ML19310A639
| ML19310A639 | |
| Person / Time | |
|---|---|
| Site: | 07100102 |
| Issue date: | 05/30/1980 |
| From: | Rob Parker PARKER, R.A. |
| To: | Spraul J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 16494, NUDOCS 8006200586 | |
| Download: ML19310A639 (2) | |
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.s JUNO 41980s Mr. Jack Spraul u., M W Transportaticn Certification Branch D
7 Division of Fuel Cycle and Material Safety m.,Q U.S. Nuclear Regulatory Commission NN g
Washington, D. C. 20555
Dear Mr. Spraul:
RE: Source Production & Equk.pment Co., Inc.'71-0102 Mr. R. F. Dicharry, President of Source ProductiorL&
Equipment Co.(SPEC), has requested that I in the capacity of their consultant respond to you concerning their application for a quality assurance (QA) program pursuant to 10CFR71.24 for their Type B packages.
I had previously discussed this application with Mr. Dick Oodegarten on Friday, December 5, 1979 and we have held telephone discussions on Friday, May 2, 1980 and twice on Thursdq.
May 22, 1930.
To review the status of the application Mr. Dicharry submitted a QA program on June 23, 1978 pertaining to the manufacturer of SPEC Type B packages.
A reply was sent by NRC on June 6,1979.
That reply contained a one page sheet from 10 CFR 71 - Appendix E,/Special Acceptance Criteria - Transportation Packages for Normal Form Radioactive Material containing Items I, 1-6 and II, 1-2.
This is obviously the first page only of a more comprehensive document with which I am familar.
Never-theless, the June 6, 1979 reply was in my opinion not responsive to the June 23, 1978 submission, since it stated only " Additional information is required to satisfy the requirement of Appendix E to 100FR Part 71."
SPEC had made an effort to satisfy the requirements in their June 23, 1978 submission, and at least the major points of the Appendix E criteria were submitted.
In fairness to SPEC they should have been explicitly informed as to what was unacceptable and what was required for 1
their type and size of program.
This was the subject of my December 5,1979 telephone conversation, and no response has been received to date.
In March 1980 you apparently contacted Mr. Dicharry and he informed you that he had requested my assistance.
During cur 77 F,79 ?P
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3061 Abelia Orne 3aton Rouge, Louisiana 708Cd 1'* u4-C 3 C
Pego 2 - Spraul-NRC/ SPEC telephone conversation when I was in Washington, D. C.
on May 2,1980 you mentioned to me that you were expecting a reply and I stated that I would contact you from Baton Rouge, which I did on May 22, 1930, so that I could have the files available.
In order to establish an orderly process and schedule for completion I think it would be beneficial for you to have some knowledge of the SPEC operation.
SPEC has two Type B packages: USA /9036/B which is their Model C-1 source changer for Ir-192 sources; and USA /9056/B which is their Model SPEC-2T exposure device for Ir-192 sources.
They have 7 to 9 employees:
one principally for camera construction and changer fabrication; one hot-cell operator; a shipping and receiving clerk; and the President and Vice-President, who also function in technical capacities, including responsibility for the radiation safety functions. -
The C-1 source changers and 2-T cameras consist of a depleted uranium shield casted with a tube through it which is purchased as a single item from a national manufacturer.
SPEC simply encases those castings in a steel shell and attaches. appropriate closures.
Large numbers of these devices are not manufactured.
Of the seventeen point criteria in 10CFR Part 71, Appendix E, their June 23, 1978 submission specifically addressed seven points.
Because of the nature and size of their program elements of the remaining ten points are contained in the seven enumerated, and most points in 10CFR Part 71, Appendix E are not applicable to the scope of the SPEC program described above.
In total fairness to SPEC and to clearly lay the foundation for an orderly completion, please explain what exactly is not acceptable in the June 23, 1978 application and specify explicity in context with the above description of the scope of their operation which remaining points appear to apply and to what extent.
Please forward that to me and upon receipt I will review it and establish a proposed schedule for completion which I will discuss with you so that we can reach a j
mutually agreeable time table..
Sincerely,
. Parker, Ph.D.
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