ML19347A819

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Responds to NRC Re Violations Noted in IE Insp Rept 50-344/80-17.Corrective Actions:Procedure Implemented Requiring Checklist Be Used During Insp of Drums Prior to Shipment to Verify Proper Labeling
ML19347A819
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 08/22/1980
From: Goodwin C
PORTLAND GENERAL ELECTRIC CO.
To: Engelken R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML19347A818 List:
References
NUDOCS 8009300314
Download: ML19347A819 (3)


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August 22, 1980 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. R. H. Engelken, Director U. S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 199J N. California Blvd.

Walnut Creek, CA 94596 De_e Sir:

Your letter of August 6,1980 forwarded the results of the unannounced NRC inspection of'a radioactive waste shipment from the Trojan Nuclear Plant to Richland, Washington, on June 19, 1980. The inspection identi-fled two. items of noncompliance. The attachment to this letter contains PGE's response to tne Notice of Violation.

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C. Goodwin, Jr.

Assistant Vice President Thermal Plant Operation and Maintenance i

CC/TDW/mg/4sa5A5 Attachment c:

Mr. Lynn Frank, Director State 'of Oregon Department of Energy 1-l21 SW Smen hMot 4"*wt Gigon 9/204 G'r 8009300314 U V %m* '/

ATTACHMENT RESPONSE TO NOTICE OF VIOLATION Item A 10 CFR 71.5(a) requires that licensees delivering licensed material to a carrier for transport comply with the applicable requirements of the regulations appropriate to the mode of transport, of the Department of Transportation in 49 CFR Parts 170-189.

Regulation 49 CFR 173.392(c)(8) requires that packages of low specific activity materials transported in transport vehicles assigned for sole use of that consignor be stencilled or marked on the outside with the words " Radioactive - LSA".

Contrary to this re uirement (10 CFR 71.5), two containers, No. 363 and No. 409, in your shipment dated June 18, 1980 did not have the marking

" Radioactive - LSA" on the outside of the package.

Response

The two containers, No. 363 and No. 409, were buried at the Nuclear Engineering Co. (NECO) site following approval by the State of Washington inspector and inspection by a. representative of PGE.

Co.

A new procedure was issued which requires that a checklist be uued during the inspection of the drums prior to shipment to verify that all con-tainers are properly labeled. The new procedure was approved and implemented on June 26, 1980.

Item B 10 CFR 71.5(a) requires that licensees delivering licensed material to a carrier for transport comply with the applicable requirements of the regulations appropriate to the mode of transport, of the Department of Transportation in 49 CFR Parts 170-189.

Regulation 49 CFR 173.392(c)(1) requires that packages of low specific activity materials tansported in transport vehicles assigned for sole use of that consignor be packaged in strong tight packages so that there will be no leakage of radioactive material under conditions normally incident to transportation.

In addi-tion, 10 CFR 30.41(b) limits the transfer of byproduct materials to "any person authorized to receive such byproduct material under terms of a specific license.

issued by.

an Agreement State".

Para-graph "(a)" of Condition 27 in license No. WN-IO19-2, issued by the State of Washington to Nuclear Engineering Company, Inc., states that "the licenuae shall not receive any liquid waste".

Contrary to the above, one container, No. 365, in your shipment dated June 18, 1980 was observed to drip liquid during of f-loading at the Nuclear Engineering Company, Richland, Washington, disposal site.

Wipes taken of the leaked liquid and container indicated no removable radioactive contamination.

Response

Container No. 365 was opened at Richland at the NECO site and inspected by representatives of PGE cnd NECO.

A small quantity of liquid (probably water) was found on various plastic articles in the drum.

This liquid contained no detectable radioactive contamination.

The inspection indicated that the liquid entered the drum through a damaged lid. The lid was dented, permitting water to collect on the lid and enter through a bung in the lid.

In addition, the lid gasket was not properly seated. The drum was resealed and placed inside a NECO recovery drum ~which was packed with absorbent, sealed, and buried.

In addition to the inspection of drum No. 365, PGE canceled further t'TP shipments of radioactive waste (prior to the State of Washington suspen-sion of the Trojan disposal permit)' pending completion of permanent corrective action on site.

The new procedure discussed in our Response to A above requires that drums be inspected for to ensure that drums with defects are not utilized for future shipments.

Specifically, the procedure requires the following:

a.

Drum lids will not have bungs.

b.

Drum lid gaskets will be glued in place.

An approved absorbent will be added to each drum during c.

filling.

d.

The drums will be visually inspected for damage prior to shipment and inspected for any evidence of liquid.

This procedure was approved and implemented on June 26, 1980.

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