ML20106D701

Responds to NRC Re Violations Noted in Insp Repts 50-373/92-18 & 50-374/92-18.Corrective Actions:Radwaste Shipment Checklist Revised on 920924 to Address Proper Labeling of Yellow III & LSA Waste Shipments

ML20106D701
Person / Time
Site:	LaSalle
Issue date:	10/08/1992
From:	Kovach T COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9210130268
Download: ML20106D701 (3)

Text

- - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _

[,.m' C:mmonwe:lth Edison 4.q) Downers Grove, lilinois 60515 1400 Opus Place g

'y j

\\

j yd October 8,1992 U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

Subject:

LaSalle County Nuclear Power Station Units 1 and 2 Reply to Notice of Violation Inspection Report Nos. 50-373/92018; 50-374/92018 NBO_DochemoL30-373 and10-3Z4 Reference.

C. Pederson letter to Cordell Reed dated September 9,1992 transmitting NRC Inspection Repon 50-373/92018; 50-374/92018 Enclosed is the Commonwealth Edison Company (CECO) response to the Notice of Violation (NOV) which was transmitted with the reference letter and Inspection Report. The NOV concerned a waste shipment sent to the Barnwell burial sii without the required information entered on the Yellow Ill label. CECO's response is provided in the attachment, if your staff has any questions or comments concerning this letter, please refer them to Jim Watson, Compliance Engineer at (708) 515-7205.

Sinc 9 rely, eur' T.J. Kovach Nuclear Licensing Manager Attachment cc:

A.C. Davis, Regional Administrator - Region 111 B.L. Siegel, Pro ~ect Manager, NRR D. Hills, Senior Resident inspector i300.1.0 9210130268 921000 PDR ADOCK o5000373

)

{\\ 8 G

PDR

/[

i ZNLD/2188/1

BESPONSE_TO.NOIICE_OE V!OLATION N.BCJNSEEGIlON.BEP_Oli2NOS, 50-373/92018tS0-374/92018 VIOLATIONLOR.3Z3(3ZR'92010M) 10 CFR 71.5 states, in part, that each licensee who transports licensed material outside of the confines of the plant shall comply with the applicable requirements oi the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.

49 CFR 172.403(a) states, in part, that each package of radioactive material must be labeled as provided in this section.

49 CFR 172.403(g) states, in part, that the following applicable items of information must be entered in the blank spaces on the RADIOACTIVE label by legible printing: contents (a listing of the radionuclides in the package); activity (cune amount); and the transport index.

Contrary to the above, a package of radioactive spent resins was transported from the LaSalle County Station and was received at the Bernwell, S.C. burial site, on August 13,1992, bearing a RADIOACTIVE Yellow-lli label that did not have the required information of content, activity, and transport index entered in the blank spaces on the label.

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

BEAGON EOBlHEXIOLAILON:

CECO acknowledges the violation. The violation occurred because tho procedure (LAP-100-27 " Guideline for Radioactive Waste / Material Shipments") used to verify a shipment was ready to be released from site did not provide adec uate guidance for labelling. This procedure previded adequate guidance for LSA shipments, but was inadequate for other types of shipments. This was the first Yellow... shipment performed by the Radwacte department; previous shipments were LSA.

COBRECTIVESIEES_TAKENAND_THERESULTS_ ACHIEVED:

An investigation was performed which determined that procedure inadequacy was the root cause.

CORRECIIVE STEES_TAKENIOAVOID.EUBTHER VIOLAliONS:

The radioactive waste shipment checklist for LaSalle County Station (contained in procedure LAP-100-27 "Guidelinas for Radioactive Waste / Material Shiprnents") was revised on September 24,1992, to address proper labelling of Yellow 111 and LSA waste shipments.

ZNLD/2188/2

BESNSEJO_NDIlCEQEYKXAllON NBCJNSEECIT)QN RERORT_NOE 50:37292016L50-aL4/92016

- COBBERTJYE_STEESJAKEN.IOMOlDJUBIHEB_VKAATIONS; (contirmed)

O)erational personnelinvolved in the transportation of radioactive waste have been informed of this event and have reviewed the revised version of --

LAP-100-27.

Further evaluation is in progress v*ich considers other recent waste shipping events within CECO. This evaluation and appropriate program / procedure changes applicable to LaSalle are expected to be completed by December.31,1992.

DATE WHEN.EULLCOMELIANCEWILLBEACHIEVED Full compilance was achieved upon revising LAP-100 27.

I l

l L

L L

l l

l

- ZNLD/2188/3 -

i l-

-