ML20011A342
| ML20011A342 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 03/10/1981 |
| From: | Gregg R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20011A337 | List: |
| References | |
| RJG:81-48, NUDOCS 8110090335 | |
| Download: ML20011A342 (4) | |
Text
-..
~
l*
Uf1C RECOVERY SYSTEMS Division of United Nuclear Corporanon One Narragansett Trail Telephonean1'364 /701 A Unc RESOURCES Comrfany Wood River Junction. Rhode Island 02894 RJG: 81-48 March 10, 1981 U.
S.
Nuclear Regulatory Commission Mr. George II. Smith, Chief Fuel Facility and Materials Safety Branch Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC Inspection 70-820/80-25
Reference:
Letter on Subject, George H.
Smith to Glenn O. Amy, Dated February ll, 1981 Gentlemen:
Attached is UNC Recovery System's response to the subject inspection report, which was transmitted via the referenced letter.
We trust that this response will satisfactorily resolve the items delineated in Appendix A of your letter.
If further amplifi-cation is needed, we will of course be happy to discuss the matter with you.
Very truly yours, UNC RECOVERY SYSTEMS
'l N
R.
J.
Gregg Plant Manager RJG:amc cc:
G.
O.
Amy K.
A.
IIelgeson File Attachment tv 8110090335 810924 PDR ADOCK 07000820 C
4 ATTACHMENT TO LETTER RJG: 81-48 R.
J. GREGG TO GEORGE H.-SMITH DATED MAReff 10, 1981 USNRC INSPECTION 70-820/80-25 ITEM A USNRC COMMENT.
Contrary to License Condition No. 9 and Section 206.2 of the license, an unsafe geometry vacuum cleaner was used in the uranium process area on October 22, 1980, and it had not been evaluated or had signed written approval by NIS at the time of this inspectior,.
UNC-RS RESPONSE Although a formal authorization document had not. been issued at the time of use of the vacuum cleaner, an evaluation of operating criteria applicable to its use had been performed by J. E. Neumann, Criticality Safety Specialist and K. A. Helgeson, Manager, NIS, prior to its use.
It was agreed that the use of the vacuum cleaner would be handled on a case-by-case basis utilizing the Safety Work Permit systen.
The. operating parameters would be evaluated by the Manager, NIS and an SWP would be issued, incorporating prerequisites or conditions for its' use.
In the instance cited, an SWP was issued with a floor survey required prior to the vacuum cleaner's use, in order to assure that the material to be vacuumed was con-tamination and not concentrated material.
It should be noted that this was over two months into the decommissioning program, sub-sequent to cessation of uranium recovery operations.
UNC immediately stopped'use of the vacuum cleaner when the NRC inspector identified this item, although no hazard was posed by its use under the con-trols which were in place.
A formal safety analysis was subsequently made prior to further use of the cleaner.
Item B USNRC COMMENT Contrary to License Condition No. 9 and Section 404.2 of the license, on December 18, 1980 and again on December 19, 1980, the airflow was from areas cf higher contamination to areas of lower contamination.
UNC-RS RESPONSE The original design of the air handling system for the UNC-RS fa-cility relied upon HEPA filtered equipment exhaust systems to sup-ply the major portion of the negative pressure for the process area.
Due to removal of process equipment during the decommissioning acti-vities, these filtered exhaust systems had to be shut down and removed.
l L
'~
Pega 2
+.
a i
.At the time.of the inspector's visit, UNC-RS was in the process of determining a method of correcting the air balance for this area.
This was accomplished subsequent to the NRC inspection, and the proper airflow now exists 4 Although the direction of airflow was reversed on the occasions cited, inspection of the air sample records for several weeks prior to andiduring the week of December 15 show the concentration of airborne particulate material averaged less than 10% of the maxi-mum permissable concentration inside the process area and less than 5% of the maximum permissable concentration in areas immediately adjacent to the process area.
In addition, evaluation of removable contamination (smear)' survey records outside of the process area for this period show no indications that instances of reverse flow resulted in increased levels of centamination.
At no time was there an instance that threatened to cause the exposure of personnel, inside or outside the plant, to inordinate levels of airborne radio-active material.
ITEM C USNRC COMMENT Contrary to License Condition No. 9, Section 206.1 of the license and Standard Operating Procedure I-Z, Revision 1, Section 4.1.1, fixed contamination surveys have not been performed at any time during 1980.
UNC-RS RESPONSE At the time of the inspector's visit, no survey document could be found.
There was, in fact, such a survey made and the documenta-tion was found misfiled in the Special Environmental Survey Log Book instead of the Monthly Inspection Log Dook where these surveys would normally be filed.
A copy of the survey will be available during the inspector's next visit or will be forwarded to you if requested.
We regret this clerical error.
Prior to 1980 and the decision to terminate operations at the facility, these fixed contamination surveys were done on a monthly basis.
ITEM D USNRC COMMENT Contrary to License Condition No. 9 and Section 207 2 of the license, which require that a quarterly do- ",2nted review and appraisal of the weekly safety inspections be performed by the Manager, Nuclear and Industrial Safety, a quarterly documented review was only conducted by the Nuclear and Industrial Safety Manager during the first quarter of 1980.
Pago 3 UNC-RS RESPONSE UNC agrees-that this documented review was not completed.
On July 1, 1980, the Manager, Nuclear and Ind,ustrial Safety suffered a heart attack'and was hospitialized.
He did not return to work until mid September and in his absence, coverage was provided by personnel from the UNC Naval Products Division's Nuc 3ar and Industrial Safety department.
The personnel were not thoroughly familiar with the reporting requirements of the UNC-RS license and this particular report was overlooked.
However, all of the re-quired weekly inspections were performed and responsible manage-ment personnel were informed of the findings.
No adverse trends were. indicated, and this fact has now been documented on quarterly summary reports.
As the necessary management controls were in place to protect against adverse safety trends, UNC does not feel that the lack of formal reports resulting, from an unusual personnel problem should be treated,as an item on non-compliance.
ITEM E USNRC COMMENT Centrary to the requirements of 10CPR 20.408, an employee termi-nated his employnent with the licensee August 30, 1980, and the required exposure reports had not been submitted at the time of the inspection, an elapsed period of approximately 110 days.
UNC-RS RESPONSE UNC concurs with the inspector's findings.
Approximately 14 tem-parary employees were terminated during this period, but the report for this individual was overlooked.
It should be noted that this individual received no detectable exposure due to work at this facility.
UNC feels that this was an isol ated case, and that it should not recur in the future.
t l
l l