ML17308A251

Responds to Violations Noted in Insp Repts 50-335/86-09 & 50-389/86-08.Corrective Actions:Shipping Procedure Changed to Reflect New Regulation Re Radiation Level Limitations & Issuance of Respiratory Protection Devices Proceduralized

ML17308A251
Person / Time
Site:	Saint Lucie
Issue date:	07/30/1986
From:	Woody C FLORIDA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
L-86-316, NUDOCS 8608110518
Download: ML17308A251 (7)

Text

e ~ Il ~ FLORIDA POWER & LiGHT COMPANY I

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~30 $ BBB L-86-316 Dr. 3. Nelson Grace Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323

Dear Or. Crace:

RE: St. Lucie Units 1 R 2 Docket Nos. 50-335, 50-389 Ins ection Re rt 86-09 and 86-08 Florida Power R Light Company has reviewed the subject inspection report, and a response is attached.

There 'o proprietary information in the report.

V y tr ly your,.

. O. Woody C up Vice desi en Nuclear Energy COW/SA V/eh attachment cc: Harold F. Reis, Esquire PNS-LI'-86-228 8608110518 860730 PDR ADOCK 05000335 PDR PSy 1 PEOPLE ~, . SERVING PE<

4 RE: St. Lucie Units 1 and 2 Docket Nos. 50-335 and Report 86-09 and 86-08 50-389'nspection ATTACHMENT Violation A. 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of their plants or other place of use, or who deliver licensed material to a carrier for transport, comply with the applicable requirements of the regulation appropriate to the mode of transportation of the Department of Transportation in 09 CFR Parts 170 through 189.

09 CFR 173.001(a) states that except as provided in 09 CFR 173.041(b), each package of radioactive materials offered for transportation shall 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 December 13, 1985, the licensee shipped two boxes of radioactive materials, Box No.85-105 and Box No.85-112, to a land disposal facility at Barnwell, S. C. with dose rates of 250 and 000 millirem per hour, respectively, on the external surfaces of the packages. The exceptions of 09 CFR 173.001(b) did not apply because the shipment was not made in an enclosed vehicle.

Response A. Florida Power and Light (FPL) concurs with this violation.

2. The violation occurred due to the interpretation of a

- change in D.O.T. shipping regulations.

30 The shipping procedure has been changed to reflect the new regulation. A detailed description of the Radiation Level Limitations for package and vehicles has been incorporated into the procedure. There have been no violations since this finding.

The initial corrective actions are sufficient to avoid further violations.

5. Full compliance has been achieved.

PSO 1 Page 1 of 3

Violation B. 10 CFR 71.5 requires that licensees who transport licensed material outside the confines of their plants comply with the applicable requirements appropriate to the mode of transport of the Department of Transportation (DOT) 09 CFR Parts 170 through 189.

09 CFR 173.025(b)(l) requires that packaged shipments of low specific activity (LSA) material consigned as exclusive use must be packaged in a DOT Specification 7A Type A package or in a strong, tight package so that there will be no leakage of radioactive material under conditions normally incident to transportation.

Contrary to the above, the licensee failed to package a shipment of LSA radioactive material in a DOT Specification 7A Type A package or a strong, tight package in that on October 22, 1985, shipment No. 85-09 arrived at the burial facility with a hole in one B-25 metal box.

Response B.

l. Florida Power and Light (FPL) concurs with this violation.

2. Based upon all of the evidence considered, FPL believes the most probable reason for the violation was due to personnel oversight during inspection of the radioactive materials shipment.

3. The shipping procedure has been changed to provide for a more thorough inspection of containers prior to shipment. There have been no violations since this finding.

The initial corrective actions are sufficient to avoid fur ther violations.

5. Full compliance has been achieved.

PSO 1 Page 2 of 3

Violation C. 10 CFR 20.103(c)(2) provides in part that the licensees may make allowance for use of respiratory protective equipment in estimating exposures of individuals to radioactive materials in air provided that the licensee maintains and implements a respiratory protection program that includes, as a minimum, written procedure regarding supervision and training of personnel and maintenance of records.

Contrary to the above, on April 18, 1986, the NRC inspector noted the licensee was making allowance in its Maximum Permissible Concentration hour assignment records for use of respiratory protective equipment in estimating exposures of individuals to radioactive material in air for purposes of determining compliance with 10 CFR 20.103. However, the licensee did not have written procedures regarding maintenance of records

'showing that an individual had been issued a respirator.

Responce C. 1. Florida Power and Light (FPL) concurs with this violation.

2. The violation was due to an incorrect interpretation of the regulations by the Health Physics Group.

3. The issuance of respiratory protection devices has been proceduralized. There have been no violations since this finding.

The initial corrective actions are sufficient to avoid further violations.

5. Full compliance has been achieved.

PSO:1 Page 3 of 3

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