ML20083P105

Responds to NRC Re Violations Noted in IE Insp Rept 50-220/83-26.Corrective Actions:Procedure RP-6, Packaging & Transport of Radioactive Matl, Revised to Include Specific Activity & Decay Heat Load Documentations

ML20083P105
Person / Time
Site:	Nine Mile Point
Issue date:	02/21/1984
From:	Lempges T NIAGARA MOHAWK POWER CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20083P083	List: ML20083P105 ML20083P131
References
NMP-7865, NUDOCS 8404190381
Download: ML20083P105 (3)

Text

h NMP-7865 e'

NIAGARA MOHAWK POWER CORPORATION NIAGARA MOHAWK 300 ERIE BOULEVARD, WEST SYRACUSE. N. Y.13 202 Felvtuary 21, 1984 th. Thomas T. Martin, Director Division of Engineering and Technical Programs United States Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, Pennsytvania 19406 Re: Docket No. 50-220 Inspection Report 83-26

Dear ik. Martin,

This' refers to the routine Safett Inspection conducted by th. P. Clemons of your staff on Novem)ber 7-10, 1983, at Nine-Mile Point Unit 61, Scriba, New York of activilies authorized by NRC License No. DPR-63, and to the discussions of your findings held by Sk' P. Clemons saith bk. T. Perkins and other members of our staff at the conclusion of the inspection.

. ITBI A 10 CFR 71-12(c)~ requires that a person using.a package to transport

-licensed material must' have a copy of the Certificate of Compliance, and the person must also comply with the conditions of the Certificate.

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' Certificate of Compliance No'. 9111, Revision No'. 8,.. requires that the; decay. heat load not:cxceed 400 watts.

-Contrary-to the above, th'e licensee did not determine.theEdecay

' heat load of. a package of 14 curies :of-licensed-material shipped

.on February-11, 1983, having.the Certificate of Compliance No.=9111.

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-Certificate of Compliance No. 9094, Revision'No. 6, requires that the contents of.a package must meet the. requirements forclow

. specific ~ activity. material.

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' Contrary to the above, the;1icensee did not determine if a package

. shipped on April 22, 1983, having the CertificateLof. Compliance:

No. 9094, met the requirements for low specific. activity material.

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IR 83-26 g

RESPONSE

Due to inadequacies in procedures, de decay heat load af a padage of 14 curies of licensed material shipped on February 11, 1983, havhg the Certificate of Compliance No. 911!, was determined not to exceed de limit, but not documented. Also, he specific activity of a package shipped on April 22, 1983, having de Certificate of Compliance No. 9094, as determined but compared to the LSA limits was not documented.

Procedure RP-6, Packaging and Transport of Radioactive Materlat, was issued via tco revisions so as.to include de specific activity documen-tation and de decay heat toad documentation. The revisions were dated September 7,1983 and January 13, 1984 respectively. Also, att radio-active waste shipments from de year 1983 will be reviewed and documented so as to show tha.t ne heat load and specific activity Limits have not been exceeded. This review process is schedated to begin in. mediately,-

and it is ' anticipated.to be completed by %tch 1,1984. These corrective actions should prevent nese violations from occurring in de future.

ITEM B 10 CFR 71.101(b) requires each license to establish a quality assurance program for packages.

10 CFR. 71.101(f) states that

a Commission approved quality assurance. program that satisfies the applicable criteria of Appendix B of Part 50 of this chapter,-

and which'is established, maintained and executed with regard to' transport packages willEbe accepted as: satisfying the~. require-ments of paragraph;(b) of this section.

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Criteria,II, Appendix B of Part 50 of the licensee's previously.

-approved program requires that the licensee identify the structures,.

l systems and~~ components.to be covered by the quality assurance-

-program, Coritrary_ to the-above,i as - of November 9,' 1983, "the-licensee has-p not: identified transport packages as a structure,Lsystem or.com ~

L ponent:to be covered by the quality 1 assurance program.

-RESPONSE

. /By a tetter dctedJJune 2,l1983[from Niagara'Mbhad Nuclear Quality

Control Supervisor Mr. David Palmer to Niagara Mohawk General Superintendent'

~ of Nuclear Generation Mr.; Thomas Perkins, z. transportation packages were -

included in.the:Nine Mile Point Unit 1 Quality Assurance Program.' Audit /;

/survelitance reports are on'flie proving Quality ' Assurance.; activity. inh

this area ;However, radioactive materlat transpor.t is 'notspecificatty

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included in de Q-listas desired by USNRC Region IbInspector-Mr Percy

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'Ctemons. LWe request;a 30-day extension:to clarify the Legal requirements -

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pertaining;to this item and.to, provide a ; satisfactory; resolution.

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r Page 3 NMP-7865 IR~83-26 ITEM C 10 CFR 71.105(d) states, "The licensee shall provide for indoc-trination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained."

Contrary to the above, one licensee employee performing activities affecting quality has not been trained in DOT and NRC regulatory requirements involved in the transfer, packaging and transport of radioactive-material to assure that suitabic proficiency was achieved and mainteined.

RESPONSE

Mr. David Palmer, Niagara Mohawk Naciear Quality Conttol Supervisor, has been in communication with Dr. Ronald Beitamy, Chief of RadiMion Protection of your Region 1 office, to obtain a clarification of this item. ' We request a 30-day extension to clarify and provide a satisfactory resolut on to this item.

i Very truty yours, y.

M- -

Thomas E Lempges Vice President Nuclear Generation TEL/RGR/jm 2

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