ML20042A354

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Responds to NRC Re Violations Noted in IE Insp Repts 50-295/82-02 & 50-304/82-02.Corrective Actions: Procedure Change Made to RP 1520-1 Stating Acceptable Methods of Verification Must Precede Shipment of Matl
ML20042A354
Person / Time
Site: Zion  File:ZionSolutions icon.png
Issue date: 03/05/1982
From: Delgeorge L
COMMONWEALTH EDISON CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20042A352 List:
References
NUDOCS 8203230355
Download: ML20042A354 (2)


Text

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Commonwealth Edison

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) One Fir;I N:tional Pt rt. Chicago, illanois 4 (

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J Address Reply to: Post Office Box 767

' Chicago, Illinois 6%90 y

March 5, 1982 Mr. James G.

Keppler, Regional Administrator Directorate o f Inspection and Enforcement - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Zion Station Units 1 and 2 Response to I.E.

Inspection Report Nos. 50-295/82-02 and 50-304/82-02 NRC Docket Nos. 50-295 and 304 Reference (a):

February 3, 1982, letter from C. E.

Norelius to Cordell Reed.

Dear Mr. Keppler:

Reference (a) transmitted the results o f an inspection by Mr.

P.

C.

Lovendale of your of fice on January 18-19, 1982, o f acti-vities at Zion Station.

During that inspection, certain activities appeared to be in noncompliance with NRC requirements.

Attachment A to this letter provides Commonwealth Edison's response to the Notice of Violation contained in reference (a).

To the best of my knowledge and belief, the statements contained in this letter and the attachment are true and correct.

In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.

Such information has been reviewed in accordance with Company practice and I believe it to be reliable.

Please address questions regarding this matter to this office.

Very truly yours, L. O. DelGeo rge Director o f Nuclear Licensing 1m Attachment cc:

Zico Resident Inspector SUBSCRIBED and SWORN to before me this g d day of GMt 1982 11.6/-

Notary PuQlic

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a byproduct transferring tne ma er receipt af the type, tne licensee tne rerrea.

transferee's license autnorizesmatPrial to De trans of o y ;; r a d d C t and Q;1antity two shipments of licensee made without t' i r s t tre 5 tate licensee to the aoove, material to an Agreement receipt.

Contrary Dyprouuct license authorized verifying if their anc mesults Acnievec Taxen (NNC) ana Corrective sction Nuclear Corporation contacteo National inspection of NNC's eased on receive Tne licensee ootained a copy of its license, was authorized to tnat NNL have

iicense, material sent April 15, 1981, out woula not was determined the Dyproduct receive tne SJU ti of mixed fission prooucts it to dutnorized oeen sent August 21, 1981 tne reinstructea on p,ysicists were titiec "uft-site 1;z0-1, licensee's heattn Procedure H requires tnat oetore R

The in Hadiation Material", which verity tnat tne provisionso f Radioactivematerial, the licensee of Snigment ano amount transferring byproduct receive the type receiver is licensed to HP 1520-1 furtner states raoicactive metnaas o f verification are listed in ;J CFx material oeing snippec.

r e -re v i e we a nave acceptaalt licensee's health pnysicists ad part of tnis reinstruction.

tnat The 30.41(d) 3U.91(c) section l ')

CFn No n-Comp l i a nc e Ac t i o n To de Ta<en to Avoid Furtner exDiicitly state Corrective to RP 1 520-1 will De made tort tne change to verification A proceaure a c ce;,t aole me tn o a o f amount of tnat tne most eceive tne type ano nc r eaci':,

oossession a

receiver is licenseo *.

isDy Dei;g snippeu, 1 cense 3:

raoladctive material nsferee's specific 1

of a current copy af the tra certific-te registrdti0n Uate Wnen Full Compliance Ail i ce Met

'ne time Ine licensee is in fall compliance at the present t 3m;31 e t e c will ce change to HP iSCO-1 aescrioed aoave proceaure Dy May 1,

19e2 3573N

ATTACHMENT A I

Response to Notice o f Violation Violation b

10 CFR 30.41(c) states, in part, that before transferring byproduct material to a specific licensee o f an Agreement State, the licensee transfurring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.

Contrary to the above, the licensee made two shipments o f byproduct material to an Agreement State licensee without first verifying if their license authorized receipt.

Corrective Action Taken and Results Achieved The licensee contacted National Nuclear Corporation (NNC) and obtained a copy of its license.

Based on inspection of NNC's license, it was determined that NNC was authorized to receive the byproduct material sent April 15, 1981, but would not have been authorized to receive the 500 C1 of mixed fission products sent August 21, 1981.

The licensee's health physicists were reinstructed on the provisions in Radiation Procedure RP 1520-1, titled "Off-site Shipment o f Radioactive Material", which requires that before transferring byproduct material, the licensee verify that the receiver is licensed to receive the type and amount o f radioactive material being shipped.

RP 1520-1 further states that acceptable methods o f verification are listed in 10 CFR 30.41(d).

The licensee 's health physicists have re-reviewed section 10 CFR 30.41(d) as part o f this reinstruction.

Corrective Action To Be Taken to Avoid Further Non-Compliance A procedure change to RP 1520-1 will be made to explicitly state that the most acceptable method of verification that the receiver is licensed to receive the type and amount of radioactive material being shipped, is by possession and reading of a current copy of the transferee's specific license or registration certificate.

Date When Full Compliance Will Be Met The licensee is in full compliance at the present time.

The procedure change to RP 1520-1 described above will be completed by May 1, 1982.

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