ML20059A746
| ML20059A746 | |
| Person / Time | |
|---|---|
| Site: | 07001252 |
| Issue date: | 08/20/1990 |
| From: | Ravenscroft N EDLOW INTERNATIONAL CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9008230206 | |
| Download: ML20059A746 (3) | |
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Edlow International Company l
1666 Connecikut Ave., N.W., Suite 5(U
(
Wtshington, D.C. 20lO9 U.S.A.
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Tel 002) 4604959 August 20, 1990 Th 64387 A 6491095 -
[
I u 902)4sb4840 Nuclear Regulatory Commission
{
Attn: Document Control Desk t
Washington, D.C.
20555 l
Gentimen:
Reply to a Notice of Violation l
This refers to the Notice of-Violation, NRC inspection report no.
70-1252/90-03, dated July 24, 1990, for a shipment of. irradiated fuel onboard
- Mitsui 0.S.K. Lines' vessel " Alligator Irdepence" which departed Portsmouth, VA on July 1,1990.
We acknowledge the violations contained in this report with the following explanation regarding the relsvant. circumstances.
l Ref: Enclosure 1, A.
We were unable to provide advance notice to the Nuclear. Regulatory Commission or the Governor's designee for.the state of North Carolina, due to the fact that we were also not aware of the intended stop at the Port of ~
Wilmington, N.C.
We were never advised by Mitsui 0.S.K.- Line (Mitsui) that
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the " Alligator Independence" would be calling. the. Port -of Wilmington.
The booking strrangements for the " Alligator Independence" with Mitsui-were made appraximately two months in advance of the scheduled July:2 shipment.
There is no indication on any of the shipping schedules issued by Mitsui that any of their vessels call.at the Port of Wilmington,- neither was the issue addressed during conversations with the shipping conpany prior to arrival of the vessel J
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in Portsmouth, VA.
The schedule referenced by Mitsui, indicating that L
Wilmington was P. scheduled port is an internal schedule for their use "only, not a published schedule.
Edlow International manages many irradiated f ael shipments and we are fully aware of the regulatory ' requirements for notifications, etc.
We of ten.
's use Mitsui for shipments -that are transported using the same route !in question.
It is our understanding that Mitsui normally recei.ves tobacco shipments from Wilmington at the Port of Portsmouth.
According to Mitsui's Operations Manager in Portsmouth, at the time of our shipment,- the volume of I
tobacco was such that Mitsui considered it necessary to call at the Port of-Wilmington to receive a consigrynent.
At this time:and at no time.in the past, were: we ever made aware of the occasional need to call the Port of-Wilmington to load tobacco shipments.
Had we known that 'it. was possible that the q
" Alligator Independence". would call the. Port of Wilmington,- we wouk
.1 ave i
endeavored to ensure' that we were give adequate advance warning o'r the requirement to enter the Port of Wilmington so that the necessary arrangements could have been made.
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Page Two August 20, 1990 Nuclear Regulatory Commission r
Since we did not have prior knowledge about the tobacco shipments, we did not make any inquiries. _ Mitsui did riot inform us of their intent to call l
the Port of Wilmington and we subsequently were not able to make the required advance ' notifications.
We do not feel that the notice of violation is warranted under the circumstances. outlined above, and would welcome your
.consnent as to how w.,
should realistically address this issue should similar circumstances arise in the future.
Ref: Enclosure 1, B.
f The cargo was loaded onboard the " Alligator Independence" at about 07:40 hours-on July 1,1990.
Mr. Daren Condrey and Mrs. Franchone Oshinowo of our company were present for the loading.
Immediately afterwards, they acconpanied the Mitsui Operations Manager in Portsmouth, Mr. James Bell i
onboard the vessel to discuss documentation and physical protection measures, with the ship's captain, Mr. Y. Hatoa.
It was-during these discussions that we first learned that the vessel would be transitting the Port of Wilmington, approximately ten (10) minutes prior to the departure of the vessel from Portsmouth.
Mr. Condrey and Mrs. Oshinowo sought assistance from Mr. Bell.
He contacted the Operations Manager in Wilmington, N.C., Mr. Clif ton-Karol, and asked that arrangements be made to post 9 port guard alongside the vessel while docked in Wilmington. Since we learned of the intended stop at the Port of Wilmington only minutes prior to departure from Portsmouth, advance arrangements for LLEA or Port Authority personnel to provide for a
communications center were not made.
In lieu. of this, we maintained contact with Mitsui in Wilmington on a regular basis to check on the status while the
. vessel was docked.
J With the extremely short notice of the unscheduled stop in Wilmington and in the absence of regulatory guidance at the time of= the shipment, we acted diligently and took the actions deemed appropriate. lWe felt that arranging for a guard alongside the vessel and maintaining ' direct contact with' Mitsui' i.o Lpdate shipment status was adequate, given the time restrictions.
We, therefore, do not feel that this notice of violation is warranted.
Edlow International has taken the following corrective steps..
We contacted Mitsui 0.S.K. Line New York (headquarters), and informed them of the difficulties encountered during this-shipment.
Due to the nature of 'our cargo, we strongly expressed the urgency of being notified well in advance. of
-l additonal ports of call-not published in shipping schedules.
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Page Three
' August 20, 1990 Nuclear Regulatory Commission l
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To avo'id future violations of this nature, we have made arrangements with Mitsui and other carriers to advise Edlow International of the ports of call not otherwise published.
We also will maintain regular contact with steamship line agents to update and ' affirm current schedules for shipments of i
irradiated fuel.
We would also appreciate IEC guidance as to how shippers of similar materials are to respond to regulatory - requirements when unforseen j
- circumstances result in an unplanned movement of nuclear material.
i The Nuclear Regulatory Commission can be assured that' Edlow International will do all possible to avoid future violations and will be in full compliance for future shipments.
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Sincerely
- urs, Wo Norman Ravenscroft/
i Vice President, Operations i
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