ML20204G232

Responds to NRC Re Violations Noted in IE Insp Rept 50-309/82-17.Corrective Actions:Personnel Responsible for Shipping Radioactive Matl Reminded That All Required Insps Must Be Documented.Procedure 9.1.15 Revised

ML20204G232
Person / Time
Site:	Maine Yankee
Issue date:	04/12/1983
From:	Garrity J Maine Yankee
To:	Allan J, Allen J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20204G214	List: IR 05000309/1982017 ML20204G232
References
0768L-SEN, 768L-SEN, JHG-83-76, MN-83-69, NUDOCS 8305020393
Download: ML20204G232 (4)

Text

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EDISON DRIVE MAIRE '"=itiHARHEE AToml0PDL1/ERCOMPARS*

AUGUSTA, MAINE 04336 (207) 623-3521

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-Q April 12, 1983 M4-83-69 JHG-83-76 Region I United States Nuclear Regulatory Commission Office of Inspection and Enforcement 631 Park Avenue King of Prussia, Pennsylvania 19406 Attention: Mr. James M. Allen, Deputy Administrator

References:

(a) License No. DRP-36 (Docket No. 50-309)

(b) USNRC Letter to MYAPCo dated January 31, 1983, Inspection No. 82-19

Subject:

Response to Inspection 82-17, Radioactive Material Shipment Program

Dear Sir:

This letter transmits Maine Yankee Atomic Power Company's response to Inspection Report No. 82-17. This response addresses the specific violations identified, and provides corrective actions completed and planned to reduce the probability of recurrences.

ITEM A - APPENDIX A Contrary to 10 CFR 71.62, on April 12, 1982, the licensee shipped 168.8 Curies of licensed material in a package identified as DOT Specification 20 WC-4 and the licensee did not maintain records of the results of the determinations required by 10 CFR 71.54.

RESPONSE

A mechanical problem with the source drawer assembly in the Eberline Instrument Corporation 10008 Gamma Calibrator necessitated sending the source unit back to Eberline for repair. Eberline sent the 20 WC-4 shipping container to Maine Yankee who was responsible for loading the 168.8 curie Cesium-137 source. Radiological Controls Procedure 9.1.15 requires that a record of the routine determinations required by 10 CFR 71.54 be documented.

The cask inspection was completed by the Radiological Controls Supervisor but the required documentation was not completed because he incorrectly believed that Procedure 9.1.15 applied to rad-waste shipments only.

l 8305020393 830426 DR ADDCK 05000309 PDR 0768L - SEN

MAINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission April 12, 1983 Attention: Mr. James M. Allen, Deputy Administrator Page Two MN-83-69 o

Immediate Corrective Actions:

All personnel responsible for shipping radioactive material were reminded that all required inspections must be documented.

Since this violation, no further improperly documented radioactive shipments have been made.

o Corrective Actions to Prevent Recurrence:

1.

Procedure 9.1.15 will be revised to more explicitly emphasize that the procedure applies to shipment of all radioactive material.

2.

All personnel responsible for shipping radioactive material will attend a retraining program covering federal, state and plant requirements regarding shipments of radioactive materials.

3.

This retraining program will also include a review of the violations cited in this inspection report and the personnel will be reminded of the correct policies to prevent recurrence.

This retraining program will be conducted by June 1, 1983.

Full Compliance Date:

o Full compliance was achieved when the personnel responsible for shipping radioactive material were reminded of documentation requirements on September 17, 1982.

4.

A note will be added to the file stating that the 10 CFR 71.54 determinations were in fact performed. This documentation will be clearly indicated as being a backfit for the purpose of insuring that records are complete and to bring about compliance with the requirements that the 10 CFR 71.54 determinations be documented. This action will be completed by April 18, 1983.

ITEM B.1 - APPENDIX A Procedure No. 0-03-1, Revision 0, dated August 28, 1981, " Material Receipt, Handling and Storage," developed pursuant to the above, requires a receipt inspection of all " items requiring QA as specified in Appendix C of the QA Program." Shipping packages are specified in Appendix C.

Item 4.2 of Procedure No. 0-03-1 requires receipt inspections be documented on Form No.

0-03-1-1.

Contrary to the above, the procedure was not followed on or about April 12, 1982, inasmuch as the receipt inspection performed on the package identified as DOT Specification 20 WC-4 was not documented on Form No.

0-03-1-1.

0768L - SEN

MAIME YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission April 12, 1983 Attention: Mr. James M. Allen, Deputy Administrator Page Three MN-83-69

RESPONSE

Quality Assurance Procedure No. 0-03-1, " Material Receipt, Handling and Storage," requires a receipt inspection of all QA related materials and documentation of sucn using Form No. 0-03-1-1.

The shipping container was not ordered QA related because Appendix C of the Maine Yankee QA program only requires that packaging of radioactive waste materials for transport be treated as QA related. The source was not considered to be waste and therefore was not considered to require QA. As a result, the QA Department was not notified upon receipt of the container and, therefore, did not perform the inspection required by their procedure. This notwithstanding, Maine Yankee believes that this is a valid deficiency requiring corrective action.

o Immediate Corrective Actions:

Upon notice of the procedure violation, QA personnel decided that performing a receipt-inspection at that time to backfit QA records was not necessary since the shipping container was inspected in accordance with 10 CFR 71.54 prior to shipment offsite to the vendor, o

Corrective Actions to Prevent Recurrence:

In order to correct deficiencies in communications between the Radiological Controls and Quality Assurance Departments:

5.

The QA Department will review receiving and shipping procedures for conformance to the QA program and make appropriate procedure changes.

6.

Procedure No. 0-03-1 will be revised to specify the requirements for receipt intoection of all containers used to handle greater than Type A material as defined in 10 CFR 71.7.

7.

The retraining program for Radiological Controls personnel, mentioned l

in response to Item A, will identify the root cause of this violation and stress correct procedures for the ordering and handling of this material.

These actions will be completed by October 1, 1983.

In addition, the requirements of Appendix C of the QA Program regarding radioactive material shipping containers will be reviewed for compliance with 10 CFR 71.51.

8.

Any changes to the QA Program found to be necessary will be proposed by October 1, 1983.

0768L - SEN

i, M AINE YANKEE ATOMIC POWER COMPANY United States Nuclear Regulatory Commission April 12, 1983 Attention: Mr. James M. Allen, Deputy Administrator Page Four MN-83-69 o

Full Compliance Date:

Full compliance to 10 CFR 71 was restored when the shipping container was inspected prior to shipment offsite to the vendor on April 12, 1982.

ITEM B.2 - APPENDIX A Item 5.10 of Procedure No. 9.1.15, Revision No. 8, dated February 12, 1982, developed pursuant to the above states, "The Radioactive Quality Assurance Record (MY-HP-108-79) must be completed for all shipments of radioactive waste, and any material containing greater than Type "A" quantities of radioactive material."

Contrary to the above, the procedure was not followed en April 12, 1982, inasmuch as the licensee shipped 168.8 Curies of Cesium-137, an amount in excess of Type A quantities, and the Radioactive Quality Assurance Record (MY-HP-108-79) was not completed.

RESPONSE

The violation in Item A of Appendix A, Reference (b), was cited because personnel did not conform with the requirements of 10 CFR 71.54 when they shipped 168.8 curies of Cesium-137 on April 12, 1982. This violation also resulted because the same personnel did not follow Radiological Controls Procedure No. 9.1.15 for the same shipment on April 12, 1982.

If that procedure were followed correctly, neither the Item A violation nor this violation would have occurred.

The response to this item is provided in the response to Item A.

We trust this response is satisfactory. Should you have further questions, please feel free to contact us.

Very truly yours, MAINE YANKEE ATOMIC F0WER COM'ANY John H. Garrity, Seniors Director Nuclear Engineering and' Licensing JHG:pjp cc: Mr. Robert A. Clark Mr. Paul A. Swetland 0768L - SEN