ML17258A516

Responds to NRC 811130 Ltr Re Violations Noted in IE Insp Rept 50-244/81-16.Corrective Actions:Drum Lifting Device Replaced W/Passive Sys Designed to Grip Drums from Side & Not from Lip of Drum

ML17258A516
Person / Time
Site:	Ginna
Issue date:	12/28/1981
From:	Maier J ROCHESTER GAS & ELECTRIC CORP.
To:	Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML17258A514	List: ML17258A516
References
NUDOCS 8202090252
Download: ML17258A516 (7)

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ROCHESTER GAS AND ELECTRIC CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649

"'OHN E. MAIER TELEPHONE VICE PRESIDENT ARK* coDE Tld 546.2700 December 28, 1981 Mr . Ronald C. Haynes, Director U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA 19406

Subject:

I&E Inspection Report No. 81-16 Notice of Violations Failure to Meet 49 CFR 173. 392 (c) (1)

R. E. Ginna Nuclear Power Plant, Unit No. 1 Docket No . 50-244

Dear Mr. Haynes:

In accordance with the above subject which stated:

"As a result of the inspection conducted on July 10, 1981 by the State of Nevada Resident Inspector at the U.S. Ecology, Beatty, Nevada Burial Site of the shipment of LSA radioactive waste which was shipped from the Rochester Gas and Electric Company's facility in Ontario, New York on July 6, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980), the following was identified:

10 CFR 7 1.5 prohibits delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Trans-portation in 49 CFR Parts 170-189.

49 CRT 73.392 (c)(1) states, "Material must packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation."

Contrary to the above, on July 6, 1981, the licensee delivered to a carrier for transport to the U.S. Ecology, Beatty, Nevada burial site, licensed material (LSA radioactive waste) in a container that was not a strong, tight package. There was a hole in the side of the 55-gallon drum used as the shipping container (Package No. 1034).

the following is submitted in response.

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ROCHESTER GAS AND ELECTRIC CORP. SHEET NO. 2 DATE December 28, 1981 To Ronald C. Haynes Please note the following referenced correspondence dated August 10, 1981 to the State of Nevada, Department of Human Resources, Division of Health, Attn: Mr. John Vaden, Supervisor of Radiological Health and subsequent October 12, 1981 response to Mr. John E. Maier, Vice President of Rochester Gas and Electric from Mr. John Vaden of Nevada.

Very truly yours, John E. Maier Subscribed and sworn to me on this 28th day of December, 1981.

SHARON G. CAVALERI NOTARY PUBLIC, State of II. Y., Monroe County My Commission Expires March 30, 19,gg SECr<"'r A2 I:3C

U;S NRC REGlON X hl 5K 30 Ptl l 52

oc: L. D. White, Jr.

L. S. Lang

'e B. A. Snow F. J. MIs ROCH ES TER GAS AND ELEC TRI C CORPORATION ~ 89 EAST AVENUE, ROCHESTER, N.Y. 14649 JOHN E. MA IER TCLCPHONC VICE PRESIDENT ARCA CODC Tle 546-2700 August 10, 1981 Mr. John Vaden Supervisor, Radiological Health State of Nevada Department of Human Resources 505 East King Street Carson City, Nevada 89710

Dear Mr. Vaden:

In response to your July 16, 1981 letter, please find enclosed our corrective action being submitted for your review. The effort put forth is of a two phased approach. The first is the removal of the equipment that caused the breach of integrity on the drum. The drum lifting device has been replaced with a more passive system designed to grip the drums from the side and not from the lip'of the drum. This can be seen by the attached pictures.

Secondly, the procedures have now been revised to include exten-participation by Quality Control. As can be determined by the proce- 'ive dure, the inspector views the container prior to being loaded on the truck and after it has been placed on the vehicle.

This double check system will prevent containers from being loaded on the vehicle that were damaged after the. initial inspection.

The Corporate Quality Assurance program is designed to monitor the work of the plant Quality Control program along with other departments involved in shipping.

The Corporate Quality Assurance performs regular audits of .all the involved departments to insure compliance. This serves. as a further check.

I trust these changes are acceptable and that we may resume ship-ments upon receiving authorization from your office.

Sincerely, Jo n E. Maier Enclosures

STATE OF NEVADA DEPARTMENT OF HUMAN RESOURCES D lVISlON OF H EALTH BUREAU OF CONSUI4KR HKAI TH PROTKCTION SERVICES 505 EAST KINO STRKCT 520 BCLROSC STRCKT LAS VCOAS. NCVAOA 88l58 CARSON CITY, NCVAOA 897IO TKLCRNONCi (702) 385 024l TKLCRHONKI 'l702I 885 475Ckr 4

October 12, 1981 John E. Maier, Vice President Rochester Gas and Electric Corporation 89 East Avenue Rochester, New York 14649

Dear Mr. Maier:

Me have received a requalification inspection audit of the Ginna facility performed by Nevada Inspection Services on September 30, 1981.

Our review of their report indicates that the revised quality control procedures mentioned in your letter'of August 10, 1981, appear to be effective.

Therefore, as of this date Rochester Gas and Electric Corporation is again allowed to ship radioactive waste to the Nevada State disposal site.

Sine'erely, ohn Vaden, Supervisor Radiological Health JV/jc cc: Nevada Inspection Services Steve Carpenter, Site Manager, U.S. Ecology, Inc.

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