ML20076E511

Responds to NRC Re Violations Noted in IE Insp Rept 50-247/83-05.Corrective Actions:Cask Handling Procedure Reviewed,Approved & Implemented & Advance Transport Notification Sent to Governor.Disputes Violation B

ML20076E511
Person / Time
Site:	Indian Point
Issue date:	04/16/1983
From:	Otoole J CONSOLIDATED EDISON CO. OF NEW YORK, INC.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20076E470	List: ML20076E511
References
NUDOCS 8306010126
Download: ML20076E511 (12)

Text

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. . John D. O'Toob

. . Vice Prescent Cons 0 Mated Edison Cornpany of New York. Inc 4 Irving Place, New York, NY 10003 Telephone (212) 400-2533 April 16, 1983 Re: Indian Point Unit No. 2 Docket No. 50-247 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, Penna. 19406 >

Dear Mr. Martin:

This refers to Inspection 50-247/83-05 conducted by Mr. P. Clemons on February 9-10, 1983 of activities authorized by NRC License No. DPR-26 at Indian Point Station. Your March 17, 1983 letter stated that it appeared that two of our activities were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed therewith as Appendix A.

Provided herewith as Attachment A is our response to Appendix A of Inspection Report 50-247/83-05.

Should you or your staff have any questions, please contact us.

Ver truly yours,

/

14 i, a TT Attach cc: Mr. Thomas Foley, Senior. Resident Inspector U. S. Nuclear Regulatory Commission P. O. box 38 Buchanan, New York 10511 8306010126 830525 PDR ADOCK 05000247 G PDR

50-247/83-05 ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION APPENDIX A On February 9-10, 1983, Mr. P. Clemons, of the Nuclear Regulatory Crunnission (NRC), Region I Offices, performed a routine safety inspection at Indian Point Units 1 and 1, in Buchanan, New York. The inspection-report indicated that certain of our activities were not conducted in full compliance with NRC requirements.

In the Notice of Violation.- dated March 17, 1983, the following violations were identified.

Violation A. Technical Specification 6.8.2 requires each procedure that meets or exceeds the requirements and recommendation of Section 5.1 and 5 3 of ANSI 18.7-1972, and Appendix "A" of USAEC Regulatory Guide 1.33 be reviewed and approved for implementation in accordance l with a written administrative control procedure approved by the I appropriate General Manager, and with the concurrence of the Station Nuclear Safety Committee and the Nuclear Facilities Safety Committee.

Contrary to the above, the licensee has implemented two transport package loading procedures and the procedures were not reviewed and approved for implementation in accordance with a written administrative control procedure approved by the appropriate General Manager, and with the concurrence of the Station Nuclear Safety Committee and the Nuclear Facilities Safety Committee.

This is a Severity Level V violation (Supplement V).

Response

A procedure for controlling cask handling was provided by the vendor and was in use at the time. The procedure has now been reviewed, approved and implemented in accordance with the written administrative control procedure (Station Administrative Order 102 l

" Procedure / Procedure Change Approval Policy").

Violation B. 10 CFR 71.5a states, " prior to the transport of any nuclear waste outside of the confines of the licensee's plant or other place of use or storage, or prior to the delivery of any nuclear waste to a carrier for transport, each licensee shall comply with the procedures in 10 CFR 71.5b for advance notification to the governor of a state or the governor's designee for the transport of nuclear waste to, through, or across the boundary of the state."

10 CFR 71.5b states in part that a copy of the advance notification must be retained as a record for one year by the licensee.

Contrary to the above, on August 20, 1982, the licensee transported a large quantity of nuclear waste to Barnwell, South Carolina, and a copy of the advance notification was not maintained by the licensee.

This is a Severity Level V Violation (Supplement V).

Response

We disagree that this constituted an item of non-compliance.

A copy of the advance notification document which was sent to l the state governor's designee was retained on file. This 1

f document did list all the states notified in Section 6 of the I

form and a procedural sign off was completed. We have l

subsequently received documents from each state indicating that l

they did receive the notification. (See attachments).

In the future, the state governor's designee will also receive a cover letter clearly indicating the addressee.

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i 5.2.3 The p e.i n t of o r 1 R i si the shipment, and the seven day period dut ng which departure of the shipment is estimate

• to occur.

.;,' _. 5.2.4 The seven day period during which arrival of the

'O shipment at state boundaries is estimated to

' , occur.

, _ . . . . . . , ..q . - ;

e 5.2.5 The destination of the shipment, and the seven

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day period during which arrival of the shipment is estimated to occur.

,. ;[ pl.i.2r. .. re . 5.2.6 A point of. contact with a telephone number for current shipment information.

!  ; - 5.2.7 Advance written notifications have been made.

(Copies on file in Radwaste Office).

i hl / 9 f3 $ L con Ed Project nager Da'et 8 l, 5.3 Test solidification of si lated waste stream has been perforned per: CNSI Process Control Program for CNSI Cement Solidification Units. SD-OP-003.

(Attachment 9.5)

Ok 12 91 $ 2. L /5 'ff1. *

Con Ed 'Proj c e ] n a g e'r / D'a t e ' CNS{,../ Wate 5.4 Approved Work mit, signed by Waich Supervisor.

5.5 Approved Radiation Work Permit, signed by Radiation Protection Supervisor, Radwaste Supervisor a,nd Watch Supervisor.

5.6, During resin transfer operations (Sections 8.1 through l 8.17) a minimum of (2) Decontamination Technicians. two (2) CNSI Solidification Operators. (3) Radiation Protec-tion Technicians, (6) NPO's, one '(1) Radiation Protec-tion Supervisor, one (1) Radwaste Supervisor and ( 1 )' * ~

' 'Q.A. and Radwaste General Supervisor must be present.

5.7 During solidification operations (section*s 8.18 through 8.31) a minimum of (3) Radiation Protection Technicians two (2) Decontamination Technicians, two (2) CNSI '

. solidification operators, one (1) Radiation Protection I Supervisor, one (1) Radwaste Supervisor, one (1) Quality Assurance Technician and Radweste Ceneral Supervisor must be present.

Page 5 of 52

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a. Name af flow York. Inc. a. Name _ Chem-Nuclear Systems Inc.

b. Address indian Dnin* station b. Address _P.O. Box 726 nenadway and Bleaklev Aves

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nocha na n, IL Y. 10511 Barnwell. South Caroli,n_a

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C. TW1.~ No. _ f o14 ) Ex-K436 (24 hnur emarcancy number (914-526-5295)) c. Tel. No. (803) 259-1781 (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> enercency number (803-259-17861)

3. Receiver

' 4. This notification is being

a. Name furnished ~ in compliance with NRC chem-t!uelear Systens Inc. regulations in:

1. b. Address P.O. Box 725 i Part 71 TTi Part 73 L_j i Barm' ell . South Carolina 29812 _ _ _

c. Tel. No. (803) 259-1781 (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emeroency number (8.93-259-1705))

. 5. 49 A CFRDESCRIPTI0il 0F SHIP:4E!'T AS REQUIRED BY DEPART 'Eti 55172.202 & 172.203(d) 15 ATTACHED.

_ 6._ ADDITICt:AL It60R".AT:0:; FOR A PART 71 EMITI;E:iT OF fi CLEAR HASTE

a. The street address of point of origin is Broaduav and Bleakley Aves.,

Buchanan. t'cw Yort 10511 .

b. The. shipment is scheduled to begin durir.g the 7-day perico commer:ing _8/18/82

c. Schedule for shi;aent entry into in:icated state (s):

State Entry is scheduled durir.g the 7-day pericd cc=encing New York ' 8-18-82 New Jersey / 8-18-82 -

Delaware ' 8 18-02 Maryland < 8-18-82 Virginia / 8-18-82 North Carolina 8-18-82 South Carolina / 8-18-82 A

d. The street address of the shipment destination is Chem-fluelear Systems Inc.

Osborne Road, Barmvell. South Carolina 29812

's e. The snipmentn-n ccmencing is scnecuiec

-82 to arrive at the oesti' nation during the 7-day period

f. Current information concerning the shipment can be obtained from:

Name !11chacif'r 11ev e Adde:ss IMig.f at Stat:ct. .

Eroa(1.'iv I 8lealey Aves.

Duchanan !'cy York 10511 9 36 Tel. r:o.TiicL5_g9,pel, (Arca Goce .

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COMMONWEALTH of VIRGINIA

u. am mneson State Ofice of Emergency and Energy Services sses ae a c ,4 ,

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• April 4, 1983 10: Mr. Don Maffei Consolidated Edison Co. of New York, Inc.

Indian Point Station

. , _ . _ Broadway and'Bleakley Avenues I -

8:whanan, New York 10511 F8(M: Norman S. McTague, Operations Director ,[

This will verify that Consolidated Edison is in compliance with all

. _ . _ regulations in regard to two shipments of radioactive waste made from Buchanan, New York to Barnwell, South Carolina on August 1.1982, and August 20, 1982. Copies of the required notifications are on file in this office.

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Office of Disaster Preparedness i

Mr. Donald Maffei Co.usclidated Edison Co.

Indian Point Station Broadway and Bleakley Avenue

. Buchanan, New York 10511 i

Dear Mr. Haffei:

I This is to confirm your telephone conversation with Mr. Lee Battes of my staff on 15 February 1983.

Please be advised that we did receive the advance notifications of _

l the two shipments from Indian Point dated July 13, 1982 and August 13.-1982.

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We understand that this confirmation is necessary for these specific shipments to complete your files. We therefore do not plan to pro-vide confirmation as a routine matter, but are glad to help you out in this instance.

Sincerely, ,

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,m Donald A. DeVito Director l

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STAtt or Oct.Awaar DEPARTMENT OF PUBLtc SAFETY

,o m..ese DowLa Oh a A A=e. I 990 t Tatte.eos c 13029734 432i MEMORANDUM T Mr. Don Maffel From: Janet P.' g Pasquino, Secretary !!f Consolidated Edison in Indian Point Depart:Mnt of Public Safety

, Broadway and B,1cakley Avenues Buchanan, New York 10511 Date: February 18, 1983

Subject:

Verification of Changes in Shipment Dates of IIazardous Materials

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This morning, you telephoned me requesting that I forward to you written verification on the following changes in sliipment dates for hazardous materials.

1.

On July 13, 1982, Indian Point Station forwarded notice to the State of Delaware i on Shipment Identification No. DPR-26.

Ju'v 15,1982 at 3:12 A.M. On August 2,1982, Notice was roccited in this office on at 3:-10 P. M. . this office received

. a telephone call from you updating the information sent on July 13th.

( 2

! On August 13, 1982, Indian Point Station fonvarded notice to the State of Delaware cn Shipment Identification No. DPR-26

August 17,1982 at 11

0G A. M. Notice was received in this office on t

Ilowever, in the interim, you called on the morning cf August 1G,1982, updating the information sent on August 13th.

I hope that this information will satisfy your requirements. Please call If I can be of further assistance.

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[ ] J. Lorin Mason, Jr., M.D., Chritmin Gerald A. Kaynard. Vice-Chairman

- C Leonard W. Douglas, M. D. . Secretary

, Oren L. Brady, Jr.

Moses H. Clarkson, Jr.

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.L Barters P.Nuessle 1< D ] '

James A. Sprulil, Jr.

[ . COMMISSIONER Rotiert 8. Jackson, M.D.

2000 BullStreet Columbia, S.C.29201 February 14,,1983

~ Donald Maffei

. Radwaste Supervisor .

Consolidated Edison Company Indian Point Station Broadway and Bleakley Avenues .

Buchanan, New York 10511

Dear Mr. Maffei:

Pursuant to your recent request, this is to certify that we received advance, written notifications of radioactive waste

- ---chipments nos. 0882-257-L and 0882-261-L, filed with this agency in accordance with the provisions of Department Regulation 61-83, Cnd applicable regulations of the U.S. Nuclear Regulatory Commission and the U.S. Department of Transportation for large quantity radioactive waste shipments.

If we can be of further assistance, please do not hesitate to contact me. '

Very Truly Yours,

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Virki RNut'rh', D rector Division of RadioacEive Material Licensing and compliance Cureau of Radiological Health ,.

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, , ' 5 T A lta u r M A n i aeu-I '. DEPARTMENT OF

- ,,' PUBLIC SAFETY AND CORRECTIONAL SERVICES

=i -s MARYLAND STATE POLICE -

*W PIKESviLLE. MARYLAND 21206 3899 wwaswmtm

"" 8" "C"'"

^ AREA CODE 301 486 3101

, TTY FOR DEAF AREA CODE 301 486 0677 ausbEITue N *c'8 ".A".[nM Februah 17, 1983 l

Mr. Don Maffei Indian Point Station Broadway & Bleakley Avenues l

Buchannon, New York 10511

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Dear Mr. Maffei:

, L As per your telephone request of February 14, 1983, I am forwarding to you information from the Maryland State Police as to the receipt of notification of radioactive material shipments. The Maryland State Police received from Consolidated Edison Company notice of a shipment scheduled for July 27, 1982, listing NRC License #DPR26.

The notification was dated July 13, 1982, and was subsequently canceled and re-scheduled for August 18, 1982.

The subsequent notice of new shipment date was dated August 13, 1982, and was received timely by the Maryland State Police. In both of the scheduled notices the notification was furnished in compliance with NRC Regulations and Part 71.

A copy of these notifications remain in Maryland State Police file and are available for review if the need arises.

If I can be of any further assistance to you, please do not hesitate to contact me or 1/Lt. Henry C. Rockel, at (301) 486-3101 X29,0.

Sincerely,

.' . ,- M o ., u , t. Colonel Chief Field Operations Bureau

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DIVISION OF ENVlRONMENTAL QUALITY I4 :i

~~ suREAU OF ff ADIATION PROTECTION 4.,, 8 seo SCOTCH ROAD. TRENTON. N. J. OGsRS ' '~$ ,' ,, .

609-292-5586 C' r4h.

February 28, 1983

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. . Mr. Don Maffie Rad Waste Supervisor Consolidated Edison Company of New York, Inc.

Indian Point Station

' Broadway and Bleakley Avenues Buchanan, New York 10511

Dear Mr. Maffie:

We have received your nuclear waste shipment notifications _.

and descriptions for shipments scheduled to begin on

_ July 27, 1982 and August 18, 1982 as per NRC regulations D

Part 71 and DOT 49 CFR 172.202 and 172.203. Your file has been updated.

l Your cooperation is greatly appreciated.

, Sincerely, wra.4~m.%

Patrice-Anne M. Ryan Radiation Technician

, Bureau of Radiation Protection cab .

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u SI2 N. Sahsbury Street P. O. Box 27687 Raleigh 276117687

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' James B. Hunt.Jr., Governor .

Coboel.iohnT.Jenkins ~ C 4m -

7 : ~' Heman R. Chrk. Secretary SiseibhwayPatrol , , 1: -

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18 February 1983 . .

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. . .. Nr. Don Naffet Indian Point Station '

Broadway and Bleakley Avenues . . ,

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Buchanan, New York 10511

Dear Mr. Haffel:

Pursuant to your telephonic request, I am sending you copies of your

notification of nuclear waste shipments, dated 13 July 1982 and 13 August

! ~1982, which were subsequently mailed and delivered to me. The handwritten l notes indicate rescheduling and shipment changes that you personally

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t -notified'me of. <

l Sincerely. -

L W %,

W. K. Chapman, Lieutenant Operations WKC:Jw '

Enclosures 9

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