ML20082V385
| ML20082V385 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/20/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9109230231 | |
| Download: ML20082V385 (2) | |
Text
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O) 1400 Opus Place C:mm:nwealth Edis:n O y Downers orove. nonois cosir, v
September 20,1991 U.S. Nuclear Re0ulatory Commission Attn: Document Control Desk Washin0 ton, DC 20555
Subject:
LaSalle County Nuclear Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50 373/91016; 50 374/91010 NRC Docket Nos 50-373 and 50 374
Reference:
(a) L. Greger letter to Cordell Reed dated August 21,1991 transmitting NRC Inspection Report 50 373/91016; 50 374/91016 Enclosed is Cornmonwealth Edison Company's (CECO) response to the subject Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report. The NOV cited one Severity LevelIV violation. The violation concerned the failure to properly mark a wasto shipping container.
CECO understands the significance of this ovent as well as the need for effective corrective actions to prevent recurrence. These have been considered in develo 31ng actions in response to the cited violation. CECO's response is provided in the foi owing attachment, if your staff has any questions or comments concerning this letter, please refor them to Denise Saccomando, Complianco Engineer at (708) 515 7285.
Very truly yours,
' /M, l V
T.J.
fach l
Nuclear Lietiising Manager i
l Attachment i
l cc:
A. Bert Davis, NRC Regional Administrator - Alli B. Siegel, Project Manager NRR
'I'. Tongue, Senior Resident Inspector
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ZNLD/1165/21 j
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s ATTACHMENT A RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-373/91016; 374/91016 Violation 10 CFR 71.5(n) prohibits transport of licensed material outside the confines of a plant or other place of uso, or delivery of licensed material to a. 3rrior for transport, unless the licensee compiles with applicable requirements of the regulations, appropriate to the mode of transport, of the Depariment of Transportation (DOT)in 49 CFR Parts 170 through 189.
49 CFR 173.425(b)(8) requitos that each LSA wasto shipping cask be labeled
- Radioactive LSA".
Contrary to the above, on May 14,1991, a cask containing a linor of LSA radioactive waste sludge which arrived at the Deatty, Nevada burial sito was labolod
-Empty"instead of " Radioactive LSA" Reason for Violation The violation occurred due an error on the part of the station personnel responsible for ensuring 3 roper placement of placards, markings, and labels on radioactive wasto shipments. This shipment involved a cask which was surrounded by a personnel barrier. The cask and personnel barrier had been delivered to the station in a combined conilguration with the cask having been properly labeled as " Empty". The liner was subsequently loadd into the cask without removing the personnel barrior.
Due to the nature of the personnel barrior, the sides of the barriot obstructed view of the cask and thereby eliminated a " visual trig 0er" for shipping personnel to recognize that the label on the cask had not been changed from the " Empty" setting to correctly road
- Radioactive LSA".
Conected Steps _Taken and Results Achieved This error was discovered at the burial site in Nevada and thus precluded Commonwealth Edison from having an opportunity to take corrective steps for this incident.
Certective StepsJakenJo Avoid Eurther Violation The radioactive waste shipment checklist for LaSailo Station (contained in proceduro LAP 100 27 "Guldelines for Radioactive Waste / Material Shipments") was revised on June 6,1991. The procedural enhancements include provisions to assure casks onclosed by personnel barriers are properly labeled even if the barrier physically precludes the use of a " visual trigger" mechanism.
Additionally, personnel involved in the transportation of radioactive waste have been informed of this event and have reviewoo the revised version of LAP 100 27.
Finally, Chemistry Services willissue a letter by October 1,1991 to all CECO stations which will provido detailed information on this event along with any appropriate actions to be taken, Date.When Full Compilance Will De. Achieved Full Compliance was achloved upon revising LAP 100-27 ZNLD/1165/22
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