ML19350E834

Responds to NRC 810427 Ltr Re Violation Noted in IE Insp Rept 50-298/81-04.Corrective Actions:Meeting W/Nv State Health Dept Officials Conducted on 810121 & 22.New Procedure for Bldg Radwaste Shipping Containers Implemented

ML19350E834
Person / Time
Site:	Cooper
Issue date:	05/27/1981
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Brown G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML19350E828	List: ML19350E834
References
LQA8100060, NUDOCS 8106230567
Download: ML19350E834 (3)

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LQA8100060 May 27, 1981 Mr. Glen D. Brown, Chief Technical Inspectior. Branch U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 16011 Subj ect: NPPD Response to IE Inspection Report No. 50-298/81-04

Dear Mr. Bro 9n:

This letter is written in response to your letter dated April 27, 1981, and the subsequent inspection report number 50-298/81-04.

Statement of Violation 10CFR71.5, requires that licensed material, felivered to a carrier for transport, meet applicable requirements of the De "rtment ef Trans-portation. 49CFR173.393(n)(2), requires that pac:. ging for shipments be in an unimpaired physical condition except for superficial marks.

Contrary to this requirement, package number 80-12-943 was found to contain several badly damaged areas and one 5x8 inch hole through which a piece of metal was protruding at the time of the inspection on January 19, 1981.

Discussion

he above statement of violation references 49CFR173.393(n)(2), " General

?ackaging and Shipment Requirements".

(n) " Prior to each shipment of any package, the shipper shall insure by examination or appropriate test that:"

(2) "The package is in unimpaired physical condition except for superficial marks:"

We did visually inspect the subject package number 80-12-943 during its loading and found it free of defects. The penetration occurred during transport between Cooper Nuclear Station and the Beatty, Nevada, vaste disposal site.

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Mr.. Glen D. Brown,' Chief '

May.27,~1981 Page 2

.The subject shipment and package was LSA radioactive material. shipped.

in a transport vehicle consigned.as. exclusive use. We feel this type shipmenefis exempted from the stated regulation, 49CFR173.393, by 49CFR173.39)(b), which exempts it from specification packaging, marking,

.;;hy / ,and'labe'lfng. Even though the inspector found no. leakage of radio-active. material above the limitations as indicated in the inspection report, had the contents of the package been highly contaminated, there was a potential' violation of 4ICTR173.392(c)(1), " Materials must be ,

packaged in strong, tight packages so' that there will be no leakage ,

of: radioactive material under conditions normally incident to trans- '

portation." Therefore, even though we feel there was no actual vio-

-lacion,.the potential for'a violation did exist and we have taken cor-rective steps to rectify this potential.

Corrective Steps Taken and Results Achieved 4

Upon notification of the incident at the Beatty facility, Cooper Nuclear '

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Station's Chemistry.and Health Physics Supervisor and the Quality. As-

.surance Supervisor arranged to visit the Beatty site and to discuss the 4 -incident with Nevada' State Health Department officials. Our personnel arrived at the Beatty facility January 21, 1981. They inspected the subject package and discussed the problem with the state inspector, Mr. B. Gray, who conducted the referenced inspection, and U.S. Ecology management at the facility. The Cooper Station personnel then went to Carson City and on January 22, 1981 met with Mr. J. Vaden and Mr. A. Edmundson of the Nevada State Health Department.

It was agreed by the Cooper personnel, the individuals at the Beatty site, and the Health Department officials that the problem was caused by the placement of materials within the package and that the package

!*self was of sufficient construction. A piece of "H" beam was placed t_

i the package with a 1 x 4 inch lif ting lug protruding down. If the 4

beam would have been rotated 180 degrees such that the lif ting lug was on top, the penetration would not have .resulted. '

Correct Steps Taken to Avoid Further Violations While we believe that the construction of the wooden waste container was sufficient, Procedure 7.9.1, " Building Radwaste Shipping Containers",

was written and approved. We feel this procedure will provide the

, control to assure such wooden shipping containers are all constructed 2-the same and continue to meet our specifications.

Procedure 7.9.2, " Filling Radwaste Containers With Waste", was written

.and approved to control the filling of the wooden containers. This procedure outlines the steps and inspection to be performed during the filling process. We feel this procedure sufficiently addresses the

. items of concern and will avoid recurrence.

Copies of these procedures were sent to Mr. J. Vaden. He found them acceptable and reinstated our 3eatty Use Permit. Members of the USNRC Region IV Office and our NRC Resident Inspector, Mr. D. DuBois, also reviewed and found these procedures acceptable. Inspector DuBois also performed an extensive inspection on the following waste shipment and found-our efforts acceptable.

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-Mr. Glen D. Brown, Chief May 27, 1981

.Page 3 Date When Ful?.' Compliance Will Be Achieved The approval of the above mentioned procedures and the inspection of the subsequent following radioactive waste shipment was completed on February 26, 1981.

Wo. hope that you'will find our explanation and efforts satisfactory. If you have any questions regarding.this response, please contact us.

Sincerely, b.

M. Pilant Director of Licensing and Quality Assurance JMP:JVS:cmk

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