ML20043B933
| ML20043B933 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 05/18/1990 |
| From: | Andrews R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NIS-90-5-10, NUDOCS 9006010065 | |
| Download: ML20043B933 (5) | |
Text
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R. Bruce Andrews Prescent
===pe UNC Novel Products uunNavalProducts meg,gu._,
203/8481511 Telecopy 203/B48 0022 In Reply Please Refer to:
NIS-90-5-10 May 18, 1990 Mr. Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406 Subject NRC Inspection No. 70/371/90-01 of March 5-8, 1990
Reference:
Letter, R. R. Bellamy to R. Bruce Andrews, Inspection No. 70/371-90-01, dated 4/20/90
Dear Mr. Bellamy,
This letter is in response to the referenced letter which presented the results of NRC Inspection 7-371/90-01.
As can be seen from the details in the attachment to this letter, we have tuken prompt effective action to address the items of NRC concern presented.
In addition, we encloced comments on several reported observations, and on one inspector follow-up item.
V y t ul yo s,
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B ce Andrews President RBAtmag k
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REPLY TO NRC Item nON 70-371/90-01 I.
APPDIDIX A'- NCTTICE OF VIDIATION NRC Otanent:
Section 2.6, " Nuclear and Industrial Safety Controls:, Part 1 (Criteria) of your NRC-approved license application dated March 28, 1977 states, in p+.rt, that operating supervision uust assure that nuclear criticality safety and health ykiysics control measures are followed as defined by or approved by Nuclear and Industrial Safety-1 (NIS). Section 2.6.1.2, " Authorizations",' states that I
... Authorizations shall provide formal approval for work operations.
I and shall specify the applicable s kuls and conditions of the
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approval. All SNM approval sucessing harxiling and storage areas
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shall be posted with the Authorized criticality safety limits." NIS.
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Criticality Control Authorization Number VII-C-4, Revision 5, dated L
September 25,1987, "Iow Activity Waste-Storage Shippig and j
Receiving", issued by NIS persuant to Section 2.6.1.2 states that.the storage limit is "Any number of containers two high containing equal to or less than 50 grams U-235."
The U-235 mast be distributed'over the drum or inner container volume.
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Contrary to the above, on March 5 to 8,1990, low activity waste in 55-gallon drums was stored in the Waste Storage Area'of Building B-South in an unlimited two-high array,.and no measurements were made' i
to assure that the drums contained equal to or less than 50 grams U-235 and that the U-235 was distributed over the drum volume.
l UNC Resoonse:
1.
The corrective steps which have been taken and the results achieved.
We'have reevaluated our drum loading practices and since the start of the==issioning planning have been scanning all bags, packages, and other materials before they are placed into drums.
2.
Corrective steps which will be taken to avoid further violations.
De-ocn operations are reviewed with NIS on an ongoing basis to assure ongoing canpliance with all requirements.
3.
'Ibe date when full compliance will be achieved.
We are now in full ocatpliance..
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e NRC INSPECrfgf.y -371/90-01 CLARIFICATIQ4 AND CORRECTIONS:
6.1 Bu11dirs:: Fire Safety:
First Paragraph:
Annex III and most of East Building are protected by sprinkler cystens. Only the high bay area ard Annex I (except for the tool crib) and II are not covered by sprinkler protection in the East plant area.
Second Paragraph:
Annex III, with respect to the " moderate to heavy <v=h =tible 1
loadirg" is orotected by sprinkler systems.
'Ihird Paragraph:
At the time of installation, the acceptability of the maslite panels and ceiling were investigated and considered acceptable for the application by UNC and NEIFIA. " Sprinklers are not r
warranted due to r&O 4-Latible emncy and w=koction" per' NELPIA.
Fourth Paragraph:
h tool rom (crib) is in Annex I and has no roof or oeiling.
It is of two tier c.un kuction with sprinklers.- Under current criticality principles applicable to the entire East Buildirg ard Annexes I, II and III, the exclusion of water is.not a requirement. At the time of c.== b uction, different internal 3
criticality s+ N were in effect.
L Fifth Paragraph:
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Since "H" building is used for both corrosive and flamable materials storage, it was determined that a w n d.e block and non-corrosive (wooden) structure would be more appropriate than steel which would be subject to corrosion. Under the conditions of a high parapet (> 6 ft.) of concrete block in the adjacent A building wall and the presence of a sprinkler system, the' w=koction was considered acceptable by UNC ard ANI. In addition:
1.
h quantity of flamablo liquid is in coupliance with Table I
4-4.2.7 for Unprotected Storage 2.
Explosion proof lights are installed in the flamable liquid.
bunkers i
I 3.
An explosion proof exhaust system with ducting to within 6" of the floor is installed 4.
Containment surps are installed in front of each bunker.
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.o NRC INsiu;nON 70-371/90 l CMRIFICATIO4 AND u.aoeL'nONS:
6.2 Preciais Fire Safety:
I i'I First Paragraph:
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Hexane was no larvjer in use at the time of the inspection.
l 6.3 Eire Protection Eauhnant:
i last Paragraph:
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'Ibe diesel fire pep had been flw tested periodically by ANI-UNC up to about 1985-86.
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NRC INsetLTiOf 70-371/90-01 "Insoector Ebliow-up Item 371/86-11-06:
Establish a program to assure that reviews and audits.are conducted by :
persons not amam lated with the operaticns. 'Ihe inspector verified' l
through a review of license records that the licensee has contracted-with persons not associated with the operations to condu d reviews and audits in the areas of health physics and criticality control practices. However,' the licensee has not initiated or coupleted actions to have persons not associated with cperations corrtucts reviews and/or audits of the e -r g q planning s vig -u.
Licensee actions have not been ocupleted on this item."
'Ihis was identified as item b on page 26 of that report.
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'Ibe UNC response to this itm was submitted on June 12, 1987 and is quoted below;
-1 "hyvide for Audit of the RCP Inolamantation by Irh+rainit Personnel.
J Auditing and inprovement of the UNC Emergency Manual (Part II of.RCP) is best done by the participating organization. 'Ibe UNC Emergency Manual has been consistently inproved as a result of drills and reviews ocW+ai by the emergency team membership. We believe that:
the team's review and self. critique result in effective' changes supported by members of the emergency team.
Unplanned exercises (false alarms) pruvide for very offective critique by individuals not having direct inplementation responsibility."
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