ML20115G934
| ML20115G934 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 10/21/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9210260383 | |
| Download: ML20115G934 (3) | |
Text
_--
E Ccr.wcnw:alth Edison 1.-
1400 opus Place
_ Downers Grove,11 'ois 60515.
October 21,1992; U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention:
Document Centrol Desk
Subject:
Quad Cities Nuclear Pos.er Station Units 1'and 2 Response to Notice of Violation Inspection Report Nos. 50 254/92020; 50-265/92020 NBRDochemot.5D-25 Land 10 2fi5
Reference:
A.B. Davis letter to Cordell Reed dated September 14,1992 -
transmitting the Notice of Violation-
- Enclosed is the Commonwealth Edison Company (CECO) response to the -
Notice of Violation (NOV) which was transmitted with the reference letter. The violation concerned a failure to conduct appropriate surveys to_ ensure that the external radiation ~
J levels of a package containing radioactive mater!als were within the De 3artment of' Transportation's allowable limit prior to shipment, and the shipment of tie package in-_
an open transport exclusive use vehicle with external radiation levels exceeding the '
allowable limit. l CECO's response is provided Ir; the attachment.
If your staff has any questions or comments concerning this transmittal, please refer them to Jim Watson, Compliance Engineer at (708) 515-7205.
Sincerely, _
khbww.V[vr T.J. Kovach Nuclear Licensing Manager
- Attachment cc:
A.B. Davis, Regional Administrator - Region ill L. Olshan, Project Manager, NRR T. Taylor, Senior Resident inspector
- TJK/cah ZNLD/2228/1
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RESPOPE TO NOTICE OF VKX_ATION NHC NSPECTION REPORT
'50-254/92020;50-265/92020 N'lOLATION: (254(265)/92020 01) 10 CFR 71.5(a) requires that licensees, who transport licensed material outside the confines of their plants or deliver licensed material to a carrier for transport, comply with the applicable requirements of the regulations appropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Part 170 189.
A.
49 CFR 173.475 requires, in part, that before each shipment of any radioactive materials package, the shipper ensure by examination or appropriate tests that ;
external radiation levels are within allowable limits.
Contrary to the above, on July 16,1992, a package containing radioactive materials (a contaminated shear cutter) was shipped withou'. the shipper ensuring by appropriate surveys that external radiation levels were within allowable limits.
Specifically, the departure survey conducted on July 16,- 1992, f a: led to identify external radiation levels of 200 to 1500 millirem per hour on the surface of the package which exceeded the 200 millirem per hour allowable limit for an open -
transport exclusive use venicle shipment.
B.
49 CFR 173.441 requires, in part, that each package of radioactive mt.terials offered for transportation in an open transport exclusive ute vehicle shall be' designed and prepared for shipment so that under conditions normally incident to transportation the radiation level does not exceed 200 m!!Ilrem per hour at any e
point on the external surface of the package.
Contrary to the above, o.n July 16,1992, a package containing radioactive in an open transport exclusive use veh)cle with external radiation levels from i
to 1500 millirem por hour on the surface of the package.
This is a Severity Level lli problem (Supplement V).
BEASONfDRJ1QLATJON CECO acknowledges the violation. Due to an iriadequate survey performed on the package, an Exclusive Use Radioactive LSA Shipment departed Quad Cities Nuclear Station with dose rates on contact with the package in excess of Department of L
Transportation (DOT) limits.
On July 20,1992, the shipment sent from Quad Cities Nuclear Station arrived at Millstone Nuclear Station. The arrival survey on the package found dose rates on l contact with the package in excess of DOT limits. The safety significance of this issue was minimal because the configuration of the shipment was such that the radiation levels for the normally occupied space of the vehicle were below DOT limits. In addition, all areas routinely accessible to personnel working around the shipment would not have dose rates in excess of DOT limits.
- 2NLDl2228/2
l RESPONSE TO NOTICE OF VIOLATION 4
NRC INSPECTION REPORT.
.y' 254/92020;50-265/92020
- )
'l COBBEGILVESTEPS TAKENANDEESULISACBIEVED:
- Personnel involved were counselled with respect to their performance in not meeting management's expectations.- Emphasis was placed on the conduct of thorough i
surveys,- documentation of survey results, the need to take additional action when
. observing a radiological condition which could lead to a DOT violation, and
.i communications.
Radiation Protection Management monitored the performance of the Radiation Protection Technicians involved in this incident during their next assignment to a shipping evolution. These overviews were cornpleted on October 12,1992 with each Technician's performance viewed as adequate.
Appropriate disciplinary action was taken.
COJ3BEGIIVE STEP _lBALWlU BE TAKENTO AVO_lD FURTilER VIOLATIONS:
Procedure ORP 1520-2, " Surveying Radioactive Material Shipments," has been revised:
ltems being prepared for shipment with contact dose rates greater than 100 mR/hr will be documented on a survey indicating the items location in the package. These surveys will be forwarded to Radiation Protection Management who will review the documentation for conditions that could contribute to potentially exceeding DOT requirements.
Precautions have been added to emphasize proper orientation or shleiding of hot spots.
When packages are being loaded onto a shipping truck, the bottom surface of the package will be surveyed prior to placement on the truck.
Training on these changes has t een provided to Radiation Protection Department personnel.
DAi.EEHENfULL COMPLIANCEEU.BEACHIEYED; Full compliance was achieved on October 12,1992 with the monitoring of the Radiation '
Protection Technician involved performance on a radioactive shipment survey.
ZNLD/2228/3
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