ML20207S298

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 70-0371/86-02.Specific Restriction Added Re Unauthorized Use of SNM

ML20207S298
Person / Time
Site:	07000371
Issue date:	03/10/1987
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Kaufman N UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
Shared Package
ML20207S299	List: ML20207S298 ML20207S317
References
NUDOCS 8703190250
Download: ML20207S298 (2)

Text

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MAR 101987 Docket No.-70-371 UNC, Incorporated UNC Naval Products Division ATTN: Mr. N. C. Kaufman President and General Manager 67 Sandy Desert Road j Uncasville, Connecticut 06382 Gentlemen:

Subject:

, Inspection No. 70-371/86-02 Your letter dated July 2,1986, in response to our letter dated June 2,1986, provided corrective action for the violations identified during the subject inspection and expressed your disagreement with one of the violations.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of your licensed program.

With regard to Appendix A, Item 8, we have evaluated your response, taking into consideration the additional information you provided as a basis for refuting the violation. For the following reasons, we have concluded that the violation is correct as cited. Condition 9 of your current license, issued on February 2, 1985, authorizes use of special nuclear materials in those facilities that existed when the license was approved by the NRC. The specific restriction on use in existing facilities was added to your license as a result of discussions held prior to the approval of that license in 1985 and we understand that the reason for that restriction was made clear to your staff by NRC's Office of

l. Nuclear Material Safety and Safeguards at that time. In any event, the reason l for that restriction should be clear - the NRC can only authorize the use of l SNM in facilities that it has reviewed and found suitable for the intended use '

of that SNM.

l Additions to existing facilities, as in your case, are considered by the NRC l to be new facilities, since they have not undergone NRC review for suitability.

l In addition, it is immaterial that the drawing which depicts the existing I

facilities is in Part II of your license (Demonstration Section). The bases

-for NRC's approval of your license in 1985 included only the facilities de-picted on that drawing, at that time, as indicated by reference to that drawing in Part I of your license (Criteria Section). Therefore, a subsequent revision to that drawing, to show additions to those existing facilities af ter license approval, is not sufficient information for NRC to assess the use to which those additions will be put, i.e., that SNM will be used/ stored therein. It is for this reason that providing a revised drawing to NRC for information only, as you did, cannot be considered adequate to meet your license condition.

OFFICIAL RECORD COPY RL UNC NAV 86 0001.0.0 i 01/28/87 0703190250 870310 PDR c

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l UNC Naval Products 2 MAR 101987 I

On the basis of the foregoing information, we concluded that the violation was correct as cited. However, we note that you have taken steps to correct this violation by letter to the NRC's Office of Nuclear Material Safety and Safeguards dated December 8,1986, that requested your NRC license be amended to incorporate those facilities that did not exist on February 27, 1985, but in which SNM is now being used. The license amendment which resolves this matter was issued on February 9,1987.

In order to meet your obligation pursuant to 10 CFR 2.201, please provide this office in writing, within 30 days, those actions you will take to prevent recurrence of this violation.

The response requested above is not subject to clearance by the office of Management and Budget under the Paperwork Reduction Act of 1980, PL 96-511.

Your cooperation with us is appreciated.

Sincerely, Original Signed ?y:

Thomas T. Martin Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:

PublicDocumentRoom(PDR)

Nuclear Safety Information Center (NSIC)

State of Connecticut bec:

RegionIDocketRoom(w/ concurrences)

Management Assistant, DRMA Robert J. Bores, DRSS J. Roth, DRSS G. Bidinger, NMSS

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