ML20214J689
| ML20214J689 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 04/08/1987 |
| From: | Kaufman N UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20214J660 | List: |
| References | |
| NUDOCS 8705280160 | |
| Download: ML20214J689 (1) | |
Text
!
as yamy e UNC Naval Products unuNavalProducts wax _,
2031848-1511 April 8,1987 Thomas T. Martin, Director U.S. Nuclear Regulatory Commission Region I Division of Radiation Safety and Safeguards 631 Park Avenue King of Prussia, PA 19406 Gentlemen:
Subject:
USNRC Inspection 70-731/86-02
Reference:
Letter on Subject, T. T. Martin to N. C. Kaufman dated March 10,1987 This is in response to the referenced letter, which responded to our letter of July 2,1986, relative to the subject inspection. Based on the comments in your letter, UNC Naval Products acknowledges the item of non-compliance which was in question, and as noted in your letter, has already taken action to correct the deficiency. In the future, we will take necessary, timely action to amend our N!!C license for the addition of fuel handling facilities to our pla n t.
Very truly yours,
[l N. C. Kaufman Presidenp
/kjh cc: R. J. Gregg W. F. Kirk 1".
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$31 PARK AVENUE KING Ofr PRUSSIA, PENNSYLVANI A 19404 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 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 j
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 j
reason for that restriction was made clear to your staff by NRC's Office of Nuclear Material Safety and Safeguards at that time.
In any event, the reason for that restriction should be clear - the NRC can only authorize the use of SNM in facilities that it has reviewed and found suitable for the intended use of that SNM.
Additions to existing facilities, as in your case, are considered by the NRC to be new facilities, since they have not undergone NRC review for suitability.
In addition, it is immaterial that the drawing which depicts the existing facilities is in Part II of your license (Demonstration Section). The bases l
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 l
in Part I of your license (Criteria Section). Therefore, a subsequent revision to that drawing, to show additions to those existing facilities after license approval, is not sufficient information for NRC to assess the use to which l
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.
9(-
UNC Naval Products 2
MAR 101987 On the basis of the foregoing infonnation, 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 ccoperation with us is aprreciatec.
Sincerely, m
Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:
Public Document Room (PDR)
Nuclear Safety Information Center (NSIC)
State of Connecticut bec:
Region I Docket Room (w/ concurrences)
Management Assistant, DRMA Robert J. Bores, DRSS J. Roth, DRSS G. Bidinger, NHSS
Unc fmVAL PRODUCTO Dvision of UNC Resources Inc 67 Sandy Desert Road T elephone 203/848 1511 j g Uncasvdle Connecteut 06382-098' In Reply Please Refer 'ib:
NIS-86-7-2 July 2, 1986 Mr. 'Ihcanas T. Martin, Dirafa Division of Padiation Safety and Safeguards U.S. Nuclear Regulatory hiscion Region 1 631 Park Avenue King of Prussia, 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,
'Ihis letter is in response to the referenced letter, which presented the results of the subject inspection. As can be seen frcan the details in the attadm _-nt to this letter, we have taken gwyt., effective action to address the items of NRC concern presented in A;pendix A to the referenced 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 nonocenpliance, and feel that we have provided sound reasons for our disagreemer.t. We i
are, of course, prepared to die== any of those itens with you at your convenience.
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i very truly N. C.
Presi and General Manager NCyjup oc: R.J. Gregg W.F. Kirk Attachment hhkh
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4 ATDOttENI' TO IEITER, N. C. MAUFMAN TO T. MhRFIN, Dn3'ED JULY 2,1986 i
UNC RESRESE TO NRC INSPECTICH NO. 70-731/86-02 i
1.
Appardix A, Item A, ard DePalla of Inspectica paragraph 3.a-cri&4r=14tv Safety Postinas (Posted limits not present for a fuel element on a table).
A fuel element used far develogmient purposes was placed on a 4
table which was located in a red dat area. The DNR routing instruction was stamped at the operation as "cbserve Posted criticality Limits" (rather than the normally used element stang
" Criticality Limit: 1 STD S.Q. - 10 elements"). Since the table was not specifically rewyaized on any area posting, no " Posted criticality Limit" existed.
(1)
The wuactive s+=r= which have baan taken and the Results Achieved.
As noted in Details of Inspection paragraph 3.a, an NIS Authorizatice was i==nad 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 poi.m.had have been reinstructed with re
.t. to assuring that criticality safety instructierVlimits given en routing instructions are compatible to general area posting of NIS Criticality i
Authorizaticus.
1he operation, as performed, was safe, though not in t
compliance with requirements.
(2)
Cvuactive Star = Nhich Will Be Taken To Avoid Ibrtissr Violations.
As stated in pa %,..ais (1) above.
(3)
The Date When 7bil N 11ance Will Be Achieved.
We are currently in full cxmpliance.
2.
Appendix A, Item B, and Detalla of Ir.,=ction pa%,..nia 4.a Facility Mndifications (Use of new mi-ilian btildings without NRC approval).
During resolution of the NRC License issued in 1977, IMC moved the noted drawing E-740913-150 frca Part I (NRC approved) to Part II (Information to NRC) with NRC concurrence so that minor btilding changes could be made by UNC; with the need for NRC concurrence being determined by the gni_delines 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 pari.g4 1.2.2 was also added to clarify the restrictions that would apply to new or modified areas or ht41dLngs: "The possession or use of Stet in any area or btilding shall not be permitted unless it confonns to NRC requirumments (e.g. ruclear alanes)".
(1)
UNITED NUCLEAR Qay
/
C G G P C C A T I O C3 a
LICENSE:
SNM-368, DOCKET-NO.70-371 Revision NAVAL PRODUCTS DIVISION Approved JUN 0 4 1976 PART I CONDITIONS AND SPECIFICATIONS CHAPTER:
1 - GENERAL INFORMATION I'8"'d 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 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 shors 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 f a rms, and two hospitals.
Fort m,i le 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 Building B Building C 8
Building D Building M East Building Building S Building C is an office-type building and Building S is a warehouse.
- Specific operations in the other buildings are discussed in Chapter 10.
Basic operations performed at Montville are as described in Section 1.1 ias (2) 1-2
UCC UNITED MUCLEAR
- c o n P o a a T I O N LICENSE:
SNM-368, DOCKET-NO.70-371 Revision 2
l NAVAL PRODUCTS DIVISION 4A1 v a dLL PART I:
CONDITIONS AND SPECIFICATIONS APP # V'd
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CHAPTER:
1 - GENERAL IN FO RM ATION 2815'77 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 te the vest 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 shout 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.
The distance from the plant site to the esst 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 aqre State Park, is located about one m,ile 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 IIIBdilding A 3
Building B Building C Building D Building M East Building Building S Building C is an office-type building and Building S is a warehous..
Specific 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 Re q u i r e m e n t's ' ( e. g. nucle'ar alarms).
1-2 (3)
m ATDOBIENT TO IETIER, N. C. IUCPMAN TO 7
T. MARTIN, Dh21D JULY 2,1986 UNC RESPQ4SE TO NRC INSPECTICE NO. 70-731/86-02 We have harulled the additions of E-Plant Armax II and Annex III, IHiicuth Unit II, H-Biilding and R-Baild_ing on this basis in the past. In all cases, including the sost recent Nilding additions, the NRC has been notified in advance via changes in the Security Plan and the Materials control Plan (if appropriate).
j Our " facilities" are changed several times a year by the addition of new equipment, deletion of old equipment, additions of a=iliavy Wildings or similar actions. As long as we are working
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within estahlished criticality controls and without causing any significant envi m atal effects, we consider we are working with " existing facilities".
We understand that when significant new buildings or significant i
new processes are planned that could affect the environment or criticality limits, such change will be sukunitted to the NRC for evaluation. However, the auxiliary buildings added were small additions to existirg buildings, replacing paved areas adjacent to the buildings, and have Do effect on the site envimum. sat. 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===t to the words " existing facilities" under the background noted above.
In our current license (letter W. F. Kirk to W. T. Crow dated i
January 22,1986) page 9-15 and 9-16 described the==41immf buildings now being ocanmented upcm by NRC Region I. Our letter (W. F. Kirk to W. T. Crow dated Mazd121,1986) transmitted revised copies of Figure E-740913-150 for informaticmal purposes only.
In the future, we will more prtmptly transmit building additicm drawings to the NRC Uranium Fuel Licensing Group in additicm to the information sent to NRC Ramrity and Materials Safeguards Groups.
3.
Appendix A, Item C, and Details of Ir%-tion parap4a 5.a (3)
Stack Air hies (Possible effects cm sampling of line lengths, line materials and line bends).
'Ihe samplers are located so that sample results assure that applicable limits are D2t avnaadad for release of material to i
uiEnicted areas. The band radii of 3" - 6" and length of
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sample tubes used with tube diamater of 7/16"-3/8" 1.D, are not ocmsidered to significantly affect sampler results. Use of tygen j
tubing (3/8" 1.D) allows a visual determination to be made of possible particle deposition. No deposition has been r+aarved over long tima periods in the two sanple lines (decen &
sectioning area) using 10-12 foot lengths of heavy wall tygon.
Most of the tubing run is vertical.
(4)
1 ATDOBIENT TO IMTER, N. C. RAUFMAN TO T. MMEIN, DMED JUIX 2,1986 j
I2ic RESR3ISE TO NRC INSPECTIN No. 70-731/86-02 A Sampler head was placed nucts closer to the deoen duct sampling s
point in March 1986; no significant differences in results have been obtained date (i.e. in a 2 nonth ocupar the results were 0.16 1/3/86 to 3/14/86 and 0.12 l
3/14/86-6/10/86, excluding 3 days of cross-cantamination by j
hands of tactinician).As stated in the NRC ir==+iat ymm:p-ru 5.a (3), the sampling point of S-17 (Secticrting) is conearvatively placed qpstream of the filter.
The sample tube on the Health Physics Hood Stack is short (~ 8 ft) of 7/16" 1.D. Stainless steel with about 6 ft. of horizontal s
run and 2 ft. of vertical run, including 4 bands of about 6" radius. The contaminaticri level of the Health Physics hood processing is significantly lower than prmanaing===~ iated with sectioning or deoon ducts.
With us.m to the NRC comment "10 CFR 20.106(a) states, in part, that a licensee shall not p=ca==, use or transfer licensed I
material so as to release to an unrestricted area radioactive material in cumukations which exceed the limits specified in Appendix B, Table II of this part." NUREG 1112 (Envie.u _ dal
?--
- d. of UNC Naval Products) has evaluated airborne doses associated with this facility with the following results en page i
1 40 of the report (1978-82 Data):
i Dose to the easimally esposed individwei i
The 50 year nose coseitsents to the masisally encosea indiviewat living at the nearest residence (a25 m =est of the plant) f rom the ateborne ef fluents are i
shown in Table a 5 from the ingestion (161) and enhalatior (23) path.4,sThe total
- body dose of 0 013 milltres resulted prima)
Accccsimately 971 of the dose was attributatte to the 83* U released (fatte a 6)
The htgnent I
organ dose of C 17 =es to the bone and.as caused p"martly b, ingessten (761) of aseg gg7g3 The total body and organ Ocses resulting f rom the airborne releases are onl small f racttoa y a of the aoolicable **! *egulaticns of 500 milliremiyeas to the total body, J000 milltres/ year to the boaet. aad 1500 attitre*/yeae to t%e other organs, designated in or derived free 10 CFR Part 20 Similarly, the i
doses are well below the invironmental Protect 6en Agency ([Pa) standards for
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the utentum fuel cycle (40 CF A Part 190)
The total body dose is only about 0.0521. the bone cose about 0.685. and the lung dose about 0.00a% of the (PA standard of 25. m ire./, ear for the tot.i u dy and tnese organs.
Additionally. the total body dose of 0.013 stiltree is only about 0.012% of the becsground for the area (110 millirea/ year). and thus the contributton to the entsting background levels would be M gitg1ble.
Oose to the seputation within to km of the plant site The 1940 population distributton with an 80 ha (50-elle) radius of the plant tite is shown in Tables 3.4 and 3.5.
A total of 3,597.500 persons live within this area.
The population dose commitments free the routine annual releases of radionuclides (Table 4.a) are shown in table 4.7.
The total
- body dose to the population of 0.015 sen ree is only about 0.00000st of the population dose of 1.8 a 105 man-ree resulting free natural background radiation.
(5) i l
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ATDOMENT TO IEITER, N. C. EAUFMhN TO T. MhRTIN, DATED JUIX 2,1986 UNC RESENSE TO NRC INSPECTICN No. 70-731/86-02 We believe under the above cirt:umstances that any small survey errors that the NRC ocmsiders may be present (but whidt UNC has f.s Lated are not present) fall with the survey criteria of 10 CER 20.201 (b)(2):
"are reasonable under the ciramstances to evaluate the extent of radiaticut hazards that may be present".
4.
Appendix A, Itan D, and Details of Inspecticri par
,.da 5.g.
g Ocntaminated Shoe Covers (Shoe covers washed at our facilities were not checked under any required ye-- twe).
(1)
'Ihe CLn=ctive S+m= Nhich Have - i Taken And The "- lts Achieved On-site laundering of shoe covers has ceased and been returned to the off-site laundry ven$or (INS). 'Ihis 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 h=antation of ocntrols.
(2)
Cvn =ctive Sem w Which Will Be Taken To Avoid nirther Violations See above par i4 4 (1) g (3)
The Date When Full Ozoliance Will Be Achieved We are currently in full cxmpliance.
5.
Other While not required to respond to other inspection ocanments, we wish to make the following otsunents.
- a. Details of Inspecticx1 parg,.64 3.b. (2) Storaae nor Transfer Cart (0: 1 trol of a specified number of elements was difficult to determina)
The NIS authorization has been revised to "the capacity of the box" since a safe cross-section and ew1.vya. late spacings are maintained,
- b. Details of Inspection 3.b(3) Glovebox Enclosure Fire _
Safety (Use of flansnable solvent in air in open glovebox during cleancut)
(6)
ATDOBENT TO IATIER, N. C. IGNMAN TO T. MhRFIN, DGED JUIX 2,1986 UNC RESP 0 HSE TO NRC INSPEC.TICH No. 70-731/86-02 Ievywyf1 alcohol wipedowns are used to clean TF _M.
and w i d.s at several locations within our c
facilities. Measurements have been made that show the i
air concentrations encountered are well below the lower explosive limit. Men flammable materials are used, no-anoking limits apply and other sources of ignition are
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not present. She flammable liah used in such material i
cleaning operations are limited to small quantities. The
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1 use of non-flassable solvents present health hazards or product prohibitions.
I
- c. Details of Inspecticri 3.c Housekeepim Am=Gation of ocabustible materials in the areas noted (1) under Building M room air supply fan located i
adjacent to Shop II Manager's office (2) Building A i
I ha==mant, and (3) upper level of East Plant low bay area, has been mininized.
- d. Details of Inspection, parm.oih 7.a Uranium content of w
j the Facility Septic Field k
Revised figures 3,4, and 6 were prepared and transmitted i
to NRC Idoensing (W. Crow) on April 22, 1986.
Our vendor was requested to review all uranium data and identified a transcription error; 235 U had been reported as @ instead of pci. With this error 2
corrected, the 234/235 ratios are as expected.
The vendor has recountad the aanples and states that the isot@ ic data is considered correct. This revised information will be sent to NRC-NMSS by July 11, 1986.
1here does appear to be similar ratios between the total U value in micrograms per gram of sample and the total i
isotopic picoeuries per gram of sample. Natural uranium i
to which a ana11 amount of enriched uranium has been added would have such values, j
- e. Details of Inspection, pa @ u A 7.b Liquid E C, d e Analyses i
' Ccsposite retainer samples of rad wasta have been collected for particle size analysis.1he data is i
expected to be available in August. We will contime this investigation until data-suppceted ocnclusions are obtained. The information will be Mmmamart with the NRC i
inspector during future visits.
1 (7)
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