ML20195J782

Discusses Insp Rept 70-0371/88-02 on 880219-0318 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20195J782
Person / Time
Site:	07000371
Issue date:	06/13/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kaufman N UNC, INC. (FORMERLY UNC RESOURCES, INC.)
Shared Package
ML20195J786	List: ML20195J782 ML20195J822
References
EA-88-094, EA-88-94, NUDOCS 8806290235
Download: ML20195J782 (3)

Text

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t 13 JUN 1988 Docket No.70-371 License No. SNM-368 EA 88-94 UNC Naval Products, Inc.

Division of UNC:Resoc: Inc.

ATTN: Mr. N. Kaufman President and General Manager 67 Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:

SUBJECT:

-NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NO. 70-371/88-02)

This refers to the NRC inspection conducted on February 19 - March 18, 1988 at your facility in Uncasville, Connecticut of activities authorized by Special Nuclear Materials-License No. SNM-368. The report of the inspection was forwarded to you on April 7, 1988. During the inspection, seven violations of NRC requirements were identified, including multiple examples of some of these violations. On April 25, 1988, an enforcement conference was conducted with you and members of your staff to discuss the violations, their causes, and your corrective actions.

The violations, which are described ir the enclosed Notice, include, but are not limited to: (1) failure, on a number of occasions, to adequately measure airborne activity and adequately survey the radiological conditions at your facility; (2) failure to adequately control the amount and direction of ventilation flow; (3) a lack of adequate procedures for implementing the radia-tion safety program; and (4) failure to perform adequate audits of the radiation safety program. These violations, when considered collectively, are indicative of a lack of management and supervisory oversight of the health physics program, and they created a substantial potential for workers' intake of radioactive material in an amount in excess of the regulatory limit.

The NRC is particularly concerned that procedures were not clearly and adequately l established to implement all applicable requirements set forth in 10 CFR Part 20.

Given the extent of management's inattention to these activities, a rigorous and thorough assessment by you of all aspects of your manufacturing operation is needed to determine the adequacy of this program. This should include an eval-uation of the responsibilities and authorities of organizational personnel with respect to the health physics program and, the adequacy of the health physics l oversight to ensure all activities are conducted safely and in accordance with l the terms of your license and all the applicable requirements of 10 CFR Part 20.

l CERTIFIED MAIL (i RETURN RECEIPT REQUESTED j OFFICIAL RECORD COPY CP PKG UNITED NUCLEAR REV 1 - 1 l

l 8806290235 080613 05/09/00 1

! PDR ADOCK 07000371 ,

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• UNC Naval Products, Inc. 2 To emphasize this need, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Regional

-Operations, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Twelve Thousand Five Hundred Dollars

($12,500) for the violations described in the enclosed Notice. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1988) (Enforcement Policy), the viclations have been collectively categorized in the aggregate as a Severity Level III problem to focus on the underlying NRC concern, namely, a lack of adequate management and supervisory oversight of the health physics program. The base civil penalty for a Severity Level III violation or problem is $12,500. The escalation and mitigation factors in the Enforcement Policy were considered and no adjustment has been deemed appropriate because (1) the violations were identified by the NRC; (2) the corrective actions, as described at the enforcement conference, were not considered unusually prorpt and extensive in that they were not specifically defined; and (3) although only one violation of Health Physics requirements was previously identified by the NRC during Health Physics inspections since January 1986, the overall enforcement history since that time in other related areas involves several more violations.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. Further, you should describe in detail your plans _for (1) performing a assessment of your radiation protection program, particularly, with regard to procedures, training and improvements in supervisory oversight of radiological control activities; and (2) instituting appropriate correctiva measures to upgrade the program based on the assessment findings. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.

Sincerely, OrfC17al Signed By Lill.Y. T. CSSEI.

William T. Russell Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty 0FFICIAL RECORD COPY CP PKG UNITED NUCLEAR REV 1 -

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Public Document _ Room (PDR)

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. Region I Docket Room (w/ concurrences)

Management Assistant, DRMA (w/o encl)

Robert J. Bores, DRSS

.J. Roth,.DRSS t G. Bidinger,~ NMSS DRP Section Chief.

SECY

'J. Taylor, DED0 J' Lieberman, 0E E. Flack, CE W. Russell,'RI H. Thompson, NMSS

-D. Holody, RI L. Chandler, 0GC T. Martin, DEDs0 Enforcement Directors, RII-RIII Enforcement Officers, RIV-RV F.-Ingram, PA J. Bradburne, CA E. Jordan, AE00 B. Hayes, 01 S. Connelly, 0IA D. Nussbaumer, SLITP OE Files (3 copies + ltr hd)

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