ML20041A810
| ML20041A810 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 01/21/1982 |
| From: | Ganley D UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20041A805 | List: |
| References | |
| NUDOCS 8202220544 | |
| Download: ML20041A810 (4) | |
Text
UnC nRVAL PRZDUCTS Division of United Nuclear Corporation 67 Sandy Desert Road Tetephone 203 848-1511 Ur1C A UnC RESOURCES Company Uncasvute. Connecticut 06382 January 21, 1982 Mr. R. W. Starostecki, Director Div. of Resident and Project Inspection U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Pennsylvania 19406
Subject:
Inspection No. 70-371/81-18 November 16 - 19, 1981 Ref. :
Letter, R. W. Starostecki/D. E. Ganley, 12/23/81
Dear Mr. Starostecki:
In reply to the referenced letter, the following comments are made:
Item A. of Appendix A, and caracraph 3. a. of Details, Ooeration Control.
Referenced Section 2.5, " Operation Control," applies to operating procedures as specified in succeeding paragraph 2.5.2 and not to
" posted authorizations forms" which are covered in Section 2.6.1.2 of our License.
However, we consider existing postings to be satisfactory to NPD Management for the following reasons:
1.
The posted authorizations are approved by NPD Management (i.e., Shop Managers are the area criticality coordinators).
2.
Posted authorizations are not intended to incorporate all details of process operating documents upon which the authorization is based, nor can the postings be taken independent of the complete operations framework within which they exist.
3.
There are very stringent requirements on personnel qualification, detailed documentation of the operations, equipment and process qualification, and continuing manufacture by our customer.
This tight product quality control is an important factor in our nuclear criticality safety program.
8202220544 820205 PDR ADOCK 07000371 C
Mr. R. W. Starostecki January 21,1982 Uf1C Page Two Considering the examples stated in the Inspection Report:
Paracraoh 3.a.1) of Details - Residual Storace Applicable process documents to the collection and use of residuals well define the operations.
Personnel responsible are familiar with the meaning of " residuals" and their importance.
These residuals are used on a statistical basis in the establishment of fuel loading control in individual fillers.
We do not have any criticality control concerns with respect to the characterization of the material and the posted limite and shall maintain it.
Paracraph 3.a.2) of Details - Chemistry Laboratory 1
Items adding to the criticality safety which were not mentioned were:
1.
Addition of the neutron poison, cadmium nitrate solution, to all containers having uranium solutions.
See Section 3.4 of our NRC License and TID 7016, Rev.1, page 32.
2.
Wet filters and sludges were put in 55-gallon drums only after ISAF determination of the uranium content.
3.
Compliance with zone limits of 350 grams of uranium were acceptable in all cases.
4.
Chem Lab practice when starting a container of solutions of uranium is to attach a log sheet which requires the addition of the cadmium nitrate solution and the logging of uranium additions.
5.
Where no uranium content of a sample is known, the total weight is assumed to be U-235 in the log.
6.
In order to comply with the posted limits, running balances of the U-235 content is maintained for drums, except for those drums set aside to collect only slightly contaminated waste for burial.
These drums are inspected for uranium content prior to the shipment.
Existing postings shall be maintained until revised for other reasons.
At that time consideration shall be given to the recommended clarifications.
6 Mr. R. W. Starost:cki January 21, 1982 Page Three Paracraoh 3.a.3) a) & b) of Details - Outside Drum Storace and Doc Pen Spacing of the low activity waste drums from the buildings was considered in the evaluations and the current locations were not considered to affect criticality safety of any individual components in work areas adjacent to the Pens.
The low activity waste drums are well-safe in infinite numbers and arrangement per Nuclear Safety Guide TID 7016,10CFR 73 and other acceptable standards.
The " clear" area of.ily empty containers at the rear of Pen No. 2 was established for fire safety reasons only.
The drums which are stored outside in the. fenced Pens are double protected from any potential corrosion problem; the material inside the steel drums (with a wall thickness approximately 0.040" min.) are packaged in plastic containers or bags.
We consider that the storage containers are satisfac-tory for longer term storage without loss of integrity.
We are taking meaningful action to reduce the inventory of stored material and expect that container integrity will not be a problem during the time period it is to be stored., Periodic random visual inspection of the drums shall be performed.
Paracraph 3.a.4) of Details - Health Physics Basement Drum Storace Area Nuclear Materials Centrol personnel responsible for the area have, in the past, checked the T.I. of the area each time any drum was added or subtracted from the crea without recording the results of their checks. The suggestion to maintain a runnicq total has been incorporated.
The posted criticality control signs shall remain as stated.
Paracraph 3.a.5) of Details - Trailer Drum Storace Since Trailer No. 2 contained drums of items which were slightly contam-inated with enriched uranium on their surfaces and no measured value of uranium could be determined for the purpose of inventory listing, or would be so low as to not require an assigned value for inventory purposes (i.e., less than 0.5 g per drum), no SNM running inventory was maintained.
Since the conclusion of paragraph 3.a. of Details does not include the reference to SNM control in the Metallography Laboratory Sample Inspection Room, we assume that the inclusion of the subject in Item A. of Appendix A is erroneous and will consider it in Item B of Appendix A, as noted in the conclusion of paragraph 3.b.
of Details.
'Mr.
'R. W. St rost:cki January 21, 1982 Page Four Item B. of Appendix A and paracraph 3.b.1) & 2) of Details - Posted Limits 1.
Corrective Steps which have been taken and the Results Achieved The necessity for compliance to posted criticality signs and require-ments has been re-emphasized to Metallography Laboratory and Nuclear Materials Control personnel.
Improved control systems have been implemented in the Metallography Laboratory.
No drums in excess of posted limits are now stored in the outside Pens.
2.
Corrective Steps which will be taken to avoid further violations As stated above.
3.
Date when Full Compliance will be Achieved We are urrently in full compliance.
Item C. of Appendix A and paragraph 3.c. of Details - Fuel Cart Parkino 1.
Corrective Steps which have been taken and the Results Achieved Disciplinary action has been taken with respect to the employee responsible for the deficiency.
Awareness Training has been conducted.
2.
Corrective Steps which will be taken to avoid further violations Continue the actions of paragraph 1., above.
3.
Date when Full Compliance will be Achieved We are currently in full compliance.
Should further information be necessary, please contact us.
Sincerely, b
David E. Ganley b'
President and General Manager
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