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Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Waste Packaging Insp Rept 15000039/79-08E
	ML19344A960
Person / Time
Site:	02700047, Quad Cities
Issue date:	04/21/1980
From:	Davis A; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Reed C; COMMONWEALTH EDISON CO.
References
	NUDOCS 8008250216
	Download: ML19344A960 (2)
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Docket No. 5C-254

Consonwealth Edison Company

ATTN: Mr. Cordell Reed

Vice President

Post Office Box 767

Chicago, IL 60690

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Gentlemen:

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This is in reply to your letter of March 18, 1980 in response to our

Notice of Violation dated February 22, 1980. As discussed below, we do

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not accept your position that the noncompliance did not occur. Please

review your position and respond, as requested in our February 22, 1980,

1etter, to the following:

(1) corrective action taken and the results

achieved; (2) corrective action to be taken to avoid further noncom-

pliance; and (3) the date when full compliance will be achieved.

According to 49 CFR 173.392(c)(8) the outside of each outside package

must be marked " Radioactive - LSA."

49 CFR 171.8 defines "Outside Pack-

age" as the assembly of one or more containers necessary to assure com-

pliance with the requirements of 49 CFR 110-189. As stated in your letter

of March 18, 1980, the HN-100 cask was used as shielding, presumably to

meet the radiation level requirements of 49 CFR 173.393(j)(3) and (4).

We therefore conclude that the HN-100 cask was a necessary "Outside

Package" which required marking in accordance with 49 CFR 173.392(c)(8),

as stated in our February 22, 1980, Notice of Violation.

This noncompliance was incorrectly classed as Severity Level III. This

is a Severity Level IV noncompliance.

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Compassalth Edison Company

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We will gladly d4 - s any fu ther quantimas you have concerning this

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matter.

Simcarely.

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A. 3. Davis, Chief

Feel Facility and

Materials Safacy Branch

ec w/Itr dtd 3/18/80:

Mr. D. L. Fooples, Director

of Euclear Licensing

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One F.rst Peones mara. cuaqo.16ewo_s

Accress Rapty to: Post Othee Boa 767

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March 18, 1980

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Mr. James G. Keppler, Director

Directorate of Inspection and

Enforcement - Region III

U. S. Nuclear Regulatcry Commission

799 Roosevelt Road

Glen Ellyn, IL

60137

Subject:

Quad Cities Station Unit 1

Response to IE Inspection

Report No. 15000039/79-08E

NRC Docket No. 50-254

.

Reference (a):

A. B. Davis letter to C. Reed

dated 2/22/80

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Dear Mr. Keppler:

Reference (a) transmitted the results of an inspection

conducted by Mr. R. A. Brown of Region II on December 19, 1979

and indicated that certain of our activities appeared to be in

noncompliance with NRC requirements.

Commenwealth Edison Co. has reviewed the information

pertaining to the items of inspection and we do not agree that

any items of noncompliance existed.

As indicated in the

attachment to this letter, we believe that the radioactive

waste shipment in question did in fact meet all applicable

requirements of 49 CFR Parts 170-189, as required by 10 CFR 71.5.

Please address any questions you may have concerning

this matter to this office.

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Very truly yours,

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D. L. Pe@les

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Director of

Nuclear Licensing

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ATTACHMENT

COMMONWEALTH EDISON CO.

NRC Docket No. 50-254

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Response to Notice of Violation

.

,

The item of noncompliance identified in Appendix A to

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the NRC letter dated February 22, 1980, is responded to in the

following paragraphs.

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1.

Notice of Violation

As required by 10 CFR 71.5,'no licensee shall transport any

licensed materi 1 outside of the confines of his plant or

other place of use, unless the licensee complies with

applicable requirements of the regulations appropriate to

the mode of transport of the Department of Transportation

in 49 CFR Parts 170-189.

Contrary the above, on December 19, 1979, the day of the

inspection, a cask shipped from your Quad-Cities facility

was not marked " Radioactive LSA" as required by 49 CFR

173.392(c)(8).

This is a Severity Level III noncompliance.

Discussion

A review of the information pertaining to the shipment

inspected on December 19, 1979 indicates that the shipment

was conducted in full compliance with NRC requirements.

The shipment of concern was shipment number QC 962 which

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departed the Quad Cities Nuclear Power Station on December

17, 1979.

A copy of the Raoicactive Shipment Record (RSR)

for QC 962 is found in Appendix A.

The shipment consisted of 14 55-gallon DOT Spec 17H drums

in an HN-100 Unit 6 cask.

The RSR specifically stated "The

drums serve as the packages."

Each drum was labeled

" Radioactive LSA" by the manufacturer, in complete

conformance with 49 CFR 172.200 and 172.400 labeling and

marking requirements.

No drum exeeded a Type A quantity,

and thus, all were in compliance with 10 CFR 71.7; each

being an adequate package far the material contained

within.

The packages were in compliance with the General

Packaging and Shipment Requirements of 49 CFR 173.393 and

Lcw Specific Activity Radioactive Material 49 CFR 173.392.

The HN 100 cask was employed solely for shielding

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purposes.

To label the cask " Radioactive LSA" would be

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misleading, giving the incorrect impression that the cask

was the package.

This is equivalent to labeling as

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" Radioactive LSA", any shield or vehicle structure that

encloses packages of LSA material.

49 CFR 172.392(c)(8)

states "The outside of each outside package must be

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stenciled or otherwise marked ' Radioactive LSA'.7

The only

packages employed in the specified shipment, 14 17H 55

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gallon drums, were suitably marked.

No violation of

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applicable regulations existed with this shipment.

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ML19344A960

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