ML19256G437
| ML19256G437 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 10/24/1979 |
| From: | Bowers C UNC RECOVERY SYSTEMS, UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19256G434 | List: |
| References | |
| 79-197, NUDOCS 7912310299 | |
| Download: ML19256G437 (4) | |
Text
9 Uf1C RECOVERY SYSTEMS Division of United Nuclear Corporation One Narragansett Trail Teiephone 401'364-7701 g
j A UnC RE5oURCES Company Wood River Junction. Rhode island 02894 CEB:
79-197 October 24, 1979 United States Nuclear Regulatory Commission George H.
Smith, Chief Fuel Facility and Materials Safety Branch Region I 631 Park Avenue King of Prussia, PA 19406
Subject:
USNRC Inspection 70-820/79-16
Reference:
Letter on Subject, George H.
Smith to C.
E.
Bowers dated October 9, 1979 Gentlemen:
Attached is UNC Recovery Systems' response to the subject inspection report, which was transmitted to us via the referenced letter.
We trust that this response will satisfactorily resolve the items de-lineated in Appendix A of your letter.
If further amplification is needed, we will of course be happy to discuss the matter with you.
Very truly yours, f'
C.
E.
Bowers General Manager CEB : FJG: maw Attachment 1664 175 7912310 299
UUC Attachment to Letter CEB:
79-197 C.
E.
Bowers to George H.
Smith Dated October 24, 1979 USNRC INSPECTION 70-820/79-16 ITEM 1 USNRC COMMENT Contrary to the requirements of 10 CFR 71.54 (i),
on August 29, 1979, the written procedure for packaging product did not address the closure of the inner containers of the shipping containers.
UNC RESPONSE While UNC recognizes the importance of assuring that the inner container closures of SNM shipping containers are acceptable, we do not acknowledge that this condition constitutes an item of non-compliance.
As pointed out in the body of the NRC inspection report, UNC-RS does have a written procedure for loading and closing SNM shipping containers, as is required by 10 CFR 71.54 (i).
To our know-ledge, the degree of detail to be included in such a procedure is not specified in any por-tion of 10 CFR which was applicable to our operations at the time of this inspection.
The quality assurance program required by 10 CFR 71.51 is obviously intended to introduce a greater degree of formality and detail to activities asso-ciated with shipment of SNM, and UNC-RS is in the process of developing more extensive systems and procedures to be implemented when our quality assurance plan is approved by the NRC.
These procedures will specifically address the closure of inner containers.
However, we are currently operating in accordance with the existing program, as is authorized by 10 CFR 71.51 (a).
This program, in our opinion, meets the requirements of 10 CFR 71.54.
It should be noted that neither the lack of this specific detail in the current procedure, nor the lack of specific coverage of the inner container closure in the associated records (see Item 2 below) is any indication that these closures have not been acceptable on SNM shipments made from UNC-RS.
Many shipments of SNM are made from this 1664 176
Uf1C Attachment Page 2 October 24, 1979 facility using the UNC-1484 container, and a large portion of these shipments go directly to U.S.
Government facilities.
To the best of our know-ledge, no shipment has ever been found to be faulty by any of their recipients.
UNC-RS per-sonnel are well trained regarding proper SNM packaging procedures, and are conscientious in the performance of their duties.
Therefore, a high level of confidence exists that all SNM shipments have been and will continue to be fully acceptable.
The implementation of new or modified systems and procedures with the new quality assurance program will further enhance that high level of confidence.
ITEM 2 USNRC COMMENT Contrary to the requirements of 10 CFR 71.62 (a)
(10) and 10 CFR 71.54 (c), the licensee's records for the packaging of product during January through July 1979 did not include records showing that the closure of the inner container was closed pro-perly with the use of defect-free gaskets or sealing lute.
UNC RESPONSE UNC acknowledges that the records do not include the results of the determination that "the closure of the package and any sealing gaskets are present and are a
free from defects" as this requirement relates to the inner containers.
While this determination is made by Operations personnel, there have been no specific records maintained attesting to the results.
As identified in the NRC inspection report, such records are maintained relative to the outer container.
This condition is being corrected, and future shipments of SNM in containers having an inner container will have the required records.
As discussed in Item 1 above, UNC is in the process of developing new or modified systems and procedures for implementation under the new c,uality assurance program.
These procedures will address preparation and maintenance of records, to assure that the applicable regulations are complied with.
I664 177
Uf1C Attachment Page 3 October 24, 1979 ITEM 3 USNRC COMMENT Contrary to the requirements of Section 305.1.1.2 of License No. SNM-777, the borosilicate glass raschig rings in I-D-24A filtrate tank as of November 22, 1978, did not have a boron content in the range of 11.2 to 13.8 weight percent E 0
- 23 UNC RESPONSE We agree that the raschig rings in the I-D-24A tank contain a higher B 02 3 content than do the rings in the other tanks in the plant.
We also note that this higher boron content provides a greater degree of protection against an accidental criticality than is achieved with the other rings.
Research of the available plant records indicates that the rings in this tank are type EN-1 glass fabricated by Owens-Illinois, and contain 18.5 nominal percent B20.
Best available information 3
also indicates that this type of glass was accept-able and was used throughout the plant at the time the facility was first placed in operation (early 1960's).
Subsequent to that time, information became available that the lower B 03 content rings 2
were more resistant to attack by certain chemicals.
On that basis, the type of rings ordered for use was changed to that which is specified in the cur-rent revision of license SNM-777.
However, the rings in the I-D-24A tank have never been replaced, as the yearly inspections have always shown that no significant deterioration existed.
This is most likely due to the fact that this specific tank does not contain acid solutions.
Based on the above, UNC does not concur that this situation is an item of non-compliance.
The rings were acceptable when they were placed in the tank, they have been in use for approximately fifteen years without significant deterioration, and they provide a greater margin of nuclear safety than do the cur-rently specified rings.
Therefore, no corrective ac-tions are felt to be necessary, and none are planned.
1664 178