ML20070G348
| ML20070G348 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/14/1994 |
| From: | Denton R BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9407200080 | |
| Download: ML20070G348 (4) | |
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Ronn:n r E. UtxtON Baltimore Gas and Electric Company Calvert C@ Nuclear Power Plant Vice President 1650 Calvert Cliffs Parkway Nucin r Energ~y Lusby, Afaryland 2cf>57 110 5 6-22cx) Ext. 4455 local 8
410 260-4455 Baltimore l
l July 14,1994 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Document Control Desk SUHJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos 50-317 & 50-318 Reply to Notice of Violation - NRC Inspection Report Nos. 50-317(318)/94-21 Shipment _of Radioactive Material on May 17.1994
REFERENCE:
(a)
Letter from Mr. J. H. Joyner (NRC) to Mr. R. E. Denton (BGE), dated June 15, 1994, Notice of Violation, NRC Combined Inspection Nos. 50-317/94-21; 50-318/94-21 In response to Reference (a), Attachment (1) details our response to the cited violation concerning our May 17,1994 shipment of radioactive material.
Should you have any questions regarding this matter, we will be pleased to discuss them with you.
Venj truly yours, P
. &,.rto sf for Ik E. Denton Vice President-Nuclear Energy RED /MDM/dlm
Attachment:
(1)
Reply to Notice of Violation; Inspection Report Nos. 50-317(318)/94-21 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire M. K. Boyle, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R.1. McLean, DNR
, J.11. Walter, PSC
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ATTACIIMENT m REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318)/94-21 L
DESCRIPTION AND CAUSE OF VIOLATION Title 10 Code of Federal Regulations (CFR) 71.5 requires, in part, that NRC licensees comply with all applicable provisions of Title 49 CFR when transporting radioactive material. Title 49 CFR 173.441(b)(1) requires, in part, that the radiation levels on the exterior of a vehicle used for an exclusive use shipment of radioactive material, including the underside of the vehicle, have radiation levels not exceeding 200 millirem per hour (mr/hr). Reference (a) states that contrary to the above, on May 17, 1994, Baltimore Gas and Electric Company (BGE) shipped radioactive material from the Calvert Cliffs Nuclear Power Plant (CCNPP) to Scientific Ecology Group, Inc. (SEG) in Oak Ridge, Tennessee, that upon receipt was found to have radiation levels exceeding 200 mr/hr on the underside of the transport truck.
The radioactive material consisted of miscellaneous outage-related low level radioactive waste and was shipped in a 48-foot shielded van loaded on a transport vehicle. Upon receipt of the van, SEG performed a receipt survey using a Geiger Muller (GM) detector and measured 300 mr/hr on contact on the underside of the van. Scientific Ecology Group then notified us of the results and we requested they re-survey the van using the same ion chamber used to survey the van at CCNPP prior to shipment. The second survey, using the CCNPP ion chamber measured two contact readings of 380 mr/hr and 240 mr/hr. Surveys performed at CCNPP during loading and prior to shipment showed no dose rates exceeding 140 mr/hr on contact.
After performing the second survey we requested SEG inspect the van to see if any of the containers with radioactive packages had shifted, and to survey the packages in each container to see if they had shifted within the container. Scientific Ecology Group's survey of the packages revealed dose rates that were higher than the pre-shipment rates on two 55 gallon drums. One drum contained a nuclear excore detector and the other drum contained a Reactor Vessel Level Monitoring Sys:cm (RVLMS) probe. The excore detector drum measured 1100 mr/hr on contact at SEG versus a pre-shipment survey of 200 mr/hr. The RVLMS drum measured 600 mr/hr versus a pre-shipment survey of 180 mr/hr. The increase in dose rates indicates the contents of the drums shifted during transport. The locations of these two drums ih the transport van corresponded to the location of the contact spots on the transport vehicle that exceeded the 49 CFR limits.
A root cause investigation was performed at CCNPP to determine why the contents of the two drums had shifted during transport. The radioactive material was originally placed in the drums inside the plant in 1993, and then moved to the Materials Processing Facility (MPF) for storage and eventual shipment. The investigation determined the process for ensuring radioactive material packages are properly packaged and internally braced prior to shipment was inadequate. Several contributing factors were identified including:
A.
Failure of CCNPP Radiation Safety Technicians in the MPF to inspect the material in the drums for proper intemal bracing prior to shipment. Attachment (1), Section 1, of Radiation Safety Procedure (RSP) 2-204 provides guidance on packaging and bracing material, but was not closely followed by the technicians. Additionally, the technicians assumed the dmms had been properly packaged in the plant where the radioactive material originated, based on the absence of any noise indicating a loose component when the drums were moved out of storage prior to shipment. Thus, they did not open the drums. The technicians also failed to question the survey results of the drums when the material was initially stored in the MPF with the pre-shipment survey results.. If they had compared the two surveys, they should have questioned why the pre-shipment rates (200 mr/hr) were 1
ATTACIIMENT m REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-317(318)/94-21 twice as high as the MPF storage survey rates (100 mr/hr), indicating the contents had shined when the drums were moved from storage in the MPF prior to shipping; B.
The guidance for packaging material contained in RSP-2-204 was specific with respect to bracing containers, but was less clear with respect to packing material within the containers. Thus the technicians ensured the drums were properly braced, but did not secure the drum contents. Additionally, the procedure did not contain any special precautions or steps that would have required the technicians to perform additional checks for infrequently performed evolutions; and, C.
Due to the nature of the material being shipped and infrequency of the task, additional preparation and supervisory oversight should have been applied to the process. Although the MPF supenisor was aware of the material being shipped, he did not personally direct or supenise the technicians efforts involving the two drums.
II, CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED in response to this event, the General Supervisor - Radiation Safety issued a memorandum to the MPF supenisor on May 20,1994, directing the immediate actions to be taken to prevent further occurrences.
These immediate actions included inspecting all waste containers to ensure internal bracing or cushioning is adequate to assure that vehicle dose rates on contact do not exceed Department of Transportation (DOT) regulations. There have been no shipments of radioactive material from CCNPP since the event on May 17,1994, that have exceeded DOT limits Additionally, appropsiate actions were taken to address the personnel errors.
III.
CORRECTIVE ACTIONS TAKEN TO AVOID FURTIIER VIOLATIONS To improve the packaging process, the following changes have been made to RSP-2-204:
A.
All packages and containers will be inspected prior to snipment to ensure the material i
inside is properly stabilized to prevent shining during transpon. This inspection will either be performed in the MPF prior to shipment or when the material is originally packed.
B.
For shipments requiring a shielded van containing package (s) exceeding contact measurements of 200 mr/hr, a Principal Radiation Safety Technician will perform a 1
follow-up package inspection / survey and truck survey prior to nelease from CCNPP.
C.
For packages containing radioactive material which have the potential to be greater than or equal to 1000 mr/hr on contact, the additional use of overpacks, pallets, etc. wiP be verified by MPF supenision. These additional measures will ensure the contact readings on the transport vehicle remain below DOT limits, even if the packaged material shins i
during transport.
2 t
t ATTACIIMENT (1)
REPLY TO NOTICE OF VIOLATION INSPECTION ~ REPORT NOS. 50-317(318)/94-21 To ensure adequate preparation and oversight are provided for special shipments, written guidance is being developed to describe the responsibilities, direction, and control that should be determined prior to performing these special evolutions.
Radiation Safety personnel have been briefed on the cause and corrective actions associated with this event and lessons learned will be incorporated into the Radiation Safety Technician Continuing Training Program.
IV.
DATE WilEN FULL COMPLIANCE WILL BE ACIIIEVED Full compliance was achieved on May 20,1994, when interim inspection criteria were implemented via the General Supervisor-Radiation Safety memorandum.
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