ML20126J576

Responds to NRC Re Violations Noted in IE Insp Rept 70-0820/80-14.Disputes Violation.Presents Seven Reasons for Considering U Scrap to Have Been Unirradiated Matl

ML20126J576
Person / Time
Site:	Wood River Junction
Issue date:	02/06/1981
From:	Amy G UNC RECOVERY SYSTEMS, UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
To:	Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20126J572	List: ML20126J569 ML20126J576
References
GOA-81-01, GOA-81-1, NUDOCS 8105010142
Download: ML20126J576 (11)

Text

.

Uf1C R2COVORY DYOTOm]

O GOA 81-01 Onnsion of United Nuclear Corporation One Narragansett Trail Telephone 401/364-7701 gg A UOC RESOURCES Company Wood River Junction, Rhode island 02894 February 6, 1981

?

U.

S. Nuclear Regulatory Commission Mr. Boyce H. Grier Director, Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

USNRC Inspection 70-820/80-14

Reference:

Letter on Subject, Boyce H. Grier to G.

O. Amy, dated January 14, 1981 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 item de-lineated in Appendix A of your letter.

If you de-sire further information, we will be pleased to discuss the matter with you.

Very trul

ours, d

O. A(ny

/

General Manager /

cc:

R.

J. Gregg J.

L'Heureux K. Helgeson l

8105010l%

i

.7 ATTACHSENT'TO-LETTER GOA 81-01 f

1 G. O. AMY.TO:BOYCE H. GRIER DATED FEBRUARY 6, 1981 l

'USNRC INSPECTION 70-820/80-20

-j ii USNRC COMMENT' i

Contrary-to the-requirements of Subsection 103 to License No.

SNM-777, during the. years of 1977 through11980, the licensee handled and processed.without authorization various types.of 1

irradiated nuclear fuel scrap in order to reclaim approximately 390 kilograms of uranium-235 for recycling.

d UNC RESPONSE i

'UNC acknowledges that the material described in the body of the.

' inspection report was in fact. processed at our facility.

Since this. facility ceased uranium recovery operations in August, 1980,

.no further actions are necessary to assure that similar materials j

are not processed in the future.

l l

We do not, however, agree that the processing of this material l

. constitutes an item of UNC non-compliance with NRC regulations, for the.following reasons:

j

. l.

The material involved was clearly identified, in both the paperwork which was the basis for our contract bid to the DOE, and in the DOE shipping papers, as being unirradiated.

This identification was by use of the ANSI material identification code for Unirra-diated Uranium Scrap (applicable sections are at-l tached).

As pointed out in an attachment to the NRC inspection report, this characterization was made using internal DOE criteria (ERDA Appendix 7452).

This was done despite the availability of an NRC/ DOE material code for " Irradiate Pecyclable Fuel" in the Nuclear Material Transaction Report Instructions (Forms DOE /NRC 741 and 741A).

i 2.

The NRC has. stated that they consider the material in question to be slightly irradiated, and UNC technically i

agrees with that statement.

However, it must be pointeo out that, to our knowledge, Chapter I to Title 10 of the Code.of Federal Regulations does not define irradiated material.

Therefore, it appears that the only such Federal definition is the one in use by the DOE.

l 3.

The DOE in-their correspondence with the NRC, stated j

t that they considered this material as being unirradiated.

Also, they stated that " DOE's contracts with UNC required the contractor to have all necessary licenses to possess j

and process the material."

Based on the material infor-mation provided to us by the DOE (i.e.,

it was declared l

as "unirradiated"), UNC did have the required licenses.

I

. m.

4.

10CFR 70.42(c) states that, "Before transferring specia] nuclear material to a specific licensee of the Commission or an Agreement State or to a general licensee who is required to register with the Com-mission or with an Agreement State prior to receipt of the special nuclear material, the licensee transfer-ring the material shall verify that the transferee's license authorizes receipt of the type, form, and quantity of special nuclear material to be transferred."

While the DOE is not subject to this regulation, it is clear that the intent is to place the burden of assur-rance on the shipper as they are the only party having the knowledge of the material which is necessary to make this determination.

It is highly improbable that the DOE would have shipped i

commercial reactor scrap or byproduct material to UNC without identifying it as such and assuring that we were t

licensed to receive it.

The fact that they made no such effort for the material in question is fully consistent with their definition and declaration of the material as being unirradiated.

l 5.

We cannot locate any documentation to fully clarify the basis for the 1976 license change which deleted specific reference to processing of slightly irradiated scrap.

The best recollection of the then responsible individual (who is no longer employed by UNC) is that we were not being sent any slightly irradiated material at that time, i

and that we would be notified of any such potential ship-ments so that the licensing could be handled on a. case basis.

We can find no records of such notifications from DOE.

6.

All of the materials in question were receipt inspec-i ted by UNC and found to be within the acceptance limits for surface radiation, with no indications of abnor-r mality or differences from other scrap.

In addition, I

standard Health Physics monitoring during material re-covery operations, showed no abnormal situations which would have indicated the presence of irradiated material.

7.

The processing of this material was done in full com-pliance with all applicable requirements, involved no adverse exposures of personnel, and resulted in no improper releases to the environment.

In fact, as pointed cut in the NRC inspection report, it is probable that the low level of fission products currently found in some of our monitoring wells is associated with pre-1976 processing, at a time when it was specifically authorized by the license'.

'e-While:we-realize that the above. response _is quiteLlengthy, the-obje'ctive'is to show that:

a.)

UNC has, at no time, knowingly processed' irradiated material when not permitted to do-so-by our license; b.)

our lack of specific knowledge regarding the DOE material involved was not due to a failure on our part to exercise normal and prudent care, c.)

no conditions-have arisen as a result of. processing this. material which pose any hazard to the public or our employees; and

.d.)'

there arefdifferences which currently exist between l

NRC and. DOE interpretations and. methods which should be addressed, in' order to help assure that other li-censees are not faced with similar problems in the t

future.

1 t

e f

i 1

. - - ~.

USNRC NUCLEAR MATERIAL TRANSAUTION REPORT INSTRUCTIONS (Forms DOE /NRC - 74I and 741A)

CODE Call: GORY tln Dr.;,Cl;iPI10l1 IF WARRAllTED) r; 701 Unalloyed lietal Product 702 Alloyed Metal Product 8

771 Samples and Standards 637 Sintered Products Scrap - for reco" cry *+

A00 Unalloyed metal B00 Alloyed metal C00 Compunds 000 Combustib1es E00 Noncombustibler F00 Solutions G00 Process residues 375 Irradiate Recyclable Fuel Waste - for disi"'rsal:

Waste mterial shoul<i be described by an appropriate scrap cate<jory.

ENCAPSULATED 291 Fabricated Fuel Elements - pins, rods, plates 309 fuel ast.emblies (Assemoled Items Product) 481

• naled sources (Fahric.it< d Sources l'roduc t )

OTHER 776 Other Produc M

• American Na tional c tanda rd i r, f i t u t.o r.o,'e - forunirieIiateduranium or plutonium scrap may be '.. l in 1ieu o f *.hese codt 3,

+Where a number of dissimil,r i t ei.n o f 4, a n.i re. put in.o the same container, use the cre; '.ition codo 1.

..rihing the predominant scrap citeaory.

3 C

15.

TRANSFER AU1 HOR 1,1Y

, DOE Owned Ma_teria l - I f the ma t erial i. DOE-owned, en ter such transfer authority as may be appr opriate, e.g., DOE Contract Number, lease Agreement Number, Nuclear Material (NM) order number, purchase order numbor, etc.

If the transfer is being made as a result of the llM Draf t (Form 00E-437), enter the dra f t number.

Privately Owned Mater,ia_l_ - Make no entry in this block for non-DOE-owned material.

16.

EXPORT OR IMPORT'T,RAjlSFERS -

A.

For all export or import transfers, enter the NRC export or import license number, respectively under which R

special nuclear material, source material, or tritium is being transferred.

Does not apply for imports of source material or tritium, where authorized by a general license.

6.

For all export or import transfers, enter the U.S. Port of Exit / Entry code designating where the shipment exited or entered the United States.

Appendix 1 to these instructions contains a listing of a11 United States Customs ports and their assigned four digit codes.

17. MATERIAL TYPE,A))D Dl;S 1.PT.I.0]! - f nter t he preci se type of special nuclear matnrial (Pu, Pu-238,11-233, or uranium O

enriched in the isot ope U-235), source material (depleted

2 uranium, na tura l nr.m ium, th>rium),oi 'ritium, together with its physical unl themical toin.

I nter whether material being transferred is irradiated.

18.

TRANSPORTATI0i! pHDFil.E - A full transportation profile, including identi f i a tion of transnorta tion carriers and transfer point s fm up to five dif ferent trip segments, is required to be reported on all shipments involving quantities of material subje< ' to f.he requiiements for the physical protection of sper ial nucleat material in-transit specified in 10 CFR Part 73.

NOTE:

For transiers of material subj"ct to the above physical protection requirement'.. Form 00E/flRC-741 must be O

dispatched u.y " registered or tcelified-return receipt requested" nail nervice.

A.

TRIP SEGMENT,- !!n rolry rmpeired.

B.

CARRIER lilDITil 11.3110tl Enter the !ransportation carrier identi fication i'+ f or each t rip scyment.

Appendix 11 to these instruct inns contains a listing of the most frequently ust<' r.in iers and Iheir assigned four character codes.

Carriri c Ars not fonnl in Appendi.x !! should be obtained from the <arrier or b/ <.nn.ulling the complete list of I ran',p n1 i t inn i ai r lei - onel thrir codes, which is contained in ti"' "Contint:nlal hirettory itMF-101 of Standard Carri"' oIpha iod"n an I %Landard larif f Agent p

Codes," availchin ' om i hr Ital ino/il Motor i reight i

i l

l

/

,,e American National Standard 7

Classification of Unirradiated Uranium Scrap i

W

1. Scope and Purpose i

standard is to provide a classification system with in for facilitating activities in the nuclear industry relevant to the classifications standard.

s i

2. Classification Systein 1

i j

2.1 Basic Identification Code. The cla,sification system for unirradiated scra by degree of five characters as follows:U enrichment, rnajor grade. and subgrade. The basic id!

erial Isotopic Enrichment e.

Maior Grarle Subgrade XX X

XX l

I Listed and described in the classification categories are seven rnajor gra subgrades of scrap with their arociated identification codes. Scrap not [

ree the subgrades listed in this guide shonid he identified with respect to its major of i

enrichment codes and described in detai!

e and isotopic 2.2 Identification Codes for Isotopic Enrichment llanges. The irlentificatio characters as shown in l'able t. enrichment ranges are identified nionerwa n codes for the isotopic I

rst and second t

Table 1

[

Identification Codes for Isotopic Enrichment llanges

..___m___._.m_

i Type Type I

-Code Description T>pe Type Percont Corte Description Percent i

10XXX Depleted U Total i

11XXX

< 0 21 24XXX

?

l.60 to < 2.20 t2XXX t

25 X X '*'

0 21 to 0.28 2.20 to < 2 00 13XXX

> 0 24 to < 0 26 2tiX N.s 2 60 to < 2.90 14XXX 0 26 tn < 02%

27 X X N 2.90 to < 3.10 15XX X O N to 4 O 'id 110 to < 3 10

/9NNX 16XXX 0.30 to - o.50

) 40 to < 3 00 2bXXX

)

t7XXX 0.50 to < 0 60 3.90 to c 4 to 30X X X tBXXX 0M0 to <, Norm al (0.711 )

410 to < 4 50 itXXX t

32X X X l.50 to < 8 00 81XXX Norrnal U Totalit)311';)

33XXX 8.00 to < 25 00

'liX X X 25.n0 to < 35 00 t

20XXX Enriched U Tuul 35X X X 35 00 to < 41.00 21XXX

- Nortnal e0311) to.: 0 m

16X X X 45 00 to < 80.00 22X X X 17XNX 0 9d to < 1 15 80 no to < 92 00 23XX X 1.!'ilo o I 60 92.00 to < '11.00 3dXNN 3XNX 94 00 and abnw l

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i AMI:l(ICAN NATIONAL STANDARD

'N15.1 2.3 Major Grades. The major graites are identified alphabetically by the third character as a

follows:

XXAXX linalloyed f,h tal XXBXX Alloyal Metal XXCXX Compounds XXDXX Com be nble.,

XXEXN Nmnomhur.tihics X XI/X X Solutions XXGXX l'roce.s liesiduc3 2

An example of the classification.ystem for pure recastable met.d. enriched to 5 percent

U, would be 32A10.

3. Classification Outline

't.1 Unalloyed Metal - XXAXX. This material is defiard as scrap since it is in excess of the current needs of the generating site or is not 04ahle ;n its present form, or has become contaminated with impurities to the extent that it is not acceptable for fabrication programs.

Every effort should be made to keen XX AXX material separated from other grades of scrap.

Grade Title Deucription XX A10 Recastable hietal This is a general category for metal in this class such as (pure) anassive pieces. foil plates. Chips in oil, and so forth, which are acceptable for recasting. A further subdivision follows for use when a snore specific category for pure recastable metal is desired.

XXA11 Recastable hietal P.letal ar.d metal plates in sizes suitai,1c for remelt and not requirine pickling.

XXA12 Recastable hietal itriquettable chips which m e acceptable for recasting.

XXA13 Recastable hietal solid metal re quiring pickling prior to recasting.

XXA14 Recastable hietal Alassive metal requirine sa vin.: prior to recasting.

XXA15 Recastable hietal alasive met.il requiring sa.ing and pickling prior to recasting.

XXA16 Recastable Meid

.%Iid metal which may be ie< ast after double melting.

XXA17 Recastable Metal l'artially ci:ul metal reca a dile after nitric pickling.

XXA18 Recastable Metal s't.nl metal reca, table aft, hydroiluoric and nitric acid pick.

ling, for example, tiromiu a clad. metal.

XXA20 Recastable hietal Metal clad with material w her than zirconium and aluminum, im i.xample atainleu steel X X A30 Metal Massn e metal, foil, plater. chips, and t.o forth, which may be (relatively pure) hurneil to an oxide similar to the specifications set forth in Table 2.

XXA40 Metal Massive metal, foil, plates chip 3. and so forth, which cannot be (impure) conver ted to an oxide meetinv the specifications shuilar to those in Talite 2 without i hemical purification.

3.2 Alloyed Metal - XX11X X. This' materi.il is alloved uetal in which uranium is a major h

constituent (one percent U or inoie) and in whi(h the otlies inajor constituerits are known. This category also includes mixtares that lum ph3 -ical propt rc es sinolar to alloys, such as uranium oxides and metallic powders cominned m pre 4.ag opn sti.o -

t 8

',. ',f[p#p3stFICAlfl3&BF t WutE2MTp HUGITTrMT~&

m

...g 3

. z g,,b Tills Iberipti m.

l y Uranium-Aluminum Alhiy billets m other maa. picies which rmiuire physical Alloy hiassive hietal treatment (for i s,onple, choppings 1.cfore chemical treatment, r

Imtividual fuel plates are Grade X XBil, but assemblies of fuel

. plates belong in thi,i:r ade.

XXB11 Uranium Aluminum Fillers, plates, strips. or cino...md turnings meeting the general l

Alloy specification for Grade XXIG X.

NO l'E: Sorne of the items inilinted in ihis vrmf e may require chopping or other ph) deal treannent, dependiin: un (l.c n.nure of the procestor's equipment.

f i

XXB12 Uranium Aluminum Castine skull, dross, ami simdar residues. This grade must Alloy Solids and contain at least une per cent uramum.

l Residues I

XXB13 U Als Pressed Filters, plates, strina, and scrap.

v l

Powders XXB14 U A1x Fillers, and so forth, cl.nl in aluminum.

XXB15 Uranium Oxide in Ur mium oxide coated with m dispersed in aluminum or both.

j Aluminum Alloy hillets conta nine uranium and zirconium or zircalloy, or i

XXB20 Uranium Zirconium Alloy hiassive Nietal other manive piec es which rmuire physical treatment (for l

ekample, chopping) before chemical treatment. Individual fuel plates are Crade XXIl21, but assernblies of fuel plates belong in this grade.

l XXB21 Uranium-Zirconium Fillers, plates, strips, chop >tock, or chips and turnings meeting l

Alloy the general specifications for Grade XXBXX. (See Note to l

)

Grade XXB11.)

i t

XXB22 Uraniuni-Z:.conium l'asting r esid u cs, melt sinhs, grinding sindge, and similat i

Alloy Solids and residnes, but not s apor bla a erit. I his grade must contain at i

Residues least one percent in anium

{

XXB23 Uranium Oxide in ifranium oxide coated with,,r dispersed in zirconium or both,

~ Zirconium This grade im ludts UO. ?.io, only if coated or clad with f

nrconm' m.

i XXB24 Uranium Oxide in Uranium oxide coated with or dinnersed in zirconium or both.

Zirconium l'his grade inchnics t o..Zu n if coated or clad with material i

other than rirconium j

XXB30 Uranium Molybde-Allov billets or other massis e pieces which require physical num Alloy hiassive im.ument tfor ex.nople. choppiner before chemical treatment Metal Individual t'ncl plat 3.n e Gr.nle XX H:ll, but assemblies of fuel plates belong in this gr.nle.

i j

XXB31 Uranium blolybde-l'dlers, plates, rods, st rips. turninus, chips, and the like.

num Alloy XXB32 Uranium-hlolybde-t % ing re iilnes, melt stub <. crinding shulge, and similar j

num Alloy Solids residues. Init not s apm bl.rt crit. This grade must contain at l

and Residues lea,t one pert ent oranium.

l XXB40 Other Alloys -

Alloy hillets, or other ma-sive pieecs containing uranium and Massive h!etal metals other th m aluminmn, molybdenum, or zirconium, j

which reipiire physu al treatment (for example. choppine) bef ore chemical treatment. Indnidual fuel plates are Grade l

)

X Xit 11. but ae,emblic i of im I plat., belone in this grade.

j 1

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@nnWKurmcnsumQr;mnWnnncMD

'1 '., ' Nib t 4

Grsde Titir Description X X B41' Other Alloys Fillers plain strips, chop stock, chips, turnings, and similar 4

materiah.. meeting the eeneral specifications. for Grade XXilXX. This vrade im boles alloys containing significant amounts of any third cleno nt. (See Note to Grade XXB11.)

XXB42 Other Alloy Solids Uranium alloyed with or canned in elements other than and flesidues aluminum, mol>hdenum, or zirconium. This grade includes massisc pieces, fillers. plaies. chips and turnings, and solid residues such a.< those listol for aluminum, molybdenum, and fircontum.

X XH50 Uranium Oxi.le with Uranium aide roated with or dispersed in stainless steel or Stainless Steel both. This cr.nic inchule, all of the arious stainless steel

- formulations, hnt doe-not inchule t' emry mixtures. It must contain at least one pert ent uranium.

X.X B60 Uranium Oxide with Uranimn oxide coated with or di<per ed in any metallic ele.

Other Metallic ment nother than tiramium, alunnmnn, or stainless steel) or Elements both. This grade also includes all ternary dispersions. It must contain at least one percent uranium.

3.3 Compounds - XXCXX. This material is compou d of mixed oxides and compounds of uranium, or oxides and compounds mixed with non fioih materials.

Grade - Title Description XXC01 Oxides UO. UO., or mixture thereof. which can be calcined directly to 2

7 (relatively pure) a product meetine specilitations similar to those in Table 2.

XXC04 Oxides (impure)

UO:, UO3. U,0.. or mixtures thereof, which cannot be calcined directly to acceptable product. This grade includes UO ZrO 2

(not metallie clail) ami similar mixed oxides which contain at least one percent uranium.

XXC05 Oxides with Ca0 UO Z 0: or other uranium oxides mixed with calcium oxide.

This gr,nh must he at least one percent uranium.

110 Tho,or other uranium oxides mixed with thorium oxide.

XXC07 Oxides with Th0:

2 This prade must he at least one percent uranium.

XXC08 Oxides with BeO UO Im or other uranium oxides nuxed with beryllium oxide.

This grade must be at le &t one percent uranium.

XXC10 U F, Ifranimn hexanuoride.

XXC11 UP. (relatively Meetim: the son ificatium, similar to those in Table 2.

pute)

XXC12 Miscellaneous liluoride componmis of her than UF, and UF,.

Uranium Fluorides XXC13 ' Uranium ilatide Incholes dry compmuuls of uranium halides other than fluo.

Compounds rides.

XXC21 Crystalline Uranvi nitrate hexahyihate which can be calcined directly uranyl nitrate according to the sperdicarnms in Table 2.

(relatively pure)

XXC24 Crystalline uranyl Uranyl nitrate crysta!* c ontaininc sufficient impurities such

)

nitrate (impu re) that dirert ralcination e.imbi not sicht a product ineeting the uptcifications sunilar to th we in Table 2.

'2

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