ML19347F987
| ML19347F987 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 04/27/1981 |
| From: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Amy G UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 8105280008 | |
| Download: ML19347F987 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION ai REGION l
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%'V KING OF PRUSSIA, PENNSYLVANIA 194o6
,j Docket No.70-820 g
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APR 271981 l
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United Nuclear Corporation Mf ATTN: Mr. G. O. Amy
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General Manager coassa o
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Wood River Junction, Rhode Island 02854 T&.. @y
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Gentlemen:
Subject:
Inspection 70-820/80-14 This refers to your letter dated February 6,1981, in response to our letter dated January 14, 1981. We have evaluated your reasons for considering the slightly irradiated scrap which you received and processed after July 16, 1976, to have been unirradiated as indicated in our letter dated March 11, 1981.
In our evaluation of the reasons we also considered the information you provided to us in your letter of Octoba 7,1980, which also concerned the definition of unirradiated uranium scrap.
Your first four reasons have the central concapt that the Department of Energy (DOE) sent the irradiated material to you for uranium recovery as unirradiated material, therefore, the material was unirradiated according to a Federal definition.
This is not the case, according to the information given to us in a November 13, 1980, letter from Mr. R. J. Hart, Manager, Oak Ridge Operations of the Department of Energy, to Boyce H. Grier, Director of Region I.
In this letter, it was stated that all the materials shipped to UNC Recovery Systems for uranium recovery met the criteria of either unirradiated or slightly irradiated (radiation level less than 100 mfIlirem per hour on contact) scrap material as defined by ERDA Appendix 7452.
It was further noted that Appendix 7452 states that for recovery purposes, slightly irradiated scrap can be considered as unirradiated scrap if the radiation levels are less than 100 l
millirem per hour on contact.
It must be noted that slightly irradiated material was defined as material having surface radiation readings of less than 100 millirem per hour, and this slightly irradiated material could be processed for uranium recovery purposes as if it were unirradiated.
Nothing in this modifies our definitica of irrad1ated i
material. We consider the material in question to have been irradiated as l
long as it had been been exposed to neutrons in a critical assembly. Therefore, we consider the item of noncompliance valid.
In your fourth reason you state that you find it highly improbable that the DOE would have shipped the material in question to you unless they considered that your license authorized your receipt of the material.
In your fifth reason you state that your individual responsible for licensing of your activities 8105280003 d.
United Nuclear Corporation 2
APR 271981 in 1976 recalled that, after the license no longer authorized the processing of slightly irradiated material, you would be notified of any potential shipments of slightly irradiated material and the necessary license authorization would then have been obtained on a case basis. There is an apparent discrepancy between these statements.
For such notification of potential shipments of slightly irradiated scrap to be possible, United Nuclear Corporation would have had to have informed Oak Ridge Operations of the fact that after July 16, 1976, your license no longer authorized the receipt and processing of slightly irradiated material.
It is noteworthy that in the letter from Mr. Hart, Manager of Oak Ridge Operations, to Mr. Grier, it was stated that neither the Schenectady Naval Reactors Office nor Oak Ridge Operations was aware that you were no longer authorized to receive slightly irradicted material.
This lack of knowledge is the apparent reason that you were never notified of potential shipments of slightly irradiated material from DOE as you state in the last sentence of your fifth reason.
Your sixth and seventh reasons state that the material in question did not have high radiation levels; and the processing of the material did not cause different radiation levels in equipment or facilities, adverse exposure to personnel, or improper releases to the environment.
During our inspections of your radiation control at your facilities since 1976, we bave found no unacceptable exposure of personnel or unacceptable radiation levels. As you are aware, the reason for the concern on the part of the NRC in this situation is the presence of fission products in the effluent lagoon waste and the subsequent presence of the fission products in the ground water. As you mentioned in your seventh reason, it is probable that the fission products currently found in some of your monitoring wells came from leakage of lagoon B prior to 1976, when you were authorized to receive and process slightly irradiated material.
This point is significant, because if we had found that the fission products in the ground water had come from processing of slightly irradiated waste after July 16, 1976, we would have taken more stringent enforcement action than was taken in this instance.
In summary our evaluation of your reasons for your actions being in compliance with your NRC license shows the following:
With regard to the definition of slightly irradiated material, we consider the type of material involved in this situation to be irradiated material as long as it has been exposed to neutrons in a critical assembly.
The Department of Energy considers irradiated scrap to be slightly irradiated if it has surface radiation levels less than 100 millirem per hour.
There is no conflict in these definitions.
The Department of Energy Appendix 7452 states that for recovery purposes slightly irradiated scrap can be considered as unirradiated scrap.
There is nothing in this statement that defines slightly irradiated scrap as unirradiated scrap; it still has been irradiated and must have surface radiation levels less than 100 millirem per hour.
I
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United Nuclear Corporation 3
gg Upon the renewal of your license in July 1976, neither Oak Ridge Operations nor the Schenectady Naval Reactors Office of the DOE was informed that your license was changed so that you were no longer authorized to receive slightly irradiated material.
In conclusion our evaluation of your reasons for your actions does not indicate sufficient cause to find that your actions were in compliance with the requirements of your current license, and the item of noncompliance cited in our January 14, 1981, letter is valid.
You have ceased receiving and processing material and are removing the lagoon waste in your decontamination and decommissioning of your facilities.
Therefore, you can take no further corrective actions for this item of noncompliance and you need not reply to this letter.
All relevant letters and enclosures to letters will be placed in the Public Document Room since your letter of February 14, 1981, contained no application to this office to withhold such information from public disclosure.
Should you have any further questions concerning this matter, we will be pleased to discuss them with you.
Sincerely, C
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Bo H. Grier Director CC:
R. J. Gregg, Plant Manager
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