tank and shall be analyzed prior to discharge to the septic tank.
Based on results, the liquids' shall either be discharged or be given further treatmen t, resampled and then released.
Uranium content of the liquid effluent shall be monitored for each discharge as it shall be released to the septic tank.
Uranium content of the effluent stream from the sep-tic tank shall be monitored every other month.
Sampling of septic tank sludge shall be scheduled at two year intervals or if records shall show that 350 gms of uranium could have been released, whichever is earlier.
Sludge samples shall be taken and analyzed prior to author-izing. tank cleanout.
Results of the analysis shall key deposition to either a licensed burial or to routine sludges handling by authorized offsite vendors.
Spent Acid Spent acid shall be sampled and analyzed for uranium prior to shipment departure by the buyer.
The analysis results shall be recorded.
4-25 l
h.,N ' N I b I[bb b h [3.O. C C O H P O R A T I o N LICENSE:
SNM-368, DOCKET NO.70-371 Revision 3 NAVAL PRODUCTS DIVISION Approved PART I:
CONDITIONS AND SPECIFICATIONS Issued April 27, 1981 l CHAPTER:
4 - HEALTH PHYSICS STANDARDS Supersedcs Approved SECTION:
4.7 - ENVIRONMENTAL SURVEILLANCE Rev. 2 May 3, 1977
.3 Meterological Monitoring A wind measuring system for accurate data on the immediate micro wind conditions at the effluent release points shall be operating on site. Wind speed and direction shall be recorded on a dual recorder.
.4 Terrestrial _
^
Soil saniples shall be taken around the perimeter of the plant in the prevailing downwind direction semi-annually.
Three to six samples shall be taken at each sample period.
Sampling shall be performed within the " leaching field every two years.
All samples shall be analyzed for enriched uranium.
'.5 Batch Release of De Minimus Uranium Concentrations e
Controlled release of de minimus uranium concentrations in oils, solvents, acid, and septic tank sludge shall be made as identi-
'fied in Table 4.7 - 1 and in accordance with the quantity, con-centrations and analyses specified.
Results of analyses will be recorded in parts per million l
uranium and/or pei/gm 235 uranium. Each drum or carboy re-leased under this amendment will be recorded in a log containing l
the following information:
Date filled; source of waste; date
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of representative sampling and, signatures of person taking sample; analysis results; OK for Release signature; date of re-moval from company property; name of vendor removing item or e emptying tank.
UNC-NP shall maintain a current list of state approveri waste disposal vendors with which it contracts to do business.
l 9
4-26 t
TABLE 4.7-1 Uranium Release
~~IDEF ICATION OF WASTES:
Concentra tions
~~~~~~~~~~
Estimated Quantity (prior to combination Item Package Per Year with on-site non-radio-
_Ana_i si l
a_c_tive_wa_s_tel _ _ _ _ _
(A) Oils (hydraulic, vacuum) 55 gal. drum 20 drums 5 2 ppm fluo rome t 55 gal. drum (B) isopropyl alcohol 55 gal, drum 5 drums 1 10 ppm radiome tr (C) epent nitri.c acid 20 gal. carboy 10 carboys i 10 ppm fluorome t j
(D) eeptic tank sludge commercial ' septic 2000 gallons 1 20 pei/gm radiome tr;
}
waste tank truck' or isotopic j
j (E)
Miscellaneous solvents 55 gal. drum 50 drums 6
10 ppm radiome tr.
j or isotopic l.
5 e
0 e
4-27
[t5:}: I U.,Y I ~ N [. 7. O C.) U C b ! 2. 5 M C O H P O R A T I O N LICENSE:
SNM-368, DOCKET NO.70-371 Revision 3 NAVAL PRODUCTS DIVISION Approved PART I:
CONDITIONS AND SPECIFICATIONS Issued April 27, 1981 CHAPTER:
2-ORGANIZATION, PERSONNEL AND ADMINISTRATION Supersedes Approved Rev. 2 May 3',
1977 SECTION:
2.7 - INSPECTIONS AND AUDITS
- 2. 7 Inspections and Audits 2.7.1 General A continuous re-appraisal of the safety program.shall be provided through a system of daily checks, regular inspections, and audits.
Violations are corrected on the spot with the concurrence of the cognizant Specialist and/or Manager of NIS and recorded.
If co r-rective actica requires additional time to complete, a record of the violation shall be prepared and maintained until corrective action is complete.
For daily checks, inspections and aqdits, all observed violations including corrective action initiated and/or completed, shall be documented. A planned schedule of regular inspections and audits shall be established by the Department Manager.
2.7.2 Daily Checks
' Daily checks and visits shall be made routinely by Health Physics Technicians who make general observations in addition to their radia-tion survey functions.
A technician shall report observed problems to the Supervisor, and the Supervisor shall take appropriate action as required.
Violations shall require a written notice and correction.
2.7.3 Inspections Plant inspections of Health Physics and Criticality Control shall be performed by NIS Department personnel (other than technicians) 1.e.,
(Healta Physics or Nuclear Critical.ity Specialist, an Engineer, the NIS Manager,* the Division Medical Physician or the Industrial
' Safe ty Specialist. An inspection includes a review of recorded violations to determine the area of areas requirint more detailed observa-tion. Generally, a specific. area will be -observed for a suf ficient time to indicate if corrective action is needed.
Inspections shall be documented and maintained as a record for at least one year.
These inspections shall be performed as follows:
C 2-12
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.[h) b bS dbu C O R P O H A T I O N LICENSE:
SNM-368, DOCKFT NO.70-371 Revision 3
NAVAL PRODUCTS DIVISION Approved PART I:
CONDITIONS AND SPECIFICATIONS Issued April 27, 1981 QIAPTER:
2-ORGANIZATION, PERSONNEL AND ADMINISTRATION Supersedes Approved' SECTION:
2.7 - INSPECTIONS AND AUDITS Rev. 2 May 3, 197; Function By Minimum Frequency Hr.alth Physics
.NIS Professional Personnel (a) 1 month Nuclear NIS Professional. Personnel (a) 1 month Criticality Safety A
Op2 rating W Production, Process or Continuing with NMM Procedures and Quality Control EngineerinC being annually Records Control including
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Nuclear Materials Management Note (a)
Health Physics Specialist, Nuclear Criticality. Specialist, Engineer, NIS Manager, Divisica Medical Physician, or Industrial Safety Specialist
- 2. 7. 4 Audits An audit is a comprehensive review of the total protection or control aspects of the Criticality Control or Health Physics Program.
An audit shall be performed once a year by a specialist or higher level personnel from outside the Nuclear and Industrial Safety Department.
The methodology used and the areas of review shall be determined by the person (s) performing the audit. License requirements,,10 CFR 20 and appropriate NRC Regulatory Guides shall be use'd in establishing the areas of review. The professional qualifications of the personnel per-forming the audit shall be reviewed and approved by the Manager, Nuclear and Industrial Safety and the President, UNC Naval Products.
A report shall be made to the President on the effectiven2ss of the pro-gram.
Records of audits shall be maintained for at least two years.
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o n e o R A T I o N I
LICENSE:
SNM-368, DOCKET NO.70-371 Revision 3 NAVAL PRODUCTS DIVISION PART I:
CONDITIONS AND SPECIFICATIONS Approved CHAPTER:
2 - ORGANIZATION, PERSONNEL AND ADMINISTRATION 1ssued May 5, 1981 SECTION:
2,.8 - TRAINING Supersedes Approved Rev. 2
'May 3, 1977 2.8 TRAINING 2.8.1 Gene ral 4
Training programs concerning the safety aspects of handling source and special nuclear materials shall be established on a Division-wide basis.
Indoctrina-tion and training for new employees (persons on the employment roll less than 2 months) shall be provided.
Reorientation for those already in the employ of l United Nuclear Corporation shall be given at least every two years.
These por-tions of the training p,rogram shall be given or supervised by Specialists in the field of safety involved.
2,8.2 Indoctrination and Training The indoctrination and training of new employees in the safety aspects of the fueli fabrication process shall be conducted by, or under the supervision of, Specialis ts in the topic covered.
An indoctrination shall be given on the basic concepts of radiation, protective action and devices, atomic fission and the chain reaction control methods in general, and those methods utilized in NPD operations specifically; with empha-sis o,n observing safety restrictions on mass, dimension, or concentration.
Other topics shall, include, the Radiation Detection and Alarm System, its sound, and action to be taken in such emergency; company safety regulations and action in event of fire, explosion or other non-nuclear emergency. Written examina-tions shall be given to monitor employee understanding.
A record is kept of training received.
Further training of the new employee shall be continued by the supervisor, who is responsibly for instruction in all aspects of the particular assignment. Health Physics and Nuclear Criticality aspects are routinely included as a part of the regular department safety meetings. A minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> indoctrination and training shall be given to each new employee.
Documentation shall be provided to assure compliance.
2.8.3 Re-O rien tation
} UNC shall conduct mandatory refresher training in. Radiation Protection, nuclea criticality safety and emergency procedures at least every two years.
Documen '
tatica shall be provided to assure compliance.,
19071 2-14
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'" LICENSE' AMENDMENTS" N
Docket No.
William O. Miller, License Fee Management Branch, ADM
,1 MATERIALS LICENSE AMENDMENT CLASSIFICATION f
Applicant:
- A/C
~
9 License No:
, YXhM - 3b/"
Fee Category:
/IA IVo o i
Application Dated:
if/10// /
Received: r// </r//
Applicant's Classification:'
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1 The above application for amendment has been reviewed by NMSS in accordance with S170,31 of Part 170, and is classified as follows:
1.
Safety and Environmental Amendments to Licenses in Fae Categories 1A throuch 1H,'2A, 2B, 2C, and 4A (a)
Major safety and environmental (b) liino_r safety and environmental I
(c)
Safety and environmental (Categories ID through 1G only)
(d)
Administrative'
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2 Justification for reclassification: % moeinde /av/a,Ib a L A /,e di dr.- 5 d/S&/ nd,,~1% ll d' < /r>~
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3.
The application was filed (a) pursuant to written NRC request and the amendment is being issued for the convenience of the Commission, or (b)
Other(Statereason):
l Signature d ).
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.i DivisionofFuelCyclT!& Material 1
Safety I
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