ML20043E950
| ML20043E950 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 06/11/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Andrews R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 9006140028 | |
| Download: ML20043E950 (2) | |
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I Docket No.70-371 a
.UNC, Incorporated UNC Naval' Products ATTN:
Mr. R. Bruce Andrews-President F
- 67. Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:
Subject:
Inspection No. 70-371/90-01 This refers to your letter dated May 18, 1990, in response to our letter dated April 20, 1990, Thank you' for informing us of the corrective and preventive actions documented-in your letter and for the clarifying comments made concerning several observations reported during the subject inspection. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely, i
Original Signed By:
Walter J. Pasciak-Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards.
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May 18, 1990-EMr.. 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 i
presented the results of NRC. Inspection 7-371/90-01.
-As-
-can be seen from the details in the attachment to this
. letter l we have taken prompt effective action to address the items of NRC concern presented.
In addition, wo enclosed cor.ments on several reported I
observations,-and on.one inspector follow-up item.
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PEPLY 'IO NRC ' *3PECTION 70-371/90-01 I.
APPENDIX A - NCTTICE OF VIOLATION NRC Cum ait:
Section 2.6, " Nuclear and Industrial Safety Controls:, Part 1 (Criteria) of your NRC-approved license a@lication dated March 28, 1977 states, in part, that operating supervision must assure that nuclear criticality safety and health physics control measures are followed as defined by or approved by Nuclear and Industrial Safety (NIS). Section 2.6.1.2, " Authorizations", states that
... Authorizations shall provide formal approval for work operations aM shall specify the applicable controls arx1 coniitions of the '
approval. All Sm approval prr=ning handliry and storage areas shall be posted with the Authorized criticality safety limits." NIS Criticality Control Authorization Number VII-C-4, Revision 5, dated l
September 25,1987, "Iow Activity Waste-Storage Shippire ard Receiving", i==nad 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."
'Ihe U-235 nust be distributed over
'the drum or inner container volume.
1 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 to assure that the drums contained equal to or less than 50 grams U-235 arul that the U-235 was distributed over the drum volume.
UNC ResDonse:
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'Ibe corrective steps which have been taken and the results p
achieved.
We have reevaluated our drum loading practices and since the start of hissionirg planning have been scanning all bags, packages, and other materials before they are placed into drums.
2.
Corrective art ps which will be taken to avoid further violations.
De-con operations are reviewed with NIS on an ongoing basis to assure ongoing canpliance with all requirements.
3.
'Ihe date when full emplian will be adileved.
We are now in full conpliance.
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NRC Ilcm. nCN 70-371/90-01 CIARIFICATION AND CuMxtA;n0NS:
6.1 Buildim Fire Safety:
First Paragraph:
Annex III and most of East Buildirg are protected by sprinkler systems. 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.
Secord Paragraph:
Annex III, with respect to the "noderate to heavy estible loading" is orutected 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 NELPIA.
" Sprinklers are not warranted due to rrse 4-stible emmncy and construction" per NELPIA.
Fourth Paragraph:
The tool room (crib) is in Annex I and has no roof or ceiling.
It is of two tier c.uduuction with sprinklers. Under current criticality principles applicable to the entire East Buildity ard Annexes I, II and III, the exclusion of water is not a requirement. At the time of construction, different internal criticality standards were in effect.
Fifth Paragraph:
Since "H" building is used for both corrosive ard flammable materials storage, it was determined that a concrete block ard 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 ard the presence of a sprinkler system, the c.uiuuction was considered acceptable by UNC ard ANI.
In addition:
1.
'Ihe quantity of flamable liquid is in ccmpliance with Table 4-4.2.7 for Unprotected Storage 2.
Explosion proof lights are installed in the flamable liquid bunkers 3.
An explosion proof exhaust system with ducting to within 6" of the floor is installed 4.
Containment stmps are installed in front cf each bunker.
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CLARIFICATICH AND umoux;nONS:
1 6.2 Picosss Fire Safety:
First Paragraph:
Hexane ws no lorryer in use at the time of the inspection.
6.3 Fire Protection Eaui m at:
Iast Paragraph:
'Ibe diesel fire punp had been flow tested periodically by ANI-UNC up to about 1985-86.
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NRC INsetx;n0N 70-371/90-01 "Insoector Follow-uo Itte 371/86-11-06:
Establish a program to assure that reviews and audits are conducted by persons.not a=aeriated with the operations. h inspector verified through a review of license records that the licensee has cortracted with persons not associated with the operations to conduct zuviews and audits in the areas of health physics and criticality control
-practices. liowever, the licensee has not initiated or ocupleted actions to have persons not associated with operations conducts reviews and/or audits of the emergency planning pgam.
Licensee actions have not been ocmpleted on this iten."
'Ihis was identified as item b on page 26 of that report.
'Ibe UNC re=ry.ise to this itan was subnitted on June 12, 1987 ard is quoted below;
" Provide for Audit of the RCP Imolemantation by Irhndent Personnel Auditing and inprovement of the UNC Emergency Manual (Part II of RCP) is best done by the participating organization. h UNC Emergency Manual has been consistently improved as a result of drills and reviews conducted by the emergency team nembership. We believe that tie team's review and self critique result in effective changes supported by members of the emergency team.
Unplanned exercises (false alarms) provide for very effective critique by individuals not having direct inplementation responsibility."
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