ML18040A338

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-220/98-04 & 50-410-98-04.Corrective Actions:Truck Was Decontaminated by Chem-Nuclear Personnel & Performed Follow Up Surveys on Other Trailers & Equipment

ML18040A338
Person / Time
Site:	Nine Mile Point
Issue date:	04/28/1998
From:	Mueller J NIAGARA MOHAWK POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-220-98-04, 50-220-98-4, 50-410-98-04, 50-410-98-4, NMP1L-1308, NUDOCS 9805050389
Download: ML18040A338 (12)

Text

CATEGORY 1 REGULATORY XNFORMATXON DISTRIBUTION SYSTEM (RIDS)

ACCESSZON NER:9805050389 DOC.DATE: 98/04/28 NOTARZEED: YES DOCKET I FACIL:50-220 Nine Mile Point Nuclear Station, Unit 1, Niagara Powe 05000220 50 410 Nine Mile Point Nuclear Station, Unit 2, Niagara Moha 05000410 UTH.NAME AUTHOR AFFILIATION 1 ELLER,J.H.~ ~ Niagara Mohawk Power Corp.

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RECXP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to NRC ltr re violations noted in insp repts 50-220/98-04 & 50-410-98-04.Corrective actions: truck was decontaminated. by Chem-Nuclear personnel & followup surveys performed on other trailers & equipment.

DXSTRIBUTION CODE: IE01D COPIES RECEIVED:LTR 'NCL SIZE:

TXTLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD1-1 PD 1 1 HOOD,D 1 1 INTERNAL: ACRS 2 21 AEOD/SPD/RAB 1 1 TC 1 1 DEDRO 1 1 FILE CE 1 1 NRR/DRCH/HHFB 1 1 NR PM PECB 1 1 NRR/DRPM/PERB 1 1 NUDOCS-ABSTRACT 1 1 OE DXR 1 1 OGC/HDS3 1 1 RGN1 FILE 01 1 1 RNAL: LITCO BRYCE,J H 1 1 NOAC 1 1 NRC PDR 1 1 NUDOCS FULLTEXT 1 1 0

NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD) ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 19 ENCL 19

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'ViagaraMohawk John H. Mueller trice President and Vuctear Officer Omce: (315) 349?90?

Fax: (315) 349.1321 tHM9: mueltetlOntmo.con April 28, 1998 NMPlL 1308 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 RE: Nine Mile Point Unit 1 Docket No. 50-220

Subject:

Reply to Notice of Violation as Contained in NRC Tnspectipn Report

$ 0-220/9SM and $ 0-410/9S-04 Gentlemen:

Niagara Mohawk Power Corporation's reply to the subject Notice of Violation-is enclosed in the Attachment to this letter. We do not dispute this violation.

Very truly yours, John H. Mueller Chief Nuclear Officer JHM/GJG/kap Attachment xc: Mr. H. J. Miller, Regional Administrator, Region I Mr. S. S. Bajwa, Director, Project Directorate I-l, NRR Mr. B: S. Norris, Senior Resident Inspector Mr. D. S. Hood, Senior Project Manager, NRR Records Management 9805050389 980428 PDR ADQCK 05000220 6 PDR Nine Mile Point Nucfear Station, P.O. Box 63, Lycoming, New York 13093 www.nimo.corn

UNITED STATES NUCLEAR REGULATORY COMMISSION In the Matter of Niagara Mohawk Power Corporation Docket No. 50-220 Nine Mle Point Nuclear Station Unit No. 1 John H. Mueller, being duly sworn, states that he is Chief Nuclear Officer of Niagara Mohawk Power Corporation; that he is authorized on the part of said Corporation to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information, and belief.

NIAGARAMOHAWKPOKER CORPORATION By Jo n H. Mueller Chief Nuclear Officer Subscribed and sworn to before me this ~ day of April 1998.

OTARY PU LIC BEVERLY W. RIPKA rtotary public Stateot Hew York Qual. in Oswego Co. rro. 4644879 MP Commission Exp. radar~~~> 4S

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NIAGARAMOHAWK'VOWERCORPORATION NINE MILE POINT UNIT 1 DOCKET NO. 50-220 DPR "REPLY TO NOTICE OF VIOLATION,"AS CONTAINED IN INSPECTION REPORT 50-220/98-04 AND 50-410/98-04 A.

Title 10, Code of Federal Regulations (CFR), Part 71.5 requires that each licensee who delivers radioactive material for transport by a carrier comply with the applicable requirements of the Department of Transportation (DOT) regulations in 49CFR170

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through 189, as appropriate. 49CFR173.443 requires, in part, that a vehicle used to radioactive material as an exclusive use shipment may not be returned to 'ransport service until'he radiation dose rates at each accessible surface is 0,005 millisieverts per hour (0.5 millirem per hour) or less.

Contrary to the above, on February 6, 1998, the licensee returned to service a flatbed type trailer which had been used to transport radioactive materials as 'exclusive use, which upon receipt at another facility was found to have radiation levels on two accessible areas of the trailer of 0.300 millisieverts per hour (30 millirem per hour) and 0.014 millisieverts per hour (1.,4 millirem per hour), respectively.

Niagara Mohawk Power Corporation (NMPC) has determined that the violation of 49CFR173.443 was caused by an inadequate radiological survey performed prior to release of the subject vehicle from the Nine Mile Point site. The reason the survey was inadequate was because NMPC had not established proper expectations regarding the appropriate thoroughness of this type of radiological survey.

I A flatbed trailer was used to transport equipment to Nine Mile Point Unit 1 (NMP1) for use in processing material from the Spent Fuel Pool. Upon arrival at NMP1, the truck was placed in the Reactor Building truck bay where the boxed equipment was removed and transported to the refueling floor. The boxes were surveyed as they were removed from the truck. None of the equipment boxes had indication of contamination levels higher than 100 dpm/100 cm~.

After the equipment was removed, the flatbed trailer was surveyed for fixed and smearable contamination. The survey consisted of 15 smears and a frisk of 15 to 20 minutes duration.

The frisk survey covered approximately 15% of the top portion of the flatbed. This survey did

not reveal any radioactivity in excess of Department of Transportation (DOT) limits. This survey methodology was as prescribed in NMPC procedures. Following the survey, NMPC released the trailer. It was received in Post Township, Pennsylvania where the trailer was resurveyed. B & W Technicians, using a similar survey technique, but with a more sensitive instrument, identified two local fixed contaminated spots that exceeded DOT limits.

NMPC was immediately notified. A Radiation Protection Supervisor and the technician, who originally surveyed the trailer, were dispatched to Post Township, Pennsylvania. The technician resurveyed the trailer using NMPC equipment and was able to detect the contaminated spots.

A contributor to this event was a mindset on the part of the technician that the containers and surrounding work area were not contaminated. This influenced the technician who expected to be surveying an uncontaminated flatbed trailer.

The following actions have been taken:

1. The truck was decontaminated by Chem-Nuclear personnel on March 12, 1998.

2. Followup surveys were performed on other trailers and equipment associated with the Spent Fuel Pool Cleanup at NMP1. No additional contaminants were found.

3. The Radiation*Protection Managers developed and promulgated to the Radiation Protection staff specific expectations regarding surveys and free release. These expectations specified a large area survey methodology to assure the extent of survey is appropriate to detect contaminants, included the following considerations: (1) component history/prior location and use, (2) potential survey technique differences between prior and subsequent locations, and, (3) radiological/environmental factors which have the potential to impact survey results.

4. A telephone poll was conducted with other plants and the Institute of Nuclear Power Operations (INPO) to discuss vehicle releasing techniques. The results indicate that the survey methodology previously used at NMP1 is generally consistent with others in the industry, therefore NMPC has generically apprised the industry of this issue via the Nuclear Network.

5. Radiation Protection specialists from several plants with highly regarded radiological expertise conducted a thorough assessment of the NMPC shipping and free release program, including associated equipment, piocedures and practices. The recommendations developed from this assessment that are applicable to this violation are addressed in Section III of this response.

The following preventive actions have or will be taken:

Specific work order instructions which include steps to implement the considerations listed in corrective action 3 above are now used for the release of large items from the Radiologically Controlled Area. In addition, the work plans incorporate controls to escalate concerns to management for resolution when conservative threshold limits are approached. This will ensure a rigorous thought and survey process for the release surveys of large items on an individual basis. The experience gained through the use of these instructions will be incorporated into applicable Radiation Protection procedures by June 15, 1998.

2. Survey equipment with a larger probe surface area has been tested at Nine Mile Point.

As a result, equipment has been selected and procurement orders placed for meters, probes and calibration sources to facilitate future surveys. This instrumentation is expected to be in service at Nine Mile Point by June 30,1998.

Full compliance was achieved on March 12, 1998, when the flatbed truck was decontaminated,