ML20126C741

Responds to Noncompliance Noted in Insp Rept 50-155/85-06, Per 850521 Telcon.Corrective Actions:Radwaste Shipment Procedures Will Be Revised to Include Refs to 10CFR61.55 & 56 & Will Include QC Assessment of Compliance w/10CFR20.311

ML20126C741
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/31/1985
From:	Vandewalle D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 8506140511
Download: ML20126C741 (2)

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Nuclear Ucensmg General offces: 1945 West Parnall Road, Jackson, MI 49201 . (517) 788-1636 May 31, 1985 James G Keppler, Administrator Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 DOCKET 50-155 - LICENSE DPR BIG ROCK POINT PLANT -

RESPONSE TO INSPECTION REPORT 50-155/85006 One item of noncompliance was identified in Inspection Report 50-155/85006.

Per telephone conversation between respective members of our staffs on May 21, 1985 the response date was extended to May 31, 1985. The following is our response to this item:

Noncompliance 50-155/85006-01 Code of Federal Regulations Title 10 Part 20.311.(d) states:

Any generating licensee who transfers radioactive waste to a land disposal facility or a licensed waste collector shall comply with the requirements in paragraphs (d)(1) through (8) of this section.

Paragraph (d)(3) states that a licensee shall conduct a quality control

-program to assure compliance with parts 61.55 and 61.56 of this chapter; the l program must include management evaluation of audits.

Contrary to the above, the licensee does not conduct a quality control program to assure compliance with the waste classification and waste characteristics requirements of 10 CFR 61.55 and 10 CFR.56 (sic).

Discussion

-The Quality Assurance / Control Department has been and will continue to monitor radwaste shipment activities. Although no specific reference is made to 10 CFR 61 or 10 CFR 20.311 in the QC checklist for radioactive shipments, a detailed verification of all aspects of the activity is completed prior to the  ;

shipment. This is evident, since the inspectors found the three shipments j made since implementation of the new regulation to be properly classified and '

all required paperwork present. We do recognize that a corporate procedure

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J G Keppler, Administrator 2 Big Rock Point Plant Inspection Report 85006 May 31, 1985 combined with a plant procedure was used to administer these shipments and that improvements should be made.

Corrective Action Taken and Results Achieved No action taken because all three shipments under the new regulations were in compliance as noted in the Inspection Report.

Correction Action To Be Taken To Avoid Further Noncompliance Radwaste shipment procedures will be revised to include references to 10 CFR 61.55 and 56 and include Quality Control Department assessment to insure compliance with vaste classification and characteristic requirements per 10 CFR 20.311. The Quality Assurance / Quality Control personnel will not perform the calculations but will overview the shipment activities to assure compliance.

Date When Full Compliance Will Be Achieved As stated in the Inspection Report, procedure changes will be completed prior

- to the next shipment to a burial ground.

9 David J ndeWalle Director, Nuclear Licensing CC Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement NRC Resident Inspector - Big Rock Point k

OC0585-0214A-NLO4

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