ML20012B705

Responds to NRC 900131 Ltr Re Violations Noted in Insp Repts 50-334/90-05 & 50-412/90-04.Requests Withdrawal of Violation Re Stated Transport Problem & Reclassification as Noncompliance,Per 10CFR2,App C,Section G

ML20012B705
Person / Time
Site:	Beaver Valley
Issue date:	03/02/1990
From:	Sieber J DUQUESNE LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003160139
Download: ML20012B705 (4)

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) '/ Boawr Vilfry Pow:r Station ,

SNppingport, PA 16077-0004 i

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March 2, 1990. _[

h U.'S. Nuclear-Regulatory Commission  !

I Attn:

Document Control Desk 'i Washington, DC '20555

Reference:

Beaver Valley; Power Station,-Unit No.-1 andjNo. 2  ;

BV-1 Docket No. 50-334, License No. DPR-66 l BV-2 Docket No. 50-412, License No. NPF-73 '

Combined Inspection Report 50-334/90-05 and 50-412/90-04 Gentlemen:

In: response to NRC correspondence dated January 31, 1990_and in accordance with.10 CFR 2.201, the attached reply addresses tho. Notice-L of Violation included with:the referenced inspection report. -

! -Based upon our review of the circumstances surrounding this -

L event, we 'believe that this item meets the criteria of 10 CFR 2 Appendix C, Section- G.- Therefore, wes respectfully request that1the NRC- exercise- discretion as permitted by-this section, and withdraw this notice of: violation and- classify this event as a. licensee -

identified non-compliance. We have, -however, included ~ in our

. response: .the corrective actions- taken 'and -actions to prevent.

recurrence in the event that the NRC elects not to: withdraw this violation. ,

i If there are any questions concerning this response,-please

' contact my office.

Very truly yours, Ave

. D. Sieber

./;

UVice ~ President P

Nuclear Group w

Attachment

-cc:' Mr.1-J. Beall, Sr.-Resident Inspector Mr.JW. T. Russell, NRC Region I Administrator Mr. R.-R..'Bellamy,. Chief,' Facilities Radiological Safety and Safeguards Branch, Division of Radiation Safety, Region I.

Mr. P. Tam, Sr. Project Manager y Mr. R. Saunders (VEPCO)

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' 1 DUQUESNE LIGHT COMPANY  !

Nuclear Group Beaver Valley Power Station ,

Units 1 and 2 i Reolv to Notice of Violation Inspection Report 50-334/90-05; 50-412/90-04 Letter Dated January 31, 1990 y1QMTION (Severity Level IV, Supplement V)

Descrintion of Violation 10 CFR 71.5 states in part that "...each licensee who transports.

licensed- material outside 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 DOT in 49 CFR Parts 170 through' 189...". 49 CFR 173.425(b) states in part that "... packaged 6 shipments of LSA material consigned as exclusive use shall... comply with the following... materials must be packaged in strong, tight packages so that there will be no leakage of radioactive material

.under conditions normally incident to transportation..."

Contrary to the above, the licensee shipped a Seavan containing contaminated scaffolding as exclusive use, Radioactive Materials, Low Specific- Activity, to the Quadrex Recycle Center, Oak Ridge, Tennessee, on January 10, 1990, which upon receipt, was discovered to I have two holes in its sides. These holes were created during transit due to load shifting within the Seavan.

Discussion of Violation After reviewing the circumstances surrounding this event, we believe that this item meets the criteria for a licensee-identified violation-as described in 10 CFR 2, Appendix C, Section G. Because the NRC wants to encc .trage and support licensee initiatives- for y self-identification and correction of problems, 10 CFR Part 2 allows the NRC to exercise discretion and refrain from issuing a notice of L violation for a violation described in an inspection report that meets the following five criteria:

1) It was identified by the licensee.

Upon notification from the Quadrex Recycle Center, Duquesne Light Company immediately conducted an evaluation to determine the radiological consequence of this event. It was determined that the radiological consequences were insignificant as there was no contamination or radioactive material released due to the penetration of the container. The NRC Resident Inspector was notified of this event by Radiological Control supervision. This was a courtesy notification as no notification by Duquesne Light Company was required.

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ReDiv to Notice of Violation

, Inspection. Report 50-334/90-05; 50-412/90-04 Letter Dated January 31, 1990 Page'2 Discussion of Violation (continued)

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is normally classified at a Severity Level IV or V.

. This even was classified as a ~ Severity Level IV violation (Sdp%T6 ment (V) .

r L 3) It was reported, if*rqguired. 4

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• Tho NRC Resident Inspector was notified by hhdiological Control supervision.

• No reporting was required by 10 CFR 50.72, 10 CFR 50.73, 10 CFR 20.403, or 10 CFR 20.405. i

4) It =was or will be corrected, including measures to prevent recurrence, within a reasonable time.

• Immediate corrective actions were taken and long-term actions ara planned to reduce the potential for a recurrence of a similar. event.

5) It was not a willful violation or a violation that could l reasonably be expected to- have been prevented by the licensee's  !

corrective action for a' previous violation. 1 This. problem occurred during transit due to load shifting within the SeaVan. There have been no previous violations -

involving SeaVan shipments.

Since all-five criteria are met, we respectfully request that the NRC reclassify this event as a' licensee-identified non-compliance and withdraw. the violation as cited.- Notwithstanding this request, the following corrective actions and actions taken to pre' rent recurrence are submitted for your review.

Corrective Action Taken Upon notification from the Quadrex Recycle Center that two small holes were found in the side of SeaVan QD-49 during the initial receipt inspection, an evaluation was conducted to determine the radiological consequence of the event. The material packaged in QD-49 had been wiped down prior to loading at Beaver Valley Power Station and the remaining contamination levels were considered to be minimal. It. was determined that the radiological consequences were insignificant as the results of smear surveys of the two holes and the :I-beam support that caused the holes failed to detect any removable contamination.

Ren1v'to Notice of'Violat.ip.Il Inspection Report 50-334/90-05; 50-412/90-04 Letter Ohted January 31, 1990-Page'3 Our review of the event indicates that this shipment had been shored in accordance with our instructions. However, load shifting within the Seavan during transit still resulted in damage to the SeaVan.

A prev sly cheduled shipment of the same type was postponed and no further s pment of this type were made until additional shoring measures were esta 'ished. The Resident NRC Inspector was notified of the event and our ev uggion.

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Actions Taken to Prevent Recurrence

1. Per our request, a representative fror the Quadrex Recycle Center conducted a special training session at BVPS on January 24,.1990.

additional guidance The training was designed to provide the necessary for shoring a shipment of scaffolding components.

from Operations, Maintenance, Quality Control, Individuals Training, and Health Physics attended the session.

2. The Quadrex representative directly supervised the internal shoring of the Seavan for the postponed shipment.

3. Training on internal shoring of SeaVans that contain scaffolding be incorporated into the annual training course components will for individuals involved with radioactive material shipping.

4. We have been informed that a guidance document will be developed by Quadrex to provide the instructions for loading and shoring of scaffolding components in SeaVans.

has also informed us that the following SeaVan

5. Quadrex to provide additional modifications are being implemented assurance that there will not be a recurrence of this problem:

installing a 1/4" metal kick-plate on the inside a) Quadrex is used for transporting scaffolding walls of the SeaVans components. The plate will be installed at the elevation where the scaffolding carts could possibly come in contact'with the walls of the package, rounding the corners of the scaffolding carts to b) Quadrex is eliminate the sharp edges, c) Quadrex is installing wheel locks on the scaffolding carts.

Date of Full Comoliance Full compliance has been achieved at this time.

Using the guidance provided by Quadrex for internal shoring, three subsequent shipments of SeaVans containing scaffolding components have been accomplished The without incident, as had all shipments previous to the event.

guidance document will be developed and the SeaVan modifications completed prior to any future receipt of scaffolding components.

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-Reply to Notice of Violation-Inspection Report 50-334/90-05; 50-412/90-04 Letter Ohted January 31, 1990 Page*3 Our- review of the event indicates that this shipment had been shored in accordance with our instructions. However, load shifting within the SeaVan during transit still resulted in damage to the SeaVan.

usly cheduled shipment of the same type was postponed and no A prev s ipment of this type were made until additional shoring further measures were esta 'ished. The Resident NRC Inspector was notified of the event and our av ug(ion.

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Actions Taken to Prevent Redurrenco

1. Per our request, a representative from the Quadrex Recycle Center conducted a special-training session at BVPS on January 24, 1990.

additional guidance The training was designed to provide the '

necessary for shoring a shipment of scaffolding components.

from Operations, Maintenance, Quality Control, Individuals Training, and Health Physics attended the session.

l 2. The Quadrex representative directly supervised the internal shoring of the Seavan for the postponed shipment.

3. Training on internal shoring of SeaVans that contain scaffolding components will be incorporated into the annual training course ,~

l for individuals involved with radioactive material shipping.

l

4. We have been informed that a-guidance document will be developed by Quadrex to provide the instructions for loading and shoring of scaffolding components in SeaVans, i has informed us that the following SeaVan

5. Quadrex also to provide additional modifications are being implemented assurance that there will not be a recurrence of this problem:

installing a 1/4" metal kick-plate on the inside a) Quadrex is used for transporting scaffolding walls of the Seavans components. The plate will be installed at the elevation where i the scaffolding carts could possibly come in contact with the i walls of the package.

rounding the corners of the scaffolding carts to b) Quadrox is eliminate the sharp edges.

c) Quadrex is installing wheel locks on the scaffolding carts.  ;

Date of Full Compliance Full compliance has been achieved at this time.

Using the guidance provided by Quadrex for internal shoring, three subsequent shipments of SeaVans containing scaffolding components have been accomplished The without incident, as had all shipments previous to the event.

guidance document will be developed and the SeaVan modifications completed prior to any future receipt of scaffolding components.

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