ML20055E709
| ML20055E709 | |
| Person / Time | |
|---|---|
| Issue date: | 12/29/1989 |
| From: | Lickus R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Cooper J ILLINOIS, STATE OF |
| Shared Package | |
| ML20055C180 | List: |
| References | |
| FOIA-90-144 NUDOCS 9007120273 | |
| Download: ML20055E709 (7) | |
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December 29, 1989 Illinois Department of Nuclear Safety ATTN:
Mr.' John Cooper, Manager Office of Environmental Safety 1035 Outer Park Drive-Springfield, IL 62704
Dear John:
I have enclosed a copy of a recently issued Pennsylvania inspection report that documents the results of their low-level waste packaging and transportation inspections.
I thought that this might be helpful in developing your reports.
I have also included a copy of the Subagreement I implementing procedures that we discussed.
Please sign the implementing procedure on page six and return it to me.
I will have the appropriate NRC official sign the document and forward the completed procedures to you.
Please contact me if you have any questions.
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Sincerely, u
Poland Lickus, Chief State and Government Affairs
Enclosures:
As stated-bec w/o enclosures:
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l-IMPLEMENTING PROCEDURES-SUBAGREEMENT I. PERTAINING 10 LOW-LEVEL.
RADIDACTIVE WASTE PACKAGE'AND TRANSPORTA110N INSPECTIONS' l
BETWEEN THE STATE OF ILLINDIS AND THE NPC 1,
1 PAINING-A.
Illinois Staff Attendance at NRC Sponsored Courses.
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1.
Illinois staff may attend NRC sponsored training courses-when mutually agreed upon by 1111nois and NRC.
2.
Attendance at any particular course will-be scheduled on J
a space available basis.
3.
Staff applying for. attendance _must fulfill any necessary course prerequisites.
4.
Attendance will normally be limited to 1-2 individuals at any one particular course.
5.
Illinois will pay any transportation an.d per. diem expenses.
except for courses of fered in connection with the Agreement State Program where NRC pays for travel and'per diem of State personnel selected to attend.
B.
On-The-Job Training L
1.
On-the-job training will be made available to the Illinois staff in the conduct of inspections to deterraine compliance with~
the requirements in 10 CFR Parts 20, 61.and 71.-
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Any training accompaniments will nomally be limited to NRC
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licensees located in the State of Illinois.
3.
Any training accompaniments will follow a standard accompaniment protocol. Under the protocol, the activities of the individual accompanying the NRC inspector will be limited to observation p
and familiarization with plant activities and the NRC inspection i.
process. The NRC inspector will be responsible for initiating action to correct any program deficiencies identified during the inspection through NRC's normal inspection and enforcement process.
4.
The training may also involve pre-inspection planning at the Regional Office or in the NRC resident inspection office prior to the inspection.
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Any trairiing accompan'iments-will be provided by a Region based inspector who routinely inspects waste packaging and trensportation activities, not by the resident inspector.-
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The contact for the training accompaniment inspections at reactors will be the Chief. Peactor Programs Branch, Division-of Radiation Safety. and Safeguards.
C.
Initiation of Independpnt.Inspectio'ns by 111f'nois Staff 3.
.lDNS wil1Lensure that its inspectors are qualified in accordance with NRC Inspection and Enforcement Manual j
Chapter 1245, or its equivalent and will keep NRC informed of IONS inspectors so qualified and certified. - Periodically, IDNS management w11.1 ~ accompany-its inspectors during the performance of inspections to verify the inspector!s: continued effectiveness. An NRC representative may accompany 10NS inspectors periodically; arrangements for such accompaniments will be made with IDNS management.
Finally, NRC will inform IDNS management of problems identified during the NRC review
.of IONS inspection findings for appropriate' corrective action.
2.
IDNS inspectors may periodically accompany NRC inspectors during.NRC's programatic waste package and transportation inspections to maintain familiarity with a. licensee's program and NRC inspection requirements.
IDNS and NRC may alse meet l
periodically to exchange information and discuss. changes in i
procedures.
IDNS inspectors may also contact Region based and resident inspectors prior to or during IDNS'sLindependent I
inspection at the site.
3.
Arrangements to gain access to any licensee's facility are a responsibility of IDNS.
Specifically, individuals planning to conduct inspections at reactor facilities should aseet al'1 licensee requirements for site access.
- 11. PROCEDURES TO BE FOLLOWED BY ILLINOIS FOR INSPECTIONS CONDUCTED UNDER THE SUBAGREEMENT A.
Illinois will perform the following inspection activities relating.
to 10 CFR 71:
1.
Examine the licensee's written waste shipment records. As the situation allows, observe completed packages so as to:
l a.
Verify that the licensee has marked the package with the applicable general and specific package markings which are required (49 CFR 172.300 through310).
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Yerify that for' NRC-certified packages, or DOT-revalidated i
packages of foreign origin,-the outside-of the package is L
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. durably and legibly marked with-the package identification marking indicated in the Certificate of Compliance or the t
DOT Competent Authority Certificate.
b.
Verify that for.non-exempted packa9es, the' licensee provides for and accomplishes labeling of each package with the appropriate' category of RADIOACTIVE-(White-1, Yellow-Il, or Yellow-Ill)-label, one each on two opposite i
sides of the package;: and accurately completes the entry of the required information in the blank spaces thereon.
(49 CFR '172 Subpart E).
Verify that the licensee provides for and accomplishes c.
monitoring of each completed package to assure that external radiation and removable surface contamination:
are within the allowable limits [49 CFR 173.475(1),
49 CFR 173.411, 49 CFR 173.443. and 10 CFR:71.87(i) and(j)).
-l 2.
Examine the licensee's written waste shipment records. As the situation allows, observe ' actual transport operations s0:45 to; Verify whether the licensee ' prepared the. required shipping a.
paper documentation, so as to accurately include all of the applicable required elements of information, including the shipper's certificate.
[ NOTE:' For licensee private motor vehicle shipments, the certificate is not required (49 CFR 172, Subpart C).]
i b.
For non-exclusive use shipments, verify that the licensee provides to a highway carrier or' applies'directly to a rail vehicle, the required placards whenever he delivers-any quantity of RAD 10 ACTIVE-Ye110w-11111abeled packages to such carrier for transport (49 CFR 172.506 and 508).
l For exclusive use shipments, verify that the L
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licensee assures that the package and vehicle: radiation /
contaminationlevelsarewithintheregulatory]1imits
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[49'CFR 173.475(1) and 10 CFR 71.87(1) and (j).
L Verify that except for uranium or thorium ores, the transport vehicle is placarded by the licensee when delivering to a carrier any exclusive-use shipment for whichplacardingisrequired[49CFR172,SubpartF, and 49 CFR 173.425(b)(7)].
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For exclusive use shipments, verify that shipping paper i
documentation provided by the licensee to the carrier l
contains satisfactory instructions for maintenance of
. exclusive-use:shipmentcontrols[49CFR173.441(c)and 49CTR173.425(b)(9)).
Verify that for exclusive-use shipments of low-specific activity materials, the itcensee has provided for the additionalspecificrequirements[49CFR173.425(b)(1) through(9)].
j d.
Verify that.the licensee provides for notification to the consignee before shipment:.the dates of shipment-and expected arrival, any special loading / unloading or operating instructions whenever any nonexempt fissile materialand/orpackagescontaining['highwayroute49 CFR 173.22 controlled quantities" are involved a
and10CFR71.89),
a Verify that the. licensee provides for advance notification e.
to the Governor of a State, or his designee, of any shipment of radioactive waste requiring Type B packaging through, to, or across a State boundary (10 CFR 71.97).
[ NOTE:
This requirement is not the same as that required for safeguards purposes pursuant to 10 CFR 73.72].
I 3.
Review the licensee's records and reports to verify that a l
system is in place to:
t a.
Maintain on file' for two years after shipment a record of each shipment of licensed material. (which xis not exempt therefrom) and that such records contain the required information[10CFR71.87and10.CFR71.91(a)).
b.
Report to the Director. HMSS, within 30 days, any
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instances where there has been a-significant reduction in the effectiveness of any packaging during its use; providing additionally the details of any defects of safety significance to the packaging after. first use and the means employed to repair such defects to prevent their recurrence (10 CFR 71.95).
c.
Innediately report to DOT, when transporting licensed material as a private carrier, any. incident that occurs in which as a direct result of the radioactive-material:
any person is killed; receives injuries requiring hospitalization, property damage exceeds $50,000; or 4
. fire, breakage, spillage, or suspected radioactive contamination occurs (49 CFR 171.15 and 49 CFR 171.16).
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B.
1111nois will perform the following inspection activities relating to 10 CFR Parts 20 and 61:
l 1.
Review the licensee's records and, as the situation allows, observe actual-packages and transport activities to verify that each shipment of. radioactive waste intended for off-site-
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disposal to a broker or a licensed land disposal facility is 4
accompanied by a shipment manifest which includes all:of the 1
requiredinformation[10CFR20.311(b)and(c)].
2.
Review the licensee's documentation and records to determine whether-procedures have been established and are-being.
maintained to properly classify all low-level wastes according to 10 CFR 61.55.
3.
Review the licensee's documentation'and records to determine whether procedures =have been established and are being maintained, to properly characterize low-level waste-in conformance with the requirements of 10 CFR 61.56, a
4.
Review the licensee's records and, as the' situation allows, observe actual packages and transport activities to verify that each package of low-level waste intended for shipment to a licensed land disposal facility is labeled, as-appropriate, to identify it as Class A, B, or C waste in accordance with the.
classification criteria of 10 CFR 61.55 [10 CFR 20,311(d)(2)].
5.
Review the licensee's records and, as'the-situation' allows, observe actual packages and transport activities to verify that the licensee has forwarded to recipients or delivered to waste collectors at the time of shipment, a copy of the waste manifest. -Verify that acknowledgement of receipt of the manifest is'obtained.
Verify that the licensee'has a-procedure' in place to effect an investigation in any instances wherein acknowledgement of receipt of the shipment has not been received within the specified period. Verify that. procedures are in place to report such investigations to the appropriate NRC Regional Office and file the required written report
[10 CFR 20.311(d), (e), (f), and (h)].
l 6.-
Review the licensee's records to verify that the applicable disposal site license conditions are being met.
Verify that I
the licensee has on file a current version of the disposal site license.
C.
Inspections perfomed by IDNS for and on behalf of the Commission are not to include those elements of NRC inspection procedures dealing with evaluation of the licensee's-written procedures, equipnent, quality control programs, training programs or
-l staffing.
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!!I.. DOCUMENTATION OF INSPECTION FINDINGS Following each inspection IDNS will-docunent the areas covered and findings of the inspection in an inspection report using guidance set
- out in NRC Inspection and Enforcement Manual Chapters' 0610 and 0611.
-Following IONS management approval, the report will be sent to the NRC contact listed in Section 9 of the Subagreement with a copy to the licensee.
IONS will complete and forward the. inspection report to the
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NRC within 30 days of completion of the inspection.
Following appropriate NRC review, the report will be placed in the Public Document Room and a-request sent to the licensee by the NRC'for proper corrective action if deemed necessary.
For those inspections perforned by IDNS.which-result in deficiencies in compliance with NRC regulations, IDNS shall-identify the deficiencies in the cover letter transmitting the report,'and specify that any. enforcement action is a' responsibility of the NRC.. In addition, when any findings which would become a violation once the shipment departs the plant gate are identified, such findings should be furnished-to the licensee and the NRC resident inspector before the shipment departs the, licensee's site.
It is the NRC's-sole discretion-as to whether the-licensee will be requested or required to take' corrective action or;to respond to discrepancies in compliance'with NRC regulations as a result-of findings from these inspections.
IDNS inspectors will-provide support to NRC during any hearings and other meetings relating to their inspections, as required, l
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-IV.
CHANGES TO IMPLEMENTING PROCEDURES 1
These implementing procedures may be changed by mutual written agreement i
between the NRC and the State of Illinois.
E FOR THE NUCLEAR PEGULATORY COMMISSION 1
Dated:
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l FOR THE STATE OF ILLINDIS Dated:
1
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