IR 05000244/1986015
| ML17251A879 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/19/1986 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Kober R ROCHESTER GAS & ELECTRIC CORP. |
| References | |
| NUDOCS 8612020443 | |
| Download: ML17251A879 (4) | |
Text
NOV 19 1S86 Docket No. 50-244 Rochester Gas and Electric Corporation ATTN:
Nr. Roger W.
Kober Vice President Electric and Steam Production 49 East Avenue Rochester, New York 14649 Gentlemen:
Subject:
Inspection No. 50-244/86-15 This refers to your letter dated October 8, 1986, in response to our letter dated September 8,
1986.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined during a future inspection of your licensed program.
With reference to your response to Item A of Appendix A of our letter, the violation will remain as stated.
Accurate identification and characterization of a waste stream is a routine analytical task.
The Fe-55 should have been identified when initial characterization studies were made.
Limiting the characterization studies to radionuclides identified in tables of 10 CFR 61 was inappropriate since the results of the study were to be used to demonstrate compliance with 10 CFR20,
CFR 71,
CFR 172, as well as that of
CFR 61.
CFR 172.203(d)(i) requires that the nuclides listed in 49 CFR 173.435 be identified.
Fe-55 is one of the nuclides listed in 49 CFR 173.435.
Further, the NRC Branch Technical Position of May ll, 1983, that is referred to in your response does not apply to requirements of the Department of Transportation dealing with transportation, but only to NRC requirements of
CFR 20.311 having to do with the classification of wastes for burial purposes.
This violation could have been avoided by appropriate attention to transportation regulatory requirements.
With reference to your response to Item B of Appendix A of our letter, we withdraw this violation based on the new information that you provided.
Two concerns need to be mentioned, however.
First, as pointed out in the inspection report, responsible licensee personnel in the radwaste area were not aware of the use of the procedures that were identified in your response to our letter.
Your radwaste staff should be aware of how procedures are used to comply with quality control requirements.
Second, as stated in the Notice of Violation, your Administrative Procedure A-1001 requires quality requirements obtained from regulatory requirements be included in quality control inspection procedures.
As described in your response, the quality requirements are not contained in your quality control inspection procedures but are contained elsewhere.
These quality requirements should be contained in your quality control inspection procedures.
We will Sb12020443 PDR ADOCK
. OFFICIAL RECORD COPY 8b1119 05000244 PDR RL GINNA 86-15 0001.0.0 11/18/86 (
I
J
Rochester Gas and Electr ic Corporation change our records to indicate this violation has been withdrawn and that the two concerns identified above will be reviewed during a future inspection (244/86-15-02).
Your cooperation with us is appreciated.
Sincerely, Division of Radiation Safety and Safeguards Stat CC:
Harry H. Voigt, Esquire Central Records (4 copies)
Director, Power Division Public Document Room (PDR)
Local Public Document Room Nuclear Safety Information NRC Resident Inspector e of New York (LPDR)
Center (NSIC)
Region I Docket Room (with Management Assistant, DRMA DRP Section Chief Robert J. Bores, DRSS
'oncurrences)
(w/o encl)
RI: DRSS Clemons/gcb 11/
/86 I.
SS RI: DRSS s iak Bellamy 11/($ /86 11/ I(/86 11/(f/86 OFFICIAL RECORD COPY RL GINNA 86-15 0002.0.0 11/18/86
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