ML20046A004
| ML20046A004 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 07/15/1993 |
| From: | Mcmeekin T DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307230319 | |
| Download: ML20046A004 (5) | |
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Duke Ibutt Company T C Afwunn AlcCuire Nuclear Generation Departinent Vice hnident 12700 Hagers Ferry Road (AfG01A)
(704)875-4800 Hunterstille, NC28078-8985 (704)8TS-4809 iLt.
i DUKEPOWER July 15,1993 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
Subject:
McGuire Nuclear Station, Units 1 and 2 Docket Nos,50-369 and 50-370 NRC Inspection Report No. 50-.369,370/93-08 Violations 50-369/93-08-01 and 50-369,370/93-08-02 Reply to a Notice of Violation Gentlemen:
I Enclosed is the response to the Notice of Violation issued June 17,1993 concerning failure to label three vscuum cleaners in Unit 1 containment and failure to review and approve the procedure fcr controlling
.acuum cleaners containing radioactive matorial.
Should there be any questions concerning th!s response, contact Randy Cross at (704) 875-4179.
Very Truly Youis,
)tM i T. C, McMeekin Attachment xc:
(w/ attachment)
Mr. P. K. VanDoorn Mr. S. D. Ebneter NRC Senior Resident inspector Regional Administrator, Region il McGuire Nuclear Station U. S. Nuclear Regulatory Commission i
101 Marietta St., NW, Suite 2900 Atlanta, Georgia 30323 Mr. Victor Nerses U. S. Nuclear. Regulatory Commission Office of Nuclear Reactor Regulation One White Flint North, Mail Stop 9H3 Washington, D. C. 20555 930723631@ WO715
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P McGuire Nuclear Station Reply to a Notice of Violation
.t Violation 369/93-08-01 10 CFR 20.1904(a) requires the licensee to ensure that each container of licensed material bears a' durable, clearly visible label bearing the radiation symbol and the words " Caution, Radioactive Material,"
or " Danger, Radioactive Material." The label must also provide sufficient information (such as radionuclides present, an estimate of the quantity of radioactivity, the date for which the activity is estimated, radiation levels, the kinds of materials, and mass enrichment) to permit individuals handling or using the containers, or working in the vicinity of the cc.atainers, to take precautions to avoid or. minimize exposures.
Technical Specification (TS) 6.11 requires that procedures for radiation protection'sha!! be prepared.
consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.
I Radiation Protection Directive IV-2, Labeling and Marking of Containers, F3evision 0, dated January 1,;
1993, step 5.6, stated to label drums or containers used inside the radiologically controlled area (RCA).
for collecting contaminated items as follows:
5.6.1 At a minimum,- place labe;s on the center section of the drums or containers at two
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locations 180 degrees apart.
5.6.2 Use standard 2" wide yellow and magenta " Caution Radioactive Material" tape to encircle j
the top third of the drum for radioactive containers.
Contrary to the above requirements, on May 18,1993, the licensee failed to label as required by the above listed requirements, three vacuum cleaners in Unit 1 containment that contained radioactive material.
This is a Severity Level IV violation (Supplement IV).
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. Reply to Violation 369/93-08-01 J
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Reason for the violation:
l The reason for the violation is inappropriate Action. Station personnel failed to follow Radiation Protection Directive IV-2 Labeling and Marking Containers, Revision 0 dated January 1,1993, step 5.6 which requires labeling of all containers used inside the radiologically controlled area l
(RCA) for collecting contaminated items, b
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Corrective steos that have been taken and the results acNev'ed:
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All vacuum cleaners used to collect radioactive material have been surveyed and labeled
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as required.
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McGuire Nuclear Station Reply to a Notice of Violation Violation 369/93-08-01 B.
A Duke Power Company, System Radiation Protection Manual Directive 111-18, *Use of Vacuum Cleaners in Radiologically Controlled Areas" was developed to establish a program for the control of vacuum cleaners which includes details on labeling requirements for vacuum cleaners containing radioactive materials (section 5.3). Specific labeling requirements outlined in section 5.3 were implemented on July 12,1993.
No similar events have occurred since implementation of Directive 111-18, section 5.3.
3.
Corrective steps that will be taken to avoid further violations:
No further corrective actions are planned. Implernentation of the specific labeling requirements for vacuum cleaners in Directive 111-18, section 5.3 should prevent recurrence.
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Date when full compliance will be achieved:
McGuire Nuclear Station is now in full compliance.
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W McGuire Nuclear Station
- l Reply to a Notice of Violation J
1 Violation 369. 370/93-08-02
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TS 6.8.1' states that written procedures shall be established, implemented, and maintained covering the activities referenced in, among others, Appendix A of. Regulatory Guide 1.33, Revision 2, February 1978.
Section 7.e.(4) of Appendix A requires radiation protection prxxiures for contamination control.
TS 6.8.2 requires that each procedure developed pursuant to TS 6.8.1 above, and changes thereto, shall be reviewed and approved by a group manager, superintendent / manager, or one of their designated direct reports prior to implementation and shall be reviewed periodically as set forth in administrative procedures.
For procedures which implement offsite environmental, technical and laboratory activities, the above review and approval may be performed by the General Manager, Environmental Services or designee.
K-Mac Services Procedure KM/D/0015/01, Control and Use of Vacuum Cleaners in the RCA, dated March 25,1991, provided requirements for controlling vacuum cleaners containing radioactive materials and was available for use by licensee and licensee contractor personne!.
Contrary to the above, on May 18,1993, the licensee had failed to review and approve the procedure for.
controlling vacuum cleaners containing radioactive material.
Ej Rgply to Violation 369. 370/93-08 I 1.
Reason for the Violation:
1 Since no performance based problems had been experienced with vacuum cleaner use, Radiation Protection management had determined that a McGuire Nuclear Station Radiation Protection procedure to control vacuum cleaners was not necessary.
2.
Corrective steps that have been taken and the results achieved:
A Duke Power Company, System Radiation Protection Manual Directive 111-18,"Use of Vacuum
. Cleaners in Radiologically Controlled Areas" was developed, reviewed and approved in accordance with TS 6.8.2 to establish a program for the control of vacuum cleaners. Directive ill-18, section 5.3 (Labeling Requirements) was implemented on July 12, 1993 with. full implementation of Directive 111-18 scheduled no later than September 1,1993.
No similar events have occurred since the review, approval and partialimplementation of Directive
!!1-18.
3.
Corrective steps that will be taken to avoid further violations:
No further corrective actions are planned.
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McGuire Nuclear Station Reply to a Notice of Violation Violation 369. 370/93-08-02 4.
Date when full compliance will be achieved:
McGuire Nuclear Station will be in full compliance by September 1,1993.
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