ML20217F668

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Provides Revised Response to Two Items in IE Bulletin 79-19, Packaging of Low Level Radwaste for Transport & Burial. Revised Responses Provided Based on Recent Review of Commitments in to NRC
ML20217F668
Person / Time
Site: San Onofre  Southern California Edison icon.png
Issue date: 10/07/1997
From: Rainsberry J
SOUTHERN CALIFORNIA EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-361-97-10, 50-362-97-10, IEB-79-19, NUDOCS 9710090018
Download: ML20217F668 (3)


Text

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October 7, 1997 U. L. Nuclear Regulatory Commission Attn: Document Control Desk Washington D. C. 20555 Gentlemen:

Subject:

Docket Nos. 50-361 and 50-362 Revised Responses to NRC IE Bulletin No. 79-1)

San Onofre Nuclear Generating Station Units 2 and 3

References:

1. IE Bulletin No. 79-19, " Packaging of Low Level Radioactive Waste for Transport and Burial"
2. September 19, 1979 letter from Mr. J. T. Head, Jr. (SCE) to Mr. R. H. Engelken (NRC),

Subject:

Docket No. 50-206, San q

Onofre Unit 1, IE Bulletin 79-19 This letter provides revised responses to two items in IE Bulletin (IEB)

No. 79-19 (reference 1) for San Onofre Units 2 and 3.

These revised responses are provided based on a recent review of connitments made to IEB 79-19 in a September 19, 1979 letter to the NRC (reference 2). The commitment to review the Southern California Edison (SCE) positions concerning IEB 79-19 is documented in NRC-inspection report 50-361/97-10;50-362/97-10.

The two NRC information requests, items 3 and 5 from IEB 79-19, and SCE's original and revised responses are as follows:

Of[

Item #3 Designate, in writing, people in your organization who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

Original Response Station Order S-E-205, Receipt and Shipment of Radioactive Material, delineates among other things the basic requirements for snipent of radioactive materials. This procedure will be revised to designate station 9710090018 971007 PDR ADOCK 05000361 Q

PDR San Onofre Nudear Gmerating Statkm San Clemente. CA 92674 0128 714-3684 420

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d Document' Control Desk personnel who are responsible for the safe transfer, packaging and transport of low-level radioactive material.

This revision will be completed by October 31, 1979.

l Revised Response Trained and qualified Health Physics Division personnel are responsible for the safe transfer, packaging, and transport of licensed radioactive material as described in NRC IEB 79-19 and 00T regulations.

Basis for Revised Response The changes are in response to comments received during a recent NRC inspection.

Station Order S-E-205 has been superseded by other Health Physics procedures which continue to delineate responsibilities for the personnel involved in radioactive shipping activities.

Shipment of radioactive material is solely the responsibility of the Health Physics Division.

Procedure changes since 1989 have had 10 CFR 50.59 screens, and therefore do not represent an unreviewed safety question.

Item f5 Provide training and periodic retraining in the DOT and NRC regulatory requirements, the waste burial license requirements, and in your instructions and operating procedures for all personnel involved in the transfer, packaging and transport of radioactive material. Maintain a record of training dates, attendees, and subject material for future inspections by NRC personnel.

Original Response Training is currently provided to operating personnel in instructions and operating procedures related to the transfer, packaging and transport of radioactive material as part of the operator requalification program and to chemical radiation technicians in waste shipments and spent fuel chipping and transportation regulations. This training program will be expanded to include all station personnel involved in the handling, shipping and packaging of radioactive material and will cover D0T and NRC regulatory requirements and instructions and procedures related to the transfer, packaging and transport of radioactive materials.

A record of-training dates, attendees, and subject material will be maintained for future inspections.

This program shall be prepared ar,d implemented by December 31, 1979.

3

Docoment tontrol Desk Revised Response Training and periodic retraining is given to Health Physics personnel identified in the response to item #3 who have been assigned to the transfer, packaging, and transport of radioactive material.

Operations, Maintenance, Quality Control, and other ancillary personnel do-not require IE Bulletin 79-19 training in the burial site license criteri.

or applicable shipping regulations of the DOT or NRC since they are not-responsible for shipping activities.

All radiation workers performing ancillary support duties receive basic radiation protection training which qualifies them to handle radioactive material.

The level of training is comensurate with the work performed and is controlled by health physics procedures and programs.

Basis for Revised Response The changes are in response to coments received during a recent NRC inspection.

The changes do not represent a reduction in comitment in that the personnel directly responsible for and in control of radioactive material shipments are appropriately trained in both NRC and 00T regulations, and others " involved" have appropriate radiation worker training comensurate with their involvement. This is not a change in

--intent; it is only a clarification of who is " involved."

These revisions to the response to IE Bulletin 79-19 reflect the current SCE positions.and practices for handling low-level radioactive waste shipments and meet the intent of IE Bulletin 79-19.

If you have any questions or would like additional information on this subject, please contact me.

S:incerel,

cc: E. W. Herschoff, Regional Administrator, NRC Region IV K. E. Perkins, Jr., Director. Walnut Creek Field Office, NRC Region IV J. A. Sloan, NRC Senior Resident Inspector, Sar Onofre Units 2 & 3 M. B. Fields, NRC Project Manager, San Onofre Units 2 and 3