ML20138F578

Responds to 850927 Order to Show Cause Re Return of High Enriched U.Extension of 120-day Limit Requested,Based on Listed Reasons,Including Need for Order Clarifying Which Matls Require Removal to Secure Facility

ML20138F578
Person / Time
Site:	University of Wisconsin
Issue date:	10/10/1985
From:	Cashwell R WISCONSIN, UNIV. OF, MADISON, WI
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 8510250290
Download: ML20138F578 (3)

Text

k University of Wisconsin ADDRESS:

NUCLEam mEACTom LABOm&Tomy .

CO Ee AD SON w C ONs N S370 M NE 242 3391 ARE ,

October 10, 1985 ,

Secretary of the Commission U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Re: Docket 50-156

Dear .Si r:

This letter la submitted in response to an Order to Show Cause dated September 27, 1985 The order concerns return of unirradiated high-enriched uranium. Although we have previously begun the steps necessary to comply with section 111 of the order, this letter requests an extension of the 120 day time limit in the order. The reasons for the need for additional time are detailed below.

1. Need for clarification of the order to define what materials must be moved to a secure facility.

A. The order specified "unirradiated" high enriched fuel. A part of the spare fuel inventory on hand at this facility was a part of the core during the test program for the present operational core. Although the power level at which these fuel assemblies were operated was deliberately limited to keep fission product inventory at a level which would allow unshielded storage of the fuel, that portion of the fuel is definitely not unirradiated.

Is it the intent of the order that such fuel be considered irradiated or unirradiated?

B. The order allows retention of fuel to " replace one failed element for each different type element in the core". A clarification of the term

" element" is required. Instrumented fuel elements are loaded as discrete components, while all other elements are loaded as a part of a fuel bundle. Spare fuel is stored assembled in bundles of four elements. A fuel bundle consists of a bottom end fitting which supports the fuel elements (screwed into the bottom end box) and a top fitting

which affords capability for underwater handling of the fuel. A bundle

! usually contains four elements unless it is intended to contain an instrumented element or a guide tube for a control rod.

Is it the intent of the order that we be allowed to retain one unirradiated instrumented element and one unirradiated fuel bundle, which is a mechanical assembly of four elements?

2. Need for exemption from a Commission rule to allow shipment, 10 CFR Part 71.12(b) states that the general license for transport of radio-active material in an approved container " applies only to a licensee who has a quality assurance program approved by the Commission as satisfying the 8510250290 851010 PDR ADOCK 05000156 PDR

Srcretary of tha Commission Octob2r 10, 1985 d provisions of Subpsrt H of this p:rt". This fccility do2s not hava such a Comission-approved program.

We request 4 hat the Comigsion either grant an exemption from this require-ment or modify the order to allow adequate time to obtain Commission approval of such a quality assurance program.

3 Requirements outside the control of the licensee that may preclude full compliance within the 120 day 1imit in the order.

1 A. Shipping containers for the fuel type in use have been - dered on our I behalf by the U. S. Department of Energy. We have no wntrol over the time when these approved containers will be delivered to us.

B. DOE, the fuel owner, has designated the Idaho Chemical Processing Plant, (operated by Westinghouse Idaho Nuclear Company, Inc.) as the facility to which we must ship the fuel affected by the order. Receiver's Form WINCO-6466 (Rev. 3-84) was prepared for the NRC to detail fuel receipt criteria. This document states that the form must be submitted "at least 180 days prior to shipment". We submitted the information required for a. portion of our high-enriched uranium inventory on September 10, 1985 We are unable to complete the form for the remainder of the affected material until the questions raised in part (1.) of this letter are resolved and information on the shipping container to be used is received from the shipping container manufacturer.

We request that the order be modified to allow sufficient time to meet the requirements of the designated receiver of the material to be shipped.

Sincerely,

" " d

. J. Cashwell Reactor Director RJC:mid XC: Executive Legal Director ohn Dosa Region til Administrator USNRC USNRC-Document Control Desk USNRC Washington, D. C. 20555 Washington, D. C. 20555 Glen Ellyn, IL 60137 Registered Mail, Return Receipt ha,/ LL ,, : /k h /f8Ay *l Ob l*

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SECRETARY NOTE FOR: Document Control Desk FROM: Correspondence & Records Branch The enclosed document (s) are to be entered into the DCS. An advanced has been sent to the Public Document Room.

Attached are three copies of documents to be entered into the system. One set is for DCS, one for PDR and the last is for Terry Barnhart who is to be entered on the distribution list for future documents on this subject. If you have any questions, please call Tom Combs, 4-3317.

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