ML18150A056
| ML18150A056 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 04/23/1987 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 87-189, NUDOCS 8704290111 | |
| Download: ML18150A056 (8) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261.
10 CFR 2.201 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS April 23, 1987 U. S. Nuclear Regulatory Commission, Attn:
Document Control Desk Washington, D. C.
20555 Gentlemen:
VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNITS 1 AND 2 NRC INSPECTION REPORT NOS. 50-280/87-03 AND 50-281/87-03 Serial No.
NO/WDC:pms Docket Nos.
License Nos.87-189 50-280 50-281 DPR-32 DPR-37 We have reviewed your letter of March 24, 1987, in reference to the inspection conducted at Surry Power Station on February 9-13, 1987 and reported in Inspection Report* Nos.
50-280/87-03 and 50-281/87-03.
Our response to the Notice of Violation is addressed in the attachment
- We have no objection to this inspection report being_made a matter of public disclosure.
If you have any further questions, please contact us.
Very truly yours, fJL~-
- w. L. Stewart Attachment cc:
U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N. W.
Suite 2900 Atlanta, GA 30323 Mr. W. E. Holland NRC Senior Resident Inspector Surry Power Station Mr. Chandu P. Patel NRC Surry Project Manager PWR Project Directorate No. 2 Division of PWR Licensing-A 8704290111 870423
~DR ADOC~ 05000280 PDR
NRC COMMENT:
RESPONSE TO NOTICE OF VIOLATION ITEMS REPORTED DURING NRC INSPECTION CONDUCTED ON FEBRUARY 9-13, 1987 INSPECTION REPORT NO. 50-280/87-03 AND 50-281/87-03 "During the Nuclear Regulatory Commission (NRC) inspection conducted on February 9-13, 1987, violations of NRC requirements were identified.
The violations involved failure to comply with Department of Transportation and State of South Carolina requirements regarding the transportation of licensed
- material, and failure to adhere to radiation controls procedures.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1986), the violations are listed below:
A.
10 CFR 30.41c requires that before transferring byproduct material to a specific licensee of an Agreement State, the licensee transferring the material shall verify that the transferee's license authorizes the receipt of the type, form, and quantity of byproduct material to be transferred.
License Condition 26 of State of South Carolina Radioactive Material License 097, Amendment 41 requires that notwithstanding other conditions of the license, the licensee shall not accept radioactive waste for storage or disposal unless he has received advance written notification of any waste containing unusual hazards or potential hazards including but not limited to excessive removable contamination on disposal containers spipped inside casks or excessive internally contaminated casks.
License Condition 60 of State of South Carolina Radioactive Material License 097, Amendment 41 requires that unless otherwise authorized, all radioactive waste shall be received and buried in closed containers.
Loose radioactive waste and solidification residuals within shipping casks are prohibited.
Contrary to the above, the licensee failed to verify an Agreement State licensee was authorized to receive the type,
- form, and quantity of byproduct material transferred in that Radioactive Waste Shipment Number 1086-198-A, transferred to the low level radioactive waste disposal.site near Barnwell, SC, was found upon its arrival on October 24,
- 1986, to contain unpackaged radioactive resin and soil in the void space between the disposal liner and shipping cask.
The licensee had not given the disposal site advance notification of this unusual or potential hazard.
This is a Severity Level IV violation (Supplement V)."
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
(2) REASONS FOR VIOLATION:
The violation was a result of a design deficiency in our resin processing shield.
The shield design permitted resin spillage to come into direct contact with the bottom of the waste liner.
The waste liner design allowed loose resin to be entrapped and concealed in the liner base.
We believe that entrapped resin in the liner base worked loose during transport and consequently contaminated the cask interior.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
The design deficiency in our resin processing shield has been corrected.
This was accomplished by installing a drain in the base of the shield to allow cleaning and prevent accumulation of liquids.
Also, a liner support stand was fabricated to avoid liner contact with the shield bottom.
- Finally, we have procured and will use waste resin liners with improved design features which are not as susceptible to entrapment of loose. resin or moisture.
(4) CORRECTIVE* STEPS WHICH WILL BE TAKEN TO AVOID ~URTHER VIOLATIONS:
No further steps are considered necessary.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on January 20, 1987.
]I
.'... ~.
NRC COMMENT:
"B. 10 CFR 71.5a requires that each licensee who transports licensed material outside of the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation in 49 CFR Parts 170 through 189.
49 CFR 172.40l(a)(2) requiFeS that no person may offer for transportation any package bearing a label specified in this subpart unless the label represents the hazardous material in the package.
49 CFR 172.403(g)(2) requires tha:t the activity of the package, expressed in appropriate curie units must be entered in the blank space on the Radioactive label.
49 CFR 172.310(a)(l) requires that each package of radioactive materials in excess of 110 pounds must have its gross weight plainly and durably marked on the outside of the package.
49 CFR 173.475(i) requires that before each shipment of* any radioactive materials package, the shipper shall ensure by examination or appropriate tests, that external radiation levels are within allowable limits.
49 CFR 173.44l(b)(2) requires that radiation levels at any point on the outer surt:ace of exclusive use vehicles_, including the top and underside of the vehicle, must not exceed 200 millirem per hour during transporta-tion.
Contrary to the above, the licensee failed to comply with the requirements of the Department of Transportation in that:
- 1.
Radioactive Waste Shipment Number 1186-295-A, trans*ferred to the low level radioactive waste disposal site near Barnwell, SC was found upon its arrival on November-21, 1986, to have:
(a)
Displayed an "empty" label which did not represent an actual condition of the package.
(b)
No units of activity recorded on the Yellow II Radioactive
. label.
(c)
No marking of the gross weight on the outside of the package.
- 2.
No surveys of the top outer surfaces of the transport vehicles were performed for radioactive material shipments SEG-3 on December 17, 1986, _and SH-1987-003 on February 8, 1987.
This is a Severity Level IV violation.(Supplement V)."
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation described in Paragraph B.l. is correct as stated.
The violation described in Paragraph B.2.
is incorrect as stated.
We believe the requirements of 49 CFR 173.475(i) and 49 CFR 173.44l(b)(2) were met.
The "examination or appropriate tests" required by 49 CFR 173.475(i) do not imply that direct radiation surveys of all vehicle external surfaces are the only means to ensure that radiation levels are within allowable limits. Direct surveys of the sides and bottom of closed
- transport vehicles are performed as required by procedure.
Direct surveys of the tops of closed transport vehicles are not required by procedure due to personnel safety concerns.
Rather, indirect surveys (package surveys, vehicle interior surveys, etc.) are performed and evaluated to ensure that the top outer surface of the vehicle could not exceed 200 millirem per hour.
Regarding the two shipments cited by the violation, the following information is documented in the shipping packages:
- 1.
Shipment No. SEG-3 contained ten boxes of dry active waste.
Each box was surveyed prior to loading on the transport vehicle for its highest contact and one meter radiation level.
The highest level measured at one meter from any box was 15 millirem per hour.
A minimum distance of 4 feet exists from the top of any box to the top of the transport vehicle.
After loading the transport vehicle, surveys of the sides and bottom of* the vehicle showed maximum levels of 30 millirem per hour on contact.
Based on these two surveys, and the configuration of the packages in the vehicle, we feel that "appropriate tests" were performed to ensure allowable limits were met.
- 2.
Shipment No.
SH-1987-003 consis,ted of a
box containing a
radioactively contaminated pump motor.
The package survey showed maximum contact radiation level of 5 millirem per hour.
Therefore, no level exceeding 200 millirem per hpur could have existed on the vehicle.
Surveys of the sides and botoom of the vehicle showed a
maximum level of 2.5 millirem per hour.
- Again, we believe "appropriate tests" were performed to ensure compliance with 49 CFR 173.441(b) (2).
In both shipments described above, the container and vehicle survey data was evaluated by knowledgeable radwaste personnel to assure that vehicle radiation levels, including the top outer surface, were well below allowable limits.
This evaluation is performed prior to shipment certification and vehicle departure.
(2) REASONS FOR THE VIOLATION:
The violation described in Paragraph B.l. resulted from an oversight on the part of individuals responsible for radioactive waste shipments.
The labeling and marking discrepancies identified with Radioactive Waste Shipment No. 1186-295-A represent a lack of attention to detail by these individuals.
Additionally, insufficient procedural detail existed to ensure comprehensive preshipment checks were performed.
(3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Improved and expanded checklists were developed by the station group responsible for radioactive waste shipments.
To determine those items appropriate for inclusion in the new checklists, this group performed a complete review of pertinent packaging,
- shipping, and disposal regulations.
This review served not only to produce more comprehensive checklists, but also reinforced the group's awareness of regulatory details.
The new checklists have been incorporated into station procedures.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further corrective actions are considered necessary.
- However, as a
procedural enhancement, we plan to further describe the tests/surveys performed which are used to ensure acceptable radiation levels on the upper surfaces of transport vehicles.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on January 22, 1987.
NRC COMMENT:
"C. Technical Specification 6.4.D requires that radiation control procedures be followed.
Radiation Control Procedure HP 3.2.18, Temporary Low Level Waste Storage Facility, dated April 29, 1986, requires in Step 4.9 that an inventory of the building be conducted at least once a quarter, that the inventory consist of counting each LSA box and 55-gallon drum, that this inventory confirm the total number of containers listed in the building curie content log, and that a notation documenting the quarterly inventory be made in the log.
Step 4.10 of the procedure requires that routine surveys of the building and perimeter be performed daily when material is being moved in or out of the building and weekly if no material is moved in or out of the building.
Radiation Control Procedure HP 3.3.3.29, Calibration and Operation of Eberline PCM-IA, dated October 9, 1986, requires in Step 2.1 of Attachment 1 that a minimum of five performance checks be made within a seven day period.
Contrary to the above, the licensee failed to adhere to radiation control procedures in that:
- 1.
- 2.
There was no documentation in the building curie content log of the four 1986 quarterly Low Level Waste Storage inventories.
of two Facility Only radiation ieasurements on Storage Facility were made January to February 11, 1987.
the exterior of the Low* Level Waste for the daily surveys performed during
- 3.
No performance checks were performed on the PCM-IA personnel contamination monitors between the dates of December 22 and 29, 1986.
This is a Severity Level V violation (Supplement IV)."
~ --
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The violation is correct as stated.
(2) REASONS FOR VIOLATION:
The violation resulted from failure on the part technicians to ensure strict compliance with procedural documentation requirements.
of supervisors and surveillance and (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Supervisors and technicians involved in the procedural noncompliances have been interviewed.
They have been instructed that further oversights of this nature could result' in disciplinary action.
(4) CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
No further actions are considered necessary.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
Full compliance was achieved on March 1, 1987.