ML20214V958

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Submits Info Re Auxiliary Bldgs Added to Montville Facilities,In Response to NRC Re Insp Rept 70-0371/86-02 & Amend 8 .No Negative Environ Impact from Bldgs & 860702 Commitments Unchanged
ML20214V958
Person / Time
Site: 07000371
Issue date: 11/06/1986
From: Gregg R
UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
To: Crow W
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
27600, NIS-86-11-4, NUDOCS 8612100024
Download: ML20214V958 (6)


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cc: W. F. KIRVs UnC nRVAL PRODUCTS 74-3 7/

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Dnnsion of UNC Incorporated 67 Sandy Desert Road Telephone 203/8481511 E**

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In Reply Please Refer To:

NIS-86-11-4 8

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November 6, 1986 H,

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s.tW%@goM Mr. W. T.

Crow, Acting Chief d fqf g' g U.

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Nuclear Regulatory Commission 9

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Division of Fuel Cycle & Material Safety D1 ' '

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Subject:

Docket 70-371 SNM License #368

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Ref:

(1) Amendment #8 dated September 27, 1986 (2) Letter W.

F. Kirk to W. T.

Crow dated August 26, 1986 (3) Letter N.

C.

Kaufman to T. T. Martin (Region I) on NRC Inspection #70-371/86-02 dated July 2, 1986 (4) Letter T. T. Martin to G.

O. Amy on NRC Inspection 70-371/86-02 dated June 2, 1986 (5) Letter W. F. Kirk to W. T. Crow on license renewal dated January 22, 1986 (6) Letter W.

F. Kirk to W. T.

Crow dated March 21, 1986 (7) Letter R. Gigliotti to W. B.

Brown dated June 28, 1985

Dear Sir:

Amendment #8 included an additional item which concerned facilities which were constructed in 1985-86 and was one of the subjects of exchange of Ref. (3) and (4) with Region I, and which is still open.

Relative to that item, the following information is provid$d concerning the auxiliary buildings added to our Montville facilities Ref. (5) and (6). The pump house, south of A&B buildings, was constructed in order to comply with condition 27.

Sanitary waste, radwaste and selected process waters will be pumpedtotgenewlyextendedMontvillesanitarysystem.B-Annex (d 3,000 ft ) will be presently used for processing and storage of low level radioactive waste which was previously 2

performed in adjacent areas of B-South. M-Annex (d3:,000 ft )

is presently a fuel component storage building. Other additions were a replacement air compressor building south of A building, a gew office / inspection area south of M building (n/1,500 ft ), a replacement carpenter shop gt the southeast corner of M building and C-Annex (N 16,000 ft

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AC There is no negative environmental impact from these auxiliary buildings as the areas used were previously associated with the existing site as either asphalt paved or gravel areas. No added effluents are generated; and there is no change in occupational radiation exposure or radiological accident probabilities.

While we are submitting this information to you, this is being done solely to address your comment in the Amendment 8 (Ref.(1))

letter, and does not constitute a change in our position relative to the regulatory basis for such submittal.The subject of licensing requirements regarding new construction, and in particular the construction addressed here, was raised as a possible compliance issue in the Ref. (4) inspection. UNC has stated our position relative to that item in our response to that inspection report Ref. (3), and expects that its final resolution will be a result of those activities. Thus, our action in this letter is only to assure that we are not considered to be in a state of non-compliance while the iscue is being resolved, and as stated previously, does not change our position, or the commitments made to the NRC in our letter of response to the inspection (a copy of the item is attached for your information, designated as Appendix A, item B.).

Very truly yours,

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R. CREGG

Director, Technical Services RG/jmp

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ATDO9ENT TO IEITER, N. C. IQUENAN TO T. NARITN, DATED JUIX 2,1986 UNC RESPONSE 10 NRC INSPECTICM NO. 70-731/86-02 2.

Appendix A, Itaa B, and Details of Ir== tion pars.p.oph 4.a Facility Modifications (Use of new auxiliary biildings without NRC approval).

During resolution of the NRC License i==iad in 1977, UNC moved the noted drawing E-740913-150 frun Part I (NRC approved) to Part II (Information to NRC) with NRC concurrence so that minor building dianges could be made by UNC; with the need for NRC concurrence being determined by the guidalines stated below.

Attached are license pages showing that charge (i.e. page 1-2 dated June 4,1976 and May 3,1977). The last sentence of paragraph 1.2.2 was also added to clarify the restrictions that would apply to new or modified areas or biildings: "The possession or use of SNM in any area or building shall not be permitted unless it conforms to NRC requirements (e.g. nuclear j

alarms) ".

We have handled the additions of E-Plant Annex II and Annex III, l,

s-South Unit II, H-milding and R-Building on this basis in the past. In all cases, including the most recent building additions, the NRC has been notified in advance via changes in the Security Plan and the Materials Control Plan (if appropriate).

our " facilities" are changed several t imaa a year by the addition of new agii m ant, deletion of old M ii - ant, additions of auxiliary buildings or similar actions. As long as we are working within established criticality controls and without causing any l

significant envim--ital effects, we consider we are working with " existing facilities".

.w We understand that when significant new billdings or significant j

new prmanaam are planned that could affect the envim--it or criticality limits, such change will be =*=itted to the NRC for evaluation. However, the amiliary biildings addad were small additions to existing buildings, replacing paved areas adjacent to the buildings, and have Dg effect on the site envim-- it. The activities performed in these additions were already bairq performed in the structures to which they were attached.

i We do not agree that a violation of our license has <mirred with l

respect to the words " existing facilities" under the background noted above.

i In our current license (Letter W. F. Kirk to W. T. Crow dated i

j January 22,1986) page 9-15 and 9-16 daar'-ibed the auxiliary buildings now being ocanented upon by NRC Region I. Our letter l

(W. F. Kirk to W. T. Crow dated March 21, 1986) transmitted i

revised copies of Figure E-740913-150 for informational purposes only.

In %e future, we will more pruiptly transmit building addition drawings to the NRC Uranium Fbel Licensing Group in addition to i

the information sent to NRC Security and Materials Safeguards j

Groups.

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UNITED NUCLEAR Qay C C Q P O Q A T i o N

LICENSE:

SNM-368, DOCKET NO.70-371 Revision l

NAVAL PRODUCTS DIVISION Apprmred JUN 0 4 1976 PART I:

CONDITIONS AND SPECIFICATIONS CHAPTER:

1 - GENERAL INFORMATION SECTION:

1.2 SITE AND FACILITIES j

Supersedes

.l.2 SITE AND FACILITIES The Site

,1.2.1 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 l

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.

...,- n The distance from the plant site to the east shore of the i

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.

j 1.2.2 The Facilities operations conducted at the Montville site are located in buildings designated as follows (See Drawing No. E-740913-150).

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Building A Building B f

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 W

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UGC UNITED NUCLEAR

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k-ge vtas h,,, - 2' LICENSE:

SN M-3 68, ' DOCKET-av. '70 a 1 A -

g NAVAL PRODUCTS DIVISION Approved g PART I:

CONDITIONS AND SPECIFICATIONS l"

CHAPTER:

1 - GENERAL INFORMATION

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ION:

1.2 SITE AND FACILITIES Supersedes

,1. 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 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 nor'th 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 to.the mouth.

r-

.. a 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 Shantcck, a 183 acre State Park, is located about one mile to t

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 IIdtiilding A in Part Building B Building C Building D Building M East Building Building S Buildi-ng 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 1.3.

The possession or use of SNH in any area or building shall not be permitted unless it co n f o rr.s to NRC Re q u i r e m e n t's ' ( e. g. nucle'ar alarms).

O W

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