ML20237J662
| ML20237J662 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/10/1987 |
| From: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| To: | Marshall S NEVADA, STATE OF |
| Shared Package | |
| ML20237J664 | List: |
| References | |
| P-87284, NUDOCS 8708180285 | |
| Download: ML20237J662 (5) | |
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16805 WCR 19 1/2, Platteville, Colorado 80651 August 10, 1987 Fort St. Vrain Unit No. I P-87284 Mr. Stanley R. Marshall State of Nevada Department of Human Resources Health Division Radiological Health Section 505 East King Street, Room 202 Carson City, NV 89710 Docket No. 50-267
SUBJECT:
Request for waiver from third party inspection requirements, clarifying information
REFERENCE:
State of Nevada Letter, Marshall to Schleiger, dated July 17, 1987
Dear Mr. Marshall:
,,,,,,i w Thank you for the expeditious consideration of our application for j.p g;ge.c4, renewing the Nevada Site User Permit.
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In response to your letter detailing the additional clarifying g:;; r;;g pc cy,,,
information needed to evaluate our request for waiver from third l: ",2";M ""'
party inspection requirements, the following informatin and t*;J:'Mi supporting documentation is provided.
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P-87284 August 10, 1987 We appreciate this opportunity to respond to your questions concerning our request for waiver from the third party inspection requi remer..
If additional questions arise er if you require any additional documentation, please direct your concerns to Mr. Timothy E. Schleiger who will be able to assist you.
His phone number is (30',; 620-1126.
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- Sincerdy,
[ s'y' R. O. Williams, Jr.
Vice President, Nuclear Operations ROW:SSS/skd Attachments 9
5 I
Question #1 Requirement to inspect containers used for radioactive material packaging prior to use.
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Response
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The physical integrity of each container is to be inspected prior l
to use by Maintenance Quality Control (MQC) Personnel.
This inspection is detailed in paragraph 28 on page 16 of MQCIM-1 and documented on attachment MQCIM-1E, Raduaste Packaging QC Monitoring / Inspection Report.
Maintenance Quality Control again inspects each container uhen the package is prepared for shipment.
Paragraph 38 on page 17 of HQCIM-1 details this requirement and the inspection is documented on Attachment MQCIM-1F, Radioactive Materials Shipment Checklist, item #1 Containers are also inspected by the Health Physics Technician who fills the container and readies the package for storage prior to shipment.
(Reference page 29, paragraph (p). HPP-26.)
Question #2 Requirement for periodic audits by an independent group of radioactive waste processing and packaging procedures.
Response
Included is a copy of the applicable page from the Final Safety Analysis R,eport for Fort St. Vrain, a copy of Q-18, the Administrs!!ive Procedure that est.ablishes the QA Monitoring and Radit Program and QAAP-1 that seth the frequency cf audits of the radioactiv;evasteproces]ing and ' packaging program.
A copy of the audit' checklist used'during the January, 1987 QA audit is also included.
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L QAAP-1 of the Quality. Assurance Administrative Procedures gives instructions for creating the master audit schedule.
RADS-01 is
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the title of the audit that reviews the procedures for processing, packaging.and. shipping of radioactive materials and for-training of the personnel to perform these activities.
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i in addition to the Fort St. Vrain GA conducted audits, Health' Physics is audited and inspected in the area of radioactive l
1 material packaging, processing and shipping by the Nuclear
-j Facility Safety Committee, composed of experts independent of Public Service Company, the Nuclear Regulatory Commission and the Institute of Nuclear Pouer Operations (INPO).
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. Question #3 I
Clarification of technical statements made in HPP-30
Response
Attachment HPP-30C is a summary of all requirements for each shipping classification of radioactive inaterial.
" Radiation Controls and Limits" is a summary of 49CFR requirements for radiation levels on packages and/or vehicles of radioactive material.
More specific instructions are'given in the individual' checklist contained in attachment HPP-30D.
The statement "Each package of radioactive material shall not exceed 200 milliREN/hr and 10 millirem /hr at one meter (transport index of 10) at any point on the external surface of the package." is meant to be interpreted in the follouing way:-
1 The radiation level vill not exceed 200 millirem /hr at any j
e point on the external surface of the package.
and 1
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- 2 The radiation vel vill not exceed 10 milliREH/hr at any point one meter from the package,'a transport index of 10.
This is' meant to comply with requirements of 49CFR173.441 Question 3A' l
Refers.to pageH29 of HPP-30 a summary of the' radiation limits for nonexclusive use. shipments of LSA material.
The radiation limits are 200.mR/hr on contact on the package and 10 mR/hr at one meter from the package.
Question 38 and 3C Refers to pages-38 and 43 of-HPP-30 a summary of the radiation limits for shipping Type A and Type B packages of radioactive material.
The radiation limits for the package are.200 mR/hr on contact and 10 mR/hr at one meter from the package.
If the package'is transported by an exclusive use vehicle, the limit on the package is 1000 mR/hr on contact, 200 mR/hr on the surface of the vehicle and 10 mR/hr 2 meters from the vehicle.
Additionally, the requirements for maintaining an exclusive use vehicle.must by adhered to.
This is consistent uith the requirements'of 49CFR173 441 Question 3D Refers to pages 74 and 75 of HPP-30, a table of-minimum shipping requirements.
This query has identified a typographical error l
that was not identified in the procedure review process.
The table should read "A and A2 values".
Steps have been initiated t
to correct this error in the procedure.
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