ML19340D527
| ML19340D527 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/08/1980 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19340D526 | List: |
| References | |
| 786, NUDOCS 8012310038 | |
| Download: ML19340D527 (3) | |
Text
y VIllOINIA ELECTitIC AND PowEle ConrAxy RicxxxoNo,VznorszA noust October 8, 1980 Mr. James P. O'Reilly, Director Serial No. 786 Office of Inspection and Enforcement N0/RMT:ms U. S. Nuclear Regulatory Commission Docket No. 50-338 Region II 101 Marietta Street, Suite 3100 License No. NPF-4 Atlanta, Georgia 30303
Dear Mr. O'Reilly:
We have reviewed your letter of September 15, 1980 in reference to the inspection conducted at North Anna Power Station on June 19, 1980 and reported in IE Inspection Report No.
50-338/80-31.
Our response to the specific infraction is attached.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company has no objection to this inspection report being made a matter of public disclosure.
Very truly yours, f
/
B. R.
ylvia Manager - Nuclear Operat. ions and Maintenance Attachment cc:
Mr. J. Philip Stohr, Chief Fuel Facility and Materials Safety Branch Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing i"-..,
801281o % )
Attachment Page 1 NORTH ANNA POWER STATION RESPONSE TO NOTICE OF VIOLATION NRC Comment:
As required by 10 CFR 71.5, no licensee shall deliver licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Page 170-189. 49 CFR 173.392(c)
(8) states that the outside of each outside package must be stencilled or otherwise marked " Radioactive - LSA."
Contrary to the above, on June 19, 1980, the licensee delivered radioactive material to the Home Transportation Company trailer #035 (SSR #020845) without the prescribed marking.
This is Severity Level IV violation.
Response
The violation is not correct as stated.
1.
Four individuals, including a Senior Quality Assurance Inspector, an Assistant Health Physics Supervisor, a Step 7 Health Physics Technician and the Supervisor of Health Physics observed the cask prior to shipment on June 18, 1980.
All four individuals confirmed that, at that time, shipment number 06-80-729A was properly labeled.
Conditions normally experienced during transport may have removed the placards, i.e., adverse weather conditions.
2.
The Code of Federal Regulations Title 49 Transportation revised as of October 1,1979, Part 172.516 " Visibility and Display of Placards'." (6).
"Be maintained by the carrier in a condition so that the format, legibi-lity, color, and visibility of the placard will not be substantially reduced due to damage, deterioration, obscurement by dirt or other matter" 3.
NRC IE Informatien Notice No. 80-32 dated August 29, 1980, Appendix B, Scenario (1) states:
"The inner packaging may be considered to be the " Package" provided the outer enclosure is not necessary to achieve compliance with the radia-tion level limit of 173.393 (j) (2)."
4.
The cask was used only because Chem-Nuclear Services Incorporated, requested that dewatered resins be transported in a transport container.
There was no regulatory basis for using a type B cask, or any other transport cask.
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5.
The licensee contends that the cask and liner were properly placarded, prior to the vehicle leaving the control area of Virginia Electric and Power Company's North Anna Power Station.
Furthermore, the licensee maintains that they cannot be responsible for the transport vehicle after the vehicle leaves our control area.
6.
The licensee further contends that the violation is not warranted.
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