ML20083E687
| ML20083E687 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 12/16/1983 |
| From: | Larson C NORTHERN STATES POWER CO. |
| To: | Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8312290348 | |
| Download: ML20083E687 (5) | |
Text
DCJ s
Northem States Power Company 414 Nicollet Mall Minneapohs. Minnesota 554V1 Telephone (612) 330-5500 -
December 16, 1983 Mr Richard C DeYoung, Director Office of Inspection and Enforcement U S Nuclear Regulatory Commission Washington, D C 20555 MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 Response to NRC Enforcement Letter Dated November 22, 1983 This refers to the notice of violation and proposed imposition of civil penal-ties issued by the Director of Office of Inspection and Enforcement, NRC, to Mr C E Larson, NSP, dated November 22, 1983.
Two alleged violations were referenced in this report.
Pursuant to 10CFR2.201 and 10CFR2.205, the follow-ing report is herewith submitted.
In response to the violation desi NSP agrees that 49CFR 173.245(b)(gnated as A in the notice of violation report:
- 1) was violated.
Description of the Event In May of 1983, the fill-head for the Chem-Nuclear mobile solidification unit had become contaminated to the extent that it was an external exposure hazard to personnel ' in the area.
Decontamination failed and a new fill-head was obtained ta replace the contaninated equipment.
Because of the exposure rates on the contaminated fill-head, it had to be made inaccessible to personnel.
By placing it into a steel LSA box and pos1:ioning the box yithin a high radiation area, accessible whole body dose rates greater than 1000 mr/hr were prevented and the requirement to lock the area was nega-ted.
The fill-head remained as described for several months, for it was Chen-Nuclear's intention to have the equipment returned to Barnwell for refur-bishing.
On September 15th, the Chem-Nuclear opef ator' stationed at Ncnticello notified the radioactive material shipping coordinator that a shielded an was enroute to Monticello to retrieve the contaminated fill-head.
The truck arrived on the following morning.
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NORTHERN CTATE'3 POWER COMPANY Director, I&E December 16, 1983 Page 2^
The r.ormal shipping process was initiated to handle the shipment.
Two proce-dures' were identified to provide instructions: #8110, MASTER RADI0 ACTIVE MATERIAL SHIPPING PROCEDURE, and #8077, RADI0 ACTIVE MATERIALS SHIPMENT-LSA-NOT EXCEEDING A TYPE "A" QUANTITY IN EXCLUSIVE USE VEHICLE.
Upon arrival of the shipment at Barnwell Waste Management Facility, a routine t
receipt inspection revealed a hole in the bottom of the box.
Compliance personnel of the Chem-Nuclear organization at Barnwell subsequently notified the Monticello shipping coordinator by telephone.
Even though NSP was not I
required to report this event, the U.S. Nuclear Regulatory Commission, Region III,c was notified by NSP in accordance with the policy setforth in Section IV. A, - pa ragraph (3), of 10CTR Part 2, Appendix C.
Northern States Power offered to immediately send a representative to Barnwell to assist the site personnel with assessment or any cleanup that might be required.
Because of the inconsequential nature and insignificance of the event, Chem-Nuclear stated that' NSP presence was not necessary.
Even so, Northern States Power did elect to send the. Supervisor of Radiation Services at Chem-Nuclear's earliest conven-ience to inspect the LSA box, its contents and discuss the matter with site personnel..
Cause of Violation The box was punctured dufing transportation by a tie-down tab on the fill-head.
There are four welded tie-down appendages extending radially from the upper part of the fill-head.
When the fill-head was placed on its side in the box, two of the protruding tie-down tabs were supporting one end of the head.
It is believed that the concentrated weight, combined with the vibrations associated J
with truck transportation, produced a puncture between the supporting skids on the bottom of the box.
In accordance with 49CFR 173.425(b)(1) which requires that shipments of low spccific activity (LSA) materials transported in exclusive use vehicles must be packaged in strorg, tight packages so that there will be no leakage of radio-active material under condittoas normally incident to transportation, the fill-head was in a strong tight container when it left the Monticello Nuclear Plant.
l It 'was believed at that time by radwaste shipping personnel that there would be no breach of package integrity under conditions normally incident to transpor-tation.
It should also be noted that the fill-head was not removed fran the A LSA box for obvious ALARA concerns in regard to exposure but was braced to 4 provent any lateral movement.
Immediate Corrective Steps Taken Because of the. nature of this event, there was no inmediate corrective action ava ilable.
The radioactive material was safely in the hands of another licen-
'seeiand there was nothing that could undo or ameliorate the situation.
g*
Corrective Steps Taken To Avoid Further Violations A To prevent repetition of this event, several actions were taken.
First, the problem was discussed with the personnel involved in the specific shipment,
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plus those who may he involved in future shipments, to ensure that the cause and possible preventive measures for this event are understcod.
NORTHERN CTATED POWER COMPANY l
Director, I&E December 16, 1983 Page 3 Secondly, a representative traveled to Barnwell to take advantage of anything which could be learned from inspecting the box and contents or from talking to site personnel.
Finally, procedures #8077 (previously referenced) and #8089 (Radioactive Material Shipment - Type A Quantity, Fissile Exempt) were revised to include a step for the radioactive material shipping coordinator to inspect all packages, except compacted waste which is inspected prior to compaction, specifically to identify problems which could develop enroute.
Date When Full Compliance Will Be Achieved The procedures referenced, #8089 and #8077,' were revised and approved October 6,1983, only 20 days after the event was identified in accordance with the policy setforth in Section IV.A of 10CFR Part 2, Appendix C.
In response to the Violation designated as B in the flotice of Violation Report:
flSP agrees that 49CFR173.441(b)(a) was violated.
Description of the Event Upon arrival of the LSA shipment containing the contaminated fill-head, previously discussed, at the Barnwell Waste Management Facility a routine receipt inspection revcaled dose rates on contact with the bottom of the pack-age in excess of 1000 mr/hr.
Compliance personnel of the Chem-fluclear organization at Barnwell subsequently notified the Monticello shipping coordinator by telephone.
In turn, the U.S.
fluclear Regulatory Commission, Region III was notified by flSP in accordance with the policy setforth in Section IV.A. paragraph 3, of 10CFR Part 2, Appen-dix C.
Cause of Violation Procedure #8077 used in conjunction with shipping operations at Monticello did not reflect the recent change, as of July 1,1983, to the shipping regulations.
This was an over-sight on the part of the Radiation Protection personnel who reviewed the rules revisions.
It should be noted that as of July 1,1983,.
there were substantial changes to the shipping regulations made by D.O.T. and if the shipment was made prior to that date there would not have been a viola-tion.
Immediate Corrective Steps Taken Because of the nature of this event, there was no immediate corrective action available.
The radioactive material was safely in the hands of another licen-see and there was nothing that could undo or ameliorate the situation.
Corrective Steps Taken To Avoid Further Violations To prevent repetition of this event, shipping procedures #8077 and #8089 were revised to include the new exposure dose rate limit.
Also, the problem was
NORTHERN CTATE"') POWER COMPANY Director, I&E December 16, 1983 Page 4 discussed with the personnel involved in the specific shipment, plus those who may be involved in future shipments to ensure that the cause and possible preventive measures for this event are understood.
Date When Full Compliance Will Be Achieved The shipping procedures #8089 and #8077 were revised and approved October 6, 1983, only 20 days after the event was identified in accordance with the policy setforth in Section IV.A of 10CFR Part 2, Appendix C.
With respect to the analysis of the event, the following is offered:
This event did not msult in a release of radioactive material to the environ-ment and did not present radiation exposure hazards for the general public in excess of allowable limits.
The hole did pennit a small amount of radioactive material to escape the ship-ping package even though the majority of the contanination was fixed; however, the contamination was confined to a small area directly below the box on the hef of the enclosed trailer.
(Chem-Nuclear surveys indicated
< 4000 dpm/100 cm, within applicable limits.) Chem-Nuclear personnel attended to this matter and safely disposed of the material.
The exposure rates on the box did exceed the limits for the node of transport, but the exposure rates measured on the accessible surfaces of the vehicle were within the limits established for all radioactive shipments. Since this was an exclusive use shipment, there was no occasion for the driver or other member of the general public to enter the trailer and be exposed to the excessive dose
- rates, i
Ssetion I of 10CFR Part 2 states "the purpose of the NRC enforcement program is to promote and protect the radiological health and safety of the public, including employees' health and safety, the common defense and security, and the environment and "each enforcement action is dependent on the circumstances of the case and requires the exercise of the discretion after consideration of these policies and procedures."
It should be noted as addressed in Section III of 10CFR Part 2, Appendix C that the examples given in Supplement V (Transportation) of 10CFR Part 2, Appendix C do not create new requirements.
They are neither exhaustive nor controlling.
It states that, "in each case, the severity of a violation will be character-ized at the level best suited to the significance of the particular violation",
therefore to assess the violation as a Severity Level III merely because it appears as an example implies a mechanistic approach to the detennination of severity levels, which is contradictory to Section VI of 10CFR Part 2, Appendix C.
Based on the extenuating circumstances addressed above, Northern States Power i
respectfully requests that the violation be reconsidered as a Severity Level V and the enclosed $2500 be remitted. We would also like to state, that Northern States Power is fully aware of its responsibilities to the health and safety of the public and recognizes the importance of properly packaging materials for shipment.
This was demonstrated by NSP's prompt attention to the
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NORTHERN CTATED POWER COMPANY Director, I&E December 16, 1983 Page 5 aforementioned event.
Therefore, to emphasize importance through an elevated enforcement action is unnecessary and contradictory to the policies and philo-sophies delineated in 10CFR Part 2.
Enclosed is a check for $2,500, pending your disposition of the protested civil penalties, kch is the amount specified in the NRC E OF; C E Ldrsory s
s Director of Nuclear Generation cc: J G Keppler NRC Resident Inspector NRC NRR Project fianager Enclosure
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