ML18096A148
| ML18096A148 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 07/18/1991 |
| From: | Labruna S Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLR-N91124, NUDOCS 9107240170 | |
| Download: ML18096A148 (4) | |
Text
Public Service Electric and Gas Company Stanley LaBruna Public Service Electric and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-4800 Vice President - Nucleor Operations JUL l ~ 1991 NLR-N91124 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-272/91-13 AND 50-311/91-13 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas (PSE&G) has received the Inspection Report dated June 17, 1991.
Within the scope of this report, one apparent violation of NRC requirements was identified.
The violation involved one example of failure to comply with the requirements of 10 CFR 30.41.
Pursuant to the requirements of 10 CFR 2.201, PSE&G hereby submits its response to the notice of violation.
Should you have any questions in regard to this transmittal, do not hesitate to call.
Sincerely, Attachment
.*. Ur\\ I
//,.
!..,.t;
/'
\\
I \\ \\
Document Control Desk NLR-N91124 C
Mr. J. C. Stone Licensing Project Manager Mr. T. Johnson Senior Resident Inspector 2
Mr. T. Martin, Administrator Region I Mr. Kent Tosch, Chief New Jersey Department of Environmental Protection Division of Environmental Quality Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 JUL J. 1'. l~l
.NLR-N91124 ATTACHMENT During an NRC inspection conducted on May 13-17, 1991, a violation of NRC requirements was identified.
In accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the violation is listed b~low:
10 CFR30.41 (c) states, in part, that before transferring by-product to a specific licensee of the commission, the licensee transferring the mater.ial (transferor) shall verify that the transferee's license authorizes the receipt of the type, fopn, and quantity of by-product material to be transferred.
10 CFR 30.41(d) provides five methods acceptable to the NRC for
.verification as follows:
(1)
(2)
(3)
(4)
(5)
The transferor may have in his possession, and read, a current copy of the transferee's specific license; The transferor may have in his possession a written certification by the transferee that he is author1zed by license or registtation c~rtificate to receive th* type, form and quantity of by-product material to be transferred; For emergency shipments, the transferor may accept oral ceitification by the transferee that he is authorized by license or registration certificate to receive the type, form, and quantity of by-product material to be transferred provided, that the oral certification is confirmed in writing ~ithin 10 days; The transferor may obtain other sources of information compiled by reporting services from official records by the Commission or the licensing agency of an Agreement State as to the identity of licenses and t.he scope and expiration date of licenses anq registration; or When none of these methods of verification described above are readily available or when a transferor desires to verify that information received by one of the above methods is correct or up-to-date, the transferor may obtain and record confirmation from the Commission or licensing agency of an Agreement State that the transferee is licensed to receive the by-product material.
Contrary to the above, on September 18, 1990, the licensee transferred 20 microcuries of by-product material contained in shipment No. 90-57 (reactor coolant pump motor) to a vendor and the licensee did not verify that the transferee's license authorized the receipt of type, form, and quantity of by-product material transferred.
PSE&G DOES NOT DISPUTE THE VIOLATION ROOT CAUSE The root cause of this event was determined to be procedure inadequacy based on regulatory policy misinterpretation.
In accordance with the guidance given by the Letters of Consideration for Part 30, dated September 1, 1991, PSE&G personnel did not believe that all the documentation required by 10 CFR 30.41 (d) was required in this particular instance.
PSE&G's program and interpretation of the regulations is (was) consistent with other's licensee's program for shipment of radioactive materials.
The reactor coolant pump motqr was shipped only after PSE&G, in good faith, had verified that the vendor was authorized to receive the shipment.
PSE&G telephoned the vendor asking the status of their license since the PSE&G's file copy had already expired.
PSE&G was informed by the vendor that a renewal had been submitted to the NRC and that, per official NRC documentation, the license that PSE&G had on file would remain valid until issuance of the license renewal.
PSE&G did not document t~e call nor obtain a copy of the license renewal submittal.
PSE&G believes that there was no safety significance associated with this violation as defined by 10 CFR 2, Supplement VII.
CORRECTIVE ACTIONS TAKEN Upon notification of this discrepancy, copies of letters regarding the vendor's license to receive radioactive material at its facility were obtained.
These documents will remain on file until the renewed license is issued by the Commission.
This action was completed on May 14,1991.
A review of all other licenses was performed to insure proper documentation existed on file.
No other discrepancies with expired licenses were found.
This review was completed on June 4, 1991.
All Radiation Protection personnel responsible for shipping radioactive materials from Salem were appraised of this issue and the requirements of 10 CFR 30.41.
This action was completed on June 4, 1991.
CORRECTIVE ACTIONS TAKEN TO PREVENT RECURRENCE A revision to Radiation Protection procedure RP 909 was submitted on June 4, 1991.
The procedure revision will require that prior to shipment of any radioactive material, a valid license be on file or an official confirmation from the Commission is obtained stating that the transferee is licensed to receive the radioactive material.
This revision will be completed by September 3, 1991.
PSE&G IS IN FULL COMPLIANCE