ML20050K870
| ML20050K870 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 02/05/1982 |
| From: | Gregg R UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20050K663 | List: |
| References | |
| RJG:82-11, NUDOCS 8204140234 | |
| Download: ML20050K870 (3) | |
Text
'
UnC R$2,VERYCVSTCm5 O l
Dmsron of United Nucfear Corporation One Narragansett Trait Telephone 401/364-7701 A UnC RESOURCES Company Wood River Junction, Rhode island 02894 RJG:
82-11 February 5, 1982 U.
S.
Nuclear Pegulatory Commission Mr. Thomas T. Martin Director, Division of Engineering and Technical Inspection Rcgion I 631 Park Avenue King of Prussia, PA 19406
Subject:
Response to USNRC Inspection 70-820/81-08 Gentlemen:
Attached is UNC Recovery Systems' recponse to the subject inspection which was transmitted to us and received on January 18, 1982.
We trust that this response will satisfactorily resolve the item delineated in Appendix A of your letter.
If fur-ther information is desired, we will be pleased to discuss the matter with you.
Very truly yours, UNC RECOVERY SYSTEMS (i[G R.
J.
Grecjg Plant Manager RJG:ame cc:
G.
O.
Amy g{
K.
A.
IIelgeson NCrTARY FUBUC B204140234 820408 STATE CF W
{DRADOCK07000 MY COMMLSSION EXPIRES JUNE 30,1986
~
O O
ATTACHMENT TO LETTER RJG 82-11 R.
J.
GREGG TO THOMAS T. MARTIN DATED FEBRUARY 10, 1982 USNRC INSPECTION 70-820/81-08 USNRC COMMENT Contrary to 10 CFR 71.5, which prohibite the delivery of licensed material to a carrier for transport unless the li-censee complies with the regulations in 49 CFR Parts 170-189 and 4 9 CFR 173. 24 (a), which requires that cach package used in such transfer has its contents so limited that under con-ditions normally incident to transportation the effectiveness of the packaging will not he substantially reduced, on June 9, 1981, a package containing 56.4 microcuries of licensed radio-active material was delivered to a carrier for transport and its contents were not so limited.
Its effectiveness was sub-stantially reduced under normal transport conditions.
A 1-1/4" x 2-1/2" puncture was produced in the container's side by a pipe within it.
This is a Severity Level III violation (Supplement V.C.1)
UNC RESPONSE UNC acknowledges that container (box) number 1764 did contain a 1h" x 2h" puncture in its side when it arrived at the Beatty, Nevada burial site.
This hole did not exist when the package left UNC's facility.
Inasmuch as this facility is no longer in operation, we do not wish to contest the NRC's finding of non-compliance.
However, we do think it appropriate to review the situation in further detail:
1.
There is significant doubt as to the applicability of 10 CPR 71 to this violation of 49 CFR.
Section
- 71. 7 (a) states:
"A licensee is exempt from all the requirements of this part to the extent that he de-livers to a carrier for transport packages each of which contains no licensed material having a specific activity in excess of 0.002 microcurie / gram."
Since there was 56.4 microcuries in this package having a net weight of approximately 2,534 pounds, the specific activity of the contents was 0.00005 microcurie / gram.
Even though UNC considers the activity to have been essentially uniformly distributed, we note that that 49 CFR requirement is not reflected in 10 CFR 71.
2.
The designation of this item as being Severity Level III is based on published NRC policy which fails to distinguish between hazard levels.
To quote from the Federal Register, Volume 45, No. 196, p. 66755, para.
III: "In general, violations that are included in these severity categories (I, II, and III) involve actual or
O O
high potential impact on the public."
It is clear that the material in the subject container, or in any other box of this type shipped by UNC Recovery Systems, even if broken open, would not have a high impact on the public.
The material contained in the crate and in others like it, is associated with the decommissioning of this facility, which until mid-1980 was engaged in the recovery of enriched uranium from unirradiated scrap materials.
The type of material being shipped typically consists of pipe, light fixtures, wiring, concrete blocks, etc.
Before shipping, this material is cleaned (e.g., by acid washing, wire brushing, steam cleaning, etc.)
to reduce the radioactive contamination to the low-est level practical.
The material is then gamma counted, using a calibrated measuring system, to assure that it ic free of measureable quantities of uranium.
This decommissioning material is shipped to burial either because it exceeds the permissable levelc defined by the USNRC for disposal to unrestricted areas, or because of the difficulty in assuring that all portions of the material meet those criteria.
In all cases, UNC elects to send material to burial where any element of doubt may exist as to its accepta-bility for unrestricted disposal.
The lack of real or potential impact on the public is further supported by the fact that all radioactivity measuremento taken on and around the subject container 1
by the State of Nevada and US Ecology mat government limits for unrestricted release.
l 3.
To prevent future occurrence of this situation, des-pite the lack of hazard in a container breach, UNC is now placing double thicknesses of plywood on the containor walls.
All employees are aware of the ori-ginal condition and will exercise caution in loading materials into the containers.
It chould be pointed out that UNC has shipped over 115 boxes of this design to burial over the past three years.
Of these, approximately 40 travelled the same route and were handled in the same manner as Box No.
1764, and arrived at Beatty, Nevada intact and without incident.
The others were shipped to Barnwell, SC and also completed the trip without an occurrence of this nature.
Given this prior shipping experience, there was no reason for UNC to anticipate that an event of 1
thic nature could happen, nor do we expect one in the future.
i s___
m.,,..__