ML20207S317
| ML20207S317 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 07/02/1986 |
| From: | Kaufman N UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20207S299 | List: |
| References | |
| NIS-86-7-2, NUDOCS 8703190268 | |
| Download: ML20207S317 (8) | |
Text
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UnC'nRVAL PRODUCTS Dmsion of UNC Resources. Inc 67 Sandy Desert Road Te'ephone 203/848-1511 g
Uncasvdle Connecticut 06382-0981 In Reply Please Refer 'Ib:
NIS-86-7-2 July 2, 1986 Mr. Thcmas T. Martin, Director Division of Radiation Safety and Safeguartis U.S. Nuclear Regulatory h ianion Region 1 631 Park Avenue King of Pnnsia, Pennsylvania 19406
Subject:
USNRC Inspection No. 70-371/86-02 Ref:
letter on Subject, T. T. Martin to G. O. Amy dated June 2, 1986
+
Dear Sir,
This letter is in response to the refereic.si letter, which presented the results of the subject inspection. As can be seen fran the details in the attachment to this letter, we have taken p1wyL, effective action to address the items of NRC concern presented in Appendix A to the refemc.si letter. In addition, we have specifically addressed additional items which were covered in the body of the inspection report. As reviewed in the attachment to this letter, we do not concur in all of the items identified by the NRC as items of noncompliance, and feel that we have provided sound reasons for our disagreement. We are, of course, prepared to discuss any of those items with you at your convenience.
Very truly N. C.
4AN Presid and General Manager NClyjup oc: R.J. Gregg W.F. Kirk Attachment 8703190268 870310 PDR ADOCK 07000371 C
PDR OSSPO551
1l.
ATIAOMENT TO IEITER, N. C. KAUEMAN TO
.~
T. MARI'IN, DATED JUIX 2,1986 UNC RESPQ4SE TO NRC INSPECTICH NO. 70-731/86-02 l
1.
Appendix A, Item A, and Details of Inspection paragraph 3.a-Criticality Safety Postinas (Posted limits not present for a fuel element on a table).
A fuel elenent used for develvp-ad. pulpaises was placed on a table which was located in a red dat area. The DWR routing instruction was s'M at the operation as "nhaarve Posted Criticality Limits" (rather than the normally used element stang
" Criticality Limit: 1 STD S.Q. - 10 elements"). Since the table was not specifically recognized on any area posting, no " Posted Criticality Limit" existed.
(1)
The cuitective s+== which have Mart taken and the Ramits Achieved.
As noted in Details of Inspection par idi 3.a, an NIS m
Authorization was i=d to recognize the table.
In addition, since criticality safety limits can be set forth by area postings or on NIS approved routing instructions, NIS and Engineering personnel have been reinstructed with I-;+1 to assuring that criticality safety instructicxg/ limits given on routing instructions are ocmpatible to general area posting of NIS Criticality Authorizations.
The operation, as performed, was safe, though not in ocupliance with requitamuds.
(2)
Cuttactive Steos Which Will Be Taken Tb Avoid R1rther Violations.
As stated in par.p.Si (1) above.
(3)
The Date When M111 (Y=nliance Will Be Acitieved.
We are currently in full ocupliance.
2.
Appendix A, Item B, and DeMila of Inspection paragraph 4.a Facility Mod.ifications (Use of new awiliary buildings without NRC approval).
During resolution of the NRC License i=d in 1977, UNC moved the noted drawing E-740913-150 frtun Part I (NRC approved) to Part II (Information to NRC) with NRC concurrence so that minor building changes could be made by UNC; with the need for NRC concurrence being deNmined by the guidelines stated below.
Attached are license pages showing that change (i.e. page 1-2 dated June 4, 1976 and May 3, 1977). The last sentence of l
s par i411.2.2 was also aMari to clarify the restrictions that w
would apply to new or wriified areas or buildings: "The pma-alon or use of SNM in any area or building shall not be permitted unless it conforms to NRC requit=s==its (e.g. nuclear alarms)".
1 (1)
UNITED NUCLEAR Qay
/
C C Q P O Q A T l C N a
LICENSE:
SNM-368, DOCKET NO.70-371 Revision NAVAL PRODUCTS DIVISION PProved JUN 0 4 1976 PART I CONDITIONS AND SPECIFICATIONS CHAPTER:
1 - GENERAL INFORMATION SECTION:
1.2 SITE AND FACILITIES Supersedes
.l. 2 SITE AND FACILITIES l.2.1 The Site The 231 acre UNC site is located in the northeast corner of the town of Montville.
It is bounded on the east by the Thames River, on the north by Trading Cove, and on the west and south by privately owned land.
The nearest site boundary is to the north, at a distance of about 650 feet from the effluent stacks.
The nearest residents is about 1400 feet to the west.
There are about 300 people living to the west and south within a half mile of the plant.
The total population of Montville in 1970 was 15,662.
The city of Norwich, which lies to the north of site, had a population of about 40,000 in 1970.
The most densely populated area of the city is about two to three miles from the plant.
The nearest occupied buildings in Norwich.are about 2200 feet from the plant.
The city of New London, with a 1970 population of about 32,000 is about 10 miles to.the south.
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The distance from the plant site to the east shore of the Thames River is about 3300 feet.
The area within a one mile
' radius of the plant site includes woodlands, residences, light businesses, a few chicken farms, and two hospitals.
Fort m,ile to Shantock, a 183 acre State Park, is located about one the south.
1.2.2 The Facilities Operations conducted at the Montville site are located in buildings designated as follows (See Drawing No. E-740913-150).
Building A l'
Building B Building C i
Building D Building M East Building Building S Building C is an office-type building and Building S is a warehouse.
Specifi.c operations in the other buildings are discussed in Chapter 10.
Basic operations performed at Montville are as described in Section 1.1 (2) 1-2
l UGC UNITED NUCLEAR c O R P O R A T I O N LICENSE:
SNM-368, DOCKET NO.70-371 Revision 2
l NAVAL PRODUCTS DIVISION Appe ved g g((
PART I:
CONDITIONS AND SPECIFICATIONS
~
GENERAL INFORMATION f"'
CHAPTER:
1 SECTION:
1.2 SITE AND FACILITIES Supersedes
.l. 2 SITE AND FACILITIES 1.2.1 The Site The 231 acre UNC site is located in the northeast corner of the town of Montville.
It is bounded on the east by the Thames River, on the north by Trading Cove, and on the west and south by privately owned land.
The nearest site boundary is to the north, at a distance of about 650 feet from the effluent stacks.
The nearest residence is about 1400 feet to the west.
There are about 300 people living tc the west and south within a half mile of the plant.
The total population of Montville in 1970 was 15,662.
The city of Norwich, which lies to the north of the site, had a population of about 40,000 in 1970.
The most densely populated area of the city is about two to three miles from the plant.
The nearest occupied buildings in Norwich.are about 2200 feet from the plant.
The city of New London, 'with a 1970 population of
.about 32,000 is about 10 miles tc.the south.
The distance from the plant site to the east shore of the Thames River is about 3300 feet.
The area within a one mile
' radius of the plant site includes woodlands, residences, light businesses, a few chicken farms, and two hospitals.
Fort Shantock, a 183 acre State Park, is located about one mile to the south.
1.2/2 The Facilities Operations conducted at the Montville site are located in buildings designated as follows (See Drawing No. E-740913-150 in Part IIdu. 1 ding A i
1 Building B Building C r
Building D Building M East Building Building S B u ild i-n g C is an office-type building and Building S is a warehous. *Specifi.c operations in the other buildings are discussed in Chapter 10.
Basic operations performed at Montville are as described in Section 1.3.
The possession or use of SNM in any area or building shall not be permitted unless it g
. conforms to NRC Require me n t's '( e. g. nucle'ar alarms).
1-2 (3)
ATDOBENI TO IEITER, N. C. IGUFMAN TO T. MARTIN, DNIED JULY 2,1986 UNC RESEQ3SE TO NRC INSPECIICN NO. 70-731/86-02 We have handled the additions of E-Plant Annex II and Annex III, M Unit II, H-Billdiilg and R-Building on this basis in the past. In all naaaa, including the most recent bi41 ding additions, the NRC has been notified in advance via changes in the Security Plan and the Materials Control Plan (if appropriate).
Our " facilities" are dianged several rimaa a year by the addition of new agii,==nt, deletion of old aqiirmant, additions of ativiliary buildings or similar actions. As Icsig as we are working within estahlished criticality controls and without causing any significant envi& m -mL21 effects, we consider we are working with " existing facilities".
We understand that when significant new buildings or significant new promaaaaa are planned that could affect the enviraseit or criticality limits, such change will be sutznitted to the NRC for evaluation. However, the auxiliary buildings added were small additions to existing buildings, replacing paved areas adjacent to the buildings, and have Dg effect on the site envitemait. The activities performed in these additions were already being performed in the structures to which they were attached.
We do not agree that a violation of our license has occurred with r-;+1 to the words " existing facilities" under the background noted above.
In our current license (Istter W. F. Kirk to W. T. Cruw dated l
January 22,1986) page 9-15 and 9-16 daaeribed the ativilia7 buildings now being 6.
ied upon by NRC Region I. Our letter (W. F. Kirk to W. T. Crow dated Mardi 21, 1986) transmitted revised copies of Figure E-740913-150 for informational purposes only.
l In the future, we will more prtxnptly transmit building addition drawings to the NRC Uranium Fuel Licensing Group in addition to the information sent to NRC Security and Materials Safeguards Groups.
Appendix A, Item C, and Detalla of Inspection pars.p.as 5.a (3) 3.
Stack Air Ramlag (Pcssible effects en sanpling of line lengths, l
line materials and line bends).
i The sanplers are located so that sanple results aamive that applicable limits are Dgt avnaadad for release of material to um a h icted areas. The bend radii of 3" - 6" and length of sanple *nham used with tube diamater of 7/16"-3/8" 1.D, are not i
considered to significantly affect sanpler results. Use of tygon i
tubing (3/8" 1.D) allows a visual determination to be made of I
possible particle deposition. No deposition has been observed over long time periods in the two sanple lines (deocn &
=achir=11ng area) using 10-12 foot lengths of heavy wall tygon.
Most of the tubing run is vertical.
(4)
ATDOBENf TO IEITER, N. C. RAUFMAN TO T. MARITN, DATED JUIX 2,1986 INC RESPCHSE TO NRC INSPECTICE NO. 70-731/86-02 A Sanpler head was placed nucil closer to the decan duct sanpling point in Hardi.1986; no significant differences in results have been obt:ained date (i.e. in a 2 month ocupar the results were 0.16 1/3/86 to 3/14/86 and 0.12 3/14/86-6/10/86, excluding 3 days of cross-contamination by hands of technician).As stated in the NRC ir& don parcepc@
5.a (3), the sanplinJ point of S-17 (Sectioning) is conservatively placed upstream of the filter.
The sanple tube on the Health Riysics Hood Stack is short (~ 8 ft) of 7/16" 1.D. Stainless steel with about 6 ft. of horizontal run and 2 ft. of vertical run, including 4 bends of about 6" radius. The contamination level of the Health Ihysics hood processing is significantly lower than s ucessing associated with sectioning or fhn ducts.
With respect to the NRC comment "10 tTR 20.106(a) states, in part, that a licensee shall not p maa==, use or transfer licensed material so as to release to an tuuu=Lcicted area radioactive material in concentrations which eyrw r1 the limits specified in Appendix B, Table II of this part." NUREG 1112 (Enviwimsuial Awamant of UNC Naval Products) has evaluated airborne rkww associated with this facility with the following results on page 40 of the report (1978-82 Data):
Dose to the manically esposed individual The 50 year dose cormitments to the mastmally exposeo individwal livirg at the nearest residence (425 m west of the plant) f rom the aircorne ef fluents are shown in Table 4.5.
The total-body dose of 0 013 millirem resulted primarily f rom the ingestion (76%) and inhalation (22%) patn.ays Approsisately 97% of the dose was attributable to the sae.U released (f able 4 6)
The hignest organ dose of 0.17 -as to the bone and was caused primarily e3 ingestion (76%)
of 23eV (97%).
1
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The total-body and organ doses resulting f rom the airborne releases are only a small fraction of the aoolicable pot regulations of $00 milliremiyear to the total body; J000 millires/ year to the boaes; aad 1500 millire*/yeae to t'ie other organs, designated in or derived from 10 CFR Part 20.
Similarly, the doses are well below the invironmental Protection Agency (EPA) standards for the uranium fuel cycle (40 CFR part 190). The total-body done is only about 0.052% tre bone dose about 0.68%, and the lung dose about 0 004% of the EPA standard of 25 millfrem/ year for the total body and these organs.
Additionally, the total-body dose of 0.013 milliren is only about 0.012% of the background for the area (110 millires/ year), and thus the contribution to the existing background levels would be negligible.
Oose to the population within 80 km of the plant site The 1980 population distribution with an 80-km (50-mile) radius of the plant site is shown in Tables 3.4 and 3.5.
A total of 3,597.500 persons live within this area. The population dose commitments from the routine annual releases of radionuclides (Table 4.4) are shown in Table 4.7.
The total-body dose to the population of 0.015 man-rem is only about 0.000008% of the population dose of 1.8 m 105 man-rem resulting from natural background radiation.
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l (5) l I
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ATDGMENT TO IEITER, N. C. KAUENAN TO T. MARTIN, DATED JULY 2,1986 e
UNC RESPCHSE TO NRC INSPECTION NO. 70-731/86-02 We believe under the above circumstances that any small' survey errors that the NRC corsiders may be present (but which UNC has degg= Lated are not present) fall with the survey criteria of 10 CFR 20.201 (b)(2):
"are reasonable under the circumstances to evaluate the extent of radiation hazards that may be present".
Appendix A, Item D, and Detailm of Inspection paragraph 5.g.
4.
Contaminated Shoe Covers (Shoe covers washed at our facilities were not checked under any required procedure).
(1)
The Corrective Stam Which Have han Taken And The Results Achieved on-site laundering of shoe covers has ceased and been returned to the off-site laundry vendor (INS). This vendor performs alpha and beta-gamma monitoring of all laundered items as specified in the purchase order prior to returning them to UNC. Operating Personnel have been reinstructed on the need for NIS review, approval and documentation of controls.
(2)
Corrective Steos Which Will Be Taken To Avoid Further Violations l
See above paragraph 4 (1)
I (3)
'Ihe Date When Full Otznoliance Will Be Achieved l
We are currently in full ocupliance.
l S.* Other While not required to respcud to other inspdon wusits, we l
wish to make the following h melt.s.
l
- a. Details of Inspection paragraph 3.b. (2) Storace Box Transfer Cart (Centrol of a specified number of elements j
was difficult to determine)
The NIS authorization has been revised to "the capacity of the box" since a safe cross-section and appropriate l
spacings are maintained.
1
}
- b. Details of Inspection 3.b(3) Glovebox Enclosure Fire Safety (Use of flammable solvent in air in open glovebox l
during cleanout)
(6) i
t ATDO9ENI' 'IO IEIT!!R, N. C. IOGMAN 'IO T. MARTIN, DATED JUIX 2,1986 i
UNC RESR2iSE 'IO NRC INSPECI'ICN NO. 70-731/86-02 Isopropyl alcohol wipedowns are used to clean agiir= ant and u w =4s at several locations within our facilities. Measurements have been made that show the j
air concentrations encountered are well below the lower explosive limit. Een flansnable materials are used, no-smoking limits apply and other sources of ignition are not in.=s a.. 'Iha flannable liquids used in such material cleaning operations are limited to amm11 quantities. 'Ihe use of non-flannable solvents present health hazards or product prohibitions.
- c. Details of Inspection 3.c Housekeeoim kv=ilation of emhiatible materials in the areas noted (1) under Billait1g M room air supply fan located adjacent to Shop II Manager's office (2) Billdirig A haaamant, and (3) upper level of East Plant low bay area, has been minimized.
- d. Details of Inspection, paragraph 7.a Uranium Content of l
the Facility Septic Field Revised figures 3,4, and 6 were prepared and i.carsuitted to NRC Licensing (W. Crow) on April 22, 1986.
Our vendor was requested to review all uranium data and identified a 1.sarm u iption error; 235 U had been reported as dpa instead of pci. With this error j_
uu.& acted, the 234/235 ratios are as expected.
'Iha vendor has recounted the sangles and states that the isotopic data is considered uu.i ct. 'Ihis revised information will be sent to NRC-NES by July 11, 1986.
i
'Ihere does appear to be similar ratios between the total U value in mi% sa - per gram of sample and the total isotopic pirw,iries. per gram of sanple. Natural uranium to which a small amount of enriched uranium has been aMad would have such values,
- e. Debilm of Inspection, parimp. api 7.b Liould Radwaste Analyses Otmposite retainer sanples of rad waste have been collected for particle size analysis. 'Ihe data is expected to be available in August. We will continue this investigation until data-supported conclusions are obtained. 'Ihe information will be diarmaad with the NRC inspector during future visits.
1 (7) l
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