ML20197B657
| ML20197B657 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 10/18/1978 |
| From: | Bowers C UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20197B624 | List: |
| References | |
| CEB-78-196, NUDOCS 7811080049 | |
| Download: ML20197B657 (12) | |
Text
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(j UnC>, UNITED NUCLEAR
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CORPORATION FutL RECOVERf CPERATION/ WOOD RIVER JUNCTION. R. 1. 02894 October 18, 1978 CEB 78-196 United States Nuclear Regulatory Commission Mr. Boyce H.
Grier, Director Region I 63 Park Avenue King of Prussia, PA
Dear Mr. Grier:
Receipt of your letter of October 16, 1978 " Physical Protection Program at UNC Fuel Recovery Operation (License No. SNM-777)" is acknowledged.
As always, UNC's policy remains one of full cooperation with NRC and of prompt correction of every deficiency.
However, with regard to recent allegations reported orally to UNC and repeated in the press, we have been presented with no evidence that a deficiency j
exists nor have we been officially notified of such a deficiency.
We trust you will appreciate that it would be unwise and irrespon-sible for us to react precipitously on the basis of informal com-munications from NRC and unverified press reports.
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Therefore, in lieu of specialized " corrective action", UNC intends to follow established procedures as outlined in Enclosure 1.
We believe these procedures to be adequate; regular procedures call for actions virtually identical to the first two requested actions contained in the enclosure to your letter.
UNC has not been presented with any evidence demonstrating tre necessity of the third requested action, and does not therefc.. consider the suggested modification of its existing procedures to be warranted.
To assure full public knowledge of both sides of this issue, we request that this reply and its enclosures be placed in the Public Document Room along with your letter and any other documentation regarding this matter.
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Sincerely, UNITED NUCLEAR CORPORATION l
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Bowers General Manager Fuel Recovery Operation j
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Enclosures ftYW C
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ENCLOSURE 1 4
i PHYSICAL PROTECTION PROGRAM AT UNC FUEL RECOVERY OPERATION l
l 1.
Firearms Requalification In compliance with UNC's standard practice, requali-
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fication in the use of firearms is conducted routinely as prescribed in Paragraph 5.3.3 of the Physical Plant Protection Plan and License Condition 9.3.35.
Accord-ingly, requalification had already been scheduled on j
September 18, 1978 to commence on October 16, 1978 as shown by Enclosure 2.
UNC will complete this requali-fication, under standard procedures, by November 16, 1978.
2.
Audit of Security Guards' Training Records UNC's standard practice includes an audit of security guards' training records approximately every three months.
A routine audit, which included personal verification by each guard. hat he had actually received all training indicated in hia records, was completed in September, 1978 and verified during the period October 7-10, 1978.
In view of the fact that UNC has been shown no evidence as to the inadequacy of this procedure, no special audit is warranted.
The next regularly scheduled audit of these records will take place on or about December 15, 1978.
Associated rec-ords, as is the case in all records, are available for NRC review at any time.
3.
Maintenance of Journal Records The journal of the security supervisors is maintained optionally by UNC, in excess of regulatory requirements and internal procedures.
All known records requirements are m>t by strict compliance with existing UNC procedures, as specified in Enclosure 3.
No evidence of the need to include the additional information requested by your let-ter o f October 16, 1978 has been presented to UNC; ac-cordingly, UNC does not consider the requested modification of its existing procedures to be warranted.
Even so, UNC is conridering formalizing the referenced journal, as shown in Enclosure 4.
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ENCLOSURE 2 3
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IN T E R.O F FIC E MEMO q~.77.;
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To D. M.
Schultz FRO 9 /18/78 47
- og7, FROM R.H. Brown FRO AT COPY 10 suus:T Weapons Training and Qualification 1.
Attachment "A" is a proposed schedule for completion of all qtalification firing.
As noted in my previous memo we have a total of 42 persons to qualify.
(6 shotgun only and 36 all weapons)
A.
OIC designated to provide management support for CPL Grenier.
It is not intended that the OIC be physically present at the range.
B.
RSO CPL Grenier is designated as Range Safety Officer for Monday to Thursday and Saturday.
On Friday, October 20, CPL Grenier shall qualify.
C.
On Friday October 20, CPL Hampton is designated as Range Safety Officer 2.
Sgt's and CPL's were assigned dated designated by Captain LaChappelles draft notice dated September 18.
3.
Security Specialists (SS) shall be designated by NAME by Captain LaChappelle in the numbers listed for each day (i.e., on Monday, October 16 he shall name 5 specialists to qualify).
4.
Saturday, October 21 is designated only to qualify Sgt Keegan and only those persons who must shoot a second time to qualify.
That is those persons who fired on their designated day but did not qualify.
This date is not a make-up for absenteeism.
5.
Attachment B is a proposal for satisfying the FAMILIARIZATION firing at night.
I could find no specific requirement for this to be accomplished within any time frame (i.e., semi-annual, annual, etc.) Since it is however a requirement we would get more benefit from alternating the qualification firing and familiarization firing semi-annually and we would still be expending the same amount of ammunition.
6.
Attachments 1 - 6 should be self-explanatory.
I suggest that attachments 3 (Night Practice Handgun) and 6 (Night Practice Rifle) be utilized without change.
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f 9/18/78 Weapons Training and Qualification 7.
Note Attachment 5.
I intend to establish a marksman rating for the handgun and shotgun.
(I.just didn't get to it tonight).
8.
As I finish this tonight I am leaving & copy with Captain LaChappelle to review also prior to our meeting 8 Attachments
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ENCLOSURE 3 1
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Date of Basic Procedure p
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COMPLIANCE DEPARTMENT June 7, 1978 PROCEDURE Date o5 his Revision run ucov n ommow Jswg Procedu'res 5
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G.
Rounds Schedule 1.
Rounds (patrols) take precedence over other guard activities.
2.
Patrol rounds shall include the entire facility area.
3.
Patrol rounds times are randomly selected and must be scheduled not more than two hours apart.
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The UNC Security Management Representative. should notify the guard force of the round approximately five minutes prior tovscheduled round time.
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Arms and Ammunition h
1.
UNC Security Management Representatives..must con-duct or supervise and verify the guards' qualifica-tion firing, 2.
UNC Security Management Representatives who issue ammunitionvmust document the issue and provide the documentation to the documentation coordinator.
3.
UNC Security Management Representatives must v
periodically inspect the contract guard force's, weapons to determine whether they are clean and in working order.
Shortcomings shall be reported to the local guard contractor management representa-tive.
'C 4.
UNC 'ecurity Management Representatives must collect all spent casings and return them to the storage locker.
VII.
Records Requirements Prer, red,?y:
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QQ[I COMPLIANCE DJE %T j W
June 7, 1978 l%-
Date of This Revision full IICOVilf OPitADON 4
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Ap.TheLocalGuardCon,tractorShiftSupervisor'sjournal (see Attachment 1I)) must be maintained for each shif t.
Items.wi-11 be numbered and times entered in numerical sequence.
Items to be entered in the Journal should consist of, but not be limited to, the following:
1.
Security checks, tours, inspections and results thereof, made by the contractor shift supervisor.
2.
Report of any unusual happenings and actions taken.
3.
Record of important phone calls (incoming and outgoing).
4.
Range firing times.
5.
Discharge of any weapons and reasons for discharge.
6.
Nuclear and non-nuclear al. arms and actions taken as a result.
7.
Problems with alarms systems and reasons for placing an alarm in the access mode after proper authorization has been granted.
8.
Problems with contract guard force personnel and actions taken.
9.
Turning in of check sheets, jcurnals, and completed '
paperwork to the UNC Security Management Represen-tative.
10.
Any other pertinent information of interest to the Manager, Compliance covering your tour of' duty.
11.
Administration of Post exams and in-service' training.
12.
Issuance of physical security seals.
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Date of Basic Procedure p
QQ[I COMPLIANCE DEPARTMENT June 7, 1978 l
PROCEDURE f This Pavision g
FUIL If COVitf OtlI ADON k '*5 ? ?," )
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Each day's genegat n
guard reports are to be
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gathered at 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br /> each morning for the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, collated as follows, and turned in to the Managc-, Compliance:
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Local Guard Contractor Shift Supervisor's journal for 0700,to 1500.
3.
Local Guard Contractor Shift Supervisor's journal for 1500-to 2300.
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4.
Local Guard Contractor Shift Supervisor's.4*. journal for 2300 to 0-700.
n 5.
Equipment repair requests (blue copy only).
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6.
Equipment check sheets in order (Post A, B, C,h for each shift.
7.
Alarm logs in order (Post A, B) for the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
8.
Key control receipts..,f,,)].,.
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Classified contain'r logs'must be initialed by the e
cleared security person conducting the daily checks and turned in to the documentation coordinator at the end of each month (see Attachment 2II).
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Rounds Log (in-Post-A},.' ' ' )/N ' '...
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Irregularity Reports (seeAttachment.III).
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ENCLOSURE 4 l
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Date of Basic Procedure QQQ COMPLIANCE DEPARTMENT June 7, 1978 lb.
PROCEDURE Date of This Revision October 18, 1978 FUEL RICOVitY OPERAfiON H.
Arms and Ammunition 1.
UNC Security Management Representatives shall con-duct or supervise and verify the 'uards' qualification g
firing.
2.
UNC Security Management Representatives who issue ammunition shall document the issue and provide the documentation to the documentation coordinator.
2.
UNC Security Management Representatives shall peri-odically inspect the contract guard force weapons to determine whether they are clean and in working order.
Shortcomings shall be reported to the local l
guard contractor management representative.
4.
UNC Security Management Representatives shall collect all spent casings and return them to the storage locker.
VII.
Records Requirements A.
A Security Management Representative's Journal (See Attachment I) shall be maintained for each shift.
Items to be entered in the journal should consist of, but not be limited to, the following:
1.
Guard assignments and patrols 2.
Accessed alarms 3.
Managers telephone calls 4.
Tests and scenarios 5.
Results of their inspection tour 6.
Unusual incidents and actions taken B.
A Local Guard Contractor Shift Supervisor's journal (See Attachment II) shall be maintained for each shift.
- I s Prepared By:
Reviewed By:
Page of Pages
Date of Basic Procedure l-QQQ COMPLIANCE DEPARTMENT June 7, 1978 PROCEDURE Date of This Revision e
evn ucovm ommes October 18, 1978 Items shall be numbered and times entered in numerical sequence.
Items to be entered in the Journal should consist of, but not be limited to the following:
1.
Security checks, tours, inspections and results thereof, made by the contractor shift supervisor.
2.
Report of any unusual happenings and actions taken.
3.
Record of important phone calls (incoming and out-going).
4.
Range firing times.
5.
Discharge of any weapons and reasons for discharge.
6.
Nuclear and non-nuclear alarms and actions taken as a result.
7.
Problems with alarm systems and reasons for placing an alarm in the access mode after proper authoriza-tion has been granted.
8.
Problems with contract guard force personnel and actions taken.
9.
Turning in of check sheet, journals, and completed paperwork to the UNC Security Management Represen-tative.
10.
Any other pertinent information of interest to the Manager, Compliance covering your tour of duty.
11.
Administration of Post exams and in-service training.
12.
- Issuance of physical security seals.
C.
Each day's generation of guard reports are to be gathered at 0007 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> each morning for the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, collated as follows, and turned in to the Manager, Compliance:
,/
Prepared By:
Reviewed By:
Page of Pages
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