ML20087E522

Responds to NRC Re Violations Noted in IE Insp Rept 50-219/83-27.Corrective Actions:Supervisors Instructed to Verify Drain Plug Integrity.Temporary Rev to Procedure 351.32 Submitted for Review

ML20087E522
Person / Time
Site:	Oyster Creek
Issue date:	02/24/1984
From:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20087E510	List: ML20087E522
References
NUDOCS 8403160208
Download: ML20087E522 (3)

Text

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GPU Nuclear Corporation Nuclear

'  :::gg;388 Forked River, New Jersey 087310388 609 971-4000 Writer's Direct Dial Number:

February 24, 1984 Mr. Thomas T. Martin, Director Division of Engineering and Technical Programs U.S. Nuclear Regulatory Commission Region 1 631 Park Avenue King of Prussia, PA 19406

Subject:

Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection Report 83-27

'1his letter is submitted in response to your letter of January 17, 1984, regarding the Notice of Violation (t W ) contained in Appendix A. On February 17, 1984, an extension of response time to February 24, 1984 was ,

requested via telephone by GPU Nuclear and granted by Mr. Monte Conner of Region I.

In accordance with 10 CFR 2.201, the attachment to this letter represents our reply to the tW . If there are any questions regarding the information therein, please contact me or Mr. Michael Laggart of my staff at (609)971-4643.

Very truly yours, f -

1$ ,

J'wbr2 Petef B. Fiedler Vice President and Director Oyster Creek PBF:PFC: dam Attachment cc: Dr. 'Ihomas E. Murley, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station

• Forked River, PU 08731 r

i 8403160200 840307 PDR ADOCK 05000219 G. PDR GPU Nuclea Corporation is a subsidiary of the General Pubhc Utilities Corporation L

. .. =

e ATI'ACHMENT Violation:

As a result of an inspection conducted on November 29, 1983 to December 2, 1983, and in accordance with the NRC Enforcement Policy, 10 CFR 2, Appendix C, the following violation was identified:

10 CFR 71.12(a) is a general license issued to any licensee of the emission to transport licensed material in a package for which a '

certificate of compliance has been issued by the NRC. 10 CFR 71.12(c)  ;

requires a licensee using such a package to have a copy of the certificate l of coupliance for the package, and the licensee must comply with the terms l and conditions of the certificate.

Condition No. 9 of Certificate of e mpliance (C of C) No. 6601 for package Model No. CNS 8-120, requires the drain line and access plugs to be appropriately plugged and sealed prior to transport.

Contrary to the above, package Model No. CNS 8-120, Certificate of Compliance No. 6601, was used to transport 42 Curies of licensed material on November 2,1983, and the drain line and access plugs were not verified to be appropriately plugged and sealed prior to transport.

This a Severity Invel V violation (Supplement V).

Reply:

We concur with the violation as stated.

In response to the inspector's concern, package integrity was imediately verified with Gem-Nuclear Services, Inc. (CNSI) at the time of the inspection by telephone conversation. GPU Nuclear subsequently received a letter of confirmation from CNSI stating that the package tack-Welded drain plug was in place prior to delivery to Oyster Creek and upon receipt of the shipment at the disposal site. The tack-welded drain plug constitutes a " security seal" or anti-tanper seal" which we understand is not a requirement. CNSI indicates that all CNSI 8-120 casks have security seal provisions on drain plugs or it is tack-welded as was the case with this specific cask.

As an interim measure regarding the drain line plug, all Radwaste Shipping supervisers were informed of the procedural deficiency and instructed to verify drain plug integrity and document same in the comments section contained in Procedure 351.32, Figure 351.32.1, Step 11. A temporary revision to Procedure 351.32, was submitted for review on December' 2,

~1983. This revision-requires inspection of the CNSI Model 8-120 package drain plug and documentation of that inspection on the appropriate form.

Final review of the procedure revision was coupleted on February-19,1984.

With regard to the access plugs on the package lid, it is our understanding, based upon comunications between GPU Nuclear and CNSI and between CNSI and the Transportation Oertification Branch of IRC, that security seals are not required for the access plugs. In addition, the access plugs are no longer utilized. 'Ibey were provided in the package design to accomodate in-cask solidification which is no longer the method used. CNSI has indicated that the access plugs are insertcd in conjunction with a sealant. We consider a QA receipt inspection of the package to be sufficient to assure that the access plugs are appropriately plugged and sealed. However, a visual inspection prior to shipment to verify the access plugs are in place will be performed. A procedure revision was submitted on February 24, 1984 to document this visual inspection.

'Ihe November 2,1983 shipment and all subsequent shipments with the CNSI 8-120 packages were in accordance with the package approval.

Full compliance was achieved on November 29, 1983.

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