ML20098A251
| ML20098A251 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/03/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20098A249 | List: |
| References | |
| 423, NUDOCS 8409240387 | |
| Download: ML20098A251 (2) | |
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-3 VIRGINIA ELucTulc Awn Powna COMPANY RIcnxown,VIROINIA 20261 go.O
August 3," g
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1984 Vaca Pusetouwr Nuctuam oramarnows
_Mr. James P. O'Reilly Serial No.:
423 Regional Administrator N0/DWL,RFS/lms U. S. Nuclear Regulatory Commission Docket Nos.:50 0 b
' Region II 50-2 1 101 Marietta Street, Suite 2900 License Nos.DPR-32 Atlanta, Georgia 30323 DPR-37
Dear Mr. O'Reilly:
We have reviewed your letter of July 3, 1984, in reference to the inspection conducted at Surry Power Station between May 29, 1984 and June 1, 1984 and reported in IE Inspection Report Nos. 50-280/84-18 and 50-281/84-19.
Our response to the specific infraction is attached.
Pursuant to the telephone conversation held on June 22, 1984, between J.
L.
Wilson and H.
C.
Dance, a review of station radioactive material shipment proceduree has been performed end procede.rel modificationc are in progresa to provide additional assurance of proper load bracing and shoring prior to transport. These modifications will !c completed by August 15, 1984.
We have determined that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company ha's no obj action to this inspection report being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and. belief.
Very truly yours, 1
T W. L. Stewart Attachment ec:
Mr. Richard C. Lewis, Director Division of Project and Resident Programs Mr. Steven A. Varga Operating Reactors Branch No. 1 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station 8409240387 84082d PDR ADOCK 05000280 t
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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT WOS. 50-280/84-18 and 50-281/84-19 A.
NRC COMMENT:
10 CFR 20.311 (d)(3) requires that any licensee who transfers radioactive waste to a land disposal facility conduct a quality control program to assure compliance with 10 CFR 61.55 and 61.56.
The quality control program must include audits.
Contrary to the above, the requirements to conduct a quality control program which included audits was not met, in that no audits which evaluated licensee compliance with the requirements of 10 CFR 61 had been performed or scheduled.
This is a Severity Level V Violation (Supplement IV).,
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
(2) REASONS FOR VIOLATION:
The reason for the violation was determined to be a misinterpretation of the audit requirements en the part of the Quality Assurance Department.
A consultant was hired to develop a 10 CFR 61 Compliance Program Description and HP.3.2.9 was written to reflect the program description.
The existing audit program for Haalth Physics verified compliance with approved procedures and was considered to meet the intent of 10 CFR 20.311 (d)(3) since HP.3.2.9 was specifically written to address the requirements of 10 CFR 61.
Several audits had been conducted p'cior to the notice of violation and in addition, Quality Cor. trol Inspectors witness the preparation of every shipment that leaves the Station, all of which ensures compliance to procedure.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
A special audit was conducted to evaluate compliance with the require-ments of 10 CFR 61.
It was determined from the audit that compliance with the requirements of 10 CFR 61 have been achieved.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
1 The requirement of 10 CFR 20.311 (d)(3) has been thoroughly reviewed by the Quality Assurance Department and all future audits of Health Physics will evaluate compliance with the requirements of 10 CFR 61.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance has been achieved.
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