ML20039G334
| ML20039G334 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 12/14/1981 |
| From: | Bidinger G, Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20039G331 | List: |
| References | |
| NUDOCS 8201180069 | |
| Download: ML20039G334 (2) | |
Text
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Distribution:
Docket File 70-368
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GHBidinger LTyson WTCrow JBlaylock RErickson JRobertson DOCKET N0:
70-371 APPLICANT:
United Nuclear Corpo=ation Uncasville, Connecticut
SUBJECT:
REVIEW 0F AMENDMENT APPLICATION DATED APRIL 30, 1981 TO REVISE REQUIREMENTS Oil ENVIRONMENTAL SAMPLING, AUDITS. TRAINING, POSSESSION LIMITS AND DE MINIMUS CONCENTRATIONS 07000371021S I.
Background
The licensee has requested the following changes:
a.
An increase in the possession limit from 12,000 kg to 20,000 kg U-235. This was subsequently authorized in Amendment No.15.
b.
A revised inspection and audit program.
c.
A reduced frequency for retraining.
d.
A revised environmental surveillance program, e.
De minimus limits for uranium concentrations in waste oils, solvents, acids, and septic tank sludges.
II.
Discussion In the revised inspection and audit program, the HP technicians no longer document daily general observations. Violattons of safety requirements would be reported to the technicians' supervisor who would initiate corrective action. Violations and corrective actions would be documented.
The IE l'roject Inspector (Mr. William Kinney) prefers documentation of the daily observations because it will be difficult to establish that daily observations were performed by technicians. The daily observations are not " required" by the draft Regulatory Guide, Task FP-716-4, October 1980.
Monthly inspections by specialists are inde and are documented.
Under the proposed audit program, an annual audit would be conducted by a specialist outside the Nuclear Industrial Safety Department. The auditor would be approved by the NIS Manager and the Naval Products President. The audit report would be submitted to the President. The applicant defines an audit as a comprehensive review of the total protection or control aspects of the criticality control or health physics programs. The auditor (s) would determine the methodology and the areas of rcview.
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- DEC 141981 The proposed audit program does not require management approval of the audit plan. The audit does cover nuclear criticality safety, radiation protection and environmental quality.
(The applicant includes radiation protection and environmental quality under his health physics program.)
This issue can be resolved by the following condition:
The Criticality Control Program and the Health Physics Program shall be audited yearly according to written audit plans. The plans shall be reviewed and approved in a manner established by the President, UNC Naval Products Division.
Under the proposed revised retraining program, retraining would be conducted every two years. The recently assigned NRC Region I project inspector (Mr. J. Roth) expressed a strong preferenee for annual training for UNC employees. As a result, the following license condition was proposed by the NMSS project manager and agreed to by the project inspector and the NIS manager:
Health physics technicians and employees working with radioactive materials in readily dispersible fom shall be trained at least annually in nuclear criticality safety and radiation protection.
A separate SER is being written for the proposed changes in the envircamental monitoring program and for the proposed de minimus limits for uranium in waste solvents, acids, oils and sludges.
III. Concl31sion and Recommendation The proposed revisions to the audit and retraining programs are acceptable to the staff because the changes should have no adverse effects on public health and safety or on the environment. Subject to the license conditions described above, approul of the application is recommended.
original signed by George H. Bidinger G. H. Bidinger Uranium Process Licensing Section Uranium Fuel Licensing Branch Division of Fuel Cycle and Oritim1315" E DY*
Material Safety w.T. Crow Approved by:
W. T. Crow, Section Leader
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