ML041060612
| ML041060612 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 04/12/2004 |
| From: | Jensen J Indiana Michigan Power Co |
| To: | Document Control Desk, NRC/OE |
| References | |
| AEP:NRC:2201-02, EA-04-006 | |
| Download: ML041060612 (5) | |
Text
Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1395 INDIANA MICHIGAN POWER April 12, 2004 AEP:NRC:2201-02 Docket No.:
50-315 50-316 U. S. Nuclear Regulatory Commission, ATTN: Document Control Desk Mail Stop O-Pl-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 REPLY TO NOTICE OF VIOLATION AND ENFORCEMENT ACTION EA-04-006 Indiana Michigan Power Company (I&M), the licensee for Donald C. Cook Nuclear Plant, Units 1 and 2, is submitting the attached information in response to the Notice Of Violation (NOV) identified in Nuclear Regulatory Commission (NRC) Inspection Report 50-315/2004005 (DRS); 50-316/2004005 (DRS) and Enforcement Action (EA) EA-04-006. Specifically, on October 7, 2003, I&M dispatched a radioactive waste shipment to Radiological Assistance Consulting and Engineering (RACE) for processing.
Upon arrival at RACE, it was identified the shipment had a localized surface contact reading in excess of shipping limits established in 49 CFR 173.441. I&M acknowledges and accepts this violation.
The attachment to this letter contains a detailed discussion of I&M's evaluation and corrective actions associated with this NOV and EA.
No commitments are identified in this letter.
If you have any questions or desire additional information, please contact Mr. Toby K. Woods, Compliance Supervisor, at (269) 466-2798.
- Sincqcdy, N.Jensen Site Vice President RAM/jen Attachment W/f~A
U. S. Nuclear Regulatory Commission Page 2 AEP:NRC:220 1-02 c:
J. L. Caldwell - NRC Region III K. D. Curry - AEP Ft. Wayne J. T. King - MPSC MDEQ - WHMD/HWRPS NRC Resident Inspector J. F. Stang, Jr. - NRC Washington DC
ATTACHMENT TO AEP:NRC:2201-02 REPLY TO NOTICE OF VIOLATION AND ENFORCEMENT ACTION EA-04-006 Restatement of Violation:
"During an NRC inspection conducted between December 1, 2003, and January 8, 2004, at the D. C. Cook Nuclear Power Plant, a violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
NUREG-1600, the violation is listed below:
10 CFR 71.5(a) requires that each licensee who transports licensed material outside of the site of usage, as specified in the NRC license, or where transport is on public highways, or who delivers licensed material to a carrier for transport, comply with the applicable requirements of the Department of Transportation (DOT) regulations in 49 CFR Parts 170 through 189 appropriate to the mode of transport.
49 CFR 173.441(a) requires, in part, that each package of Class 7 (radioactive) materials offered for transportation must be designed and prepared for shipment, so that under conditions normally incident to transportation, the radiation level does not exceed 200 millirem per hour at any point on the external surface of the package.
Contrary to the above, on October 7, 2003, the licensee offered for transportation to a carrier a Class 7 (radioactive) material package that was not prepared for shipment so that, under conditions normally incident to transportation, the radiation level did not exceed 200 millirem per hour at any point on the external surface of the package. Specifically, the radiation level on a localized area of the package surface was 250 millirem per hour when the package arrived at its destination on October 8, 2003."
Admission/Denial of the Violation:
Indiana Michigan Power Company (I&M) acknowledges the violation described above.
Reasons for the Violation:
The failure to properly prepare the shipment to ensure that, under conditions normally incident to transportation, the package external surface dose rates did not exceed the DOT dose rate limit was the result of human error and inadequate procedural controls. The shipment (RMC03-103) contained two packages. The package that was found to exceed the DOT dose rate limit was a sea van container loaded with bags containing dry active waste (DAW). In accordance with
Attachment to AEP:NRC:2201-02 P ag e 2 Donald C. Cook Nuclear Plant (CNP) procedures, a radiological survey of the exterior surface of the shipment's packages was performed prior to dispatching the shipment.
This radiological survey indicated that the highest surface contact reading on the subject package was 33 mR/hour as measured with a Bicron Tech-50 GM tube survey instrument. This sea van was loaded on the rear of the trailer approximately two feet forward of the end of the trailer. The suspected cause of the increased exterior dose rate was the movement of radioactive material within a bag loaded near the external surface of the van during transport. Procedural controls for the loading of DAW into the package were not adequate to prevent this occurrence.
Corrective Actions that Have Been Taken and Results Achieved:
- On October 8, 2003, I&M immediately dispatched an individual to the Radiological Assistance Consulting and Engineering (RACE) facility in Memphis, TN, to verify, confirm, and investigate the RACE findings.
[CR 03281042 Section VII, Condition Evaluation, Sub-Section 6.0, Corrective Actions]
- On October 9, 2003, a stand-down with applicable I&M personnel was held to discuss the details of the event.
Additionally, a requirement to have the Radiation Protection (RP)
Manager's and Site Vice President's approval prior to the release of future shipments was communicated to all individuals.
[CR 03281042 Section VII, Condition Evaluation, Sub-Section 6.0, Corrective Actions]
- On October 23, 2003, formal interim corrective actions were completed and put in place.
Environmental Department personnel were trained on these interim corrective actions. These interim actions were established until the final corrective actions were implemented. These interim corrective actions included:
[CR 03281042 Section VII, Condition Evaluation, Sub-Section 6.0, and Corrective Actions Action 2]
O Specification of the use of an ESP-2 with an HP-270 probe (GM tube) for outgoing radioactive shipments greater than a Limited Quantity as defined by DOT.
0 Required use of audible response during the conduct of surveys.
0 Verification of waste bags' "RAM tag" (radioactive material tag), data if indicated dose rate exceeded 10 mR/hour.
0 Reinforcement of the need to take special care during the survey of items containing discreet radioactive particles.
0 Required use of a "loading plan" approved by an Environmental Supervisor prior to loading any wastes > 50 mR/hour and any wastes containing discreet radioactive particles
> IO mR/hr.
0 Reinforcement of the requirement to survey the entire surface area of outgoing radioactive material packages.
0 Established enhanced controls over the packaging of radioactive materials for shipment (non-waste materials), that are packed by non-Environmental Department personnel.
I Attachment to AEP:NRC:2201-02 Page 3 0
Required that individuals performing outgoing package and vehicle surveys review any pertinent information as to the package or vehicle's radioactive contents (e.g., packing lists, equipment/package survey reports, and shipping plans).
- During the month of February 2004, four different formal training sessions were conducted to train all RP and Environmental technicians on various Operating Experience (OE) events pertaining to shipments in which the DOT dose rate limits were exceeded. The training also included a dynamic learning activity in which the lessons learned from the various OEs were simulated in a laboratory setting. [CR 03281042 Actions 3 and 4]
- On March 19, 2004, revisions to affected radioactive shipping and packaging procedures were completed. These revisions incorporated the formal interim corrective actions that were put in place on October 23, 2003. [CR 03281042 Action 2]
The above discussed corrective actions have established enhanced procedural controls for the packaging and surveying of radioactive shipments, established enhanced personnel knowledge and abilities, and ensured the appropriate radiological survey equipment is available and used during the conduct of radiological surveys of potentially radioactive shipments.
Corrective Actions that Will Be Taken to Avoid Further Violations:
The corrective actions discussed above have been reviewed and deemed adequate to prevent recurrence of the event identified in Enforcement Action EA-04-006.
Date Full Compliance Will Be Achieved:
I&M achieved full compliance on October 23, 2003.