ML20128D684

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0371/84-12. Shipper in Error in Declaring That Alternative Requirements Could Have Applied After Act of Shipment

ML20128D684
Person / Time
Site:	07000371
Issue date:	05/16/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Amy G UNC, INC. (FORMERLY UNC RESOURCES, INC.)
References
NUDOCS 8505290165
Download: ML20128D684 (2)

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MAY 161985 Docket No.70-371 License No. SNM-368

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UNCNava} Products, Division of UNC Resources, Inc.

ATTN: Mr. G. O. Amy President and General Manager 67 Sandy Desert Road Uncasville, Connecticut 06382 Gentlemen:

Subjec't: Inspection Report No. 70-371/84-12 This refers to your letter dated March 5, 1985, in response to our letter dated February 5, 1985.

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 Item 3 of your response, it is the position of the Nuclear Regulatory Commission that it is inappropriate for a shipper to declare, after the act of shipment, that alternative requirements could have been applied, in lieu of those which were'actually applied (i.e. material that is packaged, labeled as radioactive material, identified on the manifest as such, and delivered to a carrier for transport, shall be, subject to the applicable NRC/

DOT regulations).

3 Your cooperation with us is appreciated.

Sincerely, origina1 Signoa By:

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i. Thomas T. Martin, Director 9 Division of Radiation Safety and Safeguards cc:

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

State of Connecticut 0FFICIAL RECORD COPY RL UNC 84 0001.0.0 04/05/85 I

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UNC Naval Products, Div. of UNC Resources 2 bec:

Region I Docket Room (with concurrences)

T. C. Elsasser, DRP i

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, OFFICIAL RECORD COPY RL UNC 84 0002.0.0 04/05/85 i

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a . Unc DRVRL PRODUCTS UnC A UnC RE5DURCES Company 67 Sandy Desert Road Telephone 203/848-1511

. Uncasv&,. Connecticut 06382 N I S-85 1 March 5,1985 U. S. Nuclear Regulatory Commission Region i f/Z,, ^,0 631 Park Avenue c e ca w ana r King of Prussia, Pennsylvania 19406 Attention: Thomas T. Martin, Director Div. of Engineering & Technical Programs

Subject:

NRC Inspection No. 70-371/84-12

Reference:

Letter, T. T. Martin to G. O. Amy, dated 2/5/85

Dear Sir:

This letter is in response to the referenced letter, which advised us of an item of noncompliance relative to low-level waste from this facility which was inspected at Chem-Nuclear Systems' burial site at Barnwell, South Carolina. While the level of radioactivity in this material was extremely low, we nonetheless consider this situation to be serious and have taken strong corrective action to prevent recurrence, as outlined in the attachment to this letter.

I believe you will find our actions to be fully responsive to the items presented in your inspection report.

Very truly ours, i

l bl Attachment cc: R. J. Gregg W. F. Kirk J. J. Vickary h

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l Att chment to Lettsr, G. O. Amy to T.' T. Martin dated March 5,1985 RESPONSE TO NRC INSPECT!ON 70-371/84-12

1. Corrective Steps Which Have Been Taken and the Results Achieved:

All solidified rad waste drums prepared prior to 10-31-84 have been placed on quality hold and are in the precess of being inspected for the presence of free-standing water and proper solidication using j a revised inspection document prepared for this purpose. f No further solidication has been performed pending implementation y Of the actions described in (2.) below.

2. Corrective Steps Which Will Be Taken to Avoid Further Violations: }

For each new type of rad waste designated for solidification, test runs will be made using fully representative samples of pH adjusted material. The ratio of solidification agent, rad waste material (percent solids / liquids), and water will be recorded for each test. Test speci-mens will be prepared until a recipe is obtained that gives acceptable results. Approval to solidify in burial drums will be given by manage-ment personnel only after verification of the quality of the solidified test samples via inspection and testing as necessary.

Special inspection drums will be available for use in the solidification process. These drums shall have removable bottom bungs for probing the solidified waste from the bottom. A sufficient number will be used to provide assure that the actual production solidification has not varied from the approved test solidifications before changing to unbunged drums.

The degree of solidification will be determined by production personnel ]

who shall document their inspections. Checking will be accomplished @

by:

}e (a) Visual examinations for the absence of free-standing water.  ;

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(b) Mechanically striking the top surface with a metal bar and mallet.

1 (c) Probing th'e bottom of the solidified waste via an inspection port incorporated for this purpose (when bungs are present i in bottom).

Prior to final sealing the drum, a confirming inspection will be done by an individual who did not participate in the drum solidification. The results of this inspection shall be documented.

Acceptable drums will be released for closure and shipment.

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RE'SPONSE TO NRC INSPECTION 70-371/84-12

2. (cont'd. )

Solidified rad waste drums cannot be incorporated into a burial ship-ment without all of the above verified as completed and acceptable.

This verification will be made by the burial shipment coordinator, generally a member of the Nuclear Materials Control Department.

3. The Date When Full Compliance Will Be Achieved:

We are currently in full compliance.

While not intending to reduce the significance of this condition, we  ;

do feel it is appropriate to note that the level of radioactivity in the ,

items noted was so low as to not be considered a " radioactive material" under Department of Transportation Regulations 49CFR 173.403(Y);

and meets the average concentration requirements of 10CFR 20, Appendix B, Table I, Column 2 for discharge to a sanitary system without further dilution.

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