ML20002A909
| ML20002A909 | |
| Person / Time | |
|---|---|
| Site: | 02700047, FitzPatrick |
| Issue date: | 10/28/1980 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Pasternak R POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK |
| Shared Package | |
| ML20002A910 | List: |
| References | |
| NUDOCS 8012090149 | |
| Download: ML20002A909 (1) | |
See also: IR 015000039/1980014
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UNITED STATES
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Docket No. 50-333
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Power Authority of the State of New York
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James A. FitzPatrick Nuclear Power Plant
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ATTN: Mr. R. J. Pasternak
Resident Manager
P. O. Box 41
Lycoming, New York 13093
Gentlemen:
Subject:
Inspection 50-333/80-14
This refers to your letter dated September 18, 1980, in response to
our letter dated September 3,1980.
Thank you for informing us of the corrective and preventive actions
documented in your letter. These actions will be examined during 1
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subsequent inspection of your licensed program.
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Your cooperation with us is appreciated.
Sincerely,
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Geo ge
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F cility and Materials
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George T. Berry, President and Chief Operating Officer
J. P. Bayne, Senior Vice President-Nuclear Generation
A. Klausmann, Director, Quality Assurance
M. C. Cosgrove, Site Q,tality Engineer
J. F. Davis, Chairman, Safety Review Committee
C. M. Pratt, Assistant General Counsel
G. M. Wilverding, Manager-Nuclear Licensing
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POWER AUTHORITY OF THE STATE OF NEW YORK
.IAMES A. FIT 2 PATRICK NUCLEAR POWER PLANT
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RAYMOND J. PASTERNAK
P.O. Box 41
Res; dent Meneger
Lycoming, New York 13093
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315-342 3840
September 18, 1980
SERIAL:
Mr. Boyce H. Grier
United States Nuclear Regulatory Commission
Region I
631 Park Ave.
King of Prussia, PA 19406
Subject:
INSPECTION NO. 50-333/80-14 (15000039/80-14)
Dear Mr. Grier:
With reference to the inspection conducted by Mr. T. C. MacArthur of your
Region II office on June 19, 1980 at the Chem-Nuclear Systems, Inc., and in
accordance with the provisions of Section 2.201 of Part II of Title 10 of the
Code of Federal Regulations, we are submitting our response to Appendix A_ Notice
of Violation transmitted by your letter dated September 3,1980 as received by
the undersigned on September 11, 1980.
APPENDI.T A
Based on the results of an NRC inspection conducted on June 19, 1980 of the
shipment of radioactive waste which was shipped from your facility on or about
June 17, 1980, it appears that one of your activities was not conducted in full
compliance with federal regulations and the conditions of your NRC facility
license DPR-59 as indicated below.
10 CFR 71.5 prohibits delivery of licensed material to a carrier for transport
unless the licensee complies with applicable regulations of the Department of
Transportation in 49 CFR Parts 170-189.
49 CFR 173.392(c)(8) requires that the outside of each package of low specific
activity radioactive materials transported in a sole use vehicle must be stencilled
or otherwise marked " Radioactive LSA".
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JAFP-80-
Contrary to the above, on or about. June 17, 1980, the licensee delivered a
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. package of low specific activity (LSA) radioactive licensed material to a
carrier for transport to the waste burial site on a tractor-trailer assigned for
sole use and upon arrival at the burial site on June 19, 1980, the outside of
the package (a Model 14-195-H, Number 10 shipping cask) was not stencilled or
otherwise marked " Radioactive-LSA" to identify the contents.
This is a Severity Level IV noncompliance.
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While we cannot dispute the condition of the vehicle upon arrival, we can
. provide evidence that the vehicle was properly placarded and labeled immediately
prior to leaving the Fit: Patrick plant. We do recognize our responsibilities as
the " shipper", however, it should be pointed out that 49 CFR 176.33 and 177.815
require the " carrier" to replace label (s) that become lost or detached.
In
fact, we provided additional placards and labels to the carrier for the purpose
of replacement enroute on this occasion.
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This particular shipment record was reviewed and a copy is available for your
review at the plant. With regard to these records, the fo'. lowing is noted:
1.
The Chem-Nuclear Systems Inc. engineer responsible for preparing the concentrator
bottoms (solidifying) for burial verified, by his signature, that the
shipment, among other things, was properly marked and labeled. This is in
referene to the Barnwell Waste Management Facility shipment record.
2.
The technician responsible for preparing the shipment records, verified by
his signature that the shipment, among other things, was properly marked
and labeled. This is in reference to the Power Authority of the State of'
New York (PASNY) shipment record.
3.
The Home Transport Company driver verified by his initials that he was
tendered and acnepted, two each, additional " RADIOACTIVE" placards and
"RADI0 ACTIVE-LSA" labels. This was done to assure that the carrier would
have an adequate supply of replacement placards and labels to enable him to
conform with the requirements of 49 CFR 177.815. This is in reference to
the PASNY shipment record. The driver, also, verified that just prior to
leaving the site the vehicle and shipping cask were properly placarded and
labeled. This is in reference to the Driver Checklist / Security Checklist
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form.
4.
The driver was provided a one page instruction sheet, which among other
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things, instructed him that each outside package must be stencilled or
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otherwise marked " Radioactive - LSA".
Refer to Chem-Nuclear's " Notice to
Carrier", " Driver Instructions for Exclusive Use Vehicles" which is included
with each set of shipment papers.
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5.
The adhesive quality of the Radioactive - LSA labels used at James A.
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FitzPatrick Nuclear Power Plant was recently tested by placing and removing
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one from an LSA cask.
It was determined that these labels are very difficult
to manually remove and it would be highly unlikely that inclement weather
conditions enroute could result in the removal of both labels that were and
are attached to each LSA package shipped from this plant.
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JAFP-80-
The system of checks just described provides reasonable assurance that the cask
referred to in this inspection was properly labeled prior to leaving this site.
To ensure that future shipments display the proper placards and labels enroute
and at it's destination, Plant Standing Order No. 18 Exhibit 9.1 will be revised.
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This exhibit pertains to a statement prepared by PASNY instructing the carrier
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driver to follow specified routes, to call the plant SS if delayed and to not
tamper with the contents of the shipment.
This statement shall be read and
signed by the driver. We will add to this statement instructions to the effect
that the vehicle be inspected after each significant stop (rest, fuel, food,
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etc) to ensure that it remains properly placarded, the package (s) properly
labeled (if visible) and the cargo area properly sealed (if required).
This added statement will be placed in the procedure, the procedure revision
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approved and issued no later than October 31, 1980.
Very truly yours,
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Raymond J. Pasternak
Resident Manager
CC:
G. H. Smith - NRC
G. T. Berry - NYO
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J. P. Bayne - NYO
A. Klausmann - NYO
J. F. Davis - NYO
C. M. Pratt - NYO
G. M. Wilverding - NYO
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R. Baker
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M. C. Cosgrove
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E. A. Mulcahey
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Document Control Center
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