ML19321A593

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Responds to Notice of Violation & Notice of Proposed Imposition of Civil Penalties,Transmitted by NRC . Util Administrative Procedure for Radwaste Shipments Revised to Require Instrument Surveys.Penalty Payment Encl
ML19321A593
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/27/1980
From: Conway W
VERMONT YANKEE NUCLEAR POWER CORP.
To: Stello V
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
EA-80-022, EA-80-22, NUDOCS 8007230695
Download: ML19321A593 (2)


Text

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Deek K SD-M l VERMONT YANKEE NUCLEAR POWER CORPORATION P. O. BOX 157 GOVERNOE HUNT ROAD VERNON, VERMONT 05354 gA.go - 2,2, VY-5675 pog G.2 2o 27 May 1980 United States Nuclear Regulatory Cor: mission Washington, DC 20666 Attention:

Mr. Victor Stello, Jr., Director Office of Inspection and Enforcement

References:

(a)

Licensee No. DPR-28 (Docket No. 50-271)

(b) USNRC letter dated May 7, 1980 (c) USNRC Inspection Report No. 50-271/80-03 dated May 9, 1980 (d) USNRC Inspection Report 15000046/80-19 dated February 27, 1980

Subject:

" Notice of Violation" and " Notice of Proposed Imposition of a Civil Penalty"/Radicactive Waste Ship::Kat to Richland, Washington.

Dear Sir:

This letter, together with the attachment is intended to respond to your letter of Reference (b) and to the attachments to that letter namely, Appendix A, identified as " Notice of Violation" and Appendix B, identified as " Notice of Proposed Imposition of a Civil Penalty".

Please be assured that the Vermont Yankee Nuclear Power Corporation recognizes the seriousness of the events surrounding the shipment of (LSA) radioactive wastes to Richland, Washington-in February 1980.

Procedure changes have already been implemented to preclude future occurrences. of this letter sets forth in detail our response to your " Notice of Violation". Th.s attachment also describes an error in the " Notice of Violation".

We trust that you will find this letter together with the attachment responsive to your requirements.

Respectfully submitted, VERMONT YANKEE NUCLEAD. POWER CORPOPATICN

/

W. F. Conway Vice President & Manager of Operations WFC/caf Attachment 8007230QS

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Answer to Notice of Violation & Notice of Proposed Imposition of a Civil Penalty Dated Mav, 7 1980 Contrary to the statement in the " Notice of Violation", the shipment was an exclusive use shipment made under the provisions of 49 CFR 173. 393. (j ). As previously stated, the trailer was incorrectly surveyed, thus allowing the trailer to proceed in violation of 49 CFR 173.393(j).

As described in References-(b), (c), and (d), Shipment 80-02 was incorrectly surveyed prior to its release for shipment to Richland, Washington. This resulted in the failure to detect radiation levels at the external surface of the trailer that were in excess of the 200 millirem / hour limit stated in 49 CFR 173.393.j (2).

Previously, Vermont Yankee did not coesider the underneath portion of the trailer or the top portion of the trailer to be accessible areas and as such did not survey those areas.

In accordance with the " Corrective Action" described in Reference (c), the Vermont Yankee Administrative Procedure AP 0504 covering ship-ment of radioactive waste, has been revised to require surveys of all areas of a shietent.

In addition, thi-s orocedure was revised to clarify the instructions necessary to maintain exclusive use shipment controls.

This revision was issued as Department Instruction 80-1 on February 15, 1980. Full compliance was achieved by this revision and no further action is determined to be necessary.

Enclosed is a check for $4,000.00 as required by the " Notice of Proposed Imposition of a Civil Pencity".

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